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This is not the answer that I am looking for. I would like receive one similar to the one that I've got from Ely, Counselor at Law on my last question.
Below is the answer that I received from him.
Sample reply:TITLE AND PARTIES (just copy of their filing) DEFENDANT'S JOINT DEFENDANTS’ RESPONSE TO MOTION FOR DEFAULT JUDGMENT (centered)NOW COMES Defendant, YOUR NAME, named Defendant in the above-entitled and numbered cause, and files this Defendants’ Response to Motion for Default Judgment, and shows the Court:FACTS1. Plaintiff is _____. 2. Defendants are ___.3. Plaintiff served… (explain what happened, and the Plaintiff’s cofusion).4.5.6. Defendants filed an Answer with the Court on ___, within the time allotted as not to default.GENERAL DENIALDefendant denies allegations in paragraph 1 of Plaintiff’s pleading.Defendant denies allegations in paragraph 2 of Plaintiff’s pleading.Defendant denies allegations in paragraph 3 of Plaintiff’s pleading.Defendant denies allegations in paragraph 4 of Plaintiff’s pleading.(etc)Defendant denies each and every allegation of Plaintiff's Motion for Default Judgment, and demands strict proof thereof as required by rules of evidence and procedure for the State of Florida.PRAYERDefendant prays the Court, after notice and hearing or trial, enters judgment in favor of Defendant, denies Plaintiff default judgment, awards Defendant the costs of court, legal fees, and such other and further relief as Defendant may be entitled to in law or in equity. Respectfully submitted, Your Signatures Your names (NEW PAGE)CERTIFICATE OF SERVICE (centered)I certify that on (date filed) a true and correct copy of Defendant's Defendants’ Response to Motion for Default Judgment was served to the opposing party.Your Signature Your name
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