Motion for Default Judgment 7th JUDICIAL DISTRICT COURT 10/9/2025 2:18 PM RACHEL GONZALES CLERK OF THE COURT /s/ Micaela Zamora Socorro County STATE OF NEW MEXICO COUNTY OF SOCORRO SEVENTH JUDICIAL DISTRICT DERYK JAE GACANICH, Petitioner, vs. BETHANY ROSE GACANICH, Respondent. MOTION FOR DEFAULT JUDGMENT No. D-725-DM-2024-00047 COMES NOW the Petitioner, Deryk Jae Gacanich, by and through his attorney, Scott Pistone, Esq., and for his Motion for Default Judgment, hereby states: 1The Petitioner filed a Petition for Dissolution of Marriage on July 19, 2024;2. Respondent has been duly served with process herein on July 26, 2024;3. Respondent has failed to follow Court Orders, appear at hearings and participating in this litigation; 4.There is no just cause for delay in entering Judgment in favor of Petitioner and against the Respondent in accordance with the Petition; 5. This Court has jurisdiction of the parties and subject matter herein; 6. A Merits Hearing in this matter is scheduled for November 17, 2025, at 10 a.m. 7.Petitioner seeks an Order: a. Granting the Petitioner a divorce on the grounds of incompatibility; b .Finding that the Petitioner is the natural father of the minor children; c. Awarding the Petitioner sole legal and sole physical custody of the minor children. d. Establishing child support; WHEREFORE, The Petitioner prays this Court for its Order: A. Granting the Petitioner a divorce on the grounds of incompatibility B. Finding that the Petitioner is the natural father of the minor children; C. Awarding the Petitioner sole legal and sole physical custody of the minor children; D. Establishing child support; E. Ordering such other and further relief as this Court may deem just and appropriate. Respectfully submitted, /s/ Scott Pistone, Esq. Scott Pistone, Esq. Attorney for the Petitioner 1010 Bridge Blvd. SW Ste. C Albuquerque, New Mexico 87105 (505) 842-9498 #11869111 11/30 12/7 12/14/2025