Filingr ll T5?l3?23 E-Filed DTBUIZUIS 04:46:16 PM
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`IN THE CIRCUIT CDIIRT FDR THE 11TH .IIIDICIAL CIRCUIT IN
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`AND FOR MIAMI-[IADE CUUNTY, FLDRIDA
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`GENERAL JURISDICTIDN DIVISION
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`CASE NO: lT-fllfildl-CA-ll’t
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`WAYNE BLOCK,
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`a natural person and resident of Florida
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`Plaintiff,
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`V.
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`MARKET! DEJr‘tNDVIC,
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`a natural person and resident of Florida, et al.,
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`Defendants.
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`f
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`PLAINTIFF’S RESPDNSE IN flPPflSITIflN TU DEFENDANT LDRENA
`DEJANDVIC‘S MOTION FOR PRCIITECTIVE CtRIIIER
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`AND- REQUES'I" FUR SANC'HUNS
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`The Plaintiff, 1|titlayne Bloelt {the ”Plaintiff” and “Bloek”}, by and through his undersigned
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`counsel, respectfully submits this opposition to the motion of the defendant Lorena Dejanoyic for
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`a protective order. The motion should be denied, and pursuant to Rule 1.381] of the Florida Rules
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`of Civil Procedure, sanctions should be imposed upon this defendant, including awarding Mr.
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`Block his attomey’s fees and costs in having to defend against this motion.‘
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`1
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`Mrs. Dejanoyie made no effort to resolve the issues raised in the motion prior to
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`filing the motion. To the contrary, site pertnitted Iter deposition to be scheduled and waited until
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`close to the eye of the deposition to file her motion, and then she set it for hearing on the satne day
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`of the deposition. Mrs. Dejanoyie had h-ilr. Block’s answers to her intetrogatories since May 1,
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`EDIE. Yet, she made no tnotion until July 213, 2013, after re-scheduling her deposition for Augu st
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`2, 21313.
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`I.
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`Mrs. Dejanoyic moves for a protective order near the eye of her deposition. The
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`motion should be denied, and she should be sanctioned, including ordered to pay the Plaintiff's
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`reasonable attorney’s fees and costs.
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`flACKG RIDE ND
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`2.
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`By way of' background. Mrs. Dejanoyics deposition was first scheduled For April
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`24. EMS {and then re-noticed for May 4, 2018]. which was coordinated with her counsel. 1|When
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`her husband’s lawyers — who represent her as well — moved to withdraw as counsel for her
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`husband. the undersigned. as an unrequested courtesy. cancelled her deposition and stated that he
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`would reschedule it for some time after the Court entered an order permitting the 1withdrawal.
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`3.
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`On May ], 2018. Mr. Block served his answcls to Mrs. chanoyic’s intcrtogatory
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`answers with attachments. including the American Express statements.
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`4.
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`{in June 29, Efllfl. again with the coordination of her counsel, the deposition was
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`rescheduled For August 2, EDIE.
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`5.
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`At the time that the deposition was rescheduled for August 2. Mrs. Dejanoyic had
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`the Plaintiff‘s answers to her interrogatories and the attachments thereto, which included the
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`American Express statements.2
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`a
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`As
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`the Conn is aware.
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`this case concerns. among other
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`things. material
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`misrepresentations that were made to the Plaintiff about the capital structure of and the funding
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`for two companies, Claws Investments.
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`Inc.
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`(“Claws") and Sigma Equity Lending. LLC
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`(“Sigma“), as well as Fraudulent transfers ot~ corporate assets to Mrs. Dejanoyic and her husband
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`As Mr. Block argues below. the Dejanoyics do not own the American Express
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`account that they used to fuel their extravagant lifestyle at the expense of others.
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`2
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`— which the},r used to finance a lavish lifestyle — that Iefi the companies broke and unable to meet
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`their obligations, including to the Plaintitt‘.
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`'t'.
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`In Fact. Mr. Block contends that both companies never intended to engage in actual
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`business but served as mere fronts for the Dej anovics to obtain funds from unsuspecting third-
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`parties under the false pretense that the Funds were needed for business purposes. Dnce the
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`Dej anosics obtained the Funds, the Dejanovics spent the money on personal expenses.
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`8.
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`For example,
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`in March EDIE. the Dejanovics obtained a $2.5 million dollar by
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`mortgaging their home to lfir' Lendi ng, and the terms of the loan were that the proceeds were to be
