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Golden v. Management & Training Corporation

United States District Court, District of Columbia

November 15, 2019

DAVID GOLDEN, Plaintiff,

         Re Document Nos.: 62, 63, 68



         Denying Plaintiff's Motion to Enforce Settlement Agreement, Denying MTC's Request for Fees, and Granting MTC's Motion to Extend Discovery Period

         I. Introduction

         This matter comes before the Court upon David Golden's motion to enforce a settlement agreement upon Management & Training Corporation (“MTC”). After considering the parties' submissions and the governing law, the Court concludes the following: Mr. Golden's motion to enforce the settlement agreement shall be denied because no valid, enforceable settlement agreement was formed between Mr. Golden and MTC. At the time Mr. Golden alleges that the settlement agreement was formed, the parties had not reached the requisite meeting of the minds over a material term: the scope of the settlement agreement. The Court also grants MTC's motion to extend the discovery period and requests that the parties meet and submit a proposed discovery schedule within 30 days.

         II. Factual Background

         On September 24, 2018, Mr. Golden's counsel, Mr. Crump, initiated settlement negotiations with a global settlement offer that “attempt[ed] to settle the referenced matter with Management Training Corporation (MTC) and Chugach Government Solutions (CGSI)” for $128, 000. Defs.' Opp'n Mot. to Enforce Settlement Agreement (“Defs.' Opp'n”) Ex. 1, ECF No. 68-1 (emphasis added). MTC responded on November 30 with a global counteroffer, “MTC offers [$]10[, 000] to settle the case as to all defendants.” Defs.' Opp'n Ex. 3, ECF No. 68-3. On December 19, MTC made another counteroffer, again specifying its global nature. See Defs.' Opp'n Ex. 4, ECF No. 68-4 (“We counter with [$]15[, 000] to settle all claims as to all defendants.”).

         Between February 8 and 12 of 2019, Mr. Crump and MTC exchanged emails trying to reach an exact settlement amount. MTC inquired if Mr. Crump could settle for $25, 000, and Mr. Crump answered asking if MTC's counsel “could get [MTC] to [$]35[, 000].” Defs.' Opp'n Ex. 6, ECF No. 68-6. MTC stated that it was “a real push to get to [$]25[, 000], ” but that it might be possible to get to $30, 000 if that would settle the matter. Defs.' Opp'n Ex. 7, ECF No. 68-7. At no point in this round of negotiations did either party make any explicit statement that the settlement was to be with respect to both Defendants, or that these proposals were to deviate from the previously explicit global settlement.

         On February 19, Mr. Crump replied, “My client has now authorized me to settle his claim with respect to MTC for . . . [$]30[, 000].” Pl.'s Mot. Enforce Settlement Agreement (“Pl.'s Mot.”) Ex. 2, ECF No. 63-2 (emphasis added). MTC accepted the counteroffer and arranged to prepare a settlement agreement for Mr. Crump's review. Pl.'s Mot. Ex. 3, ECF No. 63-3 (“Great, thanks for letting me know. Will prepare an agreement and send to you for review.”). On March 5 at 11:32 am, MTC sent Mr. Crump a complete settlement agreement that read in relevant part, “[t]his . . . settlement agreement . . . is made and entered into by and between David Golden . . . and Management Training Corporation and Chugach Government Services, Inc., on their own behalves, and on behalf of their successors, predecessors and assigns.” Defs.' Opp'n Ex. 10, ECF No. 68-10 (emphasis added).

         Mr. Crump responded to MTC at 12:58 pm, asking why MTC had included Chugach in the settlement agreement. Defs.' Opp'n Ex. 11, ECF No. 68-11. Mr. Crump asserted that the negotiations had only been between Mr. Golden and MTC, and that the settlement was not with respect to all parties. Defs.' Opp'n Ex. 11, ECF No. 68-11. Further, Mr. Crump stated that Chugach's counsel had informed him that Chugach would not be settling the case. Id. MTC replied at 1:13 pm and asserted that since the beginning of the settlement negotiations, the parties had been discussing a global settlement. Defs.' Opp'n Ex. 12, ECF No. 68-12. During that exchange, MTC “made [it] clear” that “there will be no settlement if all defendants are not included.” Id.

         At 1:30 pm, Mr. Crump reasserted that MTC had “made absolutely no mention of a global settlement agreement” and that MTC's “emails to [Mr. Crump did] not even mention a global settlement.” Defs.' Opp'n Ex. 13, ECF No. 68-13. In addition to these claims, Mr. Crump stated that any allegation made by MTC that Mr. Crump was “walking back anything is misplaced and not in good faith.” Id.

         At 2:31 pm, MTC replied, “Please see your 9/24/18 initial demand, which explicitly propose[d] a global settlement.”[1] Defs.' Opp'n Ex. 14, ECF No. 68-14. MTC continued, “We then countered globally, as reflected in [the] email counters to you of 11/30 and 12/19, each of which makes clear that the counters [MTC] were making were to settle the case as to all defendants.” Id. Mr. Crump replied two minutes later that he would “get back to [MTC].” Id.

         Chugach responded to Mr. Crump's email two days later at 10:14 am on March 7, expressing “surprise” at the position Mr. Crump was taking. Defs.' Opp'n Ex. 16, ECF No. 68-16. Chugach stated that in the previous conversation between Chugach and Mr. Crump, Mr. Crump had asked “whether Chugach would contribute more than what [MTC] had already put on the table for both defendants.” Id.

         Mr. Crump replied to Chugach at 10:33 am, stating that Chugach was “correct in [its] assertion.” Defs.' Opp'n ...

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