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Filing # 51992547 E-Filed 02/02/2017 03:14:08 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION
POWER DESIGN, INC., a Florida
corporation,
Plaintiff,
v. Case No. 16-CA-002324
ARCHER WESTERN DEANGELIS
DIAMOND, JV; ARCHER WESTERN
CONSTRUCTION, LLC, DEANGELIS
DIAMOND CONSTRUCTION, LLC,
and TRAVELERS CASUALTY AND
SURETY COMPANY OF AMERICA,
Defendants.
NOTICE OF FILING
Plaintiff, Power Design, Inc., by and through its undersigned attorneys, hereby
gives notice of filing the Summons, Standing Order, and Return of Service as to
Defendant, Archer Western Deangelis Diamond, JV.
Dated: February 2, 2017
/s/ Paul J. Ullom
Paul J. Ullom
Florida Bar No. 776513
Jason J. Quintero
Florida Bar No. 019142
Carlton Fields PA
PO Box 3239
Tampa, FL 33601-3239
Telephone 813-223-7000
Facsimile 813-229-4133
pullom@carltonfields.com
jquintero@carltonfields.com
Icoffey@carltonfields.com
delliott@carltonfields.com
Counsel for Plaintiff
110290983.1
FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 02/03/2017 12:19:14 PMRETURN OF SERVICE
State of Florida County of Colller Circuit Court
Case Number: 11-16-CA-2324-1-XX
Plaintiff,
Power Design Inc.,
vs.
Defendant:
Archer Western Deangells Diamond, Jv; Archer Western Construction, Lie; Deangelis
Diamond Construction, Llc; Travelers Casualty and Surety Company of America,
For: Paul J. Ullom
Carlton Flelds Jorden Burt, P.A.
Received by SLK INVESTIGATIONS, INC. on the 29th day of December, 2016 at 12:23 bm fo 10 be served ‘on Archer Western
te eee Diamond, Jv, 929 West Adams Street, Chicago, IL, 60807, |, do hereby affirm that on
the Z7 day y of Aaanaty 20.17 at_{] :i5 Asm, executed service by hosing wie Copy of the SUMMONS, STANDING
ORDER IN CIVIL CASES IN THE TWENTIETH JUDICIAL CIRCUIT, COMPLAINT and EXHIBITS in accordance with state statutes in
the manner marked below:
() AUTHORIZED ENTITY: By serving as .
3 PUBLIC AGENCY: B oy serving of the within-named agency,
CORPORATE SERVICE: By ning Bor Blo ae.
Cotaalote Couns?
() OTHER SERVICE: As described in the Comments below by serving
as
() NON SERVICE: For the reason detalled in the Comments below.
comments: The addizsss oe Seiee was 307 S Sengam on Ch.cage, Il IL €0607%
\_gerves Etc Gas ns Compote Course
| certify that | have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service
was made, Under penalties of perjury, | declare that | have read the foregoing affidavit and that the facts stated in it are true.”
Chm
PROCESS SERVER #
Appointed In accordance with State Statutes
SLK INVESTIGATIONS, INC,
2212 East 5th Avenue
Tampa, FL 33605
(813) 247-6250
Our Job Serial Number: 2016005922
‘Copyright © 1982-2016 Dalabaso Servicos, Inc, - Procoss Server's Toalbox V/.19,
5) 964IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
Power Design Inc
Plaintiff(s),
vs. CASE NO: 11-2016-CA-002324-0001-XX
Archer Western Deangelis Diamond, Jv
Archer Western Construction, Lle
Deangelis Diamond Construction, Llc
Travelers Casualty And Surety Company Of America
Defendant(s).
