Opinion
1:21-cv-01383
05-28-2021
LANCE DOLPH SCOTT, Plaintiff, Self-Represented, v. LUKE ANDREW CASSON, ET. AL., Defendants.
Harry D. Leinerweber, District Judge
Suni R. Hariani, Magistrate Judge
PLAINTIFF'S MOTION FOR JUDGMENT BY DEFAULT AGAINST DEFENDANTS LUKE ANDREW CASSON, ANDREOU & CASSON, .. ELIZABETH A. GRANOFF AND LAW OFFICE OF ELIZABETH A. GRANOFF PURSUANT TO FRCP RULE 55(b)(1)
INTRODUCTION
COMES NOW United States Federal Government citizen, LANCE DOLPH SCOTT, plaintiff, self-represented, reserving all of my rights, and waiving none, ever, and submits my motion for judgment by default against defendants Luke Andrew Casson, Andreou & Casson, Elizabeth A. Granoff, Law Office of Elizabeth A. Granoff pursuant to frcp rule 55(b)(1) seeking of this Court, by the Clerk, to enter Default Judgment against defendants Luke Andrew Casson, Andreou & Casson, Elizabeth A. Granoff and Law Office of Elizabeth A. Granoff for their failure to Appear after being served with Summons and Complaint pursuant to frcp rule 55(a)(1).
PROCEDURAL BACKGROUND
On or about the 17th day of March, 2021, pursuant to Rule 4(c)(1)(2) of the Federal Rules of Civil Procedure, via the U.S. Postal Service, I certified mailed a copy of my __.
PLAINTIFF LANCE DOLPH SCOTT'S DELARATION FOR DEFAULT JUDGMENT PURSUANT TO FRCP RULE 55(b)(1)
I, Lance Dolph Scott, plaintiff self-represented declare if called upon could competently testify to the following claims from my own personal knowledge.
I am the plaintiff, self-represented in the above caption cause and the moving party for this default judgment against defendants Luke Andrew Casson, Andreou & Casson, Elizabeth A. Granoff, and Law Offices of Elizabeth A. Granoff in reference to Counts IV to VII of the verified complaint.
I am making this declaration to set forth the amount due per Count of the verified complaint directed against defendants Luke Andrew Casson, Andreou & Casson, Elizabeth A. Granoff, and the Law Offices of Elizabeth Granoff
Count II Title 42 U.S.C. Section 1985(3) Conspiracy To Interfere With Rights Defendant Luke Andrew Casson, Andreou & Casson, Elizabeth . Granoff, Law Office of Elizabeth A. Granoff
$25,000.00 Compensatory damages
$5,000.00 Discretionary damages
$5,000.00 General damages
$5,000.00 Proximate damages
$75,000.00 Punitive damages
Count IV Negligent Breach of Fiduciary Duty, Defendant Luke Andrew Casson, $250,000.00
Count V Conversion, Defendant Luke Andrew Casson, $250,000.00, along with a reasonable interest owed on the wrongful cancelled $6,000.00 second installment payment from the Settlement which was wrongfully with held for twelve (12) years.
Count VI Breach of Contract and Covenant of Good Faith and Fair Dealings, Defendant Luke Andrew Casson, $250,000.00
Count VII Punitive Damages, Defendant Luke Andrew Casson, $40,000.00
2. I, Lance Dolph Scott, declare under penalty of perjury under the Laws of the United States of America that the amount of monies due from defendant Luke Andrew Casson, Andreou & Casson, Elizabeth A. Grandoff, and the Law Offices of Elizabeth A. Granoff as set forth in this declaration is true and correct.