CAUSE NO. -----------------
`BG PERSONNEL SERVICES, L.P. § IN THE DISTRICT COURT
`§
`Plaintiff, §
`§
`vs. § JUDICIAL DISTRICT
`§
`TZADIK PROPERTIES, LLC §
`d/b/a SUMMER LAKE VILLAS §
`APARTMENTS and SUMMER LAKE §
`VILLA'S HOMEOWNERS ASSOCIATION,§
`INC. d/b/a SUMMER LAKE VILLAS §
`APARTMENTS §
`§
`Defendants. § DALLAS COUNTY, TEXAS
`PLAINTIFF'S ORIGINAL PETITION
`TO THE HONORABLE JUDGE OF SAID COURT:
`COMES NOW, BG PERSONNEL SERVICES, L.P. (hereinafter referred to as
`"Plaintiff'), by and through its Attorney of Record, and files this, its Original Petition
`complaining of TZADIK PROPERTIES, LLC d/b/a SUMMER LAKE VILLAS
`APARTMENTS ("TZADIK") and SUMMER LAKE VILLA'S HOMEOWNERS
`ASSOCIATION, INC. d/b/a SUMMER LAKE VILLAS APARTMENTS ("SUMMER")
`(hereinafter collectively referred to as "Defendants"), and for a cause of action would
`respectfully show as follows:
`I.
`Discovery is intended to be conducted under Level 1 of Texas Rule of Civil Procedure
`190.2. Plaintiff seeks only monetary relief of $100,000 or less, including damages of any kind,
`penalties, costs, expenses, prejudgment interest, and attorney's fees.
`PLAINTIFF'S ORIGINAL PETITION PAGE 1
`2-CITS E-SERVE
`DC-15-02206
`Tonya Pointer
`FILED
`DALLAS COUNTY
`2/25/2015 4:03:57 PM
`FELICIA PITRE
`DISTRICT CLERK
`M-298TH
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`II.
`Plaintiff is a limited partnership duly organized and existing under the laws of the State
`of Texas, having its principal place of business in Dallas County, Texas.
`Defendant TZADIK is a limited liability company duly organized and existing under the
`laws of the State of Florida. Service of TZADIK may be had by serving its Registered Agent,
`TZADIK CONSULTING, LLC, at 11098 Biscayne Boulevard, Ste. 203, North Miami, Florida
`33161 OR WHEREVERITMAYBEFOUND.
`Defendant SUMMER is a limited partnership duly organized and existing under the laws
`of the State of Florida. Service of SUMMER may be had by serving its Registered Agent,
`TZADIK MANAGEMENT GROUP, LLC, at 11098 Biscayne Blvd, Ste. 203, North Miami,
`Florida 33161 OR WHEREVER IT MAY BE FOUND.
`VENUE
`III.
`Venue is proper in Dallas County, Texas because the contracts made the basis of this
`lawsuit were entered into and performable in part in Dallas County, Texas.
`FIRST CAUSE OF ACTION:
`SWORN ACCOUNT
`IV.
`At all times mentioned herein, SUMMER owned the Summer Lake Villas Apartments,
`located at 4331 Fiji Drive, New Port Richey, Florida 34653 ("the Property") and did business
`under the assumed name of "Summer Lake Villas Apartments." At all times mentioned herein,
`TZADIK managed the Summer Lake Villas Apartments and was an undisclosed agent of
`SUMMER. At all times mentioned herein, TZADIK did business under the assumed name of
`"Summer Lake Villas Apartments."
`PLAINTIFF'S ORIGINAL PETITION PAGE2
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`v.
`On several occasions from on or about August 3, 2014 to on or about October 5, 2014, as
`more particularly shown on the attached Exhibit "A," a verified account representing a liquidated
`money demand which is incorporated herein by reference the same as if fully copied and set
`forth at length, Plaintiff, at the request of TZADIK, sold staffing and placement services to
`Defendants for the Summer Lake Villas Apa11ments. In consideration of such sales, on which a
`systematic record has been kept, Defendants promised and agreed to pay Plaintiff the aggregate
`sum of $24,415.22, being a reasonable sum for such services.
`VI.
`As an undisclosed agent for the Owner of the Property, TZADIK is liable to Plaintiff for
`the full amount of the debt. SUMMER, as owner of the property, is liable for the debt incurred
`by the Property.
`VII.
`After the allowance of all just and lawful offsets, payments and credits to Defendants, the
`aggregate sum of $24,415.22 is past due and unpaid and Defendants, though often requested,
`have failed and still refuse to pay the debt.
`VIII.
