Motion For Default Judgment

Case 2:24-cv-00295-JAD-EJY Document 20 Filed 02/22/24 Page 1 of 11
MR. CLAYTON-M. BERNARD-EX.

Mr. Clayton-M. Bernard-Ex.
10120 W. Flamingo Rd, Ste 4-215
Las Vegas, Nevada 89147
Tel: (702) 530-6740
Email: mr.claytonm.bernardex@gmail.com
Secured Party Creditor/ Beneficial Owner/

Attorney-in-Fact for MR. CLAYTON-M. BERNARD-EX.
UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
Mr. Clayton-M. Bernard-Ex., Case No.: 2:24-cv-00295-JAD-EJY

Plaintiff(s),
MOTION FOR DEFAULT
JUDGMENT AGAINST
-V- DEFENDANTS JENNIFER A.
DORSEY AND ELAYNA J. YOUCHAH
Las Vegas Township Justice Court JURY TRIAL DEMANDED

(aka) Las Vegas Justice Court,
an Entity;
Jessica Goodey, in her private,
Individual and official capacity;
Erica Adam Goodman (aka)
Eric A. Goodman, in his private,
individual and official capacity;
Jennifer Anna Dorsey (aka)
Jennifer A. Dorsey, in her private,
Gloria Marie Navarro
(aka) Gloria M. Navarro,
in her private, individual
and official capacity;
Richard Franklin Boulware II (aka)
Richard F. Boulware II;
Richard F. Boulware; Richard Boulware II, in his private,

Aaron Blazevich-Gonzalez (aka) Aaron Blazevich;
Aaron Gonzalez, in his private,
Elayna J. Youchah, in her private,
Natalie M. Cox (aka) Natalie Cox,
in her private, individual and official capacity;
Maximiliano D. Couvillier III,
in his private, individual and official capacity;
Daniel J. Albregts, in his private,
James Cameron Mahan (aka) James C. Mahan,
Robert A. McQuaid Jr., in his private,
Robert C. Jones, in his private,
Larry R. Hicks, in his private,
Kent J. Dawson, in his private,
Andrew Patrick Gordon (aka)
Andrew P. Gordon, in his private,
Howard D. McKibben, in his private,
Vincent Cam Ferenbach (aka)
Vincent Ferenbach; Cam Ferenbach,
Christina Dionne Silva (aka) Christina D. Silva,
Anne Rachel Traum (aka) Anne R. Traum,
Mike Kiyoshi Nakagawa (aka) Mike K. Nakagawa;
Mike Nakagawa, in his private,
Nancy J. Koppe (aka) Nancy Jill Koppe,
Craig Stephen Denny (aka)

Craig S. Denny, in his private,
Carla B. Balwin (aka) Carla Balwin,
James Paul Oetken (aka) James P. Oetken;
James Oetken, in his private, individual and official capacity;
Brenda N. Weksler (aka) Brenda Weksler,
Jennifer Elaine Willis (aka) Jennifer E. Willis; Jennifer Willis,
Miranda Mai Du (aka) Miranda M. Du, in her private,
Jennifer Paige Togliatti (aka) Jennifer P. Togliatti; Jennifer Togliatti,
in her private, individual and official capacity
and et al,
Defendants.
DEFAULT JUDGMENT
AGAINST DEFENDANTS JENNIFER A. DORSEY AND ELAYNA J.
YOUCHAH
MEMORANDUM OF POINTS AND AUTHORITES
I. Introduc on
Plain ff, Mr. Clayton-M. Bernard-Ex, respec ully moves for default judgment against
Defendants Jennifer Anna Dorsey (aka) Jennifer A. Dorsey and Elayna J. Youchah
pursuant to Rule 55 of the Federal Rules of Civil Procedure. Defendants have egregiously
failed to adhere to their judicial obliga ons, violated established legal procedures, and
demonstrated a blatant disregard for the United States Cons tu on and laws. Their
ac ons warrant the most severe of consequences – default judgment.
II. Background
Defendants Jennifer Anna Dorsey (aka) Jennifer A. Dorsey and Elayna J. Youchah, both
judges in this honorable court, stand accused not only in their capacity as judges but
also as individual defendants in the underlying ma er involving racial discrimina on,
conspiracy against rights, depriva on of rights, and copyright infringement under
relevant sec ons of the United States Code.
Despite being served with Summons and Objec ons mely filed by Plain ff, Defendants
have failed to respond in accordance with the Federal Rules of Civil Procedure and this
Court's direc ves. They have not rebu ed the Affidavit Legal No ce and Demand, nor
have they complied with their oath of office to uphold the Cons tu on and laws of the
United States.
III. Legal Merits for Default Judgment

