UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
AROR-ARK ARK O’DIAH,
Plaintiff,
v. Civil Action No. 25-cv-2220 (TSC)
UNITED STATES DEPARTMENT OF JUSTICE, et al.,
Defendants.
OPINION AND ORDER
On July 14, 2025, Plaintiff Aror-Ark Ark O’Diah, proceeding pro se, sued over eighty
Defendants, including the Chief Justice of the United States Supreme Court, the Attorney General,
the U.S. Attorney for the District of Columbia, several banking institutions and businesses, the
New York state government and its agencies, attorneys, and other civilians. See Compl. at 1–2,
ECF No. 1 (“Compl.”). In his Complaint, Plaintiff alleged a “far-reaching conspiracy” wherein
“Defendants acted in concert to defame him, deny him access to credit lines and business loans,
subject him to thirty-one false arrests, and even to murder his late wife.” Mem. Op. at 1, ECF No.
92. Numerous Defendants moved to dismiss. See ECF Nos. 7, 8, 10, 16, 18, 22, 25, 27, 31, 38,
42, 47, 60, 73, 75, 77, 83, 84. On September 24, 2025, the court granted those motions and
dismissed the Complaint sua sponte as to all other Defendants because it was “patently obvious”
Plaintiff could not prevail based on the facts alleged. Mem. Op. at 3. Plaintiff now moves for
relief from this court’s Opinion, see First Mot. for Recon., ECF No. 94, and accompanying Order,
see Second Mot. for Recon., ECF No. 96. Because Plaintiff fails to proffer any valid ground for
his requested relief, his Motions for Reconsideration are DENIED.
Page 1 of 5 Plaintiff’s motions invoke Federal Rule of Civil Procedure 60(a) and (b). First Mot. for
Recon. at 2, 4; Second Mot. for Recon. at 2, 4. Rule 60 permits relief from a final judgment for
“clerical” issues as well as:
(1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b); (3) fraud . . . misrepresentation, or misconduct by an opposing party; (4) the judgment is void; (5) the judgment has been satisfied, released, or discharged; it is based on an earlier judgment that has been reversed or vacated; or applying it prospectively is no longer equitable; or (6) any other reason that justifies relief.
Fed. R. Civ. P. 60(a)–(b). In considering a Rule 60(b) motion, courts “must strike a delicate
balance between the sanctity of final judgments . . . and the incessant command of a court’s
conscience that justice be done in light of all the facts.” People for the Ethical Treatment of
Animals v. U.S. Dep’t of Health & Hum. Servs., 901 F.3d 343, 354–55 (D.C. Cir. 2018) (internal
quotations and citation omitted).
Notably, Plaintiff does not point to any clerical mistake, oversight, or omission, as required
for relief under Rule 60(a). See First Mot. for Recon. at 2–8; Second Mot. for Recon. at 2–8. That
leaves only relief under Rule 60(b). It is well-established, however, that Rule 60(b) is “not simply
an opportunity to reargue facts and theories upon which a court has already ruled.” Black v.
Tomlinson, 235 F.R.D. 532, 533 (D.D.C. 2006) (quoting New York v. United States, 880 F. Supp.
37, 38 (D.D.C. 1995)). Yet this is precisely what Plaintiff attempts to do, compare Compl. at 6–
21 with First Mot. for Recon. at 2–8 and Second Mot. for Recon. at 2–8. While Plaintiff’s motions
invoke the words “newly discovered evidence,” “fraud,” and “void,” see First Mot. for Recon. at
2–8; Second Mot. for Recon. at 2–8, he merely realleges the same “far-reaching conspiracy” that
the court already dismissed, see Mem. Op. at 1, 3. As another judge explained in rejecting a similar
motion for reconsideration by Plaintiff, his “allegations are neither new nor evidence,” Min Ord.,
O’Diah v. Moss, No. 24-cv-2736 (D.D.C. July 24, 2025) (denying Plaintiff’s Rule 60(b) motion
Page 2 of 5 raising purportedly newly discovered evidence of judicial misconduct). “Instead, they simply
rehash the earlier irrational and far-fetched claims that have been dismissed by the Court . . . and
amount to mere conjecture and unsupported assertions.” Id. (internal quotations and citations
omitted).
