Davis Motion For Default

Case 2:18-cv-02433-SVW-JPR Document 49 Filed 10/10/18 Page 1 of 14 Page ID #:243
MARC Y. LAZO, SBN: 215998

1 WILSON KEADJIAN BROWNDORF, LLP
2 1900 Main Street, Suite 600
Irvine, CA 92614
3 Phone No.: (888) 690-5557
4 Fax No.:(949) 234-6254
5 Attorneys for Plaintiffs MICHAEL DAVIS and UPTONE PICTURES, INC.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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MICHAEL DAVIS, an individual; and Case No.: 2:18−cv−02433−SVW−JPR
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UPTONE PICTURES, INC., a North
12 Carolina corporation, NOTICE OF APPLICATION AND
13 APPLICATION FOR DEFAULT
Plaintiffs, JUDGMENT BY COURT AGAINST
14 ERIC PARKINSON, CRIMSON
vs. ENTERTAINMENT GROUP, INC.,
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TRUMAN PRESS, INC., MEDALLION
16 ERIC PARKINSON, an individual; RELEASING, INC., AND HANNOVER
HANNOVER HOUSE, INC., a HOUSE, INC.
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Wyoming corporation; TRUMAN
18 PRESS, INC. (d/b/a "HANNOVER
Date: November 19, 2018
19 HOUSE"), an Arkansas corporation,
Time: 1:30 p.m.
CRIMSON FOREST
The Honorable Stephen V. Wilson
20 ENTERTAINMENT GROUP, INC., a
Courtroom 10A
21 Nevada Corporation; HINDS &
SHANKMAN, a California Limited
22 Liability Partnership, and
23 MEDALLION RELEASING, INC.,
an Arkansas corporation, and DOES
24 1-10,
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Defendants.
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NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE THAT on November 19, 2018 at 1:30 p.m., or as soon
3 thereafter as this matter may be heard by the above-entitled Court, located at First Street
4 Courthouse, 350 West First Street, Courtroom 10A, Los Angeles, CA 90012, Plaintiffs
5 MICHAEL DAVIS (“DAVIS”) and UPTONE PICTURES, INC. (“UPTONE”)
6 (hereinafter collectively referred to as “PLAINTIFFS”) will present their application for
7 a default judgment against Defendants ERIC PARKINSON (“PARKINSON”),
8 CRIMSON ENTERTAINMENT GROUP, INC. (“CRIMSON”), TRUMAN PRESS,
9 INC. (“TRUMAN”), MEDALLION RELEASING, INC. (“MEDALLION”), and
10 HANNOVER HOUSE, INC. (“HANNOVER”) (collectively “Defendants”). The clerk
11 has previously entered the default of TRUMAN, MEDALLION, HANNOVER
12 Defendants on May 18, 2018, and the default of PARKINSON and CRIMSON
13 Defendants on September 7, 2018. At the time and place of hearing, Plaintiffs will
14 present proof of the following matters:
15 1. Such Defendants are not minors or incompetent persons or in military
16 service or otherwise exempted under the Soldiers’ and Sailors’ Civil Relief Act of 1940;
17 and
18 2. Such Defendants have not appeared in this action;
19 3. Notice of this application for default judgment by the Court was served as
20 set forth in the Declaration of Service filed herein and by Local Rules 14.12.1.
21 4. Plaintiffs are entitled to judgment against Defendants on account of the
22 following claims pleaded in the complaint: Breach of Contract, Tortious Breach of
23 Covenant of Good Faith and Fair Dealing, Fraud by False Promise, Fraud by
24 Concealment, Unfair Competition in Violation of Cal. Bus. & Prof. Code §17200 et seq.,
25 Unjust Enrichment, Accounting, and Violation of Cal. Civ. Code sec. 1719.
26 5. The amount of judgment sought against Defendants is the sum of
27 $10,000.00 in liquidation damages due to DEFENDANTS’ fraudulent accountings plus
28 $800,000.00 due to DEFENDANTS’ business disparagement of PLAINTIFFS in their
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1 place of work; $150,000.00 due to DEFENDANTS’ negligence and failure to deliver the
2 Picture in DVD format in a timely matter that resulted in lost in sales $1,500.00 in
3 statutory damages due to violation of Cal. Civ. Code sec. 1719; $1,500.00 in costs and
4 expenses related to the subject action set forth in the declarations of Michael Davis and
5 Marc Y. Lazo.
6 The Application is based on this Notice, the declarations and exhibits filed
7 herewith, and the pleadings, files, and other matters that may be presented at the
8 hearing.
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10 Dated: October 10, 2018 WILSON KEADJIAN BROWNDORF, LLP
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12 ______________________________
Marc Y. Lazo
13 Attorney for Plaintiff
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1 APPLICATION FOR DEFAULT JUDGMENT BY COURT

