Exhibit A 

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 1 of 18
MIAMI-DADE COUNTY CLERK OF THE 

COURTS

HARVEY RUVIN

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ARNALDO LIMANSKY ET AL VS LABORATORY CORPORATION OF AMERICA

Local Case Number: 2020-015360-CA-01 Filing Date: 07/21/2020

State Case Number: 132020CA015360000001 Judicial Section: CA04

Consolidated Case No.: N/A Case Type: Medical Malpractice

Case Status: OPEN

 Parties Total Of Parties: 3 +

 Hearing Details Total Of Hearings: 0 +

 Dockets Total Of Dockets: 10 −

Number Date Book/Page Docket Entry

Event 

Type Comments



9 08/14/2020 Notice of Filing: Event RETURN OF SERVICE WITHOUT SUMMON

07/29/2020 20 Day Summons 

Issued

Service



8 07/29/2020 ESummons 20 

Day Issued

Event Parties: Laboratory Corporation of America

7 07/29/2020 Receipt: Event RECEIPT#:2610127 AMT PAID:$10.00 NAME:SOROGON, LEILANI 

9155 S. DADELAND BOULEVARD SUITE 1216 MIAMI FL 33156 

COMMENT: ALLOCATION CODE QUANTITY UNIT AMOUNT 

3139-SUMMONS ISSUE FEE 1 $10.00 $10.00 TENDER 

TYPE:E-FILING ACH TENDER AMT:



6 07/28/2020 (M) 20 Day (C) 

Summons (Sub)

Received

Event

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Number Date Book/Page Docket Entry

Event 

Type Comments

5 07/22/2020 Receipt: Event RECEIPT#:2630194 AMT PAID:$401.00 NAME:SOROGON, 

LEILANI 9155 S. DADELAND BOULEVARD SUITE 1216 MIAMI FL 

33156 COMMENT: ALLOCATION CODE QUANTITY UNIT 

AMOUNT 3100-CIRCUIT FILING FEE 1 $401.00 $401.00 TENDER 

TYPE:E-FILING ACH TENDER AM



4 07/21/2020 Request for 

Production

Event



3 07/21/2020 Notice of 

Interrogatory

Event



2 07/21/2020 Complaint Event



1 07/21/2020 Civil Cover Sheet 

- Claim Amount

Event

General

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HARVEY RUVIN

Miami-Dade County 

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©2020 Clerk of the Courts. All rights reserved.

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Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 3 of 18
FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions

for completion.)

I. CASE STYLE

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: _________________

Judge: ____________________

Arnaldo Limansky, Maria Luisa Limansky

Plaintiff

 vs.

Laboratory Corporation of America

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim rounded to the nearest dollar $750,000

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main

category and subcategory lines.

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence – other

 ☐ Business governance

 ☐ Business torts

 ☐ Environmental/Toxic tort

 ☐ Third party indemnification

 ☐ Construction defect

 ☐ Mass tort

 ☐ Negligent security

 ☐ Nursing home negligence

 ☐ Premises liability – commercial

 ☐ Premises liability – residential

☐ Products liability

☐ Real Property/Mortgage foreclosure

 ☐ Commercial foreclosure

 ☐ Homestead residential foreclosure

 ☐ Non-homestead residential foreclosure

 ☐ Other real property actions

 ☒ Professional malpractice

 ☐ Malpractice – business

 ☒ Malpractice – medical

 ☐ Malpractice – other professional

 ☐ Other

 ☐ Antitrust/Trade Regulation

 ☐ Business Transaction

 ☐ Circuit Civil - Not Applicable

 ☐ Constitutional challenge-statute or ordinance

 ☐ Constitutional challenge-proposed amendment

 ☐ Corporate Trusts

 ☐ Discrimination-employment or other

 ☐ Insurance claims

 ☐ Intellectual property

 ☐ Libel/Slander

 ☐ Shareholder derivative action

 ☐ Securities litigation

 ☐ Trade secrets

 ☐ Trust litigation

 ☐ County Civil

 ☐ Small Claims up to $8,000 

 ☐ Civil 

 ☐ Replevins

 ☐ Evictions

 ☐ Other civil (non-monetary)

