THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
cankral770,
Plaintiff(s)
v.
EctopIex et al.,
Defendant(s)
Case No. RSC-CV-2769
Presiding Judge: The Hon. AlexJCabot
REQUEST FOR ENTRY OF DEFAULT
Dear Mr. Clerk of the Superior Court,
Plaintiff, by and through his undersigned counsel, requests that you enter default pursuant
to Rid. R. Civ. P. 37(a) as to the above-mentioned matter because the defendant has failed to file
an answer to the civil complaint within the appropriate time frame.
Attached below is an affidavit in support, where attestation is given that the images and
proof of the Defendant failing to answer the civil complaint is truthful and factual, and can be
confirmed by the court.
DATED: June 7th, 2024
Respectfully submitted,
acerxtro, Esq.
R. Bar No. 17137
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
Counsel for Plaintiffs
THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
cankral770,
Plaintiff(s)
v.
EctopIex et al.,
Defendant(s)
Case No. RSC-CV-2769
Presiding Judge: The Hon. AlexJCabot
MOTION FOR DEFAULT JUDGMENT
Plaintiff, by and through his undersigned counsel, respectfully moves and requests that
this court enter default judgment pursuant to Rid. R. Civ. P. 37(b), as all defendants have
defaulted on filing an answer to the civil complaint, resulting in the entry of default.
Plaintiff reiterates the demands for judgment in the complaint, with reasoning given in an
affidavit attached hereto.
1.
DATED: June 7th, 2024
Respectfully submitted,
acerxtro, Esq.
R. Bar No. 17137
Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
Counsel for Plaintiffs
THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
cankral770,
Plaintiff(s)
v.
EctopIex et al.,
Defendant(s)
Case No. RSC-CV-2769
Presiding Judge: The Hon. AlexJCabot
AFFIDAVIT IN SUPPORT OF DEFAULT
I, acerxtro, do swear under the pains and penalties of perjury:
1. I am of sound mind and capable of making this statement. I have personal knowledge of
the facts written in this statement. This statement is accurate to the best of my knowledge.
2. I am an attorney licensed to practice law before all courts in the State of Ridgeway and
counsel for Plaintiffs in the above-captioned action.
3. The Complaint and summons were served to all defendants, RickyPedina, the Bank of
Ecto (through RickyPedina) and Aczero_Verxa, on May 5th, 2024, at 5:43 PM Eastern
Time.
4. An answer to the complaint was due on May 11th, 2024, at 5:44 PM Eastern Time.
5. No answer or motion was filed within the time allowed, and therefore, the case is in
default. A request for declaration of default is attached in this package.
6. The amount owed by the Bank of Ecto totals $236,000.
a. Compensatory
i. $75,000 for the unlawful acquisition of the cankral770’s farmhouse (PTC)
ii. $90,000 for a return of Nlx095’s original money, supposed to be for
cankral770’s farmhouse (PTN)
b. Punitive
i. $10,000 for Breach of Contract to cankral770 (PTC)
ii. $5,000 for Fraud to cankral770 (PTC)
iii. $4,500 for Negligence to cankral770 (PTC)
iv. $6,000 for Criminal Conspiracy to cankral770 (PTC)
v. $10,000 for Breach of Contract to Nlx095 (PTN)
vi. $5,000 for Fraud to Nlx095 (PTN)
vii. $4,500 for Negligence to Nlx095 (PTN)
viii. $6,000 for Criminal Conspiracy to Nlx095 (PTN)
ix. $5,000 for Negligence Per Se to both plaintiffs (SPLIT)
x. $5,000 for Negligence Per Se to both plaintiffs (SPLIT)
xi. $5,000 for Negligence Per Se to both plaintiffs (SPLIT)
xii. $5,000 for Negligence Per Se to both plaintiffs (SPLIT)
7. The amount owed by Aczero_Verxa totals $6,000.
a. Compensatory
i. N/A
b. Punitive
i. $6,000 for Criminal Conspiracy to Nlx095 (PTN)
8. The amount owed by Rickypedina totals $12,000.
a. Compensatory
i. N/A
b. Punitive
i. $6,000 for Criminal Conspiracy to Nlx095 (PTN)
ii. $6,000 for Criminal Conspiracy to cankral770 (PTC)
9. The amount owed in attorney’s fees totals $125 (split between all defendants).
a. $125 court filing cost
10. Plaintiff incorporates all other previous pleadings herein in support of this declaration and
motion.
DATED: June 7th, 2024
Respectfully submitted,
acerxtro, Esq.
R. Bar No. 17137
Affiant & Counsel of Record
Cohn, Cicero, & Goodrich LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
Counsel for Plaintiffs
