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S.D.N.Y.Procedural orderFiled Jan. 25, 2021

Guglielmo v. Assouline, Inc.

Judge
Vernon Broderick
Docket
1:20-cv-05921
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Guglielmo v. Assouline, Inc., Judge Broderick dismissed the claims without prejudice because service was late and no good cause was shown.

Who this affects

Joseph Guglielmo’s claims against Assouline, Inc. and Assouline Publishing, Inc. were dismissed without prejudice, and the case was closed.

What happened

In Guglielmo v. Assouline, Inc., Joseph Guglielmo filed a lawsuit against Assouline, Inc. and later added Assouline Publishing, Inc. The court said service on the defendants was overdue.

The court had ordered Guglielmo to explain why the case should not be dismissed under the service rule, but he did not respond. He also did not show a legally sufficient reason to extend the deadline for serving the defendants.

Judge Vernon S. Broderick dismissed Guglielmo’s claims against both defendants without prejudice under Rule 4(m) and directed the clerk to close the case.

The detailed version

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

Case
Guglielmo v. Assouline, Inc. · No. 1:20-cv-05921
Judge
Vernon Broderick
Date
Jan. 25, 2021

Background

Joseph Guglielmo filed the action against Assouline, Inc. on July 30, 2020, and obtained a summons for that defendant the next day. On October 7, 2020, he filed an amended complaint naming Assouline, Inc. and Assouline Publishing, Inc., and obtained a summons for Assouline Publishing, Inc. on October 8, 2020.

The court stated that Guglielmo had not filed affidavits showing service or taken other action to prosecute the case. Under Federal Rule of Civil Procedure 4(m), a defendant generally must be served within 90 days after the complaint is filed. If the plaintiff shows good cause for failing to serve the defendant, the court must extend the service deadline for an appropriate period. The court explained that good cause generally requires exceptional circumstances beyond the plaintiff’s control.

Court’s Order

On January 11, 2021, the court ordered Guglielmo to submit a letter of no more than three pages explaining, with legal authority, why the case should not be dismissed under Rule 4(m). The court warned that failure to comply would result in dismissal. Guglielmo did not comply with that order and did not show good cause for extending the service deadline.

Judge Vernon S. Broderick ordered that Guglielmo’s claims against Assouline, Inc. and Assouline Publishing, Inc. be dismissed without prejudice under Rule 4(m). The clerk was directed to close the case.

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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