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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF WAKE SUPERIOR COURT DIVISION
File No. 21-CVS-10322
STETSON MANSFIELD WEBSTER,
Plaintiff,
MOTION FOR
DEFAULT JUDGMENT
ANDY GEORGE, ANTHONY THOMAS,
KRISTEN GRUBER, TAMMY GOLDER
AND KEITH HUBBARD,
Defendants.
NOW COMES the Plaintiff, Stetson Mansfield Webster, pro se, and respect-
fully requests the Court to enter a Default JJudgment against Defendant Keith Hub-
bard, and in support thereof states as follows:
1. The Plaintiff filed raa
Complaint against Defendant Keith Hubbard on 3 August
2021.
2. The Defendant, Keith Hubbard, was duly served with the Complaint but failed
to answer or respond within the time prescribed by law.
3. An Order for Entry of Default against Defendant Keith Hubbard was entered
by this Court on 16 May 2022.
4. A Request for Admissions was served upon Defendant Keith Hubbard, which
was deemed admitted in its entirety by Order of this Court on 12 July 2022.
5. That the matters admitted establish Defendant Keith Hubbard's liability for
Alienation of Affection and Criminal Conversation and the damages suffered
by Plaintiff as a direct result of Defendant Keith Hubbard's actions.
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Electronically Filed Date: 1/16/2024 10:00 AM Wake County Clerk of Superior Court
WHEREFORE, Plaintiff respectfully requests the Court to enter a Default
Judgment against Defendant Keith Hubbard and award damages, costs, and any
other relief the Court deems just and proper.
Respectfully submitted on this 16th J
day of anuary 2024.
ils.
Stetson Mansfield Webster, Plairfti f Pro Se
320 Fowlkes Street Wendell, NC 27591
|
(919) 250-0052 stetson@stetsonwebster.com
|
CERTIFICATE OF SERVICE
Thereby certify that a copy of this Motion for Default JJudgment has been duly served
as follows:
1. To BOVIS KYLE BURCH AND MEDLIN at 806 Green Valley Rd, Suite 203,
Greensboro, NC 27408, by United States Postal Service in a postage-prepaid
envelope, properly addressed.
2. To KEITH HUBBARD at 1358 E 72nd Pl, Apt E, Chicago, IL, 60619, by
designated courier (FedEx), properly addressed.
This the 16* day of January 2024.
bile.
Stetson Mansfield Webster, Plafnt ff Pro Se
320 Fowlkes Street Wendell, NC 27591
|
(919) 250-0052 stetson@stetsonwebster.com
|
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DRAFT ORDER
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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF WAKE SUPERIOR COURT DIVISION
File No. 21-CVS-10322
STETSON MANSFIELD WEBSTER,
Plaintiff,
ORDER FOR
ANDY GEORGE, ANTHONY THOMAS,
DEFAULT JUDGMENT
KRISTEN GRUBER, TAMMY GOLDER
AND KEITH HUBBARD,
Defendants.
The Plaintiff, Stetson Mansfield Webster, respectfully submits this Proposed Default
Judgment against Defendant Keith Hubbard and, in support thereof, states as fol-
lows:
1. This Court entered an Order for Entry of Default against Defendant Keith
Hubbard on 16 May 2022 due to Defendant Keith Hubbard's failure to answer
or otherwise respond to Plaintiff's Complaint.
2. That pursuant to the Order Deeming Admitted Truth of Facts dated 12 July
2022, the facts set forth in the Plaintiff's Request for Admissions, served on
Defendant Keith Hubbard on 3 November 2021, are deemed admitted.
3. The admitted facts establish Defendant Keith Hubbard's liability for Aliena-
tion of Affection and Criminal Conversation and the damages suffered by
Plaintiff.
THEREFORE, it is hereby ORDERED, ADJUDGED, and DECREED that:
A. Plaintiff, Stetson Mansfield Webster, shall have and recover from Defendant
Keith Hubbard the sum of One Thousand (1,000) U.S. Dollars, representing
damages for Alienation of Affection and Criminal Conversation.
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B. That the Plaintiff shall recover costs of this action.
C. Any further relief deemed just and proper by the Court.
DATED this day of .20.
