2591028 Ontario Limited v. Vector Technology Systems LLC

CourtDistrict Court, D. Arizona
DecidedSeptember 14, 2021
Docket2:21-cv-01090
StatusUnknown

This text of 2591028 Ontario Limited v. Vector Technology Systems LLC (2591028 Ontario Limited v. Vector Technology Systems LLC) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
2591028 Ontario Limited v. Vector Technology Systems LLC, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 2591028 Ontario Limited, ) No. CV-21-01090-PHX-SPL ) 9 ) 10 Plaintiff, ) ORDER vs. ) ) 11 ) Vector Technology Systems LLC, et ) 12 al., ) 13 ) ) Defendants. ) 14 Before the Court are Defendants’ Motion to Set Aside Entry of Default (Doc. 21) 15 and Plaintiff’s Motion for Default Judgment (Doc. 23). Having considered the respective 16 Motions and accompanying briefings and exhibits, for the reasons stated below, the Court 17 grants Defendants’ Motion to Set Aside Entry of Default and denies Plaintiff’s Motion for 18 Default Judgment as moot. 19 I. BACKGROUND 20 On June 23, 2021, Plaintiff 2591028 Ontario Limited filed suit against Defendants 21 Vector Technology Systems, LLC, Mark Cohn, and Jane Doe (Susan) Cohn alleging 22 various counts related to a sales contract between the parties. (Doc. 1). Plaintiff served 23 Defendants on July 1, 2021 and filed proof of service on July 19, 2021. (Docs. 15–17). 24 On July 29, 2021, with no further action having been taken in the case, the Court 25 ordered Plaintiff to show cause why the action should not be dismissed for failure to 26 prosecute no later than August 6, 2021, unless a responsive pleading was filed or it applied 27 for entry of default before that date. (Doc. 18). Accordingly, on August 5, 2021, Plaintiff 28 1 filed an Application for Entry of Default (Doc. 19), and on August 6, 2021, the Clerk of 2 Court entered default against Defendants (Doc. 20). 3 On August 20, 2021, Defendants filed their Motion to Set Aside Default. (Doc. 21.) 4 On August 24, 2021, Plaintiff filed its Motion for Default Judgment. (Doc. 23.) In 5 Plaintiff’s Response opposing Defendants’ Motion, Plaintiff alternatively requested that 6 Defendants’ Motion be granted only on the condition that Defendants pay the attorneys’ 7 fees and costs incurred by Plaintiff in pursuing default judgment. (Doc. 24). 8 II. LEGAL STANDARD 9 Federal Rule of Civil Procedure (“Rule”) 55(c) directs that “[t]he court may set aside 10 an entry of default for good cause.” In determining whether good cause exists, a court must 11 consider: “(1) whether the party seeking to set aside the default engaged in culpable 12 conduct that led to the default; (2) whether it had no meritorious defense; or (3) whether 13 reopening the default judgment would prejudice the other party.” United States v. Signed 14 Personal Check No. 730 of Yubran S. Mesle, 615 F.3d 1085, 1091 (9th Cir. 2010) (internal 15 quotation marks and alterations omitted). If any one of the factors is true, the court has 16 sufficient reason to refuse to set aside the default. Id. However, the court’s discretion under 17 Rule 55(c) is “especially broad,” and the court should “resolve[ ] all doubt in favor of 18 setting aside the entry of default and deciding the case on its merits.” O’Connor v. Nevada, 19 27 F.3d 357, 364 (9th Cir. 1994). This is because “judgment by default is a drastic step 20 appropriate only in extreme circumstances; a case should, whenever possible, be decided 21 on the merits.” Mesle, 615 F.3d at 1091 (quoting Falk v. Allen, 739 F.2d 461, 463 (9th Cir. 22 1984)). 23 III. DISCUSSION 24 A. Rule 55(c) 25 The Court finds that Defendants have demonstrated good cause such that the entry 26 of default should be set aside. 