UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

 

In re: Case No.: 18-15499-BKC-AJC 

WORLD GLOBAL FINANCING, INC., Chapter 7 

Debtor. 

 / 

 

ROSS. R. HARTOG, AS THE CHAPTER 7 

TRUSTEE, 

 

 Plaintiff, Adv. Pro. No.: 20-01163-AJC 

v. 

 

WILADYS CASTILLO, 

 

 Defendant. 

 / 

VERIFIED MOTION FOR CLERK’S DEFAULT 

Plaintiff, Ross R. Hartog, the chapter 7 trustee (the “Trustee” or “Plaintiff”) for the estate 

of World Global Financing, Inc., through undersigned counsel and pursuant to Rule 7055 of the 

Federal Rules of Bankruptcy Procedure and Local Rule 7055-1, moves for the entry of a default 

(the “Motion”) against defendant, Wiladys Castillo (the “Defendant” or “Castillo”), for failure to 

plead or otherwise defend against the Complaint [ECF No. 1]. In support of this motion (the 

“Motion”), the Plaintiff states: 

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 

1334(b). 

2. This is a core proceeding, which the Court is authorized to hear, determine, and 

enter final orders in accordance with 28 U.S.C. § 157(b)(1), (b)(2)(A), (H), and (O). 

Case 20-01163-AJC Doc 12 Filed 07/16/20 Page 1 of 3
3. Venue is proper pursuant to 28 U.S.C. § 1409, as the Debtor’s main bankruptcy 

case is pending in this District. 

4. On May 4, 2020, Plaintiff commenced this proceeding by filing the Complaint 

seeking, among other things, the avoidance and recovery of transfers made by the Debtor to the 

Defendant. 

5. On June 9, 2020, this Court issued an Alias Summons [ECF No. 7] (the “Alias 

Summons”) on the Defendant. 

6. On June 12, 2020, the Plaintiff served the Defendant with copies of the Alias 

Summons, Complaint and Order Setting Filing and Disclosure Requirements for Pretrial and 

Trial [ECF No. 3], by U.S. mail. See Certificate of Service [ECF No. 11]. 

7. To date, the Defendant has failed to timely file any responsive papers to the 

Complaint as required by the Alias Summons. A review of the Court’s CM/ECF System on July 

15, 2020 prior to filing this Motion confirms same. 

WHEREFORE, the Plaintiff requests the entry of a default against the Defendant, 

Wiladys Castillo, for failure to file or serve any response to the Complaint. 

Declaration - 28 U.S.C. § 1746 

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

July 16, 2020. 

 By: /s/ Alan R. Rosenberg 

Alan R. Rosenberg, Esq. 

Fla. Bar No. 92004 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of this motion was served on all 

counsel of record and interested parties registered to receive electronic noticing in this case via 

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the Court’s CM/ECF and by U.S. Mail to Wiladys Castillo, Defendant, on July 16, 2020 as noted 

on the attached service list. 

MARKOWITZ RINGEL TRUSTY & HARTOG, P.A. 

Counsel for the Plaintiff 

9130 South Dadeland Blvd., Suite 1800 

Miami, FL 33156 

Tel: (305) 670-5000 

Fax: (305) 670-5011 

 By: /s/ Alan R. Rosenberg 

ALAN R. ROSENBERG 

Fla. Bar No.: 92004 

arosenberg@mrthlaw.com 

SERVICE LIST 

Via Electronic Mail Notice: 

The following is the list of parties who are currently on the list to receive email notice/service 

for this case. 

 Adrian C. Delancy adelancy@mrthlaw.com, 

ycandia@mrthlaw.com,gruiz@mrthlaw.com,ecfnotices@mrthlaw.com;mrthbkc@gmail.c

om 

 Alan R Rosenberg arosenberg@mrthlaw.com, 

gruiz@mrthlaw.com,jgarey@mrthlaw.com,ycandia@mrthlaw.com,mrthbkc@gmail.com 

Via U.S. Mail To: 

Wiladys Castillo 

3150 S Decatur Blvd Apt 34 

Las Vegas, NV 89102‐7128 

822152

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