Among the decisions handed down in May and June in the United States District Court for the Southern District of New York were a decision by Judge Jed S. Rakoff holding that private civil RICO plaintiffs may seek injunctive relief and two decisions by Judge Lewis A. Kaplan addressing the question of when an injury caused by an out-of-state defendant will be considered an injury within New York for purposes of long-arm jurisdiction.
In other cases, Judge John F. Keenan imposed sanctions against a party for pre-litigation destruction of documents and Judge Shira A. Scheindlin again rejected claims that she should recuse herself based on her stock holdings in companies involved in the class action litigation pending before her. Finally, Judge Whitman Knapp held that there was a mandatory one-year limitations period for commencing an action for summary confirmation of an arbitration award under 9 USC �9.