2 1. This legal dispute primarily centers around DEFENDANTS’ refusal,
3 excepting Defendant HINDS & SHANKMAN, LLP (“H&S”), to perform under the terms
4 of a Settlement Agreement (“SA”) even though PLAINTIFFS have fulfilled their
5 obligations under the contract. Despite the repeated demands by PLAINTIFFS,
6 DEFENDANTS, excepting H&S, refuse to abide by the required terms of the SA.
7 (Declaration of Michael Davis (“Decl. Davis”) ¶2).
8 2. Plaintiff UPTONE is the authorized distribution agency and proprietor, as
9 well as the licensing source for the feature film, Union Bound (“Picture.”) Plaintiff
10 DAVIS acted as the principal of the Picture and maintained exclusive control and creative
11 responsibility for developing, producing and directing the Picture, and at all times alleged
12 herein owned all rights to the Picture. (Decl. Davis ¶3).
13 3. Defendants HANNOVER and MEDALLION and TRUMAN are
14 commercial business entities in the market of film distribution and campaign –
15 advertisement for television programs in all applicable formats; and additionally, relating
16 to media for theatrical releases, home video and video-on-demand markets in the territory
17 of the United States of America and English-speaking provinces of Canada. (Decl. Davis
18 ¶4).
19 4. Defendant PARKINSON is an individual with managerial responsibility and
20 ownership interests in HANNOVER, TRUMAN, and MEDALLION. (Decl. Davis ¶5).
21 5. Defendant H&S, is a California law firm that was retained by the other
22 Defendants to consult, negotiate, and advocate for HANNOVER, TRUMAN,
23 MEDALLION, CRIMSON, and PARKINSON in their business dealings with
24 PLAINTIFF. (Decl. Davis ¶6).
25 6. In or around mid-2015, Defendant PARKINSON and Defendant H&S
26 entered into preliminary discussions with Plaintiff DAVIS. The negotiations concentrated
27 on a potential agreement for Defendants HANNOVER, TRUMAN, MEDALLION, and
28 PARKINSON to market and distribute the Picture prior to its release.
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1 7. On or about January 12, 2016, PLAINTIFFS and DEFENDANTS,

