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S.D.N.Y.Procedural orderFiled Mar. 7, 2024

Zelvin v. AW Authentic, Inc.

Judge
Rearden
Docket
1:23-cv-09241
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Zelvin v. AW Authentic, Inc., Judge Rearden dismissed the case without prejudice for failure to prosecute after Plaintiff failed to correct a default-judgment motion.

Who this affects

Lynn Zelvin and AW Authentic, Inc.; the case was closed after the court dismissed it without prejudice for failure to prosecute.

What happened

In Zelvin v. AW Authentic, Inc., Lynn Zelvin sued AW Authentic, Inc. The company was served with the complaint but did not respond or appear.

The court ordered Zelvin to seek a default judgment or explain why the case should not be dismissed. Zelvin filed a default-judgment motion, but it lacked required information, including evidence supporting the requested damages. After the court gave Zelvin a deadline to file a corrected motion, Zelvin did not do so.

Judge Jennifer H. Rearden dismissed the case without prejudice for failure to prosecute under Federal Rule of Civil Procedure 41(b) and the court’s inherent authority. The clerk was directed to close the case.

The detailed version

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

Case
Zelvin v. AW Authentic, Inc. · No. 1:23-cv-09241
Judge
Rearden
Date
Mar. 7, 2024

Background

Lynn Zelvin filed the complaint on October 20, 2023. AW Authentic, Inc. was served on January 9, 2024, making its response due on January 30, 2024. The company did not respond to the complaint or otherwise appear.

Orders concerning default judgment

On February 18, 2024, the court ordered Zelvin to file a motion for default judgment by February 26, 2024, or explain why the case should not be dismissed for failure to prosecute. The court warned that failing to file a timely and proper motion could result in dismissal without prejudice.

Zelvin filed a default-judgment motion on February 26, but the motion did not comply with the court’s rules. Among other deficiencies, it did not include evidence supporting the proposed damages or legal authority addressing whether a damages hearing was necessary. On February 28, the court stated that it would not consider the application and gave Zelvin until March 5 to file a corrected motion. The court again warned that failure to file a timely and proper motion could result in dismissal without prejudice. Zelvin did not file a corrected motion.

Ruling

Judge Jennifer H. Rearden dismissed the case, without prejudice, for failure to prosecute under Federal Rule of Civil Procedure 41(b) and the court’s inherent authority. The court directed the clerk to close the case. The opinion does not decide the underlying claims or damages issues.

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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