(May 22, 2017, 10:43 AM EDT) -- PHILADELPHIA — Saying it is a matter of first impression in the circuit, a franchisee in a May 2 brief to the Third Circuit U.S. Court of Appeals says the court should adopt the rule of a majority of the circuits that do not require a party to move first in a district court to vacate a default judgment before appealing (Howard Johnson International Inc. v. Saisat LLC, et al., No. 16-4345, 3rd Cir.)....