IN
THE
CIRCUIT COURT
OF
THE
NINTH JUDICIAL CIRCUIT,
IN AND FOR ORANGE COUNTY, FLORIDA
WRIGHT ENTERTAINMENT
GROUP,
LLC
and WRIGHT
ENTERTAINMENT GROUP, INC.,
Plaintiffs,
vs.
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
------=D:....:e:..:::t.:..:en""'d=a-=n::..:t::..:s.
_____
I
CASE
NO:
48-2007-CA-014233-O
DIVISION: 32
MOTION FOR DEFAULT
COME(S) NOW the Plaintiffs, WRIGHT ENTERTAINMENT GROUP,
LLC
and
WRIGHT ENTERTAINMENT GROUP, INC. (collectively referred
to
hereinafter
as
"Plaintiffs"),
by
and through their undersigned attorneys, and moves
this Court for the entry
of
a default against the Defendant, BRITNEY TOURING,
INC., for failure
to
file an Answer or responsive pleading
to
the Plaintiffs'
Complaint
as
required by Rule l.140(a)(l)
of
the Florida Rules
of
Civil Procedure
and in support thereof would state the following:
1.
The Plaintiffs filed their initial Complaint with this Court on October
26,
2007.
2.
The Defendant, BRITNEY SPEARS, is the President and a Director
of
BRITNEY TOURING, INC., a Louisiana corporation registered to conduct business
Case No.: 48-2007-CA-014233 Page 1
of3
ns'
Motion for Clerk's Default
in Florida. (See attached Application for Authorization
to
Transact Business in
Florida -Exhibit A).
3.
On November
1,
2007, personal service
of
process was perfected on
BRITNEY SPEARS, as President
of
BRITNEY TOURING, INC., who received the
Summons and Complaint in the above-captioned case on said date. (See attached
Notice
of
Filing Affidavits
of
Service on the Defendants- Exhibit B).
4.
On November
9,
2007, personal service
of
process was perfected on the
Registered Agent, Kim Glover for Corporation Service Company, for the Defendant,
BRITNEY TOURING, INC., who received the Summons and Complaint in the
above-captioned case on said date. (See Exhibit B).
5.
The Defendant, BRITNEY TOURING, INC., was served a copy
of
the
Notice
of
Filing Affidavits
of
Service on the Defendants on November 21, 2007. (See
attached certified mail return receipt cards for BRITNEY SPEARS' residence, place
of
employment, and Registered Agent for BRITNEY TOURING, INC. -Exhibit
C).
6.
The Defendant, BRITNEY TOURING INC., has failed
to
answer the
Complaint or file a responsive pleading pursuant
to
Rule 1.140 (a)(l)
of
the Florida
Rules
of
Civil Procedure and within the time specified on the Summons. (See
attached Summons -Exhibit D).
7.
The Plaintiffs further state that this action has been brought in a county
in
which venue is proper, pursuant
to§
47, Florida Statutes.
Case No.: 48-2007-CA-014233 Page 2
of3
ns' Motion for Clerk's Default
WHEREFORE, Plaintiffs, WRIGHT ENTERTAINMENT GROUP, LLC
and WRIGHT ENTERTAINMENT GROUP, INC., respectfully request that this
Court enter a default against the Defendant, BRITNEY TOURlNG INC., for failure
to
file
a responsive pleading to the Plaintiffs' Complaint pursuant to Rule 1.140
(a)(
1)
of
the Florida Rules
of
Civil Procedure.
Respectfully Submitted,
Isl
Cfay
~-
<J'ownsena
CLAY M. TOWNSEND, ESQ.
FloridaBarNo.: 363375
KEITH MITNIK, ESQ.
Florida Bar No.: 436127
GREGORIO FRANCIS, ESQ.
Florida Bar No.: 8478
MORGAN & MORGAN, P.A.
20 N. Orange Avenue, Ste. 1600
Orlando, FL 32801
PH:
(407)420-1414
Fax: ( 407) 425-8171
Attorneys
for
Plaintiffs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy
of
the foregoing has been
furnished,
by.
certified mail, this
18
th
day
of
December, 2007, to: Britney Spears,
12095 Summit Circle, Beverly Hills, CA 90210; Britney Spears, 10100 Santa
Monica Boulevard, Suite 1300, Los Angeles, CA 90067-4114; and Britney
Touring, Inc., c/o Corporation Service Company (Registered Agent),
1201
Hays
Street, Tallahassee, FL 32301-2525.
Case No.: 48-2007-CA-014233
Isl
Cfay
~-
<J'ownsena
Clay Townsend, Esquire
Page 3
of3
71:s'
Motion
for
Clerk's Default
