JAMES L. COTT, Magistrate Judge.
Petitioners Trustees of the New York City District Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund, and Apprenticeship, Journeyman Retraining, Educational and Industry Fund; Trustees of the New York City District Council of Carpenters Relief and Charity Fund; the New York City and Vicinity Carpenters Labor-Management Corporation; and New York City District Council of Carpenters ("Petitioners") filed a petition to confirm an arbitration award on February 13, 2017. Respondent Golden Development and Construction Corp. ("Respondent") has not opposed the petition or otherwise appeared in this action. For the reasons set forth below, I recommend that the Court confirm the arbitration award, and, as modified, grant Petitioners' application for attorneys' fees and costs.
Petitioners consist of four different parties: First, the Trustees of the New York City District Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund, and Apprenticeship, Journeyman Retraining, Educational and Industry Fund ("the ERISA Funds") are "trustees of multiemployer labor-management trust funds" that are operated in accordance with the Employee Retirement Income Security Act of 1974 ("ERISA"). Petition to Confirm an Arbitration Award ("Pet.") (Dkt. No. 1) ¶ 4. Second, the Trustees of the New York City District Council of Carpenters Relief and Charity Fund ("the Charity Fund") are trustees of a charitable organization. Id. ¶ 5. Third, the New York City and Vicinity Carpenters Labor-Management Corporation is a not-for-profit corporation that, together with the ERISA Funds and the Charity Fund, make up "the Funds." Id. ¶ 6. Finally, the New York City District Council of Carpenters ("the Union") is a labor organization and the "certified bargaining representative" for some of Respondent's employees. Id. ¶ 7. Respondent is a corporation that incorporated under the laws of New York. Id. ¶ 8.
On or about August 15, 2007, Respondent and the Union executed a collective bargaining agreement. Id. ¶ 9; see also Independent Building Construction Agreement ("CBA") (Dkt. No. 1, Ex. A) at 63.
If a dispute arises between the Union and Respondent regarding payments to the Funds, the CBA permits either party to seek arbitration of the dispute. Pet. ¶ 13; see also CBA at 44-45. If a party initiates arbitration proceedings and "if such arbitrator renders an award in favor of [the Funds], the arbitrator shall be empowered to award such interest, liquidated damages, and/or costs as may be applicable." CBA at 44. Further, if the Funds initiate court proceedings against Respondent and the court renders a judgment favorable to the Funds, Respondent is obligated to pay, "in accordance with the judgement of the court," unpaid contributions plus interest, an amount equal to the greater of the interest charge on unpaid contributions or 20 percent of the unpaid contributions, reasonable attorney's fees and costs, and any other relief that the court deems appropriate. CBA at 43-44. Finally, the CBA also binds Respondent to the Funds Collection Policy, Pet. ¶ 15, which sets out the policies and procedures for the collection of employer contributions to the Funds. (Dkt. No. 1, Ex. D).
An audit of Respondent's records for the period of April 1, 2012 to March 24, 2015 revealed that Respondent had failed to contribute to the Funds in the principal amount of $42,802.60. Pet. ¶ 17. In response, Petitioners initiated arbitration proceedings and sent notice of the hearing to Respondent. Id. ¶ 18. The arbitrator conducted a hearing on December 2, 2016, and found Respondent to be in default when it did not appear. Opinion and Default Award of Arbitrator ("Award") (Dkt. No. 1, Ex. E) at 1-2. At the hearing, the arbitrator reviewed the terms of the CBA and took testimony from the auditor about the process of the audit and its results. Id. at 2. On December 5, 2016, the arbitrator issued an opinion finding Respondent delinquent in contributing to the Funds as required by the CBA. Id. Accordingly, the arbitrator determined that Respondent was obligated to pay an award of $108,808.41 to the Funds, with interest to accrue at a rate of five and a half percent from the date of the award. Id. at 3. That total was made up of the principal sum of delinquent contributions in the amount of $42,802.60, total interest thereon of $7,413.99, liquidated damages thereon of $8,675.84, non-audit late payment interest of $508.25, assessments to the promotional fund of $81.20, additional shortage-principal in the amount of $33,126.59, additional interest thereon of $2,058.07, liquidated damages thereon of $6,625.32, court costs of $400.00, attorneys' fees of $1,500.00, arbitrator's fee of $500.00, and audit costs of $5,116.55. Id.; see also Pet. ¶ 20. This award has not been vacated or modified, and no application for such relief is pending. Pet. ¶ 23.
