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Parker Waichman LLP v. Salas LC

Citation: 320 F. Supp. 3d 327Docket: Civil No. 16–1333 (FAB)

Court: United States District Court; May 25, 2018; Federal District Court

Narrative Opinion Summary

In a case concerning the termination of a confidential operating agreement related to litigation following an explosion at the Caribbean Petroleum Corporation, several motions were filed by the parties. The plaintiff, Parker Waichman LLP, alleged breach of the CAPECO Agreement by defendants, asserting claims for specific performance and, alternatively, quantum meruit for unreimbursed expenditures. The court previously deemed the CAPECO Agreement unenforceable for specific performance but allowed the pursuit of equitable relief. Defendants moved to strike evidence and sought summary judgment, arguing the non-recoverability of advertising costs and lack of admissible evidence by Parker. The court denied these motions, finding genuine disputes of material fact and the relevance of Parker's evidence. Additionally, the court denied Parker's motion to withdraw its jury trial request and rejected defendants' motion for partial dismissal of the quantum meruit claim. Quetglas's motion to amend his crossclaim was granted, based on new evidence regarding fee distribution. The court's decisions emphasize the application of Puerto Rico contract law and quantum meruit principles, with a focus on preventing unjust enrichment and ensuring fair compensation for services rendered.

Legal Issues Addressed

Jury Trial Withdrawal

Application: The court denied Parker's motion to withdraw its request for a jury trial, noting that the withdrawal required consent from both parties, which was not obtained.

Reasoning: The court denied Parker's motion, stating that once a jury trial is requested, both parties must consent to withdrawal, and the defendants did not consent.

Motion to Amend a Crossclaim

Application: The court granted Quetglas's motion to amend his crossclaim, finding substantial and convincing evidence of new information justifying the amendment.

Reasoning: Quetglas has presented substantial and convincing evidence justifying his late request to amend his crossclaim, as new evidence from discovery revealed pertinent information regarding settlement amounts and attorney fees.

Motion to Strike Evidence

Application: The court denied the defendants' motion to strike evidence from the record, emphasizing that the nonmovant is not required to provide evidence in an admissible form to avoid summary judgment.

Reasoning: Parker is not required to provide evidence in an admissible form to avoid summary judgment, and the defendants did not adequately explain why Parker's evidence could not be authenticated for trial.

Quantum Meruit under Puerto Rico Law

Application: The court allowed Parker to pursue a quantum meruit claim for reasonable compensation for services rendered, applying Puerto Rico's principle of preventing unjust enrichment.

Reasoning: Under Article 1473 of the Puerto Rico Civil Code, professional services' remuneration is determined by the parties' agreement, and in its absence, the reasonable value of services can be recovered through quantum meruit.

Summary Judgment Standard

Application: The court outlined that summary judgment is not suitable where genuine disputes over material facts exist, as such disputes could lead a reasonable jury to favor the nonmoving party.

Reasoning: A genuine dispute exists when evidence could lead a reasonable jury to favor the nonmoving party, and a material fact is one that could influence the outcome of the case.