SUMMONS
THE STATE OF FLORIDA
To Each Sheriff of the State or duly constituted public officer qualified to serve process
in the state or jurisdiction:
YOU ARE COMMANDED to serve this summons and a copy of the complaint in this
lawsuit on defendant:
Archer Western Deangelis Diamond, Jv
929 West Adams Street Chicago IL 60607
Each defendant is required to serve written defenses to the complaint or petition on
Quintero, Jason Jude PO Box 3239 Tampa FL 336013239 8132237000, within 20 days
after service of this summons on that defendant, exclusive of the day of service, and to
file the original of the defenses with the clerk of this court either before service on
plaintiff's attorney or immediately thereafter. If a defendant fails to do so, a default will
be entered against that defendant for the relief demanded in the complaint or petition.
DATED on 28th of December, 2016
Dwight E Brock
As Clerk of the Court
Cacia Xl
By Catherine Klug, Deputy Clerk
ORIGINALIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
Power Design Inc
Plaintiff(s),
vs. CASE NO: 11-2016-CA-002324-0001-XX
Archer Western Deangelis Diamond, Jv
Archer Western Construction, Lle
Deangelis Diamond Construction, Lic
Travelers Casualty And Surety Company Of America
Defendant(s).
STANDING ORDER IN CIVIL CASES IN THE TWENTIETH JUDICIAL CIRCUIT
PURSUANT to Florida Rule of Civil Procedure 1.200(a), Florida Rule of Judicial
Administration 2.545, and Administrative Order 1.13 entered by the Chief Judge of this Circuit,
the parties are ordered to adhere to the following information and procedures applicable to civil
lawsuits:
1. SERVICE OF THIS ORDER, The Plaintiff is directed to serve a copy of this Order
with each Summons issued in this case. One copy of this Order is to be filed with the
Clerk of the Circuit Court with proof of service. The Plaintiff shall pay the appropriate
statutory clerk’s fees on copies for each Standing Order issued and attached to the
Summons.
2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has
established guidelines for the prompt processing and resolution of civil cases. This
Court has adopted a case management system to help meet those guidelines. In
contested cases (other than foreclosures, involuntary commitment of sexually violent
predators and eminent domain cases), the parties are required to participate in the case
management system. The case management system requires early consultation and
cooperation among the parties for the preparation and submission of an Agreed Case
Management Plan, early interaction with a Civil Case Manager and early involvement
by the Court. The Agreed Case Management Plan requires the parties to identify a
case track, confer in good faith, attempt to narrow the matters in controversy, identify
the issues that require direct involvement by the Court and establish a schedule for
addressing those issues.' The Agreed Case Management Plan may be accessed at the
Court’s website at: [www.ca.cjis20.org].
Unless all of the Defendants have been served and have defaulted, an Agreed Case
Management Plan will be submitted to the Civil Case Manager c/o Magistrate’s Office
(ATTENTION: Sherry), Collier County Courthouse, 3315 Tamiami Trail E., Suite
509, Naples, FL 34112 on or before 150 days from the date of filing the initial
complaint. If the parties are unable to agree on an Agreed Case Management Plan, a
case management conference will be scheduled by the Court. If a case management
1 Case Track options include Expedited, Standard or Complex. Case Tracks have been established in order to
comply with the case disposition standards set forth in Florida Rule of Judicial Administration 2.250(a)(1)B.conference is scheduled, attendance by trial counsel and those parties who are not
represented by counsel is mandatory.
. ALTERNATIVE DISPUTE RESOLUTION (ADR). ADR provides parties with an
out-of-court alternative to settling disagreements. The Court requires the parties to
participate in ADR prior to trial. Mediation is mandatory unless the parties agree to
another form of ADR. Mediation is a conference at which an independent third party
attempts to arrange a settlement between the parties.
. RULES OF PROFESSIONALISM. The Twentieth Judicial Circuit has adopted
Administrative Order 2.20, which sets forth standards of professional courtesy and
conduct for all counsel or pro-se litigants practicing within the Circuit. The Court
requires that all familiarize themselves and comply with Administrative Order 2.20.
Administrative Order 2.20 may be viewed on the Court’s website at:
[www.ca.cjis20.org].
