Christopher Creagh v. Espiritus LLC and Jay S. Maltby

Summary

The court orders Plaintiff Christopher Creagh to file an affidavit detailing attorneys’ fees accrued when the complaint was filed, for purposes of determining whether the amount-in-controversy requirement is satisfied. The order follows the appearance of counsel for Espiritus LLC, which previously could not proceed pro se through its sole member.

Holdings

1. A limited liability company may appear in federal court only through a licensed attorney.

Questions Presented

1. Whether a limited liability company may appear in federal court through a nonlawyer member proceeding pro se.
2. Whether Plaintiff should be required to document attorneys' fees accrued at the time of filing for purposes related to the amount-in-controversy requirement.

Disposition

other