Case 1:07-cv-00555-JJF Document 12 Filed O1/25/2008 Page 1 of 1 I
In the U.S. District Court for the District of Delaware
Xianhua Zhang . __ . _ t . -, _2.... . _ :._. ____
Plaintiff F E i. E D l Case No. 07-555 J
. JAN 2 5 ZGHE
ING Direct .... .... ......7,. t ii Jury Trial Demanded
u.s. as l" ‘’i‘‘‘ ? J
. Sc - i
Request to Enter Default Judgment 1
Please enter default against defendant ING Direct pursuant to Federal Rules of Civil
Procedure Rule 12.
Defendant received the request for Waiver of Service of Summons Form from Plaintiff E
on 10/31/2007 and signed the Form on 11/6/2007. But Defendant did not file the Answer
until 1/7/ 2008. It violates Federal Rules of Civil Procedure Rule 12.
(A) A defendant must serve an answer:
(ii) if it has timely waived service tmder Rule 4; d Q, within 60 days after |
the request for a waiver was sent, or within 90 days after it was sent to the
defendant outside any judicial district of the United States.
WHEREFORE,‘P1aintifiQ Xianhua Zhang, requests that the Court enter Default Judgment
against Defendant ING Direct.
Respectfully submitted,
XWLM Z
Xianhua Zhang
. _ p Plaintiff
Date:[h’5[2lf?é§ 3 - __ _ J
Case 1:07-cv-00555-JJF
Document 12
Filed 01/25/2008
Page 1 of 1