2 excepting. CRIMSON and H&S, reached a final and fully executed Sales Agreement,
3 whereby DEFENDANTS received the exclusive right to advertise, market, license, and
4 distribute the Picture in set geographic areas. Under the Sales Agreement, PLAINTIFFS
5 received a cash amount calculated from the prospective gross revenue of the Picture.
6 (Decl. Davis ¶6).
7 8. Despite the Sales Agreement, DEFENDANTS, excepting CRIMSON and
8 H&S, manifestly failed to use commercially reasonable standards to perform.
9 DEFENDANTS, excepting, CRIMSON and H&S, refused to make the agreed-on Sales
10 Agreement expenditures for adequate advertising; failed to provide suitable
11 documentation to evidence the placement of the Picture in agreed-upon market areas in
12 the United States; and otherwise refused to perform its obligations. (Decl. Davis ¶7).
13 9. Upon PLAINTIFFS making demand for assurances of contract performance
14 and explanations for DEFENDANTS’ non-performance, excepting CRIMSON’S and
15 H&S’, no suitable response was received.
16 10. On March 12, 2017, PLAINTIFFS initiated a lawsuit in federal court,
17 stemming from DEFENDANTS’, excepting CRIMSON’S and H&S’, total breach of
18 obligations under the original Sales Agreement. The anticipated lawsuit sought damages
19 for Breach of Contract; Breach of Covenant of Good Faith and Fair Dealing; Breach of
20 Fiduciary Duty; False Promise; Unjust Enrichment; Intentional Misrepresentation;
21 Fraudulent Concealment; Unfair Business Practices, and Accounting. (Decl. Davis ¶8).
22 11. On or about May 10, 2017, Defendant PARKINSON and Defendant
23 HANNOVER entered into a Stock-for-Stock Swap with CRIMSON, whereby the
24 companies took the initial steps to merge the business entities into one. PLAINTIFFS
25 were never informed of this business development, and DEFENDANTS intentionally
26 withheld all information related to this event. PLAINTIFFS willingness and business
27 decision to enter in to the SA would have been altered had such information been given
28 to them. Moreover, this action of not informing PLAINTIFFS is exactly synonymous to
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1 PARKINSON’S, HANNOVER’S, MEDALLION’S, and TRUMAN’S previous conduct

2 under the Sales Agreement. (Decl. Davis ¶9).
3 12. In or about September 2017, PLAINTIFFS and DEFENDANTS entered into
4 the SA for the federal lawsuit to be dismissed with prejudice. (Decl. Davis ¶10, Ex. A).
5 To date, PLAINTIFFS have abided by the confidentiality terms of the SA, but this present
6 and pending legal dispute obligates PLAINTIFFS to provide this Court with copy for
7 adjudication and enforcement purposes. The SA called for DEFENDANTS to, among
8 other bargained-for duties and obligations, provide the previously breached advertising,
9 promotional, and distribution services to PLAINTIFFS in furtherance of the commercial
10 marketing of the Picture they had originally agreed to undertake. (Decl. Davis ¶10).
11 13. As a material inducement of PLAINTIFFS entering into the SA,
12 PLAINTIFFS required verified documentation detailing the financial health of
13 HANNOVER, MEDALLION, and TRUMAN, such as current and recent business
14 transactions. The required documentation resulted from DEFENDANTS’ counsel’s
15 verbal and written representations that his clients were financially destitute, and in fact
16 owed him several thousand dollars in attorney’s fees. (Decl. Davis ¶11).
17 14. The disclosure of financial documents from Defendant H&S to
18 PLAINTIFFS and their attorneys served the purpose of informing PLAINTIFFS to what
19 degree PARKINSON, HANNOVER, MEDALLION, and TRUMAN could ever satisfy a
20 monetary judgment, and thus whether pursuing the same would ever be fruitful. Upon
21 review of the verified financial documentation, PLAINTIFFS determined that
22 DEFENDANTS would never be able to satisfy a monetary judgment – even a nominal
23 one – which H&S confirmed on numerous occasions. (Decl. Davis ¶12).
24 15. DEFENDANTS, particularly H&S, never disclosed – and PLAINTIFFS are
25 informed and believe actively and fraudulently concealed – the existence of the stock
26 purchase agreement and merger between Defendant CRIMSON and Defendant
27 HANNOVER. The May 2017 Stock-for-Stock Purchase was purposely and entirely
28 withheld by H&S in the negotiation discussions with PLAINTIFFS, and H&S made
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1 representations to the contrary in furtherance of their fraudulent inducement efforts to

