LAW OFFICES OF THOMAS MORE HOLLAND 

BY: THO MAS MORE HOLLAND

IDENTIFICATION NO.: 43517

1522 LOCUST STREET

GRACE HALL

PHILADELPHIA, PA 19102

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

 

JOSEPH MARINO §

Plaintiff, § 

v. §

§

KENT LINE INTERNATIONAL §

d/b/a VOYAGEUR SHIPPING LTD., et al. § CIVIL ACTION No.: 02-CV-4488

Defendants. §

§

 § 

 

 

ORDER

And now this day of , 2003 based upon the Motion of Plaintiff for the imposition of

a default judgment against Joseph Levy and Maureen Levy and any reply thereto the Motion is

GRANTED. This matter shall proceed to trial against Defendants Joseph Levy and Maureen Levy

with respect to damages only. As a matter of law Defendants Joseph Levy and Maureen Levy are liable

to Plaintiff. 

 

J.

Case 2:02-cv-04488-BMS Document 41 Filed 08/22/2003 Page 1 of 5
LAW OFFICES OF THOMAS MORE HOLLAND 

BY: THO MAS MORE HOLLAND

IDENTIFICATION NO.: 43517

1522 LOCUST STREET

GRACE HALL

PHILADELPHIA, PA 19102

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

 

JOSEPH MARINO §

Plaintiff, § 

v. §

§

KENT LINE INTERNATIONAL §

d/b/a VOYAGEUR SHIPPING LTD., et al. § CIVIL ACTION No.: 02-CV-4488

Defendants. §

§

 § 

 

MOTION FOR ENTRY OF A DEFAULT JUDGEMENT AGAINST

DEFENDANTS JOSEPH LEVY AND MAUREEN LEVY

Joseph Marino by and through his counsel the Law Offices of Thomas More Holland,

hereby moves to impose a default judgment against Defendants Joseph Levy and Maureen Levy. In

support thereof it is averred:

1. The above captioned action was filed in 1992. On or about May of 2003 the

subsequent cause of action No.: 03-CV-3058. That subsequent action named

Defendants Joseph Levy and Maureen Levy. 

2. Sua sponte the Court consolidated the 2002 action with the 2003 action under the

2002 docket number.

3. Defendant Joseph Levy was served at the address referenced in the caption of the

2003 action: Gloucester City Pier, Gloucester, New Jersey 08030.

4. Appended hereto and made apart hereof is a copy of the Summons that was filed

timely with the clerk, Exhibit “A”. 

5. Defendant Maureen Levy was served at the address referenced in the caption of the

2003 action: Gloucester City Pier, Gloucester, New Jersey 08030.

6. Appended hereto and made apart hereof is a copy of the Summons that was filed

timely with the clerk, Exhibit “B”. 

Case 2:02-cv-04488-BMS Document 41 Filed 08/22/2003 Page 2 of 5
7. Defendant Joseph Levy has failed to enter an appearance in this action.

8. Defendant Maureen Levy has failed to enter an appearance in this action.

9. It is believed and averred that Defendants Joseph Levy and Maureen Levy are adults,

competent, are not infirm and are not now or any time since this action has been

filed serving in the United States Military. 

10. Defendants Joseph Levy and Maureen Levy have failed to plead or otherwise defend.

11. Plaintiff would be unduly prejudiced if the default judgment is not entered.

WHEREFORE, it is respectfully requested that default judgments be entered against

Defendants Joseph Levy and Maureen Levy.

Respectfully Submitted, 

Date: August 22, 2003 

THOMAS MORE HOLLAND

Attorney for Plaintiff

Case 2:02-cv-04488-BMS Document 41 Filed 08/22/2003 Page 3 of 5
LAW OFFICES OF THOMAS MORE HOLLAND 

BY: THO MAS MORE HOLLAND

IDENTIFICATION NO.: 43517

1522 LOCUST STREET

GRACE HALL

PHILADELPHIA, PA 19102

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

 

JOSEPH MARINO §

Plaintiff, § 

v. §

§

KENT LINE INTERNATIONAL §

d/b/a VOYAGEUR SHIPPING LTD., et al. § CIVIL ACTION No.: 02-CV-4488

Defendants. §

§

 § 

 

 

BRIEF IN SUPPORT OF THE ENTRY OF A DEFAULT JUDGEMENT AGAINST

DEFENDANTS JOSEPH AND MAUREEN LEVY

Respondents Joseph Levy and Maureen Levy have failed to appear in this action. These

Defendants have failed to plead or otherwise defend as provided in the rules. As a consequence the

default judgment can be entered in the Court’s discretion at this time. 

Alternatively the Court may conduct hearings to determine what is necessary and proper in

adjudicating whether the Plaintiff is entitled to the relief of the entry of a default against these

Defendants. 

Respectfully submitted,

 

Date: August 22, 2003 THOMAS MORE HOLLAND

 Attorney for Plaintiff

Case 2:02-cv-04488-BMS Document 41 Filed 08/22/2003 Page 4 of 5
PROOF OF SERVICE

I, Thomas More Holland, Esquire, hereby certify that a true and correct copy of the foregoing

ENTRY OF A DEFAULT JUDGEMENT AGAINST DEFENDANTS JOSEPH AND

MAUREEN LEVY to the court and counsel of record electronically:

Ann-Michele G. Higgins, Esquire

Rawle & Henderson LLP

The Widener Building

One South Penn Square

Philadelphia, PA 19107

A. Robert Degen, Esquire

Fox Rothschild O’Brien & Frankel

2000 Market Street - 10

th floor

Philadelphia, PA 19103

Faustino Mattioni, Esquire

Mattioni, Ltd.

399 Market Street

2d Floor

Philadelphia, PA 19106

and to the pro se Defendants by regular mail:

Mr. Joseph & Maureen Levy 

Trans Ocean Maritime Services Inc.

P.O. Box 560

Gloucester City, NJ 08030-0560

 

Date: August 22, 2003 THOMAS MORE HOLLAND

Attorney for Plaintiff

Case 2:02-cv-04488-BMS Document 41 Filed 08/22/2003 Page 5 of 5