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Baghirzade v. Armenian National Committee of America
3:24-cv-01077
S.D. Cal.
Apr 14, 2025
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Background

  • Plaintiff Aynur Baghirzade, an attorney, filed suit in the Southern District of California against the Armenian National Committee of America and others, advancing federal claims.
  • Previous versions of the complaint were dismissed for failure to state a cognizable federal claim; leave to amend was granted but strictly limited to correcting deficiencies in five federal claims only, with explicit instructions not to add new claims or defendants without permission.
  • Plaintiff was repeatedly reminded by the court of specific procedural requirements, including submitting a redlined copy of any amended complaint, complying with local rules, and using specified formatting (e.g., 14-point font).
  • Plaintiff requested and was granted two extensions to file a Third Amended Complaint (TAC), but was advised that no further extensions would be granted.
  • The ultimately filed TAC was substantially longer (198 pages vs. 78), used the wrong font size, failed to submit a compliant redline, and added a new defendant (ARF Eastern USA, Inc.) without leave of court.
  • The court struck the TAC for noncompliance with clear orders and rules, resulting in dismissal of the action.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Scope of permitted amendment Claimed added defendant ARF was not new, just a corrected name Addition of ARF is unauthorized, exceeds scope of leave to amend Court held addition exceeded permitted amendment scope
Requirement to file redline of amendments Submitted a version highlighting added text but not deletions Did not submit proper redline showing changes as required Court found noncompliance with Local Rule 15.1(c)
Compliance with formatting/local rules Filed in 12-point font, contrary to explicit orders Argued filings failed to comply with font and page limit rules Court found repeated violations of local rules/orders
Repeated deadline extensions and compliance Sought more time and reconsideration, citing new information Argued against further extensions due to pattern of noncompliance Court denied further extensions, struck TAC, dismissed

Key Cases Cited

  • Atchison, Topeka & Santa Fe Ry. v. Hercules, Inc., 146 F.3d 1071 (9th Cir. 1998) (affirmed district courts’ inherent power to manage their docket)
  • Christian v. Mattel, Inc., 286 F.3d 1118 (9th Cir. 2002) (district courts can strike filings for failure to comply with local rules)
  • Ferdik v. Bonzelet, 963 F.2d 1258 (9th Cir. 1992) (listed factors to consider before dismissing a case for failure to comply with court orders)
  • Yourish v. Cal. Amplifier, 191 F.3d 983 (9th Cir. 1999) (public’s interest in expeditious litigation favors dismissal)
Read the full case

Case Details

Case Name: Baghirzade v. Armenian National Committee of America
Court Name: District Court, S.D. California
Date Published: Apr 14, 2025
Docket Number: 3:24-cv-01077
Court Abbreviation: S.D. Cal.