Bishop v. Indeed Laboratories Usa Inc.
Cedric Bishop, on behalf of himself and all other persons similarly situated v. Indeed Laboratories USA Inc.
- Ronnie Abrams
- 1:25-cv-03350
- U.S. District Court · Southern District of New York
- 2
In Bishop v. Indeed Laboratories, Judge Abrams gave Bishop until September 26, 2025, to support service or seek default judgment, warning dismissal could follow.
Cedric Bishop and Indeed Laboratories USA Inc.; the order also concerns the proposed class identified in the complaint because the action was brought on behalf of similarly situated persons.
What happened
In Cedric Bishop v. Indeed Laboratories USA Inc., Bishop said he served the defendant through Corporation Service Company, which he identified as the defendant’s registered agent. The defendant had not appeared.
The court questioned whether leaving the summons and complaint “in the basket” properly completed service. Bishop was ordered to explain his position and said service was proper based on the registered-agent relationship and statements he said the process server made.
The order allows Bishop until September 26, 2025, to seek default judgment and requires supporting legal authority about service. Judge Ronnie Abrams also said Bishop may provide additional materials correcting his proof of service and warned that failing to file the required submissions could lead to dismissal for failure to prosecute.
The detailed version
- Bishop v. Indeed Laboratories Usa Inc. · No. 1:25-cv-03350
- Ronnie Abrams
- Aug. 27, 2025
Background
Cedric Bishop brought this putative class action on April 22, 2025. On July 21, 2025, he filed an affidavit of service stating that “Corporation Service Company” had been served by leaving the summons and complaint “in the basket.” Indeed Laboratories USA Inc. had not appeared.
Service issue
The court ordered Bishop to explain whether service on Indeed Laboratories was properly completed. Bishop responded that service was proper because Corporation Service Company was Indeed Laboratories’ registered agent and because of representations that the process server allegedly made to him. The court noted that those representations were not included in the process server’s affidavit.
Order
The court directed that, if Bishop intends to seek default judgment, he must file the motion no later than September 26, 2025. The motion must include the legal basis and supporting case law for his position that service was properly completed. Bishop may also submit an affidavit or other materials supplementing or correcting his proof of service under Federal Rule of Civil Procedure 4(l)(3). Judge Ronnie Abrams warned that failure to file these submissions may result in dismissal of the action for failure to prosecute. The order did not decide whether service was valid, whether default judgment should be entered, or the merits of Bishop’s claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.