Case 2:18-cv-02433-SVW-JPR Document 50 Filed 11/05/18 Page 1 of 5 Page ID #:291

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, PLAINTIFFS’ NOTICE OF NON-
13 OPPOSITION TO APPLICATION FOR
Plaintiffs, DEFAULT JUDGMENT BY COURT
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vs.
15 Date: November 19, 2018
Time: 1:30 p.m.
16 ERIC PARKINSON, an individual;
The Honorable Stephen V. Wilson
HANNOVER HOUSE, INC., a
17 Courtroom 10A
Wyoming corporation; TRUMAN
18 PRESS, INC. (d/b/a "HANNOVER
19 HOUSE"), an Arkansas corporation,
CRIMSON FOREST
20 ENTERTAINMENT GROUP, INC., a
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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PLAINTIFFS’ NOTICE OF NON-OPPOSITION BY DEFENDANTS TO PLAINTIFFS’ APPLICATION FOR

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Case 2:18-cv-02433-SVW-JPR Document 50 Filed 11/05/18 Page 2 of 5 Page ID #:292

1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE THAT there has been no written opposition filed by
3 Defaulted Defendants ERIC PARKINSON (“PARKINSON”), CRIMSON
4 ENTERTAINMENT GROUP, INC. (“CRIMSON”), TRUMAN PRESS, INC.
5 (“TRUMAN”), MEDALLION RELEASING, INC. (“MEDALLION”), and
6 HANNOVER HOUSE, INC. (“HANNOVER”) (collectively “Defendants”) to Plaintiffs
7 MICHAEL DAVIS (“DAVIS”) and UPTONE PICTURES, INC. (“UPTONE”)
8 (hereinafter collectively referred to as “Plaintiffs”) Application for Default Judgment by
9 Court (the “Application"), which is set for hearing on November 19, 2018, at 1:30 p.m.
10 before this Court.
11 On October 10, 2018, Plaintiffs filed the and supporting documents with this
12 Court (Docket No.: 49.) Plaintiffs served the Defendants with the Application and the
13 supporting documents via Overnight United Parcel Service (“UPS”) on October 10, 2018
14 (UPS tracking numbers: 1ZF2R0350191324745, 1ZF2R0350192114372,
15 1ZF2R0350191594552, 1ZF2R0350194636386, 1ZF2R0350190485761.)
16 Pursuant to the Local Rule 7-9, opposing papers shall be filed and served not later
17 than twenty-one (21) days prior the date designated for the hearing of the Application.
18 Defendants’ deadline for submitting the opposing papers was October 29, 2018. As of
19 November 5, 2018, no opposition papers to the Application have been served by the
20 Defendants.
21 Based on the foregoing, Plaintiffs requests that the Defendants be precluded from
22 offering oral argument at the hearing on the Application and that the Court find that the
23 failure of the Defendants to file any opposition papers creates an inference that the
24 Application is meritorious.
25 Wherefore, Plaintiffs respectfully request the Application to be granted in its
26 entirety.
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1 CONCLUSION
2 As such, Plaintiffs respectfully request that this Court grant the Application and
3 enter judgment in the amount of $963,000.00 against each of Defendants PARKINSON,
4 CRIMSON, TRUMAN, MEDALLION, and HANNOVER, jointly and severally.
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6 Dated: November 5, 2018 WILSON KEADJIAN BROWNDORF, LLP
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8 ___________________________
Marc Y. Lazo
9 Attorney for Plaintiff
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1 CERTIFICATE OF SERVICE
2 I certify that on November 5, 2018, I caused a copy of the foregoing to be filed
3 electronically and that the document is available for viewing and downloading from the
4 ECF system. Participants in the case who are registered CM/ECF users will be served
5 by the CM/ECF system.
6 Executed on November 5, 2018, at Irvine, California.
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___________________________
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By Marc 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.
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On November 5, 2018, I served the following document(s) described as:
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PLAINTIFFS’ NOTICE OF NON-OPPOSITION TO APPLICATION FOR DEFAULT
5 JUDGMENT BY COURT
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on the interested parties listed below:
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Hannover House, Inc. Eric Parkinson
8 300 North College Avenue, Suite 311 300 North College Avenue, Suite 311
Fayetteville, AR 72701 Fayetteville, AR 72701
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10 Medallion Releasing, Inc. Truman Press, Inc.
300 North College Avenue, Suite 311 300 North College Avenue, Suite 311,
11 Fayetteville, AR 72701 Fayetteville, AR 72701
12 Crimson Entertainment Group, Inc.
8335 W. Sunset Blvd., Ste. 238
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Los Angeles, CA 90069
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[X] BY OVERNIGHT UNITED PARCEL SERVICE: On the above mentioned date, I placed a true
15 copy of the above mentioned document(s) in a sealed envelope or package designated by
United Parcel Service with delivery fees paid or provided for, addressed to the person(s) as
16 indicated above and deposited same in a box or other facility regularly maintained by United
17 Parcel Service to received documents.

18 [X] (Federal) I declare that I am employed in the office of a member of the Bar of this Court at
whose direction the service was made. I declare under penalty of perjury under the laws of the
19 United States of America that the above is true and correct.
20 I declare under penalty of perjury that I am employed in the office of a member of the bar of
21 this Court at whose direction this service was made and that the foregoing is true and correct.

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Executed on November 5, 2018, at Irvine, California.
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24 /s/ Nicole Lipowski
Nicole Lipowski
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