 

Filing # 110565105 E-Filed 07/21/2020 02:48:39 PM Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 4 of 18
COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☐ Non-monetary declaratory or injunctive relief;

☐ Punitive

V. NUMBER OF CAUSES OF ACTION: 

(Specify)

1

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ Yes

☒ No

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ No

☐ Yes – If “yes” list all related cases by name, case number and court:

N/A

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

 ☒ Yes

 ☐ No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature: s/ Leilani Sorogon King 

Attorney or party

FL Bar No.: 112187 

(Bar number, if attorney)

 Leilani Sorogon King

 (Type or print name)

 Date: 07/21/2020

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 5 of 18
1

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

IN THE CIRCUIT COURT OF THE 11th

JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION

CASE NO.:

ARNALDO LIMANSKY and

MARIA LUISA LIMANSKY, his wife,

Plaintiffs,

v.

LABORATORY CORPORATION OF AMERICA,

Defendant.

 /

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA LIMANSKY, his wife, by and 

through undersigned counsel, sue Defendant, LABORATORY CORPORATION OF AMERICA,

and allege:

1. This is an action for damages in excess of Thirty Thousand ($30,000.00) Dollars.

2. At all times material herein Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA 

LIMANSKY, his wife, were and are residents of Miami-Dade County, Florida. 

3. At all times material herein Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA 

LIMANSKY, were and are lawful spouses.

4. At all times material herein, Defendant, LABORATORY CORPORATION OF 

AMERICA, was and is a foreign corporation licensed to do business in the State of Florida, and 

owned, controlled, maintained and operated the LABORATORY CORPORATION OF AMERICA

clinic located at 400 Arthur Godfrey Road, Suite #510, Miami Florida 33140, Miami-Dade County, 

Florida.

Filing # 110565105 E-Filed 07/21/2020 02:48:39 PM Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 6 of 18
2

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

5. At all times material herein Phlebotomist, CHELEY JEAN-BAPTISTE, was and is a 

phlebotomist licensed to practice in the State of Florida.

6. At all times material herein Phlebotomist, CHELEY JEAN-BAPTISTE, was a 

resident of Miami-Dade County, Florida and her last known addressis 2958 NW 132nd Street, Apt. #

422, Miami, FL 33054.

7. At all times material herein, Phlebotomist, CHELEY JEAN-BAPTISTE, was and is 

an employee, agent and/or apparent agent of Defendant, LABORATORY CORPORATION OF 

AMERICA.

8. On April 1, 2019, Plaintiff, ARNALDO LIMANSKY, underwent a routine blood 

draw procedure at the Defendant’s clinic. Phlebotomist, CHELEY JEAN-BAPTISTE, conducted the 

subject routine blood draw procedure for and on behalf of Defendant, LABORATORY

CORPORATION OF AMERICA.

9. As a result of the blood draw procedure, Plaintiff, ARNALDO LIMANSKY, suffered 

an arterial injury requiring surgical repair.

COUNT I – NEGLIGENCE CLAIM VS. LABORATORY CORPORATION OF

AMERICA

10. Plaintiffs restate and reallege paragraphs 1-9 and further allege as follows:

11. At all times material herein, Phlebotomist, CHELEY JEAN-BAPTISTE, was acting 

within the course of her agency and/or employment relationship with Defendant, LABORATORY

CORPORATION OF AMERICA during the time she provided care and treatment to ARNALDO 

LIMANSKY. As such, Defendant, LABORATORY CORPORATION OF AMERICA is 

vicariously liable for her negligence described herein.

12. At all times material herein Defendant, LABORATORY CORPORATION OF

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 7 of 18
3

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

AMERICA, acknowledged that its selected employee/agent, Phlebotomist, CHELEY JEANBAPTISTE, would act for it by working at LABORATORY CORPORATION OF AMERICA and 

providing medical care and services to patients like ARNALDO LIMANSKY.

