Pacific Law Center et al v. Saadat-Nejad

Filing 28

Request for Entry of Clerks Default against Shahrokh Saadat-Nejad. (Attachments: # 1 Declaration of Edward J. McIntyre# 2 [Proposed] Default by Clerk)(McIntyre, Edward)

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EDWARD J. MCINTYRE [SBN 80402] [e-mail] SOLOMON WARD SEIDENWURM & SMITH, LLP 401 B Street, Suite 1200 San Diego, California 92101 Telephone: [phone] Facsimile: [phone] Attorneys for Pacific Law Center and Solomon Ward Seidenwurm & Smith, LLP

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

PACIFIC LAW CENTER, a Professional Law Corporation; and SOLOMON WARD SEIDENWURM & SMITH, LLP, Plaintiffs, v. SHAHROKH SAADAT-NEJAD, an individual, Defendant.

CASE NO. 07-CV-00460 LAB (POR) DECLARATION OF EDWARD J. MCINTYRE IN SUPPORT OF REQUEST TO ENTER DEFAULT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55(a) Courtroom: 9 Hon. Larry Alan Burns

P:304877.1:57122.003

07-CV-00460 LAB (POR) DECLARATION OF EDWARD J. MCINTYRE IN SUPPORT OF REQUEST TO ENTER DEFAULT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55(a)

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Edward J. McIntyre declares: 1. I am the partner in charge of representing Pacific Law Center and Solomon

Ward Seidenwurm & Smith, LLP in this matter. I have personal knowledge of these facts. 2. The summons and complaint were personally served on Shahrokh Saadat-

Nejad at Department 75 of the San Diego Superior Court, located at 330 West Broadway, San Diego, California 92101, on March 14, 2007 at 8:40 a.m. 3. 4. 5. On March 29, 2007 I filed the affidavit of personal service with the Court. Shahrokh Saadat-Nejad was due to respond to the complaint by April 3, 2007. As of April 26, 2007, Shahrokh Saadat-Nejad has failed to answer the

complaint or file a motion permitted by Federal Rule of Civil Procedure 12. 6. To my best knowledge, Shahrokh Saadat-Nejad is an adult, is not incompetent

or a member of the military service. I declare under penalty of perjury under the laws of the United States of America and the laws of the State of California that the foregoing is true and correct of my own personal knowledge and that I executed this declaration on May 8, 2007 at San Diego, California.

/s/ Edward J. McIntyre__________________ EDWARD J. MCINTYRE

P:304877.1:57122.003

-107-CV-00460 LAB (POR) DECLARATION OF EDWARD J. MCINTYRE IN SUPPORT OF REQUEST TO ENTER DEFAULT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55(a)

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P:304877.1:57122.003

CERTIFICATE OF SERVICE I caused the DECLARATION OF EDWARD J. MCINTYRE IN SUPPORT OF REQUEST TO ENTER DEFAULT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55(a) to be served in the following manner: Electronic Mail Notice List The following are those who are currently on the list to receive e-mail notices for this case. Electronic Mail Notice List NONE. I manually served the following: Shahrokh Saadat-Nejad 3713 Mt. Ashmun Place San Diego, CA 92111 VIA U.S. MAIL /s/ Edward J. McIntyre__________ EDWARD J. MCINTYRE

-207-CV-00460 LAB (POR) DECLARATION OF EDWARD J. MCINTYRE IN SUPPORT OF REQUEST TO ENTER DEFAULT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55(a)