`
`FORM 1.997. CIVIL COVER SHEET
`
`The civil cover sheet and the information contained in it neither replace nor supplement the filing
`and service of pleadings or other documents as required by law. This form must be filed by the
`plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant
`to section 25.075, Florida Statutes. (See instructions for completion.)
`
`I.
`
`CASE STYLE
`
`
`
`IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
`IN AND FOR MIAMI-DADE COUNTY, FLORIDA
`
`IRMD Consulting, LLC, Tomorrowpay LLC, Richard Binns, Elochukwu Obimdike, Nathan
`DeYoung, Dylan Deselin,
`Margo Woodall, Roberto
`Luis Peinado Serradell,
`Vandrea Johnson, Josh
`Hawton, Hythum Ismail,
`Tarquin Vesagas, Rita
`Vesagas, HFA LLC,
`Resiliency LLC, Danat, LLC
`Case #
`Judge
`
`Plaintiff
`
`
`
`vs.
`HFA Consulting LLC, Anthony Agyeman, Megan Shears, Steve Golden, Hands Free Automation,
`Wealthway, 5 Stars Vacation Realty
`Defendant
`
`AMOUNT OF CLAIM
`II.
`Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of
`the claim is requested for data collection and clerical processing purposes only. The amount of the claim
`shall not be used for any other purpose.
`
` ☐ $8,000 or less
`☐ $8,001 - $30,000
`☐ $30,001- $50,000
`☐ $50,001- $75,000
`☐ $75,001 - $100,000
`☒ over $100,000.00
`
`TYPE OF CASE
`III.
`(If the case fits more than one type of case, select the most
`definitive category.) If the most descriptive label is a subcategory (is indented under a broader
`category), place an x on both the main category and subcategory lines.
`
`- 1 -
`
`
`
`CIRCUIT CIVIL
`☐ Condominium
`☒ Contracts and indebtedness
`☐ Eminent domain
`☐ Auto negligence
`☐ Negligence—other
`☐ Business governance
`☐ Business torts
`☐ Environmental/Toxic tort
`☐ Third party indemnification
`☐ Construction defect
`☐ Mass tort
`☐ Negligent security
`☐ Nursing home negligence
`☐ Premises liability—commercial
`☐ Premises liability—residential
`☐ Products liability
` ☐ Real Property/Mortgage foreclosure
`☐ Commercial foreclosure
`☐ Homestead residential foreclosure
`☐ Non-homestead residential foreclosure
`☐ Other real property actions
`
`☐Professional malpractice
`☐ Malpractice—business
`☐ Malpractice—medical
`☐ Malpractice—other professional
`☐ Other
`☐ Antitrust/Trade regulation
`☐ Business transactions
`☐ Constitutional challenge—statute or ordinance
`☐ Constitutional challenge—proposed amendment
`☐ Corporate trusts
`☐ Discrimination—employment or other
`☐ Insurance claims
`☐ Intellectual property
`☐ Libel/Slander
`☐ Shareholder derivative action
`☐ Securities litigation
`☐ Trade secrets
`☐ Trust litigation
`
`COUNTY CIVIL
`☐ Small Claims up to $8,000
`☐ Civil
`☐ Real property/Mortgage foreclosure
`
`- 2 -
`
`
`
`☐ Replevins
`☐ Evictions☐ Residential Evictions
`☐ Non-residential Evictions
`☐ Other civil (non-monetary)
`
`COMPLEX BUSINESS COURT
`
`This action is appropriate for assignment to Complex Business Court as delineated and mandated by the
`Administrative Order. Yes ☐ No ☒
`
`REMEDIES SOUGHT (check all that apply):
`IV.
`☒ Monetary;
`☐ Nonmonetary declaratory or injunctive relief;
`☐ Punitive
`
`NUMBER OF CAUSES OF ACTION: [ ]
`V.
`(Specify)
`
`6
`VI.
`
`IS THIS CASE A CLASS ACTION LAWSUIT?
`☐ yes
`☒ no
`
`VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?
`☐ no
`☒ yes If “yes,” list all related cases by name, case number, and court.
`Dreamstay Homes LLC et al v. HFA Consulting, LLC, et al. Miami-Dade Case
`No.: 2023-003189-CA-01; Executive Ventures, LLC, et al. v. HFA Consulting,
`LLC, et al. Miami-Dade Case No.: 2024-004456-CA-01
`IS JURY TRIAL DEMANDED IN COMPLAINT?
`☒ yes
`☐ no
`
`VIII.
`
`IX.
`
`DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?
`☐ yes
`☒ no
`
`I CERTIFY that the information I have provided in this cover sheet is accurate to the best of
`my knowledge and belief, and that I have read and will comply with the requirements of
`Florida Rule of Judicial Administration 2.425.
`
`Signature: s/ David P Reiner II
`Attorney or party
`
`Fla. Bar # 416400
`(Bar # if attorney)
`
`- 3 -
`
`
`
`David P Reiner II
`(type or print name)
`
` 06/12/2024
`Date
`
`- 4 -
`
`
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