Judge
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Preview
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE COUNTY OF WAKE SUPERIOR COURT DIVISION File No. 21-CVS-10322 STETSON MANSFIELD WEBSTER, Plaintiff, MOTION FOR DEFAULT JUDGMENT ANDY GEORGE, ANTHONY THOMAS, KRISTEN GRUBER, TAMMY GOLDER AND KEITH HUBBARD, Defendants. NOW COMES the Plaintiff, Stetson Mansfield Webster, pro se, and respect- fully requests the Court to enter a Default JJudgment against Defendant Keith Hub- bard, and in support thereof states as follows: 1. The Plaintiff filed raa Complaint against Defendant Keith Hubbard on 3 August 2021. 2. The Defendant, Keith Hubbard, was duly served with the Complaint but failed to answer or respond within the time prescribed by law. 3. An Order for Entry of Default against Defendant Keith Hubbard was entered by this Court on 16 May 2022. 4. A Request for Admissions was served upon Defendant Keith Hubbard, which was deemed admitted in its entirety by Order of this Court on 12 July 2022. 5. That the matters admitted establish Defendant Keith Hubbard's liability for Alienation of Affection and Criminal Conversation and the damages suffered by Plaintiff as a direct result of Defendant Keith Hubbard's actions. 1 Electronically Filed Date: 1/16/2024 10:00 AM Wake County Clerk of Superior Court WHEREFORE, Plaintiff respectfully requests the Court to enter a Default Judgment against Defendant Keith Hubbard and award damages, costs, and any other relief the Court deems just and proper. Respectfully submitted on this 16th J day of anuary 2024. ils. Stetson Mansfield Webster, Plairfti f Pro Se 320 Fowlkes Street Wendell, NC 27591 | (919) 250-0052 stetson@stetsonwebster.com | CERTIFICATE OF SERVICE Thereby certify that a copy of this Motion for Default JJudgment has been duly served as follows: 1. To BOVIS KYLE BURCH AND MEDLIN at 806 Green Valley Rd, Suite 203, Greensboro, NC 27408, by United States Postal Service in a postage-prepaid envelope, properly addressed. 2. To KEITH HUBBARD at 1358 E 72nd Pl, Apt E, Chicago, IL, 60619, by designated courier (FedEx), properly addressed. This the 16* day of January 2024. bile. Stetson Mansfield Webster, Plafnt ff Pro Se 320 Fowlkes Street Wendell, NC 27591 | (919) 250-0052 stetson@stetsonwebster.com | 2 DRAFT ORDER 3 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE COUNTY OF WAKE SUPERIOR COURT DIVISION File No. 21-CVS-10322 STETSON MANSFIELD WEBSTER, Plaintiff, ORDER FOR ANDY GEORGE, ANTHONY THOMAS, DEFAULT JUDGMENT KRISTEN GRUBER, TAMMY GOLDER AND KEITH HUBBARD, Defendants. The Plaintiff, Stetson Mansfield Webster, respectfully submits this Proposed Default Judgment against Defendant Keith Hubbard and, in support thereof, states as fol- lows: 1. This Court entered an Order for Entry of Default against Defendant Keith Hubbard on 16 May 2022 due to Defendant Keith Hubbard's failure to answer or otherwise respond to Plaintiff's Complaint. 2. That pursuant to the Order Deeming Admitted Truth of Facts dated 12 July 2022, the facts set forth in the Plaintiff's Request for Admissions, served on Defendant Keith Hubbard on 3 November 2021, are deemed admitted. 3. The admitted facts establish Defendant Keith Hubbard's liability for Aliena- tion of Affection and Criminal Conversation and the damages suffered by Plaintiff. THEREFORE, it is hereby ORDERED, ADJUDGED, and DECREED that: A. Plaintiff, Stetson Mansfield Webster, shall have and recover from Defendant Keith Hubbard the sum of One Thousand (1,000) U.S. Dollars, representing damages for Alienation of Affection and Criminal Conversation. 4 B. That the Plaintiff shall recover costs of this action. C. Any further relief deemed just and proper by the Court. DATED this day of .20. Judge 5