Gulum v. Permanent Mission of the People’s Democratic Republic of Algeria to…
Jemal Gulum, as Administrator c.t.a of the Estate of Fatouma Gulum v. Permanent Mission of the People’s Democratic Republic of Algeria to the United Nations
- John Cronan
- 1:26-cv-03079
- U.S. District Court · Southern District of New York
- 2
In Jemal Gulum v. Permanent Mission of the People’s Democratic Republic of Algeria, Judge Cronan ordered a service-status letter by July 22, 2026, warning the case could be dismissed.
Jemal Gulum, as administrator of the estate, must provide the required service information and any proof of service. The defendant, the Permanent Mission of the People’s Democratic Republic of Algeria to the United Nations, had not appeared according to the order.
What happened
In Jemal Gulum, as Administrator c.t.a. of the Estate of Fatouma Gulum v. Permanent Mission of the People’s Democratic Republic of Algeria to the United Nations, the complaint was filed on April 15, 2026, but the defendant had not appeared and the docket did not show whether it had been served.
The court ordered Jemal Gulum to file a letter by July 22, 2026, stating whether service had been completed and, if not, why there was a good reason to excuse missing the 90-day service deadline. The letter was required even if service had already occurred, and proof of service also had to be filed if applicable.
Judge John P. Cronan did not dismiss the case in this order. He warned that failing to file the required letter could lead to dismissal for failure to prosecute.
The detailed version
- Gulum v. Permanent Mission of the People’s Democratic Republic of Algeria to… · No. 1:26-cv-03079
- John Cronan
- July 15, 2026
Background
The complaint was filed on April 15, 2026. The defendant had not appeared, and the docket did not show whether the defendant had been served. The plaintiff had not requested more time to serve the defendant.
Court’s Order
Federal Rule of Civil Procedure 4(m) generally requires service within 90 days after a complaint is filed. The rule allows a court to dismiss an unserved defendant without prejudice or order service by a specified deadline. It also requires the court to extend the service period for an appropriate time if the plaintiff shows good cause, meaning circumstances beyond the plaintiff’s control despite diligent attempts.
The court ordered the plaintiff to file a status letter by July 22, 2026. The letter must state whether the summons and complaint were served. If they were not served, the letter must explain why good cause exists to excuse the failure to meet the 90-day deadline. The plaintiff must file the letter even if service had already been made. If service had occurred, the plaintiff also had to file proof of service by July 22, 2026.
The court warned that failure to file the letter could result in dismissal for failure to prosecute. The order did not itself dismiss the case or decide the underlying dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.