1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION FOR ENTRY OF DEFAULT - 1
SHILLINGS S.P.
Albert Wellesley, Esq. (RBN No. 17116)
12 Madison Avenue NE
Suite 203, Pinkerton Heights
Milton, RW 80144
(555) 147-2811 | (555) 147-2801
D: kezzera
Dr. RebelPilot09, Esq.
Milton, RW 80140
D: funnypoliceman
Attorneys for Plaintiff Wynneboy2010
IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
RIDGEWAY COUNTY
WYNNEBOY2010,
Plaintiff,
vs.
KENZODOWNLOAD,
Defendant
Case No.: RSC-CV-5344
MOTION FOR ENTRY OF DEFAULT
Plaintiff WYNNEBOY2010, through undersigned counsel, pursuant to Rule 37(a) of the Ridgeway
Rules of Civil Procedure, moves this Court for entry of a default against Defendant KENZODOWNLOAD, for the
following grounds and reasons:
1. Service of Process has been made on the Defendant KENZODOWNLOAD on July 9, 2026 by
HALO4ASIN through Automated Systems caseHAWK, rumFiling and the Court’s Electronic
Docket Distribution.
2. Defendant appeared, and a second Service of Process has been made on the Defendant
KENZODOWNLOAD on July 10, 2026, after Plaintiff submitted its First Amended Complaint,
by proceeding communications.
3. Defendant, since July 9, 2026, is able to read and respond to messages by all other parties and
the Court involved in this matter.
4. Extension of time was sought by Defendant, which this Court has granted until July 18, 2026.
No further extensions were sought.
5. Defendant has failed to file a responsible pleading or motion to Plaintiff’s Amended Complaint.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION FOR ENTRY OF DEFAULT - 2
Wherefore Plaintiff seeks a default against the Defendant for failure to respond.
Dated this 20th day of July, 2026.
Albert Wellesley
Attorney for Plaintiff wynneboy2010
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION FOR ENTRY OF DEFAULT - 3
PLAINTIFF’S AFFIDAVIT FOR ENTRY OF DEFAULT
(RULE 37(a), RIDGEWAY RULES OF CIVIL PROCEDURE)
I, Albert Wellesley, being first duly sworn, deposes and says that:
1. I am the attorney for the Plaintiff in this matter.
2. I make this affidavit based on my own personal knowledge, and I am competent and can testify
to the matters herein.
3. I make this affidavit in support of a default to be entered against Defendant
KENZODOWNLOAD.
4. The Complaint in this matter was filed with the Court on July 9, 2026.
5. The Summons and Complaint, as attached, were properly served on Defendant
KENZODOWNLOAD on July 9, 2026 by Automated Systems caseHAWK, rumFiling and the
Court’s Electronic Docket Distribution. The Proof of Service was filed with the Court on the
same day (rumFiling File No. BATES-20260709-5087499944).
6. The Complaint was amended the first time (“First Amended Complaint”) and entered on July
10, 2026. The Summons and First Amended Complaint, as attached, (“Second Service”) were
properly served on Defendant KENZODOWNLOAD on the same day by proceeding
communications pursuant to Rule 5(b) of the Ridgeway Rules of Civil Procedure.
7. Defendant KENZODOWNLOAD was required to plead or otherwise respond to the First
Amended Complaint by July 16, 2026. The time to plead or otherwise respond to the Complaint
has been extended by agreement of the parties, and with leave of this Court, to July 18, 2026.
8. Upon information and belief, the Defendant is not incompetent, a corporation, a state agent or
in military service to the United States or Ridgeway.
9. That more than eight (8) days have elapsed since the date of the Second Service, and the
Defendant has failed to plead or otherwise defend this action by the required deadline of July
18, 2026.
Further deponent sayeth not.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION FOR ENTRY OF DEFAULT - 4
Dated this 20th day of July, 2026.
Respectfully submitted,
Albert Wellesley (RBN 17116)
Attorney for Plaintiff wynneboy2010
