Free Request for Default - District Court of Delaware - Delaware

Case 1 :04-cv-01556-JJF Document 6 Filed O4/O1/2005 Page 1 of 4
IN TI-IE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PLUMBERS & PIPEFITTERS LOCAL UNION : CIVIL ACTION
NO. 74 ANNUITY FUND, et al. 1
Plaintiffs 1
v.
NLD. AL1..E1\i, LC
Defendant NO. 04~C\/-1556 (.111:)
REQUEST TO CLERK TO ENTER DEFAULT
PURSUANT TO FED. R. CIV. P. 55(a)
You will please enter a default on Defendant, M..D. Allen, LC, for failure to plead or
otherwise defend as provided in Rule 55(a) ofthe Federal Rules of Civil Procedure as appears in
the attached affidavit of Timothy .1*.. Snyder,.
Respectfully submitted,
YOUNG CONAWAY
STARGATT & TAYLOR, LLP
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Date: @0 I ` D6 Byr 4
nnothy .1. S y
Atton1ey1.D.. · 2
The Bzandyw uilci ig
1000 West lh Floor
Wilmington, E 19801
Telephone: (302) 571-6645
Facsimile: (302) 576-3.336
Email: 1S1}YCl€1“(CI_1j_,\fCSI.CO1]1
OF COUNSEL:
Sanford G. Rosenthal
Jennings Sigmond, PC,
The Penn Mutual Towers, 16th Fl.
510 Walnut Street
Philadelphia, PA 19106
(215) .35E—061l
Attorneys for Plaintiffs

Case 1:04-cv—O1556-JJF Document 6 Filed O4/O1/2005 Page 2 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PLUMBERS & PIPEFITTERS LOCAL UNION : CIVIL ACTION
NO. 74 ANNUITY FUND, et al. :
Plaintiffs :
v.
MD, ALLEN, LC
Defendant NO. 04—CV—1556 (JJ F)
AFFIDAVIT OF TIMOTHY J. SNYDER
FOR ENTRY OF DEFAULT
Timothy J. Snyder, having been tirst duly sworn according to law, hereby deposes and
states as follows:
Iam an attorney for the Plaintiffs in the aboveentitled action.
The Complaint and Summons in this action were served on the Defendant, MD. Allen,
LC, by serving the Secretary of State ofthe State of Delaware, on December 30, 2004, as appears
from the Return of Service of Complaint, which was duly docketed with the Court on January 3,
2005, A copy ofthe Complaint and Sumrnons were sent by registered mail, return receipt to
NLD. Allen, LC on January 4, 2005 and delivered on January 6, 2005, the receipts for which were
duly doclceted with the Court on January I2, 2005. The time in which Defendant may answer or
otherwise move as to the Complaint has expired
The Defendant has not answered or otherwise moved and the time for Defendant to
answer or otherwise move has not been extended.
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Case 1:04-cv—O1556-JJF Document 6 Filed O4/O1/2005 Page 3 of 4
The Defendant is neither an infant nor an incompetent person and is not in the military
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. 0THY J. S w 11 * '
Sworn to and subscribed before
me this [ge day of [ , 2005
$§TARY PUELIC
LUCINDA B. JOSEP
NOTARY PUBLIC H
A _ STATES OF DELAWARE
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Case 1:04-cv—O1556-JJF Document 6 Filed O4/O1/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I, Timothy J. Snyder, state under penalty of perjury that I caused a copy of the foregoing
Request To Clerk To Enter Default Pursuant To Fed. R. Civ. P. 55(a) to be served via first class
mail, postage prepaid on the date and to the address below:
Robert Valliant Jones, Esquire
157 East Main Street
Elkton, MD 2192}-5974
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