Filing # 233433764 E-Filed 10/10/2025 05:06:59 PM
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`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO.: 2025-015587-CA-01
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`ASSOCIATED ENERGY GROUP, LLC,
`A Texas limited liability company,
`
`Plaintiff,
`V.
`
`Zero Gravity Corporation, a Maryland
`Corporation,
`Defendant.
`/
`
`JOINT NOTICE OF SETTLEMENT AND MOTION
`FOR ENTRY OF AGREED FINAL JUDGMENT
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`Plaintiff, ASSOCIATED ENERGY GROUP, LLC (“Plaintiff” or “AEG”), and Defendant,
`ZERO GRAVITY CORPORATION (“Defendant” or “Zero Gravity”), hereby file this Joint Notice
`of Settlement and Motion for Entry of Agreed Final Judgment, and state as follows:
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`1. Plaintiff and Defendant, ZERO GRAVITY CORPORATION (“Defendant” or
`“Zero Gravity”), have executed a Settlement Stipulation, which is intended to fully resolve this
`lawsuit. A true and correct copy of the Settlement Stipulation is attached hereto as Exhibit “1”.
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`2. Pursuant to the Settlement Stipulation, Defendant has waived formal service of
`process, by signing below and by executing the Settlement Stipulation, Defendant has accepted
`service of the Complaint and Summons in this action.
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`3. Pursuant to the Settlement Stipulation, Plaintiff is entitled to the immediate entry
`of an Agreed Final Judgment, a copy of which is attached hereto as Exhibit “2”.
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`4. Plaintiff and Defendant jointly respectfully request that the Court enter the Agreed
`Final Judgment, in the form attached hereto as Exhibit “2”, in accordance with the Settlement
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`Stipulation.
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`WHEREFORE, Plaintiff, ASSOCIATED ENERGY GROUP, LLC, and Defendant, ZERO
`GRAVITY CORPORATION, jointly respectfully request that this Honorable Court enter the
`Agreed Final Judgment attached hereto as Exhibit “2”, in accordance with the Settlement
`Stipulation executed by the parties, and for any further and other relief the Court deems necessary
`and just under the circumstances.
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`Respectfully submitted,
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`ASSOCIATED ENERGY GROUP, LLC ZERO GRAVITY CORP.
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`By: /s/ Harold E. Patricoff, Esq. By: /s/ Philip Hover-Smoot
`Counsel for Plaintiff General Counsel and Authorized
`Representative for Defendant
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that on this 10th day of October, 2025, a copy hereof has been
`electronically served via Florida ePortal to all counsel of record and to Zero Gravity Corp., c/o its
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`General Counsel, Philip Hover-Smoot, Esq. at philip@gozerog.com.
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`By: /s/Harold E. Patricoff
`HAROLD E. PATRICOFF, ESQ.
`FLORIDA BAR NUMBER: 508357
`LAWSON HUCK GONZALEZ, PLLC
`121 Alhambra Plaza, 10th Floor
`Coral Gables, FL 33134
`Telephone: 850-825-4334
`hep@lawsonhuckgonzalez.com
`hilary@lawsonhuckgonzalez.com
`corinne@lawsonhuckgonzalez.com
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`aviance(@lawsonhuckgonzalez.com
`Counsel for Plaintiff
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`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO.: 2025-015587-CA-01
`
`ASSOCIATED ENERGY GROUP, LLC,
`A Texas limited liability company,
`
`Plaintiff,
`V.
`
`Zero Gravity Corporation, a Maryland
`Corporation,
`
`Defendant.
`
`SETTLEMENT STIPULATION
`
`This Settlement Stipulation (“Stipulation”) is made and entered into by and between
`ASSOCIATED ENERGY GROUP, LLC (“AEG”), a Texas limited liability company, and ZERO
`GRAVITY CORPORATION, a Maryland company (“Zero Gravity”). This Stipulation shall bind
`AEG and Zero Gravity, and each of their respective past, present and future principals, agents,
`employees, members, partners, representatives, officers, directors, managers, shareholders,
`affiliated entities, successors and assigns.
