Doe v. Zugress Security Services, Inc.

• Court: District Court, E.D. Missouri
• Decided: August 12, 2025
• Docket: 4:17-cv-02303
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JANE DOE, ) ) Plaintiff, ) v. ) Case No. 4:17-cv-02303-SNLJ ) ZUGRESS SECURITY SERVICES, INC., ) and HASAN TAHIROVIC, ) ) Defendants. )

MEMORANDUM AND ORDER

This closed case is before the Court on a Motion to Seal or, in the alternative, to Redact Court Records and Memorandum in Support filed by Dennis Tahirovic. [Docs. 38, 39]. Dennis Tahirovic did not sign the pleading as an attorney but claims he is acting on behalf of his father, Hasan Tahirovic, under a durable power of attorney. [Doc. 38]. For the reasons stated below, the motion and memorandum are stricken. Dennis Tahirovic cannot represent another person in federal court unless he is a licensed attorney, even if he has power of attorney. Ali on behalf of Alexander v. Kismal, 4:21-CV-640 JAR, 2021 WL 2588874 (E.D. Mo. June 24, 2021). A non- attorney may not represent another person in federal court. See 28 U.S.C. § 1654 “[i]In all courts of the United States the parties may plead and conduct their own cases personally or by counsel …”); Lewis v. Lenc–Smith Mfg. Co., 784 F.2d 829, 830 (7th Cir. 1986) (stating that a person who is not licensed to practice law may not represent another individual in federal court).

Under Missouri law, a non-attorney representing another person in court is engaged in the unauthorized practice of law, which can carry criminal penalties. See § 484.020 RSMo. The practice of law is defined to include “the appearance as an advocate in a representative capacity or the drawing of papers, pleadings or

documents or the performance of any act in such capacity in connection with proceedings pending or prospective before any court of record.” § 484.010 RSMo. Missouri law further provides, “No person shall engage in the practice of law or do law business, as defined in section 484.010, or both, unless he shall have been duly

licensed therefor and while his license therefor is in full force and effect.... Any person, association, partnership, limited liability company or corporation who shall violate the foregoing prohibition of this section shall be guilty of a misdemeanor.” § 484.020 RSMo.

Additionally, Federal Rule of Civil Procedure 11(a) requires an unrepresented party to personally sign all of his pleadings, motions, and other papers, and requires courts to “strike an unsigned paper unless the omission is promptly corrected after being called to the ... party's attention.” Fed. R. Civ. P. 11(a). Similarly, the local rules of this Court also require that a self-represented party sign all filings. See E.D.

Mo. L.R. 2.01(A)(1). IT IS HEREBY ORDERED that the Motion to Seal or, in the alternative, to Redact Court Records and the Memorandum in Support filed by Dennis Tahirovic [Docs. 38, 39] are STRICKEN. SO ORDERED this 12th day of August, 2025.

fe : magi ia 4 fp KLIAG. . Fomine STEPHEN N. LIMBAUGH, JR. / SENIOR UNITED STATES DISTRICT JUDGE