Page 1 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

Dayna J. Christian, OSB #97336

Nicole McMillan, OSB #114573

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, Oregon 97209

Phone: (503) 802-5533

Fax: (503) 802-5351

E-Mail: dayna.christian@immixlaw.com

E-Mail: nicole.mcmillan@immixlaw.com

Attorneys for Plaintiff Morasch Meats, Inc.

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

I. LOCAL RULE 7-1 AND 55-1 CERTIFICATION

Pursuant to Local Rules 7-1 and 55-1, counsel for Plaintiff Morasch Meats, Inc. 

(“Plaintiff” or “Morasch”) certifies that it has thoroughly conferred in good faith with Michelle 

E. Vocht (“Ms. Vocht”), counsel for Frevol HPP, LLC (“Frevol”), All Natural Freshness, Inc. 

(“ANF”), and Gerald R. Ludwick (“Mr. Ludwick”) (collectively “Defendants,” and together with 

MORASCH MEATS, INC., an Oregon 

corporation,

Plaintiff,

v.

FREVOL HPP, LLC fka FRESHER 

EVOLUTION HPP, L.L.C., a Michigan 

limited liability company, dba NEXT HPP; 

ALL NATURAL FRESHNESS, INC., a 

Michigan corporation; and GERALD R. 

LUDWICK, an individual,

Defendants.

Case No.: 3:16-cv-00269-PK

PLAINTIFF MORASCH MEATS, INC.’S

MOTION FOR RECONSIDERATION OF 

PLAINTIFF’S MOTION FOR ENTRY OF 

DEFAULT AND DEFAULT JUDGMENT 

AGAINST DEFENDANTS FREVOL HPP, 

LLC AND ALL NATURAL FRESHNESS, 

INC. ONLY

Oral Argument Requested

Expedited Consideration Requested
Page 2 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

Plaintiff, the “Parties”) via telephone regarding the matters addressed in this Motion for 

Reconsideration of Plaintiff’s Motion for Entry of Default and Default Judgment Against 

Defendants Frevol HPP, LLC and All Natural Freshness, Inc. Only (“Motion for 

Reconsideration”). Due to the content of this Motion for Reconsideration and its request 

directed at the Court, Ms. Vocht’s position is that she cannot consent.

II. MOTION FOR RECONSIDERATION

Pursuant to Federal Rule of Civil Procedure (“FRCP”) 60(b)(6), Plaintiff moves this 

Court for reconsideration of its denial of Plaintiff’s Motion for Entry of Default and Default 

Judgment Against Defendants Frevol HPP, LLC and All Natural Freshness, Inc. Only (Docket 

No. 207) (“Motion for Default”), which was filed on May 24, 2018. Specifically, Plaintiff seeks 

relief from: (1) this Court’s order waiving Local Rule 83-3(a)(1) and permitting Ms. Vocht to 

proceed in representing Defendants without local counsel; and (2) this Court’s order ruling that 

Plaintiff’s dispositive Motion for Default was denied as moot. This Motion for Reconsideration

is supported by the background facts and memorandum of law set forth below.

III. BACKGROUND FACTS

Plaintiff’s Motion for Default includes a complete statement of the background facts 

upon which it is based. See Motion for Default, 2–4. Those background facts are hereby 

incorporated as if fully restated herein. Plaintiff also hereby incorporates as if fully restated 

herein the facts set forth in Plaintiff Morasch Meats, Inc.’s Motion for Sanctions, which detail 

(among other things) the significant need for the assistance of local counsel in this case and the 

impact that ineffective local counsel has had upon Plaintiff and Plaintiff’s counsel during the 

litigation of this case. See Plaintiff Morasch Meats, Inc.’s Motion for Sanctions (Docket No. 

156). 

