Haldiram India P Ltd v. Punjab Trading Inc

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 HALDIRAM INDIA (P) LTD, CASE NO. 2:25-cv-01462-LK 11 Plaintiff, ORDER STRIKING MOTION FOR 12 v. EXTENSION OF TIME AND GRANTING MOTION FOR DEFAULT 14 Defendant. 15

This matter comes before the Court on Defendant Punjab Trading, Inc.’s Request for 16 Extension to Respond to Plaintiff Haldiram India (P) Ltd.’s motion for a preliminary injunction, 17 Dkt. No. 16, and Haldiram’s motion for entry of default against Punjab, Dkt. No. 18. For the 18 reasons set forth below, the Court strikes the motion for an extension and grants the motion for 19 default. 20 21 A. The Court Strikes the Motion for an Extension Punjab requests an extension of its September 10 deadline to respond to the motion for a 22 preliminary injunction because it is “currently consulting with attorneys to represent [it] regarding 23 this matter.” Dkt. No. 16 at 1. Punjab’s motion is not properly before the Court. Business entities 24 1 other than sole proprietorships must be represented by counsel and cannot proceed pro se. See 2 Rowland v. Cal. Men’s Colony, 506 U.S. 194, 201–02 (1993); LCR 83.2(b)(4) (“A business entity, 3 except a sole proprietorship, must be represented by counsel.”). Here, no counsel has appeared on 4 Punjab’s behalf, and the motion is signed by an individual who does not identify themselves by

5 name or as an attorney. Dkt. No. 16 at 2. A non-attorney cannot act as counsel for a business entity. 6 See Omni Innovations, LLC v. Ascentive, LLC, No. C06-1284-JCC, 2008 WL 11506654, at *1 7 (W.D. Wash. Apr. 30, 2008). The Court therefore strikes the pro se motion, Dkt. No. 16. 8 B. The Court Grants the Motion for Default 9 Haldiram moves for entry of default against Punjab because it has failed to plead or 10 otherwise defend. Dkt. No. 18 at 2; see also Fed. R. Civ. P. 55(a). Haldiram served Punjab on 11 August 15, 2025. Dkt. No. 7 at 2–4 (Affidavit of Service on Kulwant Singh); see also Washington 12 State Office of the Secretary of State Corporations & Charities Division, Corporation Search 13 Result for Punjab Trading, Inc., https://ccfs.sos.wa.gov (last visited September 19, 2025) (listing 14 Kulwant Singh as a Governor and Registered Agent of Punjab); Fed. R. Civ. P. 4(h)(1)(B). Punjab

15 was therefore required to respond to the complaint by September 5, 2025, Fed. R. Civ. P. 16 12(a)(1)(A)(i), but Punjab has failed to plead or otherwise defend. It has not filed an answer or a 17 response to Haldiram’s motion for a preliminary injunction, and as set forth above, its pro se 18 motion is not properly before the Court. In addition, the Local Civil Rules provide that a business 19 entity that is not represented by counsel may face “entry of default against the business entity as 20 to any claims of other parties.” LCR 83.2(b)(4). Accordingly, the Court grants the motion for 21 default. 22 For the foregoing reasons, the Court STRIKES the motion for an extension, Dkt. No. 16, 23 and GRANTS the motion for entry of default, Dkt. No. 18. The Court directs the Clerk to enter

24 this default in the docket and mail copies of this Order to (1) Punjab Trading, Inc. at 4710 B Street 1 NW, Unit 103, Auburn, WA, 98001, and to (2) Kulwant Singh at 12722 SE 295th Street, Auburn, 2 WA, 98092. Haldiram is reminded that any motion for default judgment must comply with Section 3 VIII of this Court’s Standing Order for all Civil Cases. Dkt. No. 5-1 at 6. 4 Dated this 19th day of September, 2025.

5 A 6 Lauren King United States District Judge 7

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