On December 06, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Granada Insurance Company,
and
Morancy, Yves,
Rr Treasure Coast Llc,
St Louis, Daniel,
St. Louis, Samuel Derlin,
for Circuit Civil
in the District Court of St. Lucie County.
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Filing # 101544107 E-Filed 01/13/2020 01:07:07 PM
IN THE CIRCUIT COURT OF THE
NINETEENTH JUDICIAL CIRCUIT, IN
AND FOR’ ST. LUCIE COUNTY,
FLORIDA
CIVIL DIVISION
GRANADA INSURANCE COMPANY,
Plaintiff,
CASE NO. 2019-CA-002350
vs.
RR TREASURE COAST, LLC, YVES
MORANCY, SAMUEL DERLIN ST. LOUIS,
AND DANIEL ST. LOUIS,
Defendants.
/
PLAINTIFF’S MOTION FOR ENTRY OF CLERK’S DEFAULT AGAINST
DEFENDANT YVES MORANCY
Plaintiff, Granada Insurance Company ("Granada"), pursuant to Fla. R. Civ. P. 1.500(a),
moves for entry of a default by the Clerk of Court against Defendant, Yves Morancy
(“Morancy”), and states as follows:
1. Granada filed its Complaint for Declaratory Relief on December 6, 2019.
2. Morancy was then served with the Complaint on December 20, 2019.
3. To date, Morancy has failed to appear, file or serve any paper upon Granada in
response to this action and the time in which to do so has since expired.
4. According to the SCRA - Servicemembers Civil Relief Act the defendant is not in
active military service.
5. For the foregoing reasons, Granada is entitled to a Clerk’s default against
Morancy. A proposed default is attached as Exhibit "A".
1023239\304945591.v1WHEREFORE Plaintiff, Granada Insurance Company, moves for the entry of a default
by the Clerk of this Court against the Defendant, Yves Morancy, for failure to serve any paper on
the undersigned or file any paper as required by law.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 13, 2020, the foregoing document is being served
via the Florida Courts e-Filing Portal which sends an automatic notification to all counsel of
record and a copy is being mailed to the defendant Yves Morancy at 207 Southland Drive,
Apartment 5, Fort Pierce, Florida 34982.
HINSHAW & CULBERTSON LLP
/s/Ronald L. Kammer
RONALD L. KAMMER
Florida Bar No. 360589
rkammer@hinshawlaw.com
LEVI GLICK
Florida Bar No. 1010718
Iglick@hinshawlaw.com
2525 Ponce de Leon Boulevard, Fourth Floor
Coral Gables, FL 33134
Telephone: 305-358-7747
Facsimile: 305-577-1063
Attorneys for Granada Insurance Company
1023239\304945591.v1EXHIBIT “A”IN THE CIRCUIT COURT OF THE
NINETEENTH JUDICIAL CIRCUIT, IN
AND FOR ST. LUCIE COUNTY,
FLORIDA
CIVIL DIVISION
GRANADA INSURANCE COMPANY,
Plaintiff,
CASE NO. 2019-CA-002350
vs.
RR TREASURE COAST, LLC, YVES
MORANCY, SAMUEL DERLIN ST. LOUIS,
AND DANIEL ST. LOUIS,
Defendants.
/
CLERKS DEFAULT AGAINST YVES MORANCY
It appearing that the Defendant, Yves Morancy, is in default for failure to answer or
otherwise plead to the complaint filed herein within the time required by law. Default is hereby
entered against the defendant, Yves Morancy, as a matter of course on
Clerk of the Circuit Court
By:
As Deputy Clerk
1023239\304945527.v1
Document Filed Date
January 13, 2020
Case Filing Date
December 06, 2019
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Filing # 101544107 E-Filed 01/13/2020 01:07:07 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, IN AND FOR’ ST. LUCIE COUNTY, FLORIDA CIVIL DIVISION GRANADA INSURANCE COMPANY, Plaintiff, CASE NO. 2019-CA-002350 vs. RR TREASURE COAST, LLC, YVES MORANCY, SAMUEL DERLIN ST. LOUIS, AND DANIEL ST. LOUIS, Defendants. / PLAINTIFF’S MOTION FOR ENTRY OF CLERK’S DEFAULT AGAINST DEFENDANT YVES MORANCY Plaintiff, Granada Insurance Company ("Granada"), pursuant to Fla. R. Civ. P. 1.500(a), moves for entry of a default by the Clerk of Court against Defendant, Yves Morancy (“Morancy”), and states as follows: 1. Granada filed its Complaint for Declaratory Relief on December 6, 2019. 2. Morancy was then served with the Complaint on December 20, 2019. 3. To date, Morancy has failed to appear, file or serve any paper upon Granada in response to this action and the time in which to do so has since expired. 4. According to the SCRA - Servicemembers Civil Relief Act the defendant is not in active military service. 5. For the foregoing reasons, Granada is entitled to a Clerk’s default against Morancy. A proposed default is attached as Exhibit "A". 1023239\304945591.v1WHEREFORE Plaintiff, Granada Insurance Company, moves for the entry of a default by the Clerk of this Court against the Defendant, Yves Morancy, for failure to serve any paper on the undersigned or file any paper as required by law. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 13, 2020, the foregoing document is being served via the Florida Courts e-Filing Portal which sends an automatic notification to all counsel of record and a copy is being mailed to the defendant Yves Morancy at 207 Southland Drive, Apartment 5, Fort Pierce, Florida 34982. HINSHAW & CULBERTSON LLP /s/Ronald L. Kammer RONALD L. KAMMER Florida Bar No. 360589 rkammer@hinshawlaw.com LEVI GLICK Florida Bar No. 1010718 Iglick@hinshawlaw.com 2525 Ponce de Leon Boulevard, Fourth Floor Coral Gables, FL 33134 Telephone: 305-358-7747 Facsimile: 305-577-1063 Attorneys for Granada Insurance Company 1023239\304945591.v1EXHIBIT “A”IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, IN AND FOR ST. LUCIE COUNTY, FLORIDA CIVIL DIVISION GRANADA INSURANCE COMPANY, Plaintiff, CASE NO. 2019-CA-002350 vs. RR TREASURE COAST, LLC, YVES MORANCY, SAMUEL DERLIN ST. LOUIS, AND DANIEL ST. LOUIS, Defendants. / CLERKS DEFAULT AGAINST YVES MORANCY It appearing that the Defendant, Yves Morancy, is in default for failure to answer or otherwise plead to the complaint filed herein within the time required by law. Default is hereby entered against the defendant, Yves Morancy, as a matter of course on Clerk of the Circuit Court By: As Deputy Clerk 1023239\304945527.v1