This column reports on several recent significant decisions from the United States District Court for the Eastern District of New York. Judge Brian M. Cogan dismissed a claim for lack of subject matter jurisdiction. Judge Eric R. Komitee denied a motion to withdraw a guilty plea. And Judge Joan M. Azrack designated a case as complex for the purposes of exclusion of time under the Speedy Trial Act.

  1. Dismissal Of Claim For Failure To Adequately Allege Diversity Jurisdiction

In Coward v. Nat’l Railroad Passenger Corp., 24 CV 7562 (EDNY, Nov. 13, 2024), Judge Cogan dismissed one of plaintiff’s claims for want of subject matter jurisdiction based on the failure to properly allege diversity jurisdiction with respect to a limited liability company defendant.