Filing # 197180301 E-Filed 04/29/2024 11:59:02 AM
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`RETURN OF SERVICE
`
`State of Florida
`
`County of Miami-Dade
`
`Circuit Court
`
`Case Number: 2024-004901-CA-01
`
`Plaintiff:
`UNITED STATE LIFE SAFETY SERVICES CORP., A FLORIDA
`CORPORATION,
`vs.
`Defendant:
`TOP ACCURACY CORP. D/B/A LOUFIREPROOF, A FLORIDA
`CORPORATION,
`
`For:
`Daniel R. Vega, Esq.
`Delgado Vega PLLC.
`201 Alhambra Cir.
`Ste. 801
`Coral Gables, FL 33134
`
`VER2024000385
`
`Received by One Call Legal, Inc. on the 20th day of March, 2024 at 6:32 pm to be served on TOP ACCURACY
`CORP D/B/A LOUFIREPROOF C/O LOUIS BOLANOS, REGISTERED AGENT, 1756 ALIBABA AVE., UNIT # 2,
`OPA LOCKA, FL 33054.
`
`I, Alberto Rivera, do hereby affirm that on the 24th day of April, 2024 at 3:56 pm, I:
`
`I CORPORATE served a REGISTERED AGENT by delivering a true copy of the Summons and Complaint with
`the date and hour of service endorsed thereon by me, to: LOUIS BOLANOS as Registered Agent at the address
`of: 1756 ALIBABA AVE., OPA LOCKA, FL 33054 on behalf of TOP ACCURACY CORP D/B/A LOUFIREPROOF,
`and informed said person of the contents therein, in compliance with state statutes.
`
`Additional Information pertaining to this Service:
`3/21/2024 12:50 pm SERVICE ATTEMPTED: 1756 ALI BABA AVE, OPA LOCKA, FL - ADDRESS PROVIDED IS
`TO A SMALL THREE APARTMENT PROPERTY.
`CONTACT MADE WITH A FEMALE TENANT WHO RESIDES IN THE FRONT UNIT. SERVER ASKED IF LOUIS
`BOLANOS WAS AVAILABLE AND SHE STATED THAT HE WAS THE OWNER OF THE BUILDING, BUT THAT HE
`WAS NOT THERE.
`SHE CALLED MR BOLANOS AND SERVER WAS ABLE TO SPEAK WITH HIM AND INFORM HIM OF THE
`CONTENTS OF THE SUMMONS AND COMPLAINT.
`MR BOLANOS STATED THAT HE USES THE APARTMENT IN THE REAR OF THE PROPERTY AS HIS OFFICE,
`BUT THAT HE WAS NOT GOING TO BE THERE ANYTIME SOON.
`HE ASKED THE SERVER WHY THE DOCUMENTS WEREN'T FORWARDED TO HIS ATTORNEY. SERVER
`ASKED MR BOLANOS FOR HIS ATTORNEY'S NAME, BUT HE DID NOT PROVIDE IT.
`MR BOLANOS ASKED THE SERVER TO LEAVE HIS CONTACT CARD AND SAID THAT HE WAS GOING TO
`SPEAK WITH HIS ATTORNEY.
`SERVER LEFT HIS CONTACT CARD WITH THE FEMALE TENANT.
`3/26/2024 11:25 am SERVICE ATTEMPTED AT: 1756 ALI BABA AVE, OPA LOCKA, FL - SERVER WAS
`INFORMED BY ONE OF THE TENANTS THAT LOUIS BOLANOS WAS NOT AT THE PROPERTY.
`3/26/2024 3:20 pm SERVICE ATTEMPTED: 610 NW 58TH CT, MIAMI, FL - CONTACT MADE WITH A WHITE
`HISPANIC FEMALE, CURRENT TENANT, WHO STATED THAT SHE KNOWS LOUIS BOLANOS, BUT THAT HE
`DOES NOT LIVE THERE.
`
`SHE INFORMED THE SERVER THAT LOUIS BOLANOS AND HER SPOUSE WERE PREVIOUS BUSINESS
`PARTNERS, BUT THEY STOPPED WORKING TOGETHER APPROXIMATELY THREE YEARS AGO. SHE SAID
`THAT HER SPOUSE IS NO LONGER ASSOCIATED TO THE BUSINESS OR LOUIS BOLANOS.
