Paralegal Application

You are employed by attorney Sara Livingston, who has just handed you the Smith v Jones file with a memo, and left the office. The memo explains that Ms. Livingston represents Janet Smith, on whose behalf she filed and served a Complaint in the California state court. The Complaint was for injuries suffered by Jane Smith in an automobile accident involving a car driven by Robert Jones. Ms. Livingston's memo states that she things the file has "fallen through the cracks,' and she wants you to see what's going on in the case, and advise her of anything that needs to be done immediately. Today is February 13, 2019. You pull the file. You find the following: 1. A file-stamped copy of the Complaint showing that it was filed with the court on November 21, 2018. 2. A file-stamped copy of a Proof of Service of Summons and Complaint stating that the Summons, Complaint, and clerk's notices were personally served on defendant Jones on January 9, 2019. 3. Nothing subsequent to the Proof of Service of Summons and Complaint has been filed by either party in the case.

What do you tell Ms. Livingston must be done, and by what date?Explain.

Ms. Livingston applauds your work on the assignment after you have filed the Request to Enter Default and served it along with a Statement of Damages. She tells you to put the file away, calendar a tickler to check the file in two months to see whether the defendant has filed a motion to be relieved of the entry of default. What should you tell her?