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Home Court filings U.S. v. Ryan Bailey RKB, Inc.'s Motion to Set Aside Entry of Default — U.S. v. Bailey

Court filing

RKB, Inc.'s Motion to Set Aside Entry of Default — U.S. v. Bailey

Record facts

CourtU.S. District Court, Southern District of West Virginia
Filed2024-11-26

U.S. District Court, Southern District of West Virginia · No. 5:24-cv-00456 · Doc. 17 · 2024-11-26 · Docket on CourtListener

Summary

A motion by defendant RKB, Inc. to set aside the clerk's entry of default in United States of America v. Ryan Bailey and RKB, Inc., Civil Action No. 5:24-CV-00456, in the U.S. District Court for the Southern District of West Virginia, filed November 26, 2024 as Doc. 17. Filed by counsel James R. Sheatsley, it asks the court to set aside the default entered October 16, 2024 under Federal Rule of Civil Procedure 60(b) and 60(c). The motion states that RKB, Inc. is a West Virginia corporation whose sole shareholder is codefendant Ryan Bailey, who was between counsel when the default was entered and has filed a similar motion (Docket Number 15). It asserts that the plaintiff is not prejudiced and that the motion is timely. The three-page filing ends with a certificate of service.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

1 
 
UNITED STATES DISTRICT COURT  
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA  
Beckley Division  
 
UNITED STATES OF AMERICA,  
 
 
Plaintiff,  
v. 
 
 
 
 
 
 
 
 Civil Action No.: 5:24-CV-00456 
 
RYAN BAILEY and RKB, INC. 
 
 
Defendant. 
 
MOTION OF THE DEFENDANT, RKB, INC., TO SET ASIDE ENTRY OF DEFAULT 
PURSUANT TO RULE 60 OF THE WEST VIRGINIA RULES OF CIVIL PROCEDURE 
 
 
Now comes the Defendant, RKB, Inc., by counsel, James R. Sheatsley, and moves 
this Honorable Court to set aside the entry of Default by the Clerk entered on the 16th day 
of October, 2024 pursuant to Federal Rule of Civil Procedure 60(b)(1), 60(b)(6) and 60(c).   
 
In support thereof, the Defendant, RKB, Inc., represents as follows.  
1. 
RKB, Inc. is a West Virginia corporation of which the sole shareholder is 
Codefendant, Ryan Bailey,  
2. 
Ryan Bailey has recently, by appointed counsel, filed a similar Motion to Set Aside 
Entry of Default by Clerk.  
3. 
At the time the Default was entered October 16, 2024, the Codefendant, Ryan 
Bailey, was in transition as between counsel all as set forth in the Motion of Ryan Bailey 
to Set Aside Default by Clerk. See Docket Number 15. 
4. 
Inasmuch as the sole shareholder of RKB, Inc. was without counsel, he had no 
legal representation to advise him of the legal ramifications related to Codefendant, RKB, 
Inc., of which he is the sole shareholder.   
5. 
Codefendant, RKB, Inc., respectfully represents that the Plaintiff herein is not 
prejudiced by entry of an Order setting aside the Default Judgment.  
Case 5:24-cv-00456     Document 17     Filed 11/26/24     Page 1 of 3 PageID #: 108

2 
 
6. 
The Codefendant, RKB, Inc., respectfully represents that this Motion under Rule 
60(b) of the Federal Rules of Civil Procedure has been timely made.  
 
WHEREFORE, the Codefendant, RKB, Inc., prays that this Honorable Court set 
aside the Default entered October 16, 2024.   
 
 
 
 
 
 
 
 
RKB, Inc.  
 
 
 
 
 
 
 
By Counsel,  
 
 
 
 
 
 
 
 
/s/ James R. Sheatsley  
 
 
 
 
 
 
 
 
 
 
James R. Sheatsley (WVBN 3359)  
 
 
 
 
 
 
 
Gorman, Sheatsley & Company, LC 
 
 
 
 
 
 
 
PO Box 5518 ● 343 Prince Street  
 
 
 
 
 
 
 
Beckley, WV 25801 
 
 
 
 
 
 
 
Phone: (304) 252-5321 
 
 
 
 
 
 
 
jsheatsley@gormansheatsley.org  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 5:24-cv-00456     Document 17     Filed 11/26/24     Page 2 of 3 PageID #: 109

3 
 
UNITED STATES DISTRICT COURT  
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA  
Beckley Division  
 
UNITED STATES OF AMERICA,  
 
 
Plaintiff,  
v. 
 
 
 
 
 
 
 
 Civil Action No.: 5:24-CV-00456 
 
RYAN BAILEY and RKB, INC. 
 
 
Defendant. 
 
CERTIFICATE OF SERVICE  
 
 
I, James R. Sheatsley, counsel for the Defendant, RKB, Inc., do hereby certify that 
I electronically filed the foregoing MOTION OF THE DEFENDANT, RKB, INC., TO SET 
ASIDE ENTRY OF DEFAULT PURSUANT TO RULE 60 OF THE WEST VIRGINIA 
RULES OF CIVIL PROCEDURE with the U.S. District Court, Southern District of West 
Virginia using the CM/ECF system maintained by the Court which will notify the following 
person(s) via electronic mail this the 25th day of November, 2024. 
 
Fred B. Westfall, Jr.  
Assistant United States Attorney  
.300 Virginia Street East, Room 4000 
Charleston, WV 25301 
Counsel for the Plaintiff 
 
G. Todd Houck 
Hrko Building  
105 Guyandotte Avenue  
Mullens, WV 25882 
Counsel for Ryan Bailey  
 
 
/s/ James R. Sheatsley  
 
 
 
 
 
 
 
 
 
 
James R. Sheatsley (WVBN 3359)  
 
 
 
 
 
 
 
Gorman, Sheatsley & Company, LC 
 
 
 
 
 
 
 
PO Box 5518 ● 343 Prince Street  
 
 
 
 
 
 
 
Beckley, WV 25801 
 
 
 
 
 
 
 
Phone: (304) 252-5321 
 
 
 
 
 
 
 
jsheatsley@gormansheatsley.org  
CC: 
Client electronically  
Case 5:24-cv-00456     Document 17     Filed 11/26/24     Page 3 of 3 PageID #: 110

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