Motion,Ex Parte: FEREIDOUN KHALILIAN VS PMC WRECKER SERVICE, LLC. ET AL

On October 14, 2021 a Motion,Ex Parte was filed involving a dispute between Khalilian, Fereidoun, and Begona, Alexis Jesus, Pmc Wrecker Service, Llc., for Other Negligence in the District Court of Miami-Dade County.

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Filing # 141818142 E-Filed 01/12/2022 09:06:04 AM

IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI DADE COUNTY, FLORIDA

CASE NO.: 2021-023135-CA-01
FEREIDOUN KHALILIAN

Plaintiff,

vs.

ALEXIS JESUS BEGONA, individually,
and PMC WRECKER SERVICE, LLC.

Defendants.
________________________________________/

PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION FOR MORE DEFINITE
STATEMENT AND MOTION TO DISMISS COUNT V

Plaintiff, Fereidoun Khalilian (“Khalilian” or “Plaintiff”) hereby files this Response to

Defendants’ Alexis Jesus Begona (“Begona”) and PMC Wrecker Service, LLC (“PMC”)

(collectively referred to as the “Defendants”) Motion for more definite statement and Motion to

Dismiss Count V, and in support thereof state as follows:

I. INTRODUCTION

Plaintiff’s security director, Jonathan Klay (“Klay”) rented a U-Haul in South Miami,

Florida to store Plaintiff’s belongings. Plaintiff’s belongings were boxed and stored inside the U-

Haul and Klay parked the truck on the 1200 block of Madruga Avenue. On or about December 9,

2020, at approximately 9:06 A.M. Officers were dispatched to 1200 block of Madruga Avenue in

reference to a U-Haul vehicle parked illegally on the side, northside of the road where there were

“No Parking” signs posted. As a result of the illegal parking, Coral Gables Police contacted

Defendant, PMC to tow the U-Haul. Defendant Begona was the tow truck Driver, who was an

employee of Defendant PMC. Begona arrived on site to tow the vehicle. The cargo area of the

vehicle was locked with a bronze U-Haul lock. Even though the U-Haul was rented from the
location on 6701 S Dixie Hwy, it was towed to U-Haul’s Medley location.

On December 13, 2020, when the Plaintiff and his security director responded to U-Haul

located in Medley, they noticed a different lock that was not bronze on the vehicle. U-Haul

subsequently cut the lock for them and once they opened the cargo area of the vehicle it was empty,

and all of the property was missing. Plaintiff’s property, as a result of Defendants’ actions were

stolen sometime between the towing of the vehicle from Coral Gables to Medley.

On or about October 14, 2021, the Plaintiff filed suit against the Defendants alleging the

following causes of action I. Negligent Hiring as to Defendant, PMC, II. Negligent Retention as

to Defendant, PMC, III. Negligent Supervision, IV. Conversion as to Defendant Begona, and V.

Civil Theft against all Defendants.

The Defendants have moved to dismiss count V of the Complaint. For the reasons set

forth below, the Defendants’ Motion to Dismiss (“Motion”) is meritless and should be denied.

II. MEMORANDUM OF LAW

a. LEGAL STANDARD

In order to state a cause of action, a complaint must allege sufficient ultimate facts

showing the Defendant is entitled to relief. Edwards v. Landsman, 51 So. 3d 1208, 1213 (Fla. 4th

DCA 2011); W.R. Townsend Contracting, Inc. v. Jensen Civil Constr., Inc., 728 So. 2d 297, 300

(Fla. 1st DCA 1999). The purpose of a complaint is to advise the defendant of the nature of the

case. Kest v. Nathanson, 216 So. 2d 233, 235 (Fla. 4th DCA 1986). “Whether a complaint is

sufficient to state a cause of action is an issue of law.” W.R. Townsend Contracting, Inc., 728 So.

2d at 300. Therefore, when determining whether to dismiss the complaint, “the trial court must

confine its review to the four corners of the complaint, draw all inferences in favor of the pleader,

and accept as true all well-pleaded allegations.” Fox v. Prof'l Wrecker Operators of Fla., Inc., 801
So. 2d 175, 178 (Fla. 5th DCA 2001). The Court’s review is limited to the petition and documents

incorporated therein. Fla. R. Civ. P. 1.130(b) (“[a]ny exhibit attached to a pleading shall be

considered a part thereof for all purposes”).

