Edward B. Hubbuch v. Mullooly, Jeffrey, Rooney & Flynn LLP et al.

CourtDistrict Court, S.D. New York
DecidedSeptember 8, 2025
Docket1:25-cv-05547
StatusUnknown

This text of Edward B. Hubbuch v. Mullooly, Jeffrey, Rooney & Flynn LLP et al. (Edward B. Hubbuch v. Mullooly, Jeffrey, Rooney & Flynn LLP et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edward B. Hubbuch v. Mullooly, Jeffrey, Rooney & Flynn LLP et al., (S.D.N.Y. 2025).

Opinion

DOCUMENT ELECTRONICALLY FILED DOC 2: UNITED STATES DISTRICT COURT DATE FILED: 9/8/2025 SOUTHERN DISTRICT OF NEW YORK EDWARD B. HUBBUCH, 29-CV-5547 (JAR) (BCM) Plaintiff, MEMORANDUM AND ORDER RE: -against- (1) MOTION FOR DEFAULT; AND (2) MOTION TO VACATE DEFAULT MULLOOLY, JEFFREY, ROONEY & FLYNN LLP et al., Defendant.

BARBARA MOSES, United States Magistrate Judge. Plaintiff Edward B. Hubbuch, proceeding pro se, commenced this action on July 2, 2025, against a law firm, Mullooly, Jeffrey, Rooney & Flynn LLP (MJRF); a lawyer, Amy Gavlik (Gavlik); and a bank, JP Morgan Chase Bank, N.A. (Chase). Plaintiff alleges that defendants violated the Fair Credit Reporting Act, the Fair Debt Collection Practices Act (FDCPA), and state law in connection with a collection action filed against plaintiff in state court a few months earlier. On August 7, 2025 — 23 days after plaintiff served MJRF with process in this action — he obtained a certificate of default pursuant to Fed. R. Civ. P. 55(a) and filed a motion for a default judgment against MJRF pursuant to Fed. R. Civ. P. 55(b)(2). (Dkt. 23.) Five days later, MJRF filed a motion to vacate the default pursuant to Fed. R. Civ. P. 55(c). (Dkts. 33, 34.) For the reasons that follow, defendant's vacatur motion will be granted, thereby mooting plaintiff's default motion. I. BACKGROUND On April 14, 2025, defendant Chase, represented by MJRF, filed a lawsuit in Kings County Civil Court to collect a credit card debt allegedly owed by plaintiff to Chase. See Compl. (Dkt. 1) {| 11. Two and a half months later — with the Kings County case pending — plaintiff filed this action, alleging that defendants provided untimely and insufficient responses to a Demand for a Bill of Particulars that he served in state court, see id. □□ 11-14, 19-20, & Exs. D-E, and failed to respond to his requests for clarification. /d. J 15. Plaintiff further alleges that Chase reported his account to

credit bureaus as "charged off," without "any indication that the debt was being actively litigated or formally disputed," id. ¶ 17, and refused to correct that tradeline despite demand from plaintiff. Id. ¶¶ 18, 29. Plaintiff adds that MJRF sent him a debt collection letter on June 17, 2025, signed by MJRF attorney Gavlik, that did not comply with the FDCPA. Id. ¶¶ 22-23 & Ex. H. Taken together, plaintiff alleges, these acts "reflect a systemic abuse of process: weaponizing the court

system and federal credit reporting infrastructure not to resolve a valid claim, but to coerce informal settlement through intimidation, reputational damage, and procedural attrition." Id. ¶ 30. Plaintiff served MJRF with a summons and his federal complaint on July 15, 2025, via the New York Secretary of State (see Dkt. 8), in accordance with N.Y.C.P.L.R. (CPLR) § 306 and Fed. R. Civ. P. 4(h)(1)(A), making MJRF's answer or other response to the complaint due August 5, 2025. See Fed. R. Civ. P. 12(a)(1)(A)(i), 12(b). Plaintiff served Gavlik on July 18, 2025 (Dkt. 13), making her response due August 8, 2025. Plaintiff served Chase on July 22, 2025 (Dkt. 12), making its response due August 12, 2025. However, with plaintiff's consent, the Court extended Chase's time to respond to the Complaint to September 11, 2025. (Dkt. 29.)