Petitioners report that Respondent has failed to pay any portion of the award. Id. ¶ 22. Consequently, Petitioners initiated this action on February 13, 2017, by filing a petition to confirm arbitration. Petitioners bring this action under section 502(a)(3) of ERISA, as amended at 29 U.S.C. § 1132(a)(3); section 301 of the Labor Management Relations Act of 1947 ("LMRA"), as amended at 29 U.S.C. § 185; and section 9 of the Federal Arbitration Act ("FAA"), 9 U.S.C. § 9. Id. ¶ 1. Although Respondent was served with the petition it did not respond. Accordingly, the Court directed Respondent to answer the petition by April 21, 2017, or its failure to contest the petition would "weigh against it." Order, dated Apr. 4, 2017 (citing D.H. Blair & Co. v. Gottdiener, 462 F.3d 95, 109 (2d Cir.2006)) (Dkt. No. 8). As of the date of this Report, Respondent has not responded to the petition or appeared in this action.
As an initial matter, Petitioners have brought this action under ERISA, the LMRA, and the FAA. However, "[b]ecause this dispute involves the assertion of rights under a collective bargaining agreement," the Court should only consider this petition pursuant to section 301 of the LMRA. Nat'l Football League Mgmt. Council v. Nat'l Football League Players Ass'n, 820 F.3d 527, 536 (2d Cir. 2016); see also, e.g., Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund v. Formula 1 Builders, LLC, No. 17-CV-1234 (GHW), 2017 WL 1483369, at *1 n.1 (S.D.N.Y. Apr. 25, 2017). The Second Circuit has held that "an action to confirm an arbitration award is not an appropriate vehicle for adjudication of ERISA claims for damages." Ottley v. Schwartzberg, 819 F.2d 373, 377 (2d Cir. 1987); see also, e.g., N.Y.C. Dist. Council of Carpenters Pension Fund v. E. Millenium Constr., Inc., No. 03-CV-5122 (DAB), 2003 WL 22773355, at *1 n.1 (S.D.N.Y. Nov. 21, 2003). Likewise, because "the substantive law fashioned under § 301 is `analytically distinct' from the provisions of the FAA . . . the FAA is no longer applicable to actions to enforce arbitration awards brought pursuant to § 301 of the LMRA." Westerbeke Corp. v. Daihatsu Motor Co., 304 F.3d 200, 222 (2d Cir. 2002) (quoting Coca-Cola Bottling Co. of N.Y. v. Soft Drink & Brewery Workers Union Local 812 Int'l Bhd. of Teamsters, 242 F.3d 52, 54 (2d Cir. 2001)); see, e.g., Neshgold LP v. N.Y. Hotel & Motel Trades Council, AFL-CIO, No. 13-CV-2399 (KPF), 2013 WL 5298332, at *4 (S.D.N.Y. Sept. 19, 2013) (noting the FAA "does not apply of its own force to contracts of employment of workers engaged in foreign or interstate commerce") (internal quotation marks and alterations omitted).
"The LMRA embodies a `clear preference for the private resolution of labor disputes without government intervention.'" Nat'l Football League, 820 F.3d at 536 (quoting Int'l Bhd. of Elec. Workers v. Niagara Mohawk Power Corp., 143 F.3d 704, 714 (2d Cir. 1998)). Accordingly, "a federal court's review of labor arbitration awards is narrowly circumscribed and highly deferential — indeed, among the most deferential in the law." Id. at 532. The court "must simply ensure that the arbitrator was `even arguably construing or applying the contract and acting within the scope of his authority' and did not `ignore the plain language of the contract.'" Id. (quoting United Paperworks Int'l Union v. Misco, Inc., 484 U.S. 29, 38 (1987)). "As long as the award draws its essence from the collective bargaining agreement and is not merely the arbitrator's own brand of industrial justice, it must be confirmed." Id. at 537 (internal quotation marks omitted).