Plaintiff alternatively seeks leave to file an Amended Complaint. See First Mot. for Recon.
at 4, 5; 8; Second Mot. for Recon. at 4, 5, 8. While a court “should freely give leave when justice
so requires,” Fed. R. Civ. P. 15(a)(2), particularly where a plaintiff proceeds pro se, see Moore v.
Agency for Int’l Dev., 994 F.2d 874, 877 (D.C. Cir. 1993), it should not do so where amendment
would be futile, would result in undue delay or prejudice, is motivated by bad faith or a dilatory
motive, or follows a “repeated failure to cure deficiencies by previous amendments.” Onyewuchi
v. Gonzalez, 267 F.R.D. 417, 420 (D.D.C. 2010). Here, Plaintiff has not attached an Amended
Complaint to his motion for leave to file, as required under the court’s Local Rules. See LCvR
7(i); see also LCvR 15.1. This is independently fatal to Plaintiff’s request. See Friends of Animals
v. Pruitt, 258 F. Supp. 3d 91, 93 (D.D.C. 2017) (noting that “[t]he Court of Appeals has repeatedly
faulted litigants for the shortcoming of failing to attach a copy of their proposed amended
complaint to a motion for leave to file an amended complaint” (cleaned up)). But even if the court
were to overlook this defect, it is not convinced that any amendment would be in good faith and
otherwise not futile.
As the court previously observed, Plaintiff’s Complaint “re-allege[d] many of the same
claims that another court in this district recently dismissed.” Mem. Op. at 2 (citing Order at 1,
O’Diah v. Moss, No. 24-cv-2736 (D.D.C. June 2, 2025)). Indeed, it appears that this case is the
latest in a pattern of frivolous and vexatious litigation initiated by Plaintiff. See O’Diah v. United
States, No. 25-cv-4195, 2026 WL 91981, at *1 (D.D.C. Jan. 13, 2026) (observing that “Plaintiff is
Page 3 of 5 well-known in this district and in other jurisdictions as a vexatious and frivolous litigant”); O’Diah
v. U.S. Small Bus. Admin., No. 22-cv-4685, 2022 WL 2279765, at *1 n.1 (S.D.N.Y. June 14, 2022)
(noting that “Plaintiff has filed almost 100 cases in federal courts around the country”). Plaintiff’s
conduct has even led other courts to place restrictions on Plaintiff’s ability to initiate new legal
actions. O’Diah, 2022 WL 2279765, at *1 (observing that “Plaintiff was barred from filing any
new civil action in this court without prior leave of court” in 2015); see also O’Diah v. Port Auth.
of N.Y. & N.J., No. 05-cv-5297, 2012 WL 113551, at *2 (E.D.N.Y. Jan. 11, 2012) (enjoining
Plaintiff “from filing any new civil action or proceeding in this Court without first obtaining leave
of the Court”).
This court has already warned Plaintiff that it “will not hesitate” to issue a similar order
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
AROR-ARK ARK O’DIAH,
Plaintiff,
v. Civil Action No. 25-cv-2220 (TSC)
UNITED STATES DEPARTMENT OF JUSTICE, et al.,
Defendants.
OPINION AND ORDER
On July 14, 2025, Plaintiff Aror-Ark Ark O’Diah, proceeding pro se, sued over eighty
Defendants, including the Chief Justice of the United States Supreme Court, the Attorney General,
the U.S. Attorney for the District of Columbia, several banking institutions and businesses, the
New York state government and its agencies, attorneys, and other civilians. See Compl. at 1–2,
ECF No. 1 (“Compl.”). In his Complaint, Plaintiff alleged a “far-reaching conspiracy” wherein
“Defendants acted in concert to defame him, deny him access to credit lines and business loans,
subject him to thirty-one false arrests, and even to murder his late wife.” Mem. Op. at 1, ECF No.
