This quarter's column explores two instructive reminders on citizenship of limited liability companies and the standards of review of a Report, Recommendation and Order of a Magistrate Judge, as well as a comprehensive decision by a federal court on the unfortunately timely topic of sexual abuse of children, including whether the New York State Child Victims Act, 2019 N.Y. Sess. Laws c. 11, §3 (CVA), creates a standalone cause of action.