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Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K. SCHMITZ,
as Husband and Wife,
Plaintiffs,
v CASE NO.: 16001754CA
ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,
Defendants.
/
COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL
COME NOW the Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, and sue
the Defendants, ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, and
allege:
JURISDICTION AND VENUE
1 This is an action for damages in excess of Fifteen Thousand ($15,000.00)
Dollars, exclusive of costs, interest and attorneys’ fees.
2. At all times material hereto, Plaintiffs, WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, were residents of Arcadia, DeSoto County, Florida.
3. At all times material hereto, the Defendant, ALEXMAR PIMIENTA GARRIDO,
was a resident of Tampa, Hillsborough County, Florida.
4. Defendant, JLL LOGISTIC INC, a Corporation, is now, and at all times herein
mentioned was, a corporation duly organized and existing under the laws of the State of Florida
and duly authorized and licensed to do business in the State of Florida.
5. At all times material hereto, the Defendant, ROBERTO LI, was a resident of
Tampa, Hillsborough County, Florida and is the owner of the Defendant vehicle.
6 All incidents giving rise to the causes of action set forth herein occurred in Punta
Gorda, Charlotte County, Florida.
GENERAL ALLEGATIONS
7. On November 24, 2015, Defendant, ALEXMAR PIMIENTA GARRIDO, operated
a 1999 Volvo truck (Vehicle Identification Number: 4VG7DARJ9XN769587) that was owned by
Defendants, JLL LOGISTIC INC and ROBERTO LI, (hereinafter “the Subject Vehicle’). The
Subject Vehicle was an instrumentality that is peculiarly dangerous in its operation.
8. At all times material hereto, the Subject Vehicle was being used at the direction
of Defendants, JLL LOGISTIC INC and ROBERTO LI, on their behalf. The Subject Vehicle was
an instrumentality that is peculiarly dangerous in its operation.
9. On November 24, 2015, Defendant, ALEXMAR PIMIENTA GARRIDO, was
operating the Subject Vehicle and was traveling on US 17 at or near the intersection of Regent
Road, Punta Gorda, Charlotte County, Florida.
10. On November 24, 2015, Plaintiff, WILLIAM H. SCHMITZ, owned and operated a
2004 Dodge Ram (Vehicle identification Number: 3D7KA28C54G272437) and was also
traveling on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County,
Florida.
41. At that time and place, Defendant, ALEXMAR PIMIENTA GARRIDO, operated,
maintained, and/or used the Subject Vehicle in such a negligent manner as to cause a collision
involving the motor vehicle operated by Plaintiff, WILLIAM H. SCHMITZ, resulting in injuries to
Plaintiff, WILLIAM H. SCHMITZ and other damages as hereinafter described.
COUNT 1: NEGLIGENCE
(As to ALEXMAR PIMIENTA GARRIDO)
12. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
eleven (11) as if fully set forth herein.
13. On November 24, 2015, and at all times material hereto, ALEXMAR PIMIENTA
GARRIDO was in possession, custody and control of the Subject Vehicle.
14. At all times material hereto, ALEXMAR PIMIENTA GARRIDO owed a duty to
exercise reasonable care in the operation, maintenance, and/or use of the Subject Vehicle for
the benefit of other individuals on public roadways.
15. On November 24, 2015, ALEXMAR PIMIENTA GARRIDO breached his duty of
care to other individuals on the above-described public roadway, and in particular to Plaintiff,
WILLIAM H. SCHMITZ, as he was negligent and careless in the operation, maintenance, and/or
use of the Subject Vehicle.
16. ALEXMAR PIMIENTA GARRIDO was negligent in his:
a. Failure to operate the Subject Vehicle in a safe and reasonable manner;
b. Failure to operate the Subject Vehicle in compliance with state and local traffic
laws;
Failure to keep headlights or other lights on the Subject Vehicle on at night;
Failure to keep an adequate and proper lookout for oncoming traffic;
Failure to avoid the collision with Plaintiff's vehicle; or
f. Other acts of negligence to be determined through discovery.
47. As a direct and proximate result of ALEXMAR PIMIENTA GARRIDO's
negligence, Plaintiff, WILLIAM H. SCHMITZ, suffered bodily injury and resulting pain and
suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life,
expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of
ability to earn money, loss of or damage to property, and/or aggravation of a previously existing
condition.
18. The losses are permanent and continuing in nature and Plaintiff will suffer such
losses in the future.