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`used For business purposes only. Mr. Dejanovic’s statement to the Plaintiffthat he would mortgage
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`his home if need be to continue to meet the obligations of the business {including Mr. Block’s
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`salary) was a material inducement for the Flaintit‘i‘ to continue working. Amended Complaint 1l23.
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`9.
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`Yet. within months the Dejanosics spent that money in complete disregard and
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`violation of their promises and undertakings in the loan documents and of Mr. Dejanos'ic’s
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`representations to the Plaintiff.
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`to. When that money ran out. to induce the Plaintiff to continue to work for deferred
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`pay. Mr. Dejanovic represented that he had personal Funds coming in. At deposition MrDejanovic
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`admitted as much and stated that the funds he was expecting were from the sale of “Chinese
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`bonds."
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`ll.
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`According to Mr. Dejanos'ic. these were bonds that had been issued by the pre—
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`Communist Chinese government. The absurdity of this testimony is clear. At the time of the
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`fraud, Mr. Dejanovie did not reveal to Mr. Block the nature of those personal assets or funds that
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`Mr. Block was requested to hold out for. Mr. Block learned ofit in discovery-l
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`[2.
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`Judicial determinations in other cases establish and confirm Mr. Block‘s allegations
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`in this case that fraud was the real business of the Dejanovics.
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`13.
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`In a separate action, 1095 Funding Now, HIT v Marat; Uejnirmve, at all, Case No.
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`EDIT-023 [43, the lender L‘v’ Lender’s successor has obtained a judgment against the Dej anovics
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`for more than $3,UUU,DDD.
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`[n the final judgment, the Court found, as the Plaintiff alleges in this
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`action [Amended Complaint 113?}, that the l'Jejanovies defrauded the lender in obtaining the
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`mortgage by failing to disclose an unrecorded, prior mortgage or lien on the property. A copy of
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`the relevant portion of that finaljudgment is annexed hereto as Exhibit A.
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`[4.
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`The prior mortgage, as found in that final judgment, is held by South Florida Sigma
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`Investments, LLC, a company owned by John Foster.
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`l5.
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`When Mr. Dejanovic was asked in deposition about Mr Foster‘s financing his
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`home, Mr. Dejanoviois lawyer — Brian Goodltind. Esq. — instmoted Mr. Dejanovie not to answer.
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`[in July 19, 2013, the Court ordered l'vlr. Dejanovic to answer the question.
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`l'vlr. Fostefs company
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`is currently suing Mr. Goodkind and his law firm, who was involved in that loan, over the failure
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`to record the lien on the house.
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`to.
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`In yet another action, Drnigi'ns M Halsey v. Mora—o Herman-ac, Case No.
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`l?-
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`{llofi‘ES—CA—EE, the Court has entered judgment against Mr. Dejanovic and Clavis for defrauding
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`the plaintiff into lending them funds for business purposes. Ely Dejanovic“s own admission in that
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`action, upon receipt of the funds, "he used the funds to pay personal expenses rather than for the
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`-‘-'
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`At deposition Mr. Dejanovic could not provide any specific testimony about these
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`"Chinese bonds," including their value or method of valuation.
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`l'vlr. Dejanovic purports to hold a
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`doctorate in economics. The bonds, as with the doctorate, are likely non—existent.
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`a
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`business purpose he had represented to Halsey. Upon infiirrnation and beliefl Dejanoyie never
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`intended to use the funds loaned to him by Halsey for any business purpose.“ A true and correct
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`copy of the judgment in that action and pertinent potions of the complaint are annexed here as
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`Composite Exhibit B.
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`1?.
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`In this case. Mr. Block alleges. among ether things. that as in the case of Douglas-
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`Holsey with respect to the funds from Mr. Halwy. the Dejanoyics obtained the funds in the LV
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`Lending transaction with the intention of using the funds primarily for personal expenses even
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`though they represented to the lender and undertook that the Funds would only be used for business
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`purposes and not for personal or family expenses.“
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`THE AMERICAN EKPRESS S'I'A'I'EMEN'I'S AND fl'THER DOCUMENTS
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`[3.
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`Mrs. Dejanoyic bases her motion on the Report and Recommendation of the
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`General Magistrate. Her reliance is nus-placed.
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`Ii}.
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`Mrs. Dejanoyie was not
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`a party to this action when the Report and
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`Recommendation was issued. Moreover.
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`the complaint at
