I have filed a complaint (stated damages in excess of ($100M) within the state court of Michigan against a very large bank and other various parties in a wrongful foreclosure action. The Defendants removed the action to federal court prior to providing an answer to the complaint; which was eventually remanded back to state Court on 9-7-12 for lack of diversity jurisdiction. As previously stated the defendants attorneys (2) never provided an answer to the complaint to this date (10-30-12).

Question:

1) Has the mandated time for the parties must answer the complaint exceeded the time for which a default judgment could be entered against them for failing to appear since the state court received the case back on remand on 9-7-12 (28 days max per court rule)?

2) If so how do I specifically go about obtaining an entry of default judgement as to not give opposing counsel "valid" grounds to succeed in having the judgement set aside?

3) There is other relief that will have to be determined by the court via a motion for default judgment. Can the stated damages still be secured through a application, affidavit, and entry of default judgment separate from the remaining non-stated relief being sought; which is injunctive, declaratory, and miscellaneous in nature?

1) It appears so, yes.
2) Apply to the clerk of court for an entry of default.

Once you get the entry of default, you should then file a motion for entry of default judgment. If you asked for these other things in your complaint, you should file, in support of your motion for default judgment, a memorandum of law explaining why you are entitled to them.