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28~~41 IN THE CIRCUIT COURT OF THE NINETEENTH
JUDICIAL CIRCUIT COURT OF FLORIDA, IN
AND FOR ST. LUCIE COUNTY.
CASE NO. 74-460 ' CA
:
IN RE: The Marriage of
ROBERT FREDERICK EARLY , Husband ~1«o ~hn ~EC~~~t~ ~
~T, WCIE COUN Y l . ` ~
and ROCEk PatRA!
OIERK C~:~CUiT COURt
~ l~FCORO VERIFIEQ..~........
IMOGENE BRITT EARLY• Wife
,~111 8 ~e ~M'l~i
MOTION FOR DEFAULT
~8~~41
COMES NOW, the Wife, IMOGENE BRITT EARLY, and would show unto
the Court that the Husband, ROBERT FREDERICK EARLY, was duly served
with process in this case on the 17th day of May, 1974, at 3:38 P.M.,
by a Deputy Sheriff of the Off ice of St. Lucie County Sheriff's
Department; that the time for f iling of any answer or other defensive
pleading in the cause has now expired, and that no answer or other
defensive pleading has been served upon the law firm of Law Off ices of
Charles R. P. Brown, P.O. Box 1418, Fort Pierce, Florida, attorneys of
record for Wife herein by Husband, ROBERT FREDERICK EARLY, or any counsel
or attorney in his behalf as of the date of this Motion.
WHEREFORE, Wife moves for entry of a default by the Clerk against
i the Husband, ROBERT FREDERICK EARLY, for failure to serve any answer or
( other defensive pleading, or to file the same in this cause, as required
€
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~ by law .
LAW OFFICES OF C~~~I~S R. P. BROWN
, ~_,I
BY : ~ ~L~V/ / . f _ ,
C arles R. P. Brown
Attorney f or Wif e ~
301 South Sixth Street {
P .O. Box 1418
• Fort Pierce, Flor=ida 33450 ~
!
D E F A U L T .
A Default is entered in this cause against the Husband named in
~ the foregoing Motion for failure to serve or file any answer or other
~ defensive pleading as required by law.
~
DATED at Fort Pierce, Florida, this /O~ay of June, A.D., 1974.
~ Y`""-f.<_~OGER POITRAS, CLERK, CIRCUIT- COURT
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