13. At all times material herein, Phlebotomist, CHELEY JEAN-BAPTISTE, undertook a 

duty to render medical care and treatment to Plaintiff, ARNALDO LIMANSKY, in a skillful and 

careful manner and in accordance with the prevailing standards of medical care and treatment

rendered in such cases by phlebotomists in Miami-Dade County, Florida, or similar medical

communities.

14. At all times material herein Defendant, LABORATORY CORPORATION OF 

AMERICA, by and through Phlebotomist, CHELEY JEAN-BAPTISTE, breached the duty owed to 

Plaintiff, ARNALDO LIMANSKY, by failing to care for and treat him as she should have done in 

accordance with the prevailing professional standards of medical care. Specifically, Defendant was 

negligent in the following ways: 

a. Negligently performing the blood draw procedure; and/or

b. Negligently failing to supervise and/or requesting supervision of the blood 

draw procedure; and/or

c. Negligently permitting an unqualified phlebotomist to perform the blood 

draw procedure; and/or

d. Negligently using an inappropriate methods and techniques; and/or 

e. Negligently using an inappropriately sized needle; and/or

f. Negligently injuring Plaintiff’s artery(ies).

15. Moreover, the blood draw procedure and associated materials and techniques were in 

the complete control of the Defendant, LABORATORY CORPORATION OF AMERICA, by and 

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 8 of 18
4

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

through Phlebotomist, CHELEY JEAN-BAPTISTE, and the injury sustained would not normally occur 

without negligence.

16. As a direct and proximate result of the negligence of Defendant, LABORATORY

CORPORATION OF AMERICA, by and through Phlebotomist, CHELEY JEAN-BAPTISTE,

Plaintiff, ARNALDO LIMANSKY, was caused to suffer significant bodily injury and resulting pain 

and suffering, impairment, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, loss of 

earnings, loss of ability to earn money and aggravation of a previously existing condition. The 

losses are either permanent or continuing and Plaintiff, ARNALDO LIMANSKY, will suffer these

losses in the future.

17. As a further direct and proximate result of the negligence of Defendant, 

LABORATORY CORPORATION OF AMERICA, by and through Phlebotomist, CHELEY JEANBAPTISTE, Plaintiff, MARIA LUISA LIMANSKY, was caused to suffer a permanent loss of her 

husband’s support, services and consortium.

WHEREFORE, Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA LIMANSKY, sue 

Defendant, LABORATORY CORPORATION OF AMERICA for compensatory damages and costs, 

and demand trial by jury of all issues triable as of right by a jury. 

DATED: July 21, 2020.

GOLD & GOLD, P.A.

Attorneys for Plaintiff(s)

Dadeland Centre I, Suite 1216

9155 S. Dadeland Blvd.

Miami, FL 33156

Telephone: (305) 567-2525

Facsimile: (305) 567-2575

Email Service: pleadings@goldlawpa.com

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 9 of 18
5

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

By: /s/

Philip A. Gold, Esquire

Florida Bar No.: 0032550

Leilani S. King, Esquire

Florida Bar No.: 112187

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 10 of 18
IN THE CIRCUIT COURT OF THE 11th 

JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA

 CASE NO.: 

ARNALDO LIMANSKY and

MARIA LUISA LIMANSKY, his wife, 

Plaintiffs, 

v. 

LABORATORY CORPORATION OF AMERICA, 

Defendant. 

 /

INTERROGATORIES TO DEFENDANT, LABORATORY CORPORATION OF 

AMERICA

 Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA LIMANSKY, pursuant to 

Rule 1.350, Florida Rules of Civil Procedure, propounds the following Interrogatories to 

Defendant, LABORATORY CORPORATION OF AMERICA, to be answered under oath, in 

writing, within the time prescribed by law.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing has been 

electronically filed with the Clerk of Courts and has been sent for service upon the Defendant. 

DATED: July 21, 2020 

GOLD & GOLD, P.A.

