Case 2:18-cv-02433-SVW-JPR Document 25-1 Filed 05/17/18 Page 1 of 3 Page ID #:133

1 Marc Y. Lazo, SBN 215998

WILSON KEADJIAN BROWNDORF LLP
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1900 Main Street, Suite 600
3 Irvine, CA 92614
Phone No.: (949) 407-5029
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Fax No.: (949) 234-6254
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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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11 MICHAEL DAVIS, an individual; Case No. 2:18-cv-02433-SVW-JPR
and UPTONE PICTURES, INC., a
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North Carolina corporation DECLARATION OF MARC LAZO IN
13 Plaintiffs, SUPPORT OF REQUEST FOR ENTRY
14 v. OF DEFAULT
ERIC PARKINSON, an individual;
15 HANNOVER HOUSE, INC., a
16 Wyoming corporation; TRUMAN
PRESS, INC. (d/b/a "HANNOVER
17 HOUSE"), an Arkansas corporation,
18 CRIMSON FOREST
ENTERTAINMENT GROUP, INC.,
19 a Nevada Corporation; HINDS &
20 SHANKMAN, a California Limited
Liability Partnership, and
21 MEDALLION RELEASING, INC.,
22 an Arkansas corporation, and DOES
1-10,
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Defendants.
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Wilson Keadjian
Browndorf LLP
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Attorneys at Law DECLARATION OF MARC LAZO
Irvine, CA
 Case 2:18-cv-02433-SVW-JPR Document 25-1 Filed 05/17/18 Page 2 of 3 Page ID #:134

1 DECLARATION OF MARC LAZO

2 I, MARC Y. LAZO, declare as follows:
3 1. I am an attorney authorized to practice law in the United States District Court for the
4 Central District of California. I am a Partner at Wilson Keadjian Browndorf LLP, attorneys of record
5 herein for the Plaintiffs Michael Davis and Uptone Pictures, Inc. (collectively, the “Plaintiffs”) in the
6 above-entitled action. This declaration is based upon my personal knowledge of the facts stated herein
7 and if called to testify as a witness, I could and would completely testify thereto.
8 2. On March 26, 2018, Plaintiffs filed a Complaint including Medallion Releasing, Inc.
9 (“Medallion”) as a defendant. [Dkt. 1]
10 3. On April 3, 2018, Defendant Medallion was properly served with the summons and
11 complaint as identified in the filed proof of service. [Dkt. 18]. A true and correct copy of the proof of
12 service is attached as Exhibit 1.
13 4. Pursuant to Federal Rule of Civil Procedure 12(a)(1)(A)(i), defendant Medallion’s
14 response to the Complaint was due on April 24, 2018.
15 5. Defendant Medallion has not answered or otherwise responded to the Complaint. A true
16 and correct copy of the docket in this matter as of the time of filing this Request, showing that no answer
17 or response has been filed, is attached as Exhibit 2.
18 6. To my knowledge, Defendant Medallion is not a minor, an incompetent person, or a
19 person in military service or otherwise exempted from default judgement under the Servicemember
20 Civil Relief Act of 1940.
21 I declare under penalty of perjury under the laws of the United States that the foregoing

22 statements are true and correct.

23
24 May 17, 2018
25 __________________________________________

26 Marc Y. Lazo

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Wilson Keadjian
Browndorf LLP
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Attorneys at Law DECLARATION OF MARC LAZO
Irvine, CA
 Case 2:18-cv-02433-SVW-JPR Document 25-1 Filed 05/17/18 Page 3 of 3 Page ID #:135

1 CERTIFICATE OF SERVICE
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3 I certify that on May 17, 2018, I caused a copy of the foregoing to be filed

4 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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7 by the CM/ECF system.
8 Executed on May 17, 2018, at Irvine, California.
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By: ______________________
12 Marc Lazo
13 Attorney for Plaintiffs
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Wilson Keadjian
Browndorf LLP
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Attorneys at Law DECLARATION OF MARC LAZO
Irvine, CA