Victor Abraham v. City of New York, et al.

CourtDistrict Court, E.D. New York
DecidedApril 29, 2026
Docket1:22-cv-01162
StatusUnknown

This text of Victor Abraham v. City of New York, et al. (Victor Abraham v. City of New York, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Victor Abraham v. City of New York, et al., (E.D.N.Y. 2026).

Opinion

United States District Court Eastern District of New York

-----------------------------------X

Victor Abraham,

Plaintiff, Memorandum and Order

- against - No. 22-cv-1162 (KAM) (RML)

City of New York, et al.

Defendants.

Kiyo A. Matsumoto, United States District Judge:

Pending before the Court is Plaintiff Victor Abraham’s objection to Magistrate Judge Levy’s April 21, 2026 Order denying his motion to reopen discovery to conduct the depositions of witnesses he submits are “material” to his case: Samuel Howard, Alex LaPierre, Alex LaPierre’s father, and former Assistant District Attorney Michael Tannousis. (See ECF No. 146.) For the reasons that follow, the Court affirms Judge Levy's order in all respects. Relevant Factual Background Plaintiff Victor Abraham commenced this 42 U.S.C. § 1983 action on March 3, 2022 alleging that Defendants City of New York, Steven Lutz, Steven Zielinski, and Jennifer Hamilton deprived him of his constitutional rights when he was prosecuted and held at Rikers Island for approximately one year based on photo arrays that a state court judge has since found were unduly suggestive. (See generally ECF No. 1, “Compl.”.) The witnesses Mr. Abraham seeks to depose feature centrally in the underlying state court proceedings: Mr. Samuel Howard and Mr. Alex LaPierre were complaining witnesses in two separate robberies on October 9, 2016 and October 27, 2016. (See id. ¶¶ 14, 34; ECF No. 96, “Am. Compl.”

¶ 3.) Both independently identified Mr. Abraham as the assailant through the faulty photo identification methods. (See Compl. ¶¶ 34, 50; Am. Compl. ¶¶ 115-118.) Mr. LaPierre’s father was reportedly on the scene and canvassed the area after Mr. LaPierre reported the robbery. (Am. Compl. ¶ 196.) Mr. Michael Tannousis is the Assistant District Attorney who prosecuted the case against Mr. Abraham. (See id. ¶ 273.) As is relevant to Mr. Abraham’s instant objection, discovery began around May 16, 2023, and was originally set to conclude by September 13, 2023. (May 16, 2023 Minute Entry (approving case management plan).) Mr. Abraham filed an Amended Complaint on December 13, 2024. (See ECF No. 96.) The discovery deadline in

this action was extended no less than ten times, and the discovery process was ultimately certified as complete on February 11, 2026. (See Sept. 11, 2023 Order (granting extension to November 15, 2023); Feb. 11, 2026 Order (certifying close of discovery).) Over the period of time between May 16, 2023 and February 11, 2026, Mr. Abraham had at least three attorneys, all of whom had had ample opportunity to depose these witnesses, yet had not, in part due to the fact that certain witnesses could not be located. (See Apr. 21 Tr. 4:19-5:7.) In between representation by counsel, Mr. Abraham also represented himself pro se. (See, e.g., ECF No. 67; July 3, 2024 Minute Entry). Despite multiple warnings from Judge Levy that discovery deadlines would be "final," including when the

deadline was extended to April 18, 2025, July 17, 2025, October 20, 2025, and December 8, 2025, Mr. Abraham and his counsel continued to choose not to depose these witnesses. Judge Levy has been particularly accommodating in extending the discovery deadline to allow Mr. Abraham and his counsel to depose Mr. Howard and Mr. Tannousis. In particular, the discovery deadline was extended from October 20, 2025 to December 8, 2025 in order to accommodate Mr. Howard's and Mr. Tannousis's depositions, the former of which had been scheduled for October 21, 2025 on Zoom. (See ECF No. 104.) Yet, by January 22, 2026, neither the Howard nor Tannousis depositions had been taken, and -- Defendants contend -- subpoenas had still not been issued despite Mr.

