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  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
  • MIDWEST FINANCIAL CREDIT UNIT K/N/A DFCU FINANCIAL v. STUBBS, DAVID E.C40 - Contracts - Collections document preview
						
                                

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NO: NNH-CV-15-6053204S SUPERIOR COURT MIDWEST FINANCIAL CREDIT JUDICIAL DISTRICT OF UNION K/N/A DFCU FINANCIAL VS. NEW HAVEN AT NEW HAVEN DAVID E. STUBBS MARCH 29, 2016 MOTION FOR DEFAULT FOR FAILURE TO PLEAD The Plaintiff in the above-entitled action respectfully represents that although the time for filing a pleading has passed the Defendant, DAVID E. STUBBS, has failed to file same. While the Defendant has filed a Motion to Dismiss [No. 109.00], he has failed to mark the matter “ready” on the short calendar thus depriving the Court the opportunity to address his Motion on the merits. The Plaintiff has filed an Objection and Memorandum of Law in Opposition to the Motion to Dismiss and has attempted to have these heard by the Court. The Defendant's delay in placing his Motion to Dismiss before the Court is prejudicing the Plaintiffs interests and preventing the timely disposition of this matter. WHEREFORE, the Plaintiff respectfully requests that a default for failure to plead enter against the Defendant, DAVID E. STUBBS or in the alternative set a date certain for argument of the Motion to Dismiss [No. 109.00]. THE PLAINTIFF, Hh ORAL ARGUMENT AND TESTIMONY ARE NOT REQUIRED By Miguel A. Imodovar, Esq. of Jacobs & Rozich, LLC 91 William Street, P.O. Box 1952 New Haven, Connecticut 06509 Tel. 203.772.4134 Fax. 203.772.4472 Juris No. 024796 NO: NNH-CV-15-6053204S SUPERIOR COURT MIDWEST FINANCIAL CREDIT JUDICIAL DISTRICT OF UNION K/N/A DFCU FINANCIAL Vs. NEW HAVEN AT NEW HAVEN DAVID E. STUBBS ORDER The Defendant(s), DAVID E. STUBBS , having failed to file a pleading within the time limited under the rules of practice, it is ORDERED” 1. That a default for failure to plead enter against the Defendant, DAVID E. STUBBS. OR 2. That the Motion to Dismiss shall be argued before the Court on , 2016. BY THE COURT JUDGE/CLERK CERTIFICATION OF SERVICE The undersigned certifies that a copy of this document was sent by first-class mail postage pre-paid to the following counsel of record, pro se parties, and/or non-appearing parties as required by the Practice Book on March 29, 2016: Roderick D. Woods Woods Law Firm LLC 100 Pearl Street 14th Fir Hartford, CT 06103 Miguel . Almodovar, Esq. Commissioner of the Superior Court