E-FILED 2014 DEC 10 4:38 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2014 DEC 10 4:38 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2014 DEC 10 4:38 PM SAC - CLERK OF DISTRICT COURT

E-FILED 2014 DEC 18 10:37 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 13 9:10 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 13 9:10 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 13 9:10 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 13 9:10 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 13 9:10 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR SAC COUNTY

PROGRESSIVE NORTHERN INS,

Plaintiff,
v.
MICHAEL GERGIS
DANIEL RANGEL,
Defendant(s).

Case No. LACV019578

MOTION FOR DEFAULT and REQUEST

FOR ENTRY OF JUDGMENT

COMES NOW the Plaintiff and hereby demands the Court or Clerk of the Court, pursuant to
Iowa R. Civ. P. 1.971 & 1.972, enter default upon Defendant(s), MICHAEL GERGIS .
Plaintiff further requests, pursuant to Iowa R. Civ. P. 1.972, that upon a finding of default in this
matter, the Court or Clerk of the Court enter judgment of record in favor of the Plaintiff(s) for
the amount set forth in the Plaintiffs Petition, together with interest and costs.
If the above Defendant(s) are individuals, then in support of this demand, Plaintiff files, or has
already filed, a Verification of Account, Identification of Judgment Debtor, and Affidavit Re
Military Service.
CERTIFICATION PURSUANT TO RULE 1.971
I, the undersigned attorney, state that I am the attorney for the Plaintiff in this action and I hereby
certify a NOTICE OF INTENT TO FILE WRITTEN APPLICATION FOR DEFAULT, a true
and correct copy which is attached hereto was served upon the Defendant(s) after default had
occurred in this action and said Notice was mailed on the date indicated in the Notice which is at
least 10 days prior to filing this request for entry of default.
I certify under penalty of perjury and pursuant to the laws of the state of Iowa that the preceding
is true and correct. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.

Date 01/28/2015

/s/ Christopher E. Pech

Christopher E. Pech AT0006178
Piper Lori Hughes AT0003675
James H McDonald AT0008887
Pech, Hughes & McDonald, P.C.
P.O. Box 2165
Cedar Rapids, IA 52406
Telephone:
(319) 362-3000
Facsimile:
(319) 362-3277
ATTORNEY FOR PLAINTIFF

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 9:57 AM SAC - CLERK OF DISTRICT COURT

E-FILED 2015 JAN 28 10:29 AM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR SAC COUNTY

PROGRESSIVE NORTHERN INS,

Plaintiff,
v.
MICHAEL GERGIS
DANIEL RANGEL ,
Defendant(s).

Case No. LACV019578

COURT'S ENTRY OF DEFAULT

JUDGMENT
UNDER IOWA R. CIV. P. 1.972(1)

COURT'S ENTRY OF DEFAULT JUDGMENT

UNDER IOWA R. CIV. P. 1.972(1)
The Court having proof of the amount owing by Affidavit and Proof of Service of
process without a timely Answer, Motion or other Pleading enters Judgment pursuant to the
request and proofs of the Plaintiff.
IT IS THEREFORE ORDERED Judgment is hereby entered against Defendant(s):
MICHAEL GERGIS :
1.
For damages in the amount of $9,474.00;
2.
For future interest at the statutory rate from the date of filing; and
3.
For court costs.

Prepared and submitted by:

Pech, Hughes & McDonald, P.C.
PO Box 2165
Cedar Rapids IA 52406

E-FILED 2015 JAN 28 10:29 AM SAC - CLERK OF DISTRICT COURT

State of Iowa Courts

Type:

ORDER FOR JUDGMENT

Case Number
LACV019578

Case Title
PROGRESSIVE NORTHERN INS VS MICHAEL GERGIS ET AL
So Ordered

Electronically signed on 2015-01-28 10:29:02

page 2 of 2