`
`WHEREAS, AEG and Zero Gravity entered into an agreement, pursuant to which AEG
`would sell and deliver aviation fuel and related services to Zero Gravity, and Zero Gravity would
`pay AEG for the goods and services rendered, in the amounts invoiced by AEG and in accordance
`with AEG’s General Terms and Conditions;
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`WHEREAS, AEG fully performed under the agreement by providing the aviation fuel and
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`related services to Zero Gravity;
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`WHEREAS, Zero Gravity received and accepted the aviation fuel and related services from
`AEG, but failed to pay the amounts due and owing to AEG, thereby breaching its agreement with
`AEG;
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`WHEREAS, the sum of $261,140.78 USD remains due and owing by Zero Gravity to AEG
`for the fuel and services rendered, exclusive of late fees and interest;
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`WHEREAS, AEG commenced the above-captioned lawsuit (the “Litigation”) against Zero
`Gravity for damages in the amount of $261,140.78 USD, exclusive of late fees, interest, and
`attorneys’ fees and costs;
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`WHEREAS, pursuant to AEG’s General Terms and Conditions, all past due amounts shall
`accrue interest at the greater of 1.5% per month or the maximum rate allowed by applicable law;
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`WHEREAS, pursuant to Florida law, which governs the AEG Terms and Conditions, the
`past due amounts accrued interest at the rate of 18% per annum, and the interest accrued from July
`1,2025, through October 3, 2025, totals $11,059.52 USD, and prejudgment interest shall continue
`to accrue at the rate of $128.76 per diem, from October 3, 2025, until the date the Agreed Final
`Judgment is entered (as defined hereinafter);
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`WHEREAS, pursuant to AEG’s General Terms and Conditions, Zero Gravity is obligated
`to pay AEG’s attorneys’ fees and costs relating to the connection of unpaid invoices in the amount
`of $25,000.00 USD;
`
`WHEREAS, the total sum due and owing by Zero Gravity to AEG is $297,200.30 USD,
`plus prejudgment interest which shall continue to accrue at the rate of $128.76 per diem, from
`October 3, 2025 until the date the Agreed Final J udgment is entered (as defined hereinafter);
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`WHEREAS, AEG and Zero Gravity have agreed to resolve the Debt and the Litigation by
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`virtue of this Stipulation.
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`NOW, THEREFORE, in consideration of the mutual promises, covenants and obligations
`set forth herein, and other good and valuable consideration, the sufficiency of which is hereby
`acknowledged, AEG and Zero Gravity agree as follows:
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`1. Payment Instructions. Zero Gravity shall remit the Settlement Sum to AEG via
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`wire transfer to the following bank account:
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`Bank Name: PNC Bank, N.A.
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`Account Title: Associated Energy Group, LLC/
`Concentration Account
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`Account Number: 1241209256
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`Wire Bank Routing/ABA Number: 043000096
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`ACH Bank Routing Number: 267084199
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`Bank SWIFT Code: PNCCUS33
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`2. The Litigation. AEG is entitled to, and Zero Gravity stipulates and agrees to, the
`immediate entry of an Agreed Final Judgment in the Litigation upon execution of this Stipulation
`by Zero Gravity. The Agreed Final Judgment shall be in the form attached hereto as Exhibit “A”.
`The Agreed Final Judgment shall be in the amount equal to: (i) the Debt; and (ii) prejudgment
`interest on the Debt at the rate of 18% per year, which shall accrue from October 3, 2025, to the
`date the Agreed Final Judgment is entered, at the rate of $128.76 per diem. After the Agreed Final
`Judgment is entered, post-judgment interest on the Agreed Final J udgment shall accrue at the rate
`prescribed by Florida law. The Agreed Final Judgment shall also state that AEG is entitled to an
`award of its attorneys’ fees and costs incurred in connection with the Agreed Final Judgment.
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`Upon execution of this Stipulation, AEG shall file a Joint Notice of Settlement and Motion
`for Entry of Agreed Final Judgment, in the form attached hereto as Exhibit “B” (the “Notice”).
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`The Notice shall state that the parties to the Litigation have entered into this Settlement Stipulation,
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`and that Plaintiff and Defendant jointly request that the Court enter the Agreed Final Judgment in
`accordance with the Settlement Stipulation.
