Case 2:12-cv-05662-PA-CW Document 31

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Leslie J. Hughes, Colo. Bar No. 15043 HughesLJ@sec.gov Securities and Exchange Commission 1801 California Street, Suite 1500 Denver, Colorado 80202 Telephone: (303) 844-1000 Fax: (303) 844-1068 Attorney for Plaintiff United States Securities and Exchange Commission UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff v. Gold Standard Mining Corp., et al. Defendants. ) ) ) ) ) ) ) ) ) )

Case No. 2:12-cv-5662 PA(CWx) PLAINTIFFS APPLICATION FOR THE CLERK TO ENTER DEFAULT AGAINST DEFENDANT KENNETH G. EADE

TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA: Plaintiff Securities and Exchange Commission (SEC) requests under Fed. R. Civ. P. 55(a) that the Clerk of the Court enter default against defendant Kenneth G. Eade (Eade) on the grounds that he has failed to respond to the complaint within the time prescribed by Fed. R. Civ. P. 12(a) and the Courts Order dated October 1, 2012 [ECF # 30]. 1. Defendant Eade was served with the Summons and Complaint on July 5, 2012, pursuant to Fed. R. Civ. P. 4(e)(2)(A). See Hughes Dec. at 2 and

Case 2:12-cv-05662-PA-CW Document 31

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Notice of Service Eade [ECF # 6]. 2. 3. 3. The SEC filed its first application for entry of default against Eade on July 30, 2012[ECF # 10], which was denied on August 10, 2012 [ECF # 16], because subsequently on July 31, 2012, Eade filed a motion to dismiss [ECF #11]. 4. at 4. 5. 6. Eade failed to file an answer on October 22, 2012 as required by Accordingly, the SEC requests that the Clerk of the Court enter Fed. R. Civ. P. 12 (a)(1)(C). See Docket Sheet, Exhibit 1; Hughes Dec. at 6. default against defendant Eade pursuant to Fed. R. Civ. P. 55(a) because Eade has failed to respond to the complaint within the time set by the Courts order. Dated: October 23, 2012. Respectfully submitted, /s/ Leslie J. Hughes Leslie J. Hughes Attorney for Plaintiff Securities and Exchange Commission The Court denied Eades motion to dismiss on October 1, 2012, and ordered him to file an answer by October 22, 2012. [ECF # 30] See Hughes Dec. Under Fed. R. Civ. P. 12(a)(1)(A)(i), Eade was required to answer or otherwise respond to the Complaint or before July 26, 2012. See Hughes Dec. at

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CERTIFICATE OF SERVICE I certify that on October 23, 2012, I electronically filed Plaintiffs Application for The Clerk to Enter Default Against Defendant Kenneth Eade with the Clerk of the Court using the ECF system, which will send notification of such filing to all parties of record herein: Kenneth G. Eade, Esq. 6699 Wilshire Blvd. Suite 507 Los Angeles, California 90048-5708 Keneade@gmail.com Appearing Pros se

I certify that on October 23, 2012, I caused true and correct copies of the foregoing to be mailed: Edward Randall Gruber, CPA Gruber & Co. LLC 99 Saybridge Manor Parkway Lake Saint Louis, MO 63367-1808 Appearing Pro se Irving M. Einhorn, Esq. 1710 10th Street Manhattan Beach, CA 90266-6206 Attorney for Panteleimon Zachos and Gold Standard Mining Corporation

/s/ Leslie J. Hughes