Ausloos v. Binkele

District Court, D. Nevada·Decided November 15, 2022·No. 2:22-cv-00372·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 ADAM AUSLOOS, Case No.: 2:22-cv-00372-APG-DJA

4 Petitioner ORDER (1) GRANTING MOTION TO QUASH SERVICE, (2) DENYING 5 v. MOTION TO DISMISS, (3) DENYING MISFILED MOTION, (4) DEEMING 6 ROBERT J. BINKELE and ESTATE ORDER TO SHOW CAUSE SATISFIED, PLANNING TEAM, INC., and (5) REQUIRING AUSLOOS TO 7 PROPERLY SERVE THE Respondents RESPONDENTS 8 [ECF Nos. 11, 13, 17] 9

11 Petitioner Adam Ausloos moves to vacate an arbitration award against him and in favor 12 of respondents Robert Binkele and Estate Planning Team, Inc (EPT). Binkele moves to quash 13 service and dismiss the action, maintaining that the purported service of process on his wife, 14 Kelly Binkele, never occurred. Ausloos contends that Mrs. Binkele was served and that service 15 on her is sufficient to serve the respondents. He also asserts that Mr. Binkele impermissibly 16 moves to dismiss the case on behalf of EPT. 17 I previously ordered Ausloos to show cause why this case should not be dismissed for 18 lack of subject matter jurisdiction because his state citizenship was in question. ECF No. 27. 19 Ausloos provided evidence that the parties are diverse. ECF Nos. 28; 28-1; 28-2. I thus deem the 20 order to show cause satisfied and will exercise jurisdiction over this case. 21 I grant the motion to quash service because Ausloos’ return of service is deficient, and he 22 offers no other admissible evidence proving proper service. I deny the motion to dismiss 23 1 because I will grant Ausloos additional time to properly serve the respondents. I deny ECF No. 2 17 because it is an affidavit misfiled as a motion. 3 I. ANALYSIS 4 “A federal court does not have jurisdiction over a defendant unless the defendant has

5 been served properly under Fed. R. Civ. P. 4.” Direct Mail Specialists, Inc. v. Eclat 6 Computerized Techs., Inc., 840 F.2d 685, 688 (9th Cir. 1988). If a defendant is not properly 7 served under Rule 4, he can assert the defense of insufficient service of process under Federal 8 Rule of Civil Procedure 12(b)(5). While “Rule 4 is a flexible rule that should be liberally 9 construed so long as a party receives sufficient notice of the complaint,” the serving party must 10 substantially comply with the rule. Crowley v. Bannister, 734 F.3d 967, 975 (9th Cir. 2013) 11 (quotation omitted). The serving plaintiff bears the burden of establishing that a challenged 12 service was valid. Brockmeyer v. May, 383 F.3d 798, 801 (9th Cir. 2004). 13 A signed return of service constitutes prima facie evidence of valid service. S.E.C. v. 14 Internet Sols. for Bus. Inc., 509 F.3d 1161, 1166 (9th Cir. 2007). However, a vague return is

15 insufficient. See Homer v. Jones-Bey, 415 F.3d 748, 753 (7th Cir. 2005) (noting that several 16 federal courts “have held vague returns . . . to be inadequate”). Parties may support their 17 positions on a Rule 12(b)(5) motion with affidavits and other evidence, but those documents 18 must comply with the Federal Rules of Evidence. See, e.g., Travelers Cas. & Sur. Co. v. Telstar 19 Constr. Co., 252 F. Supp. 2d 917, 922-23 (D. Ariz. 2003) (collecting cases); Worthen v. 20 Aftermath, Inc., No. 2:11-cv-00344-RLH-CWH, 2011 WL 5239986, at *2 n.3 (D. Nev. Oct. 31, 21 2011). I have discretion to dismiss the action or quash service if service is insufficient. S.J. v. 22 Issaquah Sch. Dist. No. 411, 470 F.3d 1288, 1293 (9th Cir. 2006). 23 1 The parties agree that service may be made according to the law in Nevada (where this 2 judicial district is located) or California (where service allegedly occurred).1 See Fed. R. Civ. P. 3 4(e)(1), 4(h)(1)(A). However, they dispute whether service occurred or otherwise complied with 4 the rules. Ausloos asserts that Van Wilcox, a process server, personally served Mrs. Binkele on

5 March 12, 2022. He claims that he subsequently sent case filings via UPS as a precaution to 6 comply with California law, but that Mrs. Binkele’s personal service complied with Nevada law. 7 As proof of service, Ausloos offers an affidavit from Wilcox stating that Wilcox “served the 8 above-described documents in the above-entitled matter upon Kelly Binkele [a]gent for Robert 9 Binkele.” ECF No. 10. Ausloos also offers his own declaration wherein he outlines Wilcox’s 10 efforts to serve the respondents and Mrs. Binkele. ECF No. 18-1. 11 Mr. Binkele argues that service on Mrs. Binkele never occurred, and that Wilcox’s return 12 of service is defective. He submits a declaration from Mrs. Binkele stating she has never met 13 Wilcox and was not served by him. ECF No. 14. She claims she only received relevant 14 documents one week later, when “some filings” were delivered via UPS. Id. at 2. Mr. Binkele

15 also offers a photo of the UPS package and a still image from a doorbell camera depicting the 16 UPS delivery person. ECF Nos. 14-1 at 2; 14-2 at 2. 17 A. In-Person Service on March 12, 2022 18 In Nevada, a party may serve an individual out of state “by leaving a copy of the 19 summons and complaint at the individual’s dwelling or usual place of abode with a person of 20 suitable age and discretion who currently resides therein and is not an adverse party to the 21 individual being served.” Nev. R. Civ. P. 4.2(a)(2), 4.3(a)(1). Service may be made on a 22

23 1 Ausloos does not reference the Federal Rules of Civil Procedure in his response brief, but he argues that he complied with the Nevada and California rules. 1 corporate entity by serving an officer of the corporation. Nev. R. Civ. P. 4.2(c)(1)(A), 4.3(a)(3). 2 Mr. Binkele does not dispute that the Binkeles reside together or that Mrs. Binkele is of 3 suitable age and discretion. And Ausloos offers unrefuted evidence that Mrs. Binkele is an 4 officer of EPT. ECF No. 18-2 at 1-3. Thus, proper personal service on her could constitute

5 service on the respondents under Nevada law. 6 However, Ausloos has not met his burden of proving personal service on Mrs. Binkele. 7 Wilcox’s affidavit is defective because it fails to disclose enough facts to demonstrate valid 8 service. Wilcox says he served “the above-described documents,” but no documents are 9 described other than the document title: “motion to vacate arbitration award.”2 ECF No. 10 at 1- 10 2. A return of service mistitled as a motion to vacate is insufficient to prove that the motion to 11 vacate was served. The affidavit does not identify any other documents served on Mrs. Binkele, 12 nor does it detail the manner of service beyond a statement that Wilcox left the unspecified 13 documents with “Kelly Binkele [a]uthorized to accept service.” Id. at 2. It also fails to clearly 14 state which respondent Wilcox intended to serve by serving Mrs. Binkele. The return of service

15 is therefore too vague to qualify as prima facie evidence of sufficient service of process.

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