Opinion
1:21-cv-06323
01-28-2022
BUMKOO INDUSTRIAL CO., LTD, Plaintiff, v. CROWN BRANDS LLC dba Oneida Hospitality Group, and THE ONEIDA GROUP INC., Defendants.
Mark D. Petersen, Pro Hac Vice Attorneys for Plaintiff BUMKOO INDUSTRIAL CO., LTD.
Mark D. Petersen, Pro Hac Vice Attorneys for Plaintiff
BUMKOO INDUSTRIAL CO., LTD.
AFFIDAVIT OF MARK D. PETERSEN IN SUPPORT OF PLAINTIFF'S MOTION FOR ENTRY OF JUDGMENT AND PROVE UP OF DAMAGES
JUDGE: HON. ROBERT M. DOW, JR.
AFFIDAVIT IN SUPPORT OF REQUEST FOR ENTRY OF DEFAULT
I, Mark D. Petersen, declare under penalty of perjury that the following facts are true and correct to the best of my information and belief:
1. I am an attorney at law, admitted to practice before this Court pro hac vice. I am a partner with the firm of Farella Braun + Martel LLP, counsel of record for Plaintiff Bumkoo Industrial Co., Ltd.
2. A complaint was filed in this case on November 24, 2021. Crown was served pursuant to Rule 4(c), Fed.R.Civ.P. by Service of Summons, which was duly served by special process server on December 1, 2021. See Exhibit 1 (Affidavit of Service on Crown Brands LLC), attached hereto.
3. More than twenty-one days have elapsed since the date of service, and Crown has failed to plead or otherwise defend this action, as required by the Federal Rules of Civil Procedure.
4. On January 25, 2022, my office served a copy of this Court's January 14, 2022 minute entry (stating that Plaintiff's motion for an Order of Default had been granted and a
prove-up hearing had been set for February 4, 2020 at 9:00 a.m.) upon Crown. See Exhibit 2 (Process of Service), attached hereto.
5. On information and belief, defendants are not infants, incompetent natural persons, or persons in military service or otherwise exempted from default judgment.
Pursuant to 28 U.S.C. section1746, I verify under penalty of perjury that the foregoing is true and correct.