Filing # 130530986 E-Filed 07/13/2021 11:20:59 AM
`
`In the Circuit Court of the Eleventh Judicial Circuit
`in and for Miami-Dade County, Florida
`
`General Jurisdiction Division
`
`Case No.
`
`
`
`Plaintiff,
`
`
`Global Biologics, LLC,
`
`
`
`vs.
`
`Health Medical Equipment, Inc., Crown
`Global Holdings, Inc. and Fernando Gonzalez,
`
` Defendants.
`
`__________________________________/
`
`
`Complaint
`The Plaintiff, Global Biologics, LLC (hereinafter referred to as “Plaintiff”), by and
`
`
`
`through the undersigned attorneys files this verified complaint against Defendants, Health
`
`Medical Equipment, Inc. (hereinafter referred to as “Health Equip.”), Crown Global
`
`Holdings, Inc. (hereinafter referred to as “Crown Global”) and Fernando Gonzalez
`
`(hereinafter referred to as “Gonzalez”) and in support states as follows:
`
`Common Allegations
`Parties, Jurisdiction and Venue
`
`Plaintiff is a Florida limited liability company existing by virtue of the laws
`
`1.
`
`of the State of Florida.
`
`2.
`
`3.
`
`4.
`
`Defendant, Health Equip. is a Florida corporation.
`
`Defendant, Crown Global is a Florida corporation.
`
`At all times material hereto, Defendant, Gonzalez, was, and is, a Florida
`
`resident residing in Miami-Dade County and is otherwise sui juris. Moreover at all times
`
`relevant hereto Defendant Gonzalez, was the president of Crown Global.
`
`
`
`1
`
`
`
`In the Circuit Court of the Eleventh Judicial Circuit
`in and for Miami-Dade County, Florida
`
`General Jurisdiction Division
`
`Case No.
`
`
`
`Plaintiff,
`
`
`Global Biologics, LLC,
`
`
`
`vs.
`
`Health Medical Equipment, Inc., Crown
`Global Holdings, Inc. and Fernando Gonzalez,
`
` Defendants.
`
`__________________________________/
`
`
`Complaint
`The Plaintiff, Global Biologics, LLC (hereinafter referred to as “Plaintiff”), by and
`
`
`
`through the undersigned attorneys files this verified complaint against Defendants, Health
`
`Medical Equipment, Inc. (hereinafter referred to as “Health Equip.”), Crown Global
`
`Holdings, Inc. (hereinafter referred to as “Crown Global”) and Fernando Gonzalez
`
`(hereinafter referred to as “Gonzalez”) and in support states as follows:
`
`Common Allegations
`Parties, Jurisdiction and Venue
`
`Plaintiff is a Florida limited liability company existing by virtue of the laws
`
`1.
`
`of the State of Florida.
`
`2.
`
`3.
`
`4.
`
`Defendant, Health Equip. is a Florida corporation.
`
`Defendant, Crown Global is a Florida corporation.
`
`At all times material hereto, Defendant, Gonzalez, was, and is, a Florida
`
`resident residing in Miami-Dade County and is otherwise sui juris. Moreover at all times
`
`relevant hereto Defendant Gonzalez, was the president of Crown Global.
`
`
`
`1
`
`
`
`5.
`
`Venue is proper in Miami-Dade County, Florida because the Defendant
`
`Gonzalez resides in Miami-Dade County, because Defendants Health Equip. and Crown
`
`Global maintain their respective principal places of business in Miami-Dade County and
`
`because the facts and occurrences giving rise to the causes of action occurred in Miami-
`
`Dade County.
`
`6.
`
`Plaintiff has retained the undersigned counsel in order that his rights and
`
`interests may be protected. Plaintiff has become obligated to pay the undersigned a
`
`reasonable attorney's fee. Plaintiff shall seek prevailing party fees pursuant to Florida
`
`Statutes and terms of the documents sought to be enforced herein as applicable.
`
`7.
`
`All conditions precedent to bringing this action have occurred, been
`
`performed or excused.
`
`
`
`
`Factual Allegations
`
`A.
`
`8.
`
`Transaction Concerning Nutreceutics
`
`On or about early 2020, Plaintiff secured the sale of fifty (50) Trilogy Evo
`
`Life Support Respirators (the “Respirators”) (the “First Order”), to its client a Panamanian
`
`company, Nutreceutics SA (“Nutreceutics”).
