Filing # 195210717 E-Filed 04/01/2024 03:20:32 PM
`
`IN THE COUNTY COURT OF THE, IN
`AND FOR ORANGE COUNTY,
`FLORIDA
`
`CASE NO.:
`
`GLOBAL SUPPLY EXCHANGE, LLC,
`a Florida corporation,
`
`Plaintiff,
`
`VS.
`
`PRECISIONMED, LLC,
`limited company,
`a Texas professional
`
`Defendants.
`
`COMPLAINT
`
`Comes Now, Plaintiff, GLOBAL SUPPLY EXCHANGE, LLC hereinafter referred to as
`("Plaintiff), by and through its undersigned counsel, hereby sues Defendants, PRECISIONMED,
`LLC, a Texas limited liability company, hereinafter collectively referred to as the (Defendants")
`and for its cause of action, declares and avers
`as follows:
`
`PARTIES AND JURISDICTION
`
`1. Plaintiff, provided services and products for Defendants, and bring this action to recover
`the
`balance of an unpaid invoice and other relief under claims of Breach of Contract, Open Account,
`Account Stated, and Unjust Enrichment.
`
`is a Florida limited liability company,
`2. Plaintiff, GLOBAL SUPPLY EXCHANGE, LLC,
`hereinafter referred to as GLOBAL, and, therefore, is within the jurisdiction of this Court.
`
`3. Defendant, PRECISIONMED, LLC is a Texas limited liability company, hereinafter referred to
`to Section 48.193, Florida Statutes, submitted itself
`to the
`as PRECISIONMED, pursuant
`jurisdiction of this Court by, among other things, engaging in business in Florida, by breaching a
`in Florida by failing to perform acts as required by the agreement that it entered into in
`contract
`Orange County, Florida, with Plaintiff and by engaging in substantial activity within this state, of
`which such activity was conducted in both intrastate and interstate matters that conducts business
`in Florida. Therefore, this matter is within the jurisdiction of this Court.
`in excess
`4. Plaintiff
`of action is not
`in the amount of or
`of Fifty Thousand Dollars
`causes
`($50,000.00), excluding interest, costs, and attorneysfees, and as such, are within the jurisdiction
`of this Court.
`
`s
`
`
`
`IN THE COUNTY COURT OF THE, IN
`AND FOR ORANGE COUNTY,
`FLORIDA
`
`CASE NO.:
`
`GLOBAL SUPPLY EXCHANGE, LLC,
`a Florida corporation,
`
`Plaintiff,
`
`VS.
`
`PRECISIONMED, LLC,
`limited company,
`a Texas professional
`
`Defendants.
`
`COMPLAINT
`
`Comes Now, Plaintiff, GLOBAL SUPPLY EXCHANGE, LLC hereinafter referred to as
`("Plaintiff), by and through its undersigned counsel, hereby sues Defendants, PRECISIONMED,
`LLC, a Texas limited liability company, hereinafter collectively referred to as the (Defendants")
`and for its cause of action, declares and avers
`as follows:
`
`PARTIES AND JURISDICTION
`
`1. Plaintiff, provided services and products for Defendants, and bring this action to recover
`the
`balance of an unpaid invoice and other relief under claims of Breach of Contract, Open Account,
`Account Stated, and Unjust Enrichment.
`
`is a Florida limited liability company,
`2. Plaintiff, GLOBAL SUPPLY EXCHANGE, LLC,
`hereinafter referred to as GLOBAL, and, therefore, is within the jurisdiction of this Court.
`
`3. Defendant, PRECISIONMED, LLC is a Texas limited liability company, hereinafter referred to
`to Section 48.193, Florida Statutes, submitted itself
`to the
`as PRECISIONMED, pursuant
`jurisdiction of this Court by, among other things, engaging in business in Florida, by breaching a
`in Florida by failing to perform acts as required by the agreement that it entered into in
`contract
`Orange County, Florida, with Plaintiff and by engaging in substantial activity within this state, of
`which such activity was conducted in both intrastate and interstate matters that conducts business
`in Florida. Therefore, this matter is within the jurisdiction of this Court.
`in excess
`4. Plaintiff
`of action is not
`in the amount of or
`of Fifty Thousand Dollars
`causes
`($50,000.00), excluding interest, costs, and attorneysfees, and as such, are within the jurisdiction
`of this Court.
`
`s
`
`
`
`5. Plaintiff brings forth this cause of action against Defendants to recover
`an unpaid invoices for the
`fulfillment and shipping of COVID-19 OTC TESTS on behalf of Defendants to its patients and
`said interest and late fees accumulated thereupon.
`
`6. PRECISIONMED did not object to the invoices.
`
`7. PRECISIONMED a owes GLOBAL a balance in the amount of $12,096.00. A copy of the final
`invoice is attached as Exhibit A.