If a complaint does not state a cause of action, the opportunity to amend should be

liberally given, unless it is apparent the pleading cannot be amended to state a cause of

action. Gamma Dev. Corp. v. Steinberg, 621 So. 2d 718, 719 (Fla. 4th DCA 1993).

b. ARGUMENT

i. THE PLAINTIFF HAS SUFFICIENTLY SET FORTH A CLAIM

FOR CIVIL THEFT AGAINST DEFENDANTS

Every pleading setting forth a claim for relief shall contain “a short and plain statement

of the ultimate facts showing that the pleader is entitled to relief.” Fla. R. Civ. P. 1.110(b). To

establish a claim for civil theft, a party must prove that a conversion has taken place and that the

accused party acted with criminal intent.” Gasparini v. Pordomingo, 972 So. 2d 1053, 1056 (Fla.

3d DCA 2008).

Here, the Plaintiff has alleged all the essential elements to set forth a claim for civil theft.

In paragraph eight of the Complaint, the Plaintiff states “[a]t all times material, the Defendant,

Begona, acting as an agent of his employer, PMC, as a tow truck driver, owed a duty and had the

responsibility to ensure its invitees, that during the time that their possessions were in his care they

would not be lost, stolen, altered, and/or damaged.” (See Exhibit A Complaint) Additionally, in

paragraphs 56 of the Complaint, the Plaintiff states “PMC [], and [] Begona have obtained and/or

used $1,500,000.00 of [] Khalilian’s property without [] Khalilian’s permission.” (See Exhibit A

Complaint). It is clear on the face of the Complaint that PMC and Begona unlawfully and

knowingly used or endeavored to use Khalilian’s property and did knowingly deprive or endeavor
to deprive Khalilian of his property with intent to temporarily or permanently deprive Khalilian of

his right to the property and benefit thereof, all for Defendants’ own use, or the use of any person

not entitled thereto with a felonious intent to steal in violation of §812.014. Additionally, Plaintiff’s

property was stolen sometime between the towing of the vehicle from Coral Gables to Medley, the

only person who had access to the U-Haul during this time was Begona and PMC. Based on the

foregoing, the Plaintiffs have set forth a claim for civil theft and Defendants’ Motion to Dismiss

Count V should be denied.

Defendants additionally argue that “Khalilian alleges that $1,500,000.00 in property was

stolen from him but fails to describe the property in any detail. In paragraphs 11, 18, 19, 29, 39,

48, 49, 52, 57, 59, 60, 61, 62, and 63 of Khalilian’s Complaint he references the $1,500,000.00 in

property as “Plaintiff’s belongings”, “property”, “Plaintiff’s property”, “items”, and “personal

property”. Begona and PMC require a detailed list of the items that were allegedly stolen.”

Defendants are demanding information which is contrary to what Fla. R. Civ. P. 1.110(b) requires

to set forth a claim for relief. The discovery process would be better suited for Defendants to

request the information they are demanding.

ii. RESIDENCY

Defendants allege that “[a] party cannot be a resident of two states. Additionally, a review

of Miami Dade County official records indicates that Khalilian has not filed a sworn statement of

residency with the Miami-Dade County Clerk of Court as required by Statute 222.17.” This

assertion is incorrect. Florida Statute §1009.21(d) defines “legal resident” or “resident” as “a

person who has maintained his or her residence in this state for the preceding year, has purchased

a home which is occupied by him or her as his or her residence, or has established a domicile in

this state pursuant to s. 222.17.” §222.17, Fla. Stat. (2021).
Additionally, Florida Statute §222.17 is very clear that “(1) any person who shall have

established a domicile in this state may manifest and evidence the same by filing in the office of

the clerk of the circuit court for the county in which the said person shall reside a sworn statement

showing that he or she resides in and maintains a place of abode in that county which he or she

recognizes and intends to maintain as his or her permanent home.” §222.17, Fla. Stat. (2021).