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`the time of the Report and
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`Recommendation has been superseded by an amended pleading that added additional counts.
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`including against Mrs. Dejanoyic’s and her husband‘s company Clayis. and that added her as 5
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`party. The Court has already ruled that Mr. Block is entitled to the business records of that
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`company as well as those of Sigma. including their bank records.5 The Court has also ruled. when
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`The Court dismissed Mr. Block‘s count that he was a third-party beneficiary of the
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`L‘i.’ Lending transaction. accepting the Defendants" argument that the beneficiary was Clayis. the
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`business of the Dejanoyics. Thus. there can be no dispute that the LV Lending funds were a
`corporate asset.
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`‘
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`lndeed1 Mr. Block has already obtained judgments in this action against Clayis and
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`Sigma.
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`I'ylr. Block is independently entitled to those records as discovery in aid of execution and
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`is further entitled to trace the dissipation of corporate assets by Petr. Dejanoyic and his wife.
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`5
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`it ordered her husband to answer questions that he had been instructed not to answer at deposition,
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`that the financial affairs of her husband {and by extension those ofhis wife Lorena Dejanoyic] are
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`at issue in this action for Efllfi and 20'16, including regarding the loan from Mr. Foster and the
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`American Express account.
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`2D.
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`Significantly, once Mrs. Dejanoyic was added as a party. she propounded requests
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`for production in which she specifically requested production of the documents that had been
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`obtained pursuant to the subpoenas referred to in her motion. She tltus admits and cannot deny the
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`relevance of th osc records to this action, for she herself asked for them to be produced in discovery.
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`2].
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`Contrary to her assertion that Mr. Block has refused to divulge himself of those
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`documents. the records were produced to her counsel in response to her requests for production.
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`and her counsel is in possession ofa copy of the records.
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`22.
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`Mrs. Dejanovic‘s aspersion that the Plaintiff or his undersigned counsel improperly
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`obtained the American Express documents attached to Mr. Blockis answers to her interrogatories
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`is frivolous. As she all but admits. she does not know how those documents were obtained. and
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`thus, has no basis whatsoever to assert any impropriety. Her motion is not supported by any
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`affidavit.
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`23.
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`The American Express statements attached to Mr. Block‘s interrogatory answers
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`were not obtained from the subpoenas referred to in the motion. Rather, the statements were
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`obtained from the actual comer of the American Express account. Mr. and Mrs. Dejanovic do not
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`own the American Express account;
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`rather, the owner is a third party. Hendrik Eonse—Geuking
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`who agreed to issue cards to Mr. and Mrs. Dejanoyic under his account. Under the agreement with
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`Mr. Bonse-Geuking, the Dejanorics would payr for their charges as part of their agreement but Mr.
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`Bonse-Geuking remained liable to American Express for the charges and balances.
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`24.
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`Accordingly, Mrs. chanonic's motion is unfounded and worse, disingenuous to
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`the extent that she asserts that Mr. Block or his counsel improperly obtained documents.
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`25.
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`For all the foregoing reasons, the motion should be denied. Furthermore, the Court
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`should sanction Mrs. ch anoyic and award Mr. Block his attomcy’s fees and costs in having to
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`oppose the m otion.
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`Dated: July 30, 2013
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`Respectfully submitted,
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`BURSTEIN Sr ASSOCIATES, PA.
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`Attorneys for the Plaintiff Wayne Block
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`l 3?44 Biscayne Boulevard
`North Miami Beach, Florida 33131
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`Telephone No. [3135} QST-Tflfifi
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`Facsimile No.1 {EDS} QST-TUET
`E-mail: bb ursteinfifdhursteinpacom
`Bursteinandassociatestii
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`By:
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`Est Bernardo Burstein
`Bernardo Burstein
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`Florida Bar No; 9722!)?
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`CERTIFICATE DF SERVICE
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`I hereby certify that a true and correct copy of the foregoing was sewed by email through
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`the Florida eFiling portal upon Brian K. Goodkind, Esq., and Kenneth R. Florio, Esq, 4|2| La
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`Flaya Boulevard, Coral Gables, Florida 33133: Heloiza Correa, Esq, Heloise A. (Jones, PA,
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`2665 S. Bayshore Dr. Ste. 22:), Coconut Grove, FL 33 l33-54D2 on this 313th day oFJuly 2013.
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`Est Bernardo Burstein
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`Bernardo Burstein
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`

