Titlecraft, Inc. v. National Football League et al

Filing 11

APPLICATION FOR ENTRY OF DEFAULT. (Attachments: # 1 Certificate of Service)(Cruz, Timothy)

Titlecraft, Inc. v. National Football League et al

Doc. 11

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

TITLECRAFT, INC., Plaintiff and Counterclaim Defendant,
v.

No. 0:10-cv-00758-RHK-JJK DEFENDANTS/COUNTERCLAIM PLAINTIFFS NATIONAL FOOTBALL LEAGUE and NFL PROPERTIES LLC' APPLICATION FOR ENTRY S OF DEFAULT

NATIONAL FOOTBALL LEAGUE and NFL PROPERTIES, LLC, Defendants and Counterclaim Plaintiffs.

Defendants and Counterclaim Plaintiffs National Football League and NFL Properties, LLC (collectively "he NFL", by and through their attorneys, hereby request t ) the entry of default pursuant to Federal Rule of Civil Procedure 55(a) and LR 7.1 (b), against Plaintiff and Counterclaim Defendant Titlecraft, Inc. (" itlecraft" for failure to T ) respond or defend against the NFL' counterclaims herein. In support of its application s for default, the NFL states as follows: 1. Plaintiff and Counterclaim Defendant Titlecraft, Inc. was served with the NFL' Counterclaims and Answer on June 6, 2010; s 2. This Court has jurisdiction over the federal claims asserted herein under 15 U.S.C. § 1121(a) and 28 U.S.C. §§ 1331 and 1338. This Court has supplemental jurisdiction over all other claims asserted herein under 28

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U.S.C.§ 1367(a). The matter in controversy exceeds the value of $75,000, exclusive of interest and costs.
3. Plaintiff and Counterclaim Defendant Titlecraft, Inc. has failed to answer or

otherwise respond to the counterclaims herein (See Declaration of Timothy J. Cruz.) WHEREFORE, for the foregoing reasons, the NFL requests that an entry of default be entered against Titlecraft pursuant to Rule 55(a) of the Federal Rules of Civil Procedure Dated: July 12, 2010 Respectfully submitted, s/Timothy J. Cruz Daniel J. Connolly, #197427 Timothy J. Cruz #0386626 FAEGRE & BENSON 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, Minnesota 55402 [phone] Bruce P. Keller DEBEVOISE & PLIMPTON LLP 919 Third Avenue New York, New York 10022 [phone] Attorneys for Defendants and Counterclaim Plaintiffs National Football League and NFL Properties LLC

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