Motion for Default - Party: Plaintiff Rodriguez, Jose - Jose Rodriguez Plaintiff vs. Celtic Insurance Company Defendant

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On October 21, 2020 contract and indebtedness case was filed by Rodriguez, Jose, represented by Santi, Maria T., Esq., against Celtic Insurance Company, represented by Smith, Craig H., in the jurisdiction of Broward County. Judge McCarthy, Barbara presiding.

                        
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                          Filing # 116860739 E-Filed 11/18/2020 10:11:42 AM

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…