`Plaintiff has fully performed all conditions, covenants and promises to be performed by
`Plaintiff under Plaintiffs contracts with Defendants.
`IX.
`Plaintiffs claim was timely presented to Defendants and remains unpaid. More than
`thirty (30) days have elapsed since such presentation, and it has become necessary for Plaintiff to
`hire the undersigned attorney in order for Plaintiff to acquire the outstanding balance to which it
`PLAINTIFF'S ORIGINAL PETITION PAGE3
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`is entitled. In accordance with Section 38.001 of the Texas Civil Practice and Remedies Code,
`Plaintiff is entitled to reimbursement by Defendants for its reasonable attorney's fees, which
`reasonable attorney's fees Plaintiff alleges to be at least $10,000.00 through trial, plus an
`additional $10,000.00 for an appeal to the Texas Court of Appeals, if such an appeal is had, and
`an additional $10,000.00 for an appeal to the Supreme Court of Texas, if such an appeal is had.
`X.
`Plaintiff would fmiher show that Plaintiff is entitled to prejudgment and postjudgment
`interest at the highest legal rate.
`SECOND CAUSE OF ACTION
`QUANTUM MERUTT
`XI.
`Paragraphs I. through X. are incorporated herein by reference the same as if fully copied
`and set forth at length.
`XII.
`Pleading further and in the alternative, Plaintiff would show that on several occasions
`from on or about August 3, 2014 to on or about October 5, 2014, at the request of Defendant
`TZADIK, Plaintiff sold staffing and placement services to the Defendants for the Property.
`Defendants accepted the benefits of such services and knew, or under the circumstances
`reasonably should have known, that Plaintiff expected payment from Defendants for such
`services. The services furnished by Plaintiff were reasonably worth the aggregate sum of
`$24,415.22 at the time same were furnished.
`PLAINTIFF'S ORIGINAL PETITION PAGE4
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`XIII.
`There remains due and owing to Plaintiff the aggregate sum of $24,415.22, which
`Defendants have failed and refused to pay the debt although proper demand for payment has
`been made by Plaintiff.
`XIV.
`Plaintiff's claim was timely presented to Defendants and remains unpaid. More than
`thirty (30) days have elapsed since such presentation, and it has become necessary for Plaintiff to
`hire the undersigned attorney in order for Plaintiff to acquire the outstanding balance to which it
`is entitled. In accordance with Section 38.001 of the Texas Civil Practice and Remedies Code,
`Plaintiff is entitled to reimbursement by Defendants for its reasonable attorney's fees, which
`reasonable attorney's fees Plaintiff alleges to be at least $10,000.00 through trial, plus an
`additional $10,000.00 for an appeal to the Texas Court of Appeals, if such an appeal is had, and
`an additional $10,000.00 for an appeal to the Supreme Court of Texas, if such an appeal is had.
`XV.
`Plaintiff would further show that Plaintiff is entitled to pr~judgment and postjudgment
`interest at the highest legal rate.
`WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendants
`SUMMER and TZADIK be cited to appear and answer, and that on final trial, Plaintiff have:
`I. Judgment against Defendants, jointly and severally, in the principal sum of
`$24,415.22, with prejudgment interest thereon at the highest legal rate and
`postjudgment interest thereon at the highest legal rate from the date of judgment
`until paid;
`2. Judgment against Defendants, jointly and severally, for attorney's fees as alleged
`above, with postjudgment interest thereon at the highest legal rate from the date of
`judgment until paid;
`3. Judgment against Defendants, jointly and severally, for all costs of suit; and
`PLAINTIFF'S ORIGINAL PETITION PAGES
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`4. Such other and further relief to which Plaintiff may show itself justly entitled to
`receive.
`PLAINTIFF'S ORIGINAL PETITION
`Respectfully submitted,
`awlins Street, Suite 1300
`D ]as, Texas 75219
`14/521-2814-Telephone
`214/521-8995 -Facsimile
`craigbemstein@birch.net
`ATTORNEY FOR PLAINTIFF
`PAGE6
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`AFFIDAVIT OF AARON J. GILE
`STATE OF TEXAS §
`§
`COUNTY OF DALLAS §
`BEFORE ME, the undersigned authority, on this day personally appeared AARON J.
`GILE, known to me to be the person whose name is subscribed to the following instrument, and
`who, having been by me duly sworn, upon his oath deposes and states as follows;
`1. "My name is Aaron J. Gile."
`2. "I am the President of the Mutli-Family Division of BG Personnel Services, L.P.
`I am over the age of 21 years, have never been convicted of a felony, and am fully authorized
`and competent to make this affidavit and have pet·sonal knowledge to testifY to all matters
`herein."