`3/27/2024 1:45 pm SERVICE ATTEMPTED AT: 5801 SW 9TH TER, MIAMI, FL - PER CURRENT TENANT, LOUIS
`BOLANOS IS THE OWNER OF THE HOME, BUT DOES NOT RESIDE AT THIS ADDRESS. HE STATED THAT HE
`RENTS THE HOME FROM MR BOLANOS.
`
`

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`RETURN OF SERVICE For 2024-004901-CA-01
`
`SUBJECT SHOWED ME A PAPER WITH AN ADDRESS IN OAKLAND, CA AND A PHONE NUMBER OF
`415-517-6767.
`3/28/2024 11:20 am SERVICE ATTEMPTED AT: 1756 ALI BABA AVE, OPA LOCKA, FL - PER TENANT IN UNIT 1,
`LOUIS BOLANOS WAS NOT AT THE PROPERTY.
`HE STOPPED BY YESTERDAY AND DROPPED OFF HIS ATTORNEY'S BUSINESS CARD AND SAID THAT HE
`SHOULD BE CONTACTED ABOUT THE SUBPOENA.
`4/5/2024 2:15 pm SERVICE ATTEMPTED: 2145 NW 84TH STREET, MIAMI, FL - PER CURRENT TENANT,
`LOUIS BOLANOS OWNS THE PROPERTY, BUT HE DOES NOT RESIDE THERE.
`SHE DOES NOT HAVE ANY INFORMATION ON HIS CURRENT WHEREABOUTS AS HE ONLY STOPS BY TO
`PICK UP THE RENT.
`4/24/2024 3:56 pm SERVICE ATTEMPTED AT: 1756 ALI BABA AVE, OPA LOCKA, FL - AT APPROXIMATELY 3:50
`PM SERVER ARRIVED AT THE PROPERTY AND OBSERVED A TENANT WALKING ON THE SIDE OF THE
`PROPERTY AND ALSO SOME VEHICLES PARKED IN THE REAR OF THE PROPERTY BEHIND THE LOCKED
`GATES.
`AT APPROXIMATELY 3:55 PM, SERVER OBSERVED A WHITE MALE ARRIVE AT THE PROPERTY IN A SMALL
`WHITE CHEVY. THE MALE INDIVIDUAL GOT OUT OF THE CAR AND BEGAN TO SPEAK TO THE WOMAN IN
`THE YARD.
`SERVER QUICKLY APPROACHED THE MAN AND CALLED HIM BY THE NAME, LOUIS BOLANOS.
`THE MAN TURNED AND CONFIRMED TO THE SERVER THAT HE WAS LOUIS BOLANOS.
`SERVER INFORMED HIM OF THE CONTENTS OF THE DOCUMENTS AND THAT HE WAS SERVING HIM AS
`REGISTERED AGENT.
`MR BOLANOS QUICKLY BECAME UPSET AND SAID THAT HE WASN'T ACCEPTING ANY DOCUMENTS. HE
`TOOK OUT HIS ATTORNEY'S BUSINESS CARD AND SAID THAT SERVICE SHOULD BE MADE ON HIM.
`SERVER INFORMED MR BOLANOS THAT CONTACT WITH HIS ATTORNEY WAS NOT SUCCESSFUL AND
`THAT HE WAS BEING SERVED.
`MR BOLANOS, BECAME VERY UPSET AND IMMEDIATELY STARTED RECORDING THE SERVER WITH HIS
`PHONE CAMERA. IN ADDITION TO RECORDING, MR BOLANOS BEGAN TO USE FOWL LANGUAGE
`TOWARDS THE SERVER IN FRONT OF HIS TENANT.
`SERVER NOTICED THAT MR BOLANOS WAS VERY UPSET AND NEARING A POINT OF GETTING
`AGGRESSIVE.
`IN AN EFFORT TO AVOID ANY FURTHER ESCALATION OF THE SITUATION AND ANY PHYSICAL VIOLENCE,
`SERVER INFORMED MR BOLANOS THAT HE HAD BEEN SERVER AND WAS LEAVING THE DOCUMENTS FOR
`HIM FOR HIS REFUSAL TO TAKE THEM IN HAND.
`AFTER PLACING THE DOCUMENTS AT MR BOLANOS' FEET, SERVER TURNED AND BEGAN TO WALK BACK
`TO HIS CAR.