DONE AND ORDERED in Chambers at Naples, Collier County, Florida, on this
28th of December, 2016
Jig pape!
Hugh D Hayes, Circuit Judge
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Filing # 51992547 E-Filed 02/02/2017 03:14:08 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISION POWER DESIGN, INC., a Florida corporation, Plaintiff, v. Case No. 16-CA-002324 ARCHER WESTERN DEANGELIS DIAMOND, JV; ARCHER WESTERN CONSTRUCTION, LLC, DEANGELIS DIAMOND CONSTRUCTION, LLC, and TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA, Defendants. NOTICE OF FILING Plaintiff, Power Design, Inc., by and through its undersigned attorneys, hereby gives notice of filing the Summons, Standing Order, and Return of Service as to Defendant, Archer Western Deangelis Diamond, JV. Dated: February 2, 2017 /s/ Paul J. Ullom Paul J. Ullom Florida Bar No. 776513 Jason J. Quintero Florida Bar No. 019142 Carlton Fields PA PO Box 3239 Tampa, FL 33601-3239 Telephone 813-223-7000 Facsimile 813-229-4133 pullom@carltonfields.com jquintero@carltonfields.com Icoffey@carltonfields.com delliott@carltonfields.com Counsel for Plaintiff 110290983.1 FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 02/03/2017 12:19:14 PMRETURN OF SERVICE State of Florida County of Colller Circuit Court Case Number: 11-16-CA-2324-1-XX Plaintiff, Power Design Inc., vs. Defendant: Archer Western Deangells Diamond, Jv; Archer Western Construction, Lie; Deangelis Diamond Construction, Llc; Travelers Casualty and Surety Company of America, For: Paul J. Ullom Carlton Flelds Jorden Burt, P.A. Received by SLK INVESTIGATIONS, INC. on the 29th day of December, 2016 at 12:23 bm fo 10 be served ‘on Archer Western te eee Diamond, Jv, 929 West Adams Street, Chicago, IL, 60807, |, do hereby affirm that on the Z7 day y of Aaanaty 20.17 at_{] :i5 Asm, executed service by hosing wie Copy of the SUMMONS, STANDING ORDER IN CIVIL CASES IN THE TWENTIETH JUDICIAL CIRCUIT, COMPLAINT and EXHIBITS in accordance with state statutes in the manner marked below: () AUTHORIZED ENTITY: By serving as . 3 PUBLIC AGENCY: B oy serving of the within-named agency, CORPORATE SERVICE: By ning Bor Blo ae. Cotaalote Couns? () OTHER SERVICE: As described in the Comments below by serving as () NON SERVICE: For the reason detalled in the Comments below. comments: The addizsss oe Seiee was 307 S Sengam on Ch.cage, Il IL €0607% \_gerves Etc Gas ns Compote Course | certify that | have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made, Under penalties of perjury, | declare that | have read the foregoing affidavit and that the facts stated in it are true.” Chm PROCESS SERVER # Appointed In accordance with State Statutes SLK INVESTIGATIONS, INC, 2212 East 5th Avenue Tampa, FL 33605 (813) 247-6250 Our Job Serial Number: 2016005922 ‘Copyright © 1982-2016 Dalabaso Servicos, Inc, - Procoss Server's Toalbox V/.19, 5) 964IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION Power Design Inc Plaintiff(s), vs. CASE NO: 11-2016-CA-002324-0001-XX Archer Western Deangelis Diamond, Jv Archer Western Construction, Lle Deangelis Diamond Construction, Llc Travelers Casualty And Surety Company Of America Defendant(s). SUMMONS THE STATE OF FLORIDA To Each Sheriff of the State or duly constituted public officer qualified to serve process in the state or jurisdiction: YOU ARE COMMANDED to serve this summons and a copy of the complaint in this lawsuit on defendant: Archer Western Deangelis Diamond, Jv 929 West Adams Street Chicago IL 60607 Each defendant is required to serve written defenses to the complaint or petition on Quintero, Jason Jude PO Box 3239 Tampa FL 336013239 8132237000, within 20 days after service of this summons on that defendant, exclusive of the day of service, and to file the original of the defenses with the clerk of this court either before service on plaintiff's attorney or immediately thereafter. If a defendant fails to do so, a default will be entered