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 

v. 

 

WILADYS CASTILLO, 

 

 Defendant. 

 / 

PLAINTIFF’S EX PARTE MOTION FOR AN ORDER

DIRECTING CLERK TO ISSUE AN ALIAS SUMMONS 

Plaintiff, Ross R. Hartog, the duly appointed chapter 7 Trustee (the “Plaintiff” or 

“Trustee”) by and through the undersigned counsel, pursuant to Fed.R.Bankr.P. 7004(e) and 

Local Rule 7004-2(B), requests that this Court enter an order, on an ex parte basis, directing 

the clerk to issue an alias summons for defendant Wiladys Castillo (the “Defendant”). In support 

of this motion (the “Motion”), Plaintiff states: 

Background 

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

[ECF No. 1] against Wiladys Castillo. 

 

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2. On May 5, 2020, the Clerk of the Court issued the Summons and Notice of 

Pretrial/Trial in an Adversary Proceeding (the “Summons”) [ECF No. 2]. 

3. On May 5, 2020, the Court also entered the Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial (the “Pretrial Order”) [ECF No. 3]. 

4. Despite combing through the Debtor’s records, the Plaintiff was unable to locate 

exact contact information for the Defendant. However, by comparing the Debtor’s records with 

the public records, the Plaintiff believes that he may have located the Defendant. 

Request for Issuance of Alias Summons

5. Fed.R. Bankr.P. 7004(e) requires a summons to be served “within 7days after 

the summons is issued ... [i]f a summons is not timely delivered or mailed, another summons 

shall be issued and served.” 

6. The Plaintiff requires an alias summons in order to serve the Complaint, Summons 

and Pretrial Order on the Defendant. 

7. Based on the foregoing, the Plaintiff requests the Court enter an order directing the 

Clerk of the Bankruptcy Court to issue an alias summons for service upon the Defendant. 

WHEREFORE, the Plaintiff respectfully requests the Court enter an order, on an ex parte 

basis: (i) granting the Motion; (ii) directing the Clerk to issue an alias summons; and (iii) for 

such other and further relief as this Court deems just and proper. 

Dated June 8, 2020. Respectfully submitted, 

MARKOWITZ RINGEL TRUSTY & HARTOG, P.A. 

Counsel for the Plaintiff 

9130 S. Dadeland Blvd., Suite 1800 

Miami, Florida 33156 

Tel: (305) 670-5000 /Fax: (305) 670-5011 

 By: s/ Alan Rosenberg . 

 ALAN R. ROSENBERG 

 Fla. Bar No.: 92004 

 arosenberg@mrthlaw.com 

819952 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the forgoing was served by electronic 

mail via the Court’s CM/ECF to all counsel of record registered to receive electronic noticing in 

this case and listed on the attached service list on June 8, 2020. 

By: s/ Alan R. Rosenberg 

ALAN R. ROSENBERG 

 

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ELECTRONIC SERVICE LIST 

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;mrthbk

c@gmail.com 

 Alan R Rosenberg arosenberg@mrthlaw.com, 

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

mail.com 

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