`3. "I have care, custody and control of all records concerning the account of
`Defendants TZADIK PROPERTIES, LLC d/b/a SUMMER LAKE VILLAS APARTMENTS
`and SUMMER LAKE VILLA'S HOMEOWNERS ASSOCIATION, INC. d/b/a SUMMER
`LAKE VILLAS APARTMENTS (hereinafter collectively referred to as "Defendants").
`4. "These records show that a principal balance of $24,415.22, exclusive of interest,
`is due and payable by Defendants.
`5. "The Defendants' account which is marked Exhibit "A," is altached to Plaintiffs
`Original Petition, and is within my personal knowledge just and true. The total amount of the
`account is due to Plaintiff by Defendants, and all just and lawful offsets, payments and credits
`have been allowed."
`fURTHER AFFlANT SA YETH NOT.
`PLAINTlFF'S ORlGINAL PETlTION PAGE?
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`BG PERSONNEL SERVICES, L.P.
`ByM~
`PRESIDENT OF MULTI-FAMILY DIVISION
`SUBSCRIBED AND SWORN TO BEFORE ME, this the 10 day of February, 2015,
`to certify which witness my hand and official seal.
`,.,;;;t~~~. ABBY JOAN JOHNSON
`{:~:..C') .'\ Notary Public, State of Texas
`',,;.·. '"!"{_.:,,; My Commission Expires
`.....,-;.· ·~ •"'ft."''"'
`··!.~.?.ft.:···· January 28, 2019
`PLAINTIFF'S ORIGINAL PETITION
`N~~~& (;~;%~~~Cfet.,
`My Commission Expires: ~'Z.B ZO I G1
`PAGES
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`f..:J BG Staffi n8
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`SUMMER lAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/3/2014
`Davila, Rafael Luis
`Feliz, Antonio
`Sanjurju, Paul
`Suarez, Jeffrey
`Vila, Jose
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`907236
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs ·Reg Rate OT Hrs
`40.00 $16.00 0.00
`40.00 $16.00 0.00
`40.00 $22.00 1.00
`16.00 $16.00 0.00
`24.00 $16.00 0.00
`160.00 1.00
`**2% lATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`907236
`Customer#
`104314
`Please detach and return with remittance
`Customer Name
`SUMMER lAKE VILlAS
`MAIL PAYMENTS TO : DUE UPON RECEIPT
`Invoice Date
`8/3/2014
`Invoice Amt
`$2,833.00
`OT Rate Total
`$24.00 $640.00
`$24.00 $640.00
`$33.00 $913.00
`$24.00 $256.00
`$24.00 $384.00
`$2,833.00
`EXHIBIT
`A
`Please Pay
`$2,833.00
`Staffing **2% lATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
`5000 Legacy Dr Suite 3 50
`Plano, TX 7 5024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/10/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`907979
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 0.00
`23.75 $19.45 0.00
`40.00 $22.00 0.00
`103.75 0.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`907979
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/10/2014
`Invoice Amt
`$1,981.94
`OT Rate Total
`$24.00 $640.00
`$29.18 $461.94
`$33.00 $880.00
`$1,981.94
`Please Pay
`$1,981.94
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
`
`
`
`
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`
`y BG Staffi n~
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`INVOICE
`Customer#
`104314
`Invoice#
`909978
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`PAYMENT TERMS
`DUE UPON RECEIPT
`TAMPA, FL 34653
`Employee Description Reg Hrs Reg Rate OT Hrs
`WeekendDate: 8/17/2014
`Feliz, Antonio 40.00 $16.00 7.50
`Golden, Andrea 40.00 $19.45 1.50
`Sanjurju, Paul 40.00 $22.00 6.00
`Totals: 120.00 15.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE ....
`Invoice#
`909978
`Customer#
`104314
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`Invoice Date
`8/17/2014
`Invoice Amt
`$2,719.77
`OT Rate Total
`$24.00 $820.00
`$29.18 $821.77
`$33.00 $1,078.00
`$2,719.77
`MAIL PAYMENTS TO: DUE UPON RECEIPT Please Pay
`Page 1 of 1
`f/:t BG Staffing $
`2
`,7
`19
`.
`77
`~~~ **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE ....