On May 31, 2018, this Court held a telephone conference to discuss Defendants’ failure 

to obtain local counsel following Alexander Trauman’s (“Mr. Trauman”) withdrawal. See 

Minutes of Proceedings (Docket No. 216). During that telephone conference, the Court waived 
Page 3 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

Local Rule 83-3(a)(1), which requires an out-of-state attorney who is admitted pro hac vice—

such as Ms. Vocht—to associate with local counsel “who will meaningfully participate in the 

preparation and trial of the case.” Local Rule 83-3(a)(1); see Minutes of Proceedings (Docket 

No. 216). The Court then ordered that Ms. Vocht could “proceed as representing Defendants 

without local counsel,” and as a result denied Plaintiff’s Motion for Default as moot. See 

Minutes of Proceedings (Docket No. 216). No separate hearing was held to address the 

substance of Plaintiff’s Motion for Default. See id. Plaintiff’s counsel believes that the Court’s 

waiver of Local Rule 83-3(a)(1) and the resulting denial of Plaintiff’s Motion for Default was in 

error and hereby respectfully requests that this Court reconsider its ruling. 

IV. MEMORANDUM OF LAW

A. This Court’s Local Rules require attorneys who are admitted pro hac vice to

associate with local counsel. This requirement may only be waived if no party’s 

substantial rights would be affected by such waiver. 

District courts have discretion to adopt local rules. Hollingsworth v. Perry, 558 U.S. 183, 

191 (2010); see also 28 U.S.C. § 2071; FRCP 83. Once adopted, local rules “have ‘the force of 

law.’” Hollingsworth, 558 U.S. at 191 (quoting Weil v. Neary, 278 U.S. 160, 169 (1929)). Local 

rules “are binding upon the parties and upon the court.” Prof’l Programs Grp. v. Dep’t of 

Commerce, 29 F.3d 1349, 1353 (9th Cir. 1994); see also In re Corrinet, 645 F.3d 1141, 1146 

(9th Cir. 2011) (“District judges must adhere to their court’s local rules, which have the force of 

federal law.”). To amend a local rule, specific procedures must be followed, typically including 

a public notice and comment period. Hollingsworth, 558 U.S. at 191; FRCP 83(a)(1).

This Court’s Local Rules require that all attorneys practicing before it must either be 

members of the Oregon State Bar or appear in association with an Oregon State Bar member. 

Admission to this District Court’s bar “is limited to attorneys of good moral character who are 

active members in good standing with the Oregon State Bar.” Local Rule 83-2. With regard to

out-of-state attorneys who wish to appear before this District Court in a particular case, the Local 

Rules provide:
Page 4 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

Any attorney who is an active member in good standing of the bar of any United 

States court, or the highest court of any state, territory, or insular possession of the 

United States, may apply to be specially admitted pro hac vice in a particular case, 

provided he or she . . . [a]ssociates with an attorney admitted to general practice 

before the bar of this Court, who will meaningfully participate in the preparation 

and trial of the case. 

Local Rule 83-3(a)(1). The Application for Pro Hac Vice Admission and CM/ECF Registration 

reiterates this requirement, stating that “LR 83-3(a)(1) requires applicants for pro hac vice

admission to associate with local counsel, unless requesting a waiver of the requirement under 

LR 45-1.” Application for Pro Hac Vice Admission and CM/ECF Registration, at 4, available at 

https://ord.uscourts.gov/index.php/606-attorneys/attorney-admissions (emphasis added). This 

waiver is only applicable to attorneys seeking admission “for the limited purpose of filing a 

motion related to a subpoena that [the District Court] did not issue.” Id.; see also Local Rule 45. 

Thus, except under the limited circumstances set forth in Local Rule 45, all pro hac vice

attorneys appearing before this District Court must be affiliated with a local Oregon attorney 

who is a meaningful participant in the case. The purpose of this requirement is to ensure that 

out-of-state attorneys are well-versed in the Local Rules, comfortable with Oregon law, and rise 

to the level of professionalism required in the District of Oregon. In re Pac. Cargo Servs., LLC,

No. 13-30439, 2013 WL 5299545, at *10 (D. Or. Sept. 18, 2013). 