There is nothing in this language which requires Khalilian to file a sworn statement of residency

with the clerk of court. Further, there is no evidence that suggests a person cannot achieve dual

residency.

iii. COMMINGLING OF DEFENDANTS IN COUNT V

Florida Rule of Civil Procedure 1.110(f) requires “all averments of claim or defense [to

be] made in consecutively numbered paragraphs, the contents of each of which shall be limited as

far as practicable to a statement of a single set of circumstances, and a paragraph may be referred

to by number in all subsequent pleadings. Each claim founded upon a separate transaction or

occurrence. . . shall be stated in a separate count or defense when a separation facilitates the clear

presentation of the matter set forth.” F.R.C.P. 1.110(f).

There is no rule which requires Plaintiff to separate any causes of action which are alleged

against two Defendants. Florida Rule of Civil Procedure 1.110(f) suggests that when separation

facilitates the clear presentation of the matter it is appropriate however, in this case, Count V for

Civil Theft against both Begona and PMC is clear in that the allegations against each are clearly

formulated and are not confusing. Based on the foregoing, the Plaintiffs have properly set forth a

claim for civil theft and Defendants’ Motion to Dismiss Count V should be denied.

WHEREFORE, Plaintiff, Fereidoun Khalilian, respectfully requests this Court to enter

an Order denying Defendants Motion to Dismiss and any such further relief this Court deems just
and equitable.

Respectfully submitted,

DORTA & ORTEGA, P.A.

___Rey Dorta_________
/s/ Rey Dorta, Esq.
Florida Bar No. 0084920
Yvette C. Buergo, Esq.
Florida Bar No. 1003212
3860 SW 8th Street, PH
Coral Gables, Florida 33134
Telephone: (305) 461-5454
Fax: (305) 461-5226
Email: rdorta@dortaandortega.com
Email: ybuergo@dortaandortega.com
Email: dcruz@dortaandortega.com
Counsel for Plaintiff

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic
correspondence on this 12th day of January 2022 to:

Paul E. Wilson, Esq.
1776 N. Pine Island Blvd. Suite 308
Plantation, Florida 33322
Telephone: 954-327-7285
Email: pwilson@paulwilsonesq.com

______/s/ Rey Dorta______________
REY DORTA
EXHIBIT “A”
Filing # 136547101 E-Filed 10/14/2021 11:33:41 AM

IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

GENERAL JURISDICTION
CASE NO. 2021-0023135-CA-01
FEREIDOUN KHALILIAN,

Plaintiff,

vs.

ALEXIS JESUS BEGONA, individually.
PMC WRECKER SERVICE, LLC., and

Defendants,
/

COMPLAINT

Plaintiff, FEREIDOUN KHALILIAN (herein referred to as “Plaintiff”) sues Defendants,

Alexis Jesus Begona (“Begona”) and PMC Wrecker Service, LLC. (“PMC”) and allege as follows:

JURISDICTIONAL AND GENERAL ALLEGATIONS

1. This is an action for damages in excess of this Court’s jurisdictional minimum of

$30,000.00, exclusive of interest, costs, and attorney’s fees.

2. Plaintiff is a resident of California and Miami-Dade County, Florida and is sui juris.

3. Defendant, PMC Wrecker Service, LLC. is a Florida limited liability company

authorized to transact business in the State of Florida with its principal place of business located

at 1525 NW 89th CT Doral FL, 33172 and is sui juris.

4. Defendant, Alexis Jesus Begona resides in Miami-Dade County, Florida and is sui

juris.

5. Venue is proper in Miami-Dade County Florida, as the subject incident occurred in

Miami-Dade County, Florida.
6. At all times pertinent hereto, Defendant, PMC acted by and through its agents,

apparent agents, ostensible agents, and/or employees, all of which acted within the course and

scope of their employment for Defendant, PMC.

7. At all times pertinent hereto, Defendant, Begona, was employed by PMC as a tow

truck driver acting within the course and scope of his employment for Defendant, PMC.

8. At all times material, the Defendant, Begona, acting as an agent of his employer,

PMC, as a tow truck driver, owed a duty and had the responsibility to ensure its invitees, that

during the time that their possessions were in his care they would not be lost, stolen, altered, and/or

damaged.

