Free Motion for Default Entry 55(a) - District Court of Connecticut - Connecticut

I Case 3:03-cv-OO383qW|G Document 154 Filed 04/27/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT L _ Q.
WASLEY PRODUCTS, INC., ET AL., MASTER CONSOLIDATED CASE i
CIVIL NO. 3:03 CV 383 (MRK) p ` _‘
Plaintiffs, ·
THIS PLEADING PERTAINS TO:
P CIVIL NO. 3:03 CV 1790 (MRK)
V. (Prentiss et al. v. Wasley Products, Inc. et al. I
I BARRY BULAKITES, ET AL.,
Defendants. APRIL 26, 2005 I ·
MOTION FOR JUDGMENT BY DEFAULT "
_ Pursuant to Fed. R. Civ. P. 55 ofthe Federal Rules of Civil Procedure, I
. defendants! crossclaim plaintiffs Wasley Products, Inc., Alan A. Wasley, Andrew Brady, - J
Sandi Dumas-LaFerriere, and Barry Connell (collectively, the "Wasley Defendants") in `
the matter of Prentiss et al. v. Wasley Products et al., docket # 3:03 CV 1790 (MRK), i
_ hereby move the court for a default judgment in their favor on all of the crossclaims
brought by them against co—defendants Barry Bulakites, James Winslow, and Joshua
. Adams Corp. (collectively, the "Bulakites Defenda;nts”). The crossclaims are set `forth in _
_ the Wasley Defendants’ Answer, Affirmative Defenses, and Crossclaims dated . .,.__
- February 23, 2004.
The reasons for this motion are as follows. On April 12, 2005, following a
I telephonic status conference in which the Bulakites Defendants participated, the court

Case 3:03-cv—OO383-WIG Document 154 Filed 04/27/2005 Page 2 of 3 j _‘_‘.
ordered the Bulakites Defendants to obtain replacement counsel or, if appropriate, to file ·
pro se appearances on or before April 22, 2005.1 The court clearly stated that, if I
. appearances were not tiled, it would entertain motions for default and warned the
Bulakites Defendants of the consequences of default judgment. As of the date of this
motion, no appearances have been filed on behalf of any of the Bulakites Defendants. q
Rule 55(d) of the Federal Rules of Civil Procedure states that the provisions ofthe
rule apply not only to plaintiffs but also to parties who have pleaded a crossclaim. The
Wasley Defendants therefore request that the court enter a default judgment against the
Bulakites Defendants on all of the Wasley Defendants’ crossclaims. I Z
I DEFENDANTS and CROSSCLAIM PLAINTIFFS
WASLEY PRODUCTS, INC., ALAN A. WASLEY, ‘
ANDREW BRADY, SANDI DUMAS-
LAF ERRIERE, AND BARRY CONNELL
By: . \
· Theodore J. Tucci (ct05249)
_ [email protected]
- Jean E. Tomasco (ct09635) fj
[email protected] ri
_ . Robinson & Cole LLP
.280 Trumbull Street
Hartford, CT 06103-3597
Tel. No.: (860) 275-8200 gg
‘ q Fax: (860) 275-8299
I The Wasley Defendants note that the Bulakites Defendants had fled two previous motions for extension of time to
i retain replacement counsel. The first motion for extension of time was tiled on March 11, 2005. The second motion
for extension of time was filed on April 15, 2005. The court granted both motions, but the Bulakites Defendants
failed to comply with the deadlines for appearances. up
2 iff

Case 3:03-cv—OO383¢W|G Document 154 Filed 04{27[2005 Page 3 of 3
CERTIFICATION
. This is to certify that a copy of the foregoing was mailed by certified mail, return by
receipt requested, on the twenty-sixth day of April 2005 to the following:
Barry Bulakites
558 Castle Pines Parkway Unit B4 #401 `_
_ Castle Rock, CO 80108
(via certified mail 7003 3110 0003 7068 9617) -
J ames-Albert Winslow
45 Sagamore Terrace South
Westbrook, CT 06498
(via certified mail 7003 3110 0003 7068 9624)
And that a copy was also mailed via first—class mail, postage prepaid, to the following:
Deborah S. Freeman, Esq. q
Sara R. Simeonidis, Esq. Thomas G. Moukawsher, Esq.
Bingham McCutchen LLP Ian O. Smith, Esq.
One State Street Moukawsher & Walsh LLC
Hartford, CT 06103-3178 · 21 Oak Street, Suite 209
‘ Hartford, CT 06106
Albert Zakarian, Esq.
Victoria Woodin Chavey, Esq. Joseph V. Meaney, Jr., Esq. -
_ L Eric L. Sussman, Esq. Cranmore, Fitzgerald & Meaney
`Day, Berry & Howard LLP 49 Wethersfield Ave. ‘
. CityPlace _ Hartford, CT 06114-1102 ig,
Hartford, CT 06103-3499 :2;
Theodore J. Tuc `
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