Attorneys for Plaintiff

Dadeland Centre I, Suite 1216 

9155 S. Dadeland Boulevard 

Miami, FL 33156

Telephone: (305) 567-2525

Facsimile: (305) 567-2575 

Email Service: pleadings@goldlawpa.com

By: 

 Philip A. Gold, Esquire

Florida Bar No.: 32550 

Leilani Sorogon, Esquire

Florida Bar No.: 112187 

Filing # 110565105 E-Filed 07/21/2020 02:48:39 PM Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 11 of 18
1

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

IN THE CIRCUIT COURT OF THE 11th

JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION

CASE NO.:

ARNALDO LIMANSKY and

MARIA LUISA LIMANSKY, his wife,

Plaintiffs,

v.

LABORATORY CORPORATION OF AMERICA,

Defendant.

 /

PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT,

LABORATORY CORPORATION OF AMERICA

Plaintiffs, ARNALDO LIMANSKY and MARIA LUISA LIMANSKY, by and through 

undersigned counsel and in accordance with Florida Rule of Civil Procedure 1.280, requests

Defendants to produce at the offices of Plaintiffs’ counsel within the time prescribed by law, the 

following documents:

1) A color laser copy of each medical chart, narrative, record, report or other 

document of any nature whatsoever pertaining to Plaintiff, ARNALDO LIMANSKY.

2) A fully itemized billing statement(s) showing charges for all services rendered to 

Plaintiff, ARNALDO LIMANSKY.

3) Any and all statements previously made by ARNALDO LIMANSKY, including 

any written statements signed or otherwise adopted or approved by ARNALDO LIMANSKY

and any stenographic, mechanical, electrical or other such recording, or any transcription thereof.

4) Any and all photographs of ARNALDO LIMANSKY taken or directed to be 

taken by you, your employees or agents.

5) A list containing the full name and current address of every physician, RN, LPN, 

Medical Assistant, Medical Technician, phlebotomist, or other employee or agent of the

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2

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

Defendant who provided any care and/or treatment to Plaintiff, ARNALDO LIMANSKY at any 

time.

6) A copy of the most current resume or curriculum vitae of any expert you intend to 

call to testify at trial on your behalf.

7) A copy of all current licenses held by any employee or agent named above in your 

response to number 5.

8) All written reports obtained from any expert whom you intend to call to testify at 

trial on your behalf.

9) Copies of any and all surveillance movies, videotapes, photographs or films 

reflecting ARNALDO LIMANSKY.

10) All records or documents of any nature whatsoever submitted by you or on your 

behalf to any physician or medical provider in connection with or relevant to ARNALDO 

LIMANSKY.

11) Any and all letters, notes, memoranda or documentation of any nature whatsoever 

received from any physician or person pertaining to the care and treatment of ARNALDO 

LIMANSKY.

12) Copies of all x-rays or other diagnostic films pertaining to ARNALDO 

LIMANSKY.

13) All employment contracts, agreements, or documentation of any nature 

whatsoever between Defendants, LABORATORY CORPORATION OF AMERICA and 

CHELEY JEAN-BAPTISTE and/or any medical group employer.

14) Any and all applicable policies of liability insurance that would apply to the 

allegations made in this lawsuit, whether insuring LABORATORY CORPORATION OF 

AMERICA and/or CHELEY JEAN-BAPTISTE.

15) Any and all documents reflecting CHELEY JEAN-BAPTISTE professional 

certifications, resume and/or curriculum vitae.

15) Any and all documents reflecting CHELEY JEAN-BAPTISTE application and 

employment with LABORATORY CORPORATION OF AMERICA.

16) A copy of the LABORATORY CORPORATION OF AMERICA patient

schedule for 4/1/2019, with all patient names and other identifying and HIPAA information

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 13 of 18
3

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

redacted (aside from Arnaldo Limansky’s). Please include all information concerning the date 

and time of the appointment, medical provider seen, and the reason for the patient’s visit. 

17) Copies of any and all documents that were associated with, attached to and/or

submitted with ARNALDO LIMANSKY’s blood taken on 4/1/2019. 

18) Any and all documents, writings, contracts, or agreements between Laboratory 

Corporation of America and the subject technician who provided services to Arnaldo Limansky

at the time that Arnaldo Limansky received treatment at Laboratory Corporation of America with 

respect to the incident identified in the notice of intent, including but not limited to the subject 

blood drawing procedure.

