Supreme Court of Delaware
Greenspon v. Black Knight Financial Services, Inc.
September 15, 2017
Summary
The Supreme Court of Delaware affirmed the Superior Court’s denial of reconsideration of a Commissioner’s order quashing a subpoena for documents located outside Delaware. It held that the Superior Court applied the standard required for reconsideration of a Commissioner’s non-case-dispositive order and properly placed the burden on Greenspon to show clear error, legal error, or abuse of discretion. The Court declined to consider Greenspon’s separate challenge to the Commissioner’s treatment of the discovery motions as non-case-dispositive because he had not raised that objection below and could not demonstrate plain error.