9. All conditions precedent to the filing of this action have been performed.

FACTUAL ALLEGATIONS

10. Plaintiff’s security director, Jonathan Klay rented a U-Haul in South Miami,

Florida.

11. Plaintiff’s belongings were boxed and stored inside the U-Haul.

12. Mr. Klay parked the truck on the 1200 block of Madruga Avenue.

13. On or about December 9, 2020, at approximately 9:06 A.M., Officers were

dispatched to 1200 block of Madruga Avenue in reference to a U-Haul vehicle parked illegally on

the side, northside of the road where there were “No Parking” signs posted.

14. As a result of the illegal parking, Coral Gables Police contacted Defendant, PMC

to tow the U-Haul.

15. The tow truck driver, Defendant, Begona, an employee of Defendant PMC, arrived

on site to tow the vehicle. The cargo area of the vehicle was locked with a bronze U-Haul lock.

16. The responding officer waited for the tow truck driver to hook the U-Haul and

depart before he cleared the scene.
17. Even though the U-Haul was rented from the location on 6701 S Dixie Hwy, it was

towed to U-Haul’s Medley location.

18. On December 13, 2020, when the Plaintiff and his security director responded to

U-Haul located in Medley, they noticed a different lock that was not bronze was on the vehicle.

U-Haul subsequently cut the lock for them and once they opened the cargo area of the vehicle it

was empty, and all of the property was missing.

19. Plaintiff’s property, as a result of Defendants’ actions, were stolen sometime

between the towing of the vehicle from Coral Gables to Medley.

COUNT 1:
NEGLIGENT HIRING AS TO DEFENDANT, PMC WRECKER SERVICE LLC.

20. Plaintiff re-alleges and incorporates by reference the allegations contained in

paragraphs 1- 19 above, as though fully set forth herein.

21. At all times material hereto, PMC owed a duty of care to Plaintiff to hire competent,

qualified, and safe employees, and to implement appropriate procedures for the hiring of its

employees, including performing background checks on its employees.

22. At the time of hiring and thereafter Defendant, PMC knew or should have known

that it was foreseeable that their employee would engage in criminal activity, i.e., theft, as he was

on probation for Grand Theft Auto and Petty Theft.

23. “Negligent Hiring” occurs when, prior to the time the employee is actually hired,

the employer knew or should have known of the employee’s unfitness.

24. Defendant, Begona, is an employee of PMC. On March 21, 2018, the Defendant,

Begona was placed on probation for three years for the charge of Grand Theft Auto and Petty

Theft. The Defendant’s probation was to end on March 19, 2021. On the date of this incident on

December 9, 2020, the Defendant was on probation for Grand Theft Auto and Petty Theft.
25. At the time of hiring, the Defendant, PMC Wrecker Service LLC., knew or should

have known that their employee was on probation for the above-mentioned charges.

26. PMC owed the Plaintiff a duty and it was foreseeable that their employee would

engage in the same conduct which he was on probation for while he was employed by them.

27. PMC breached its duty of reasonable care by failing to properly perform a

background check on Begona and by hiring and employee that was unfit for employment.

28. The failure of PMC to exercise reasonable care was a proximate cause of the loss

suffered by Plaintiff.

29. As a result of their negligent hiring, Plaintiff suffered damages when the items

stored in the U-Haul were stolen by Begona.

30. The theft of the personal property in the U-Haul were of the same category as the

criminal past Begona had when hired by Defendant PMC Wrecker, LLC.

WHEREFORE, Plaintiff sues Defendant PMC for damages in excess of $30,000.00, court

costs, and any and all further relief this Court deems just and proper.

COUNT 2:
NEGLIGENT RETENTION, AS TO DEFENDANT, PMC WRECKER SERVICE LLC.

31. Plaintiff re-alleges and incorporates by reference the allegations contained in

paragraphs 1- 19 above, as though fully set forth herein.