"Conversely, a court should vacate an award if it `contradicts an express and unambiguous term of the contract or . . . so far departs from the terms of the agreement that it is not even arguably derived from the contract. . . .'" N.Y.C. & Vicinity Dist. Council of United Bhd. of Carpenters & Joiners of Am. v. Ass'n of Wall-Ceiling & Carpentry Indus. of N.Y., Inc., 826 F.3d 611, 618 (2d Cir. 2016) (quoting United Bhd. of Carpenters v. Tappan Zee Constructors, LLC, 804 F.3d 270, 275 (2d Cir. 2015)). Although the FAA does not apply to arbitrations conducted pursuant to the LMRA, "courts have often consulted the FAA `for guidance in labor arbitration cases,' especially given the grant of authority under the LMRA to `fashion rules of federal common law to govern' suits for violations of collective bargaining agreements." Neshgold, 2013 WL 5298332, at *4 (quoting Misco, 484 U.S. at 40 n.9).
Additionally, when a petition to confirm an arbitration award is unanswered, the "petition and accompanying record should [be] treated as akin to a motion for summary judgment based on the movant's submissions." D.H. Blair, 462 F.3d at 109. The moving party bears the burden of showing the court "that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). Thus, as with a motion for summary judgment, "[e]ven unopposed motions . . . must `fail where the undisputed facts fail to show that the moving party is entitled to judgment as a matter of law.'" D.H. Blair, 462 F.3d at 110 (quoting Vt. Teddy Bear Co. v. 1-800 Beargram Co., 373 F.3d 241, 244 (2d Cir. 2004)).
Respondent has not challenged the arbitration award or otherwise appeared in this action, so the petition to confirm the arbitration award is unopposed. Petitioners, meanwhile, have submitted undisputed evidence to the Court that arbitration was appropriate in this case and that the arbitrator acted within the scope of his authority. Further, the amount of the award is uncontested. Accordingly, the Court should confirm the arbitrator's award. See, e.g., Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund v. Jessica Rose Enter. Corp., No. 15-CV-9040 (RA), 2016 WL 6952345, at *3-4 (S.D.N.Y. Nov. 28, 2016).
First, arbitration was appropriate in this matter, as evidenced by Petitioner's submissions. The CBA, which was executed by both the Union and Respondent, provides that, "[s]hould any dispute or disagreement arise between the parties hereto . . . concerning any claim arising from payments to the Fund of principal and/or interest which is allegedly due, either party may seek arbitration of the dispute before the impartial arbitrator designated hereunder." CBA at 44-45. As the audit indicated that Respondent had not been contributing to the Funds, the CBA permitted Petitioners to initiate arbitration proceedings.
The terms of the CBA also confirm that the arbitrator did not go beyond his authority — particularly because his authority was quite broad. The CBA states that the arbitrator would have "full and complete authority to decide any and all issues raised by the [party's] submission and to fashion an appropriate remedy including, but not limited to, monetary damages." CBA at 45. It was thus within the arbitrator's authority to review Petitioners' allegations that Respondent had breached the terms of the CBA, and to award damages to Petitioners as a result. Additionally, the categories of monetary damages awarded to Petitioners by the arbitrator generally correspond to categories described by the CBA. Both include unpaid contributions, interest on those contributions, liquidated damages, and attorney's fees and costs associated with the action. Compare CBA at 44 with Award at 3. The arbitrator's award was therefore "`plausibly grounded in the parties' agreement,' which is all the law requires." Nat'l Football League, 820 F.3d at 539 (quoting Wackenhut Corp. v. Amalgamated Local 515, 126 F.3d 29, 32 (2d Cir. 1997)).
Finally, the arbitrator's final award has not been contested by Respondent, despite multiple opportunities to do so. The arbitrator noted that Respondent had been notified of the audit and the calculation of its delinquencies, but did not comply with Petitioners' demand for payment. Award at 2. At the hearing, the arbitrator was presented with relevant evidence in support of the award amount, such as the CBA and the auditor's testimony. Id. Despite having notice of the hearing, Respondent did not participate and therefore did not contest the evidence introduced by Petitioners in support of the award. Id. at 1-2. Respondent has also declined to appear in proceedings before this Court, despite the Court's admonition that failure to appear would weigh against it.