2 procure dismissal with prejudice of the underlying federal case. (Decl. Davis ¶12).
3 16. The lack of full disclosure of the merger and Stock-for-Stock Purchase
4 between Defendant HANNOVER and Defendant CRIMSON is direct evidence that the
5 verified information disclosed to PLAINTIFFS during the negotiations were incomplete
6 and inaccurate. Current financial schedules were not actually current because statements
7 did not reflect Defendant CRIMSON’S existing operations and outstanding liabilities.
8 PLAINTIFFS lacked full and complete knowledge of the degree to which PARKINSON,
9 HANNOVER, TRUMAN and MEDALLION could commit to the Picture, particularly
10 because of the merger information that was withheld. (Decl. Davis ¶12).
11 17. While Defendant H&S is not a nominal party to the SA, H&S’s
12 misrepresentations were reasonably relied upon by PLAINTIFFS as being true and
13 accurate, particularly due to the following provisions in the SA that imputed an
14 affirmative duty upon H&S to have provided honest and accurate information to
15 PLAINTIFFS, upon which H&S knew PLAINTIFFS would be relying in agreeing to
16 settle the underlying matter under the terms and conditions set forth in the SA as the
17 following: In the event the Parties hereto breach any of the provisions, covenants or
18 promises set forth herein, to the extent that any representation made by any Party hereto
19 or by any Parties’ counsel should prove to be materially false, in addition to other relief
20 to which the other Party may be entitled hereunder, the other Party shall also be entitled
21 to injunctive relief from a court of competent jurisdiction, to enforce the terms of this
22 Settlement Agreement and obtain the benefits intended between the Parties. (Decl. Davis
23 ¶10, Ex. A, page (“pg.”), 11, paragraph (“¶”)14.) This Settlement Agreement, and all the
24 terms and provisions hereof, shall be binding on the Parties and their respective heirs,
25 legal representatives, successors and assigns, and shall inure to the benefit of the Parties
26 and their respective heirs, legal representatives, successors, and assigns. (Decl. Davis ¶10,
27 Ex. A, pg. 11, ¶15.) This Settlement Agreement in all respects has been voluntarily and
28 //
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1 knowingly executed by the Parties on advice and with approval of their respective legal
2 counsel. (Decl. Davis ¶10, Ex. A, pg. 11; ¶13).
3 18. Unaware of the extent of DEFENDANTS’ business dealings, excepting
4 H&S, PLAINTIFFS filed their Request for Dismissal under Federal Rules of Civil
5 Procedure 41 (a) or (c) on October 2, 2017. Since that time, all actions taken by
6 Defendants HANNOVER, MEDALLION, TRUMAN, and PARKINSON have been in
7 contravention of the SA and in a manner exactly similar to conduct regarding the previous
8 Sales Agreement. (Decl. Davis ¶14).
9 19. Under Paragraph 2 of the SA et seq., “Settlement Terms,” Defendant
10 PARKINSON is required to issue a signed statement under penalty of perjury attesting to
11 DEFENDANTS’ compliance under the SA. On or about December 21, 2017, Defendant
12 PARKINSON issued a sworn affidavit and declaration detailing his version of the events
13 and his belief of DEFENDANTS’ completed obligations under the SA. In effect,
14 however, PARKINSON’S sworn affidavit and declaration directly points out to this Court
15 DEFENDANTS’ breaches, excepting H&S, given the explicit contradictions between the
16 terms of the SA and Defendant PARKINSON’S recitation of the “terms.”
17 20. DEFENDANTS, excepting H&S, materially breached the terms of the SA
18 by intentionally misquoting the division of the Picture’s home video revenues to recoup
19 overall costs. The SA states DEFENDANTS, excepting H&S, and PLAINTIFFS will
20 divide video revenue proceeds according to 60% to PLAINTIFFS and 40% to
21 DEFENDANTS’ split, excepting H&S. (Decl. Davis ¶10, Ex. A, pg. 3, ¶2.) As a result,
22 PLAINTIFFS only received $2,539 as their portion in revenue from a total $5,078 of
23 proceeds. In actuality, PLAINTIFFS should have received $3,046.80, pursuant to the SA.
24 This is the first blatant instance of DEFENDANTS, excepting H&S, manifestly breaching
25 the SA and trying to insert their own terms. (Decl. Davis ¶15).
26 21. DEFENDANTS, excepting H&S, further materially breached the terms of
27 the SA by intentionally ignoring the required accounting to accompany the Sales
28 Proceeds: “A full accounting of said sales proceeds [of the Picture] shall be completed by
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1 Defendants [DEFENDANTS, discluding H&S] and given to Plaintiffs [PLAINTIFFS.]”