A. Failure to Comply with Deadlines: Defendants were under obliga on to respond to
Plain ff's filings within the specified meframes as per the Federal Rules of Civil
Procedure and this Court's direc ves. Their failure to do so warrants default judgment.
The Supreme Court has held that failure to adhere to prescribed deadlines cons tutes
grounds for default judgment (See Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd.
P'ship, 507 U.S. 380 (1993)).
B. Viola on of Oath of Office: Defendants, as judicial officers, have sworn an oath to

uphold the Cons tu on and laws of the United States. Their failure to comply with legal
procedures and cons tu onal obliga ons cons tutes a viola on of this oath and
warrants default judgment (See 28 U.S. Code § 453 - Oaths of jus ces and judges).
C. Refusal to Comply with Local Rules: Defendants' refusal to comply with the Local
Rules of this Court, par cularly IB 3-1 and IB 3-2, further underscores their disregard for
legal procedures and jus fies the imposi on of default judgment.
IV. Precedent Case Law

Numerous legal precedents support the gran ng of default judgment under
circumstances similar to those presented by Defendants' egregious conduct. Courts have
consistently ruled in favor of default judgment when par es, especially judicial officers,
fail to comply with procedural rules and cons tu onal obliga ons (See Marshall v.
Bagge , 616 F.3d 849 (8th Cir. 2010); Silge v. Merz, 510 F.3d 157 (2d Cir. 2007)).
V. Conclusion
In light of Defendants' failure to respond within the prescribed deadlines, their viola on
of the oath of office, and refusal to comply with legal procedures, Plain ff respec ully
requests this honorable Court to enter default judgment against Defendants Jennifer
Anna Dorsey (aka) Jennifer A. Dorsey and Elayna J. Youchah.
Dated this 22nd day of February 2024

Respec ully submi ed,
/s/ Mr. Clayton-M. Bernard-Ex., UCC 1-308, All rights reserved.
10120 W. Flamingo Rd, Ste 4-215
Tel: (702) 530-6740
I AFFIRM UNDER PENALTY OF PERJURY UNDER THE LAWS OF

THE UNITED STATES OF AMERICA THAT FORGOING IS TRUE AND
CORRECT. See 28 U.S.C. § 1746 AND 28 U.S.C. § 1621.
Dated this 22nd day of February 2024

Respectfully Submitted by:

____________________________________________
MR. CLAYTON-M. BERNARD-EX.
10120 W Flamingo Rd Ste 4-215
Tel: (702) 530-6740
Secured Party Creditor/ Beneficial Owner/

Attorney-in-Fact for MR. CLAYTON-M. BERNARD-EX
CERTIFICATE OF SERVICE
I certify that on this 22nd day of February 2024, I served a true and correct
copy of the forgoing MOTION FOR DEFAULT JUDGMENT AGAINST
DEFENDANTS JENNIFER ANNA DORSEY aka JENNIFER A. DORSEY AND
ELAYNA J. YOUCHAH through CM/ECF Electronic Filing system of the United
States District Court for the District of Columbia (or. If necessary, by U.S. Mail,
first class, postage pre-paid), upon the following:
DATED this 22nd day of February 2024

10120 W Flamingo Rd Ste 4-215
Tel: (702) 530-6740
Secured Party Creditor/ Beneficial Owner/
A orney-in-Fact for MR. CLAYTON-M. BERNARD-EX.
1. LAS VEGAS TOWNSHIP JUSTICE COURT

