Motion,Ex Parte: LINDA VEGA ET AL VS YOSVANY MOREJON CASTILLO

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                                Filing # 141561992 E-Filed 01/07/2022 11:48:13 AM


                   IN THE CIRCUIT                COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN
                                        AND FOR MIAMI-DADE                       COUNTY, FLORIDA


                  LINDA VEGA
                           ,                                   CASE NO.: 2021-CA-23158

                           Plaintiff,

                  Vs.

                  YOSVANY MOREJON CASTILLO

                           Defendant.

                                    PLAINTIFF’S MOTION FOR CLERK’S                                  DEFAULT


                           COMES NOW, the Plaintiff, by and through undersigned counsel, and

                  pursuant to F.R.C.P. 1.500(a) hereby files the following Motion for Clerk’s Default,

                  and alleges as follows:

                           Florida Rule of Civil Procedure 1.500(a) states that “When a party against

                  whom affirmative relief is sought has failed to file or serve any document in the

                  action, the party seeking relief may have the clerk enter a default against the party

                  failing to serve or file such document.”

                           Here, the Defendant was served on November 30th, 2021.                             The Defendant

                  had 20 day to file a responsive pleading, or until December 20th, 2021.
                  To date, the Defendant has failed to file any paper or document or any responsive

                  pleading nor has sought any extension of time. Accordingly, a clerk’s default

                  should be entered against the Defendant.

                           WHEREFORE, for the foregoing reasons, the Plaintiff respectfully requests

                  that a clerk’s default be entered against the Defendant.




                                                                                 Respectfully submitted this th day of
                                                                                 January , 2022,


                                                                                 /s/Gregory Saldamando
                                                                                 _______________________
                                                                                 Gregory Saldamando, Esq.
                                                                                 Saldamando Law, P.A.
                                                                                 4000 Ponce de Leon Blvd, Suite 470
                                                                                 Coral Gables, FL 33146
                                                                                 Ph: 786-498-2210
                                                                                 Email: Greg@SaldamandoPA.com
                                                                                 Attorney for Plaintiff
                           I HEREBY CERTIFY that a copy of the foregoing Motion will be delivered

                  to the Defendant, US mail to defendant , YOSVANY MOREJON CASTILLO, at

                  his last known address, 13062 S.W. 185th Terr., Miami, FL 33177.




                                                                                 /s/Gregory Saldamando, Esq.
                                                                                 _________________________
                                                                                 Gregory Saldamando, Esq.
                                                                                 Saldamando Law, P.A.
                                                                                 4000 Ponce de Leon Blvd, Suite 470
                                                                                 Coral Gables, FL 33146
                                                                                 Ph: 786-498-2210
                                                                                 Email: Greg@SaldamandoPA.com
                                                                                 Attorney for Defendant