“Chutzpah” as a legal term of art is analytically similar to “unclean hands,” though not necessarily coterminous with that concept as understood in Chancery. The “classic definition” of chutzpah has been described as “that quality enshrined in a man who, having killed his mother and father, throws himself on the mercy of the court Because he is an orphan.” Leo Rosten, The Joys of Yiddish 92 (1968). Courts in .this Circuit have employed the “classic definition” and contemporary variations where a party’s conduct is especially and brazenly faulty. See, e.g., Thaler v. Second New Haven Bank, Civ. No. B-713, slip op. at 1 (D.Conn. Apr. 10, 1974) (Jon O. Newman, J.) (dismissing a lawsuit brought by Seymour R. Thaler, a former New York State Senator who — while serving a sentence for selling stolen bonds to the Second New Haven Bank — sued the bank for negligence, contending that if a teller had checked that day’s list of stolen bonds, the bonds would not have been accepted and Thaler would not have been convicted); see id. (“When the apocryphal child murdered his parents and then sought mercy as an orphan, he set a standard for courtroom chutzpah that has not been rivaled until the filing of this lawsuit.”). Cf. Scher v. Nat’l Assoc, of Sec. Dealers, 386 F.Supp.2d 402, 404 (S.D.N.Y. 2005) (Michael B. Mukasey, J.) (quoting the unpublished opinion by then-District Judge Newman); Lawrence Fellows, Judge Rebuffs Thaler Suit As New High in `Chutzpah’, N.Y. Times, Apr. 12, 1974, at A35 (“Judge Newman dismissed the suit in Federal District Court . . . and, in an accompanying memorandum he denounced both the complaint and its author for aspiring to a new `standard for courtroom chutzpah.'”). Although “chutzpah” is, in some respects, “vastly overused,” Yates v. City of New York, No. 04 Civ. 9928, 2006 WL 2239430, at *1, 2006 U.S. Dist. LEXIS 54199, at *1 (S.D.N.Y. Aug. 4, 2006) (Sidney H. Stein, J.), it endures in judicial opinions whenever judges — who have “seen it all” — encounter such flagrant abuses that no single word adequately expresses appropriate disgust. See id. (observing that “chutzpah” was the “most appropriate” term to describe “an individual, [who] after being mauled by the 450-pound Siberian tiger he had been raising inside his fifth-floor apartment along with an alligator, sue[d] the city and the police who entered the apartment in an effort to rescue the animals for doing so without a search warrant”). Such is the case we decide today.
Motorola Credit Corp. v. Uzan, 561 F.3d 123, 129 n.5 (2d Cir. 2009)