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Date Filed 7/5/2022 4:13 P
Superior Court - Hampden
Docket Number 2279C V00266
COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, SS. SUPERIOR COURT
DEPARTMENT OF THE TRIAL COURT
CIVIL ACTION NO. 2279CV00266
KEITH DIXSON as Guardian of NELL
DIXSON,
07/05/22
Plaintiff REQUEST FOR DEFAULT AS TO
DEFENDANTS WILMINGTON
Vv. SAVINGS FUND SOCIETY, FSB
TRUSTEE FOR CASCADE FUNDING
WILMINGTON SAVINGS FUND MORTGAGE TRUST HB2 AND
SOCIETY, FSB Trustee for CASCADE HAROLD DIXSON
FUNDING MORTGAGE TRUST HB2
and HAROLD DIXSON,
Defendants
NOW COMES the Plaintiff, Keith Dixson, as Guardian of Nell Dixson, and respectfully
requests this Honorable Court enter default against the Defendants, Wilmington Savings Fund
BACON WILSON, P.C.
Society, FSB Trustee for Cascade Funding Mortgage Trust HB2 (“Wilmington”) and Harold
ATTORNEYS AT Law
6 SouTH East STREET Dixson, as to all counts of the Plaintiff's Complaint.
AMHERST, MA 01002
TELEPHONE (413) 256-6701
Fax (413) 256-6469 AS REASON THEREFOR, the Plaintiff states that, per the sworn Proof of Service and
100 RusseLt Street
PO. Box 377 Affidavit of Service of Denorris Britt, Brandywine Process Servers, LTD affixed to the summons
HADLEY. MA 01035,
TELEPHONE (413) 586-5055,
FAX (413) 586-0005 served on Wilmington, and Proof of Service of Process of the Hampden County Sheriffs Office
57 CENTER STREET affixed to the summons served on Harold Dixson now on file with the Court (see File Ref. Nos.
NORTHAMPTON, MA o1060
TELEPHONE (4131 584-1287
FAX 14131 584-0453 7-9), service was made on the two Defendants against whom default is now requested as follows:
33 STATE Street
SPRINGFIELD, MA o103 1 Wilmington on May 11, 2022, by service on Jay Curret, Managing Agent; and
TELEPHONE (413) 761-0560
FAx (619) 739-7740
2) Harold Dixson May 11, 2022 by leaving at his last and usual place of abode.
99 SPRINGFIELD ROAD
WestFieLo, MA o1085 To date, Defendants have failed to file an answer or other responsive pleading, or
TELEPHONE (4131 562-6611
FAX (4131 739-7740
otherwise defend this action as provided by the Rules of Civil Procedure.
11
f
Date Filed 7/5/2022 4:13
Superior Court - Hampde!
Docket Number 2279C VOI
WHEREFORE, pursuant to Mass. R. Civ. P. 55(a), Plaintiff requests that default be
entered as to each of the two Defendants, Wilmington and Harold Dixson forthwith
Respectfully submitted.
The Plaintiff,
Keith Dixson, as Guardian of Nell Dixson,
wy
s Attorney,
Ut & De DKG—
RYA O'HARA, ESQ.
