Free Request for Default - District Court of Delaware - Delaware

Case 1:07-cv-00201-***-MPT

Document 5

Filed 05/10/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PRETIUM CANADA COMPANY, Plaintiff, v. GREEN GROUP ASSOCIATES, LLC, a Delaware limited liability company, Defendant. : : : : Civil Action No. 07- 201 (***) : : : : : : :

REQUEST TO ENTER DEFAULT PURSUANT TO F.R.C.P. 55(a) You will please enter a default on Defendant, Green Group Associates, LLC ("Defendant"), for its failure to plead or otherwise defend the Complaint filed on April 13, 2007 as provided in Rule 55(a) of the Federal Rules of Civil Procedure as appears in the attached declaration of Rick S. Miller, Esquire. FERRY, JOSEPH & PEARCE, P.A. By: /s/ Rick S. Miller RICK S. MILLER (#3418) Ferry, Joseph & Pearce, P.A. 824 Market St., Suite 904 P.O. Box 1351 Wilmington, DE 19899 (302) 575-1555 Date: May 10, 2007 OF COUNSEL: Mark T. Keaney, Esquire Lewis Rice & Fingersh, L.C, 500 N. Broadway, Suite 2000 St. Louis MO 63102-2147 (314) 444-7600 Attorneys for Plaintiff

Case 1:07-cv-00201-***-MPT

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PRETIUM CANADA COMPANY, Plaintiff, v. GREEN GROUP ASSOCIATES, LLC, a Delaware limited liability company, Defendant. : : : : Civil Action No. 07- 201 (***) : : : : : : :

DECLARATION OF RICK S. MILLER FOR ENTRY OF DEFAULT RICK S. MILLER, Esquire, declares and states as follows: 1. 2. I am the attorney for the Plaintiffs in the above-entitled action. The Complaint and Summons in this action were served on Green Group

Associates, LLC, a Delaware limited liability company, on April 17, 2007 at its Registered Agent's (Registered Agents, Ltd.) office located at 1220 N. Market Street, Suite 804, Wilmington, DE 19801 by Kevin Dunn, Process Server, who served Laura Bryda, the person in charge at Registered Agents, Ltd. (Registered Agent) , as appears from the Affidavit of Service of the Complaint which has been duly docketed with the Court. (D.I. 3). 3. The time in which the Defendant may answer or otherwise move as to the

Complaint has expired. 4. The Defendant has not answered or otherwise moved and the time for Defendant

to answer or otherwise move has not been extended. 5. service. 2 Inasmuch as the Defendant is a limited liability company, it is not in the military

Case 1:07-cv-00201-***-MPT

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6.

Defendant is neither an infant nor an incompetent person. I declare under penalty of perjury in accordance with 28 U.S.C. §1746 that the foregoing is true and correct to the best of my knowledge, information and belief

Date: May 10, 2007

/s/ Rick S. Miller RICK S. MILLER, ESQUIRE (#3418)

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Case 1:07-cv-00201-***-MPT

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Filed 05/10/2007

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CERTIFICATE OF SERVICE I, Rick S. Miller, Esquire, state under penalty of perjury that I caused a copy of the foregoing Request to Clerk to Enter Default Pursuant to F.R.C.P. 55(a) to be served via first class mail, postage prepaid on the date and to the address below: Green Group Associates, LLC C/o Registered Agents, Ltd. 1220 N. Market Street, Suite 804 Wilmington DE 19801 and Green Group Associates, LLC Edificio Arriaga 77 3 Andar, Sala 305 Funchal 9000 Madeira, Republic of Portugal

Date: May 10, 2007

/s/ Rick S. Miller RICK S. MILLER, ESQUIRE (#3418)

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