Because Respondent declined to contest the information submitted to the arbitrator or the final award, Petitioners' evidence that the arbitrator "was, at the very least, `arguably construing or applying the contract,'" is uncontested. Nat'l Football League, 820 F.3d at 547 (quoting Misco, 484 U.S. at 38); see also Jessica Rose, 2016 WL 6952345, at *3 ("No evidence suggests that this amount is incorrect. Nor is there any evidence suggesting that the auditor's accounting methods are not sound."). Petitioners have thus demonstrated that there are no genuine disputes of material fact as to whether they are entitled to confirmation of the arbitration award. Accordingly, the Court should confirm the arbitration award.
Petitioners also seek to recover attorneys' fees and costs associated with this action. "`[I]n a federal action, attorney's fees cannot be recovered by the successful party in the absence of statutory authority for the award.'" Abondolo v. Jerry WWHS Co., 829 F.Supp.2d 120, 130 (E.D.N.Y. 2011) (quoting Int'l Chem. Workers Union (AFL-CIO), Local No. 227 v. BASF Wyandotte Corp., 774 F.2d 43, 47 (2d Cir. 1985)). "Section 301 of the [LMRA] does not provide for attorney's fees in actions to confirm and enforce an arbitrator's award." Int'l Chem. Workers, 774 F.2d at 47. "Pursuant to its inherent equitable powers, however, a court may award attorney's fees when the opposing counsel acts `in bad faith, vexatiously, wantonly, or for oppressive reasons.'" Id. (quoting F.D. Rich Co. v. United States ex rel. Indus. Lumber Co., 417 U.S. 116, 129 (1974)); see also Adkins v. Gen. Motors Acceptance Corp., 363 F. App'x 97, 99 (2d Cir. 2010). "In the context of a petition to confirm an arbitration award, an award of attorney's fees is permissible where `the party challenging the award has refuse[d] to abide by an arbitrator's decision without justification.'" Jessica Rose, 2016 WL 6952345, at *4 (quoting First Nat'l Supermarkets, Inc. v. Retail, Wholesale & Chain Store Food Emp. Union Local 338, 118 F.3d 892, 898 (2d Cir. 1997)) (collecting cases).
Here, Respondent agreed to the CBA, which permits either party to initiate binding arbitration. CBA at 43-45. Respondent did not participate in the arbitration proceedings, it has not satisfied the arbitrator's award, and further, it has not appeared in these proceedings. By declining to oppose the petition to confirm the arbitration award, Respondent has not provided the Court with any justification for its failure to oppose the arbitration proceedings or to abide by the award that resulted. Courts routinely award attorneys' fees and costs to petitioners in such circumstances. See, e.g., N.Y.C. & Vicinity Dist. Council of Carpenters v. Plaza Constr. Grp., Inc., No. 16-CV-1115 (GHW), 2016 WL 3951187, at *1 (S.D.N.Y. July 19, 2016); Trustees of N.Y.C. Dist. Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund, Apprenticeship, Journeyman Retraining, Educ. & Indus. Fund, Charity Fund v. Dedicated Indus. LLC, No. 14-CV-7610 (RA), 2015 WL 4503695, at *5 (S.D.N.Y. July 23, 2015) ("[C]ourts in this District `have routinely awarded attorneys fees in cases where a party merely refuses to abide by an arbitrator's award without challenging or seeking to vacate it through a motion to the court.'") (quoting Abondolo v. H. & M.S. Meat Corp., No. 07-CV-3870 (RJS), 2008 WL 2047612, at *4 (S.D.N.Y. May 12, 2008)). Accordingly, attorneys' fees are appropriate here, as well.
