Free Motion for Default Judgment - District Court of Delaware - Delaware

Case 1 :07-cv-00271-JJF Document 5 Filed 06/27/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOE GANO :
Plaintiff :
v. I NO. 07-271
DONALD MARK EHART AND I
SPREAD EAGLE, INC., a Delaware :
Corporation formerly known as Red :
Eagle Avionics, Inc. :
Defendant :
MOTION FOR JUDGMENT BY DEFAULT
Pursuant to U.S. District Court Rule 55(b), Plaintiff, Joe Gano, requests the entry of default
judgment against the Defendants, Donald Mark Ehart and Spread Eagle, Inc., a Delaware Corporation
formerly known as Red Eagle Avionics, Inc.
The grounds for the motion are as follows:
I. The Plaintiff filed the above action on May 18, 2007, with regard to the sale of corporate
assets.
2. The Summons and Complaint were served personally by process server on May 3I, 2007.
3. Defendant has failed to answer or otherwise plead.
WHEREFORE, the undersigned respectfully requests that the Court enter the attached Order
entering judgment by default in favor of Plaintiff, Joe Gano, and against the Defendants, Donald Mark
Ehart and Spread Eagle, Inc., a Delaware Corporation formerly known as Red Eagle Avionics, Inc. in
the minimum amount of $1,1 52,069.40 plus interest, additional damages, and equitable relief to be
determined after hearing.

Case 1:07-cv-00271-JJF Document 5 Filed 06/27/2007 Page 2 of 2
FOX ROTHSCHILD LLP
BY: /s Sophia Siddigui gI.D. No. 4914)
Sophia Siddiqui, Esquire (I.D. No. 4914)
919 N. Market Street, Suite 1300
Wilmington, DE 19899-2323
(302) 654-7444
(302) 656-8920 (facsimile)
Wendy G. Rothstein, Esquire (To be admitted Pro Hac Vice)
1250 South Broad Street
P.O. Box 431
Lansdale, PA 19446-0431
(215) 699-6000
(215) 699-0231 (facsimile)
-and-
Todd B. Nurick, Esquire (To Be Admitted Pro Hac Vice)
NURICK LAW GROUP
111 West Germantown Pike
Plymouth Meeting, PA 19462
(610) 238-9000
(610) 238-9977 (facsimile)

Case 1:07-cv-00271-JJF Document 5-2 Filed 06/27/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOE GANO :
Plaintiff :
v. : NO. 07-271
DONALD MARK EI-IART AND J
SPREAD EAGLE, INC., a Delaware :
Corporation formerly known as Red :
Eagle Avionics, Inc. :
Defendant :
ORDER
AND NOW, TO WIT, this day of , 2007, the Court
having been presented with Plaintiffs Motion for Judgment by Default,
IT IS HEREBY ORDERED that the judgment by default shall be entered in favor of Plaintiff,
Joe Gano, and against the Defendants, Donald Mark Ehart and Spread Eagle, Inc., a Delaware
Corporation formerly known as Red Eagle Avionics, Inc., in the minimum amount of $l,l52,069.40
plus interest, additional damages, and equitable relief to be determined after hearing.
BY THE COURT:


Case 1:07-cv-00271-JJF Document 5-3 Filed 06/27/2007 Page 1 of 1
CERTIFICATE OF SERVICE
The undersigned hereby certifies that two (2) copies of the attached Motion for Judgment by Default
were served this gjid/ay of June, 2007, via federal express, upon the following individuals:
Spread Eagle, Inc.
c/o Donald Mark Ehart
795 Union Church Road
Townsend, DE 19734
Donald Mark Ehart
12514 Ashdown Dr.
Odessa, FL 33556
/s/ Sophia Siddigui
Sophia Siddiqui, Esquire (#4914)