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`EXHIBITA
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`

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`ISFN: 2E1flfl43$55fi BOOK 310535 F!! 49ft
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`DATE‘GNEE'EU‘LE iris-ease AM
`HARVEY Ftl_|"I.I'IN'. CLERK OF EQURT MIA-BABE t
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`IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT1
`IN AND FOR MIAMLDADE COUNTY. FLORIDA
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`lflS‘i 5 FUNDING NOTE LLC, a Delaware
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`limited liability enmnan};~
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`Plaintiff,
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`CASE NU. 2fl17—D23143-CA—fl1
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`VS.
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`Individual;
`an
`I'vLARKU DEJAN’DVIC,
`LURENA DEJANDVIC We MARIA
`
`IDRENA DRTEGA,
`SDUTH
`FLORIDA
`
`an
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`individual;
`SIGMA
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`INVESTMENTS, LLC, a Florida limited
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`UNKNOWN
`and
`company;
`liability
`TENANT #1; and UNKNOWN TENANT
`#2,
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`.'|-'
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`Defendants.
`|-I"
`p.3-
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`FINAL JUDGMENT 0F FD RECLOSURE
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`SStllli‘i'LIlit?Elili
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`THIS ACTl'DN came before the Court at hearing on Jul}.r IT, 21313 on predecessor Plaintiff
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`LV Lending LLC’s {“L‘v’ Lending‘T‘ Motion for Final Judgment (”Motion“) and its Afi'tdavit of
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`Hon-Performance. The Court, having reviewed the Motion, having heard argument of counsel,
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`and being otherwise duly advised in the premises. it is hereby
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`DRBERED and ADJUDGED as follows:
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`1.
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`Defendants Marko Dejanovie and Lorena Dojanovio ai'lo‘a Maria Lorena Ortega
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`{collectively the “(mer Defendants-”i have been duly and regularly serve-ct with proeeSs in this
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`action and Final Judgment is entered in favor ofthe substituted Plaintiff 10915 Funding Note LLC
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`1 As of the date of this Final Judgment of Foreelosurei 1|}ng Funding Notei LLC has been
`substituted as the party Plaintiff in this action and this Final Judgment is eaelusivelji.r in its favor.
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`