32. To establish a Negligent Retention claim under Florida law, a Plaintiff needs to

establish the following: “Negligent Retention” occurs when, during the course of employment, the

employer becomes aware or should have become aware of problems with an employee that

indicated his unfitness, and the employer fails to take further action, such as investigation,

discharge, or reassignment. Magill v. Bartlett Towing, Inc., 35 So.3d 1017 (Fla. 5th DCA 2010).
33. During the time that the Begona was employed by the Defendant, PMC Wrecker

Service LLC., he was on probation for Grand Theft Auto and Petty Theft.

34. PMC failed in whole or in part to continue to monitor Begona after he was hired

and never conducted follow-up investigations into Begona’s criminal record.

35. By failing to do a proper background investigation of Begona, and to re-check

Begona’s background, before sending him to perform his work assignments, PMC failed to use

reasonable care towards Plaintiff.

36. By failing to conduct due diligence regarding its own employment with Begona

that would have timely alerted PMC to Begona’s criminal propensities, PMC failed to use

reasonable care towards Plaintiff.

37. But for its failing to properly monitor Begona, after he was hired, Defendant would

have otherwise been put on notice of Begona’s criminal background and propensity for theft and

would have taken steps to discharge or engage in further investigation.

38. PMC breached its duty to retain only competent and qualified employees to

Plaintiff by retaining Begona as its employee.

39. As a result of the foregoing, Plaintiff suffered damages in the theft of his items by

Begona.

WHEREFORE, Plaintiff sues Defendant PMC for damages in excess of $30,000.00, court

costs and any and all further relief this Court deems just and proper.

COUNT 3:
NEGLIGENT SUPERVISION

40. Plaintiff re-alleges and incorporates by reference the allegations contained in

paragraphs 1- 19 above, as though fully set forth herein.
41. PMC knew or should have known that Begona had a record of criminal behavior

but entrusted him with a tow truck equipped with emergency lights, and the ability to tow vehicles.

Providing such items to a known criminal created a risk of harm to the public at large and Plaintiff,

as such items were used in the theft.

42. PMC had a duty to supervise Begona when he came into contact with the general

public and to ensure the safety of the personal property within the vehicles he towed.

43. During the course of Begona’s employment PMC became aware or should have

become aware of his unfitness for employment but failed to take further action to investigate or

discharge him.

44. PMC breached its duty of supervising Begona to the Plaintiff by not supervising

him adequately, failing to implement policies and procedures for reporting criminal conduct by

employees and failing to implement policies and procedures for the supervision of its employees.

45. PMC’s breach of its supervisory duty over its employee was a proximate cause for

the damages suffered by the Plaintiff.

WHEREFORE, Plaintiff sues Defendant PMC for damages in excess of $30,000.00, court

costs, and any and all further relief this Court deems just and proper.

COUNT 4:
CONVERSION, AS TO DEFENDANT, ALEXIS JESUS BEGONA

46. Plaintiff re-alleges and incorporates by reference the allegations contained in

paragraphs 1- 19 above, as though fully set forth herein.

47. Conversion is the exercise of wrongful dominion or control over property to the

detriment of the rights of the actual owner. United American Bank of Central Florida, Inc. v.

Seligman, 599 So.2d 1014, 1017 (Fla. 5th DCA).

48. The Plaintiff was the rightful owner of the personal property in the U-Haul.
49. Defendant Begona exercised control over the property by placing the U-Haul with

the property on the tow truck.

50. As a result of the tow, Begona was able to appropriate and pilfer Plaintiff’s personal

property and exercise wrongful dominion over said property.

51. This wrongful dominion was to the detriment of the Plaintiff.

52. As a result of Begona’s actions, the Plaintiff’s personal property was stolen, and he

has been damaged as a result.

53. WHEREFORE, Plaintiff sues Defendant PMC for damages in excess of

$30,000.00, court costs, and any and all further relief this Court deems just and proper.

COUNT 5:
CIVIL THEFT AGAINST ALL DEFENDANTS

54. Plaintiff re-alleges and incorporated the allegation contained in paragraphs 1-19

above, as though fully set forth herein.

55. This is an action for civil theft pursuant to Fla. Stat. § 722.11.

56. PMC Wrecker Service, LLC., and Alexis Jesus Begona have obtained and/or used

$1,500,000.00 of Fereidoun Khalilian’s property without Fereidoun Khalilian’s permission.