against that defendant for the relief demanded in the complaint or petition. DATED on 28th of December, 2016 Dwight E Brock As Clerk of the Court Cacia Xl By Catherine Klug, Deputy Clerk ORIGINALIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION Power Design Inc Plaintiff(s), vs. CASE NO: 11-2016-CA-002324-0001-XX Archer Western Deangelis Diamond, Jv Archer Western Construction, Lle Deangelis Diamond Construction, Lic Travelers Casualty And Surety Company Of America Defendant(s). STANDING ORDER IN CIVIL CASES IN THE TWENTIETH JUDICIAL CIRCUIT PURSUANT to Florida Rule of Civil Procedure 1.200(a), Florida Rule of Judicial Administration 2.545, and Administrative Order 1.13 entered by the Chief Judge of this Circuit, the parties are ordered to adhere to the following information and procedures applicable to civil lawsuits: 1. SERVICE OF THIS ORDER, The Plaintiff is directed to serve a copy of this Order with each Summons issued in this case. One copy of this Order is to be filed with the Clerk of the Circuit Court with proof of service. The Plaintiff shall pay the appropriate statutory clerk’s fees on copies for each Standing Order issued and attached to the Summons. 2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has established guidelines for the prompt processing and resolution of civil cases. This Court has adopted a case management system to help meet those guidelines. In contested cases (other than foreclosures, involuntary commitment of sexually violent predators and eminent domain cases), the parties are required to participate in the case management system. The case management system requires early consultation and cooperation among the parties for the preparation and submission of an Agreed Case Management Plan, early interaction with a Civil Case Manager and early involvement by the Court. The Agreed Case Management Plan requires the parties to identify a case track, confer in good faith, attempt to narrow the matters in controversy, identify the issues that require direct involvement by the Court and establish a schedule for addressing those issues.' The Agreed Case Management Plan may be accessed at the Court’s website at: [www.ca.cjis20.org]. Unless all of the Defendants have been served and have defaulted, an Agreed Case Management Plan will be submitted to the Civil Case Manager c/o Magistrate’s Office (ATTENTION: Sherry), Collier County Courthouse, 3315 Tamiami Trail E., Suite 509, Naples, FL 34112 on or before 150 days from the date of filing the initial complaint. If the parties are unable to agree on an Agreed Case Management Plan, a case management conference will be scheduled by the Court. If a case management 1 Case Track options include Expedited, Standard or Complex. Case Tracks have been established in order to comply with the case disposition standards set forth in Florida Rule of Judicial Administration 2.250(a)(1)B.conference is scheduled, attendance by trial counsel and those parties who are not represented by counsel is mandatory. . ALTERNATIVE DISPUTE RESOLUTION (ADR). ADR provides parties with an out-of-court alternative to settling disagreements. The Court requires the parties to participate in ADR prior to trial. Mediation is mandatory unless the parties agree to another form of ADR. Mediation is a conference at which an independent third party attempts to arrange a settlement between the parties. . RULES OF PROFESSIONALISM. The Twentieth Judicial Circuit has adopted Administrative Order 2.20, which sets forth standards of professional courtesy and conduct for all counsel or pro-se litigants practicing within the Circuit. The Court requires that all familiarize themselves and comply with Administrative Order 2.20. Administrative Order 2.20 may be viewed on the Court’s website at: [www.ca.cjis20.org]. DONE AND ORDERED in Chambers at Naples, Collier County, Florida, on this 28th of December, 2016 Jig pape! Hugh D Hayes, Circuit Judge