`

`CFN 20139-136555 BOOK 31055 PAGE 498?
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`ATTDRNE‘KS’ FEES INCURRED
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`Attorneys’ Fees:
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`ssrssese
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`GRAND TOTAL A MOUNT:
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`$3,15Tlfifi’l'33
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`That total referenced in this paragraph shall bear interest from this date forward at the prevailing
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`legal interest rate. Thereafter, on January 1 of each Succeeding year until the judgment is fully
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`satisfied, the interest rale her hereunder shall adjust in accordance with Section 55133, Elg[ids
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`3.
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`Findings of Fact. The Owner Defendants executed a purchase money mortgage
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`{the ”Sigma Mortgage”) in favor of South Florida Sigma Investments, LLC (“Sigma") to fund
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`their purchase of the Property (as defined below] and satisfy a prcyious mortgage eneurnhen'ng the
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`Property. After the Sigma Mortgage was executed. but before it was recorded, the aner
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`Defendants executed two mortgages in favor of LV Lending, Which 1were recorded at Miami—Dede
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`Ufficiai Records Book 29999. Page 4543 and Book 3flfl21, Page sso, respectively {the “DJ
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`Mortgages“). The U." Mortgages have since been assigned to Plaintiff. Even though they executed
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`the Sigma Mortgage,
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`the DWIIEF Defendants falsely covenanted to predecessor Plaintiff L‘u’
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`Lending that the Property was free of all liens and claims when they entered into the LV Mortgages
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`unbeknownst to predecessor Plaintiff LU Lending. See Compl, Ex. 3 at '|] 3; fat, Ex.
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`lfl at '!l 3.
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`Thus, at least in part due to the Owner Defendants‘ failure to notify LU Lending of the Sigma
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`Mortgage, LU Lending “did not have notice of any mortgage or interestts) of [Sigma] at the time
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`of the execution of Plaintiff's mortgages." Order Granting Plaintiff’s Mot. for Summ. 1., '1' 4, May
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`23, ED] 8. Therefore. the LV Mortgages new “are superior to and have priority over any interestts}
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`of [Sigma] in the [Property]? M. Certainly L‘y’ Lending is not at fault that the Owner Defendants”
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`failure to disclose the Sigma Mortgage.
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`

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`CFN: 23130436556 BOOK 314356 PAGE 4991
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`TO NIAKE SURE THAT YOU UNDERSTAND WHAT YOU ARE SIGNING AND THAT
`YOU ARE NOT 'I'MNSFERRING YOUR PROPERTY OR THE EQUITY IN YOUR
`PROPERTY WITHOUT THE PROPER INFORMATION. IF YOU CANNOT AFFORD
`TO PAY AN ATTORNEY, YOU MAY CONTACT THE LEGAL AID SOCIETY AT LEGAL
`AID SERYICES OF GREATER MIAMI, Jflflfl BIS CAWE ROU LEYARD. SUITE SIIII.
`MIAMI, FL 33]}? (TELEPHONE {LIBS} STE-“HEB TO SEE IF YOU QUALIFY
`Fl1W.-!I..I"'IICIAILL"I‘r FOR THEIR SERVICES. IF THEY CANNOT ASSIST YOU. THEY MAY
`BE ABLE TO REFER YOU TO A LOCAL BAR REFERRAL AGENCY OR SUGGEST
`
`OTHER OPTIONS. IF 1YOU CII OOSE TO CONTACT (NAME OF LOCAL OR NEAREST
`LEGAL AID OFFICE AND TELEPHONE NUMBER] FOR ASSISTANCE, YOU SHOULD
`DO SO AS SOON AS POSSIBLE AFTER RECEIPT OF THIS NOTICE.
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`DONE and ORDERED in Miami-[Jade Cuunty, Fluridn, on Jul}.r 1T, ZINE
`
` HEY SMITH '
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`CIRCUIT COURT JUDGE
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`"E'Eflh " fl-
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`“IW “W
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`J'TJUEG‘E
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`
`
`

`

`EXHIBIT B
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`

`

`CFN: 2G130114999 BOOK GDEFE PAGE 14?
`DATEi'IZIEIETI'IEGW 10:51'45 AM
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`IN THE errttitifitfioomssverrwsfisemwst
`ELevr-ivru rootetar. eiaeLnT IN sat)
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`For-t straw-Daria COUNTY, rLoatoa
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`CIRCUIT CIVIL DIVISION
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`Case No.
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`IT—DtoQBS—(‘a—ZE
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`DUUGLHS M. HALSF‘I’.
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`an IndividttaL
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`Plaintiffs
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`v.
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`MARKU DEJhNfllv'IC,
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`an individual. and
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`CLAVIS INVESTMENTS, INCA
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`a Florida corporation~
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`De Fend ants.
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`f
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`CDNSENT FINAL JUDGMENT FDR PLAINTIFF
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`Upon consideration of' the parties” settlement agreement and the Defendants’ agreement
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`in the entry of this Consent Final Judgment without a hearing, and the Coutt having reviewed the
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`pleadings and being otherwise t‘ullv advised. it is flRDERED AND ADJ UDGED that:
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`l_
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`Final Judgment is entered in favor ol" I’laintit‘l‘. Douglas M. Halsesa and against
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`Defendants Marko Dejanovie and Clavis Investments,
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`lno_, jointly and severalIv. on all counts
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`of the A mended Foraplaint. in the amount of 3334113131].
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`Ptaintit‘t‘Douglas M. Halsev‘s address is USES SW 'i'tl'“ :‘tve.._ Miami, FL 3315-5.
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`Defendant Marko Dejanovie‘s address is lflfltfi SW 62"" ante.~ Miami, FL 33 lid.
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`Defendant [flavis Investments. [ne’s address is |0915 SW 132'“ Aves Miami, Fl.
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`2.
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`3
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`4
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`33156.
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`5.
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`The total amount referenced in Paragraph I shall bear interest from the below date
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`at the prevailing legal rate.
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`