2 (Decl. Davis ¶10, Ex. A, pg. 3, ¶2). Under the SA, the accounting was due by the 46th
3 day since the full execution of the agreement. (Decl. Davis ¶10, Ex. A, pg. 3, ¶2).
4 DEFENDANTS have neither provided an accounting nor given an explanation for the
5 lack of this contractual term being met. (Decl. Davis ¶16).
7 by refusing to make good faith attempts to resell the existing inventory. Under the SA, by
8 the 46th day after full execution, DEFENDANTS, excepting H&S, are to attempt to sell-
9 off remaining inventory at Wal-Mart and other similar retailers through Budget/Value Bin
10 selection. (Decl. Davis ¶10, Ex. A, pg. 3-4, ¶3). The SA further anticipates that the
11 duration and coordination of this placement process may extend to possibly June 1, 2018.
12 And, absent the successful implementation of a Budget/Value Bin option, a third-party
13 may be selected to sell-off the remaining inventory. (Decl. Davis ¶10, Ex. A, pg. 4, ¶3;
14 ¶17.)
15 23. DEFENDANTS, excluding H&S, additionally materially breached the terms
16 of the SA by refusing to return the unsold Picture inventory cost-free to PLAINTIFFS.
17 For, the SA mandates “All copies of the [Picture] will not be destroyed… [but] delivered
18 to Plaintiff Uptone [UPTONE] at Hannover House’s [HANNOVER’S] expense…”
19 within 45 days of execution of the SA (Decl. Davis ¶10, Ex. A, pg. 7, ¶9.)
20 DEFENDANTS’ unilateral decision, excepting H&S, to either destroy the remaining
21 product or charge Plaintiff UPTONE a fee per unit for return is contrary to the SA’s terms
22 and is a material breach. (Decl. Davis ¶18).
23 24. DEFENDANTS, excepting H&S, further materially breached the terms of
24 the SA by refusing to carry out commercially reasonable methods to carry out third-party
25 collection services for PLAINTIFFS. Under the SA, DEFENDANTS, excepting H&S,
26 must make best efforts to procure sale proceeds from third parties, such as Cinedigm,
27 INC. or Technicolor, INC., in accordance with the 60% - PLAINTIFFS, 40% -
28 DEFENDANTS’ division of revenue, excepting H&S. (Decl. Davis ¶10, Ex. A, pg. 5,
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1 ¶4.) The division of sales proceeds was previously bargained for and agreed to between
2 PLAINTIFFS and DEFENDANTS, excepting H&S, to be set at 60% for PLAINTIFFS
3 and 40% for DEFENDANTS, excepting H&S. The attempts of DEFENDANTS,
4 excepting H&S, to re-state the terms to their benefit in such a manner is a material breach
5 of the SA.
7 by providing a check with insufficient funds to PLAINTIFFS. On or about November 20,
8 2017, DEFENDANTS, excepting H&S, remitted a check for “$2,539” to PLAINTIFFS
9 for the 50% share of the Picture sale proceeds. Despite the fact that this check amount of
10 “$2,539 was only 50%” of the current total sales proceeds when it should have been
11 “3,046.80, [60%]” the partial payment did not even clear when cashed. DEFENDANTS,
12 excepting H&S, knowingly submitted a bad check to PLAINTIFFS, and this conduct
13 amounts to one more action in a history of deceptive conduct.
14 26. DEFENDANTS, excepting H&S, have materially violated the terms of the
15 SA by their blatant attempt to unload costs from third-party Cinedigm, INC. onto
16 PLAINTIFFS. Pursuant to the SA, any money due to third-party Cinedigm is to be
17 entirely borne from DEFENDANTS, excepting H&S. (Decl. Davis, Ex. A, pg. 6, ¶5.)
18 27. On or about January 10, 2018, Plaintiff DAVIS attempted to cash a check
19 remitted to him by the DEFENDANTS, excepting H&S. Plaintiff DAVIS was informed
20 that the check could not be cashed due to insufficient funds. Through counsel,
21 PLAINTIFFS provided written demand to DEFENDANTS, excepting H&S, more than
22 30 days prior to brining the suit, and satisfying the requirements of California Civil Code
23 section 1719. (Declaration of Mark Y. Lazo (“Decl. Lazo”) ¶4.)
24 28. On March 28, 2018, through counsel, PLAINTIFFS filed their Complaint
25 (“Complaint”) for Breach of Contract, Tortious Breach of Covenant of Good Faith and
26 Fair Dealing, Fraud by False Promise, Fraud by Concealment, Unfair Competition in
27 Violation of Cal. Bus. & Prof. Code §17200 et seq., Unjust Enrichment, Accounting, and
28 Violation of Cal. Civ. Code sec. 1719 (Decl. Lazo ¶5.)
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1 29. The Complaint was properly served on DEFENDANTS. PLAINTIFFS filed

