Free Motion for Entry of Default - District Court of California - California

Case 3:07-cv-04946-JSW

Document 46

Filed 02/11/2008

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CHRISTOPHER COOKE, CA Bar #142342 STEPHEN S. WU, CA Bar # 205091 COOKE KOBRICK & WU LLP 177 Bovet Road, Suite 600 San Mateo, CA 94402 Email: [email protected] [email protected] Tel: (650) 638-2370 Fax: (650) 341-1395 Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MEI-FANG LISA ZHANG, BAY AREA AFFORDABLE HOUSING, LLC, XUEHUAN GAO, YANG-CHUN ZHANG, CAROL JIAN DENG, and HAO LIANG, ) ) ) ) ) ) ) Plaintiffs, ) ) vs. ) ) WEI-MAN RAYMOND TSE, RUN PING ) ) ZHOU a.k.a. FLORA ZHOU, THERESA WONG, JAMES YU, BILL SHU WAI MA, ) ) MOLLY LAU, VICTOR SO, JIAN XIAO, ) CHRIST INVESTMENT SERVICE INC., CIS ) SERVICE, INC., PACIFIC BEST GROUP ) ) LTD. a.k.a. PACIFIC BEST COMPANY LTD., and SOUTH CHINA INVESTMENT ) ) INC., ) Defendants. ) Case No.: C-07-04946 JSW (Related to C-05-02641 JSW) P A N IF ' L I T F S REQUEST FOR ENTRY OF DEFAULT AGAINST DEFENDANTS RUN PING ZHOU a.k.a. FLORA ZHOU, BILL SHU WAI MA, CHRIST INVESTMENT SERVICE INC., CIS SERVICE, INC., PACIFIC BEST GROUP LTD. a.k.a. PACIFIC BEST COMPANY LTD., and SOUTH CHINA INVESTMENT INC. UNDER FED. R. CIV. P. 55(a)

Pursuant to Fed. R. Civ. P. 55(a), Plaintiffs hereby apply for the entry of a default by the Clerk against Defendants Run Ping Zhou a.k.a. Flora Zhou, Bill Shu Wai Ma, Christ Investment Service Inc., CIS Service, Inc., Pacific Best Group Ltd. a.k.a. Pacific Best Company Ltd., and South China Investment Inc. As shown by the Declaration of Stephen S. Wu filed herewith in support of this Request ( D c r i " t Pa tffe t iC m ln o Sp m e2, " Wu el ao ) h ln f id h r o p i n et br 4 a t n , e i is l e at e -1P A N IF ' L I TF S REQUEST FOR ENTRY OF DEFAULT/ Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 46

Filed 02/11/2008

Page 2 of 2

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2007. Moreover, the Complaint and Summons were served (1) on Defendants Run Ping Zhou a.k.a. Flora Zhou and South China Investment Inc. on December 6, 2007; (2) on Defendants Bill Shu Wai Ma, Christ Investment Service Inc., CIS Service, Inc. on December 2, 2007; and (3) on Defendant Pacific Best Group Ltd. a.k.a. Pacific Best Company Ltd. on September 27, 2007. Under Fed. R. Civ. P. 12, the Defendants must serve an Answer or other response to the Complaint within twenty days from the date they were served with the Complaint and Summons. Defendants R nPn Z o' n S u C i Ivs etIcsAnswers or other u i husad ot h a net n n. g h n m ' responses to the Complaint were due by December 26, 2007. Defendants Bill Shu Wai Ma' s , Christ Investment Service Inc.' and CIS Service, Inc.' s , sAnswers or other responses to the Complaint were due by December 24, 2007. Defendant Pacific Best Group Ltd.' A s e o s nw r r other response to the Complaint was due by October 17, 2007. As shown by the Wu Declaration, as of 9:18 am on Monday, February 11, 2008, none of the above Defendants has filed an Answer or other response to the Complaint. In addition, Plaintiffs' one hs not received from such Defendants an Answer or other response to the cusl a Complaint in the mail, by fax, by email, or any other means. For the foregoing reasons, pursuant to Fed. R. Civ. P. 55(a), Plaintiffs respectfully request that the Clerk enter a default against Defendants Run Ping Zhou a.k.a. Flora Zhou, Bill Shu Wai Ma, Christ Investment Service Inc., CIS Service, Inc., Pacific Best Group Ltd. a.k.a. Pacific Best Company Ltd., and South China Investment Inc.

Respectfully Submitted, COOKE, KOBRICK, & WU LLP Dated: February 11, 2008 /s/ By: STEPHEN S. WU Attorneys for Plaintiffs

-2P A N IF ' L I TF S REQUEST FOR ENTRY OF DEFAULT/ Case No.: C-07-04946 JSW