Motion,Ex Parte: CAREER FINANCIAL CORP. vs LABELLE LAND PARTNERSHIP

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                                Filing # 149871486 E-Filed 05/18/2022 05:51:03 PM

 Filing # 149849709 E-Filed 05/18/2022 03:09:04 PM


                       IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
                                  IN AND FOR GLADES COUNTY, FLORIDA

          CAREER FINANCIAL CORP.,                  )                  Case No. 2022 CA51
                                                   )
          Plaintiff,                               )
                                                   )
          -vs-                                     )
                                                   )
          LABELLE LAND PARTNERSHIP,                )
          DAVID B. KAGAN D.M.D. PROFIT             )
          SHARING TRUST, and                       )
          DAVID B. KAGAN, individually and         )
         as Trustee of the DAVID B. KAGAN )
         0.M.D. PROFIT SHARING TRUST, )
                                                   )
          Defendants.                              )
                                                   )
                                              MOTION
                                                 FOR DEFAULT
                   Plaintiff, CAREER    FINANCIAL      CORP.,    pursuant to Fla. R. Civ. P. 1.500(a),

         moves for entry of a Default by the Clerk against Defendants, DAVID B. KAGAN D.M.D.

         PROFIT SHARING TRUST, and DAVID B. KAGAN, individually and as Trustee of the

         DAVID B. KAGAN D.M.D. PROFIT SHARING TRUST, for failure to serve any document

         on the undersigned or file any document in this action as required by law. As grounds

         for this motion, Plaintiff states:

                   1     Defendants, DAVID B. KAGAN             D.M.D. PROFIT SHARING      TRUST, and

         DAVID B. KAGAN, individually and as Trustee of the DAVID B. KAGAN D.M.D. PROFIT

         SHARING TRUST, were each served with a Summons and a copy of the Complaint on

         April 21, 2022, and their written defenses to the Complaint were due served and filed on

         or before May 11, 2002. See Returns of Service, Doc ## 24, 25.



         Farscirarirailly Filed Glades Cased LUO       CANA OSA 3027050304
                                                                        FM
Case No. 2022 CA 51

       2.     Defendants, DAVID B. KAGAN                         D.M.D. PROFIT SHARING      TRUST, and

DAVID B. KAGAN, individually and as Trustee of the DAVID B. KAGAN D.M.D. PROFIT

SHARING TRUST, have each failed to serve or file any document in this action as
required by law, thereby entitling Plaintiff to entry of a Default against them by the Clerk.

See Fla. R. Civ. P. 1.500(a).

       DATED ON May 18, 2022
                                                                 ALBERTO A. ee ESQ.
                                                                 Fla. Bar No. 0378453
                                                                 Attorney for Plaintiff
                                                                 3129 Carriage Circle
                                                                 Naples, Florida 34105-2700
                                                                 Telephone: 239-248-9150
                                                                 Email: albertoamacia@gmail.com

                                               DEFAULT
       A DEFAULT      is hereby entered                 in this action against Defendants,     DAVID B.

KAGAN D.M.D. PROFIT SHARING TRUST, and DAVID B. KAGAN, individually and as

Trustee of the DAVID B. KAGAN D.M.D. PROFIT SHARING TRUST, for failure to serve

or file any document as required by law.

       DATED this {8 day of Moy __ 2022.
                                                                       TAMI PEARCE SIMMONS
                                                                       Clerk of the Circuit Court
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