2 the Proof of Service of Summons (Decl. Lazo ¶6.)
3 30. DEFENDANTS failed to file a response to Complaint in a timely manner.
4 Therefore, PLAINTIFF submitted their Application for Entry of Default as to
5 DEFENDANTS. The clerk entered the default of TRUMAN, MEDALLION,
6 HANNOVER Defendants on May 18, 2018, and the default of PARKINSON and
7 CRIMSON Defendants on September 7, 2018. (Decl. Lazo ¶7.)
8 31. Defendants’ actions, excepting H&S, have violated Plaintiffs’ rights under
9 the SA, and I ask this Court to hold them accountable. (Decl. Davis ¶19; Decl. Lazo ¶8.)
10 32. Based on information PLAINTIFFS have learned from the industry contacts,
11 PLAINTIFFS are informed and believe that DEFENDANTS committed fraud by
12 distributing the Picture in digital form and withholding all the related profits, which
13 bluntly violates the SA and entitles PLAINTIFFS to “…liquidated damages in an amount
14 equal to the greater of $10,000.00 or the amount of actual proceeds due and owing to
15 UPTONE.” (Decl. Davis ¶10, Ex. A. p. 5 ¶5; ¶20.)
16 33. DEFENDANTS further violated the SA by disparaging PLAINTIFFS as an
17 unethical individual/entity, irreversibly damaging their position in the film industry.
18 Under the law, such damage to my business reputation are presumed as damages.
19 PLAINTIFFS have lost close to $800,000.00 in business deals that would otherwise have
20 consummated, including foreign theatrical and digital sales, U.S. digital sales, on demand
21 sales, OTT (Netflix, Hulu, etc.) sales and other ancillary sales as well as future projects.
22 (Decl. Davis ¶21.)
23 34. Moreover, due to DEFENDANTS’ negligence and failure to deliver the
24 Picture in DVD format in a timely matter, PLAINTIFFS were affected by the substantial
25 decline in the DVD market resulting in significant lost in sales. (Decl. Davis ¶10, Ex. A,
26 p. 10 ¶26; ¶22.)
27 //
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1 35. As such, as of date of signing this Declaration, Plaintiff’s Request for Court
2 Judgment comprises of the following:
3 a. $10,000.00 in liquidation damages due to PLAINTIFFS fraudulent
4 accountings;
5 b. $800,000.00 due to DEFENDANTS’ business disparagement of
6 PLAINTIFFS in their place of work;
7 c. $150,000.00 due to DEFENDANTS’ negligence and failure to deliver the
8 Picture in DVD format in a timely matter that resulted in lost in sales;
9 d. $1,500.00 in statutory damages due to violation of Cal. Civ. Code sec. 1719;
10 e. $1,500.00 in costs related to the subject action.
11 (Decl. Davis ¶21,22; Decl. Lazo ¶ 9.)
12 36. Accordingly, judgment should be entered in the amount of $963,000.00
13 against Defendants PARKINSON, CRIMSON, TRUMAN, MEDALLION, and
14 HANNOVER. (Decl. Lazo ¶10.)
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17 Dated: October 10, 2018 WILSON KEADJIAN BROWNDORF, LLP
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19 ______________________________
Marc Y. Lazo
20 Attorney for Plaintiff
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1 CERTIFICATE OF SERVICE
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I certify that on October 10, 2018, I caused a copy of the foregoing to be filed
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electronically and that the document is available for viewing and downloading from the
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ECF system. Participants in the case who are registered CM/ECF users will be served
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by the CM/ECF system.
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Executed on October 10, 2018, at Irvine, California.
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9 By: ______________________________
10 Marc Y. Lazo
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PROOF OF SERVICE
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2 I am employed in the City and County of Orange, California. I am over the age of 18 and
not a party to the within action. My business address is 1900 Main Street, Ste. 600, Irvine, CA 92614.
3
On October 10, 2018, I served the following document(s) described as:
4
5 AGAINST ERIC PARKINSON, CRIMSON ENTERTAINMENT GROUP, INC., TRUMAN
6 PRESS, INC., MEDALLION RELEASING, INC., AND HANNOVER HOUSE, INC.
7 on the interested parties listed below:
8 Hannover House, Inc. Eric Parkinson