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`3. Forbearance. AEG agrees to forbear from taking any collection, enforcement, or
`execution action against Zero Gravity with respect to Agreed Final Judgment for a period of six
`(6) months, through and including April 3, 2026 (the “Forbearance Period”). During the
`Forbearance Period, AEG will not file any new lawsuits, seek writs of execution or garnishment
`and/or attachment, record any judgment liens, or otherwise pursue collection or enforcement of
`Agreed Final Judgment. Upon expiration of the Forbearance Period, if Zero Gravity fails to comply
`with any term of this Stipulation, AEG may immediately pursue any and all remedies available at
`law or in equity, and may take any action to collect, enforce and/or execute upon the Agreed Final
`Judgment.
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`4. Bankruptey Acknowledgment and Non-Objection. Zero Gravity expressly
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`acknowledges and agrees that the obligations set forth in this Settlement Stipulation constitute a
`valid, liquidated, and non-contingent debt within the meaning of 11 U.S.C. § 101(5). In the event
`Zero Gravity becomes a debtor in any case under Chapter 7 or Chapter 11 of the United States
`Bankruptcy Code:
`a. Zero Gravity shall not dispute, object to, or otherwise contest the validity, amount,
`or enforceability of AEG’s claim as set forth in this Stipulation.
`b. Zero Gravity shall not assert any defense, offset, or counterclaim to reduce or
`disallow AEG’s claim.
`¢. Nothing herein shall be deemed a waiver of AEG’s right to seek a determination
`that the obligations are nondischargeable under 11 U.S.C. §§ 523 and/or 727, and
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`Zero Gravity shall not oppose or object to such relief if sought by AEG.
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`d. Zero Gravity further waives the right to seek subordination of AEG’s claim under
`Chriftopner Clomenti . . . L.
`CEEEEEITULS.C. § 510 or otherwise contest its treatment in any plan of reorganization
`under Chapter 11.
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`5. Entire Agreement. This Stipulation constitutes the entire agreement between AEG
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`and Zero Gravity regarding settlement of the Debt. This Stipulation supersedes all prior and
`contemporaneous, oral or written agreements, communications, negotiations, representations, and
`understandings of AEG ‘and Zero Gravity with regard to the subject matter addressed herein.
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`6. Counterparts. This Stipulation may be executed in counterparts, including
`counterparts transmitted by email, each counterpart constituting an original.
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`7. Governing Law. This Stipulation shall be governed and construed in accordance
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`with the laws of the State of Florida.
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`8. Jurisdiction. AEG and Zero Gravity agree that the state courts of Miami-Dade
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`County, Florida, shall continue to have exclusive jurisdiction to enforce the terms of this
`Stipulation, including, but not limited to, the entry of the Agreed Final Judgment and any matters
`related thereto. Zero Gravity further agrees that by entering into this Stipulation, it has submitted
`to the personal jurisdiction of such Court and waives any objection based on venue or forum non
`conveniens. Moreover, by executing this Stipulation, Zero Gravity expressly agrees that it accepts
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`service of the Complaint in the Litigation and waives formal service of process.
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`[Remainder of page intentionally left blank - signature page to follow]
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`ASSOCIATED ENERGY GROUP, LLC
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`By: Christopher Clementi
`Its: CEO
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`Date:
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`ZERO GRAVITY CORP.
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`By: Philip Hover-Smoot, Esq.
`Its: General Counsel and Authorized Representative
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`Date:
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`2025.10.06 - Zero Gravity Settlement Stipulation
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`Final Audit Report 2025-10-08
`Created: 2025-10-06
`By: Aviance Silvarrey (aviance@lawsonhuckgonzalez.com)
`Status: Signed
`Transaction ID: CBJCHBCAABAAfa0VuKJX0kbd3Qh0-000tYBnGBBBhOX2
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`"2025.10.06 - Zero Gravity Settlement Stipulation" History
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`™) Document created by Aviance Silvarrey (aviance@lawsonhuckgonzalez.com)
`2025-10-06 - 2:05:58 PM GMT
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`&3 Document emailed to Christopher Clementi (cmc@aegfuels.com) for signature
`2025-10-06 - 2:06:03 PM GMT
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`E3 Document emailed to Philip Hover-Smoot (philip@gozerog.com) for signature
`2025-10-06 - 2:06:03 PM GMT
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`™ Email viewed by Christopher Clementi (cmc@aegfuels.com)
`2025-10-06 - 3:49:47 PM GMT
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`&% Document e-signed by Christopher Clementi (cmc@aegfuels.com)
`Signature Date: 2025-10-06 - 3:50:29 PM GMT - Time Source: server
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`) Email viewed by Philip Hover-Smoot (philip@gozerog.com)
`2025-10-08 - 0:20:41 AM GMT
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`&5 Document e-signed by Philip Hover-Smoot (philip@gozerog.com)
`Signature Date: 2025-10-08 - 1:09:30 AM GMT - Time Source: server
`
`@ Agreement completed.
