Thank you, Dave. Agreed, I really could not file a Motion for Default - as I filed my MTD and the other side just failed to answer (according to the local rule I found - copied below it appears that they would have 28 days to respond to the motion).
Thereafter those 28 days, they have waived their right to respond, and the court would just issue a decision on my motion.
However, last time we were in court, the judge seemed to allude to "any other" motions I may file - I should notice them up for our next status - Jan 9th. I am still wondering what that other motion could be? Motion to have the court rule on my Motion without a response (?) That does seem unnecessary - but possible.
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