LOFLAND v. WAL-MART STORES EAST, L.P. et al

MOTION for Entry of Default

D.D.C.March 26, 2019

1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ZYMIRA LOFLAND, Plaintiff, v. WAL-MART STORES EAST, L.P., WAL- MART ASSOCIATES, INC., and BRIAN BROOKS. Defendants. Case No. 1:18-cv-01838-ABJ REQUEST FOR ENTRY OF DEFAULT Pursuant to Federal Rule Civil Procedure 55(a), Plaintiff Zymira Lofland hereby requests that the Clerk of the United States District Court for the District of Columbia enter an order of default against Defendant Brian Brooks for failure to answer, plead or otherwise respond to the Plaintiff Lofland’s complaint in this matter within the time permitted by the Federal Rules of Civil Procedure and this Court’s orders. In support of its request, Plaintiff states as follows: 1. Plaintiff filed her complaint in the Superior Court of the District of Columbia on June 22, 2018. 2. Defendant Brian Brooks was served via certified mail pursuant Rule 4(C)(ii) of the Superior Court of the District of Columbia on July 12, 2018. 3. This matter was removed to federal court on August 6, 2018. 4. On December 12, 2018 the Court ordered Defendant Brooks to file an answer or otherwise respond to the complaint by January 11, 2019. 5. No appearance has been entered by Defendant Brooks. Case 1:18-cv-01838-ABJ Document 31 Filed 03/26/19 Page 1 of 3 2 6. No pleading has been filed by Defendant Brooks and none has been served upon the attorneys for Plaintiff. Date: March 26, 2019 Respectfully submitted, CORREIA & PUTH, PLLC _____/s/ Roshni C. Shikari_______________ Linda M. Correia (D.C. Bar No. 435027) Roshni C. Shikari (D.C. Bar No. 1045298) 1400 16th Street NW, Suite 450 Washington, DC 20036 Tel: (202) 602-6500 lcorreia@correiaputh.com rshikari@correiaputh.com Counsel for Plaintiff Zymira Lofland Case 1:18-cv-01838-ABJ Document 31 Filed 03/26/19 Page 2 of 3 3 CERTIFICATE OF SERVICE I hereby certify that on March 26, 2019, the foregoing Request for Entry of Default was electronically filed with the Clerk’s Office using this Court’s CM/ECF system and was served via the Court’s ECF system upon all counsel of record. /s/ Roshni C. Shikari ________ Roshni C. Shikari Case 1:18-cv-01838-ABJ Document 31 Filed 03/26/19 Page 3 of 3