"The party seeking fees bears the burden of demonstrating that its requested fees are reasonable." 1199/SEIU United Healthcare Workers E. v. S. Bronx Mental Health Council Inc., No. 13-CV-2608 (JGK), 2014 WL 840965, at *10 (S.D.N.Y. Mar. 4, 2014) (citing Blum v. Stenson, 465 U.S. 886, 897 (1984)). Although courts may exercise discretion in determining what constitutes reasonable attorneys' fees, "the lodestar — the product of a reasonable hourly rate and the reasonable number of hours required by the case — creates a `presumptively reasonable fee.'" Millea v. Metro-N. R. Co., 658 F.3d 154, 166 (2d Cir. 2011) (quoting Arbor Hill Concerned Citizens Neighborhood Assoc. v. Cnty. of Albany, 522 F.3d 182, 183 (2d Cir. 2008)). "The reasonableness of hourly rates are guided by the market rate `[p]revailing in the community for similar services by lawyers of reasonably comparable skill, experience and reputation.'" Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund v. Installations of Am., Inc., No. 15-CV-8316 (PAE), 2017 WL 384694, at *5 (S.D.N.Y. Jan. 27, 2017) (quoting Blum, 465 U.S. at 895 n.11). As evidence that the number of attorney hours are reasonable, "the fee application must be supported by contemporaneous time records that `specify, for each attorney, the date, the hours expended, and the nature of the work done.'" 1199/SEIU United, 2014 WL 840965, at *10 (quoting N.Y. State Ass'n for Retarded Children v. Carey, 711 F.2d 1136, 1148 (2d Cir. 1983)).
Petitioners request $710.00 in total attorneys' fees and $70.00 in service fees. Pet. ¶¶ 31-32. The attorneys' fees are the result of 5.70 hours of work, distributed between two members of Virginia & Ambinder, LLP ("V&A"), the firm representing Petitioners. Id. ¶¶ 26, 31; see also Virginia & Ambinder, LLP's Invoice ("Invoice") (Dkt. No. 1, Ex. G) at 2. Todd Dickerson, "Of Counsel," to V&A, is a 2013 graduate of the University of Illinois College of Law, who joined the firm as an associate in November 2015. Pet. ¶ 27. Joel Goldenberg is a third-year law student at Brooklyn Law School, and a legal assistant at V&A. Id. ¶ 28. Dickerson completed 0.70 hours of work and billed at a rate of $300 per hour, while Goldenberg completed 5.0 hours of work, and billed at a rate of $100 per hour. Id. ¶¶ 27, 29; see also Invoice. In support of their request, Petitioners have submitted hourly billing records describing the work Dickerson and Goldenberg completed. See Invoice.
V&A's billing records are sufficiently detailed to demonstrate that their work was not "excessive, redundant, or otherwise unnecessary." Plaza Constr. Grp., 2016 WL 3951187, at *2 ("Hours that are excessive, redundant, or otherwise unnecessary, are to be excluded from the calculation of a reasonable fee.") (internal quotation marks omitted). Additionally, the $100 per hour for the legal assistant is reasonable, particularly because "the legal assistant drafted papers that, at least in part, might otherwise have been prepared by an attorney." Trustees of N.Y.C. Dist. Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund, & Apprenticeship, Journeyman Retraining Educ. & Indus. Fund v. Premium Sys., Inc., No. 12-CV-1749 (LAK) (JLC), 2012 WL 3578849, at *6 (S.D.N.Y. Aug. 20, 2012) (finding $90 per hour rate for legal assistant reasonable); see also Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund v. Coastal Envtl. Grp., Inc., No. 16-CV-6004 (GHW), 2016 WL 7335672, at *4 (S.D.N.Y. Dec. 16, 2016) (finding $100 per hour rate for paralegals reasonable).
However, $300 per hour for an attorney who has been practicing for less than four years is unreasonable, and outside the realm of what has been approved by courts in this District, including in other cases involving V&A. See Trustees of N.Y.C. Dist. Council of Carpenters Pension Fund, Welfare Fund, Annuity Fund & Apprenticeship, Journeyman Retraining, Educ. & Indus. Fund v. Dependable Office Installation LLC, No. 14-CV-9502 (JGK) (HBP), 2017 WL 934713, at *8 (S.D.N.Y. Mar. 9, 2017) (approving fee award "based on hourly rates ranging from $225 per hour for [V&A] associates [who graduated law school between 2007 and 2014] to $300 per hour for the one partner"), adopted sub nom. Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund v. Dependable Office Installation, LLC, 2017 WL 1157118 (S.D.N.Y. Mar. 27, 2017); Trustees of the N.Y.C. Dist. Council of Carpenters Pension Fund v. NYC Constr. Serv. Inc., No. 15-CV-3813 (GHW), 2016 WL 894551, at *3 (S.D.N.Y. Mar. 8, 2016) (collecting cases and finding rate of $225 per hour reasonable for V&A attorneys who graduated law school in 2007 and 2011); Trustees of the N.Y.C. Carpenters Relief & Charity Fund v. Acme Steel Shelving Corp., No. 12-CV-5572 (AJN), 2013 WL 12109394, at *2 (S.D.N.Y. June 5, 2013) (reducing V&A attorney's rate from $200 to $175 per hour for 2010 law school graduate). That being said, Dickerson is "Of Counsel," and such title has warranted $300 per hour in fees. See Coastal Envtl. Grp., 2016 WL 7335672, at *4 (finding rate of "$300/hour for partners and `of counsel'" reasonable). Nonetheless, Petitioners have not demonstrated that the title alone qualifies him to earn more than he normally would based on how long he has been practicing. Therefore, the Court should reduce his fee to $225 per hour, which would reduce the overall attorneys' fees award to $657.50.
