UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM

Chapter 7

CHANCE & ANTHEM, LLC,

Debtor.

 /

ROBERT C. FURR, not individually but ADV. NO. 19-01302-MAM

as Chapter 7 Trustee of the estate of the

Debtor, Chance & Anthem, LLC,

Plaintiff,

v.

OCEAN REEF CLUB, INC.

Defendant.

 /

PLAINTIFF’S VERIFIED MOTION FOR CLERK’S ENTRY OF 

DEFAULT AGAINST DEFENDANT OCEAN REEF CLUB, INC. 

Plaintiff, Robert C. Furr (“Plaintiff” or the “Trustee”), as Chapter 7 Trustee for the

Debtor, Chance and Anthem, LLC (the “Debtor”) (collectively, the “Debtors”), by and through 

undersigned counsel, pursuant to Fed. R. Civ. P. 55(a), as made applicable to this proceeding by 

Fed. R. Bankr. P. 7055, and Local Rule 7055-1, hereby files this Verified Motion for Clerk’s

Entry of a Default against Defendant Ocean Reef Club, Inc. (the “Defendant”), and in support 

thereof states:

1. On August 06, 2019, Plaintiff commenced this adversary proceeding against 

the Defendant [ECF No. 01].

2. On August 09, 2019, Plaintiff served the Summons, Adversary Complaint, and 

Order Setting Filing and Disclosure Requirements for Pretrial and Trial upon the Defendant at

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the addresses indicated on the Certificate of Service, via Regular First Class U.S. Mail, Postage 

Fully Prepaid, pursuant to Fed. R. Bankr. P. 7004. [ECF No. 04].

3. Pursuant to Fed. R. Bankr. P. 7012, Defendant’s response or answer to the 

Trustee’s Complaint was due on or before September 06, 2019. As of the date of this Motion, 

the Defendant has not served or filed a response or answer to Plaintiff’s Complaint as required 

by law.

4. Court papers seeking an extension of time for Defendant to respond the Adversary 

Complaint have been filed in this adversary proceeding by Jeffrey Siskind. Mr. Siskind is 

neither purporting to act as counsel to Defendant, nor is he a party to this adversary proceeding. 

5. Based upon the foregoing, Plaintiff respectfully requests that the Clerk enter a 

default against Defendant for failing to file an answer or response to Plaintiff’s Complaint.

WHEREFORE, Plaintiff respectfully requests the Court grant the relief requested herein, 

and for such other and further relief as the Court deems just and proper.

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CERTIFICATE OF SERVICE

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

electronically served upon all parties in interest registered to receive electronic notice on this 

matter via the Court’s Case Management/Electronic Case Filing System (which is incorporated 

herein by reference) on September 9, 2019 and via U.S. Mail as reflected on the Service List 

below on September 10, 2019.

By:/s/ Jesus M. Suarez 

Jesus M. Suarez, Esq.

SERVICE LIST

Served Via U.S. Mail

OCEAN REEF CLUB, INC.

C/O ROBERT MANZO, CHAIRMAN

35 OCEAN REEF DRIVE, SUITE 200

KEY LARGO, FL 33037

OCEAN REEF CLUB, INC.

C/O ROBERT A. BOGDAN, SECRETARY AND REGISTERED AGENT 

35 OCEAN REEF DRIVE, STE 200 EO

KEY LARGO, FL 33037

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