300 North College Avenue, Suite 311 300 North College Avenue, Suite 311
9 Fayetteville, AR 72701 Fayetteville, AR 72701
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Medallion Releasing, Inc. Truman Press, Inc.
11 300 North College Avenue, Suite 311 300 North College Avenue, Suite 311,
Fayetteville, AR 72701 Fayetteville, AR 72701
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Crimson Entertainment Group, Inc.
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8335 W. Sunset Blvd., Ste. 238
14 Los Angeles, CA 90069
15 [X] BY UNITED PARCEL SERVICE: On the above mentioned date, I placed a true copy of the
above mentioned document(s) in a sealed envelope or package designated by United Parcel
16 Service with delivery fees paid or provided for, addressed to the person(s) as indicated above
17 and deposited same in a box or other facility regularly maintained by United Parcel Service to
received documents.
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[X] (Federal) I declare that I am employed in the office of a member of the Bar of this Court at
19 whose direction the service was made. I declare under penalty of perjury under the laws of the
United States of America that the above is true and correct.
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21 I declare under penalty of perjury that I am employed in the office of a member of the bar of
this Court at whose direction this service was made and that the foregoing is true and correct.
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23 Executed on October 10, 2018, at Irvine, California.
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25 CARRIE RUIZ
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Davis Motion For Default

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Case 2:18-cv-02433-SVW-JPR Document 49 Filed 10/10/18 Page 1 of 14 Page ID #:243

MARC Y. LAZO, SBN: 215998

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD:

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 7. On or about January 12, 2016, PLAINTIFFS and DEFENDANTS,

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 PARKINSON’S, HANNOVER’S, MEDALLION’S, and TRUMAN’S previous conduct

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 representations to the contrary in furtherance of their fraudulent inducement efforts to

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 Defendants [DEFENDANTS, discluding H&S] and given to Plaintiffs [PLAINTIFFS.]”

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

1 29. The Complaint was properly served on DEFENDANTS. PLAINTIFFS filed

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

7 on the interested parties listed below:

8 Hannover House, Inc. Eric Parkinson

NOTICE OF APPLICATION AND APPLICATION FOR DEFAULT JUDGMENT BY COURT

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