Celebrity Actor's Camp, Inc., Winebarger v. McLaughlin, Bredbrenner, 2D2023-1742

Allison Bredbenner sued Celebrity Actors Camp, Inc. and its principal, Adrian Winebarger (aka Adrian R'Mante), for breach of contract and replevin related to payment for unprovided celebrity acting services.
Service of process was attempted at the address of a private mailbox, which was the official Florida Division of Corporations’ address for Celebrity Actors Camp, Inc.
The county court entered a clerk’s default and initial default final judgment against Celebrity and Winebarger for $5,500 plus costs.
After learning of the default, Celebrity and Winebarger moved to quash service, vacate judgments, file counterclaims, and transfer the case, but the court entered a second final judgment without addressing their motions.
The county court ultimately denied all relief, focusing on defendants’ purported lack of diligence, not the sufficiency of service.
On appeal, the Second District reviewed whether service at a private mailbox satisfied Florida statutory requirements and whether the judgments were void due to improper service.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service of process at a private mailbox complied with § 48.031(6)(a).	Mailbox was only public records address for service.	Service failed strict statutory compliance.	Service was improper; statutory requirements not strictly met.
Whether the clerk’s default and default judgments should stand.	Judgments proper based on service made.	Judgments void because of improper service.	Both judgments were void and must be vacated.
Whether defendants’ later filings waived their jurisdictional objections.	Subsequent pleadings equal submission to jurisdiction.	Sought relief after objecting to service but preserved objection.	Defendants submitted to jurisdiction for future proceedings, but service was still defective for existing judgments.
Whether pending motions required consideration before final judgment entered.	No specific argument on timing.	Judgment improper with motion to vacate pending.	Second judgment also void; trial court must resolve pending motions first.

TID Servs., Inc. v. Dass, 65 So. 3d 1 (Fla. 2d DCA 2010) (strict statutory compliance is required for service at private mailboxes; absence of evidence on discoverable addresses invalidates service)
Beckley v. Best Restorations, Inc., 13 So. 3d 125 (Fla. 4th DCA 2009) (strict statutory compliance is necessary for service of process)
Lakeview Auto Sales v. Lott, 753 So. 2d 723 (Fla. 2d DCA 2000) (trial court must address pending motions to set aside default before entering judgment)