`

`CFN: 201801 1499? BOOK SHEETS PAGE 14?1
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`6.
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`It
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`is further ordered and adjudged that Defendants inaII complete under oath
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`Florida Rule of Civil Procedure Form 1.??? {Fact Information Sheet},
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`including all required
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`attachments. and serve it on Plaintiffs alttz-rtleji.r within 45 day's from the date of thisjudgment,
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`unless thejudgment is satisfied or post-judgment discovery is stayed.
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`'i'.
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`Jurisdiction of this case is retained to enter further orders that are proper to
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`compel Defendants to complete Form 1.9T?
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`DDHE AND ORDERED in Chambers at Miami-Dade County, Florida, on UZJZUIIB.
`
` MICHAEL Hartman
`CIRCUIT COURT Juooc“
`
`FINAL ORDERS AS TO ALL PARTIES
`
`. SRS DISPOSITION NUMBER 12
`
`Judge’s initials MH
`
`THE COURT OISMISSES THIS CASE AGAINST
`ANY PARTY NOT USTED IN THIS FINAL ORDER
`' OR PREVIOUS ORDERIS}. THIS OASE IS CLOSED
`AS TO ALL PARTIES.
`
`The parties served with this Order are indicated in the accompanving 11th Circuit email
`confirmation which includes all emails provided by me submitter. The movant shall
`IMMEDIATELY serve a true and correct copv of this Order, by mail, facsimile, email or
`hand-delivery, to all partiesfcounsel of record For whom service is not indicated by the
`accompanying 11th Circuit confirmation, and file proof of service with the Clerk of
`Court.
`
`Signed original order sent electronically to the Clerk of Courts for filing in the Court file.
`Circuit Judge
`
`Copies furnished to all parties
`
`

`

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`WHEREFDRE.
`
`l-ialsey requests the Court to enter judgment in his favor and against
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`Dejanovic and Clovis for damages. pro-judgment and post—judgment interest. attorneys“ fees and
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`eosts. and such further relief as the l[Court deems appropriate.
`
`w
`Unjust E nrichmen t
`
`Halsey re—alleges paragraphs 1—24.
`
`By lending Defendants Sfiflflflfl. Halsey conferred a benefit upon Defendants.
`
`25.
`
`'26.
`
`which Defendants accepted.
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`2?.
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`It would be inequitable for Defendants to retain this benefit without reimbursing
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`Halsey.
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`23.
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`Defendants 1vvill be unjustly enriched if they are not required to reimburse Halsey
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`for the amounts loaned.
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`WHEREFDRE. Ilalsey requests the Court to enter judgment in his favor and against
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`chanovic and Clovis for all damages it incurred as a result ofthe unjust enrichment. including
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`pie-judgment and post-judgment interest. atlomeys‘ fees and costs. and such further relief as the
`
`Court deems appropriate.
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`Cflll NT l‘v'
`Fraud
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`29.
`
`Halsey re—alleges paragraphs I-lzi
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`3D.
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`in February 201?. intending to induce reliance by Halsey. Dej anovic knowingly
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`and falsely represented to Halsey that he needed $15o.ooo to complete a Ciavis funding
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`obligation to a borrower in the self-storage business. and that he would repay Halsey when
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`additional funds were going to be received by Ciavis before the end of May.
`
`