`2025-10-08 - 1:09:30 AM GMT
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`Adobe Acrobat Sign
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`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO.: 2025-015587-CA-01
`
`ASSOCIATED ENERGY GROUP, LLC,
`A Texas limited liability company,
`
`Plaintiff,
`V.
`
`Zero Gravity Corporation, a Maryland
`Corporation,
`
`Defendant.
`
`AGREED FINAL JUDGMENT
`
`THIS MATTER came before the Court upon Plaintiff, Associated Energy Group, LLC’s
`(“Plaintiff” or “AEG”) and Defendant, Zero Gravity Corporation’s (“Defendant” or “Zero
`Gravity”) Joint Notice of Settlement and Motion for Entry of Agreed Final Judgment against
`Defendant, Zero Gravity Corporation (“Defendant” or “Zero Gravity”), filed on October 9, 2025
`(the “Joint Notice and Motion for Agreed Final Judgment”). The Court, having reviewed the
`Motion for Entry of Agreed Final Judgment, the Settlement Stipulation executed by Plaintiff and
`Defendant, the Court file, and being otherwise fully advised in the premises, it is hereby
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`ORDERED, ADJUDGED and DECREED:
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`1. The Joint Notice and Motion for Agreed Final Judgment is GRANTED.
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`2. The Court finds that Plaintiff and Defendant entered into the Settlement Stipulation
`and have agreed to the entry of this Agreed Final Judgment.
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`3. Having reviewed the Settlement Stipulation, the Court finds that Defendant has
`failed to comply with its payment obligations thereunder, and further that Defendant has agreed to
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`the entry of this Final Judgment.
`EXHIBIT
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`4. Judgment is hereby entered in favor of Plaintiff, ASSOCIATED ENERGY
`GROUP, LLC, on all Counts of the Complaint, and against Defendant, ZERO GRAVITY
`CORPORATION, in the amount of $261,140.78 USD, plus interest at the rate of 18% per annum
`as accrued from July 1, 2025, through October 3, 2025, in the amount of $11,059.52 USD, plus
`attorneys’ fees and costs in the amount of $25,000.00 USD, as provided for in the Settlement
`Stipulation, for a total amount of $297,200.30 USD, for which sum let execution issue forthwith.
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`5. Pre-judgment interest shall continue to accrue at the rate of $128.76 per diem, from
`October 3, 2025, through the date of this Agreed Final Judgment.
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`6. Post-judgment interest shall accrue on the judgment amount at the rate prescribed
`by law.
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`7. Plaintiff, ASSOCIATED ENERGY GROUP, LLC’s principal place of business is
`located at 701 NW 62™ Ave, Suite 490, Miami, FL 33126.
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`8. Defendant, ZERO GRAVITY CORPORATION’s last known address is 505
`Odyssey Way, #410, Exploration Park, FL 32953.
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`9. Plaintiff, now Judgment Creditor, AEG, holds a lien for the total sum of
`$297,200.30 USD, superior to all claims of Defendant, now Judgment Debtor, Zero Gravity, on
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`the below described property (the “Aircraft”).
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`AIRCRAFT: BOEING 727-227
`REGISTRATION NUMBER: N794A]
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`SERIAL NUMBER: 21243
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`REGISTERED OWNER: ZERO GRAVITY CORP.
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`505 Odyssey Way, #410
`Exploration Park, FL 32953
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`10. Plaintiff, now Judgment Creditor, AEG, is entitled to foreclose upon its claim of
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`lien on the Aircraft pursuant to Florida law and/or Texas law, including but not limited to Texas
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`Property Code Sections 70.3031, 70.302 and 70.305.
