On November 07, 2022 a
Party Statement
was filed
involving a dispute between
Madeline Johnston,
and
Cortello Salon Inc.,
for Other Circuit Civil - Other Division: CV-C
in the District Court of Duval County.
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Filing # 164870952 E-Filed 01/17/2023 02:50:44 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
MADELINE JOHNSTON,
Plaintiff/Counter-Defendant,
Case No: 2022-CA-6522
vs.
Division: CV-C
CORTELLO SALON, INC.
Defendant/Counter-Plaintiff.
______________!
AFFIDAVIT OF GABRIELLA SCHWAB
BEFORE ME, the undersigned authority, personally appeared Gabriella Schwab, who,
upon being duly sworn, deposes and says as follows:
1. I am over the age of eighteen years and fully competent to testify as to the matters
set forth in this Affidavit, which are true and correct based upon personal knowledge.
2. I have been using Plaintiff/Counter-Defendant Madeline Johnston's hair styling
services for at least two years.
3. I first went to Cortello Salon after reading reviews. I went to Cortello with the intent
of having a master colorist color my hair, then I planned to have somebody !es exoensive take over
after the master colorist rendered service. I received good services from Ms. Johnston.
4. Cortello Salon did not have transparency in pricing, and the only time I knew how
Cortello Salon priced its services was when Ms. Johnston put together my service pricing when I
was present.
5. If I did not have Ms. Johnston as my stylist, I would not have returned to Cortello
Salon after my first visit because of pricing.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/18/2023 08:02:39 AM
6. I left Cariello Salon because I did not know which stylist was going to be assigned
to me after Ms. Johnston left and because of my concerns about the consistency of pricing.
7. I would not return to Cariello Salon following its implementation of the new price
structure regardless of whether Ms. Johnston worked there because of its inconsistent pricing. I
have received hair services from a number of saloons and have changed stylists over time, and
Cariello Salon's pricing structure is distinct because it emphasizes upselling, not on products, but
on services.
8. I learned that Ms. Johnston left Cortello Salon when I received a text message from
Cariello stating that Ms. Johnston left the salon and asking me to set up an appointment for services
with another stylist.
9. Upon learning that Ms. Johnston left Cariello Salon, I messaged Ms. Johnston to
find out why she left.
I hereby swear and affirm under oath that the facts stated in the foregoing Affidavit are
true.
Gabriella Schwab
STATE OF FLORIDA
COUNTY OF 'f>1J,(;kl
Sworn to (or affirmed) and subscribed before me by means of [A:J. personal appearance or
[_] online notarization, who is [_] personally known to me or [.&'.j_ who has produced
/40,;;.:r12..,/,;.u-.A.A.lil�ras identification this �day of �vkl?-'f 2023, by Gabriella
Schwab, after having first been duly sworn, deposes and says that the facts stated in her Affidavit
are true and correct to the best of her knowledge and belief.
2
7
ary Public, State of Florida
ignature]
Respectfully submitted this 17th day of January 2023.
DELEGAL & POINDEXTER P.A.
Isl T.A. "Tad" Delegal. III. B.C.S.
T.A. "Tad" Delegal, III, B.C.S.
FL Bar No. 0892701
Email: tad@delegal.net
James C. Poindexter
FL Bar No. 116039
Email: james@delegal.net
Alexandra E. Underkofler
Fla. Bar No.: 1018209
Email: alex@delegal.net
424 East Monroe Street
Jacksonville, FL 32202
Phone (904) 633-5000
Facsimile (904) 358-2850
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of January 2023, I electronically filed the
foregoing with the Clerk of the Court using the Florida Courts E-Filing portal, which will serve
the document electronically by email on the following:
Murphy & Anderson, P.A.
Geddes Anderson, Esq.
Email: ganderson@murphyandersonlaw.com
Sarah Jeck Hulsberg
Email: shulsberg@murphyandersonlaw.com
Isl T A. Delegal, III
T.A. Delegal, III
3
Document Filed Date
January 17, 2023
Case Filing Date
November 07, 2022
Category
Other Circuit Civil - Other Division: CV-C
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Filing # 164870952 E-Filed 01/17/2023 02:50:44 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA MADELINE JOHNSTON, Plaintiff/Counter-Defendant, Case No: 2022-CA-6522 vs. Division: CV-C CORTELLO SALON, INC. Defendant/Counter-Plaintiff. ______________! AFFIDAVIT OF GABRIELLA SCHWAB BEFORE ME, the undersigned authority, personally appeared Gabriella Schwab, who, upon being duly sworn, deposes and says as follows: 1. I am over the age of eighteen years and fully competent to testify as to the matters set forth in this Affidavit, which are true and correct based upon personal knowledge. 2. I have been using Plaintiff/Counter-Defendant Madeline Johnston's hair styling services for at least two years. 3. I first went to Cortello Salon after reading reviews. I went to Cortello with the intent of having a master colorist color my hair, then I planned to have somebody !es exoensive take over after the master colorist rendered service. I received good services from Ms. Johnston. 4. Cortello Salon did not have transparency in pricing, and the only time I knew how Cortello Salon priced its services was when Ms. Johnston put together my service pricing when I was present. 5. If I did not have Ms. Johnston as my stylist, I would not have returned to Cortello Salon after my first visit because of pricing. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/18/2023 08:02:39 AM 6. I left Cariello Salon because I did not know which stylist was going to be assigned to me after Ms. Johnston left and because of my concerns about the consistency of pricing. 7. I would not return to Cariello Salon following its implementation of the new price structure regardless of whether Ms. Johnston worked there because of its inconsistent pricing. I have received hair services from a number of saloons and have changed stylists over time, and Cariello Salon's pricing structure is distinct because it emphasizes upselling, not on products, but on services. 8. I learned that Ms. Johnston left Cortello Salon when I received a text message from Cariello stating that Ms. Johnston left the salon and asking me to set up an appointment for services with another stylist. 9. Upon learning that Ms. Johnston left Cariello Salon, I messaged Ms. Johnston to find out why she left. I hereby swear and affirm under oath that the facts stated in the foregoing Affidavit are true. Gabriella Schwab STATE OF FLORIDA COUNTY OF 'f>1J,(;kl Sworn to (or affirmed) and subscribed before me by means of [A:J. personal appearance or [_] online notarization, who is [_] personally known to me or [.&'.j_ who has produced /40,;;.:r12..,/,;.u-.A.A.lil�ras identification this �day of �vkl?-'f 2023, by Gabriella Schwab, after having first been duly sworn, deposes and says that the facts stated in her Affidavit are true and correct to the best of her knowledge and belief. 2 7 ary Public, State of Florida ignature] Respectfully submitted this 17th day of January 2023. DELEGAL & POINDEXTER P.A. Isl T.A. "Tad" Delegal. III. B.C.S. T.A. "Tad" Delegal, III, B.C.S. FL Bar No. 0892701 Email: tad@delegal.net James C. Poindexter FL Bar No. 116039 Email: james@delegal.net Alexandra E. Underkofler Fla. Bar No.: 1018209 Email: alex@delegal.net 424 East Monroe Street Jacksonville, FL 32202 Phone (904) 633-5000 Facsimile (904) 358-2850 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January 2023, I electronically filed the foregoing with the Clerk of the Court using the Florida Courts E-Filing portal, which will serve the document electronically by email on the following: Murphy & Anderson, P.A. Geddes Anderson, Esq. Email: ganderson@murphyandersonlaw.com Sarah Jeck Hulsberg Email: shulsberg@murphyandersonlaw.com Isl T A. Delegal, III T.A. Delegal, III 3