Honeedew Investing LLC v. Abadi

CourtDistrict Court, S.D. New York
DecidedApril 11, 2025
Docket1:19-cv-08951
StatusUnknown

This text of Honeedew Investing LLC v. Abadi (Honeedew Investing LLC v. Abadi) 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
Honeedew Investing LLC v. Abadi, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK wee KX HONEEDEW INVESTING LLC, Plaintiff, : -V- 19 Civ. 8951 (JPC) CARLOS ANDRES ABADI, et al., ORDER Defendants.

JOHN P. CRONAN, United States District Judge: On April 11, 2025, the Court received an email from an individual representing to be Defendant Carlos Andres Abadi. This email enclosed a letter, which is attached to this Order, submitted on behalf of the substituted Defendants in this action. In light of this development, the April 16, 2025 default judgment hearing is adjourned sine die. Plaintiff shall file a response to the contents of Mr. Abadi’s letter by April 18, 2025. SO ORDERED. Dated: April 11, 2025 New York, New York JOHN P. CRONAN United States District Judge

CARLOS ABADI

20 Gretchen Ct. Oldsmar, FL 34677 Tel: (917)309-5588 Email: carlosandresabadi@gmail.com April 11, 2025 BY ELECTRONIC MAIL (CronanNYSDChambers@nysd.uscourts.gov) The Honorable John P. Cronan United States District Judge Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street, Courtroom 12D New York, NY 10007 Re: Honeedew Investing LLC v. Francia Luisa Guthmann, et al. Civil Action No.: 19-CV-8951-(JPC) Letter Motion to Dismiss Default Judgment Application and Request for Evidentiary Hearing on Rule 25(a)(1) Compliance Dear Judge Cronan: I respectfully submit this letter motion on behalf of my mother, Francia Luisa Guthmann, and my siblings, Miguel Claudio Abadi and Yvonne Abadi (collectively, the "Substituted Defendants") in the above-referenced matter. While I am not an attorney, I am intimately familiar with the facts of this case, as I am the son of the late Jose Abadi (the original defendant) and Francia Luisa Guthmann, and brother to Miguel and Yvonne. The Substituted Defendants cannot afford U.S. counsel due to financial constraints, and I respectfully request that the Court accept this pro se submission on their behalf. This letter addresses threshold procedural defects that preclude entry of default judgment and indeed require dismissal of the entire action against the Substituted Defendants. Most critically, documentary evidence demonstrates that Plaintiff Honeedew Investing LLC ("Plaintiff") received notice of my father Jose Abadi's death on April 30, 2023—more than six months before filing its Rule 25(a)(1) substitution motion—directly contradicting counsel's sworn declaration to this Court. FACTUAL BACKGROUND My father, Jose Abadi, passed away on April 30, 2023. On that same day, my then-counsel, Mr. David G. Liston, explicitly informed Plaintiff's counsel via email that "Jose Abadi, the father of our client, Carlos Abadi, passed away early this morning." This email was addressed directly to Plaintiff's counsel, Mr. Eric S. Medina, and was also filed with the New York Supreme Court in related proceedings (Honeedew Investing LLC v. Carlos & Barbara Abadi, Index No. 652654/2017). A true and correct copy of this email is attached as Exhibit A. Despite this contemporaneous written notice, Mr. Medina submitted a sworn declaration to this Court on March 7, 2025 stating: "In November of 2023, Plaintiff learned that Jose Abadi had passed away." Medina Declaration ¶17. This representation, made under penalty of perjury pursuant to 28 U.S.C. §1746, is demonstrably false based on the April 30, 2023 email. LEGAL ARGUMENT I. The Substitution Motion Was Untimely and Must Be Dismissed Federal Rule of Civil Procedure 25(a)(1) provides that "[i]f a party dies and the claim is not extinguished, the court may order substitution of the proper party. A motion for substitution may be made by any party or by the decedent's successor or representative. If the motion is not made within 90 days after service of a statement noting the death, the action by or