southern district of ohio eastern division case no. … · 1/26/2018 · page 1 of 4 memorandum in...

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION DEAN OBEIDALLAH,

Plaintiff,

v. ANDREW B. ANGLIN,

DBA Daily Stormer, and MOONBASE HOLDINGS, LLC,

DBA Andrew Anglin, and JOHN DOES NUMBERS 1–10,

Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

CASE NO. 2:17-CV-00720-EAS-EPD Chief Judge Edmund A. Sargus Magistrate Judge Elizabeth Preston Deavers

PLAINTIFF’S REQUEST FOR ENTRY OF DEFAULT AGAINST DEFENDANT MOONBASE HOLDINGS, LLC

Case: 2:17-cv-00720-EAS-EPD Doc #: 25 Filed: 01/26/18 Page: 1 of 7 PAGEID #: 373

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PLAINTIFF’S REQUEST FOR ENTRY OF DEFAULT AGAINST

DEFENDANT MOONBASE HOLDINGS, LLC

Plaintiff Dean Obeidallah respectfully requests that the Clerk of the Court to enter default in

the above-captioned action (“Action”) against Defendant Moonbase Holdings, LLC in accordance

with Rule 55(a) of the Federal Rules of Civil Procedure. Attached hereto is a memorandum in

support which establishes that Defendant Moonbase has failed to plead or otherwise defend this

Action within the time prescribed by the Federal Rules of Civil Procedure.

Respectfully submitted,

Abid R. Qureshi (D.C. Bar No. 459227) LATHAM & WATKINS LLP 555 Eleventh St., NW, Suite 1000 Washington, D.C. 20004-1304 Phone: 202.637.2200 Fx: 202.637.2201 [email protected]

Johnathan Smith (D.C. Bar No. 1029373) Juvaria Khan (N.Y. Bar No. 5027461) MUSLIM ADVOCATES P.O. Box 66408 Washington, D.C. 20035 Phone: 202.897.1894 [email protected] [email protected] Admitted pro hac vice

/s/ Donald Screen Subodh Chandra (OH Bar No. 0069233) Donald Screen (OH Bar No. 0044070) THE CHANDRA LAW FIRM LLC 1265 W. 6th St., Suite 400 Cleveland, OH 44113-1326 Phone: 216.578.1700 Fx: 216.578.1800 [email protected] [email protected] Attorneys for Plaintiff Dean Obeidallah


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MEMORANDUM IN SUPPORT OF PLAINTIFF’S REQUEST FOR ENTRY OF DEFAULT AGAINST DEFENDANT MOONBASE HOLDINGS, LLC

Plaintiff Dean Obeidallah effected service on Defendant Moonbase Holdings, LLC

(“Moonbase”) on October 31, 2017 in accordance with Ohio Rev. Code § 1705.06, which authorizes

service upon the Ohio Secretary of State (the “Secretary”) as the agent of a limited liability company

(“LLC”). The time within which Moonbase could answer or defend expired 21 days thereafter, on

November 21, 2017. Defendant Moonbase has yet to plead or otherwise defend the above-

captioned action (the “Action”). As a result, Plaintiff respectfully requests that the Clerk of the

Court (the “Clerk”) enter default against Moonbase in accordance with Rule 55(a) of the Federal

Rules of Civil Procedure.

I. MOONBASE WAS PROPERLY SERVED

Rule 4(h)(1)(A) of the Federal Rules of Civil Procedure allows a party to serve a corporation

“in the manner prescribed by Rule 4(e)(1) for serving an individual,” which in turn permits service

“following state law . . . in the state where the district court is located.” The U.S. District Court for

the Southern District of Ohio is located in the State of Ohio. Ohio law requires LLCs to “maintain

continuously in this state an agent for service of process.” Ohio Rev. Code § 1705.06(A). When an

LLC’s registered agent “cannot be found or no longer has the address that is stated in the records of

the secretary of state,” then service may be made “upon the secretary of state as the agent of th[at]

company.” Ohio Rev. Code § 1705.06(H)(2). A party seeking service in this manner must file with

the Secretary an affidavit stating that the LLC’s registered agent “cannot be found or no longer has

the address that is stated in the records of the secretary of state or the limited liability company has

failed to maintain an agent as required by” Ohio law, and “the most recent address of the company

that the party who desires service has been able to ascertain after a diligent search.” Id. In addition

to the affidavit, the party must also deliver to the Secretary “four copies of the process, notice, or

demand . . . [and] a fee of five dollars.” Id. Once received, the Secretary must effect service on the


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LLC, which may be done by delivering the process to its principal office as shown upon the

Secretary’s records. Id. When service is made under this statute, “[s]ervice upon the company is

made when the secretary of state gives the notice and forwards the process . . . .” Id. (emphasis

added).

