Plaintiff Blake Rambin filed a motion for default judgment on Tuesday, arguing that more than 30 days have elapsed since Joe Aref, the owner of Club 409, was served.

As previously reported, Rambin filed suit against Aref on May 18 in Jefferson County District Court, claiming bouncers at Club 409 physically assaulted him without cause.

Rambin's motion states that Aref was served on June 6 and has yet to file an answer to lawsuit, entitling him to default judgment.

The motion, filed July 12, does not state how much he is asking the court to award him.

According to the lawsuit, on April 23, Rambin and some of his friends were visiting the Beaumont club when someone started to videotape his girlfriend while she danced.

Rambin confronted the individual, which prompted Club 409 bouncers to remove him. During the incident, Rambin's girlfriend was knocked to the ground. When he attempted to come to her aid, the bouncers knocked him to the ground and began beating him, the suit alleges.

On top of mental anguish, Rambin is suing for punitive and exemplary damages.

Beaumont attorney Cade Bernsen represents him.

Judge Milton Shuffield, 136th District Court, is assigned to the case.

Case No. D190-048

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