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2`73'789 IN THE CIRCUIT COURT, IN AND
FOR ST. LUCIE COUNTY, FLORIDA
.
• CASE NO. 74-17 CA
IN RE: The Marriage of *
*
* .
ERNEST W. COMBS, SR., Husband *
* f1~E0 R4!+ =:ECtJe+ ~
* sT. tUCtc COUMTY LA. .
ROG~i• : ~I'R~S L
* CIEAK C:.. _~11T C~U.
R~
* RFC4Et` YEi~'~1; ~
and -
* 1_,- FE8 10 P~'~~
*
MARY JANE COMBS, Wife *
* 2~3~'89
MOTION FOR DEFAULT ~
COMES NOW, the Husband, ERNEST W. COMBS, SR., and would
show unto the Court that the Wife., MARY JANE COMBS, was duly
' served with process in this case on the lOth day of January, 1974
at 10:18 a.m., by a Deputy~Sheriff of the office of St. Lucie
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~ County Sheriff's Department; that the time for filing of any answer
~ or other defensive pleading in the cause has now expired, and that
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~ no answer or other defensive pleading in the cause has been served
~ -
3
~ upon the law firm of Law Offices of Charles R. P. Brown, P. O. Box
6
~
~ 1418, Fort Pierce, Florida, Attorneys of Record for Husband herein,
~ by the Wife, MARY JANE COMBS, or any counsel or attorney in her
~ .
~ behalf as of the date of this Motion. . •
~ . .
~ WHEREFORE, Husband moves for entry af a default by the
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~ Clerk against the Wife, MARY JANE COMBS, for failure to serve
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~ ~ any answer or other defensive pleading, or to file the same in
this cause, as required by law.
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~ L~+,W OFF CES OF CHARLES P. BROWN
:`';,i:. ~r`',~.~,,, I u
- j Attor y for Hus an
- •:ti~' ~ ~
`::3 301 South Sixth Street
~ ~J : . ' i, - :
P. O. Box 1418
_ ' -
- - ~ : . ' Fort Pierce, Flcrida 33450
_
„ . DEFAULT
. ; .
r.~ ;
A Default is entered in this canse against the Wife named
in the foregoing Motion for failure to serve or file any answer or
:~;i:j other defensive pleading as required by law.
Dated at Fort Pierce, Florida this~~~day of February, A.D.
° 1974. ~ ROG OIT , CL RK CIRCUIT COURT -
# ~ -
_ ~ BLt+~ ~.~i BY
~ Dep y Clerk