IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

THE JAMES STREIBICH REVOCABLE 

TRUST OF 2002, an Illinois Trust, 

individually, and Derivatively, on behalf 

of FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company, 

 Plaintiffs, 

 v. 

BROCK H. FLAGSTAD, individually, 

and OXFORD MARKETING 

PARTNERS, LLC, OXFORD MEDIA, 

LLC, OXFORD TAX PARTNERS, LLC, 

OXFORD FG, LLC, OXFORD GP, LLC, 

and FINANCIAL FREEDOM 

ADVISORS, LLC, 

 Defendants. 

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No. 1:20-cv-02242 

Honorable Judge Manish S. Shah 

Honorable Magistrate Judge Maria Valdez 

PLAINTIFFS’ MOTION FOR ENTRY OF DEFAULT 

AGAINST ALL DEFENDANTS 

Plaintiffs, THE JAMES STREIBICH REVOCABLE TRUST OF 2002, an Illinois Trust, 

individually (“the Trust”), and derivatively, on behalf of FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company (“Folding Light”) (collectively, “Plaintiffs”), by and through their 

attorneys, Sheppard Mullin Richter & Hampton, LLP, pursuant to Fed. R. Civ. P. 55(a), respectfully 

request the Clerk to enter Default against the Defendants BROCK H. FLAGSTAD (“Flagstad”), 

OXFORD MARKETING PARTNERS, LLC (“Oxford Marketing”), OXFORD MEDIA, LLC 

(“Oxford Media”), OXFORD TAX PARTNERS, LLC (“Oxford Tax”), OXFORD FG, LLC 

(“Oxford FG”), OXFORD GP, LLC (“Oxford GP”), FINANCIAL FREEDOM ADVISORS, LLC 

(“FFA”); and CLOVERPOINT PARTNERS, LLC (“Cloverpoint”) (collectively, “Defendants”). 

In support of this motion, Plaintiffs state as follows: 

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1. Plaintiffs initiated this action by filing a Complaint against Defendants on April 

9, 2020. Dkt. 1. 

2. On April 17, 2020, Plaintiffs filed eight (8) Executed Returns of Service of the 

Complaint and Summons issued on each separate Defendant, along with supporting affidavits 

of service, showing that each Defendant was served in accordance with Rule 4 of the Federal 

Rules of Civil Procedure. Specifically, Oxford Marketing was served on April 16, 2020, and 

each of the seven (7) other Defendants was served on April 17, 2020. See Dkts. 7, 8, 9, 10, 

11, 12, 13, 14. 

3. Accordingly, Oxford Marketing’s original deadline to answer or otherwise 

plead to the Complaint was May 7, 2020 (Dkt. 12); and the original deadline for Flagstad, 

Cloverpoint, FFA, Oxford FG, Oxford GP, Oxford Media, and Oxford Tax to answer or 

otherwise plead to the Complaint was May 8, 2020 (Dkts. 7, 8, 9, 10, 11, 13, 14, respectively). 

See also Fed. R. Civ. P. 12(a)(1)(A)(i). 

4. Defendants’ original answer deadlines were extended twenty-eight (28) days 

pursuant to this Court’s Third Amended General Order 20-0012 In re: Coronavirus COVID19 Public Emergency. See Dkt. 15, ¶ 2. As a result, Oxford Marketing’s deadline to answer 

or otherwise plead to the Complaint was extended to June 4, 2020; and the deadline for 

Flagstad, Cloverpoint, FFA, Oxford FG, Oxford GP, Oxford Media, and Oxford Tax to 

answer or otherwise plead to the Complaint was extended to June 5, 2020. 

5. No attorney has entered an appearance on behalf of any of the Defendants. 

6. As of the date of this filing, all of the Defendants have failed to answer or 

otherwise plead to the Complaint. 

 

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7. Federal Rule 55(a) provides that “[w]hen a party against whom a judgment for 

affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown 

by affidavit or otherwise, the clerk must enter the party’s default.” Fed. R. Civ. P. 55(a). 

 WHEREFORE, Plaintiffs respectfully request that the Clerk enter Default against all 

of the Defendants pursuant to Fed. R. Civ. P. 55(a), and further grant any additional relief 

deemed appropriate and just.1 

Dated: June 10, 2020 Respectfully submitted, 

THE JAMES STREIBICH REVOCABLE TRUST 

OF 2002, an Illinois Trust, individually, and 

Derivatively, on behalf of FOLDING LIGHT, LLC, 

a Delaware Limited Liability Company 

By: /s/ William K. Kane 

 One of Its Attorneys 

William K. Kane, Esq. (6194466) 

David M. Poell, Esq. (6302765) 

SHEPPARD MULLIN RICHTER & HAMPTON LLP

Three First National Plaza 

70 West Madison Street, 48th floor 

Chicago, Illinois 60602 

Telephone: 312.499.6300 

Facsimile: 312.499.6301 

wkane@sheppardmullin.com 

dpoell@sheppardmullin.com 

Counsel for Plaintiffs 

1

 In response to the continuing pandemic, the Court’s Fourth Amended General Order has 

suspended Local Rule 5.3(b), which otherwise requires that all motions be noticed for presentment. 

See Dkt. 17, ¶ 11. Therefore, Plaintiffs request the Default be entered without requiring counsel 

for Plaintiffs to present this motion. 

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