Abraham's representation that he had been in contact with Mr. Howard. (See id.; ECF No. 113 at 2.) Judge Levy granted an additional extension for the sole purpose of allowing Mr. Abraham’s counsel to take Mr. Howard’s deposition on January 22, 2026. (Jan. 22, 2026 Minute Entry.) On February 11, 2026, Mr. Abraham's counsel represented that Mr. Howard could not be contacted by him, a private investigator he had hired, or Mr. Welton Wisham, who was Mr. Abraham's counsel from October 28, 2024 to December 2, 2025. (Feb. 10, 2026 Tr. 4:19-5:7.) Based on that representation, and without further statement or objection from Mr. Abraham, Judge Levy closed discovery, correctly concluding that discovery cannot be held open indefinitely just because Mr. Howard could no longer

be found. (Id. 5:10-18.) At that same hearing, with the consent of Mr. Abraham, Mr. Abraham’s counsel also withdrew from the case, citing a "breakdown" in the client relationship because Mr. Abraham refused to speak with him. (Id. 10:16; 11:11-23; 15:20-21.) On April 17, 2026, Mr. Abraham, who has proceeded pro se since February 10, 2026, moved to reopen discovery so he could take the depositions of Mr. Howard, Mr. LaPierre, Mr. LaPierre’s father, and Mr. Tannousis. (ECF No. 146.) Judge Levy denied the motion on April 22, 2026, though he also expressed willingness to grant a request to reopen discovery for "a brief period" to allow Mr. Abraham to obtain "affidavits from witnesses, including witnesses who have not been deposed." (Apr. 22, 2026 Minute Entry; Apr. 21,

2026 Tr. at 13:18-21; 19:22-24; 16:17-19.) Subsequently, on April 22, 2026, Mr. Abraham filed an objection to Judge Levy’s denial of his motion to reopen discovery. (ECF No. 147.) Legal Standard & Discussion This Court's review of a magistrate judge's order pertaining to "pretrial matter[s] not dispositive of a party's claim or defense" is governed by Federal Rule of Civil Procedure 72(a). Pursuant to that rule, the Court may "modify" or "set aside" an order only if it is "clearly erroneous" or "contrary to law." Fed. R. Civ. P. 72(a); see also United States v. Town of Oyster Bay, 2022 WL 4485154, at *2 (E.D.N.Y. Sept. 27, 2022) (district judge may not "disturb[]" magistrate judge order "absent a determination

that such findings were 'clearly erroneous or contrary to law'"). An order is "clearly erroneous" when, "based on all the evidence, a reviewing court 'is left with the definite and firm conviction that a mistake has been committed." McKnight as Tr. of Stacia L. McKnight Rev. Tr. v. 65 Dune Rd. LLC, 2024 WL 3937541, at *3 (E.D.N.Y. Aug. 26, 2024) (quoting Ark. Tchr. Ret. Sys. v. Goldman Sachs Grp., Inc., 77 F.4th 74, 90 (2d Cir. 2023)). An order is "'contrary to law' when it fails to apply or misapplies relevant statutes, case law, or rules of procedure." Galloway v. Cnty. of Nassau, 589 F. Supp. 3d 271, 277 (E.D.N.Y. 2022). Magistrate judges "are afforded broad discretion in resolving discovery disputes," and "reversal[s]" of their orders are

appropriate "only if that discretion is abused." Almakalani v. McAleenan, 527 F. Supp. 3d 205, 219 (E.D.N.Y. 2021). Under this highly deferential standard, "an application to reopen discovery should be denied where the moving party has not persuaded th[e] Court that it was impossible to complete the discovery by the established deadline." Baburam v. Fed. Express Corp., 318 F.R.D. 5, 8 (E.D.N.Y. 2016) (internal quotations omitted) (collecting cases). Pursuant to those principles, the Court finds that Judge Levy's order denying Mr. Abraham's motion to reopen discovery was neither "clearly erroneous" or "contrary to law." See Fed. R. Civ. P 72(a).

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Related

Baburam v. Federal Express Corp.
318 F.R.D. 5 (E.D. New York, 2016)
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