2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION TO SET ASIDE DEFAULT JUDGMENT – 1
XXX
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
Defendant in pro per

IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, XXX

XXX TOWER MANAGEMENT,
LLC,

Plaintiff,

vs.
XXX,  ET. AL.,
Defendants.

Case No.: XXXX

MOTION TO SET ASIDE DEFAULT

JUDGMENT

NOTICE OF MOTION TO SET ASIDE DEFAULT JUDGMENT

You are hereby informed that on the _______ day of __________________________, XXX, at
__________ (am/pm), or as soon thereafter as Jairo De La Vega may be heard, he will bring on
for hearing his Motion to Set Aside Default Judgment. The Motion will be based on this Notice
of Motion, the attached Motion, as well as any oral arguments presented or physical evidence
produced during the hearing.

Dated this ____ day of September, XXX.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION TO SET ASIDE DEFAULT JUDGMENT – 2

Respectfully Submitted,

___________________________________
XXX,
Defendant in pro per

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION TO SET ASIDE DEFAULT JUDGMENT – 3
XXX
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
Defendant in pro per

IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY,XXX

XXX TOWER MANAGEMENT,
LLC,

Plaintiff,

vs.
XXX, ET. AL.,
Defendants.

Case No.: XXX

MOTION TO SET ASIDE DEFAULT
JUDGMENT

MOTION TO SET ASIDE DEFAULT JUDGMENT

NOW COMES XXX, Defendant, and files this Motion to Set Aside Default
Judgment, and for cause would show this Honorable Court as follows:
1. This Court entered default judgment against Defendants on May XXX. Exhibit 1.
2. Jairo De La Vega would like this Court to set aside the default judgment pursuant to Rule
1.500(d) which states as follows: “The court may set aside a default, and if a final
judgment consequent thereon has been entered, the court may set it aside in accordance
with rule 1.540(b).”

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MOTION TO SET ASIDE DEFAULT JUDGMENT – 4

VERIFICATION

I, XXX, do hereby declare that the foregoing is true to the best of my knowledge,
except those things stated upon belief, which I believe to be true.

Dated this ____ day of September, XXX.

Respectfully Submitted,

___________________________________
XXX,
Defendant in pro per

At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, The LegalPen will be able to prepare the legal document within the shortest time possible. You can send us your quick enquiry ( here )