Local rules must be followed in all but the most limited of circumstances. Local Rule 1-4 

provides that “[i]n the interest of justice, a judge may suspend or modify the application of [the 

Local Rules] in an individual case or group of cases.” Local Rule 1-4 (emphasis added). 

However, this District Court has emphasized that such discretion should only be exercised in 

very limited circumstances: 

This court has used LR 1-4 to dispense with technical pleading requirements, such 

as page limitations or citation format, to change case schedules, or to waive the 

requirement to file certain documents such as Concise Statements of Material Fact 

(no longer required), Joint Alternative Dispute Resolution Reports, or Pretrial 

Orders. However, such use of LR 1-4 differs significantly from using it to alter 

case assignment rules. . . . Local Rules are no small matter: “District judges must 

adhere to their court’s local rules, which have the force of federal law. . . . ‘Courts 

enforce the requirement of procedural regularity on others and must follow those 

requirements themselves.’” In re Corrinet, 645 F.3d 1141, 1146 (9th Cir. 2011), 
Page 5 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

quoting Hollingsworth v. Perry, 558 U.S. 183, 184 (2010). This court is not 

persuaded that it should use LR 1-4 to dispense with the clear case assignment 

mandate embodied in [the Local Rules].

Cox v. Holcomb Family Ltd. P’ship, No. 3:13-cv-01688-ST, 2014 WL 5462022, at *18 (D. Or. 

Oct. 26, 2014). Local Rule 1-4 discretion is typically used to modify the Local Rules only as 

they apply to mere formalities or technicalities, the acceptance of which does not prejudice any 

party. See Cook v. Union Pac. R.R. Co., No. 10-6339-TC, 2011 WL 5842795, at *3 (D. Or. Nov. 

18, 2011) (permitting cross-motions that did not comply with the Local Rules to proceed when 

no party was prejudiced by this failure); Webformix, Inc. v. Airspan Networks Inc., No. 10-6229-

TC, 2010 WL 5292588, at *2 (D. Or. Dec. 17, 2010) (permitting a document into the record 

when its signed signature line failed to include the “s/” required by the Local Rules). 

Unlike exceptions for non-prejudicial technical issues, “a departure from local rules that 

affects ‘substantial rights’ requires reversal . . . [and] is justified only if the effect is ‘so slight 

and unimportant that the sensible treatment is to overlook [it].’” Prof’l Programs Grp., 29 F.3d 

at 1353 (internal citations omitted). When the Local Rules contain a “clear . . . mandate” on a 

matter that exceeds a mere technical formality, Local Rule 1-4 should not be used to dispense 

with that mandate. See Cox, 2014 WL 5462022, at *18. 

B. This Court’s decision to let Ms. Vocht appear in this matter without local counsel 

violates two Local Rules and adversely impacts both Plaintiff’s and Defendants’ 

counsel.

As set forth above, this Court’s Local Rules have the force of law and are binding upon 

the Court and all parties that appear before it. See Hollingsworth, 558 U.S. at 191; Prof’l 

Programs Grp., 29 F.3d at 1353; In re Corrinet, 645 F.3d at 1146. The Local Rules require that 

all attorneys who appear and represent parties before this Court must (1) be an active member of 

the Oregon State Bar or (2) be admitted pro hac vice to appear in a particular case and associate 

with local counsel who meaningfully participates in the case. Local Rule 83-2; Local Rule 83-

3(a)(1). This Court’s order that Ms. Vocht may appear before it and represent Defendants 

without local counsel violates these rules. 

/ / / 
Page 6 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

On September 1, 2016, Ms. Vocht was admitted to appear before this Court pro hac vice 

in relation to this matter, with Mr. Trauman as her local counsel.

