Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 5 of 19 ¶ 29; Moonbase Holdings is a limited-liability corporation registered in Ohio, id. ¶ 30; and Mr. Ade is a citizen of Tennessee. Id. ¶ 33. Additionally, Ms. Dumpson’s requested relief exceeds $75,000. Id. ¶ 38. Venue is proper in this Court and the Court has personal jurisdiction over the Defendants because the allegedly discriminatory statements were targeted at an individual that attended school in, and activities that occurred in, the District of Columbia. See Fed. R. Civ. P. 4; D.C. Code § 13-423(a)(3); 28 U.S.C. § 1391(b)(2). II. LEGAL STANDARDS A. Federal Rule of Civil Procedure 55 There is a two-step procedure for requesting default judgment. Fanning v. Seneca One Realty LLC, 265 F. Supp. 3d 31, 33 (D.D.C. 2017) (citing Boland v. Cacper Constr. Corp., 130 F. Supp. 3d 379, 382 (D.D.C. 2015)). First, Federal Rule of Civil Procedure 55(a) requires the Clerk of Court to enter default “[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.” Fed. R. Civ. P. 55(a). Second, once the Clerk has entered default, “the party must apply to the court for a default judgment.” Fed. R. Civ. P. 55(b)(2). A court may then enter default judgment as established in Rule 55(b). Id. Determining whether default judgment is appropriate “is committed to the discretion of the trial court.” Int’l Painters & Allied Trades Indus. Pension Fund v. Auxier Drywall, LLC, 531 F. Supp. 2d 56, 57 (D.D.C. 2008) (citing Jackson v. Beech, 636 F.2d 831, 836 (D.C. Cir. 1980)). “Default [judgment] establishes the defaulting party’s liability for the wellpleaded allegations of the complaint.” Boland v. Elite Terrazzo Flooring, Inc., 763 F. Supp. 2d 64, 67 (D.D.C. 2011). To authorize default judgment, a “defendant must be considered a ‘totally unresponsive’ party, and its default plainly willful, reflected by its failure to respond to the 5