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    Motion Default by Tom To Quiet

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    BISHOP STODDARD
    The plaintiffs, Thomas and Bernadette D'Alessandro, filed a motion for default against the defendant National City Bank. The plaintiffs had filed a quiet title action against National City Bank and others in January 2013. National City Bank was served in April 2013 but failed to respond to the complaint within 20 days as required. The plaintiffs are now requesting that the court enter a default against National City Bank for failing to respond and set a hearing to decide the motion.

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    Motion Default by Tom To Quiet

    Uploaded by

    BISHOP STODDARD
    28 views3 pages
    The plaintiffs, Thomas and Bernadette D'Alessandro, filed a motion for default against the defendant National City Bank. The plaintiffs had filed a quiet title action against National City Bank and others in January 2013. National City Bank was served in April 2013 but failed to respond to the complaint within 20 days as required. The plaintiffs are now requesting that the court enter a default against National City Bank for failing to respond and set a hearing to decide the motion.

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    MOTION DEFAULT BY TOM TO QUIET

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    The plaintiffs, Thomas and Bernadette D'Alessandro, filed a motion for default against the defendant National City Bank. The plaintiffs had filed a quiet title action against National City Bank and others in January 2013. National City Bank was served in April 2013 but failed to respond to the complaint within 20 days as required. The plaintiffs are now requesting that the court enter a default against National City Bank for failing to respond and set a hearing to decide the motion.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    28 views3 pages

    Motion Default by Tom To Quiet

    Uploaded by

    BISHOP STODDARD
    The plaintiffs, Thomas and Bernadette D'Alessandro, filed a motion for default against the defendant National City Bank. The plaintiffs had filed a quiet title action against National City Bank and others in January 2013. National City Bank was served in April 2013 but failed to respond to the complaint within 20 days as required. The plaintiffs are now requesting that the court enter a default against National City Bank for failing to respond and set a hearing to decide the motion.

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    You are on page 1of 3

    IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

    IN AND FOR PALM BEACH COUNTY, FLORIDA


    CIVIL DIVISION

    CASE NO.: 502013CA000865

    THOMAS C. D'ALESSANDRO, INDIVIDUALLY


    BERNADETTE H. D'ALESSANDRO, INDIVIDUALLY

    Plaintiffs,

    v.

    PY
    LEHMAN BROTHERS BANK, FSB;, NATIONAL
    CITY BANK, et al..

    CO
    Defendants.

    D
    PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT AGAINST DEFENDANT,
    NATIONAL CITY BANK FOR FAILING TO RESPOND TO PLAINTIFF’S
    IE
    COMPLAINT
    IF
    COME NOW, the Plaintiff, THOMAS C. D’ALESSANDRO AND BERNADETTE H.
    RT

    D’ALESSANDRO, Pro Se, Individually, pursuant to Fla. R. Civ. P. § 1.500(a) and hereby file

    their Motion for Default against Defendant, NATIONAL CITY BANK, in this quiet title action,
    CE

    and hereby states as grounds the following:

    1. On January 16, 2013, Plaintiff, THOMAS C. D’ALESSANDRO AND BERNADETTE


    A

    H. D’ALESSANDRO, Pro Se, Individually, filed a Verified Complaint in quiet title


    T

    against Defendants, including, but not excluded to: NATIONAL CITY BANK.
    O

    2. Defendant, NATIONAL CITY BANK, to date, has not responded in a timely fashion
    N

    under Fla. R. Civ. P. § 1.140(a), which provides that a defending party to a Complaint

    must respond within twenty (20) days’ time to said Complaint. See Id.

    3. Defendant, NATIONAL CITY BANK, was served a copy of Plaintiffs’ Complaint on or

    about April 5,2013.

    Page 1 of 5
    THOMAS C. D’ALESSANDRO, et al v. LEHMAN BROTHERS BANK, FSB, et al.
    Case No.: 502013CA000865
    4. Per Fla. R. Civ. P. § 1.500(a), if there has been no paper or pleading served in response

    by a defending party to a Complaint, then default is to be entered by the Clerk of Court

    and can be entered accordingly against such party. See Id.

    5. Per Fla. R. Civ. P. § 1.500(b), if there has been no paper or pleading served in response

    by a defending party to a Complaint, then default is to be entered by the Court and can be

    done by motion. See Id.

    WHEREFORE, Plaintiff now request and move that a Default be entered by the

    PY
    Clerk as to Defendant, NATIONAL CITY BANK, as named herein, since Defendant

    CO
    NATIONAL CITY BANK, has failed to respond to Plaintiffs’ Complaint, and that a hearing

    should now be immediately called by this Honorable Court to decide on Plaintiffs’ Motion for

    D
    Default by the Court in this matter. Upon such hearing, Plaintiffs hereby requests and moves that
    IE
    its Motion for Default be granted by the Court against Defendant NATIONAL CITY BANK, as
    IF
    named herein.
    RT

    Respectfully Submitted,
    CE

    THOMAS C.TT^ESSANDRO; Pro Se


    A

    Defendant
    19291 West Indies Lane
    T

    Tequesta, Florida 33469


    O
    N

    BERNADETTE H. D’ALESSANDRO; Pro Se


    Defendant
    19291 West Indies Lane
    Tequesta, Florida 33469

    Page 2 of 5
    THOMAS C. D’ALESSANDRO, et al v. LEHMAN BROTHERS BANK, FSB, et al.
    Case No.: 502013CA000865
    CERTIFICATE OF SERVICE

    I HEREBY CERTIFY that a true and correct copy of the foregoing was served by US

    Mail and/or e-mail upon the following party(ies): NATIONAL CITY BANK, 6750 Miller Road

    Brecksville, OH 44141, on this *3 day of June, 2013.

    THOMAS CSlTA'LESSANDRO; Pro Se

    PY
    Defendant
    19291 West Indies Lane
    Tequesta, Florida 33469

    CO
    D
    IE
    IF
    BERNADETTE H. D’ALESSANDRO; Pro Se
    RT

    Defendant
    19291 West Indies Lane
    Tequesta, Florida 33469
    CE
    A
    T
    O
    N

    Page 3 of 5
    THOMAS C. D’ALESSANDRO, et al y. LEHMAN BROTHERS BANK, FSB, et al.
    Case No.: 502013CA000865

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