Wilmington Savings Fund Society, FSB v. Kattula

CourtDistrict Court, E.D. Michigan
DecidedAugust 12, 2025
Docket5:16-cv-12813
StatusUnknown

This text of Wilmington Savings Fund Society, FSB v. Kattula (Wilmington Savings Fund Society, FSB v. Kattula) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Wilmington Savings Fund Society, FSB v. Kattula, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Wilmington Savings Fund Society, FSB, Case No. 16-cv-12813 Plaintiff, Judith E. Levy v. United States District Judge

Maria C. Kattula, Robert Kattula, Mag. Judge Anthony P. Patti Maria C. Kattula Living Trust Dated 10-23-95, TAJ Graphics Enterprises, LLC, United States of America, and Green Lake Equities, LLC,

Defendants.

________________________________/

ORDER DENYING PLAINTIFF’S MOTION FOR RELIEF FROM JUDGMENT [72] AND GRANTING DEFENDANT UNITED STATES OF AMERICA’S MOTION TO BE DISMISSED AS A DEFENDANT [76]

Before the Court are Plaintiff Wilmington Savings Fund Society, FSB’s motion for relief from judgment1 (ECF No. 72) and Defendant

1 Defendant United States of America asserts in its response to Plaintiff’s motion for relief from judgment that the motion “was not filed in compliance with L.R. 7.1(a), as Plaintiff’s counsel did not confer with counsel for the United States prior to filing the motion.” (ECF No. 74, PageID.1338 n.1.) Plaintiff’s motion is in violation of Local Rule 7.1(a) due to the failure to confer and because the motion does United States of America’s motion to be dismissed as a Defendant. (ECF No. 76.) The United States responded to Plaintiff’s motion2 (ECF No. 74),

and Plaintiff replied. (ECF No. 75.) No party responded to the United States’ motion. For the reasons set forth below, Plaintiff’s motion is

denied, and the United States’ motion is granted.

not contain a statement on concurrence. See E.D. Mich. LR 7.1(a). Plaintiff did not remedy this defect even after it was identified by the United States. Under Local Rule 7.1(a)(3), the Court “may impose sanctions . . . for violating this rule, which may include taxing costs and attorney’s fees, denying the motion, and striking the filing.” E.D. Mich. LR 7.1(a)(3). The Court will not impose sanctions at this time. But Plaintiff is warned about the possibility of sanctions if it does not comply with Local Rule 7.1(a) in the future.

2 After the United States filed its motion to be dismissed as a Defendant (ECF No. 76), Defendants Maria C. Kattula, Robert Kattula, and Maria C. Kattula Living Trust Dated 10-23-95 filed a response to Plaintiff’s motion for relief from judgment “in light of the United States of America’s motion.” (ECF No. 77 at PageID.1372.) The Kattula Defendants indicate in their response that they “had been relying on” the United States’ response to Plaintiff’s motion (ECF No. 74), “which presumably will be deemed withdrawn once the United States is allowed to withdraw.” (ECF No. 77, PageID.1372.) As Plaintiff notes, the Kattula Defendants’ “brief is almost identical to the response brief filed by the United States.” (ECF No. 79, PageID.1393.) Defendant Green Lake Equities, LLC filed a separate response (ECF No. 78) stating that it concurs with the Kattula Defendants’ response. Plaintiff argues that the responses filed by the Kattula Defendants and Green Lake Equities, LLC are untimely, and therefore, the Court should not consider them. (ECF No. 79.) The Court considers the United States’ response in resolving Plaintiff’s motion, given that the United States has not yet been dismissed from the case. As a result, it is unnecessary for the Court to consider the other responses. Even if it did, the Court’s decision on Plaintiff’s motion would be the same. I. Plaintiff’s Motion for Relief from Judgment (ECF No. 72) Plaintiff filed its motion for relief from judgment under Federal

Rule of Civil Procedure 60(b)(1). Plaintiff asks that the Court “(1) set aside the portion of the judgment dismissing [Plaintiff’s] declaratory judgment count on the merits and (2) order supplemental briefing on the

merits of [Plaintiff’s] declaratory judgment count.” (ECF No. 72, PageID.1329; ECF No. 75, PageID.1363.) The United States opposes the

motion. (ECF No. 74.) Rule 60(b)(1) provides: “On motion and just terms, the court may relieve a party or its legal representative from a final judgment, order, or

proceeding” due to “mistake, inadvertence, surprise, or excusable neglect.” Fed. R. Civ. P. 60(b)(1). “[A] motion for relief from a judgment under Rule 60(b) is addressed to the discretion of the court.” 11 Charles

Alan Wright et al., Fed. Prac. & Proc. Civ. § 2857 (3d ed. 2025); FHC Equities, L.L.C. v. MBL Life Assur. Corp., 188 F.3d 678, 683 (6th Cir. 1999) (“It is well settled that the [ruling on] a motion to set aside

judgment under Rule 60(b)(1) is a matter addressed to the sound discretion of the trial court.” (alteration in original) (quoting Lewis v. Alexander, 987 F.2d 392, 396 (6th Cir. 1993))). “A district court’s denial of a Rule 60(b)(1) motion is reviewed for abuse of discretion.” Williams v. Meyer, 346 F.3d 607, 613 (6th Cir. 2003) (citing United Coin Meter Co. v.

Seaboard Coastline R.R., 705 F.2d 839, 843 (6th Cir. 1983)). Plaintiff argues that it is entitled to relief under Rule 60(b)(1) based on its mistake, inadvertence, or excusable neglect in failing to brief the merits of its declaratory judgment count [in its post-remand supplemental brief]. Fed. R. Civ. P. 60(b)(1) allows this Court to fix this very error. [Plaintiff] mistakenly understood this Court’s order as requesting briefing on jurisdiction, alone. Based on the language of the order, as well as the Sixth Circuit’s opinion indicating that this Court would first have to confirm jurisdiction before a determination on the merits, [Plaintiff] believed it would have the opportunity to litigate the merits of the declaratory judgment count at a later point. That mistake was excusable. (ECF No. 72, PageID.1319–1320; see id. at PageID.1321–1323.) The Sixth Circuit has stated that [i]n deciding whether relief [under Rule 60(b)(1)] is warranted, three factors are relevant: (1) whether the party seeking relief is culpable; (2) whether the party opposing relief will be prejudiced; and (3) whether the party seeking relief has a meritorious claim or defense. [United Coin Meter, 705 F.2d at 845]. Culpability is “framed” by the specific language of the rule; i.e., a party demonstrates a lack of culpability by demonstrating “mistake, inadvertence, surprise, or excusable neglect.” Waifersong, Ltd. v. Classic Music Vending, 976 F.2d 290, 292 (6th Cir. 1992). And because Rule 60(b)(1) “mandates” such a demonstration, “[i]t is only when the [party seeking relief] can carry this burden that he will be permitted to demonstrate that he also can satisfy the other two factors: the existence of a meritorious defense and the absence of substantial prejudice to the [other party].”3 Id.; see also Weiss v. St. Paul Fire & Marine Ins. Co., 283 F.3d 790, 794 (6th Cir. 2002) (a party seeking relief “must demonstrate first and foremost that the default did not result from his culpable conduct”). Williams, 346 F.3d at 612–13 (first three alterations added). “Rule 60(b) does not afford defeated litigants a second chance to convince the court

3 In its motion, Plaintiff argues that the three factors listed above apply.

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