Filing # 32728455 E-Filed 10/01/2015 02:10:27 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY FLORIDA
DIAMOND CLEAN LLC fik/a CASE NO.: 2015-CA-020250
‘NL TRADE INC.
Plaintifi(s),
vs
ESTHER KLEPACH, TRUSTEE FOR THE
ESTHER KLEPACH REVOCABLE TRUST
Defendant(s).
ee
MOTION FOR CLERK’S DEFAULT
Plaintiff, pursuant to Rule 1.500 (a) of the Florida Rules of Civil Procedure moves
for entry of default in the above styled case for failure of the Defendant, ESTHER.
KLEPACH, TRUSTEE FOR THE ESTHER KLEPACH REVOCABLE TRUST,
or serve a pleading or other paper within the time required by law. A copy of the Retum
of Service on Defendant is attached hereto as Exhibit “A”,
Dated this_/ day of October. 2015.
____/s/ Omar Saleh
OMAR M. SALEH, ESQ.
Florida Bar No. 91216
Synergy Law
5455 SW 8" §
omar@synergy|
Attorney for Defendant
ENTRY OF DEFAULT
It appearing that Defendant, E
THER KLEPACH, having been duly served
according to law, and said Defendant having failed to file or serve any paper herein,
Default is hereby entered against said Defendant.
Dated this day of nn 2015.
BY:
“Deputy Clerk
NOTE TO CLERK: In the event that any of the Defendants have timely filed any paper
in the above-styied case, or should their return of service not be filed, then please strike
the name of such Defendant from the above Motion,RETURN OF SERVICE
State of Florida County of Miami-Dade Circuit Court
Case Number 2018CA020250
Plaintif:
DIAMOND CLEAN LLC F/KIA NL TRADE INC.
vs
Defendant
ESTHER KLEPACH, TRUSTEE
For:
‘Omar Saleh
Omar Saleh, Esq,
1201 Brickell Avenue
Suite 230
Miami, FL 33131
Received by DLE Process Servers on the Sth day of September, 2015 at 11:11 am to be served on Esther
Kiepach,
J, Helmer Ramirez, do hereby affirm that on the 10th day of September, 2018 at 3:40 pm, I:
INDIVIDUALLY/PERSONALLY served by delivering a true copy of the Summons, Complaint and Exhibit A with
the date and hour of service endorsed thereon by me, to: Esther Klepach at the address of
meEBNNNIN, ad informed said person of the contents therein, in compliance with state statutes
Military Status: Based upon inguity of party served, Defendant is not in the military sacvice of the United States of
America,
‘Marital Status: Gased upon inquiry of party served, Defendant is marred.
| cortty that | am over the age of 18, have no interest in the above action, and am a Certified Process Server, in
‘900d standing, in the judicial circu in which the process was served.
Under penalties of perry, | daciare that | have read the following document and that the facts stated are true. F.S.
82.825, NOTARY NOT REQUIRED PURSUANT TO FS, 92.525
Pidcoss Server #1428
DLE Process Servers
247 8.W. 8 Street
#261
Miami, FL 33430
(788) 220-9705
‘Our Job Seriai Number: DLE-2015012023
opt 91022011 Duman Sees Pons Sanat an
Exuca’