Quintyne v. Daly
Renee Quintyne v. Kenneth Daly, Kevin Shine, Maria Coupe, Nikki Rambis, Joseph Donnini, Robert Murray, John Edel, and St. Thomas Aquinas College
- Rochon
- 1:25-cv-04865
- U.S. District Court · Southern District of New York
- 3
In Renee Quintyne v. Kenneth Daly, Judge Rochon extended service and briefing deadlines after four defendants were served.
Renee Quintyne received more time to serve Nikki Rambis, John Edel, Robert Murray, and St. Thomas Aquinas College and to oppose the defendants’ motion to dismiss. The order also addressed the defendants’ service-related arguments but did not decide their motion to dismiss.
What happened
In Renee Quintyne v. Kenneth Daly, Renee Quintyne sued several individuals and St. Thomas Aquinas College. The court had ordered her to explain why all defendants had not been served within 90 days.
Defendants moved to dismiss, arguing that some defendants had not been properly served, among other grounds. Quintyne showed that four defendants were served and asked for more time to serve the remaining defendants; she did not oppose the dismissal motion by its original deadline.
Judge Jennifer L. Rochon granted Quintyne until October 29, 2025, to serve the remaining defendants and until November 5, 2025, to oppose the motion to dismiss. The opinion did not decide the motion to dismiss.
The detailed version
- Quintyne v. Daly · No. 1:25-cv-04865
- Rochon
- Oct. 23, 2025
Background
Renee Quintyne filed this case on June 10, 2025. The court later treated the complaint as asserting claims against St. Thomas Aquinas College and added the college as a defendant. On September 17, 2025, the court ordered Quintyne to explain why she had not served the defendants within the 90-day period required by Federal Rule of Civil Procedure 4(m), or to explain when and how service had occurred.
The Parties’ Filings
On October 1, 2025, the defendants moved to dismiss the complaint for lack of subject-matter jurisdiction, insufficient service of process, and failure to state a claim. They conceded that Maria Coupe, Kevin Shine, Kenneth Daly, and Joseph Donnini had been timely served, but argued that Nikki Rambis, John Edel, Robert Murray, and St. Thomas Aquinas College had not been served. Quintyne did not file an opposition to the motion or request an extension of the opposition deadline.
On October 12, 2025, Quintyne filed proof that Coupe, Shine, Daly, and Donnini had each been served on September 10, 2025. She explained that she had served only four defendants after receiving advice from a law student participating in a city bar program, and asked for additional time to serve the remaining defendants.
Court’s Analysis
Rule 4(m) requires an extension when a plaintiff demonstrates good cause. The court explained that good cause involves weighing the plaintiff’s reasonable efforts and diligence against prejudice to the defendants. The court also has discretion to grant an extension even without good cause, considering factors such as prejudice, actual notice of the lawsuit, possible statute-of-limitations consequences, and a justifiable excuse for the service failure.
The court granted an extension because Quintyne was representing herself and said she had relied on advice from a free legal-services organization. The court also found that the unserved defendants had actual notice because the defendants had timely filed a motion to dismiss, and that the defendants had not been prejudiced by the delay.
Order
The court extended Quintyne’s deadline to serve the remaining defendants to October 29, 2025. As a courtesy because she was representing herself, the court also extended her deadline to oppose the defendants’ motion to dismiss to November 5, 2025. The opinion did not rule on the motion to dismiss itself.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.