Finally, Petitioners request $70 in costs for service fees that they have incurred as part of this action. Pet. ¶ 32. "Recovery of such costs is routinely permitted," and the Court should award Petitioners their requested costs here as well. Plaza Constr. Grp., 2016 WL 3951187, at *2 (collecting cases).
Petitioners additionally request post-judgment interest on the full amount of the arbitrator's award. "Post-judgment interest serves as a means to `compensate the successful plaintiff for being deprived of compensation for the loss from the time between the ascertainment of the damage and the payment by the defendant.'" Westinghouse Credit Corp. v. D'Urso, 371 F.3d 96, 101 (2d Cir. 2004) (quoting Kaiser Aluminum & Chem. Corp. v. Bonjorno, 494 U.S. 827, 835-36 (1990)). Consistent with that policy objective, "[s]ection 1961 of Title 28 provides a uniform rate at which post-judgment interest is to accrue on civil money judgments recovered in federal district court." Westinghouse, 371 F.3d at 100.
"The award of post-judgment interest is mandatory on awards in civil cases as of the date judgment is entered," including orders that confirm arbitration awards. Lewis v. Whelan, 99 F.3d 542, 545 (2d Cir. 1996) (citing 28 U.S.C. § 1961(a)); see, e.g., Westinghouse, 371 F.3d at 100 ("There is no question but that the post-judgment interest awarded in this [confirmation of an arbitration award] was mandatory under § 1961."); PDV Sweeny, Inc. v. ConocoPhillips Co., No. 14-CV-5183 (AJN), 2015 WL 9413880, at *4 (S.D.N.Y. Dec. 21, 2015) ("And when an arbitration award is enforced through a judgment, the debt created by the award merges with a judgment entered on that award, so that the award debt is extinguished and only the judgment debt survives.") (internal quotation marks and alterations omitted), aff'd, 670 F. App'x 23 (2d Cir. 2016).
Consequently, the Petitioners are entitled to post-judgment interest on the total award of $108,808.41, plus accrued interest through the date of entry of the Court's judgment, at the rate provided for by 28 U.S.C. § 1961, from the date of entry of judgment until it is paid. See, e.g., Trustees for Mason Tenders Dist. Council Welfare Fund, Pension Fund, Annuity Fund, & Training Program Fund v. Union Const. Field, Inc., No. 14-CV-9996 (PAE), 2015 WL 3919124, at *5 (S.D.N.Y. June 25, 2015).
For the foregoing reasons, I recommend that the Court 1) confirm the arbitration award requiring Respondent to pay Petitioners $108,808.41; 2) grant Petitioners' application for attorneys' fees and costs in the amount of $727.50; and 3) grant Petitioners' application for post-judgment interest.
Pursuant to 28 U.S.C. § 636(b)(1) and Rule 72(b) of the Federal Rules of Civil Procedure, the parties have fourteen (14) days (including weekends and holidays) from service of this Report and Recommendation to file any objections (plus three days because the Report is being mailed to Respondent). See Fed. R. Civ. P. 6(a), (b), (d). A party may respond to any objections within fourteen (14) days after being served. Such objections, and any responses to objections, shall be filed with the Clerk of Court, with courtesy copies delivered to the chambers of the Honorable Vernon S. Broderick and the undersigned, United States Courthouse, 500 Pearl Street, New York, New York 10007. Any requests for an extension of time for filing objections must be directed to Judge Broderick.