against the decedent must be dismissed." (emphasis added). The Second Circuit has consistently held that the 90-day time limit in Rule 25(a)(1) is strictly enforced. See Unicorn Tales, Inc. v. Banerjee, 138 F.3d 467, 470 (2d Cir. 1998) (affirming dismissal where motion for substitution was filed after the 90-day deadline); Kernisant v. City of New York, 225 F.R.D. 422, 431 (E.D.N.Y. 2005) (noting "Rule 25(a) does not authorize a district court to extend [the 90-day] time period once it has expired"). Here, Plaintiff received actual notice of my father's death on April 30, 2023, yet did not file its substitution motion until November 6, 2023 [Dkt. 80-83]—189 days later, more than twice the permitted time period. This delay mandates dismissal under the express terms of Rule 25(a)(1). II. The Court Should Vacate Its Prior Substitution Order as Based on Material Misrepresentations The Court's July 15, 2024 Order [Dkt. 94] granting substitution was issued without the benefit of the crucial information regarding the actual timing of Plaintiff's notice of my father's death. Courts have inherent authority to vacate orders obtained through misrepresentations to the Court. See Chambers v. NASCO, Inc., 501 U.S. 32, 44 (1991) (recognizing courts' inherent power to vacate judgments obtained through fraud upon the court). The material discrepancy between the April 30, 2023 email and the Medina Declaration strongly suggests that the Court's substitution order was procured through a misrepresentation that concealed the untimeliness of the substitution motion. As such, the Court should exercise its inherent authority to vacate that order. III. At Minimum, the Court Should Hold an Evidentiary Hearing on Compliance with Rule 25(a)(1) Given the documentary evidence contradicting Mr. Medina's sworn declaration, at minimum, due process requires a hearing to determine when Plaintiff first received notice of my father's death. See In re Currency Conversion Fee Antitrust Litig., 361 F. Supp. 2d 237, 246 (S.D.N.Y. 2005) (holding that "serious disputes about material facts... require an evidentiary hearing"). The chronology of notice is a threshold jurisdictional issue that must be resolved before any default judgment could properly be entered. IV. Service of the Substitution Motion Was Procedurally Defective Rule 25(a)(3) requires that a motion to substitute "must be served on the parties as provided in Rule 5 and on nonparties as provided in Rule 4." Here, service on the Substituted Defendants, who were nonparties at the time, required compliance with Rule 4, including adherence to the Hague Convention for international service. While Plaintiff eventually effected Hague Convention service on August 29, 2024 [Dkt. 106], this service occurred after the Court had already granted the substitution motion—rendering it ineffective for purposes of the original motion. The alternative methods of service relied upon by Plaintiff—including FedEx and "Carta Documento"—do not satisfy Rule 4's requirements for service in Argentina. See Volkswagenwerk Aktiengesellschaft v. Schlunk, 486 U.S. 694, 705 (1988) (holding that when service is to be effected in a foreign country that is a signatory to the Hague Convention, the Convention's procedures are mandatory). REQUESTED RELIEF For the foregoing reasons, the Substituted Defendants respectfully request that the Court: 1. Deny Plaintiff's pending Motion for Default Judgment; 2.

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Related

Volkswagenwerk Aktiengesellschaft v. Schlunk
486 U.S. 694 (Supreme Court, 1988)
Chambers v. Nasco, Inc.
501 U.S. 32 (Supreme Court, 1991)
In Re Currency Conversion Fee Antitrust Litigation
361 F. Supp. 2d 237 (S.D. New York, 2005)
Unicorn Tales, Inc. v. Banerjee
138 F.3d 467 (Second Circuit, 1998)
Kernisant v. City of New York
225 F.R.D. 422 (E.D. New York, 2005)

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Honeedew Investing LLC v. Abadi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/honeedew-investing-llc-v-abadi-nysd-2025.