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S.D.N.Y.Procedural orderFiled Oct. 16, 2025

Fox Shiver LLC v. Individuals

Full caption

Fox Shiver LLC v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint

Judge
Jesse Furman
Docket
1:25-cv-03068
Court
U.S. District Court · Southern District of New York
Pages
6
Pro SeCivil Procedure
In one sentence

In Fox Shiver v. Individuals, Judge Furman allowed Narges Tankbris d/b/a JooJooArtStore to proceed without counsel, subject to reconsideration.

Who this affects

Narges Tankbris d/b/a JooJooArtStore, whom the court permitted to defend the action without counsel, subject to reconsideration.

What happened

In Fox Shiver LLC v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint, Narges Tankbris filed an answer without a lawyer for JooJooArtStore. The court had directed Tankbris to explain why the business should be allowed to proceed without counsel.

Tankbris said JooJooArtStore is a sole proprietorship. The court understood that the business therefore had no legal existence separate from Tankbris and that Tankbris was the real defendant. The court concluded that the usual rule preventing an unrepresented person from representing a business did not apply here.

Judge Jesse M. Furman permitted Tankbris, doing business as JooJooArtStore, to proceed without counsel, subject to reconsideration if Fox Shiver raises the issue or evidence emerges suggesting a different result. The order also provided instructions about filing papers, service, communications with the court, extensions, discovery, motions, and available assistance from the district's private legal clinic.

The detailed version

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

Case
Fox Shiver LLC v. Individuals · No. 1:25-cv-03068
Judge
Jesse Furman
Date
Oct. 16, 2025

Background

On September 30, 2025, the court directed Defendant Narges Tankbris d/b/a JooJooArtStore to show cause—explain why—she should be permitted to proceed without counsel. Tankbris had filed an answer without a lawyer. Tankbris asserted that JooJooArtStore was a sole proprietorship.

Ruling

The court understood that a sole proprietorship has no legal existence separate from its owner. It therefore understood that JooJooArtStore had no separate legal existence from Tankbris and that Tankbris was the true defendant. Subject to reconsideration if Fox Shiver raises the issue or evidence emerges suggesting otherwise, the court found that the usual rule barring a person without a lawyer from representing an entity did not apply. The court accordingly permitted Tankbris d/b/a JooJooArtStore to proceed without counsel.

Instructions for the unrepresented defendant

The order encouraged unrepresented parties to consent to electronic service through the court's electronic filing system. Unless an unrepresented party consents, attorneys must serve that party with paper copies of electronically filed documents and file proof of service with the court.

The order directed unrepresented parties to submit communications through the Pro Se Intake Unit rather than directly to chambers. It also described procedures for filing documents, requesting extensions or adjournments, handling discovery disputes, responding to motions, and participating in later case-management and trial proceedings. The order stated that a private organization, the City Bar Justice Center, operates a pro se legal clinic that may provide limited assistance, but the clinic is not part of the court and cannot file documents for the party. The Clerk of Court was directed to mail a copy of the order to Tankbris d/b/a JooJooArtStore.

The authoritative version

Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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