Joe , I like your plan !

Here is the part of e.DIGITAL from June 2015, that end up with Default.

Plaintiff has not yet sought the entry of default in this matter against the Defendants and has provided the Defendants an extension of time to respond to the Complaint.
Part of the delay in finally resolving this matter is due to the fact that some or all of the principles for the Defendants may be and/or are located in Russia and thereby certain communications to include a proposedsettlement agreement must be translated from English into Russian.
As of the date of the execution of this pleading, because Defendants have not yet appeared in the case and the identity of their respective counsel is not yet known, Plaintiff and its
counsel have been unable to meet and confer with Defendants’ counsel with respect to the matters required to be discussed and set forth in the Case Management Statement. Plaintiff has provided notice of the Case Management Conference as well as the requirements for filing a Case Management Statement with the Court to Defendants to no avail. Plaintiff has also requested multiple times that Defendants retain counsel in this matter and/or make an appearance in this matter via counsel to no avail.
Accordingly, Plaintiff is unable to file a Case Management Statement with the Court as it has been unable to meet and confer with the Defendants and/or their counsel as to the matters required by the Court.
Plaintiff has indicated to the Defendants that should a final agreement not be reached forthwith, then Plaintiff will seek the entry of default as to one or all of the Defendants. Plaintiff intends to seek the entry of default as to the Defendants by June 22, 2015 if a final agreement has
not been reached.