1

 See Application for Special 

Admission–Pro Hac Vice (Docket No. 37); Order Granting Application for Special Admission–

Pro Hac Vice Subject to Payment of Fees (Docket No. 43). On May 1, 2018, Mr. Trauman filed 

a motion to withdraw, seeking the Court’s permission to withdraw as local counsel for all 

Defendants. Motion of Motschenbacher & Blattner LLP to Withdraw as Counsel of Record for 

Defendants (Docket No. 197). During a telephonic hearing on May 4, 2018, the Court 

provisionally granted Mr. Trauman’s motion to withdraw and admonished Defendants that they 

had twenty days to find substitute local counsel, or the entity Defendants—by rule—would not 

be allowed to proceed unrepresented. Minutes of Proceedings (Docket No. 200). 

Twenty days later, Ms. Vocht notified the Court by email that Defendants had failed to 

find substitute local counsel and acknowledged that her pro hac vice status was therefore 

expiring. That same day, Plaintiff filed its Motion for Default against the now-unrepresented 

entity Defendants. See Motion for Default. The Court set a telephonic hearing on May 31, 2018, 

at which it announced to the Parties that it was waiving the local counsel requirement, Ms. Vocht 

was allowed to “proceed as representing Defendants without local counsel,” and the Motion for 

Default was therefore “Denied as Moot.” See Minutes of Proceedings (Docket No. 216). In 

doing so, this Court waived the assistance of local counsel requirement mandated by Local Rule

/ / /

 1 Ms. Vocht’s pro hac vice application sought admission to represent former Defendant Paige 

Raifsnider Ludwick (“Ms. Ludwick”) and did not address any of the other Defendants in this 

case or seek admission to appear before this Court on their behalf. See Application for Special 

Admission–Pro Hac Vice (Docket No. 37). In an odd series of filings, after the Court granted 

Ms. Vocht’s pro hac vice application, Mr. Trauman filed a Notice of Substitution of Counsel as 

to all Defendants on September 23, 2016, noticing the appearance and substitution of himself and 

Ms. Vocht as new counsel for Frevol, ANF, and Mr. Ludwick (but excluding Ms. Ludwick). See 

Notice of Substitution of Counsel (Docket No. 51). Three days later, Ms. Vocht filed a Notice of 

Appearance for herself as to all Defendants, again excluding Ms. Ludwick. See Notice of 

Appearance of Michelle E. Vocht (Docket No. 52). Ms. Ludwick was dismissed from this case 

on June 9, 2017. Judgment of Dismissal as to Defendant Paige M. Raifsnider Ludwick (Only)

(Docket No. 96). Thus, the only party Ms. Vocht has been granted permission to represent 

before this Court is no longer a party to this litigation.
Page 7 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

83-3(a)(1) and effectively elevated Ms. Vocht’s status to that of a generally admitted attorney 

pursuant to Local Rule 83-2. 

Since May 31, 2018, Ms. Vocht has followed this Court’s directive and proceeded to 

represent Defendants without the assistance of local counsel and in direct violation of Local Rule

83-3(a)(1). Further, Ms. Vocht is not a member of the Oregon State Bar, as required for standalone admission to this District Court’s bar under Local Rule 83-2. Both Local Rule 83-2 and 

83-3(a)(1) set forth clear mandates that are binding upon this Court and all parties that appear 

before it; neither includes a waiver provision. Thus, it was improper for this Court to set aside 

the local counsel requirements as applied to Ms. Vocht and direct her to represent Defendants in 

violation of the Local Rules. 

Importantly, this Court’s waiver of the local counsel requirement is particularly 

concerning with regard to the purposes underlying the local counsel requirement: ensuring that 

parties are represented by attorneys familiar with Oregon law, this Court’s Local Rules and 

customs, and the standard of professionalism required before this Court. See In re Pac. Cargo 

Servs., LLC, 2013 WL 5299545, at *10. Plaintiff moved for sanctions in this case and called to 

the Court’s attention conduct that falls squarely within the purposes for requiring meaningful 

participation of local counsel.

