Filed by Conrad · Case 26-104594-DO
11 Motion For Default Judgment On Counterclaim 2026-05-12
Canonical record: rockenhaus.net. Disputed domains are indexed at /disputed-domains/ (not authoritative).
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STATE OF MICHIGAN
IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE
THIRD JUDICIAL CIRCUIT, FAMILY DIVISION
ADRIENNE MARJORIE ROCKENHAUS, Case No. 26-104594-DO
Plaintiff/Counter-Defendant, Hon. Nicole N. Goodson
v.
CONRAD ALAN ROCKENHAUS,
Defendant/Counter-Plaintiff.
DEFENDANT/COUNTER-PLAINTIFF'S MOTION FOR DEFAULT JUDGMENT ON
COUNTERCLAIM
NOW COMES Defendant/Counter-Plaintiff Conrad Alan Rockenhaus, appearing pro se, and respectfully
moves this Honorable Court for entry of default judgment in his favor on the Counterclaim served and filed
April 15, 2026, pursuant to MCR 2.603(B)(3), on the deemed-admitted record produced by Counter-
Defendant's failure to plead within the period prescribed by MCR 2.108(A)(4). In support,
Defendant/Counter-Plaintiff states as follows.
LCR 2.119(B) COMPLIANCE
1. The undersigned hereby certifies, pursuant to LCR 2.119(B)(1), that he has complied with all provisions
of LCR 2.119(B) on motion practice. Specifically, and pursuant to LCR 2.119(B)(2), undersigned
requested concurrence of counsel for Plaintiff/Counter-Defendant in the relief sought herein on May 11,
2026, by electronic transmission to Lisa Baker, Esq. (P82555), Aldrich Legal Services, PLLC.
Concurrence was not received within the requested response window of 7:30 AM EDT, Tuesday, May
12, 2026, and is therefore deemed denied for purposes of LCR 2.119(B)(2). It is therefore necessary to
present this motion.
I. PROCEDURAL BACKGROUND
2. Plaintiff/Counter-Defendant Adrienne Marjorie Rockenhaus filed her Verified Complaint for Divorce in this
Court on April 9, 2026.
3. Defendant/Counter-Plaintiff Conrad Alan Rockenhaus filed and served his Answer to Verified Complaint
for Divorce, Affirmative Defenses, and Counterclaim ("Counterclaim") on April 15, 2026. Service was
effected by First-Class U.S. Mail to counsel of record, Lisa Baker, Esq. (P82555), Aldrich Legal Services,
PLLC, at 276 South Union Street, Plymouth, MI 48170. Service was complete on mailing pursuant to
MCR 2.107(C)(3).
4. Plaintiff/Counter-Defendant has appeared generally in this matter through Aldrich Legal Services, PLLC.
Counsel's appearance covers the Counterclaim under standard Michigan practice.
5. The Counterclaim contains a verified prayer for relief at WHEREFORE Counts A through K, including
specific monetary, accounting, property-return, and equitable-distribution items grounded in the factual
averments at Paragraphs 24 through 62.
II. PREDICATE FAILURE, COUNTERCLAIM UNANSWERED
6. MCR 2.108(A)(4) provides: "A party served with a pleading stating a cross-claim or counterclaim against
that party must serve and file an answer or take other action permitted by law or these rules within 21
days after service."
7. Twenty-one days from April 15, 2026 is May 6, 2026. The rule contains no mailing extension applicable
to counterclaim answers.
8. As of the filing of this motion on May 12, 2026, no answer, motion, or other responsive pleading has
been served or filed by Plaintiff/Counter-Defendant. The 21-day period prescribed by MCR 2.108(A)(4)
expired six days ago.
9. The factual averments of the Counterclaim are therefore deemed admitted by operation of the rule. MCR
2.603(A); see also Wood v. Detroit Auto. Inter-Ins. Exch., 413 Mich. 573, 582 (1982) (default operates as
an admission of the well-pleaded allegations of the complaint).
III. DEFAULT PROPERLY ENTERED UNDER MCR 2.603(A)
10. Defendant/Counter-Plaintiff has filed contemporaneously with this Motion a Default Request and Entry
on SCAO Form MC 07, requesting clerk's entry of default of Plaintiff/Counter-Defendant on the
Counterclaim. The Request is supported b
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About this filing
11 Motion For Default Judgment On Counterclaim 2026-05-12: filing by Conrad Alan Rockenhaus in Rockenhaus v. Rockenhaus (Divorce), Michigan Case No. 26-104594-DO, Wayne County Circuit Court. PDF and searchable text at rockenhaus.net (canonical court record). Disputed third-party domains: /disputed-domains/.
- File name
11_Motion_for_Default_Judgment_on_Counterclaim_2026-05-12.pdf- Filed date
- Case number
- 26-104594-DO
- Category
- Filed by Conrad
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- Related context
- FAQ, Joe Prich evidence, Rob Hein
- Canonical record
- rockenhaus.net