57. PMC Wrecker Service, LLC., and Alexis Jesus Begona unlawfully and knowingly

used or endeavored to use Fereidoun Khalilian’s property and did knowingly deprive or endeavor

to deprive Fereidoun Khalilian of his property with intent to temporarily or permanently deprive

Fereidoun Khalilian of its right to the property and benefit thereof, all for Defendants’ own use, or

the use of any person not entitled thereto with a felonious intent to steal, in violation of Florida

Statute § 812.014.

58. Pursuant to Fla. Stat § 722.11, Fereidoun Khalilian made a final written statutory

demand for its property on August 30, 2021, to Defendant, PWC Wrecker Service, LLC. A copy
of the demand sent to the Defendant, PWC Wrecker Service, LLC., is attached hereto as Exhibit

“A.”

59. Pursuant to Fla. Stat § 722.11, Fereidoun Khalilian made a final written statutory

demand for its property on August 30, 2021, to Defendant, Alexis Jesus Begona. A copy of the

demand sent to the Defendant Alexis Jesus Begona, is attached hereto as Exhibit “B.”

60. To date, and despite demand by Fereidoun Khalilian, Defendants have failed to

return Fereidoun Khalilian’s property.

61. As a direct and proximate cause of Defendants’ unlawful actions, Fereidoun

Khalilian was and continuous to be deprived of his rights to his property and the benefit therefrom

and has consequently suffered damages in the minimum amount of $1,500,000.00.

62. Pursuant to Fla. Stat. § 722.11, Fereidoun Khalilian is entitled to treble damages in

the minimum amount of $4,500,000.00 for the theft of his property committed by the Defendants.

63. As a direct result of the Defendants depriving Fereidoun Khalilian of his rights to

possess and enjoy its property and the benefit therefrom, and Defendants’ continuing failure and

refusal to return to Fereidoun Khalilian, Fereidoun Khalilian has had to incur attorneys’ fees and

costs.

64. Fereidoun Khalilian is entitled to an award of attorneys’ fees pursuant to Fla. Stat.

§ 722.11.

WHEREFORE, Fereidoun Khalilian demands judgment in its favor against Defendants,

PMC Wrecker Service, LLC., and Alexis Jesus Begona, jointly and severally, as follows:

a. Treble damages in the amount of $4,500,000.00;

b. Attorney’s fees and costs incurred in this matter;

c. Any further relief this court deems just and proper.
DEMAND FOR JURY TRIAL

Plaintiff demand trial by jury on all issues and counts triable by Jury as a matter of right.

Dated this 14th of October 2021.

Respectfully submitted,

DORTA & ORTEGA, P.A.

______________________
Rey Dorta, Esq.
Florida Bar No. 0084920
Yvette Buergo, Esq.
Florida Bar No. 1003212
3860 S.W. 8 Street, Suite PH
Coral Gables, Florida 33134
Telephone: (305) 461-5454
Facsimile: (305) 461-5226
Email: rdorta@dortandortega.com
Email: Ybuergo@dortaandortega.com
Email: dcruz@dortaandortega.com
EXHIBIT “A”
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3860 SW 8th Street, PH, Coral Gables, Florida 33134
Telephone • 305-461-5454 • Facsimile • 305-461-5226
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3860 SW 8th Street, PH, Coral Gables, Florida 33134
Telephone • 305-461-5454 • Facsimile • 305-461-5226
10/4/21, 11:21 AM USPS.com® - USPS Tracking® Results

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Tracking Number: 70190700000058860465

Your item was delivered to an individual at the address at 11:32 am on September 2, 2021 in
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MIAMI, FL 33178

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September 2, 2021, 11:32 am
Delivered, Left with Individual
MIAMI, FL 33178
Your item was delivered to an individual at the address at 11:32 am on September 2, 2021 in MIAMI, FL
33178.

September 1, 2021, 9:25 pm
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MIAMI FL DISTRIBUTION CENTER

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10/4/21, 11:21 AM USPS.com® - USPS Tracking® Results

August 31, 2021, 9:22 pm
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MIAMI FL DISTRIBUTION CENTER

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January 12, 2022

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October 14, 2021

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