On May 30, 2019 a
Judgment
was filed
involving a dispute between
Carraro, Victoria Rhoades,
and
Carl Westman Trustee Under The Revocable Trust Agreement Of Charles R Rhoades Date July 2 1998,
Jenkins, Annina,
Rhoades, David B,
Rhoades Iv, Charles R,
Rhoades, James,
Rhoades, Robert,
Van Dien, Pieter,
Westman, Carl,
for Other Circuit Civil
in the District Court of Collier County.
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Filing # 92418355 E-Filed 07/11/2019 03:57:29 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
VICTORIA RHOADES CARRARO,
Plaintiff,
v.
CARL WESTMAN, as Trustee under the
Revocable Trust Agreement of Charles R. Case No. 2019-CA-2160
Rhoades dated July 2, 1998; CARL
WESTMAN, as the Personal Representative
of the Estate of Charles R. Rhoades;
CHARLES R. RHOADES IV; DAVID B.
RHOADES; JAMES RHOADES; ROBERT
RHOADES; and ANNINA JENKINS,
Defendants.
MOTION FOR CLERK’S DEFAULT
Plaintiff, Victoria Rhoades Carraro, pursuant to Rule 1.500(a), Fla.R.Civ.P., moves for the
entry of a default by the Clerk against the Defendant, Charles R. Rhoades IV, for failure to serve any
paper on the undersigned or file any paper as required by law. Defendant was served on June 7, 2019
and required to respond by June 27, 2019.
I certify that no copy of an answer or other response of the above-referenced Defendant has
been received by Plaintiff’s attorney as of the time of filing this motion for default. Plaintiff has filed
the appropriate non-military affidavit related to Charles R. Rhoades IV.
CHEFFY PASSIDOMO, P.A.
821 Fifth Avenue South
Naples, FL 34102
Telephone: (239) 261-9300
Facsimile: (239) 261-9782
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/11/2019 03:57:29 PMAttorneys for Plaintiff
/s/ Andrew H. Reiss
Andrew H. Reiss
Florida Bar No. 116955
Primary e-mail: ahreiss@napleslaw.com
Secondary e-mail: raricci@napleslaw.com
CERTIFICATE OF SERVICE
Thereby certify that a true and correct copy of the foregoing has been furnished by First
Class U.S. Mail to Charles R. Rhoades IV, 2490 Downing Avenue, San Jose, CA 95128, on this
11" day of July, 2019.
/s/ Andrew H. Reiss
Andrew H. Reiss
DEFAULT
A default is entered in this action against the Defendant named in the foregoing Motion
for failure to serve or file any paper as required by law.
DATED ON THIS 18th DAY OF JULY, 2019.
CRYSTAL K. KINZEL
AS CLERK OF THE CIRCUIT COURT
Sr
By:
As Deputy Clerk
Conformed copies to:
Andrew H. Reiss, Esq.
Charles R. Rhoades IV
13133-0002-3273117-110
Case Filing Date
May 30, 2019
Category
Other Circuit Civil
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Filing # 92418355 E-Filed 07/11/2019 03:57:29 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION VICTORIA RHOADES CARRARO, Plaintiff, v. CARL WESTMAN, as Trustee under the Revocable Trust Agreement of Charles R. Case No. 2019-CA-2160 Rhoades dated July 2, 1998; CARL WESTMAN, as the Personal Representative of the Estate of Charles R. Rhoades; CHARLES R. RHOADES IV; DAVID B. RHOADES; JAMES RHOADES; ROBERT RHOADES; and ANNINA JENKINS, Defendants. MOTION FOR CLERK’S DEFAULT Plaintiff, Victoria Rhoades Carraro, pursuant to Rule 1.500(a), Fla.R.Civ.P., moves for the entry of a default by the Clerk against the Defendant, Charles R. Rhoades IV, for failure to serve any paper on the undersigned or file any paper as required by law. Defendant was served on June 7, 2019 and required to respond by June 27, 2019. I certify that no copy of an answer or other response of the above-referenced Defendant has been received by Plaintiff’s attorney as of the time of filing this motion for default. Plaintiff has filed the appropriate non-military affidavit related to Charles R. Rhoades IV. CHEFFY PASSIDOMO, P.A. 821 Fifth Avenue South Naples, FL 34102 Telephone: (239) 261-9300 Facsimile: (239) 261-9782 FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/11/2019 03:57:29 PMAttorneys for Plaintiff /s/ Andrew H. Reiss Andrew H. Reiss Florida Bar No. 116955 Primary e-mail: ahreiss@napleslaw.com Secondary e-mail: raricci@napleslaw.com CERTIFICATE OF SERVICE Thereby certify that a true and correct copy of the foregoing has been furnished by First Class U.S. Mail to Charles R. Rhoades IV, 2490 Downing Avenue, San Jose, CA 95128, on this 11" day of July, 2019. /s/ Andrew H. Reiss Andrew H. Reiss DEFAULT A default is entered in this action against the Defendant named in the foregoing Motion for failure to serve or file any paper as required by law. DATED ON THIS 18th DAY OF JULY, 2019. CRYSTAL K. KINZEL AS CLERK OF THE CIRCUIT COURT Sr By: As Deputy Clerk Conformed copies to: Andrew H. Reiss, Esq. Charles R. Rhoades IV 13133-0002-3273117-110