27 /// 28 /// 1 i. Culpable Conduct 2 “A defendant’s conduct is culpable if he has received actual or constructive notice 3 of the filing of the action and intentionally failed to answer.” Mesle, 615 F.3d at 1092 4 (internal quotation marks and alteration omitted). Under the Mesle standard, a defendant 5 “intentionally” fails to answer when he acts with bad faith, “such as an intention to take 6 advantage of the opposing party, interfere with judicial decisionmaking, or otherwise 7 manipulates the legal process.” Id. (internal quotation marks omitted). The mere 8 “conscious choice not to answer” does not make a defendant’s conduct culpable. Id. Rather, 9 the Ninth Circuit has “typically held that a defendant’s conduct was culpable for the 10 purposes of the good cause factors where there is no explanation of the default inconsistent 11 with a devious, deliberate, willful, or bad faith failure to respond.” Id. (internal quotation 12 marks and alteration omitted). 13 Plaintiff argues under that Defendants’ conduct was culpable under the standard of 14 Franchise Holding II, LLC v. Huntington Rests. Grp., Inc., which held that a defendant’s 15 conduct is culpable if he “has received actual or constructive notice of the filing of the 16 action and failed to answer,” with no express requirement of intentionality. 375 F.3d 922 17 (9th Cir. 2004) (internal quotation marks omitted). However, in Mesle, the Ninth Circuit 18 held that the Franchise Holding II standard does not apply to a defendant who “is not a 19 lawyer” and is “unrepresented at the time of the default.” 615 F.3d at 1093. The Mesle 20 Court reasoned that “[w]hen considering a legally sophisticated party’s culpability in a 21 default, an understanding of the consequences of its actions may be assumed, and with it, 22 intentionality.” Id.; see also FOC Fin. Ltd. P’ship v. Nat’l City Com. Cap. Corp., 612 F. 23 Supp. 2d 1080, 1083 (D. Ariz. 2009) (“Franchise, insofar as it creates a rule that would 24 prevent a deserving party from setting aside default, is inconsistent with Ninth Circuit 25 policy.”). 26 Here, Defendants assert that after learning of Plaintiff’s Complaint, they “began 27 organizing their financial resources to be able to afford to retain an attorney but were unable 28 to do so before the default was entered.” (Doc. 21 at 3). Plaintiff argues that Defendants in 1 fact already had representation (Doc. 24 at 3), citing an email sent by Defendant Mark 2 Cohn to Plaintiff’s counsel on June 29, 2021 in which he stated, “We have extremely 3 limited funds. That is why we did not retain an attorney to work with you. We did retain 4 counsel to deal with the SGS claim.” (Doc. 24-1 at 11). Rather than supporting Plaintiff’s 5 argument, the email bolsters Defendants’ assertion that they did not have representation in 6 the instant matter and that their efforts to obtain representation were hindered by financial 7 difficulties. 8 The Court finds that Mesle provides the appropriate standard for culpable conduct 9 in this case. The fact that Defendants had representation in a separate matter does not 10 warrant an assumption that Defendants had “an understanding of the consequences of 11 [their] actions” in the instant case such that intentionality can be assumed. Mesle, 615 F.3d 12 at 1093. Thus, because Defendants’ hardships in obtaining counsel provide a plausible 13 explanation for their failure to respond that lacks any evidence of deviousness, willfulness, 14 or bad faith, the Court finds that Defendants did not engage in culpable conduct that led to 15 default. 16 ii. Meritorious Defenses 17 For the meritorious defense factor, a defendant seeking to set aside a default 18 judgment must merely “allege sufficient facts that, if true, would constitute a defense.” Id. 19 at 1094. This burden is “not extraordinarily heavy.” Id. (internal quotation marks omitted). 20 Here, Defendants assert three defenses: (1) Plaintiff’s Complaint fails to state a claim 21 against Defendant Mark Cohn “because it contains zero factual allegation tying him to any 22 alleged wrongdoing;” (2) Plaintiff’s Complaint “wrongly asserts claims against Mr.

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2591028 Ontario Limited v. Vector Technology Systems LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/2591028-ontario-limited-v-vector-technology-systems-llc-azd-2021.