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
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`BG Staffiny
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/24/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`911324
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 3.00
`40.00 $19.45 0.50
`40.00 $22.00 3.00
`120.00 6.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`911324
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/24/2014
`Invoice Amt
`$2,483.59
`OT Rate Total
`$24.00 $712.00
`$29.18 $792.59
`$33.00 $979.00
`$2,483.59
`Please Pay
`$2,483.59
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`P0Box803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`BG Staffiny
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Alicea, Yaril
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/31/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`912972
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`20.00 $16.00 0.00
`40.00 $16.00 6.00
`40.00 $19.45 2.50
`40.00 $22.00 6.50
`140 .00 15.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE*"
`Invoice#
`912972
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/31/2014
`Invoice Amt
`$3,049.45
`OT Rate Total
`$24.00 $320.00
`$24.00 $784.00
`$29.18 $850.95
`$33.00 $1 ,094.50
`$3,049.45
`Please Pay
`$3,049.45
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-33 I 2
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
`
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`
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Alicea, Yaril
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA , FL 34653
`Description
`WeekendDate: 9/7/2014
`Golden, Andrea
`Sanjurju, Paul
`TORRES, KEISHLA
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`913255
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`4.00 $16.00 0.00
`37.00 $16.00 0.00
`32.00 $19.45 0.00
`40.00 $22.00 0.50
`8.00 $16.00 0.00
`121.00 0.50
`""2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE*"'
`Invoice#
`913255
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/7/2014
`Invoice Amt
`$2,302.90
`OT Rate Total
`$24.00 $64.00
`$24.00 $592.00
`$29.18 $622.40
`$33.00 $896.50
`$24.00 $128.00
`$2,302.90
`Please Pay
`$2,302.90
`BG Staffing *"2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE"""
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL : 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`f/;} BG Staffin~
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA , FL 34653
`Description
`WeekendDate: 9/14/2014
`Golden, Andrea
`TORRES, KEISHLA
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`915306
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 5.50
`18.50 $19.45 0.00
`16.00 $16.00 0.00
`74.50 5.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE* *
`Invoice#
`915306
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/14/2014
`Invoice Amt
`$1 ,387.83
`OT Rate Total
`$24.00 $772.00
`$29.18 $359.83
`$24.00 $256.00
`$1 ,387.83
`Please Pay
`$1 ,387.83
`f/;J, BG Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE **
`Page 1 of 1
`PO Box 8033 12
`Dallas, TX 75380-3312
`888.278 8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`f/;J• BG Staffi n~
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 9/21/2014
`GALAN, RAFAEL
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`916479
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 6.25
`23.00 $19.45 0.00
`63.00 6.25
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`916479
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/21/2014
`Invoice Amt
`$1,237.35
`OT Rate Total
`$24.00 $790.00
`$29.18 $447.35
`$1,237.35
`Please Pay
`$1,237.35
`BG Staffing
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 9/28/2014
`GALAN, RAFAEL
`Perez Perez, Roberto
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`917961
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 6.50
`36.00 $19.45 o .. oo
`17.00 $23.00 0.00
`93.00 6.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`917961
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/28/2014
`Invoice Amt
`$1,887.20
`OT Rate Total
`$24.00 $796.00
`$29.18 $700.20
`$34.50 $391.00
`$1,887.20
`Please Pay
`$1,887.20
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`t/;J) BG Staffing
`5000 Legacy D r Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 10/5/2014
`Diaz, Betzaida
`Feliz, Antonio
`GALAN , RAFAEL
`Martin Arocha, Fidel
`Martin, Jesus
`Perez Perez, Roberto
`Reavis, Chris
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`918902
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`9.00 $18.75 0.00
`40.00 $16.00 8.00
`40.00 $19.45 4.50
`24.00 $23.00 0.00
`22.50 $23.00 0.00
`40.00 $23.00 6.50
`16.50 $24.75 0.00
`192 .00 19.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`918902
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`10/5/2014
`Invoice Amt
`$4,532.19
`OT Rate Total
`$28.13 $168.75
`$24.00 $832.00
`$29.18 $909.31
`$34.50 $552.00
`$34.50 $517.50
`$34.50 $1,144.25
`$37.13 $408.38
`$4,532.19
`Please Pay
`$4,532.19
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`BG PERSONNEL SERVICES, L.P. § IN THE DISTRICT COURT
`§
`Plaintiff, §
`§
`vs. § JUDICIAL DISTRICT
`§
`TZADIK PROPERTIES, LLC §
`d/b/a SUMMER LAKE VILLAS §
`APARTMENTS and SUMMER LAKE §
`VILLA'S HOMEOWNERS ASSOCIATION,§
`INC. d/b/a SUMMER LAKE VILLAS §
`APARTMENTS §
`§
`Defendants. § DALLAS COUNTY, TEXAS
`PLAINTIFF'S ORIGINAL PETITION
`TO THE HONORABLE JUDGE OF SAID COURT:
`COMES NOW, BG PERSONNEL SERVICES, L.P. (hereinafter referred to as
`"Plaintiff'), by and through its Attorney of Record, and files this, its Original Petition
`complaining of TZADIK PROPERTIES, LLC d/b/a SUMMER LAKE VILLAS
`APARTMENTS ("TZADIK") and SUMMER LAKE VILLA'S HOMEOWNERS
`ASSOCIATION, INC. d/b/a SUMMER LAKE VILLAS APARTMENTS ("SUMMER")
`(hereinafter collectively referred to as "Defendants"), and for a cause of action would
`respectfully show as follows:
`I.