`

`3i.
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`Halsey relied on Dejanovic‘s representation concerning the business purpose of
`
`the loan. and loaned Dejanovie the requested $l fidiififl.
`
`32.
`
`After Dejanovic received the $15ti.d-d-D from Halsev. he used the funds to pay
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`personal expenses rather than for the business purpose he had represented to Halsey. Upon
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`information and belief. Dejanovic never intended to use the funds loaned to him by Halsey for
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`any business purpose
`
`33.
`
`In early l'idaf-tr ’llllT. before the Slfiflflflfl loan became due, intending to induce
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`reliance bv Halsey. Dejanovie knowingly attd falser represented to Halsey that he had millions
`
`of dollars in assets in Switzerland which were being transferred to the United States. and he
`
`needed an additional $lflfl.flflfl
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`three—week bridge loan to cover territn'iptan'j,r expenses until
`
`the
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`alleged millions of dollars would be transferred into his American accounts.
`
`34.
`
`Dejanovic also provided a letter purportedlyr front a Swiss entit},r indicating that
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`$3.5 million was being transferred to Dejanovic. Halsey.
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`in reliance on the letter and
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`Dejanovic‘s representation concerning the intended repayment funds being transferred from
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`Switzerland. loaned Dejanovic the additional iii] flflflflfl.
`
`35.
`
`Upon ittfontiation and belief. the alleged millions ofdollars from Switzerland did
`
`not exist as assets of Dejattovic or Clavi s.
`
`so.
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`As a result of l-lalsev‘s reliance on Defettdattts‘ deliberately false statements.
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`Halsev has suffered damages.
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`WHEREFURE. Halsey requests the Court
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`to enter judgment in his favor and against
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`Dejanovic and Clovis for all damages it incurred as a result of the fraud. including [ire-judgment
`
`and post—judgittent interest. attorneys‘ fees and costs. and such further relief as the Court deems
`
`appropriate.
`
`

`

`CULZ HT V
`
`Collectien el' Worthless Cheeks, Fla. Stat. fififlflftfi
`
`3?.
`
`Halsey re—alleges paragiaphs l—3e.
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`33.
`
`In eenneetien with Premisseiy Nete #L Defendants issued Halsey a eheelt in the
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`ameunt ef $1 Biltltltl dated May 3 1. 2G I T (”Cheek #l"l-.
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`ln ednneetien with Premissery Nete #2,
`
`Deiendants issued Halsey a eheek in the ameunt ef Ellflslflfl (“{Theek #2} {eelleetiyely.
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`the
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`“‘C‘heeks“).
`
`39
`
`The Cheeks were presented fer payment te the drawee. hut payment was refused
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`40.
`
`On August 3'. EDIT. Halsey demanded payittent ef the dishenered Cheeks frettt
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`Defendants. hut Defendants refused. A copy OF Halsey's demand is attaehed as Exhibit C
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`4].
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`Halsey holds the Cheeks. which haye net been paid.
`
`42.
`
`[Defendants ewe Halsey $3fiflflflfl. that is due with interest.
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`43.
`
`Pursuant to § etifléfifll-tal. Fla. Htalq Halsey is enlitled te treble damages. eeurt
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`eests. and attemeya' fees.
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`WHEREFURE. Halsey requests the Court
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`te award hittt damages.
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`together with pre—
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`judgment and pest-judgment interest. attemeys'
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`I'ees and costs. and such further relief as the
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`Cnurt deems appropriate.
`
`Dated: Ueteher 4, 2111?
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`.s'
`
`l-lft’tlt Eris-attract!
`
`Alan Resenthal
`
`Fierida Bar No. 2211333
`
`arnsentital [ttJearltttnfi eldset‘tm
`Charles 'l'hreekmerten
`
`Florida Bar New. 1013]]
`
`
`
`Atterrneys fer Plaintiff
`Carlton Fields
`
`Suite 4201?]
`lflfl SE. Seeend Street
`
`T'ytiami~ Florida 33|31
`
`