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! IN THE CIRCUIT COURT OF THE
~ NINETEENTH JUDICIAL CIRCUIT
~ OF FLORIDA, IN AND FOR
~ . ST. LUCIE COUNTY.
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I CIVIL ACTION NO. 72-898
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i IN RE: The Marriage Of :
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~ RICHARD L. BEAN,
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~ Husband, and .
ROXANNA L. BEAN, Wife.
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I MOTION FOR DEFAULT
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~ The Wife ROXANNA L. BEAN, by and through he"r undersigned
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attorney, moves the Court for the entry of a default against the
Husband, RICHARD L. BEAN, for failure to serve a copy of any ans~er
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responsive pleading or paper to the Petition herein upon the under- '
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~signed attorney Q to file any answer, responsive plea g p p
~to the Petition filed herein with the Clerk of the above-entitled
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~ ~Court as required by law and upon the following grounds:
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~ 1. That personal service of process was made upon the ~
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Isaid Husband by the Sheriff of St. Lucie County, Florida, at Fort
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Pierce, Florida, on the 26th day of February, 1973. ;
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~ 2. That said Husband and Wife have executed and acknow-
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,ledged a written Separation Agreement which will be offered in
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~4evidence in the trial of this cause.
3. That said Husband does not desire to contest a
~ dissolution of marriage in this cause and has completed, to date,
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ith the terms and conditions of said Separation Agreement.
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~y`~ 4. That, although the said Husband is in the U.S. Navy,
~ e is stationed within the Continental United States; that he has
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aken no action to stay or continue these proceedings although
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RAYMOND E. FORD ersonally served with process herein on the 26th day of February,
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