(AKA) LAS VEGAS JUSTICE COURT, AN ENTITY.
200 LEWIS AVENUE,
LAS VEGAS, NEVADA 89101
2. JESSICA GOODEY, IN HER PRIVATE,

INDIVIDUAL AND OFFICIAL CAPACITY.
200 LEWIS AVENUE, DEPARTMENT 6B
3 ERIC ADAM GOODMAN (AKA)

ERIC A. GOODMAN, IN HIS PRIVATE,
200 LEWIS AVENUE, DEPARTMENT 11
4. ELAYNA J. YOUCHAH, IN HER PRIVATE,

333 LAS VEGAS BOULEVARD SOUTH
5. JENNIFER ANNA DORSEY, IN HER PRIVATE,

333 LAS VEGAS BOULEVARD SOUTH
6. GLORIA MARIE NAVARRO

(AKA) GLORIA M. NAVARRO, IN HER PRIVATE,
333 LAS VEGAS BLVD SOUTH
7. RICHARD F. BOULWARE, IN HIS PRIVATE,

8. MAXIMILIANO D. COUVILLIER III, IN HIS PRIVATE,

9. VINCENT CAM FERENBACH (AKA);

VINCENT FERENBACH; (AKA)
CAM FERENBACH, IN HIS PRIVATE,
10. ANDREW PATRICK GORDON

(AKA) ANDREW P. GORDON, IN HIS PRIVATE,
11. DANIEL J. ALBREGTS, IN HIS PRIVATE,

12. ROBERT A. MCQUAID JR, IN HIS PRIVATE,

13. KENT J. DAWSON, IN HIS PRIVATE,

14. LARRY R. HICKS, IN HIS PRIVATE,

15. ROBERT C. JONES, IN HIS PRIVATE,

16. CRAIG STEPHEN DENNEY

(AKA) CRAIG S. DENNEY, IN HIS PRIVATE,
17. JAMES C. MAHAN, IN HIS PRIVATE,

18. BRENDA WEKSLER, IN HER PRIVATE,

19. CRISTINA D. SILVA, IN HER PRIVATE,

20. ANNE R. TRAUM, IN HER PRIVATE,

21. NANCY J. KOPPE, IN HER PRIVATE,

22. CARLA BALWIN, IN HER PRIVATE,

23. MIRANDA MAI DU (AKA)

MIRANDA M. DU, IN HER PRIVATE,
24. CARLA B. BALDWIN (AKA) CARLA BALDWIN,

in her private, individual and official capacity.
25. AARON BLAZEVICH-GONZALEZ (AKA) AARON BLAZEVICH;

AARON GONZALEZ, in his private, individual and official capacity.
26. RICHARD FRANKLIN BOULWARE II (AKA) RICHARD F. BOULWARE II;

RICHARD BOULWARE II, in his private, individual and official capacity.
27. NATALIE M. COX (AKA) NATALIE COX,

28. NANCY JILL KOPPE (AKA) NANCY J. KOPPE;

NANCY KOPPE, in her private, individual and official capacity.
29. JAMES CAMERON MAHAN (AKA) JAMES C. MAHAN;

JAMES MAHAN, in his private, individual and official capacity.
30. MIKE KIYOSHI NAKAGAWA (AKA) MIKE K. NAKAGAWA;

MIKE NAKAGAWA, in his private, individual and official capacity.
31. JAMES PAUL OETKEN (AKA) JAMES P. OETKEN;

JAMES OETKEN, in his private, individual and official capacity.
32. CRISTINA DIONNE SILVA (AKA) CRISTINA D. SILVA;

CRISTINA SILVA, in her private, individual and official capacity.
33. JENNIFER PAIGE TOGLIATTI (AKA) JENNIFER P. TOGLIATTI;

JENNIFER F. TOGLIATTI, in her private, individual and official capacity.
200 LEWIS AVENUE
34. ANNE RACHEL TRAUM (AKA) ANNE R. TRAUM;

ANNE TRAUM, in her private, individual and official capacity.
35. BRENDA N. WEKSLER (AKA) BRENDA WEKSLER,

36. JENNIFER ELAINE WILLS (AKA) JENNIFER E. WILLS;

JENNIFER WILLIS, in her private, individual and official capacity.

