UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION

RAFAEL SEGOVIA,

an individual,

PLAINTIFF,

v. 

AHNS GROUP, INC., 

a domestic corporation, 

 DEFENDANT.

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* Case No. 3:22-cv-535

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PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT

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The undersigned counsel, on behalf of Plaintiff, Joey Ramos, moves this 

Court for entry of a default judgment against Defendant, AHNS GROUP, INC., a 

limited company, (“DEFENDANT”), upon the complaint heretofore filed and 

served upon the Defendant, in accordance with the provisions of Rule 55(a) and Rule 

55(b)(2) of the Federal Rules of Civil Procedure, and in support thereof shows the 

Court the following: 

1. On March 23, 2022, the Plaintiff filed in the United States District Court, 

Northern District of Texas, Dallas Division, a Complaint alleging certain 

violations of the Americans with Disabilities Act. (ECF Document 1)

2. On March 10, 2022, the Court issued a Summons for defendant.

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3. On March 23, 2022, a copy of said Complaint and said Summons were served 

upon the Defendant by private process server licensed in the State of Texas. 

(ECF Document 7)

4. On April 11, 2022, Plaintiff agreed to an extension for Defendant to file its 

Answer, making the deadline to file an Answer be April 25, 2022.

5. Defendant has failed to answer, plead or otherwise defend this action by the 

deadline of April 25, 2022.

6. On May 19, 2022, the Clerk of Court has entered the default of the defendant, 

AHNS GROUP, INC., a limited company. (ECF Document 10)

7. Pursuant to the provisions of Rule 55(a) and Rule 55(b)(2) of the Federal 

Rules of Civil Procedure, this Court is empowered to enter a default judgment 

against the Defendant for relief sought by the Plaintiff in its Complaint, and 

written notice of this action has been given to the Defendant as set forth in the 

attached affidavit. 

WHEREFORE, Plaintiff prays that this Court enter a judgment of default against 

the Defendant, and that the Defendant be ordered to fully remedy all barriers to entry 

as defined by the ADA that are present at the property that is the subject of this 

litigation as alleged in his Complaint. Further, Plaintiff prays for an award of 

attorney’s fees consistent with the provisions of the ADA to be determined by 

subsequent affidavit and/or hearing. 

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This 19th day of May, 2022.

Respectfully submitted,

By:/s/ Duncan Strickland 

Duncan Strickland

Counsel for Plaintiff

State Bar No.: 24072374

13423 Blanco Road

San Antonio, TX 78216

Telephone: (210) 504-7874

Facsimile: (832) 218-4317

E-mail: Duncan@TexasLandLordAttorney.com

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing has been sent to the Service List via 

United States Postal Service First Class mail and by United States Postal Service 

Certified mail (tracking: 9407-1118-9876-5879-4665-18) on the 19th of May, 2022.

/s/ Duncan Strickland

SERVICE LIST:

JASON CHOE

CHOE.WALKER

2727 Lyndon B Johnson Fwy., Ste. 1020

Farmers Branch, TX 75234

Attorney for AHNS GROUP, INC.

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