`
`9.
`
`On or about March of 2020, Plaintiff contracted with Health Equip. and
`
`Crown Global to supply the Respirators.
`
`10.
`
`Plaintiff, Health Equip. and Crown Global agreed that Health Equip. and
`
`Crown Global would order Respirators and have them shipped to Nutreceutics.
`
`11.
`
`The parties agreed that the profits generated from the sale of the Respirators
`
`to Nutreceutics would be divided in equal parts, one half of profits distributed to Plaintiff,
`
`and the other half of the profits distributed to Health Equip. and Crown Global.
`
`
`
`2
`
`
`
`12.
`
`Ultimately, fifty (50) Respirators were delivered to Nutreceutics in
`
`fulfillment of the First Order and payment of the purchase price was made by Nutreceutics
`
`directly to Health Equip. and Crown Global by Nutreceutics for the amount Nutreceutics
`
`and Plaintiff agreed to, $649,750.00.
`
`13.
`
`Up to this point, the transaction occurred precisely as the parties agreed
`
`upon.
`
`14.
`
`Nutreceutics thereafter ordered an additional fifty (50) Respirators from
`
`Global (the “Second Order”).
`
`15.
`
`After receiving the funds from the sale of the First Order to Nutreceutics,
`
`Plaintiff, Health Equip. and Crown Global agreed that instead of dividing the profits
`
`associated with the First Order of the Respirators, the parties would use the funds towards
`
`the order of an additional fifty (50) Respirators from the manufacturer, Phillips Respironics
`
`(“Phillips”).
`
`16.
`
`Upon fulfilling the Second Order, Plaintiff, Health Equip. and Crown
`
`Global would split the profits in equal parts, one half of the profits unto Plaintiff and the
`
`other half unto Health Equip. and Crown Global.
`
`17.
`
`In total, the profits to be divided among Plaintiff and Health Equip. and
`
`Crown Global would correspond to the sale of one hundred (100) Respirators after the
`
`fulfillment of the Second Order (the First and Second Order each being for fifty
`
`respirators).
`
`18.
`
`Health Equip. and Crown Global placed an order with Phillips for fifty (50)
`
`Respirators in connection with the Second Order, and informed Plaintiff that payment in
`
`the amount of $324,750.00 was made to Phillips in connection with the order. The fact is
`
`
`
`3
`
`
`
`that Health Equip. and Crown Global only made payment to Phillips in the amount of
`
`$65,000.00. This was confirmed by Phillips.
`
`19.
`
`Accordingly, Phillips shipped only the Respirators for which it received
`
`payment, ten (10) Respirators at a cost of $6,500.00 each. Health Equip. and Crown Global
`
`delivered these ten (10) Respirators to Nutreceutics and Nutreceutics currently has
`
`possession of these ten (10) Respirators, which did not fulfill the Second Order for fifty
`
`(50) respirators and as a consequence Nutreceutics seeks to return them unto Plaintiff
`
`and/or Health Equip. and Crown Global.
`
`20.
`
`To date, the profits from the First Order have not been tendered to Plaintiff,
`
`and additionally, Health Equip. and Crown Global did not reinvest the funds towards the
`
`placement of the Second Order.
`
`21.
`
`Health Equip. and Crown Global acted in bad faith and made
`
`misrepresentations, alleging that payment for the Second Order was made to Phillips, when
`
`only $65,000.00 was paid.
`
`
`
`B.
`
`22.
`
`Transaction Concerning World Target
`
`On or about late 2020, Plaintiff secured the sale of certain medical products
`
`to its customer in Panama, World Target S.A. (“World Target”).
`
`23.
`
`In connection with the foregoing, Plaintiff contracted with Health Equip.
`
`and Crown Global to supply the products in connection with the sale.
`
`24.
`
`As part of the arrangement, World Target made payment directly unto
`
`Health Equip. and Crown Global in the amount of $12,369.00, half of the invoice amount,
`
`as a deposit. The remaining half of the purchase payment would be made upon delivery of
`
`the order to World Target.
`
`
`
`4
`
`
`
`25.
`
`Health Equip. and Crown Global failed to uphold their portion of the
`
`agreement - only a small delivery of product contracted for was ever made to World Target,
`
`with a value of $339.00.
`
`26.