2

 See Plaintiff Morasch Meats, Inc.’s Motion for Sanctions 

(Docket No. 156). The facts and arguments underlying Plaintiff’s request for sanctions are fully 

set forth in the Motion for Sanctions (Docket No. 156) and are hereby incorporated as if fully 

restated herein. The Court’s directive to Ms. Vocht to represent Defendants without the 

assistance of local counsel not only impacts Plaintiff’s request for sanctions, but also may well 

adversely impact Ms. Vocht’s ability to defend against the sanctions request. In this regard, both 

Plaintiff’s and Defendants’ counsel are prejudiced by the Court’s waiver of the requirement for 

local counsel assistance. 

 2 Plaintiff’s motion seeking sanctions is currently pending before this Court. The Court has 

indicated that it will be heard post-trial. See Order (Docket No. 187). 
Page 8 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

C. It was improper for this Court to waive the local counsel requirement because Local 

Rule 83-3(a)(1) sets forth a clear mandate on this point, and this departure from the 

Local Rules impacted Plaintiff’s substantial rights in a significantly prejudicial way. 

As detailed above, this Court’s Local Rules must be followed in all but the most limited 

of circumstances. While Local Rule 1-4 offers judges discretion to modify or suspend 

application of the Local Rules in the interest of justice, this District Court has clearly stated that 

such discretion may only be exercised for minor technical formalities and should not be used to 

avoid a “clear . . . mandate” set forth in the Local Rules regarding a substantive matter that 

impacts parties’ substantial interests or rights. See Cox, 2014 WL 5462022, at *18. Here, Local 

Rule 83 sets forth a clear mandate that attorneys who appear before this Court must either be 

Oregon State Bar members or pro hac vice attorneys accompanied by local counsel. Local Rule 

83 does not provide the Court with any opportunity to waive these requirements, and such waiver 

is not a mere formality or technicality without impact on the Parties’ interests or rights in this 

case. 

Rather, Plaintiff was severely prejudiced and its substantial rights were unquestionably 

impaired by the Court’s waiver of Local Rule 83-3(a)(1)’s local counsel requirements. Directing 

Ms. Vocht to proceed as counsel for Defendants3 in violation of Local Rule 83-3(a)(1)

summarily disposed of Plaintiff’s thorough and non-discretionary Motion for Default, which 

sought entry of default and a default judgment as to both Frevol and ANF. See Motion for 

Default. As fully argued in the Motion for Default, Plaintiff was entitled by law to have the 

default of both entity Defendants entered, and to have a default judgment entered against them. 

 3 It is worth noting that Defendants were well aware of the consequences of their failure to obtain 

substitute local counsel, and despite this fact made only minimal efforts. On May 4, 2018, the 

Court clearly instructed Ms. Vocht to find new local counsel within twenty days, or the entity 

Defendants would be without counsel and unable to proceed in the case. See Minutes of 

Proceedings (Docket No. 200). Ms. Vocht reported to the Court that during this twenty-day 

period, she spoke to only one Oregon attorney (who declined the engagement), as well as several 

Michigan attorneys with Oregon bar licenses (who also declined the engagement). This minimal 

effort—despite the well-known outcome that would result if the entity Defendants did not find 

local counsel—further demonstrates that a waiver of the Local Rules was unwarranted in this 

case, and was unanticipated and unrequested by any Party to this case. 
Page 9 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

See id. However, Plaintiff was given no opportunity for its Motion for Default to be heard on the 

merits; instead, the Court waived Local Rule 83-3(a)(1)’s local counsel requirement, thereby 

disposing of the entire Motion for Default as moot. See Minutes of Proceedings (Docket No. 

216). The Parties received no warning that the Court was contemplating such a departure from 

the Local Rules, and neither Plaintiff, Defendants, nor Ms. Vocht had any meaningful 

opportunity to provide their various positions on such a departure before it had been ordered. 

