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Case No.: 48-2007-CA-014233 Page 1 of 3 Agreed Motion for Oral Argument

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

WRIGHT ENTERTAINMENT GROUP,

LLC and WRIGHT ENTERTAINMENT

GROUP, INC.,

Plaintiff(s),

vs.

BRITNEY SPEARS and BRITNEY

TOURING, INC.,

Defendant(s). /

CASE NO.: 48-2007-CA-014233-O

AGREED MOTION FOR ORAL ARGUMENT

AND EVIDENTIARY HEARING

Plaintiffs, WRIGHT ENTERTAINMENT GROUP, LLC and WRIGHT

ENTERTAINMENT GROUP, INC. (hereinafter referred to collectively as

“Plaintiffs”) by and through their undersigned counsel and pursuant to Business

Court Procedure 5.4, hereby requests entry of an order granting oral argument and

evidentiary hearing on Defendants’ Verified Motion to Set Aside Final Default

Judgments (“Motion”) and states as follows:

1. On March 24, 2008, Defendants moved this Court to set aside the

defaults entered against them on December 18, 2007 and Final Judgments as to

liability entered on February 14, 2008.

2. The grounds asserted for Defendants’ Motion include excusable neglect

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Case No.: 48-2007-CA-014233 Page 2 of 3 Agreed Motion for Oral Argument

and specifically that the Court set aside Final Default Judgments against the

Defendants for Defendant SPEARS’ excusable neglect due to incapacity.

3. Plaintiffs request that the Court set a hearing for oral argument and

evidence, including testimony, required by Fl. R. Civ. P. 1.540(b) in order to permit a

full examination of the evidence and enable this Court to enter a proper judgment.

4. The Plaintiffs believe that oral argument may assist the Court with the

facts and law in the Motion and Plaintiffs’ anticipated response.

5. Default judgments may not be set aside absent evidence of excusable

neglect, due diligence, and meritorious defense. Geer v. Jacobsen, 880 So.2d 717

(Fla. 2nd DCA 2004); see also Andrade v. Andrade, 720 So.2d 551 (Fla. 4th DCA

1998)(court conducted an evidentiary hearing on the details of Appellee’s conduct).

Wherefore, Plaintiffs hereby request that this Honorable Court grant oral

argument and an evidentiary hearing for two (2) hours on the Defendants’ Verified

Motion to Set Aside Final Default Judgments and such other relief as this Court may

deem appropriate.

Certification Pursuant to BCP 5.3

The undersigned represents that he has conferred with Judith Mercier, counsel

for the Defendants, by emailing her on April 2, 2008 and speaking with her on April

3, 2008 at which time the counsel for the Defendants had no opposition to an oral

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Case No.: 48-2007-CA-014233 Page 3 of 3 Agreed Motion for Oral Argument

argument and an evidentiary hearing for two (2) hours on the Defendants’ Verified

Motion to Set Aside Final Default Judgments.

Dated this 4th day of April, 2008. Respectfully Submitted,

_/s/ Clay M. Townsend

/s/ Clay M. Townsend/s/ Clay M. Townsend

/s/ Clay M. Townsend______

CLAY M. TOWNSEND, ESQ.

Florida Bar No.: 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 U.S. mail, this 4th day of April, 2008, to: Judith Mercier, Esq., Jorge

Hernandez-Torano, Esq. and Bill Wilson, Esq., Holland & Knight, LLP, 200 S.

Orange Avenue, Suite 2600, Orlando, FL 32801.

__/s/ Clay M. Townsend

/s/ Clay M. Townsend/s/ Clay M. Townsend

/s/ Clay M. Townsend_

Clay M. Townsend, Esq.

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