Caryl Danita Carby v. Government of Nigeria, et al.

Summary

The U.S. District Court for the Eastern District of Washington denied Caryl Danita Carby’s motion to change venue and motion for an extension of time to serve the defendants. The court found the venue request unclear and determined that an extension was unnecessary because the plaintiff’s 90-day service period under Federal Rule of Civil Procedure 4(m) had not expired.

Holdings

1. The motion to change venue was denied because the requested relief was unclear, plaintiff did not present arguments supporting transfer or identify an alternative venue, and the requested relief appeared unnecessary.
2. The motion for an extension of time to serve was denied as unnecessary because plaintiff had until April 30, 2026, to properly serve defendants under Rule 4(m), which was later than the March 31, 2026, deadline she requested.

Questions Presented

1. Whether plaintiff's motion to change venue should be granted when the requested relief was unclear, unsupported, and did not identify an alternative venue.
2. Whether plaintiff was entitled to an extension of time to serve when the 90-day period under Federal Rule of Civil Procedure 4(m) had not expired.

Disposition

other