If default and default judgment had been entered against Frevol and ANF, Plaintiff was 

further entitled to application of this Court’s previous ruling that the entity Defendants’ corporate 

veils would be pierced if this litigation resulted in a judgment against either entity and Plaintiff 

was unable to collect. Opinion and Order, 11–15 (Docket No. 188). Thus, not only was 

Plaintiff entitled to a complete default judgment against the entity Defendants, but because the 

corporate veils would have been pierced, Plaintiff also would have effectively held a judgment 

for the same amount against Mr. Ludwick personally. Ultimately, this would have resolved the 

entire litigation. Thus, the ripple effect of the Court’s waiver of Local Rule 83-3(a)(1)’s local 

counsel requirement reaches to the very end of the case. 

Plaintiff’s entitlement to a default and default judgment against the entity Defendants and 

a resulting judgment in full as to all Defendants represents the exact type of “substantial rights” 

that prevent a departure from the Local Rules. See Prof’l Programs Grp., 29 F.3d at 1353. This 

Court’s waiver of Local Rule 83-3(a)(1) did not dispense with a mere technical formality, but 

instead prevented Plaintiff from obtaining a judgment to which it was entitled, and which 

ultimately would have resolved the litigation; this is unquestionably a substantial right, and 

Plaintiff was significantly prejudiced by the Court’s departure from the Local Rules. The 

resulting outright denial as moot of Plaintiff’s Motion for Default illustrates that the Court’s 

departure from Local Rule 83-3(a)(1)’s local counsel requirement was neither “slight” nor 

“unimportant” and therefore should not be overlooked. See id. Under these circumstances, 

reversal is required. See id. 
Page 10 of 10 – PLAINTIFF MORASCH MEATS, INC.’S MOTION FOR 

RECONSIDERATION OF PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT 

AND DEFAULT JUDGMENT AGAINST DEFENDANTS FREVOL HPP, LLC AND 

ALL NATURAL FRESHNESS, INC. ONLY

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

V. CONCLUSION

For the reasons set forth above, Plaintiff respectfully requests that this Court grant its 

Motion for Reconsideration and revoke its waiver of Local Rule 83-3(a)(1)’s local counsel 

requirement. Upon reconsideration, Plaintiff further requests that this Court grant its Motion for 

Default. 

DATED: June 13, 2018

IMMIX LAW GROUP PC

Dayna J. Christian, OSB #97336

Nicole McMillan, OSB #114573

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, Oregon 97209

Phone: (503) 802-5533

Fax: (503) 802-5351

E-Mail: dayna.christian@immixlaw.com

E-Mail: nicole.mcmillan@immixlaw.com

Attorneys for Plaintiff Morasch Meats, Inc.
Page 1 of 1 – CERTIFICATE OF SERVICE Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, OR 97209

Telephone: 503-802-5533

Facsimile: 503-802-5351

CERTIFICATE OF SERVICE

I hereby certify that on June 13, 2018, I served a true copy of the foregoing PLAINTIFF 

MORASCH MEATS, INC.’S MOTION FOR RECONSIDERATION OF PLAINTIFF’S 

MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMENT AGAINST 

DEFENDANTS FREVOL HPP, LLC AND ALL NATURAL FRESHNESS, INC. ONLY on 

the attorney listed below by the method(s) indicated below on said day.

Michelle E. Vocht Via E-Mail

Roy, Shecter & Vocht, P.C. 

707 S. Eton St.

Birmingham, MI 48009

vocht@rsmv.com

Attorneys for Defendants

IMMIX LAW GROUP PC

Dayna J. Christian, OSB #97336

Nicole McMillan, OSB #114573

Immix Law Group PC

600 NW Naito Parkway, Suite G

Portland, Oregon 97209

Phone: (503) 802-5533

Fax: (503) 802-5351

E-Mail: dayna.christian@immixlaw.com

E-Mail: nicole.mcmillan@immixlaw.com

Attorneys for Plaintiff Morasch Meats, Inc.