On October 27, 2017, Mr. Obeidallah’s counsel transmitted to the Secretary:

1. a cover letter requesting the Secretary’s service of Defendant Moonbase via its registered agent;

2. an affidavit by Ms. Tina Schroeder, InfoCorp’s owner, attesting that InfoCorp was unable to locate and serve Defendant Moonbase through its registered agent, Defendant Anglin, at the address then on file with the Ohio Secretary of State1;

3. four (4) copies of the Complaint and Summons in the above-captioned action;

4. a copy of Defendant Moonbase’s Articles of Incorporation reflecting its registered agent as: Andrew B. Anglin, 6827 N High Street STE 121, Worthington, Ohio 43085; and

5. a check for $5.00 to the Secretary.

Ex. 1-A, InfoCorp Aff.; Ex. 1-C, A. Qureshi Ltr.; Ex. 1-D, FedEx Tracking. Those materials were

delivered to the Secretary on October 30, 2017. Ex. 1-D, FedEx Tracking.

On October 31, 2017, the Secretary issued a Notice of Receipt stating that the Secretary

“received service of process . . . as the statutory agent for [Moonbase] . . . under Section 1705.06 of

the Ohio Revised Code” on October 31, 2017, and then forwarded such “via certified mail to any

available address of [Moonbase].” Ex. 1-E, Oh. Sec.’s Receipt.

1 From September 2, 2016 to January 15, 2018, Defendant Moonbase’s registered agent for service of process was: Andrew B. Anglin, 6827 N High Street STE 121, Worthington, Ohio 43085. On January 16, 2018, Defendant Moonbase suddenly changed its registered agent’s address to PO Box 208, Worthington, OH 43085. (As explained in plaintiff’s recently-filed motion, that PO Box was registered using the address 6827 N High Street STE 121, Worthington, Ohio 43085. ECF No. 23-12.) That change, which is further evidence of Defendants Anglin and Moonbase playing games with the Court in an effort to evade service of process, has no bearing on these proceedings because it occurred after: (1) Mr. Obeidallah properly served Defendant Moonbase at his then-current registered agent’s address; and (2) Defendant Moonbase’s time to file a responsive pleading expired.


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Based on the foregoing, Mr. Obeidallah effected service on Defendant Moonbase in accordance

with Ohio Revised Code § 1705.06(H)(2) on October 31, 2017.

II. MOONBASE IS IN DEFAULT

Rule 12 of the Federal Rules of Civil Procedure prescribes the time by which a served party

must respond to a pleading. Rule 12(a) states, in relevant part, that a defendant “must serve an

answer . . . within 21 days after being served with the summons and complaint.” Fed. R. Civ. P. 12(a)(1)(A)(i)

(emphasis added); see also Stillwagon v. City of Delaware, No. 2:14-CV-1606, 2017 WL 3037413, at *3

(S.D. Ohio July 18, 2017) (Sargus, J.) (“Typically, a defendant must simply respond . . . within 21

days after being served with the summons and complaint or, if the defendant has waived service,

within 60 days after the waiver was sent.”).

As explained above in Part I, Mr. Obeidallah served Defendant Moonbase with the

summons and complaint in accordance with federal and Ohio state law on October 31, 2017.

Defendant Moonbase was required to file a responsive pleading on or before November 21, 2017.

See Fed. R. Civ. P. 6(a)(1) (specifying that periods stated in days are calculated by excluding the day

of the triggering event and counting every intervening day, including weekends and holidays). To

date, Defendant Moonbase has neither entered an appearance, filed a responsive pleading, nor

sought an extension for additional time to answer or defend this action.

