UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO.

11 20657 CIV - COHN

ENRIQUE VARONA, Plaintiff,
V.
FILED by.

D.C.

APR 2 5 2012

FLORIDA STATE TROOPER M.G. RIETMANN, et al, Defendants,

REQUEST FOR CERTIFICATE OF DEFAULT

HERE COMES the PLAINTIFF,

Enrique Varona a human person acting pro se who MIAMI DADE

rightfully requests an Order and Certificate of Default from defendant(s),

COUNTY and CARLOS GIMENEZ mayor, pursuant to Rule 55(a) of the Federal Rules of Civil Procedure for failure to plead or otherwise defend this action as fully appears from the court file herein and from the attached affirmation.

AFFIRMATION IN SUPPORT OF REQUEST FOR CERTIFICATE OF DEFAULT

1 .1 am the plaintiff in this action. 2. This action was commenced pursuant to a Title 42 Section 1983 complaint.

3. Defendant(s), MIAMI DADE COUNTY and CARLOS GIMENEZ were served with the complaint on February 15, 2012. 4. Defendant(s), MIAMI DADE COUNTY and CARLOS GIMENEZ should have served an answer to the complaint by March 8th, 2012. The time to answer or otherwise move with respect to the complaint herein has expired. 5. Defendant(s), MIAMI DADE COUNTY and CARLOS GIMENEZ, has not answered or otherwise moved with respect to the complaint, and the time for defendant(s) to answer or otherwise move has not been extended. 6. That defendant(s) MIAMI DADE COUNTY and CARLOS GIMENEZ is not an infant or Incompetent and is not presently in the military service of the United States as appears from facts in this litigation. 7. Defendant(s) MIAMI DADE COUNTY and CARLOS GIMENEZ is indebted to plaintiff, Enrique Varona, in the following manner: A) USD $1,000,000.00 for Punitive damages. B) Any and all relief this court sees fit. WHEREFORE, Plaintiff Enrique Varona requests that the default of defendant(s) MIAMI DADE COUNTY and CARLOS GIMENEZ be noted and a certificate of default issued. I declare under penalty of perjury that the foregoing is true and accurate to the best of my knowledge, information and belief, that the amount claimed is justly due to plaintiff, and that no thereof has been paid.

Case l:ll-cv-20657-JIC

Document 67 Entered on FLSD Docket 04/26/2012 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CLERK'S DEFAULT

Enrique Varona,

CASE NO. 11 -cv-20657-Cohn

Plaintiffs),
FILED by D.C.

Apr 26, 2012

Chief Administrative Officer of Dade County Carlos A. Gimenez

STEVEN M. LARIMORE CLERK U.S. DIST. CT. S.D. OF FLA.

Defendant(s).

It appearing that the defendant(s) herein, Chief Administrative Officer of Dade County Carlos A. Gimenez, is in default for failure to appear, answer or otherwise plead to the complaint filed herein within the time required by law. Default s hereby entered against defendant(s) Chief Administrative Officer of Dade County - Carlos A. Gimenez, as of course, on this date April 26,

2012.

STEVEN M. LARIMORE
CLERK OF COURT

s/ Graciela Gomez By: Graciela Gomez Deputy Clerk cc: Hon. James I. Cohn Counsel of Record Chief Administrative Officer of Dade County - Carlos A. Gimenez Stephen P. Clark Center, 1 1 1 N.W. 1 st Street, Suite 2910. Miami, FL 33128