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

Case 1:07-cv-00196-GMS

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105.013 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KEYSTONE INSURANCE COMPANY AS SUBROGEE OF BRENDA BOYD Plaintiffs vs. NATIONAL RAILROAD PASSENGER CORPORATION A/K/A AMTRAK, AND KEVIN CONNORS Defendants/Third Party Plaintiffs vs. LYNN REDMOND AND LESLIE BOYD, JR. Third Party Defendants REQUEST TO ENTER DEFAULT JUDGM ENT AGAINST THIRD PARTY DEFENDANTS To the Clerk of the above-named Court: Please enter upon the docket the default of the Third Party Defendant, Lynn Redmond and Third-Party Defendant, Leslie Boyd, Jr., in the above action for failure to plead or otherwise defend as provided by the rules of federal procedure. GALLAGHER & ROWAN, P.C. By: /s/ Jessica E. Gensler Lippy JESSICA E. GENSLER LIPPY, ESQUIRE Attorney I.D. No. 4426 Silverside Carr Executive Center 501 Silverside Road, Suite 94 W ilmington, DE 19809 (302) 798-2779 Attorneys for Defendant/Third Party Plaintiffs National Railroad Passenger Corporation a/k/a Amtrak and Kevin Connors Dated: September 25, 2007 CIVIL ACTION NO. 1:07-cv-00196 GMS

JURY TRIAL DEMANDED 12 JURORS REQUESTED

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105.013 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KEYSTONE INSURANCE COMPANY AS SUBROGEE OF BRENDA BOYD Plaintiffs vs. NATIONAL RAILROAD PASSENGER CORPORATION A/K/A AMTRAK, AND KEVIN CONNORS Defendants/Third Party Plaintiffs vs. LYNN REDMOND AND LESLIE BOYD, JR. Third Party Defendants ATTORNEY CERTIFICATION IN SUPPORT OF REQUEST TO ENTER DEFAULT JUDGMENT 1. I, Jessica E. Gensler Lippy, Esquire, am the attorney for the CIVIL ACTION NO. 1:07-cv-00196 GMS

JURY TRIAL DEMANDED 12 JURORS REQUESTED

Defendants/Third Party Plaintiffs in the above-entitled action. I am fully familiar with the matters set forth herein. I make this Certification in support of the Defendants/Third Party Plaintiffs' request for entry of default against the Third Party Defendants Lynn Redmond and Leslie Boyd, Jr. 2. The Third Party Summons and Third Party Complaint in this action were

served upon the Third Party Defendant Lynn Redmond via process server, Timothy A. Grant, on April 19, 2007. A copy of the Affidavit of Service is attached hereto and marked Exhibit "A".

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3.

The Third Party Summons and Third Party Complaint in this action were

served upon the Third Party Defendant Leslie Boyd, Jr. via process server, Timothy A. Grant, on April 24, 2007. A copy of the Affidavit of Service is attached hereto and marked Exhibit "B". 4. The time within which Third Party Defendants may answer or otherwise

move as to the Third Party Complaint has expired and has not been extended. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. GALLAGHER & ROWAN, P.C.

By /s/ Jessica E. Gensler Lippy JESSICA E. GENSLER LIPPY, ESQUIRE Attorney I.D. No. 4426 Silverside Carr Executive Center 501 Silverside Road, Suite 94 W ilmington, DE 19809 (302) 798-2779 Attorneys for Defendant/Third Party Plaintiffs National Railroad Passenger Corporation a/k/a Amtrak and Kevin Connors Dated: September 25, 2007

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105.013 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KEYSTONE INSURANCE COMPANY AS SUBROGEE OF BRENDA BOYD Plaintiffs vs. NATIONAL RAILROAD PASSENGER CORPORATION A/K/A AMTRAK, AND KEVIN CONNORS Defendants/Third Party Plaintiffs vs. LYNN REDMOND AND LESLIE BOYD, JR. Third Party Defendants CERTIFICATE OF SERVICE I, Jessica E. Gensler Lippy, Esquire, attorney for Defendants, National Railroad Passenger Corporation a/k/a Amtrak and Kevin Connors, hereby certify that a true and correct copy of the foregoing Request to Enter Default Against Third Party Defendants, was served via first class mail, postage prepaid to the following: W illiam J. Cattie, III Rawle & Henderson, LLP 300 Delaware Avenue Suite 1015 PO Box 588 W ilmington, DE 19899-0588 (Counsel for Plaintiff) Leslie Boyd, Jr. 610 W est Diamond Street Hazelton, PA 18201 CIVIL ACTION NO. 1:07-cv-00196 GMS

JURY TRIAL DEMANDED 12 JURORS REQUESTED

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Lynn Redmond 15 S. Broom Street W ilmington, DE 19805

GALLAGHER & ROWAN, P.C.

By: /s/ Jessica E. Gensler Lippy JESSICA E. GENSLER LIPPY, ESQUIRE Attorney I.D. No. 4426 Silverside Carr Executive Center 501 Silverside Road, Suite 94 W ilmington, DE 19809 (302) 798-2779 Attorneys for Defendant/Third Party Plaintiffs National Railroad Passenger Corporation a/k/a Amtrak and Kevin Connors Dated: September 25, 2007

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