Motion for default Judgement - Vicki

              IN THE CIRCUIT COURT GREENE COUNTY MISSOURI


Marc Perkel - pro se              )
         plaintiff,               )
                                  )
vs.                               )  No. 197CC0170
                                  )
William A. Wear Jr.               )
James R. Sharp                    )
The Law Firm of Wear and Sharp    )
Vicki Stringfellow                )
Donald A. Duncan - pro se         )
The Law Firm of Turner, Reid,     )
Duncan Loomer and Patton, P.C.,   )
         defendants,              )


                     MOTION FOR DEFAULT JUDGEMENT
                 AGAINST DEFENDANT VICKI STRINGFELLOW
                 ====================================


COMES NOW, Plaintiff Marc Perkel to ask the court for default judgement
against defendant Vicki Stringfellow for not responding to the amended
pleading within the time allotted under the rules. In support of this
motion Plaintiff states as follows:


1) On 01-15-97 Plaintiff filed his original pleading. Defendant was
   served on 01-16-97.


2) On 01-24-97 Defendant Stringfellow filed a motion to dismiss stopping
   the clock.


3) On 06-02-97 Plaintiff filed an amended pleading which again started
   time.


4) Rule 55.33 states "A party shall plead in response to an amended
   pleading within the time remaining for response to the original
   pleading ..." Rule 55.25 states that the defendant has 30 days to
   respond.


5) Since the defendant was served on 01-16-97 and responded on 01-24-97
   she used up 8 of the 30 days she had to respond. Since the Plaintiff
   amended his pleading on 06-02-97 and adding the 22 remaining days
   time ran out on 06-24-97. Today is 07-01-97 and she is now seven days
   late, so even if you add a few days for mailing she is out of time.


6) Her attorneys, Mr. Wear and Mr. Sharp have not filed for an extension
   of time. Mr. Wear and Mr. Sharp are seasoned attorneys and therefore
   should know what the requirements are for responding on time. Had
   they asked for more time BEFORE the deadline it might have been
   reasonable for the court to consider granting an extension. But they
   didn't ask for an extension of time, and now it's too late.


7) They have already created a six month delay and considering the
   original pleading was filed in January and has not been answered,
   Plaintiff contends that an extension of time should be denied.
   Plaintiff contends that if he were out of time and had failed to
   request that time be extended that the court would surely dismiss his
   complaint. What's good for the Goose is good for the Gander.


WHEREFORE, having run out of time and having not responded, Plaintiff
prays for a default judgement be issued in favor of the Plaintiff and
against defendant Vicki Stringfellow for $5,000,000.