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Hi cozmofo
I just read through the threads
My apologies for the late reply. Am totally overwhelmed and work lately till 1am in attempts to keep up.
in relation to your matter, this is precisely how I would handle it
1. Have a private default judgment in place via the private administrative process (3 notices that are unanswered0
2. File an answer or reply, whatever the family Court document is that answers the application. That is essential. You list by one paragraph at a time any pleadings of fact that are relevant to your case. You also answer every paragraph your ex has made in her application, either with “admit” or “deny” then give the reason why you deny
3. Ensure you draw up an affidavit and state all your facts, then support each statement of fact with evidence by way of exhibit to the affidavit.
Ensure you answer each statement of fact in your ex’s affidavit, if there is one. If your ex’s is the last affidavit filed, yr ex will will by default. Never ever let yr opposite have the last filed affidavit. If one is filed – you make dam sure you answer it so yours is the last one filed. If the facts are unrebutted in your affidavit, it will stand as truth in commerce and you will win by default because you can then seek a summary judgment on the facts disclosed within that last affidavit.
You want to win? you gotta be smarter than your opponent and their liar – lawyer & ouytmanouvre them. It is simply “strategy”
I hope this helps
Off to. y next urgent job
cheers
mark