Northwest Administrators Inc v. National Convention Services LLC

CourtDistrict Court, W.D. Washington
DecidedMarch 3, 2023
Docket2:22-cv-01519
StatusUnknown

This text of Northwest Administrators Inc v. National Convention Services LLC (Northwest Administrators Inc v. National Convention Services LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Northwest Administrators Inc v. National Convention Services LLC, (W.D. Wash. 2023).

Opinion

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3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE

9 10 NORTHWEST CASE NO. C22-1519JLR ADMINISTRATORS, INC., 11 MINUTE ORDER Plaintiff, 12 v.

13 NATIONAL CONVENTION SERVICES, LLC, 14 15 Defendant.

16 The following minute order is made by the direction of the court, the Honorable 17 James L. Robart: 18 Before the court is a purported answer to Plaintiff Northwest Administrators, 19 Inc.’s complaint filed by James Angelino on behalf of Defendant National Convention 20 Services, LLC (“NCS”). (Pro Se Ans. (Dkt. # 10).) Mr. Angelino, the president and 21 owner of NCS, represents that he is appearing pro se. (See id. at 4.) 22 1 “While a non-attorney may appear pro se on his own behalf, ‘[h]e has no authority 2 to appear as an attorney for others than himself.’” Johns v. Cty. of San Diego, 114 F.3d

3 874, 877 (9th Cir. 1997) (quoting C.E. Pope Equity Tr. v. United States, 818 F.2d 696, 4 697 (9th Cir. 1987)). A corporation or other artificial entity, such as a limited liability 5 company (“LLC”), must be represented by licensed counsel. See, e.g., Rowland v. Cal. 6 Men’s Colony, 506 U.S. 194, 201-202 (1993) (“It has been the law for the better part of 7 two centuries . . . that a corporation may appear in federal courts only through licensed 8 counsel . . . . [T]hat rule applies equally to all artificial entities.”); Licht v. Am. W.

9 Airlines, 40 F.3d 1058, 1059 (9th Cir. 1994) (“Corporations and other unincorporated 10 associations must appear in court through an attorney.”); see also Local Rules W.D. 11 Wash. LCR 83.2(b)(4) (“A business entity, except a sole proprietorship, must be 12 represented by counsel.”). A business entity that fails to appear in federal court 13 proceedings through counsel may have default and default judgment entered against it.

14 See United States v. High Country Broad. Co., 3 F.3d 1244, 1245 (9th Cir. 1993) (“When 15 [defendant corporation] failed to . . . [retain counsel], the district court entered default 16 judgment against it; this was perfectly appropriate.”). 17 Because NCS is an LLC, Mr. Angelino cannot represent it in this court. Rather, 18 NCS must obtain counsel if it wishes to defend itself in this litigation. See Local Rules

19 W.D. Wash. LCR 83.1 (setting forth the requirements for admission to practice in this 20 court). Accordingly, the court STRIKES the purported answer filed by Mr. Angelino 21 (Dkt. # 10). 22 1 Filed and entered this 3rd day of March, 2023. 2 RAVI SUBRAMANIAN Clerk of Court 3 s/ Ashleigh Drecktrah 4 Deputy Clerk

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Northwest Administrators Inc v. National Convention Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/northwest-administrators-inc-v-national-convention-services-llc-wawd-2023.