BACO) WILSON, P.C
33 State Street
Springfield, MA 01103
Ph: (413) 781-0560
Fax: (413) 739-7740
rohara@baconwilson.com
BBO# 698768
July 5, 2022
CERTIFICATE OF SERVICE
I, RYAN K. O'HARA, hereby certify that on July 5, 2022, I caused a copy of the
foregoing Request for Default to be served upon all interested parties by mailing a copy thereof,
postage prepaid, first class mail to
Wilmington Savings Fund Society, FSB
Trustee for Cascade Funding Mortgage Trust HB2
Attn: Jay Curret, Managing Agent
500 Delaware Avenue, 11" Fl
Wilmington, DE 19801
Harold Dixson
130 Yale Street
Springfield, MA 01109
2 byoam he C than Ce (we
RYAN, O'HARA ae
3127221
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Date Filed 7/5/2022 4:13 P Superior Court - Hampden Docket Number 2279C V00266 COMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT CIVIL ACTION NO. 2279CV00266 KEITH DIXSON as Guardian of NELL DIXSON, 07/05/22 Plaintiff REQUEST FOR DEFAULT AS TO DEFENDANTS WILMINGTON Vv. SAVINGS FUND SOCIETY, FSB TRUSTEE FOR CASCADE FUNDING WILMINGTON SAVINGS FUND MORTGAGE TRUST HB2 AND SOCIETY, FSB Trustee for CASCADE HAROLD DIXSON FUNDING MORTGAGE TRUST HB2 and HAROLD DIXSON, Defendants NOW COMES the Plaintiff, Keith Dixson, as Guardian of Nell Dixson, and respectfully requests this Honorable Court enter default against the Defendants, Wilmington Savings Fund BACON WILSON, P.C. Society, FSB Trustee for Cascade Funding Mortgage Trust HB2 (“Wilmington”) and Harold ATTORNEYS AT Law 6 SouTH East STREET Dixson, as to all counts of the Plaintiff's Complaint. AMHERST, MA 01002 TELEPHONE (413) 256-6701 Fax (413) 256-6469 AS REASON THEREFOR, the Plaintiff states that, per the sworn Proof of Service and 100 RusseLt Street PO. Box 377 Affidavit of Service of Denorris Britt, Brandywine Process Servers, LTD affixed to the summons HADLEY. MA 01035, TELEPHONE (413) 586-5055, FAX (413) 586-0005 served on Wilmington, and Proof of Service of Process of the Hampden County Sheriffs Office 57 CENTER STREET affixed to the summons served on Harold Dixson now on file with the Court (see File Ref. Nos. NORTHAMPTON, MA o1060 TELEPHONE (4131 584-1287 FAX 14131 584-0453 7-9), service was made on the two Defendants against whom default is now requested as follows: 33 STATE Street SPRINGFIELD, MA o103 1 Wilmington on May 11, 2022, by service on Jay Curret, Managing Agent; and TELEPHONE (413) 761-0560 FAx (619) 739-7740 2) Harold Dixson May 11, 2022 by leaving at his last and usual place of abode. 99 SPRINGFIELD ROAD WestFieLo, MA o1085 To date, Defendants have failed to file an answer or other responsive pleading, or TELEPHONE (4131 562-6611 FAX (4131 739-7740 otherwise defend this action as provided by the Rules of Civil Procedure. 11 f Date Filed 7/5/2022 4:13 Superior Court - Hampde! Docket Number 2279C VOI WHEREFORE, pursuant to Mass. R. Civ. P. 55(a), Plaintiff requests that default be entered as to each of the two Defendants, Wilmington and Harold Dixson forthwith Respectfully submitted. The Plaintiff, Keith Dixson, as Guardian of Nell Dixson, wy s Attorney, Ut & De DKG— RYA O'HARA, ESQ. BACO) WILSON, P.C 33 State Street Springfield, MA 01103 Ph: (413) 781-0560 Fax: (413) 739-7740 rohara@baconwilson.com BBO# 698768 July 5, 2022 CERTIFICATE OF SERVICE I, RYAN K. O'HARA, hereby certify that on July 5, 2022, I caused a copy of the foregoing Request for Default to be served upon all interested parties by mailing a copy thereof, postage prepaid, first class mail to Wilmington Savings Fund Society, FSB Trustee for Cascade Funding Mortgage Trust HB2 Attn: Jay Curret, Managing Agent 500 Delaware Avenue, 11" Fl Wilmington, DE 19801 Harold Dixson 130 Yale Street Springfield, MA 01109 2 byoam he C than Ce (we RYAN, O'HARA ae 3127221