92. Numerous Defendants moved to dismiss. See ECF Nos. 7, 8, 10, 16, 18, 22, 25, 27, 31, 38,
42, 47, 60, 73, 75, 77, 83, 84. On September 24, 2025, the court granted those motions and
dismissed the Complaint sua sponte as to all other Defendants because it was “patently obvious”
Plaintiff could not prevail based on the facts alleged. Mem. Op. at 3. Plaintiff now moves for
relief from this court’s Opinion, see First Mot. for Recon., ECF No. 94, and accompanying Order,
see Second Mot. for Recon., ECF No. 96. Because Plaintiff fails to proffer any valid ground for
his requested relief, his Motions for Reconsideration are DENIED.
Page 1 of 5 Plaintiff’s motions invoke Federal Rule of Civil Procedure 60(a) and (b). First Mot. for
Recon. at 2, 4; Second Mot. for Recon. at 2, 4. Rule 60 permits relief from a final judgment for
“clerical” issues as well as:
(1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b); (3) fraud . . . misrepresentation, or misconduct by an opposing party; (4) the judgment is void; (5) the judgment has been satisfied, released, or discharged; it is based on an earlier judgment that has been reversed or vacated; or applying it prospectively is no longer equitable; or (6) any other reason that justifies relief.
Fed. R. Civ. P. 60(a)–(b). In considering a Rule 60(b) motion, courts “must strike a delicate
balance between the sanctity of final judgments . . . and the incessant command of a court’s
conscience that justice be done in light of all the facts.” People for the Ethical Treatment of
Animals v. U.S. Dep’t of Health & Hum. Servs., 901 F.3d 343, 354–55 (D.C. Cir. 2018) (internal
quotations and citation omitted).
Notably, Plaintiff does not point to any clerical mistake, oversight, or omission, as required
for relief under Rule 60(a). See First Mot. for Recon. at 2–8; Second Mot. for Recon. at 2–8. That
leaves only relief under Rule 60(b). It is well-established, however, that Rule 60(b) is “not simply
an opportunity to reargue facts and theories upon which a court has already ruled.” Black v.
Tomlinson, 235 F.R.D. 532, 533 (D.D.C. 2006) (quoting New York v. United States, 880 F. Supp.
37, 38 (D.D.C. 1995)). Yet this is precisely what Plaintiff attempts to do, compare Compl. at 6–
21 with First Mot. for Recon. at 2–8 and Second Mot. for Recon. at 2–8. While Plaintiff’s motions
invoke the words “newly discovered evidence,” “fraud,” and “void,” see First Mot. for Recon. at
2–8; Second Mot. for Recon. at 2–8, he merely realleges the same “far-reaching conspiracy” that
the court already dismissed, see Mem. Op. at 1, 3. As another judge explained in rejecting a similar
motion for reconsideration by Plaintiff, his “allegations are neither new nor evidence,” Min Ord.,
O’Diah v. Moss, No. 24-cv-2736 (D.D.C. July 24, 2025) (denying Plaintiff’s Rule 60(b) motion
Page 2 of 5 raising purportedly newly discovered evidence of judicial misconduct). “Instead, they simply
rehash the earlier irrational and far-fetched claims that have been dismissed by the Court . . . and
amount to mere conjecture and unsupported assertions.” Id. (internal quotations and citations
omitted).
Plaintiff alternatively seeks leave to file an Amended Complaint. See First Mot. for Recon.
at 4, 5; 8; Second Mot. for Recon. at 4, 5, 8. While a court “should freely give leave when justice
so requires,” Fed. R. Civ. P. 15(a)(2), particularly where a plaintiff proceeds pro se, see Moore v.
