Motion for default judgment
Due to lack of response from the defense counsel and the simplicity of the case brought forth, the Plaintiff moves for a default judgment request.
Mr Lobo, while gainfully employed by the State, took out a loan with our client with the simplest of agreements - return a certain amount by a certain date, nothing less, nothing more.
The Defendant has not contacted the Plaintiff at all prior to, at, or past the deadline of his payment, providing no excuse for his lack of payment.
Simply disappearing off the face of the planet is not enough to justify a written contract no longer being valid.
Due to this lack of presence, the plaintiff is additionally moving for Court Enforcements of Judgment - if default or any other judgement is rendered in plaintiff's favor, we request of the court to enforce this ruling by means of fund or asset seizure and forfeiture.
respectfully submitted,
Annabelle Celestine, representing Miss Knox