Mr. Obeidallah respectfully requests that the Clerk enter default against Moonbase in

accordance with Rule 55(a) of the Federal Rules of Civil Procedure. In addition to the material

presented above, Mr. Obeidallah attaches hereto an Affidavit showing that Defendant Moonbase

has failed to plead or otherwise defend this Action. See generally Ex. 1, D. Screen Decl.; see Fed. R.

Civ. P. 55(a) (“When a party against whom a judgment for affirmative relief is sought has failed to

plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter

the party's default.”).


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III. CONCLUSION

For reasons set forth herein, Mr. Obeidallah respectfully requests that the Clerk enter default

against Moonbase in accordance with Rule 55(a) of the Federal Rules of Civil Procedure.

Respectfully submitted,

/s/ Donald Screen Abid R. Qureshi (D.C. Bar No. 459227) LATHAM & WATKINS LLP 555 Eleventh St., NW, Suite 1000 Washington, D.C. 20004-1304 Phone: 202.637.2200 Fx: 202.637.2201 [email protected]

Johnathan Smith (D.C. Bar No. 1029373) Juvaria Khan (N.Y. Bar No. 5027461) MUSLIM ADVOCATES P.O. Box 66408 Washington, D.C. 20035 Phone: 202.897.1894 [email protected] [email protected] Admitted pro hac vice

Subodh Chandra (OH Bar No. 0069233) Donald Screen (OH Bar No. 0044070) THE CHANDRA LAW FIRM LLC 1265 W. 6th St., Suite 400 Cleveland, OH 44113-1326 Phone: 216.578.1700 Fx: 216.578.1800 [email protected] [email protected] Attorneys for Plaintiff Dean Obeidallah


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CERTIFICATE OF SERVICE

I certify that I served this motion, memorandum, and all attachments thereto on Defendant

Moonbase Holdings, LLC by first class mail directed to:

Moonbase Holdings, LLC C/O Andrew B. Anglin

PO Box 208 Worthington, OH 43085

I further certify that I transmitted copies of this motion, memorandum, and all attachments

thereto to the Clerk of the Court for purpose of serving Defendant Andrew B. Anglin and the Doe

Defendants because those defendants have no known address.

DATED: January 26, 2018 /s/ Donald Screen

Subodh Chandra (OH Bar No. 0069233) THE CHANDRA LAW FIRM LLC 1265 W. 6th St., Suite 400 Cleveland, OH 44113-1326 Phone: 216.578.1700 Fx: 216.578.1800 [email protected] Attorney for Plaintiff Dean Obeidallah


Case: 2:17-cv-00720-EAS-EPD Doc #: 25-1 Filed: 01/26/18 Page: 1 of 4 PAGEID #: 380

EXHIBIT 1-A



EASTERN DIVISION

DEAN OBEIDALLAH,

Plaintiff,

v.

ANDREW B. ANGLIN, DBA Daily Stormer,

and

MOONBASE HOLDINGS, LLC, DBA Andrew Anglin,

and

JOHN DOES NUMBERS 1-10, Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

CASE NO. 2: 17-CV -00720-EAS-EPD

CHIEF JUDGE EDMUND A. SARGUS

MAGISTRATE JUDGE ELIZABETH PRESTON DEAVERS

DECLARATION OF TINA L. SCHROEDER

1. My name is Tina L. Schroeder. I am over the age of eighteen, have never been

convicted of a crime, and I am competent to make this Declaration.

2. I am the Owner and President of InfoCorp Investigative Services, LLC

("InfoCorp"), an Ohio licensed professional Private Investigation Agency (License No.

2003001173) located in Columbus, Ohio.

3. InfoCorp has been retained by the law firm of Latham & Watkins LLP on behalf

of Mr. Dean Obeidallah to coordinate service of the Defendants in certain litigation styled


Obeidallah v. Anglin, et al. in the United States District Court for the Southern District of Ohio,

Eastern Division (the "Lawsuit").

4. One of the Defendants in the Lawsuit, Moonbase Holdings, LLC ("Moonbase

Holdings"), is an Ohio for-profit limited liability corporation. A copy of Moonbase Holdings'

Articles of Organization are attached hereto as Exhibit A.