`
`The remainder of the $25,078.00 order went unfulfilled, notwithstanding
`
`Health Equip. and Crown Global having received a $12,369.00 deposit towards the order.
`
`27.
`
`Due to the extended period elapsed since the order was placed, World
`
`Target no longer requires the delivery of the remaining product, and instead requests a
`
`refund from Plaintiff.
`
`Count I – Breach of Contract
`(Health Equip. and Crown Global re: World Target)
`
`28.
`
`Paragraphs 1 through 21 are repeated and realleged as if fully set forth
`
`
`
`herein.
`
`29.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`30.
`
`In March 2020, Plaintiff and Defendants, Health Equip. and Crown Global
`
`entered into a verbal agreement whereby Defendants, Health Equip. and Crown Global
`
`would supply Respirators to Nutreceutics and the parties would share in profits generated
`
`from the sale of the Respirators to Nutreceutics in equal parts - one half of profits
`
`distributed to Plaintiff, and the other half of the profits distributed to Health Equip. and
`
`Crown Global (hereinafter referred to as the “Nutreceutics Agreement”).
`
`31.
`
`32.
`
`Plaintiff performed all his obligations under the Nutreceutics Agreement.
`
`Notwithstanding Defendants, Health Equip. and Crown Global breached the
`
`Nutreceutics Agreement by failing to (i) pay Plaintiff profits to which Plaintiff is entitled
`
`
`
`5
`
`
`
`in connection with the First order, the total being $162,250.00, and (ii) fulfill the Second
`
`Order.
`
`33.
`
`As a result of Defendants, Health Equip. and Crown Global’s breaches,
`
`Plaintiff has been damaged in the sum of $162,250.00.
`
`
`
`Wherefore Plaintiff demands judgment against Defendants, Health Equip. and
`
`Crown Global for damages, together with costs and interest pursuant to the Florida Statutes,
`
`and such other relief as the Court may deem just and proper.
`
`Count II – Breach of Contract
`(Health Equip. and Crown Global re: Nutreceutics)
`
`34.
`
`Paragraphs 1 through 7 and 22 through 27 are repeated and realleged as if
`
`
`
`fully set forth herein.
`
`35.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`36.
`
`On or about late 2020, Plaintiff secured the sale of certain medical products
`
`to its customer in Panama, World Target.
`
`37.
`
`In connection with the foregoing, Plaintiff contracted with Health Equip.
`
`and Crown Global to supply the products in connection with the sale.
`
`38.
`
`As part of the arrangement, World Target made payment directly unto
`
`Health Equip. and Crown Global in the amount of $12,369.00, half of the invoice amount,
`
`as a deposit. The remaining half of the purchase payment would be made upon delivery of
`
`the order to World Target.
`
`39.
`
`The profits generated from the sale of medical products to World Target
`
`would be split equally between the parties ((hereinafter referred to as the “the World Target
`
`Agreement”).
`
`
`
`6
`
`
`
`40.
`
`Notwithstanding Plaintiff’s performance of its obligations under the World
`
`Target Agreement, Defendants, Health Equip. and Crown Global failed to uphold their
`
`portion of the World Target Agreement - only a small delivery of product contracted for
`
`was ever made to World Target, with a value of $339.00.
`
`41.
`
`The remainder of the $25,078.00 order went unfulfilled, notwithstanding
`
`Defendants, Health Equip. and Crown Global having received a $12,369.00 deposit
`
`towards the order.
`
`42.
`
`Due to the extended period elapsed since the order was placed, World
`
`Target no longer requires the delivery of the remaining product, and instead requests a
`
`refund from Plaintiff.
`
`43.
`
`As a result of Defendants, Health Equip. and Crown Global’s breaches,
`
`Plaintiff has been damaged in the sum of $12,369.00, the amount Plaintiff is obligated to
`
`pay back to World Target.
`
`
`
`Wherefore Plaintiff demands judgment against Defendants, Health Equip. and
`
`Crown Global for damages, together with costs and interest pursuant to the Florida Statutes,
`
`and such other relief as the Court may deem just and proper.
`
`Count III – Conversion
`(Health Equip., Crown Global and Gonzalez)
`
`Paragraphs 1 through 27 are repeated and realleged as if fully set forth
`
`44.
`
`herein.
`
`45.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`46.
`
`Plaintiff is entitled to share in the profits generated from the business
`
`transacted with Nutreceutics.
`
`
`
`7
`
`
`
`47.
