Document for Jose Rodriguez Plaintiff vs. Celtic Insurance Company Defendant

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                                Filing # 117050107 E-Filed 11/20/2020 02:24:38 PM

IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JOSE RODRIGUEZ, Case No.: CACE-20-017538

Plaintiff,
vs.

CELTIC INSURANCE COMPANY
d/b/a AMBETTER FROM SUNSHINE HEALTH,

Defendant.
/

MOTION FOR DEFAULT
Plaintiff, by and through undersigned counsel, asks the clerk to enter a default against
CELTIC INSURANCE COMPANY d/b/a AMBETTER FROM SUNSHINE HEALTH, a Florida
Registered Insurance Company, Defendant, for failing to respond as required by law to Plaintiff’s
complaint.
1. The Summons and Complaint was served upon Defendant on or about October 26, 2020. See
Exhibit A.
2. The Defendant was required to file a response to Plaintiff's Complaint within twenty (20) days
from the date of service.
3. Defendant was required to Answer the Complaint on or before November 16, 2020.
4. As of the date of the filing of this Motion, the Defendant has failed to respond to the Complaint.

WHEREFORE, Plaintiff requests that the Clerk enter a default against Defendant. See Exhibit B.

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*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/20/2020 02:24:38 PM.****[42714901]

Respectfully submitted,

MARIN ELJAIEK LOPEZ & MARTINEZ, P.L.
Health and Medicine Law Firm Division
Counsel for Plaintiff

2601 S. Bayshore Drive,18th Floor
Miami, FL 33133

Ph: 305-444-5969

Fax: 305-444-1939

Service email:

health@mellawyers.com

Attorney email: msanti@mellawyers.com
jnunez@mellawyers.com

By: /s/ Maria T. Santi
MARIA T. SANTI, ESQUIRE
Florida Bar No.: 117564EXHIBIT A

[42714901]Filing # 115568224 E-Filed 10/26/2020 09:24:13 AM

 

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CASE #: CACE-20-017538
JOSE RODRIGUEZ COURT: CIRCUIT COURT
COUNTY: BROWARD
PLAINTIFF(S) DFS-SOP #: 20-000332738

VS.

CELTIC INSURANCE COMPANY D/B/A.
AMBETTER FROM SUNSHINE HEALTH

DEFENDANT(S)

SUMMONS, COMPLAINT, DISCOVERY

NOTICE OF SERVICE OF PROCESS

NOTICE IS HEREBY GIVEN of acceptance of Service of Process by the Chief Financial Officer of the
State of Florida. Said process was received in my office by ELECTRONIC DELIVERY on Thursday,
October 22, 2020 and a copy was forwarded by ELECTRONIC DELIVERY on Monday, October 26,
2020 to the designated agent for the named entity as shown below.

CELTIC INSURANCE COMPANY,
AURORA LOAIZA

771 WEST WACKER DR, STE 1200
CHICAGO, IL 60601

*Our office will only serve the initial process(Summons and Complaint) or Subpoena and is not responsible
for transmittal of any subsequent filings, pleadings, or documents unless otherwise ordered by the Court
pursuant to Florida Rules of Civil Procedure, Rule #1.080

Jimmy Patronis
Chief Financial Officer

ANTHONY LOPEZ
2601 SOUTH BAYSHORE DRIVE - SUITE 850
COCONUT GROVE, FL 33133

AN

Office of the General Counsel - Service of Process Section
200 East Gaines Street - P.O. Box 6200 - Tallahassee, FL 32314-6200 - (850)413-4200EXHIBIT B

[42714901]IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JOSE RODRIGUEZ, Case No.: CACE-20-017538

Plaintiff,
vs.

CELTIC INSURANCE COMPANY
d/b/a AMBETTER FROM SUNSHINE HEALTH,

Defendant.
Fe

DEFAULT
A default is entered in this action against Defendant, CELTIC INSURANCE COMPANY
d/b/a AMBETTER FROM SUNSHINE HEALTH for failure to serve or file a response or any

paper as is required by law.

Dated:
NOV 23 2020
CLERK OF THE CIRCUIT COURT (SEAL)

By:
Deputy Clerk

 

 

BRENDA D. FORMAN

[42714901]