19) Any and all writings, documents, guidelines, booklets, pamphlets, and manuals 

indicating Laboratory Corporation of America’s policy, protocol, regulations, and procedures, 

with respect to the type of treatment received by Arnaldo Limansky at Laboratory Corporation of 

America, including but not limited to the subject blood drawing procedure.

20) Any and all Tables of Contents of Laboratory Corporation of America policy, 

protocol, regulations, and procedures, with respect to the type of treatment received by Arnaldo 

Limansky at Laboratory Corporation of America, including but not limited to the subject blood 

drawing procedure.

21) Any and all rules, regulations, procedures, policies and protocol with respect to 

the subject Laboratory Corporation of America technician who provided treatment to Arnaldo 

Limansky at Laboratory Corporation of America, including but not limited to the subject blood 

drawing procedure.

22) Any and all rules, regulations, policies, procedures with respect to any nonemployee technician who provided treatment to Arnaldo Limansky at Laboratory Corporation of 

America, including but not limited to the subject blood drawing procedure.

23) Copies of any and all medical records in your possession regarding any care and 

treatment rendered by your employees, agents or apparent agents, or technicians to Arnaldo 

Limansky as noted in the Notice of Intent. Inclusive if applicable to any copies of x-rays, 

laboratory reports, laboratory notes, pathology notes, correspondence in reference to our client, 

pictures, videos, and/or incident reports for any procedures performed on our client at Laboratory 

Corporation of America.

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 14 of 18
4

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing has been 

electronically filed with the Clerk of Courts and has been sent for service upon the Defendant. 

DATED: July 21, 2020.

GOLD & GOLD, P.A.

Attorneys for Plaintiff

Dadeland Centre I, Suite 1216

9155 S. Dadeland Boulevard

Miami, FL 33156

Telephone: (305) 567-2525

Facsimile: (305) 567-2575

Email Service: pleadings@goldlawpa.com;

lking@goldlawpa.com; aarguello@goldlawpa.com

By: 

 Philip A. Gold, Esquire

Florida Bar No.: 32550

Leilani S. King, Esquire

Florida Bar No.: 112187

Case 1:20-cv-23460-DPG Document 1-2 Entered on FLSD Docket 08/19/2020 Page 15 of 18
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1 

GOLD & GOLD, P.A.

DADELAND CENTRE I, SUITE 1216, 9155 S. DADELAND BOULEVARD, MIAMI, FLORIDA 33156

IN THE CIRCUIT COURT OF THE 11th 

JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA

 

CASE NO.: 2020-015360-CA-01 

ARNALDO LIMANSKY and

MARIA LUISA LIMANSKY, his wife,

Plaintiffs,

v. 

LABORATORY CORPORATION OF AMERICA,

Defendant. 

 /

 

CIVIL ACTION SUMMONS

STATE OF FLORIDA:

To Each Sheriff of Said State:

YOU ARE HEREBY COMMANDED to serve this Summons with a copy of the Complaint, 

Interrogatories and Request for Production in this action upon the Defendant, LABORATORY 

CORPORATION OF AMERICA, by serving its Registered Agent:

CORPORATION SERVICE COMPANY

1201 HAYS STREET

TALLAHASSEE, FL 32301-2525 

Each Defendant is required to serve written defenses to the Complaint or Petition on Plaintiffs’ 

attorney, to-wit: Leilani S. King, Esquire of Gold & Gold, P.A., 9155 S. DADELAND BLVD, 

SUITE #1216, MIAMI, FL 33156; 305-567-2525; Email: pleadings@goldlawpa.com, within 

twenty (20) days after service of this Summons on that Defendant, exclusive of the day of 

service, and to file the original of the defenses with the Clerk of this Court either before service 

on Plaintiff's attorney or immediately thereafter. If a Defendant fails to do so, a default will be 

entered against that Defendant for the relief demanded in the Complaint or Petition.

 

DATED this _____day of ___________, 2020. 

 

 As Clerk of Said Court

 By:_________________________

 As Deputy Clerk

 (Court Seal)

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