`
`Notwithstanding, Defendants Health Equip., Crown Global and Gonzalez,
`
`knowingly and deliberately and without justification and intentionally converted Plaintiff’s
`
`share, to wit: $162,250.00 for their own personal use.
`
`48.
`
`Additionally, Defendants, Health Equip., Crown Global and Gonzalez,
`
`converted the sum of $12,369.00 which they received from World Target and now Plaintiff
`
`is obligated to pay back to World Target.
`
`49.
`
`As a result of the foregoing, Plaintiff has been damaged in the sum of
`
`$174,619.00.
`
`Wherefore, Plaintiff demands judgment against Defendants, Health Equip., Crown
`
`Global and Gonzalez for damages together with interest and costs pursuant to Florida
`
`Statutes and such other relief as the Court deems just and proper.
`
`Count IV - Fraud/Constructive Fraud
`(Gonzalez)
`
`Paragraphs 1 through 27 are repeated and realleged as if fully set forth
`
`50.
`
`herein.
`
`51.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`52.
`
`As partners in the Nutreceutics and World Target Agreements, Gonzalez
`
`owed fiduciary duties to Plaintiff; however, Defendant Gonzalez abused the fiduciary
`
`relationship with Plaintiff and took unconscionable advantage of the relationship at the
`
`expense of Plaintiff.
`
`53.
`
`Defendant Gonzalez engaged in a scheme whereby he fraudulently
`
`converted funds rightfully due onto Plaintiff and in an effort to divest Plaintiff of funds in
`
`which he either beneficially owned or is entitled to (despite Plaintiff having performed his
`
`
`
`8
`
`
`
`end of the deals), Gonzalez misrepresented the status of payment to the supplier of the
`
`products purchased by Nutreceutics from Defendants, Health Equip. and Crown Global.
`
`54. More recently, Defendant Gonzalez has, and continues to, conceal profits
`
`generated from the sale to Plaintiff’s customers by failing to respond to Plaintiff’s inquiries
`
`regarding same and by failing to account to Plaintiff.
`
`55.
`
`Defendant Gonzalez achieved this by concealing and/or refusing to produce
`
`financial documents related to profits generated for the purpose of converting Plaintiff’s
`
`share of profits.
`
`56.
`
`All of the foregoing actions were taken by Defendant Gonzalez to defraud
`
`Plaintiff.
`
`57.
`
`Plaintiff has been damaged by Defendant Rodriguez’s action in the sum of
`
`$174,619.00.
`
`
`
`Wherefore Plaintiff demands judgment against Defendant Gonzalez for damages
`
`(including punitive damages) together with costs and interest pursuant to Florida Statute
`
`and such other relief as this Court deems just and proper.
`
`Count V - Quantum Meruit
`(Health Equip., Crown Global and Gonzalez)
`
`Paragraphs 1 through 27 are repeated and realleged as if fully set forth
`
`58.
`
`herein.
`
`59.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`60.
`
`Plaintiff performed all duties required of him by procuring customers for
`
`Defendants, Health Equip. and Crown Global.
`
`61.
`
`At all times material hereto, Defendants, Health Equip., Crown Global and
`
`
`
`9
`
`
`
`Gonzalez were aware of the foregoing and Defendants, Health Equip., Crown Global and
`
`Gonzalez acquiesced and benefitted from Plaintiff’s contributions to the transactions
`
`involving Nutreceutics and World Target all of which were accepted by Defendants
`
`Umbrella Holdings and Rodriguez.
`
`62.
`
`Under ordinary circumstances a reasonable person would reasonably expect
`
`to pay for such benefits, notwithstanding, Defendants, Health Equip., Crown Global and
`
`Gonzalez have failed to compensate Plaintiff.
`
`63.
`
`Defendants, Health Equip., Crown Global and Gonzalez have been unjustly
`
`enriched by virtue of the foregoing.
`
`64.
`
`A reasonable sum for the contribution Plaintiff provided to Defendants,
`
`Health Equip., Crown Global and Gonzalez is $174,619.00 or any part thereof.
`
`
`
`Wherefore Plaintiff demands judgment against Defendants, Health Equip., Crown
`
`Global and Gonzalez for damages, together with costs and interest pursuant to the Florida
`
`Statutes, and such other relief as the Court may deem just and proper.
