MOTION FOR DEFAULT JUDGMENT - 1

NATURAL RESOURCE LAW GROUP, PLLC

2217 NW Market St., Suite 27
Seattle, WA 98107
Ph: (206) 227-9800 Fax: (206) 466-5645





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THE HONORABLE BRUCE HELLER
HEARING DATE: Monday, September 15, 2014
HEARING TIME: 9:00 a.m.
WITHOUT ORAL ARGUMENT









IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING


JEAN MARIE BARTON and BYRON LEE
BARTON,

Plaintiffs,

v.

JP MORGAN CHASE BANK, N.A., FIRST
AMERICAN TITLE, QUALITY LOAN
SERVICE CORPORATION OF
WASHINGTON,

Defendants.
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NO. 14-2-12762-6 SEA

MOTION FOR DEFAULT
JUDGMENT





COMES NOW the above-named Plaintiffs, by and through their attorney, Jill J. Smith and
Natural Resource Law Group, PLLC, and hereby move the Court for an Order granting judgment
for Plaintiffs JEAN AND BYRON BARTON against ALL DEFENDANTS for the relief demanded
in the complaint filed herein.


FILED
14 SEP 04 AM 11:43
KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 14-2-12762-6 SEA


MOTION FOR DEFAULT JUDGMENT - 2
NATURAL RESOURCE LAW GROUP, PLLC
2217 NW Market St., Suite 27
Seattle, WA 98107
Ph: (206) 227-9800 Fax: (206) 466-5645





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STATEMENT OF FACTS
Defendants JP MORGAN CHASE BANK, N.A. and QUALITY LOAN SERVICE CORP
OF WASHINGTON have failed to answer despite being served with a summons and complaint in
this matter and FIRST AMERICAN TITLE has failed to appear. The procedural facts supporting
this motion are brief.
1. Plaintiffs filed their Complaint for Damages in King County Superior Court on May 5,
2014.
2. A Summons and Complaint in this matter were served upon Defendant JP MORGAN
CHASE BANK, N.A. on May 7, 2014. Attached hereto as Exhibit A is a true and correct copy of
the Affidavit of Service.
3. A Summons and Complaint in this matter were served upon Defendant QUALITY LOAN
SERVICE CORPORATION OF WASHINGTON on May 13, 2014. Attached hereto as Exhibit B
is a true and correct copy of the Affidavit of Service.
4. A Summons and Complaint in this matter were served upon Defendant FIRST AMERICAN
TITLE on or about May 13, 2014. Attached hereto as Exhibit C is a true and correct copy of the
Affidavit of Service.
5. Defendant JP Morgan Chase Bank filed a Notice of Appearance by Keesal, Young & Logan
on June 2, 2014.
6. Defendant Quality Loan Service Corporation of Washington filed a Notice of Appearance
by McCarthy and Holthus on June 11, 2014.


MOTION FOR DEFAULT JUDGMENT - 3
NATURAL RESOURCE LAW GROUP, PLLC
2217 NW Market St., Suite 27
Seattle, WA 98107
Ph: (206) 227-9800 Fax: (206) 466-5645





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7. Defendant First American Title has not entered an appearance in the case. All Defendants
have failed to file or serve an Answer or any responsive pleading in this case as of todays date,
September 4, 2014.
In light of the above, a Motion for Default Judgment should be granted in accordance with CR
55(a).
LEGAL AUTHORITIES
This motion is based upon the records and files herein. According to CR 55(a): (1) Motion.
When a party against whom a judgment for affirmative relief is sought has failed to appear, plead, or
otherwise defend as provided by these rules and that fact is made to appear by motion and affidavit,
a motion for default may be made. CR 55(a)(1).
Here, JP Morgan Chase was served with a Summons and Complaint in this case on May 7,
2014. In light of this service date, a responsive pleading was due from Chase on or about July 7,
2014. QLS Corp of WA was served at their Seattle address with a Summons and Complaint on
May 13, 2014, so a responsive pleading was due on or about June 2, 2014. This motion is being
filed on September 4, 2014. As of this date, Defendants JP Morgan Chase and QLS Corp of WA
have failed to serve or file any answer or responsive pleading in relation to this matter; and First
American Title has filed no notice of appearance or responsive pleading, so a Motion for Default
Judgment should be granted.
CR 55(a) also provides: (3) Notice. Any party who has appeared in the action for any
purpose shall be served with a written notice of motion for default and the supporting affidavit at
least five days before the hearing on the motion. Any party who has not appeared before the motion
for default and supporting affidavit are filed is not entitled to a notice of the motion, except as


MOTION FOR DEFAULT JUDGMENT - 4
NATURAL RESOURCE LAW GROUP, PLLC
2217 NW Market St., Suite 27
Seattle, WA 98107
Ph: (206) 227-9800 Fax: (206) 466-5645





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provided in rule 55(f)(2)(A). CR 55(a)(3). This motion, the Declaration of Jill J. Smith, Note for
Motion, and Declaration of Service are being served on JP Morgan Chase Bank and Quality Loan
Service Corporation of Washington.

DATED this 4
th
day of September 2014.

NATURAL RESOURCE LAW GROUP, PLLC

/s/ Jill J. Smith____________________
Jill J. Smith, WSBA #41162
Attorney for Plaintiffs
2217 NW Market St., Suite 27
Seattle, WA 98107
Phone: (206) 227-9800
Fax: (206) 466-5645