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S.D.N.Y.Procedural orderFiled Sept. 26, 2025

Michaels v. Stover

Judge
Ronnie Abrams
Docket
1:25-cv-07017
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Scott Michaels v. Erika Stover, Judge Aaron ordered the pro se plaintiff to provide a service address after renaming the defendant Erik Stover.

Who this affects

Scott Michaels and Erik Stover

What happened

Scott Michaels v. Erika Stover involves state-law claims brought by Scott Michaels, who is appearing without a lawyer. The court had already allowed Michaels to proceed without paying court fees in advance, but he did not provide an address for serving the defendant.

Michaels stated only that the defendant lived in New York. He also asked the court to change the defendant’s name from “Erika Stover” to “Erik Stover.”

The court ordered Michaels to provide a service address within 30 days or ask for more time, warning that it may dismiss the claims for failure to prosecute if he does neither. Judge Stewart D. Aaron also directed the clerk to change the defendant’s name to “Erik Stover.”

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Michaels v. Stover · No. 1:25-cv-07017
Judge
Ronnie Abrams
Date
Sept. 26, 2025

Background

Scott Michaels, identified in the order as a British citizen, brings state-law claims against the defendant and is appearing without a lawyer. The court had previously granted Michaels permission to proceed without prepaying filing fees. In such cases, the court and the U.S. Marshals Service are responsible for arranging service of the summons and complaint.

Michaels did not provide the defendant’s address in his filings. He stated only that the defendant resides in New York. Michaels also filed a letter asking that the defendant’s name be changed from “Erika Stover” to “Erik Stover.”

Order

The court directed Michaels, within 30 days after September 26, 2025, to provide an address where the defendant can be served. The court said Michaels may instead request an extension of time. If he does not provide an address or request an extension within that period, the court may dismiss the claims against the defendant under Rules 4 and 41 of the Federal Rules of Civil Procedure for failure to prosecute.

The court also advised Michaels that he could consent to receiving court documents by email. Finally, it directed the clerk to change the defendant’s name in the case to “Erik Stover.” The order addressed service and case administration; it did not decide the underlying state-law claims. The order was issued by Stewart D. Aaron, United States Magistrate Judge.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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