STATE OF INDIANA ) IN THE HANCOCK CIRCUIT COURT

)
COUNTY OF HANCOCK ) CAUSE NO. 30C01-0601-155

JURY TRIAL REQUESTED

ANN FORRESTER and WILLIAM FORRESTER, )

Husband and Wife, also on behalf of )
SARAH AND MICHAEL FORRESTER, )
Their minor children )
Plaintiffs, )
)
vs. )
)
RICHARD HART and, )
MERCURY PARCEL SERVICE, INC, )
Defendants. )

VERIFIED MOTION FOR DEFAULT JUDGMENT

The Plaintiff(s) requests the Court to enter a default judgment against the Defendant(s) as
set forth below. The Plaintiff(s) states that, to the best of their knowledge and belief:
The Defendant(s) in this case was/were served with a copy of the Complaint in this case
and has/have failed to appear for trial or plead after receiving proper notice. I have no reason to
believe that the Defendant(s) is/are either a minor or incompetent. For purposes of complying
with the Soldiers and Sailors Civil Relief Act of 1940, 50 USC 520, I have no reason to believe
that the Defendant(s) is/are in the active military service of the United States.
The Defendant(s) owe(s) the Plaintiff(s) the following amounts:
a. Damages/Principal $ 333,238.00
b. Prejudgment Interest (if claimed) $______________
c. Attorney Fees (if claimed) $______________
d. Other: Current losses incurred from lack of wages and business $162,216.00
Total (excluding filing fees) $495,454.00____

I affirm, under the penalties for perjury, that the foregoing representations are true.
Dated:___________________, 200__. ____________________________________
David P. Murphy, 9388-30
 DEFAULT JUDGEMENT

The Court, being duly advised, hereby:

A. denies the motion for default judgment because:
_________________________________________________________________________.
B. finds that the Plaintiff appeared and that the Defendant(s) failed to appear for first trial
setting and grants the motion for default judgment. The Court orders the Clerk enter
judgment in favor of the Plaintiff(s) and against the following
Defendant(s)________________________________________________________________
in the sum of $________________, plus court costs of $________
(total $_________________).

RECOMMENDED BY: APPROVED AND ORDERED:

_____________________ __________________________
Commissioner Hancock County Circuit Judge

Date:_________________ Date:______________________

Distribution: ____ Plaintiff/Attorney ____ Defendant/Attorney