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Motion & Order for Default Judgment final

Motion & Order for Default Judgment final

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Published by Todd Wetzelberger
Motion For Default Judgment for failure to answer discovery, both judicial and extrajudicial. Sham complaint filed by crooked attorney Marc Donaty, Esq.
Motion For Default Judgment for failure to answer discovery, both judicial and extrajudicial. Sham complaint filed by crooked attorney Marc Donaty, Esq.

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Categories:Types, Research
Published by: Todd Wetzelberger on Jan 19, 2011
Copyright:Attribution Non-commercial

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09/20/2013

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DISTRICT COURT OF MARYLANDCOUNTY OF BALTIMORETodd Wetzelberger Counter-plaintiff v.VICTORY VILLA LLLPVICTORY VILLA LLPVICTORY VILLA LLCBRUCE I. LEVINEMARC R. DONATY, ESQCounter-Defendant(s) )))))))))CASE NO. 0804-41155-2008MOTION FOR DEFAULTJUDGMENTMOTION FOR DEFAULT JUDGMENTCOMES NOW, Todd Wetzelberger, counter-plaintiff, and moves the court to enter an Order for default judgment against counter- defendants and states:1.A counterclaim was filed in this court on November 1, 2010.
2.
Counter-defendants were properly served with said counterclaim via Certified Mail(enclosed Exhibit 10- proofs of service) between the dates of 3 November 2010 and 5 November 2010.
3.
All counter-defendants have failed to enter a Notice of Intention to Defend per MD Rule3-307.
4.
All counter-defendants have failed to answer counterclaim and are estopped from doingso.
5.
There are no material facts in dispute.
6.
Over 30 days have passed since counter-defendants were served with said counterclaim(Exhibit 10).WHEREFORE, counter-plaintiff is entitled to judgment by default in the amount of $30,000 andmoves the court to enter an Order of Judgment in favor of counter-plaintiff, for which letexecution issue.______________________________ Todd Wetzelberger 
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VERIFICATION OF MOTIONSTATE OF __________________ COUNTY OF ____________________ BEFORE ME personally appeared Todd Wetzelberger who, being by me first duly swornand identified in accordance with Maryland law, deposes and says:1.My name is Todd Wetzelberger.
2.
I have read and understood the attached foregoing motion filed herein, and each factalleged therein is true and correct of my own personal knowledge.FURTHER THE AFFIANT SAYETH NAUGHT. ________________________ Todd Wetzelberger, AffiantSWORN TO and subscribed before me____________________________, NotaryPublic, this ___ day of _______________ 2010. ___________________________  Notary PublicMy commission expires:
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DISTRICT COURT OF MARYLANDCOUNTY OF BALTIMORETodd Wetzelberger Counter-plaintiff v.VICTORY VILLA LLLPVICTORY VILLA LLPVICTORY VILLA LLCBRUCE I. LEVINEMARC R. DONATY, ESQCounter-Defendant(s) )))))))))CASE NO. 0804-41155-2008ORDER FOR DEFAULTJUDGMENTORDER FOR DEFAULT JUDGMENTUPON CONSIDERATION of the foregoing counter-plaintiff’s Motion For Default Judgmentand the court having considered the facts and law in this matter, now therefore it is ordered andadjudged this ____day of ______________, 2010 that:Default judgment be entered for counter-plaintiff Todd Wetzelberger against all counter-defendants, names and addresses stated in Exhibit 10- proof of service, in the amount of $30,000,for which let execution issue. by
 _____________________________ ________ Judge Judge ID
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