`
`8. GLOBAL has made a demand on PRECISIONMED a for payment of the monies owed,
`however, PRECISIONMED has refused to pay.
`9. All conditions precedent to this action have been fulfilled or waived.
`
`10. As a result of PRECISIONMED's failure to pay all sums owing, GLOBAL has had to hire the
`undersigned attorney and is indebted for a fee.
`
`COUNT ONE - ACCOUNT STATED
`
`11. GLOBAL hereby reincorporates the allegations of paragraphs 1-10 above as if set forth fully
`herein.
`
`12. This is an action based on an account stated.
`
`13. Before the institution of this action, GLOBAL, PRECISIONMED a had business transactions
`and agreed to the resulting balance.
`
`14. GLOBAL rendered statements to PRECISIONMED, a copy being attached as Exhibit "A" and
`PRECISIONMED did not object.
`
`15. PRECISIONMED owes GLOBAL $12,096.00, which is due with interest since October 06,
`2023.
`
`WHEREFORE, GLOBAL SUPPLY EXCHANGE, LLC, requests this Court enter judgment
`against Defendant PRECISIONMED, LLC, in the amount of $12,096.00, plus pre-judgment
`interest, costs and attorneysfees, and such other relief as this Court deems proper.
`
`COUNT TWO - UNJUST ENRICHMENT
`
`16. GLOBAL hereby reincorporates the allegations of paragraphs 1-10 above as if set forth fully
`herein.
`
`17. In the alternative, this is an action for unjust enrichment.
`
`18. GLOBAL conferred a benefit upon PRECISIONMED by providing transportation services.
`
`2
`
`
`
`19. PRECISIONMED had knowledge, and enjoyed the benefits of the services provided by
`GLOBAL.
`
`20. PRECISIONMED has voluntarily accepted and retained the benefit conferred upon it by
`GLOBAL.
`
`21. The circumstances under which PRECISIONMED, obtained the above-described benefits make
`it inequitable for PRECISIONMED to retain the benefits without paying the value thereof to
`GLOBAL.
`
`22. GLOBAL has no adequate remedy at law.
`
`WHEREFORE, GLOBAL SUPPLY EXCHANGE, LLC, requests this Court enter judgment
`against Defendants, PRECISIONMED, LLC in the amount of $12,096.00, plus pre-judgment
`interest, costs and attorneysfees, and such other relief as this Court deems proper.
`
`Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiff
`s counsel hereby designates its primary
`email address for the purposes of email service as: pedro@malaretlawfirm.com
`MALARET LAW FIRM, LLC
`
`/s/ Pedro J. Malaret, Esquire
`Pedro J. Malaret, Esquire
`P.O. Box 4579
`Orlando, Florida 32802
`Email: pedro@malaretlawfirm.com
`Telephone: (407) 898-8758
`Fax: (407) 898-8768
`Florida Bar No. 0659177
`pedro@malaretlawfirm.com (Primary)
`pmalaret21@gmail.com (Secondary)
`
`
`
`Global Supply Exchange
`6900 Tavistock Lakes Blvd Ste 400
`Orlando, FL 32827 US
`(407) 813-2442
`sales@globalsupplyexchange.corn
`
`INVOICE
`BLL TO
`Attn: Nene
`Precisionmed
`2503 Cartwright Rd
`Missouri, TX 77459
`
`email 10.6.23
`
`"Z"
`
`0
`(.7
`
`ryy.
`
`C÷t
`
`HPF —
`Attn: Nene
`Precisionmed
`2503 Cartwright Rd
`Missouri, TX 77459
`
`1-
`
`-
`
`t
`
`1
`
`10/09/2023
`
`INVOICE
`DATE
`TERMS
`DUE DATE
`
`5393
`10/06/2023
`Due on receipt
`10/06/2023
`
`FlowFlex COVID-19 Antigen Home Test
`FlowFlex COVID-19 Antigen Home Test
`
`Name of Bank: Chase
`Bank Address: 13824 Narcoossee Road, Orlando, FL 32832
`Bank Identification Code: CHASUS33
`Bank Telephone: (407) 867-6497
`Beneficiary: Global Supply Exchange
`ABA Routing: 267084131
`Business Checking
`Wire Transfer Routing: 021000021
`
`SKU
`
`6-82607-66026-1
`
`QTY
`
`4,032
`
`RATE I
`
`AMOUNT
`
`3.00
`
`12,096.00
`
`SUBTOTAL
`
`TAX
`
`TOTAL
`
`BALANCE DUE
`
`12,096.00
`0.00
`
`12,096.00
`
`$12,096.00
`
`Terms: All sales are final. However, if you believe there s a quality control issue related to the product, please contact us and we MMM rescive the ijsuis. Call or email us
`any time for help.
`Page 1 of 1
`
`EXHIBIT A
`
`
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