5. Moonbase Holdings' most recent and only known address is that designated in its

Articles of Organization for its statutory agent: Mr. Andrew B. Anglin, 6827 N High Street STE

121, Worthington, Ohio 43085. Mr. Anglin is also named as a defendant in the Lawsuit.

InfoCorp has made diligent and reasonable efforts to serve Moonbase Holdings through its

designated agent, Mr. Anglin, at this and the following addresses:

a. lnfoCorp investigators attempted in-person service of Moonbase Holdings

through its designated agent, Mr. Anglin, at 6827 North High Street, Suite 121, Worthington, OH

43085-2517 on September 12 and 18, 2017. InfoCorp found Mr. Anglin not to occupy this

address. InfoCorp further confrrmed through persons occupying the designated suite (Suite 121)

and surrounding office space that neither Mr. Anglin nor Moonbase Holdings are located in this

multi-unit office building.

b. InfoCorp investigators also attempted in-person service on Mr. Anglin at

four of his other last-known addresses. Mr. Anglin was not found at the addresses attempted.

6. InfoCorp, through its onsite efforts, determined that Moonbase Holdings and its

statutory agent, Mr. Anglin, cannot be found at the addresses attempted.

2


* * * * * 7. I declare under penalty of perjury that the foregoing is true and correct.

Executed in Qo/ LJ-t bu.<.::. , Ohio on I g+b of October, 2017.

Tina L. Schroeder Owner and President of InfoCorp Investigative Services, LLC

3


EXHIBIT 1-B


AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

CLERK OF COURT

Date:Signature of Clerk or Deputy Clerk

Southern District of Ohio

Dean Obeidallah

2:17-cv-00720

Andrew B. Anglin, DBA Daily Stormer, et al.

Moonbase Holdings, LLCc/o Andrew B. Anglin6827 N. High Street Suite 121Worthington, OH 43085

Subodh ChandraThe Chandra Law Firm LLCThe Chandra Law Building1265 W. 6th Street, Suite 400Cleveland, OH 44113

09/08/2017


Case: 2:17-cv-00720-EAS-EPD Doc#: 13 Filed: 09/08/17 Page: 2 of 12 PAGEID #: 110

AO 440 (Rev. 06/12} Summons in a Civil Action (Page 2}

Civil Action No. 2:17-cv-00720

PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (I))

This summons for (name of individual and title·,· if any) =JloJcL '> 1 L LC__

was received by me on (date) ___ . And.n.w 6. . 8 J J n 0 I personally served the summons on the individual at (place)

on (date) ; or

0 I left the summons at the individual's residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there, -------------------------------on (date) 'and mailed a copy to the individual's last known address; or

------------

0 I served the summons on (name of individual) , who is ---------------------------------

designated by law to accept service of process on behalf of (name of organization)

on (date) ; or ----·---------

.)(I returned the summons unexecuted because ; or

0 Other (specify):

My fees are$ for travel and $ ---------

I declare under penalty of perjury that this information is true.

Date: J I L, J l ± r ,

for services, for a total of$ 0.00

Server s signature

?: UtLO A . ProC!_tSS Printed name and title

Additional information regarding attempted service, etc:

loc&crh o(2 lDB 'L 1 +l iLvh St. , . 12-1 oH 430B'::::>


EXHIBIT 1-C


Abid R. Qureshi Direct Dial: + 1.202.637.2240 abid.qureshi@ lw.com

LATHAM&WATKI N $LLP

October 26, 2017

VIAFEDEX

Ohio Secretary of State Attn: Paralegal Division - Service of Process 180 E. Broad Street, 16th Floor Columbus, OH 43215

555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004-1304 Tel: + 1.202.637.2200 Fax:+ 1.202.637.2201 www.lw.com

FIRM I AFFILIATE OFFICES Barcelona Moscow Beijing Munich Boston New York Brussels Orange County Century City Paris Chicago Riyadh Dubai Rome Dusseldorf San Diego Frankfurt San Francisco Hamburg Seoul Hong Kong Shanghai Houston Silicon Valley London Singapore Los Angeles Tokyo Madrid Washington, D.C. Milan

Re: Request for the Ohio Secretary of State's Assistance Serving Process on Moonbase Holdings, LLC (Entity No. 3938347)

To Whom It May Concern:

I write to respectfully request the Ohio Secretary of State's assistance in serving process on Defendant Moonbase Holdings, LLC in relation to Obeidallah v. Anglin, et al., 2:17-cv-00720-EAS-EPD, a case pending in the U.S. District Court for the Southern District of Ohio. I am counsel of record for Plaintiff Dean Obeidallah in that case.