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`11. If the total amount with interest, as set forth in Paragraphs 4-6, above, and all costs
`accrued subsequent to this Judgment are not paid, the Court reserves the right under Florida and/or
`Texas law to direct the Clerk of Courts to sell the Aircraft at public sale to the highest bidder for
`cash. The Court further reserves the right to order Defendant, now Judgment Debtor, Zero Gravity,
`to bring the Aircraft to Miami-Dade County, Florida, for such public sale.
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`12. Plaintiff, now Judgment Creditor, AEG, shall advance all subsequent costs of this
`action and shall be reimbursed for them by the Clerk if Plaintiff is not the purchaser of the Aircraft,
`provided, however, that the purchaser of the Aircraft shall be responsible for documentary stamps
`affixed to the certificate of title (if applicable). If Plaintiff is the purchaser, the Clerk shall credit
`Plaintiff’s bid with the total sum with interest and costs accruing subsequent to this Judgment, or
`such part of it, as is necessary to pay the bid in full.
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`13. On the filing of the Certificate of Title, the Clerk shall distribute the proceeds of
`the sale, so far as they are sufficient, by paying: first, all of the Plaintiff’s costs; second,
`documentary stamps affixed to the Certificate; third, Plaintiff’s attorneys fees; fourth, the total sum
`due to Plaintiff, less the items paid, plus interest at the rates prescribed in Paragraphs 4-6, above,
`through the date of sale; and by retaining any remaining amount pending the further Order of this
`Court.
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`14. Upon filing of the Certificate of Sale, Defendant, now Judgment Debtor, Zero
`Gravity, and all persons claiming under or against Defendant since the filing of the Texas Claim
`of Lien shall be foreclosed of all estate or claim in the Aircraft, except as to claims or rights under
`Section 45.01315, Florida Statutes (2013) shall be terminated, except as to claims or rights under
`Chapter 718 or Chapter 720, Fla. Stat., if any. Upon filing of the Certificate of Title, the person
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`named on the Certificate of Title shall be let into possession of the property.
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`15. The Court retains jurisdiction to enter further orders that are proper, including,
`without limitation, writs of possession and deficiency judgments.
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`16. IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION, THERE MAY BE
`ADDITIONAL MONEY FROM THE SALE AFTER PAYMENT OF PERSONS WHO
`ARE ENTITLED TO BE PAID FROM THE SALE PROCEEDS PURSUANT TO THE
`FINAL JUDGMENT.
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`17. IFYOU ARE A SUBORDINATE LIEN HOLDER CLAIMING A RIGHT TO
`FUNDS REMAINING AFTER THE SALE, YOU MUST FILE A CLAIM WITH THE
`CLERK NO LATER THAN SIXTY (60) DAYS AFTER THE SALE. IF YOU FAIL TO
`FILE A CLAIM, YOU WILL NOT BE ENTITLED TO ANY REMAINING FUNDS.
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`18. In accordance with Rule 1.560(c), Fla. R. Civ. P., Defendant, now Judgment
`Debtor, Zero Gravity shall complete under oath Florida Rule of Civil Procedure Form 1.977 (Fact
`Information Sheet), including all required attachments, and serve it on the Plaintiff, now Judgment
`Creditor, AEG’s attorney, or if AEG is not represented by an attorney, on AEG, within forty-five
`(45) days from the date of this Final Judgment, unless the Final Judgment is satisfied or post-
`judgment discovery is stayed.
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`19. The Court reserves jurisdiction to:
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`a. Award Plaintiff, now Judgment Creditor, AEG, any additional attorneys’ fees and
`costs;
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`b. Determine the amount of any additional reasonable attorneys’ fees and court costs
`to be awarded to Plaintiff, now Judgment Creditor, AEG;
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`c. Enter further Orders to compel Defendant, now Judgment Debtor, Zero Gravity, to
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`complete and serve on Plaintiff, now Judgment Creditor, AEG’s attorney, Harold
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`E. Patricoft, Jr., Esq., all post-judgment discovery, including but not limited to the
`completion of Form 1.977 and provision of all required attachments, and to submit
`to depositions in aid of execution;
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`d. Enforce the terms of the Settlement Stipulation; and
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`e. Enter any further or additional Orders that may be necessary or appropriate.
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`DONE and ORDERED in Chambers in Miami-Dade County, Florida, on this _ day of
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`, 202
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`Circuit Court Judge
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