Jalalian v. JPMorgan Chase Bank

Background

The court considered three motions filed by Armen Jalalian: (1) a motion for judicial notice of JPMorgan Chase Bank, N.A.’s alleged “recidivist” status and for enhanced sanctions, docket number 69; (2) a motion for a continuance of a hearing, docket number 71; and (3) a motion for sanctions and to disqualify defense counsel, docket number 75. The court decided the motions without oral argument and denied all three.

Judicial Notice and Sanctions

Jalalian sought judicial notice of a list of penalties that JPMorgan Chase allegedly incurred for various violations. The list appeared to have been copied from the Good Jobs First website. Judicial notice permits a court to accept a fact without requiring ordinary proof when the fact is generally known or can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.

The court stated that it could potentially take notice of the existence of other lawsuits or public records concerning alleged regulatory violations. But the material presented in Exhibit A was apparently from a non-government website, and nothing showed that it was not subject to reasonable dispute. The court therefore denied the request for judicial notice.

Jalalian also sought sanctions based on defense counsel’s failure to appear at an August 12, 2025 hearing on JPMorgan Chase’s motion to dismiss. The court had previously issued an order requiring counsel to explain why the motion to dismiss should not be denied or why counsel should not reimburse Jalalian’s travel costs. After counsel explained that he mistakenly believed the hearing would be remote, the court admonished counsel and discharged that order without imposing sanctions.

The court rejected sanctions under Federal Rule of Civil Procedure 11 because Jalalian challenged counsel’s failure to appear at a hearing, not a pleading, written motion, or other paper submitted for an improper purpose or without a legal or factual basis. The court also denied sanctions under 28 U.S.C. § 1927 because that provision requires bad faith, and the court credited counsel’s explanation that the nonappearance resulted from a mistaken belief about the hearing’s format. The court likewise found no bad faith supporting sanctions under its inherent authority. It declined to find that the nonappearance was an institutional strategy rather than inadvertence.

Second Sanctions and Disqualification Motion

Jalalian separately moved for sanctions and to disqualify defense counsel Brian Gee. The court stated that this motion largely repeated the earlier arguments and denied it for the reasons already explained.

Continuance

Jalalian requested that a “currently scheduled hearing” be continued to January 28, 2026. When he filed the motion, no hearing was scheduled. A later hearing on JPMorgan Chase’s motion to dismiss was set, then continued to November 18, 2025, and was the only hearing scheduled at the time of the order. Because Jalalian had not identified which hearing he wanted continued to January 2026, the court denied the request. The court stated that future requests to change a hearing time must comply with the applicable local rules.

Disposition

The court denied Jalalian’s motions at docket numbers 69, 71, and 75. It also cautioned that, although Jalalian was proceeding without a lawyer, he was required to comply with the federal rules and the court’s local rules. The court warned that duplicative motions or motions filed for an improper purpose may violate Rule 11.