Mark Williams vs. Tamara Williams

NOTICE OF MOTION AND MOTION FOR DEFAULT

State Of South Carolina
In The Family Court Of County Of Sumter
For The Third Judicial Circuit

Record Date: 03/29/12
Docket No.: 2011-DR-43-1685

RE Mark Anthony Williams,
     Plaintiff

     vs.
    
     Tamara Williams,
     Defendant.

TO: THE DEFENDANT, TAMARA WILLIAMS:

YOU WILL PLEASE TAKE NOTICE that the undersigned attorney for the Plaintiff, will move before the Presiding Judge of the Family Court of the Third Judicial Circuit, at the Sumter County Family Courthouse located at 108 North Magnolia Street, Sumter, South Carolina, on the 21st day of May, 2012 at 3:30 p.m., for the issuance of an Order declaring Defendant Tamara Williams, in default. This Motion shall be based upon the law of this State together with such other evidence as may be presented.

In support of the Motion, the Plaintiff shows the following to the Court:

1. The Summons and Complaint were mailed to the Defendant, Tamara Williams on November 23m 2011, as evidence by the Certificate of Service on November 23, 2011, attached as exhibit "A" and signed for by and adult, Amanda Johnosn, upon information and belief, residing with the Defendant, Tamara Williams, on November 26, 2011, as evidence by the Certified Mail Green Card attached as Exhibit "B" and the USPS tracking printout attached as Exhibit "C".

2. The Summons included a statement informing the Defendants that a default would be sought against them for the relief sought in the Complaint unless the Defendant answered or responded within thirty (30) days.

3. More than thirty (30) days have elapsed since the service of the Summons and Complaint.

4. The Defendant has not answered, otherwise plead, or requested an extension of the time in which to answer.

WHEREFORE, the Plaintiff respectfully moves this Court for an Order granting the Plaintiff a Decree of Separate Maintenance and Support, or in the alternative, a Decree of Divorce, based on one year separation and any other relief as the Court deems just, fit and proper.

Respectfully submitted,

YOUNG, KEFFER & DONNALD, P.A.

JOHN S KEFFER (signed)
Attorney for the Plaintiff
23 West Calhoun Street
Sumter, South Carolina 29150
(803) 773-4371 (Telephone)
(803) 773-4374 (Facsimilie)

Sumter, South Carolina
March 28, 2012


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