On August 16, 2017, Plaintiff Obeidallah filed a complaint in Obeidallah v. Anglin, et al. alleging multiple claims against Defendant Moonbase Holdings, LLC ("Moonbase"). Moonbase is an Ohio, for-profit limited liability corporation (Entity No. 3938347). Moonbase designates in its Articles of Incorporation (enclosed for ease of reference) that its Statutory Agent is:

Mr. Andrew B. Anglin 6827 N High Street STE 121 Worthington, Ohio 43085

On September 8, 2017, the Court in Obeidallah v. Anglin, et al. issued a summons for Defendant Moon base at its Statutory Agent's address. As explained in the enclosed affidavit, Plaintiff Obeidallah retained InfoCorp Investigative Services ("InfoCorp") to locate and serve Defendant Moonbase. Despite diligent efforts, InfoCorp was unable to locate and serve Moonbase through Mr. Anglin or any other Moonbase representative. (In addition to the designated address, InfoCorp attempted to locate and serve Mr. Anglin at four (4) of his other last-known addresses.)

I respectfully request the Ohio Secretary of State's assistance in serving process on Defendant Moonbase. Please find enclosed:


October 26, 2017 Page2

LATHAM&WATKI NSttP

1. an affidavit by Ms. Tina Schroeder, InfoCorp's owner, attesting that InfoCorp was unable to locate and serve Defendant Moonbase through Mr. Anglin;

2. four (4) copies of the Complaint and Summons in the Obeidallah v. Anglin, et al. action;

3. a copy of Defendant Moonbase's Articles of Incorporation, which appoints Mr. Anglin as Moonbase's Statutory Agent; and

4. a check for $5 to the Ohio Secretary of State.

Thank you for your assistance. We would be happy to discuss these matters with you further. Please feel free to contact me at (202) 637-2240 or [email protected].

ATKINS LLP

ENCLOSURES


EXHIBIT 1-D


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EXHIBIT 1-E


Jon Husted Ohio Secretary of State

180 East Broad Street, 16th Floor Columbus, Ohio 43215 Tel: (877) 767-6446 Fax: (614) 644-0649 www.OhloSecretaryofState.gov

Notice of Receipt

RECEIVED NOV 0 6 2011

BY: ............................. .

Date of Service: 10/31/2017 EPD

Case Number: 2:17 -CV -00720-EAS-

Dean Obeidallah VERSUS Andrew B. Anglin, eta!

The Secretary of State of Ohio received service of process, notice or demand as the statutory agent for Moonbase Holdings, LLC at 6827 N. High St., Ste 121, Worthington, . OH, 43085 under Section 1705.06 of the Ohio Revised Code. Service was forwarded via certified mail to any available address of the company and the address set forth in the affidavit.

lmf 9323

Sincerely,

Jon Husted Secretary of State



EASTERN DIVISION DEAN OBEIDALLAH,

Plaintiff,

v. ANDREW B. ANGLIN,

DBA Daily Stormer, and MOONBASE HOLDINGS, LLC,

DBA Andrew Anglin, and JOHN DOES NUMBERS 1–10,

Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

CASE NO. 2:17-CV-00720-EAS-EPD Chief Judge Edmund A. Sargus Magistrate Judge Elizabeth Preston Deavers

[PROPOSED] ENTRY OF DEFAULT AGAINST DEFENDANT MOONBASE HOLDINGS, LLC

It appearing that Defendant Moonbase Holdings, LLC is in default, having failed to plead or

otherwise defend in this cause as required by law.

Now therefore in accordance with Rule 55 of the Federal Rules of Civil Procedure, default is

hereby entered against Defendant Moonbase Holdings, LLC, this day of _____________, 2018.

________________, CLERK

By


southern district of ohio eastern division case no. … · 1/26/2018 · page 1 of 4 memorandum in...

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