On August 6, 2025 – one day after MJRF's response was due – plaintiff submitted a declaration requesting a certificate of default against it. (Dkt. 17.)1 On August 7, 2025 – two days after MJRF's response was due – attorney Robert Arleo appeared on its behalf (Dkt. 18) and submitted a letter "in opposition to the attempt by the Plaintiff to obtain a default judgment against MJRF[.]" (Dkt. 19.) In that letter, attorney Arleo asserted (incorrectly) that MJRF had "30 days" from the date of service (that is, another seven days) to respond to the complaint. At 3:37 p.m. on August 7, 2025, plaintiff again submitted a declaration requesting a certificate of default against

1 The Clerk of Court did not process plaintiff's August 6 request, likely because plaintiff failed to include "a proposed 'Clerk's Certificate of Default,' in a form prescribed by the clerk," as required MJRF (Dkt. 21), this time accompanied by a proposed certificate. (Dkt. 20.) The Clerk issued the certificate at 3:43 p.m. the same day. (Dkt. 22.) 2 At 10:33 p.m. that night, plaintiff filed his motion for a default judgment, writing that MJRF's "refusal to engage in this litigation" reflects "a calculated effort to default strategically and prevent Plaintiff from uncovering the full scope of its abusive operations." Default Mot. ¶ 3.

Plaintiff noted that "as of the date of this filing" (that is, six hours and 50 minutes after the entry of default), MJRF had "still not filed any responsive pleading, motion, or application to cure its procedural default." Id. ¶ 6.3 Therefore, plaintiff argued, the Court "is empowered, and indeed compelled, to enter judgment in favor of Plaintiff to vindicate the rule of law, deter future misconduct, and ensure that entities like MJRF LLP are not permitted to exploit the judicial system through silence and evasion." Id. ¶ 16. Plaintiff requested $1,000 in statutory damages and $75,000 in actual damages under the FDCPA; $225,000 in punitive damages under state law; costs; and declaratory relief. Id. ¶ 26. On August 8, 2025 – the date on which Gavlik was required to respond to the complaint –

Gavlik and MJRF filed a joint motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(1), arguing that plaintiff lacks Article III standing to sue, see U.S. Const. Art. III, § 2, in that he has not alleged any "concrete injury" flowing from defendants' alleged violations of federal and state law. Mem.

2 This was a ministerial act. See Fed. R. Civ. P. 55(a) ("[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend . . . , the clerk must enter the party's default." Thus, as the Second Circuit explained in Bricklayers & Allied Craftworkers Loc. 2, Albany, N.Y. Pension Fund v. Moulton Masonry & Const., LLC, 779 F.3d 182 (2d Cir. 2015), the entry of default, upon receipt of the proper documents, is "not discretionary." Id. at 186. 3 See also Default Mot. ¶ 12 (MJRF "has made no meaningful effort to cure the default or participate in the litigation."); id. ¶ 16 (MJRF's "failure to respond or move to vacate the default – despite having actual notice and retaining counsel – constitutes a willful abandonment of its procedural obligations."); id. ¶ 25 (MJRF's "deliberate refusal to engage with this litigation, despite clear notice and opportunity, leaves the Court with no alternative but to grant full relief as requested."). in Supp. of Mot. to Dismiss (Dkt. 28) at 2-8. On August 10, 2025, plaintiff filed an affirmation arguing that the motion should be stricken, insofar as it was filed on behalf of MJRF, because it is "well-settled" that a defaulted defendant is "not entitled to participate in this action unless and until the default is set aside." (Dkt.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Edward B. Hubbuch v. Mullooly, Jeffrey, Rooney & Flynn LLP et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-b-hubbuch-v-mullooly-jeffrey-rooney-flynn-llp-et-al-nysd-2025.