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Case 2:24-cv-00295-JAD-EJY Document 20 Filed 02/22/24 Page 1 of 11

MR. CLAYTON-M. BERNARD-EX.

Secured Party Creditor/ Beneficial Owner/

UNITED STATES DISTRICT COURT

Mr. Clayton-M. Bernard-Ex., Case No.: 2:24-cv-00295-JAD-EJY

Las Vegas Township Justice Court JURY TRIAL DEMANDED

individual and official capacity;

Craig Stephen Denny (aka)

MEMORANDUM OF POINTS AND AUTHORITES

III. Legal Merits for Default Judgment

B. Viola on of Oath of Oﬃce: Defendants, as judicial oﬃcers, have sworn an oath to

IV. Precedent Case Law

Dated this 22nd day of February 2024

I AFFIRM UNDER PENALTY OF PERJURY UNDER THE LAWS OF

Dated this 22nd day of February 2024

/s/ Mr. Clayton-M. Bernard-Ex., UCC 1-308, All rights reserved.

Secured Party Creditor/ Beneficial Owner/

DATED this 22nd day of February 2024

/s/ Mr. Clayton-M. Bernard-Ex., UCC 1-308, All rights reserved.

1. LAS VEGAS TOWNSHIP JUSTICE COURT

2. JESSICA GOODEY, IN HER PRIVATE,

3 ERIC ADAM GOODMAN (AKA)

4. ELAYNA J. YOUCHAH, IN HER PRIVATE,

5. JENNIFER ANNA DORSEY, IN HER PRIVATE,

6. GLORIA MARIE NAVARRO

7. RICHARD F. BOULWARE, IN HIS PRIVATE,

8. MAXIMILIANO D. COUVILLIER III, IN HIS PRIVATE,

9. VINCENT CAM FERENBACH (AKA);

10. ANDREW PATRICK GORDON

11. DANIEL J. ALBREGTS, IN HIS PRIVATE,

12. ROBERT A. MCQUAID JR, IN HIS PRIVATE,

13. KENT J. DAWSON, IN HIS PRIVATE,

14. LARRY R. HICKS, IN HIS PRIVATE,

15. ROBERT C. JONES, IN HIS PRIVATE,

16. CRAIG STEPHEN DENNEY

17. JAMES C. MAHAN, IN HIS PRIVATE,

18. BRENDA WEKSLER, IN HER PRIVATE,

19. CRISTINA D. SILVA, IN HER PRIVATE,

20. ANNE R. TRAUM, IN HER PRIVATE,

21. NANCY J. KOPPE, IN HER PRIVATE,

22. CARLA BALWIN, IN HER PRIVATE,

23. MIRANDA MAI DU (AKA)

24. CARLA B. BALDWIN (AKA) CARLA BALDWIN,

25. AARON BLAZEVICH-GONZALEZ (AKA) AARON BLAZEVICH;

26. RICHARD FRANKLIN BOULWARE II (AKA) RICHARD F. BOULWARE II;

27. NATALIE M. COX (AKA) NATALIE COX,

28. NANCY JILL KOPPE (AKA) NANCY J. KOPPE;

29. JAMES CAMERON MAHAN (AKA) JAMES C. MAHAN;

30. MIKE KIYOSHI NAKAGAWA (AKA) MIKE K. NAKAGAWA;

31. JAMES PAUL OETKEN (AKA) JAMES P. OETKEN;

32. CRISTINA DIONNE SILVA (AKA) CRISTINA D. SILVA;

33. JENNIFER PAIGE TOGLIATTI (AKA) JENNIFER P. TOGLIATTI;

34. ANNE RACHEL TRAUM (AKA) ANNE R. TRAUM;

35. BRENDA N. WEKSLER (AKA) BRENDA WEKSLER,

36. JENNIFER ELAINE WILLS (AKA) JENNIFER E. WILLS;

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