Saldana v. Mission Drywall, Inc. et al

Western District of Texas, txwd-5:2018-cv-01060

MOTION for Entry of Default against Mission Drywall, Inc. by Michael Saldana.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION § MICHAEL SALDAÑA, § Individually and on behalf § of all others similarly situated, § § Civil Action No. 5:18-cv-01060-FB Plaintiff, § § v. § JURY TRIAL DEMANDED § MISSION DRYWALL, INC., BOB MUTZ, § and DAVID ERNST, § COLLECTIVE ACTION § PURSUANT TO 29 U.S.C. § 216(b) Defendants. § § PLAINTIFF'S REQUEST FOR ENTRY OF DEFAULT AGAINST DEFENDANT MISSION DRYWALL, INC. Pursuant to Federal Rule of Civil Procedure 55(a), Plaintiffs request that the Clerk of Court enter default against Defendant Mission Drywall, Inc., for failure to answer the Complaint or otherwise defend with respect to the Complaint herein. (See ECF No. 1). Plaintiff further requests that they have twenty-one (21) days to file their Motion for Default with this Court after the Entry of Default against Defendant is recorded. In support of this request, Plaintiff relies upon the record in this case and the Declaration of Clif Alexander attached hereto as Exhibit A. Date: April 5, 2019 Respectfully submitted, ANDERSON ALEXANDER, PLLC By: /s/ Clif Alexander Clif Alexander Federal I.D. No. 1138436 Texas Bar No. 24064805 clif@a2xlaw.com Lauren E. Braddy Federal I.D. No. 1122168 Texas Bar No. 24071993 lauren@a2xlaw.com Alan Clifton Gordon Federal I.D. No. 19259 Texas Bar No. 00793838 cgordon@a2xlaw.com Carter T. Hastings Federal I.D. No. 3101064 Texas Bar No. 24101879 carter@a2xlaw.com 819 N. Upper Broadway Corpus Christi, Texas 78401 Telephone: (361) 452-1279 Facsimile: (361) 452-1284 Attorneys in Charge for Plaintiff and the Putative Class Members CERTIFICATE OF SERVICE I hereby certify that on April 5, 2019, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Western District of Texas, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the attorneys of record who have consented in writing to accept this Notice as service of this document by USPS First Class Mail. /s/ Clif Alexander Clif Alexander