Eddington v. Golden Bridge, LLC

Background

Lisa Eddington, doing business as Eddington Link, LLC, filed this action without a lawyer in the Southern District of New York. She invoked federal-question jurisdiction and listed Golden Bridge, LLC; Golden Bridge Funding; Stephan Felder, Esq.; Green Mountains Holding; Maurice Dicks; and Danielle P. Light as defendants. The caption did not include Dicks and Light, although the complaint listed them as defendants.

Eddington’s complaint used the court’s general complaint form and identified claims involving a home-improvement rescue scam, financial hardship, personal injury, and intellectual property. Her attached documents mostly concerned real property at 57 East 54th Street in Brooklyn, including ownership and improvement documents. The attachments also included documents from an earlier foreclosure action in the Eastern District of New York. According to the opinion, a default judgment in that action was entered against Eddington on March 30, 2022, in favor of Green Mountain Holdings.

Venue analysis

The court applied 28 U.S.C. § 1391(b), which identifies districts where a civil case may properly be filed. The opinion states that Eddington provided a Forest Hills, Queens County, New York, address for Golden Bridge, LLC, Maurice Dicks, and Stephen Felder; a Miami Beach, Florida, address for Green Mountain Holding; and a New York, New York, work address for Danielle P. Light. Because not all defendants were residents of New York, the court concluded that venue was not proper in the Southern District or the Eastern District under § 1391(b)(1), which concerns where defendants reside.

The court found that the Eastern District was a proper venue under § 1391(b)(2), which concerns where a substantial part of the events occurred or where the property involved in the case is located. Although the complaint’s precise allegations were unclear, the complaint and attachments strongly suggested that the claims arose from the foreclosure of the Brooklyn property. The court stated that Eddington alleged no facts showing that a substantial part of the events occurred in the Southern District.

The court also applied 28 U.S.C. § 1404(a), which allows a court to transfer a case to another district for the convenience of the parties and witnesses and in the interest of justice. It considered the Brooklyn location of the property and apparent underlying events, Eddington’s residence in Brooklyn, the expected location of relevant documents and witnesses, and the location of several defendants in Queens County. The court concluded that the Eastern District appeared to be the more convenient forum.

Disposition

The court ordered the Clerk to transfer the action to the United States District Court for the Eastern District of New York. It stated that the receiving court would decide whether Eddington could proceed without paying fees. The Southern District court directed that no summons issue from that court and stated that the order closed the case there. It also certified that an appeal would not be taken in good faith and denied payment-free status for purposes of an appeal. The opinion does not decide the merits of Eddington’s underlying claims.