Faughn et al v. JPMorgan Chase Bank, NA

Filing 25

MOTION for default judgment filed by Rick D. Holtsclaw on behalf of All Plaintiffs. Suggestions in opposition/response due by 6/16/2014 unless otherwise directed by the court. (Holtsclaw, Rick)

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
MARK FAUGHN, et al.,
Plaintiffs,
vs.
JPMORGAN CHASE BANK, N.A.,
Defendant.

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Case No. 14-CV-00245-BCW

PLAINTIFFS’ MOTION FOR DEFAULT JUDGMENT
COME NOW Plaintiffs, by and through counsel of record, and moves the Court for entry
of default judgment against Defendant pursuant to Federal Rule of Civil Procedure 55. In
support of their motion, Plaintiffs state as follows:
1.

This action was filed on March 13, 2014.

2.

Defendant’s counsel became aware of this action and began communicating

with Plaintiffs’ counsel on behalf of Defendant on March 14, 2014. (Exhibit 1, E-mail from Beth
Boland to Rick Holtsclaw)
3.

On March 14, 2014, Defendant filed its first motion in this case. (Doc. No. 3)

4.

On March 25, 2014, J. Loyd Gattis, III entered his appearance on behalf of

Defendant. (Doc. No. 14)
5.

On March 25, 2014, Defendant filed motions to permit Beth Boland, Rachel Blise,

and Stephen Quinlan to appear pro hac vice on behalf of Defendant. Those motions were
granted on March 26. (Doc. Nos. 15, 16, 17 and 19)

6.

None of Defendants’ attorneys entered their appearances for a limited purpose.

(Doc. Nos. 14, 15, 16, and 17)
7.

On March 25, Defendants’ attorneys participated in a hearing on behalf of

Defendant.
8.

Seventy-six days have passed between Defendant’s first participation in this

case, but no Answer to Plaintiffs’ Complaint has been filed.
WHEREFORE, for the foregoing reasons, Plaintiffs respectfully request that this Court
enter Default Judgment against Defendant.
Respectfully submitted,
/s/ Rick D. Holtsclaw
Rick D. Holtsclaw, MO #32866
HOLTSCLAW FIRM
2029 Wyandotte, Suite 100
Kansas City, Missouri 64108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I certify that on this 29th day of May, 2014, I filed the above and foregoing electronically
with CM/ECF, which will automatically transmit a copy of this document to Defendant’s counsel
of record.
/s/ Rick D. Holtsclaw
Attorney for Plaintiffs

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