`Discovery is intended to be conducted under Level 1 of Texas Rule of Civil Procedure
`190.2. Plaintiff seeks only monetary relief of $100,000 or less, including damages of any kind,
`penalties, costs, expenses, prejudgment interest, and attorney's fees.
`PLAINTIFF'S ORIGINAL PETITION PAGE 1
`2-CITS E-SERVE
`DC-15-02206
`Tonya Pointer
`FILED
`DALLAS COUNTY
`2/25/2015 4:03:57 PM
`FELICIA PITRE
`DISTRICT CLERK
`M-298TH
`
`
`
`
`
`
`
`II.
`Plaintiff is a limited partnership duly organized and existing under the laws of the State
`of Texas, having its principal place of business in Dallas County, Texas.
`Defendant TZADIK is a limited liability company duly organized and existing under the
`laws of the State of Florida. Service of TZADIK may be had by serving its Registered Agent,
`TZADIK CONSULTING, LLC, at 11098 Biscayne Boulevard, Ste. 203, North Miami, Florida
`33161 OR WHEREVERITMAYBEFOUND.
`Defendant SUMMER is a limited partnership duly organized and existing under the laws
`of the State of Florida. Service of SUMMER may be had by serving its Registered Agent,
`TZADIK MANAGEMENT GROUP, LLC, at 11098 Biscayne Blvd, Ste. 203, North Miami,
`Florida 33161 OR WHEREVER IT MAY BE FOUND.
`VENUE
`III.
`Venue is proper in Dallas County, Texas because the contracts made the basis of this
`lawsuit were entered into and performable in part in Dallas County, Texas.
`FIRST CAUSE OF ACTION:
`SWORN ACCOUNT
`IV.
`At all times mentioned herein, SUMMER owned the Summer Lake Villas Apartments,
`located at 4331 Fiji Drive, New Port Richey, Florida 34653 ("the Property") and did business
`under the assumed name of "Summer Lake Villas Apartments." At all times mentioned herein,
`TZADIK managed the Summer Lake Villas Apartments and was an undisclosed agent of
`SUMMER. At all times mentioned herein, TZADIK did business under the assumed name of
`"Summer Lake Villas Apartments."
`PLAINTIFF'S ORIGINAL PETITION PAGE2
`
`
`
`
`
`
`
`v.
`On several occasions from on or about August 3, 2014 to on or about October 5, 2014, as
`more particularly shown on the attached Exhibit "A," a verified account representing a liquidated
`money demand which is incorporated herein by reference the same as if fully copied and set
`forth at length, Plaintiff, at the request of TZADIK, sold staffing and placement services to
`Defendants for the Summer Lake Villas Apa11ments. In consideration of such sales, on which a
`systematic record has been kept, Defendants promised and agreed to pay Plaintiff the aggregate
`sum of $24,415.22, being a reasonable sum for such services.
`VI.
`As an undisclosed agent for the Owner of the Property, TZADIK is liable to Plaintiff for
`the full amount of the debt. SUMMER, as owner of the property, is liable for the debt incurred
`by the Property.
`VII.
`After the allowance of all just and lawful offsets, payments and credits to Defendants, the
`aggregate sum of $24,415.22 is past due and unpaid and Defendants, though often requested,
`have failed and still refuse to pay the debt.
`VIII.
`Plaintiff has fully performed all conditions, covenants and promises to be performed by
`Plaintiff under Plaintiffs contracts with Defendants.
`IX.
`Plaintiffs claim was timely presented to Defendants and remains unpaid. More than
`thirty (30) days have elapsed since such presentation, and it has become necessary for Plaintiff to
`hire the undersigned attorney in order for Plaintiff to acquire the outstanding balance to which it
`PLAINTIFF'S ORIGINAL PETITION PAGE3
`
`
`
`
`
`
`
`is entitled. In accordance with Section 38.001 of the Texas Civil Practice and Remedies Code,
`Plaintiff is entitled to reimbursement by Defendants for its reasonable attorney's fees, which
`reasonable attorney's fees Plaintiff alleges to be at least $10,000.00 through trial, plus an
`additional $10,000.00 for an appeal to the Texas Court of Appeals, if such an appeal is had, and
`an additional $10,000.00 for an appeal to the Supreme Court of Texas, if such an appeal is had.
