JS Freight LLC v. Snow Joe LLC

Summary

The document contains Findings and Recommendations by a United States Magistrate Judge regarding JS Freight LLC’s motion for default judgment against Snow Joe LLC in a breach-of-contract action. The court recommends entering judgment for $75,569 in principal damages plus 10% annual prejudgment interest, while denying the request for attorney’s fees and costs without prejudice and permitting supplemental briefing. The parties were given 14 days to file objections.

Holdings

1. Service was adequate because Plaintiff personally served Snow Joe LLC’s registered agent for service of process, satisfying Federal Rule of Civil Procedure 4(h).
2. Default judgment should be entered for JS Freight because the well-pleaded allegations sufficiently established the existence of a contract, Plaintiff’s performance, Defendant’s breach, and resulting damages, and the Eitel factors favored judgment.
3. JS Freight should receive $75,569 in principal damages.
4. JS Freight should receive prejudgment interest at 10 percent annually from the date each invoice became due and payable through entry of judgment, compounded annually.
5. The request for attorneys’ fees and costs should be denied without prejudice, with leave to submit supplemental briefing within 30 days after judgment is entered.

Questions Presented

1. Whether Snow Joe LLC was properly served so that default judgment could be considered.
2. Whether the well-pleaded allegations established a breach of contract claim warranting default judgment under Rule 55.
3. Whether JS Freight LLC was entitled to $75,569 in principal damages and prejudgment interest.
4. Whether JS Freight LLC was entitled to attorneys’ fees and costs on the present record.

Disposition

other