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LISA LIBERI, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
Plaintiff, Lisa Liberi, by and through her undersigned counsel, hereby requests that the
Clerk of this Court enter Default for the sum certain as outlined in the Complaint against
Defendant, collectively, jointly and severally, The Sankey Firm a/k/a and The Sankey Firm, Inc.
pursuant to Federal Rule of Civil Procedure 55(a). In support of this request, Plaintiff relies
upon the record in this case and the Declaration of Counsel submitted herein.
Respectfully submitted,
s/ Philip J. Berg
Dated: May 27, 2009 _____________________________
PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Attorney for the Plaintiff, Lisa Liberi
I, Philip J. Berg, Esquire being first duly sworn under oath, state the following:
1. I am the attorney for Plaintiff, Lisa Liberi, in the above-entitled action and I am
2. The Complaint was filed and the Summonses were issued on May 4, 2009.
3. Defendants, The Sankey Firm a/k/a and The Sankey Firm, Inc. was personally
served with a copy of the Summons and Complaint on May 5, 2009, as reflected on the
4. Defendants, The Sankey Firm a/k/a and The Sankey Firm, Inc. Answer was due
7. Plaintiff requests that the Clerk of the Court enter Default in favor of Plaintiff,
Lisa Liberi and against the Defendants, The Sankey Firm a/k/a and The Sankey Firm,
Respectfully submitted,
:
LISA LIBERI, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiff, Lisa Liberi’s Request for
Entry of Default; Declaration in Support of Request for Entry of Default; and Proposed Entry of
Default were served this 27th day of May 2009 via United States Postal Service with postage
s/ Philip J. Berg
___________________________
PHILIP J. BERG, ESQUIRE
Attorney for Plaintiff, Lisa Liberi
:
LISA LIBERI, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
ENTRY OF DEFAULT
Plaintiff, Lisa Liberi; requests that the Clerk of Court enter Default against Defendant,
collectively, jointly and severally, The Sankey Firm a/k/a and The Sankey Firm, Inc.,
pursuant to Federal Rule of Civil Procedure 55(a). It appearing from the record that
Defendant has failed to appear, plead or otherwise defend, the default of Defendant, The
Sankey Firm, is hereby entered pursuant to Federal Rule of Civil Procedure 55(a).
By: ___________________________
Deputy Clerk