Fill and Sign the Motion Ampamp Affidavit to Set Aside Entry of Default and Accept Late Filed Form

IN THE ___________________________ (Name of Court) COURT OF ___________________________ (County), ___________________________ (State) ___________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ________,_________ _____________________________________ DEFENDANT (Name of Defendant) Motion to Set Aside Entry of Default and Default Judgment Comes now ____________________________ (Name of Defendant), Defendant in the above-captioned cause, and respectfully moves that this Court set aside the Entry of Default and Default Judgment in the above-entitled and numbered cause and allow Defendant to answer the Complaint of Plaintiff, and as grounds for said Motion would show unto the Court the following: 1. The Complaint in the above-entitled and numbered cause was filed and a summons issued by the Clerk of this Court on _________________________ (date). 2. Service of process was made on Defendant on _________________________ (date). 3. Defendant, through mistake, inadvertence, and excusable neglect, failed to answer or otherwise appear in that cause for and on his behalf, within the time allowed by law. 4. An Entry of Default was entered against Defendant on ______________________ (date). 5. Default judgment was taken pursuant to that Entry of Default on ___________________ _________ (date). 6. Defendant has a meritorious defense to Plaintiff's Complaint.
7. The allegations of the said complaint are substantially true and, if true, establish a defense to the complaint; provided that, in all such cases, the court must accept all facts, and the sufficiency of which is for it to determine. 8. It is in the interest of justice to admit this complaint, the answer thereto, and to remit the said amounts of penalty and forfeiture to the clerk of the court. 9. Plaintiff and respondent request that this complaint be dismissed with prejudice. 10. Upon the court's consideration of the above-mentioned matter, the court is of the opinion that it is in the interest of justice to dismiss this cause with prejudice. Count 7: the plaintiff is a natural person who is a citizen of the United States and was born outside of any particular state or nation and who maintains and habitually engages in the business of being an attorney at law. Count seven is for monetary damages. The complaint alleges that defendant is an attorney at law, who resides and practices in Philadelphia pennsylvania and who is a citizen of the United States and was born and is now a resident of the state of Pennsylvania. Plaintiff has appeared as counsel for defendant at various court hearings related to this action. The amount sought here is 150, count 8: this count is alleged to be for an infringement on the plaintiff's copyright in the following work:   hotel, the.  (c) 1986, 1984,  boucher hayer, llc. No copyright.   (d) 1992, 1994,  boucher hayer, llc.  the copyright in this work is believed to be the author's and/or the author's agent's. No copyright assigned. (e) 1996, 1993,  boucher hayer, llc.  copyright in this work is believed to be the author's and/ or author's agent's. No copyright assigned. (i) 1996, 1992  boucher hayer, llc.  permission to copy as stated on the cover of the first edition. (j) 1996, 1993,  boucher hayer, llc.  copyright in this work is believed to be the author's and/or attorney's assignment. (k) 1995,  boucher hayer, llc.  no authonamesme.