My STBX refused to sign a Separation and Property Settlement Agreement and we were unable to reach an agreement about our marital property. So, I filed a Verified Complaint for Divorce and Equitable Distribution as a pro se Plaintiff. (Yes, we have lived separate and apart for more than one year.) Defendant failed to file a responsive pleading within 30 days of service of the Complaint. I know that he is in default, but I want to file the appropriate paperwork with the Court to ensure that the ED is properly addressed. Everything that I have found in the way of samples and forms relate to an absolute divorce and not one that includes a claim for ED.
(1) What is the proper pleading that should be filed: a request for entry of default and default judgment or a motion for summary judgment?
(2) What language should be included in the motion to address the ED claim?
(3) While I understand that a dissolution of the marriage will be granted, how is the ED claim handled after the Defendant is found to be in default?