IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PASCO COUNTY, FLORIDA

CASE NO.: 51-2004-004764-DR-WS/E

Stephen Paul MARTIN, )

Petitioner/Father, )
)
v. )
)
Theresa Marie MARTIN, )
Respondent/Mother. )
____________________________ )

Notice of Default, and Motion for Entry of Judgment and Execution

Comes now Theresa M. Martin, providing Notice of Default against Stephen P. Martin and

Arnelle M. Strand, and now moves the Court for entry of judgment and execution, to-wit:

Notice of Default

1.On June 29, 2007, the undersigned filed her “Motion for Sanctions against Arnelle Strand

for Frivolous Filings; and, Petition for Contempt against Stephen P. Martin for Failing TWO of

this Court’s ORDERS to Provide Changes in His Mailing Address” with the Clerk of this Court,

and served both adverse parties.

2.The time for answer or defense, from either or both adverse parties, has elapsed with no

responses, whatsoever; Accordingly, not only have both Stephen P. Martin and Arnelle M. Strand

waived any defense (Fla.R.Civ.P. 1.140), they also have now conceded to judicially binding

admissions of the veracity of said complaints against them (Fla.R.Civ.P. 1.110(e)).

3.Complaint was against Ms. Arnelle Strand in the amount of $275 for recompensing the

undersigned’s actual legal assistance expenses and lost productive time in having to defend her

frivolous filings, and in the amount of $1000 in punitive sanctions, to deter Ms. Strand from

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making any such filings in the future, as it displays an obvious disgust for the professional

integrity of the Florida Bar, and sanctions in the amount of $500 against each Ms. Arnelle Strand

and Mr. Stephen Martin, for refusing to comply with their duties to inform, at all, let alone

promptly, of the any changes of mailing addresses of Stephen Martin.

Motion for Entry of Judgment and Execution

4.Accordingly, the undersigned Respondent now moves the Court for Entry of Judgment and

execution thereupon, in said amounts as to each said obligor, with normal judgment interest as

may be applicable by law provided, until each said obligor pays his or her judgment in full.

WHEREFORE, the undersigned, Theresa M. Martin, now moves the Court for Entry of

Judgment and execution thereupon, in said amounts as to said obligors, with normal judgment

interest as may be applicable by law provided, until each said obligor pays his or her judgment in

full, and for all other relief that is true and lawful, and just and proper, in the premises.

Respectfully submitted,

______________________________
Theresa M. Martin

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 CERTIFICATE OF SERVICE

I hereby certify: that on this ______ day of August, 2007, a true and complete copy of the

foregoing notice of default and motion for entry of judgment and execution, by depositing the

same in the United States postal mail, first class postage preaffixed, has been duly served upon

the following:

Arnelle M. Strand, FBN 9806

Law Office of Arnelle M Strand, P.A.
8138 Massachusetts Avenue
New Port Richey, FL 34653

and, as a courtesy, unless and until he begins to represent himself, also upon:

Stephen P. Martin
25675 Hoffmeyer St.
Roseville, MI 48066

Stephen P. Martin
c/o Helene F. Ottinger
25924 Salem St.
Roseville, MI 48066

______________________________
Theresa M. Martin

Theresa M. Martin
10918 Norwood Avenue
Port Richey, FL 34668
727-457-2436