Agency for Int’l Dev., 994 F.2d 874, 877 (D.C. Cir. 1993), it should not do so where amendment
would be futile, would result in undue delay or prejudice, is motivated by bad faith or a dilatory
motive, or follows a “repeated failure to cure deficiencies by previous amendments.” Onyewuchi
v. Gonzalez, 267 F.R.D. 417, 420 (D.D.C. 2010). Here, Plaintiff has not attached an Amended
Complaint to his motion for leave to file, as required under the court’s Local Rules. See LCvR
7(i); see also LCvR 15.1. This is independently fatal to Plaintiff’s request. See Friends of Animals
v. Pruitt, 258 F. Supp. 3d 91, 93 (D.D.C. 2017) (noting that “[t]he Court of Appeals has repeatedly
faulted litigants for the shortcoming of failing to attach a copy of their proposed amended
complaint to a motion for leave to file an amended complaint” (cleaned up)). But even if the court
were to overlook this defect, it is not convinced that any amendment would be in good faith and
otherwise not futile.
As the court previously observed, Plaintiff’s Complaint “re-allege[d] many of the same
claims that another court in this district recently dismissed.” Mem. Op. at 2 (citing Order at 1,
O’Diah v. Moss, No. 24-cv-2736 (D.D.C. June 2, 2025)). Indeed, it appears that this case is the
latest in a pattern of frivolous and vexatious litigation initiated by Plaintiff. See O’Diah v. United
States, No. 25-cv-4195, 2026 WL 91981, at *1 (D.D.C. Jan. 13, 2026) (observing that “Plaintiff is
Page 3 of 5 well-known in this district and in other jurisdictions as a vexatious and frivolous litigant”); O’Diah
v. U.S. Small Bus. Admin., No. 22-cv-4685, 2022 WL 2279765, at *1 n.1 (S.D.N.Y. June 14, 2022)
(noting that “Plaintiff has filed almost 100 cases in federal courts around the country”). Plaintiff’s
conduct has even led other courts to place restrictions on Plaintiff’s ability to initiate new legal
actions. O’Diah, 2022 WL 2279765, at *1 (observing that “Plaintiff was barred from filing any
new civil action in this court without prior leave of court” in 2015); see also O’Diah v. Port Auth.
of N.Y. & N.J., No. 05-cv-5297, 2012 WL 113551, at *2 (E.D.N.Y. Jan. 11, 2012) (enjoining
Plaintiff “from filing any new civil action or proceeding in this Court without first obtaining leave
of the Court”).
This court has already warned Plaintiff that it “will not hesitate” to issue a similar order
limiting his ability to “file future lawsuits based on many of the same allegations” contained in his
Complaint and recognized that Plaintiff’s history of abusive litigation “forces Defendants to
expend unnecessary resources to defend themselves.” Mem. Op. at 2–3 (internal quotations and
citations omitted). Now, several Defendants ask the court to act on its warning. See Defendant
Extra Space Storage Inc. Mem. in Opp’n to Pl’s Mot. for Recon. at 2, ECF No. 97; Defendants
Renaissance Equity Holdings LLC and Owner, Flatbush Gardens, and Isabella Joh Mem. in Opp’n
to Pl’s Mot. for Recon. at 3–4, ECF No. 98. The court declines to do so at this juncture because
Plaintiff elected to move for reconsideration rather than initiate a new lawsuit and, more
importantly, because another court in this district has already ordered him to show cause why such
an order would not be an appropriate sanction for his litigation conduct. See O’Diah, 2026 WL
91981, at *2.
Page 4 of 5 In light of the foregoing, Plaintiff’s request for leave to amend is DENIED. It is
FURTHER ORDERED that Plaintiff’s Motions for Reconsideration, ECF Nos. 94, 96, are
DENIED.
SO ORDERED.
Date: July 29, 2026
Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge
Page 5 of 5