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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM DIVISION

www.flsb.uscourts.gov

In. re: Case No.: 21-13230-EPK

CHRISTI LEE STRAUB, Chapter 11

Debtor-in-Possession.

/

CHRISTI LEE STRAUB Adv. Case No. 21-01155-EPK

Plaintiff,

v.

MISSOURI HIGHER EDUCATION LOAN

AUTHORITY, DEPARTMENT OF

EDUCATION OF THE UNITED STATES

AND THE UNIVERSITY OF MINNESOTA, 

Defendants.

/

PLAINTIFF’S VERIFIED MOTION

FOR ENTRY OF CLERK’S DEFAULT AS TO DEFENDANTS, MISSOURI

HIGHER EDUCATION LOAN AUTHORITY; AND THE UNIVERSITY OF 

MINNESOTA FOR FAILURE TO FILE OR SERVE ANY RESPONSIVE PLEADINGS

CHRISTI LEE STRAUB (the “Plaintiff”), by and through undersigned counsel, and moves 

for the entry of a Clerk’s Default against Defendants, Missouri Higher Education Loan Authority 

and The University of Minnesota for Failure to File or Service any Responsive Pleading, and in 

support thereof, states as follows:

1. The Adversary Complaint (DE 1) was filed on May 18, 2021 (DE 1) (the “Adversary 

Complaint”).

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2. The Summons and Notice of Status Conference in an Adversary Proceeding (DE 2) 

(the “Summons”), and Order Setting Status Conference and Establishing Procedures and Deadlines

(DE 3) (the “Order”) were issued on May 19, 2021.

3. An answer to the Adversary Complaint was due on or before June 23, 2021.

4. The Summons, Complaint, and Order were properly served on Defendant Missouri 

Higher Education Loan Authority on July 19, 2021 via U.S. Mail and Certified Mail 

(#70201810000184333191) which was delivered on July 30, 2021. 

5. The Summons, Complaint, and Order were properly served on Defendant The 

University of Minnesota on July 19, 2021 via U.S. Mail and Certified Mail 

(#70201810000184333207) which was delivered on July 26, 2021. 

6. On July 19, 2021, the undersigned filed a Certificate of Service reflecting the above

(DE 9).

7. As of August 25, 2022, Defendant, Missouri Higher Education Loan Authority and 

Defendant The University of Minnesota has not filed an answer or responsive pleading with the 

time fixed by the Court or by Fed. R. Banr. P. 7012(a).

WHEREFORE, the Plaintiff, CHRISTI LEE STRAUB, respectfully requests that this 

Court enter a Default against the Defendant, MISSOURI HIGHER EDUCATION LOAN 

AUTHORITY and Defendant THE UNIVERSITY OF MINNESOTA, and such other and further 

relief as the Court deems just and proper.

RULE 7055-1 VERIFICATION

Pursuant to Local Rule 7055-1, I hereby verify under penalty of perjury, that the Defendants, 

Missouri Higher Education Loan Authority, and The University of Minnesota have been properly 

served with the Summons, Adversary Complaint, and Order Setting Status Conference and 

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Establising Procedures and Deadlines, and that no response has been served on the Plaintiff through 

the undersigned, and that the Defendants, being corporate entities, are not members of the military 

service.

Dated: August 25, 2022 VAN HORN LAW GROUP, P.A.

500 N.E. 4th Street, Suite 200

Fort Lauderdale, FL 33301

Telephone: (954) 765-3166

Facsimile: (954) 756-7103

Email: Chad@cvhlawgroup.com

 By: /s/ Chad T. Van Horn, Esq.

Chad T. Van Horn, Esq.

Florida Bar No. 64500

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