No. 25-3-00224-1 -Motion for Default

Published 1:30 am Friday, May 1, 2026

No. 25-3-00224-1

Motion for Default

(MTDFL)

Superior Court of Washington, County of PIERCE

In re:

Petitioner:

MACKENZIE SAIGE TAYLOR

And Respondent:

JUSTINE GERMAINE TAYLOR

Motion for Default

Important! The person making this motion must ask the court to sign the Order on Motion for Default (FL All Family 162) either at a hearing or at ex parte.

• If you must notify the other side about this motion, you may use the Notice of Hearing form (FL All Family 185) unless local rule requires a different form. Contact the court for scheduling information.

• If you don’t have to notify the other side, you may ask the court to sign the Order “ex parte” (without the other party there). Contact the Superior Court Clerk’s office for the procedure in your county.

1. My name is: MacKenzie Taylor.

2. Request

I ask the court to find the other party Justin Taylor, in default, and to approve final orders in this case without the other party’s participation because the other party has not filed a Response.

I have previously filed a Motion for Default, which was scheduled for 8/13/2025 and Mr. Taylor appeared at the hearing. Due to Mr. Taylor appearing, the hearing was stricken by the Commissioner. (See clerk minutes entry from the 8/13/2025 hearing). Since the hearing the Respondent has not made any efforts to do the required steps, specifically filing a response to the petition and taking the required parenting seminar. The Respondent was served over a year ago and to this day has not filed a Response so our case cannot move forward. There was a second Motion for Default that was held on 3/12/2026, and that was motion was denied and the hearing was stricken for lack of

service. (See clerk minutes entry from the 3/12/2026 hearing).

On 4/13/2026, the court granted an Order to allow service of the Motion for Default and Notice of Hearing to be served by publication. (See clerk minutes entry from the 4/13/2026 hearing granting the Order to serve by publication). I respectfully ask the Court to find Mr. Taylor in default, as he has not taken any steps to fulfill his requirements.

3. Notice about the motion

I must give the other party a copy of this motion and advance notice of the hearing

because:

• he has appeared in this case in some other way.

4. Service of Summons and Petition

The other party was properly served on 01/23/2025 with a Summons and Petition for this case and any other documents listed in the proof of service filed with the court. State where the other party was served: Pierce County, WA

5. Timing and type of service

The other party was served with the Summons and Petition by personal service in Washington State, at least 21 days ago.

6. Correct Court

(venue and jurisdiction)

At the time this case was filed:

The Petitioner lived in: PIERCE, WA

The Respondent lived in: PIERCE, WA

The children (if any) lived in: PIERCE, WA

The Petition describes how this court has jurisdiction over this case and the parties.

7. Active duty military

(The federal Servicemembers Civil Relief Act covers:

• Army, Navy, Air Force, Marine Corps, and Coast Guard members on active duty;

• National Guard or Reserve members under a call to active service for more than 30 days in a row;

and

• commissioned corps of the Public Health Service and NOAA.

The state Service Members’ Civil Relief Act covers those service members listed above who are either stationed in or residents of Washington state, and their dependents, except for the commissioned corps of the Public Health Service and NOAA.)

The other party is not covered by the state or federal Servicemembers Civil Relief Act. I know this because: The Respondent is retired from the military and is not on active duty.

Person making this motion fills out below:

I declare under penalty of perjury under the laws of the state of Washington that the facts I have provided on this form are true.

Signed at: Puyallup, WA Date: 4/14/2026

/s/ MACKENZIE TAYLOR

Lawyer (if any) fills out below

/s/ TYLER BROWN 62660 4/14/2026

IDX-1030189

May 1, 8, 15, 22, 29, June 5, 2026