`X.
`Plaintiff would fmiher show that Plaintiff is entitled to prejudgment and postjudgment
`interest at the highest legal rate.
`SECOND CAUSE OF ACTION
`QUANTUM MERUTT
`XI.
`Paragraphs I. through X. are incorporated herein by reference the same as if fully copied
`and set forth at length.
`XII.
`Pleading further and in the alternative, Plaintiff would show that on several occasions
`from on or about August 3, 2014 to on or about October 5, 2014, at the request of Defendant
`TZADIK, Plaintiff sold staffing and placement services to the Defendants for the Property.
`Defendants accepted the benefits of such services and knew, or under the circumstances
`reasonably should have known, that Plaintiff expected payment from Defendants for such
`services. The services furnished by Plaintiff were reasonably worth the aggregate sum of
`$24,415.22 at the time same were furnished.
`PLAINTIFF'S ORIGINAL PETITION PAGE4
`
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`
`
`
`
`XIII.
`There remains due and owing to Plaintiff the aggregate sum of $24,415.22, which
`Defendants have failed and refused to pay the debt although proper demand for payment has
`been made by Plaintiff.
`XIV.
`Plaintiff's claim was timely presented to Defendants and remains unpaid. More than
`thirty (30) days have elapsed since such presentation, and it has become necessary for Plaintiff to
`hire the undersigned attorney in order for Plaintiff to acquire the outstanding balance to which it
`is entitled. In accordance with Section 38.001 of the Texas Civil Practice and Remedies Code,
`Plaintiff is entitled to reimbursement by Defendants for its reasonable attorney's fees, which
`reasonable attorney's fees Plaintiff alleges to be at least $10,000.00 through trial, plus an
`additional $10,000.00 for an appeal to the Texas Court of Appeals, if such an appeal is had, and
`an additional $10,000.00 for an appeal to the Supreme Court of Texas, if such an appeal is had.
`XV.
`Plaintiff would further show that Plaintiff is entitled to pr~judgment and postjudgment
`interest at the highest legal rate.
`WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendants
`SUMMER and TZADIK be cited to appear and answer, and that on final trial, Plaintiff have:
`I. Judgment against Defendants, jointly and severally, in the principal sum of
`$24,415.22, with prejudgment interest thereon at the highest legal rate and
`postjudgment interest thereon at the highest legal rate from the date of judgment
`until paid;
`2. Judgment against Defendants, jointly and severally, for attorney's fees as alleged
`above, with postjudgment interest thereon at the highest legal rate from the date of
`judgment until paid;
`3. Judgment against Defendants, jointly and severally, for all costs of suit; and
`PLAINTIFF'S ORIGINAL PETITION PAGES
`
`
`
`
`
`
`
`4. Such other and further relief to which Plaintiff may show itself justly entitled to
`receive.
`PLAINTIFF'S ORIGINAL PETITION
`Respectfully submitted,
`awlins Street, Suite 1300
`D ]as, Texas 75219
`14/521-2814-Telephone
`214/521-8995 -Facsimile
`craigbemstein@birch.net
`ATTORNEY FOR PLAINTIFF
`PAGE6
`
`
`
`
`
`
`
`AFFIDAVIT OF AARON J. GILE
`STATE OF TEXAS §
`§
`COUNTY OF DALLAS §
`BEFORE ME, the undersigned authority, on this day personally appeared AARON J.
`GILE, known to me to be the person whose name is subscribed to the following instrument, and
`who, having been by me duly sworn, upon his oath deposes and states as follows;
`1. "My name is Aaron J. Gile."
`2. "I am the President of the Mutli-Family Division of BG Personnel Services, L.P.
`I am over the age of 21 years, have never been convicted of a felony, and am fully authorized
`and competent to make this affidavit and have pet·sonal knowledge to testifY to all matters
`herein."
`3. "I have care, custody and control of all records concerning the account of
`Defendants TZADIK PROPERTIES, LLC d/b/a SUMMER LAKE VILLAS APARTMENTS
`and SUMMER LAKE VILLA'S HOMEOWNERS ASSOCIATION, INC. d/b/a SUMMER
`LAKE VILLAS APARTMENTS (hereinafter collectively referred to as "Defendants").
`4. "These records show that a principal balance of $24,415.22, exclusive of interest,
`is due and payable by Defendants.
`5. "The Defendants' account which is marked Exhibit "A," is altached to Plaintiffs
`Original Petition, and is within my personal knowledge just and true. The total amount of the
`account is due to Plaintiff by Defendants, and all just and lawful offsets, payments and credits
`have been allowed."