`
`Count VI - Unjust Enrichment
`(Health Equip., Crown Global and Gonzalez)
`
`Paragraphs 1 through 27 are repeated and realleged as if fully set forth
`
`65.
`
`herein.
`
`66.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`67.
`
`Plaintiff conferred a benefit upon Defendants, Health Equip., Crown Global
`
`and Gonzalez by procuring customers for Defendants, Health Equip. and Crown Global.
`
`68.
`
`Defendants, Health Equip., Crown Global and Gonzalez appreciated these
`
`benefits and were thereby enriched.
`
`
`
`10
`
`
`
`69.
`
`However, Defendants, Health Equip., Crown Global and Gonzalez have not
`
`paid amounts due to Plaintiff specifically, the sum of $174,619.00 as required.
`
`70.
`
`Defendants, Health Equip., Crown Global and Gonzalez accepted and has
`
`retained the aforementioned benefit under circumstances that make it inequitable to do so
`
`without repaying these benefits.
`
`
`
`Wherefore Plaintiff demands judgment against Defendants, Health Equip., Crown
`
`Global and Gonzalez for damages, together with costs and interest pursuant to the Florida
`
`Statutes, and such other relief as the Court may deem just and proper.
`
`Count VII - Fraudulent Inducement
`(Gonzalez)
`
`Plaintiff reaffirms and realleges the allegations contained in paragraphs 1
`
`71.
`
`through 27 as if fully set forth herein.
`
`72.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`73.
`
`Prior to and during negotiations leading up to the Nutreceutics and World
`
`Target Agreements and indeed at all times subsequent thereto, Defendant Gonzalez
`
`represented to Plaintiff that profits would be split as agreed to by the parties.
`
`74.
`
`At all times relevant hereto, Defendant Gonzalez knew that the foregoing
`
`representations was false.
`
`75.
`
`Instead, Defendant Gonzalez waited until Plaintiff procured clients and
`
`when payment was made to Defendants Health Equip. and Crown Global, Defendants,
`
`Health Equip., Crown Global and Gonzalez converted Plaintiff’s share of the profits.
`
`76.
`
`Accordingly, Defendant Gonzalez’s representations were false at the time
`
`they were made and Defendant Gonzalez knew or should have known such representations
`
`
`
`11
`
`
`
`to be false at the time they were made.
`
`77.
`
`Defendant Gonzalez made such false representations for the purpose and
`
`with the intent that Plaintiff would act in reliance thereof, and procure clients.
`
`78.
`
`Prior to, at the time the agreements referenced in counts I and II were
`
`entered into and subsequent to the entry into same, Plaintiff was unaware of the falsity of
`
`Defendant Gonzalez’s representations, and Plaintiff entered into the agreements and
`
`performed in accordance to the terms of same in justifiable reliance on Defendant
`
`Gonzalez’s false representations.
`
`79.
`
`Plaintiff was justified in his reliance on Defendant Gonzalez’s statements
`
`and representations because Plaintiff lacked the knowledge necessary to discover the fraud.
`
`80.
`
`If Plaintiff had known Defendant Gonzalez would not have honored the
`
`parties’ understanding, Plaintiff would not have entered into the agreements nor performed
`
`work as obligated.
`
`81.
`
`Plaintiff has been damaged by acting in reliance on Defendant Gonzalez’s
`
`false representations.
`
`
`
`Wherefore Plaintiff demands judgment against Defendant Gonzalez (Plaintiff
`
`reserves the right to assert a claim for punitive damages in due course), together with costs
`
`and interest, and such other relief as the Court may deem just and proper.
`
`Count VIII - Fraudulent Misrepresentation
`(Gonzalez)
`
`Plaintiff reaffirms and realleges the allegations contained in paragraphs 1
`
`82.
`
`through 27 as if fully set forth herein.
`
`83.
`
`This is an action for damages that exceed $30,000.00, exclusive of costs and
`
`interest.
`
`
`
`12
`
`
`
`84.
`
`Prior to and during negotiations leading up to the Nutreceutics and World
`
`Target Agreements and indeed at all times subsequent thereto, Defendant Gonzalez
`
`represented to Plaintiff that profits would be split as agreed to by the parties.
`
`85.
`
`At all times relevant hereto, Defendant Gonzalez knew that the foregoing
`
`representations was false.
`
`86.
