Laforest v. Doe
- Edgardo Ramos
- 1:25-cv-03719
- U.S. District Court · Southern District of New York
- 2
In Laforest v. Doe, Judge Swain ordered a pro se plaintiff to pay fees or apply to proceed without payment and submit an original complaint signature.
Jean Pierre Laforest, who must address the filing-fee and signature requirements within 30 days or face dismissal of the action.
What happened
In Laforest v. Doe, Jean Pierre Laforest filed the action without a lawyer but did not pay the required $405 fee or use the Court’s application to request permission to proceed without paying the fee. The submitted application did not provide all the information needed to evaluate his ability to pay.
The Court gave Laforest 30 days to either pay the $405 fee or submit the attached application, and separately ordered him to submit an original signature page for his unsigned complaint. No summons would issue at that time. The order states that the action will be dismissed if he does not comply within the deadline.
Judge Laura Taylor Swain also ruled that any appeal from the order would not be taken in good faith and denied permission to proceed without paying appeal fees.
The detailed version
- Laforest v. Doe · No. 1:25-cv-03719
- Edgardo Ramos
- June 3, 2025
Background
Jean Pierre Laforest brought the action without a lawyer. To proceed with a civil action in the Southern District of New York, a plaintiff must either pay $405 in fees or submit a signed application requesting permission to proceed without prepaying the fees. Laforest did not use the Court’s application, and the document he submitted lacked information needed to determine whether he could pay.
Laforest also submitted an unsigned complaint. The Court explained that Federal Rule of Civil Procedure 11(a) and the applicable local rule require an unrepresented party to sign the party’s own filings with an original handwritten signature or handplaced mark.
Order
The Court ordered Laforest, within 30 days of the order, to do both of the following: either pay the $405 fee or submit the attached application to proceed without prepayment of fees, and submit the attached signature page for the complaint with an original signature. The application was to include docket number 25-CV-3719.
No summons would issue at that time. The order states that, if Laforest complied, the case would be processed under the Clerk’s Office procedures. If he failed to comply within the allowed time, the action would be dismissed.
Appeal-fee ruling
The Court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.