`fURTHER AFFlANT SA YETH NOT.
`PLAINTlFF'S ORlGINAL PETlTION PAGE?
`
`
`
`
`
`
`
`BG PERSONNEL SERVICES, L.P.
`ByM~
`PRESIDENT OF MULTI-FAMILY DIVISION
`SUBSCRIBED AND SWORN TO BEFORE ME, this the 10 day of February, 2015,
`to certify which witness my hand and official seal.
`,.,;;;t~~~. ABBY JOAN JOHNSON
`{:~:..C') .'\ Notary Public, State of Texas
`',,;.·. '"!"{_.:,,; My Commission Expires
`.....,-;.· ·~ •"'ft."''"'
`··!.~.?.ft.:···· January 28, 2019
`PLAINTIFF'S ORIGINAL PETITION
`N~~~& (;~;%~~~Cfet.,
`My Commission Expires: ~'Z.B ZO I G1
`PAGES
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`
`f..:J BG Staffi n8
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`SUMMER lAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/3/2014
`Davila, Rafael Luis
`Feliz, Antonio
`Sanjurju, Paul
`Suarez, Jeffrey
`Vila, Jose
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`907236
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs ·Reg Rate OT Hrs
`40.00 $16.00 0.00
`40.00 $16.00 0.00
`40.00 $22.00 1.00
`16.00 $16.00 0.00
`24.00 $16.00 0.00
`160.00 1.00
`**2% lATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`907236
`Customer#
`104314
`Please detach and return with remittance
`Customer Name
`SUMMER lAKE VILlAS
`MAIL PAYMENTS TO : DUE UPON RECEIPT
`Invoice Date
`8/3/2014
`Invoice Amt
`$2,833.00
`OT Rate Total
`$24.00 $640.00
`$24.00 $640.00
`$33.00 $913.00
`$24.00 $256.00
`$24.00 $384.00
`$2,833.00
`EXHIBIT
`A
`Please Pay
`$2,833.00
`Staffing **2% lATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
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`5000 Legacy Dr Suite 3 50
`Plano, TX 7 5024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/10/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`907979
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 0.00
`23.75 $19.45 0.00
`40.00 $22.00 0.00
`103.75 0.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`907979
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/10/2014
`Invoice Amt
`$1,981.94
`OT Rate Total
`$24.00 $640.00
`$29.18 $461.94
`$33.00 $880.00
`$1,981.94
`Please Pay
`$1,981.94
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
`y BG Staffi n~
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`INVOICE
`Customer#
`104314
`Invoice#
`909978
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`PAYMENT TERMS
`DUE UPON RECEIPT
`TAMPA, FL 34653
`Employee Description Reg Hrs Reg Rate OT Hrs
`WeekendDate: 8/17/2014
`Feliz, Antonio 40.00 $16.00 7.50
`Golden, Andrea 40.00 $19.45 1.50
`Sanjurju, Paul 40.00 $22.00 6.00
`Totals: 120.00 15.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE ....
`Invoice#
`909978
`Customer#
`104314
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`Invoice Date
`8/17/2014
`Invoice Amt
`$2,719.77
`OT Rate Total
`$24.00 $820.00
`$29.18 $821.77
`$33.00 $1,078.00
`$2,719.77
`MAIL PAYMENTS TO: DUE UPON RECEIPT Please Pay
`Page 1 of 1
`f/:t BG Staffing $
`2
`,7
`19
`.
`77
`~~~ **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE ....