`
`Instead, Defendant Gonzalez waited until Plaintiff procured clients and
`
`when payment was made to Defendants Health Equip. and Crown Global, Defendants,
`
`Health Equip., Crown Global and Gonzalez converted Plaintiff’s share of the profits.
`
`87.
`
`Accordingly, Defendant Gonzalez’s representations were false at the time
`
`they were made and Defendant Gonzalez knew or should have known such representations
`
`to be false at the time they were made.
`
`88.
`
`Defendant Gonzalez made such false representations for the purpose and
`
`with the intent that Plaintiff would act in reliance thereof, and procure clients.
`
`89.
`
`Prior to, at the time the agreements referenced in counts I and II were
`
`entered into and subsequent to the entry into same, Plaintiff was unaware of the falsity of
`
`Defendant Gonzalez’s representations, and Plaintiff entered into the agreements and
`
`performed in accordance to the terms of same in justifiable reliance on Defendant
`
`Gonzalez’s false representations.
`
`90.
`
`Plaintiff was justified in his reliance on Defendant Gonzalez’s statements
`
`and representations because Plaintiff lacked the knowledge necessary to discover the fraud.
`
`91.
`
`If Plaintiff had known Defendant Gonzalez would not have honored the
`
`parties’ understanding, Plaintiff would not have entered into the agreements nor performed
`
`work as obligated.
`
`
`
`13
`
`
`
`92.
`
`Plaintiff has been damaged by acting in reliance on Defendant Gonzalez’s
`
`false representations.
`
`
`
`Wherefore Plaintiff demands judgment against Defendant Gonzalez (Plaintiff
`
`reserves the right to assert a claim for punitive damages in due course), together with costs
`
`and interest, and such other relief as the Court may deem just and proper.
`
`Count IX - Piercing the Corporate Veil based on Fraud, Conversion and Fraudulent
`Inducement
`(Crown Global and Gonzalez)
`
`Plaintiff reaffirms and realleges the allegations contained in paragraphs 1
`
`93.
`
`through 27 as if fully set forth herein
`
`94.
`
`At all times relevant hereto Defendant Crown Global was owned and
`
`managed by Defendant Gonzalez.
`
`95.
`
`Upon information and belief, Defendant Gonzalez is actually the alter ego
`
`of Defendant, Crown Global and as its manager and member, Defendant Gonzalez
`
`dominates and controls Defendant Crown Global; and Defendant Crown Global was
`
`organized, or after it was organized was employed, by the Defendant Gonzalez for
`
`fraudulent or misleading purposes. Specifically, Defendant Crwon Global was organized
`
`to divert and usurp profits and revenues from Plaintiff and to tortuously divest Plaintiff of
`
`his interest in same. Moreover, Defendant Crown Global was set up to divest Plaintiff of
`
`funds which he is entitled to via profits generated from sales to Plaintiff’s customers.
`
`96.
`
`Such conduct by Defendants, Crown Global and Gonzalez caused injury to
`
`the Plaintiff.
`
`97.
`
`Upon information and belief, Defendants, Crown Global and Gonzalez
`
`commingled bank accounts and funds of one another and they converted monies received
`
`
`
`14
`
`
`
`from Defendant Crown Global for their own benefit and use.
`
`98.
`
`At all times material hereto, Defendant Crown Global disregarded its
`
`corporate structure and operated for the benefit of Defendant, Gonzalez.
`
`99.
`
`Accordingly, Defendant, Gonzalez is personally liable for the debts of
`
`Defendant Crown Global and vice versa.
`
`100. Recognition of the corporate entity of Defendant, Crown Global by this
`
`Court would permit the Defendant Gonzalez to commit fraud, evade personal responsibility
`
`and perpetrate injustice.
`
`
`
`Wherefore, Plaintiff respectfully requests judgment against Crown Global and
`
`Gonzalez for damages, including costs pursuant to the Florida Statutes and any other
`
`further relief this court deems just and proper.
`
`Demand For Jury Trial
`
`Plaintiff demands a trial by jury on all counts so triable.
`
`Garcia-Menocal Irias & Pastori LLP
`368 Minorca Avenue
`Coral Gables, FL 33134
`T: (305) 400-9652
`C: (305) 898-3577
`E-mail: jgm@gmilaw.com
`
`By: Jorge Garcia-Menocal
`Jorge A. Garcia-Menocal, Esq.
`
`Fla. Bar. # 17990
`
`Dated: July 13, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`15
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
