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. 

 / 

EX PARTE MOTION FOR DEFAULT FINAL JUDGMENT 

(Declaration of Amounts Due Attached) 

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

of World Global Financing, Inc. (the “Debtor”), by and through undersigned counsel, moves (the 

“Motion”) for the entry of a Default Final Judgment against defendant Wiladys Castillo (the 

“Defendant”), in the form attached as Exhibit A in the amounts as calculated in the Declaration 

attached as Exhibit B. 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 16 Filed 07/23/20 Page 1 of 8
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, the Plaintiff filed his complaint [ECF No. 1](the “Complaint”) 

against the Defendant to avoid and recover transfers of money totaling $288,500.00, from the 

Debtor to the Defendant, pursuant to 11 U.S.C. §§ 544, 548 and 550, and Florida Statutes §§ 

726.105, 726.106, 726.108 and 726.109. A declaration calculating the amounts due is attached as 

Exhibit B.

5. On May 5, 2020, the Court issued the Summons and Notice of Pretrial/Trial in an 

Adversary Proceeding [ECF No. 2] (the “Summons”) and the Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial [ECF No. 3]. 

6. On June 10, 2020, the Court issued the Alias Summons and Notice of Pretrial/Trial 

in an Adversary Proceeding [ECF No. 7](the “Alias Summons”), and a new Order Setting Filing 

and Disclosure Requirements for Pretrial and Trial [ECF No. 8](the “Order”). 

7. On June 10, 2020, the Defendant was served with the Complaint, Alias Summons 

and Order as evidenced by the certificate of service filed on June 12, 2020 [ECF No. 11]. 

8. A responsive pleading to the Complaint was due on or before July 9, 2020. 

9. The Defendant failed to timely file any responsive papers to the Complaint, as 

required by the Alias Summons. 

10. Accordingly, on July 16, 2020, Plaintiff filed a verified motion seeking entry of a 

clerk’s default. See ECF No. 12. 

11. On July 17, 2020, the clerk entered a default against the Defendant. See ECF No. 

13. 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 2 of 8
12. By virtue of the Defendant’s failure to respond to the Complaint, all the allegations 

in the Complaint are deemed admitted. 

13. Accordingly, the Defendant should be held liable to the estate for a total of 

$288,500.00. 

WHEREFORE, the Plaintiff respectfully requests that this Court: (1) grant the Motion; 

(2) enter a Default Final Judgment against the Defendant, Wiladys Castillo, in the form attached 

as Exhibit A; and (3) grant such other and further relief as the Court deems just and proper. 

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 

 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 3 of 8
EXHIBIT A

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. 

 / 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 4 of 8
DEFAULT FINAL JUDGMENT IN FAVOR OF PLAINTIFF 

THIS CAUSE came before the Court upon the Ex Parte Motion for Default Final Judgment

[ECF No. ___] (the “Motion”) filed by Plaintiff, Ross R. Hartog, Chapter 7 Trustee (the 

“Plaintiff”). The Court, having reviewed the Motion and the Court’s electronic docket, having 

noted the Entry of Default [ECF No. 13] after the Defendant’s failure to timely respond, and the 

allegations of the Complaint being deemed admitted, does 

ORDER AND ADJUDGE as follows: 

1. Final Judgment is entered in favor of Plaintiff, Ross R. Hartog, Chapter 7 Trustee, 

P.O. Box 14306, Fort Lauderdale, Florida 33302, and against Defendant, WILADYS 

CASTILLO, 3150 S. Decatur Blvd., Apt. 34, Las Vegas, NV 89102, on all counts of the 

Complaint. 

2. The Plaintiff shall recover from Defendant, WILADYS CASTILLO, the sum of 

$288,500.00, plus interest at the applicable rate pursuant to 28 U.S.C. § 1961 and costs, for which 

let execution issue. 

# # # 

Submitted by: 

Alan R. Rosenberg, Esq. 

Markowitz, Ringel, Trusty & Hartog, P.A. 

Counsel to Plaintiff 

9130 South Dadeland Boulevard, Suite 1800, Miami, FL 33156 

Tel: (305) 670-5000 

Copies to: 

Alan R. Rosenberg, Esq. 

(Attorney Rosenberg is directed to mail a copy of this Order to all interested parties and to file a 

certificate of service). 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 5 of 8
EXHIBIT B

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. 

 / 

DECLARATION OF AMOUNTS DUE 

IN SUPPORT OF MOTION FOR DEFAULT FINAL JUDGMENT 

Alan R. Rosenberg, counsel for the Plaintiff, under penalty of perjury, states as follows: 

1. On May 4, 2020, the Plaintiff filed a complaint [ECF No. 1](the “Complaint”) 

against the Defendant to avoid and recover transfers of money totaling $288,500.00 from the 

Debtor to the Defendant. 

2. On May 5, 2020, the Court issued the Summons and Notice of Pretrial/Trial in an 

Adversary Proceeding [ECF No. 2] (the “Summons”) and the Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial [ECF No. 3]. 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 6 of 8
3. On June 9, 2020, the Court issued the Alias Summons and Notice of Pretrial/Trial 

in an Adversary Proceeding [ECF No. 7](the “Alias Summons”) and a new Order Setting Filing 

and Disclosure Requirements for Pretrial and Trial [ECF No. 8](the “Order”). 

4. On June 10, 2020, the Defendant was served with the Complaint, Alias Summons 

and Order as evidenced by the certificate of service filed on June 12, 2020 [ECF No. 11]. 

5. A responsive pleading to the Complaint was due on or before July 9, 2020. 

6. The Defendant failed to timely file any responsive papers to the Complaint, as 

required by the Alias Summons. 

7. Accordingly, on July 16, 2020, Plaintiff filed a verified motion seeking entry of a 

clerk’s default. See ECF No. 12. 

8. On July 17, 2020, the clerk entered a default against the Defendant. See ECF No. 

13. 

9. According to records provided by the Debtor to the Trustee, the amount of the 

transfers that were made to the Defendant total $288,500.00. 

10. By virtue of the Defendant’s failure to respond, all the allegations in the Complaint 

are deemed admitted, including, the amount of the transfers made to the Defendant by the Debtor. 

Declaration - 28 U.S.C. § 1746 

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

Executed on July 23, 2020. 

/s/ Alan R. Rosenberg 

Alan R. Rosenberg 

 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 7 of 8
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of this Motion was served via the Court’s 

CM/ECF to all counsel of record and interested parties registered to receive electronic noticing in 

this case and to Wiladys Castillo, Defendant, by U.S. Mail as listed on the following service list 

on July 23, 2020. 

By: /s/ Alan R. Rosenberg 

 ALAN R. ROSENBERG 

Service List 

Via Electronic Mail Notice To:

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 

Case 20-01163-AJC Doc 16 Filed 07/23/20 Page 8 of 8