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`BG Staffiny
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/24/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`911324
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 3.00
`40.00 $19.45 0.50
`40.00 $22.00 3.00
`120.00 6.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`911324
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/24/2014
`Invoice Amt
`$2,483.59
`OT Rate Total
`$24.00 $712.00
`$29.18 $792.59
`$33.00 $979.00
`$2,483.59
`Please Pay
`$2,483.59
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`P0Box803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`BG Staffiny
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Alicea, Yaril
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 8/31/2014
`Golden, Andrea
`Sanjurju, Paul
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`912972
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`20.00 $16.00 0.00
`40.00 $16.00 6.00
`40.00 $19.45 2.50
`40.00 $22.00 6.50
`140 .00 15.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE*"
`Invoice#
`912972
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`8/31/2014
`Invoice Amt
`$3,049.45
`OT Rate Total
`$24.00 $320.00
`$24.00 $784.00
`$29.18 $850.95
`$33.00 $1 ,094.50
`$3,049.45
`Please Pay
`$3,049.45
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-33 I 2
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
`
`
`
`
`
`
`
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Alicea, Yaril
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA , FL 34653
`Description
`WeekendDate: 9/7/2014
`Golden, Andrea
`Sanjurju, Paul
`TORRES, KEISHLA
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`913255
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`4.00 $16.00 0.00
`37.00 $16.00 0.00
`32.00 $19.45 0.00
`40.00 $22.00 0.50
`8.00 $16.00 0.00
`121.00 0.50
`""2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE*"'
`Invoice#
`913255
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/7/2014
`Invoice Amt
`$2,302.90
`OT Rate Total
`$24.00 $64.00
`$24.00 $592.00
`$29.18 $622.40
`$33.00 $896.50
`$24.00 $128.00
`$2,302.90
`Please Pay
`$2,302.90
`BG Staffing *"2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE"""
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL : 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
`f/;} BG Staffin~
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA , FL 34653
`Description
`WeekendDate: 9/14/2014
`Golden, Andrea
`TORRES, KEISHLA
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`915306
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 5.50
`18.50 $19.45 0.00
`16.00 $16.00 0.00
`74.50 5.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE* *
`Invoice#
`915306
`Customer#
`104314
`MAIL PAYMENTS TO :
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/14/2014
`Invoice Amt
`$1 ,387.83
`OT Rate Total
`$24.00 $772.00
`$29.18 $359.83
`$24.00 $256.00
`$1 ,387.83
`Please Pay
`$1 ,387.83
`f/;J, BG Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE **
`Page 1 of 1
`PO Box 8033 12
`Dallas, TX 75380-3312
`888.278 8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
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`
`
`f/;J• BG Staffi n~
`5000 Legacy Dr Suite 3 50
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 9/21/2014
`GALAN, RAFAEL
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`916479
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 6.25
`23.00 $19.45 0.00
`63.00 6.25
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`916479
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/21/2014
`Invoice Amt
`$1,237.35
`OT Rate Total
`$24.00 $790.00
`$29.18 $447.35
`$1,237.35
`Please Pay
`$1,237.35
`BG Staffing
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
`
`
`
`
`
`
`
`5000 Legacy Dr Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`Feliz, Antonio
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 9/28/2014
`GALAN, RAFAEL
`Perez Perez, Roberto
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`917961
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`40.00 $16.00 6.50
`36.00 $19.45 o .. oo
`17.00 $23.00 0.00
`93.00 6.50
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`917961
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`9/28/2014
`Invoice Amt
`$1,887.20
`OT Rate Total
`$24.00 $796.00
`$29.18 $700.20
`$34.50 $391.00
`$1,887.20
`Please Pay
`$1,887.20
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
`
`
`
`
`
`
`
`t/;J) BG Staffing
`5000 Legacy D r Suite 350
`Plano, TX 75024
`(888) 278-8367 FAX (972) 692-2444
`Employee
`SUMMER LAKE VILLAS
`COMMUNITY DIRECTOR
`4331 FIJI DR
`TAMPA, FL 34653
`Description
`WeekendDate: 10/5/2014
`Diaz, Betzaida
`Feliz, Antonio
`GALAN , RAFAEL
`Martin Arocha, Fidel
`Martin, Jesus
`Perez Perez, Roberto
`Reavis, Chris
`INVOICE
`Totals:
`Customer#
`104314
`Invoice#
`918902
`PAYMENT TERMS
`DUE UPON RECEIPT
`Reg Hrs Reg Rate OT Hrs
`9.00 $18.75 0.00
`40.00 $16.00 8.00
`40.00 $19.45 4.50
`24.00 $23.00 0.00
`22.50 $23.00 0.00
`40.00 $23.00 6.50
`16.50 $24.75 0.00
`192 .00 19.00
`**2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Invoice#
`918902
`Customer#
`104314
`MAIL PAYMENTS TO:
`Please detach and return with remittance
`Customer Name
`SUMMER LAKE VILLAS
`DUE UPON RECEIPT
`Invoice Date
`10/5/2014
`Invoice Amt
`$4,532.19
`OT Rate Total
`$28.13 $168.75
`$24.00 $832.00
`$29.18 $909.31
`$34.50 $552.00
`$34.50 $517.50
`$34.50 $1,144.25
`$37.13 $408.38
`$4,532.19
`Please Pay
`$4,532.19
`Staffing **2% LATE FEE APPLIES ON INVOICES OVER 30 DAYS PAST DUE**
`Page 1 of 1
`PO Box 803312
`Dallas, TX 75380-3312
`888.278.8367 ALL BILLING INQUIRES CALL: 1-888-278-8367 OR FAX 972-692-2444
`Tampa P
`
`
`
`
`
`
`
`
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