`MR BOLANOS CONTINUED TO FOLLOW THE SERVER BACK TO HIS CAR WHILE STILL RECORDING AND
`USING FOWL LANGUAGE.
`AS SERVER ENTERED HIS VEHICLE, MR BOLANOS WALKED TO THE REAR OF THE VEHICLE AND
`PROCEEDED TO RECORD AND PHOTOGRAPH THE SERVER AUTO TAG.
`FEARING THAT MR BOLANOS WOULD HAVE THIS INFORMATION TO RETALIATE AGAINST THE SERVER IN
`THE FUTURE, SERVER TOOK PHOTOS OF MR BOLANOS AND RECORDED HIM AS HE WALKED BACK TO
`HIS VEHICLE.
`AS MR BOLANOS WALKED AWAY, HE CONTINUED TO CURSE AT THE SERVER AND USED OBSCENE HAND
`GESTURES, GRABBING HIS GENITALS.
`
`SERVER LATER OBSERVED WHEN MR BOLANOS DROVE AWAY LEAVING THE SUMMONS AND COMPLAINT
`ON THE SIDEWALK WHERE HE HAD ORIGINALLY BEEN SERVED.
`
`Description of Person Served: Age: 65, Sex: M, Race/Skin Color: WHITE, Height: 5'8, Weight: 140, Hair:
`BALDING, Glasses: Y
`
`

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`RETURN OF SERVICE For 2024-004901-CA-01
`
`I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, in
`good standing, in the judicial circuit in which the process was served. Under penalty of perjury, I declare that I have
`read the foregoing document and that the facts stated in it are true. No notary required per FL. Stat. 92.525(2).
`
`Alberto Rivera
`C.P.S. # 1921
`
`One Call Legal, Inc.
`10 Canal Street, # 222
`Miami Springs, FL 33166
`(305) 460-8077
`
`Our Job Serial Number: VER-2024000385
`
`Copyright © 1992-2024 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2k
`
`

`

`Filing # 194338172 E-Filed 03/19/2024 01:38:21 PM
`
`IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
`IN AND FOR MIAMI-DADE COUNTY, FLORIDA
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CASE NO: 2024-004901-CA-01
`
`
`
`
`UNITED STATE LIFE SAFETY SERVICES
`CORP., a Florida corporation,
`
`
`
`
`v.
`
`TOP ACCURACY CORP D/B/A
`LOUFIREPROOF, a Florida corporation,
`
`Defendant.
`
`______________________________________/
`
`
`SUMMONS
`
`THE STATE OF FLORIDA
`TO EACH SHERIFF OF THE STATE:
`
`YOU ARE COMMANDED to serve this summons a copy of the Amended Complaint in this action
`to the defendant:
`
`
`TOP ACCURACY CORP D/B/A LOUFIREPROOF
`By Serving its Registered Agent: Louis Bolanos
`1756 Alibaba Avenue, Unit #2
`Opa Locka, FL 33054
`
`
`The defendant is required to serve written defenses to the Complaint on plaintiff’s attorney, whose
`name and address is: Ceasar X. Delgado, Esq (ceasar@delgadovega.com) /Daniel R. Vega, Esq.
`(dan@delgadovega.com), Delgado Vega PLLC, 201 Alhambra Circle, Suite 801, Coral Gables, FL
`33134, within 20 days after service of this Summons upon that defendant, exclusive of the day of
`service, and to file the original of the written defenses with the clerk of this court either before
`service on plaintiff’s attorney or immediately thereafter. If a defendant fails to do so, a default will
`be entered against that defendant for the relief demanded in the complaint.
`
`3/19/2024
`Dated ________________________
`
`
`
`
`
`
`JUAN FERNANDEZ-BARQUIN,
`Clerk of the Courts
`
`_______________________
`Deputy Clerk
`
`
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`DANIEL R. VEGA, BCS
`Florida Bar No. 148120
`Ceasar X. Delgado, Esq.
`Florida Bar No. 98483
`DELGADO VEGA PLLC
`201 Alhambra Circle, Suite 801
`Coral Gables, Florida 33134
`Telephone: (305) 452-7000
`Attorneys for Plaintiff
`
`
`
`
`By:
`
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`
`