WHEREFORE, Piaintiff, WILLIAM H. SCHMITZ, demands judgment for damages
against Defendant, ALEXMAR PIMIENTA GARRIDO, in excess of $15,000, as well as post-
judgment interest and the costs of bringing this action as allowed by law, and other relief this
Honorable Court deems just and proper.
COUNT II - NEGLIGENCE
(As to JLL LOGISTIC INC)
19. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
eighteen (18) as if fully set forth herein.
20. On November 24, 2015, and at all times material hereto, the Subject Vehicle was
being used by ALEXMAR PIMIENTA GARRIDO while in the course and scope of his
employment, at the direction of JLL LOGISTIC INC, and on JLL LOGISTIC INC’s behalf.
21. At all times material hereto, JLL LOGISTIC INC owed a duty to exercise
reasonable care in the operation and/or use of the subject vehicle for the benefit of other
individuals on the public roadways.
22. At all times material hereto, JLL LOGISTIC INC, breached its duty of care to
other individuals on the above described public roadways, and in particular to Plaintiff, it was
negligent and careless in the operation and/or maintenance and/or use of the Subject Vehicle.
23. JLL LOGISTIC INC was negligent, directly and/or through the conduct of
ALEXMAR PIMIENTA GARRIDO.
24. As a direct and proximate result of JLL LOGISTIC INC’s negligence, directly or
through the conduct of ALEXMAR PIMIENTA GARRIDO, Plaintiff, WILLIAM H. SCHMITZ,
suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish,
loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care
and treatment, loss of earnings, loss of ability to earn money, loss of or damage to property,
and/or aggravation of a previously existing condition.
WHEREFORE, Plaintiff, WILLIAM H. SCHMITZ, demands judgment for damages
against Defendant, JLL LOGISTIC INC, in excess of $15,000, as well as post-judgment interest
and the costs of bringing this action as allowed by law, and other relief this Honorable Court
deems just and proper.
COUNT Il - NEGLIGENCE
(As to ROBERTO LI)
25. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
eighteen (18) as if fully set forth herein.
26. At all times material hereto, ROBERTO LI owed a duty to exercise reasonable
care in the operation and/or use of the subject vehicle for the benefit of other individuals on the
public roadways.
27. At all times material hereto, ROBERTO LI, breached his duty of care to other
individuals on the above described public roadways, and in particular to Plaintiff, it was
negligent and careless in the operation and/or maintenance and/or use of the Subject Vehicle.
28. ROBERTO LI was negligent, directly and/or through the conduct of ALEXMAR
PIMIENTA GARRIDO.
29. As a direct and proximate result of ROBERTO LI’s negligence, directly or through
the conduct of ALEXMAR PIMIENTA GARRIDO, Plaintiff, WILLIAM H. SCHMITZ, suffered
bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of
capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and
treatment, loss of earnings, loss of ability to earn money, loss of or damage to property, and/or
aggravation of a previously existing condition.
WHEREFORE, Plaintiff, WILLIAM H. SCHMITZ, demands judgment for damages
against Defendant, ROBERTO LI, in excess of $15,000, as well as post-judgment interest and
the costs of bringing this action as allowed by law, and other relief this Honorable Court deems
just and proper.
COUNT Ill: CONSORTIUM CLAIM
{As to ALEXMAR PIMIENTA GARRIDO)
30. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
eighteen (18) as if fully set forth herein.
31. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H.
SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a
family relationship.
32. As a direct and proximate result of the above-described incident, Plaintiff,
JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following
damages:
Loss of said spouse’s consortium.
Loss of said spouse’s services.
The cost and expense of having medical care, attention and treatment for
said spouse, the cost of travel necessary to secure said medical case,
attention for said spouse and the cost of related medical expense for said
spouse.
WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against
Defendant, ALEXMAR PIMIENTA GARRIDO, to the extent permitted under Florida law, as well
as post-judgment interest and the costs of bringing this action as allowed by law, and other relief
this Honorable Court deems just and proper.
COUNT III: CONSORTIUM CLAIM
(As to JLL LOGISTIC INC)
33. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
twenty-four (24) as if fully set forth herein.
34. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H.
SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a
family relationship.
35. As a direct and proximate result of the above-described incident, Plaintiff,
JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following
damages:
a Loss of said spouse's consortium.
b Loss of said spouse’s services,
C. The cost and expense of having medical care, attention and treatment for
said spouse, the cost of travel necessary to secure said medical case,
attention for said spouse and the cost of related medical expense for said
spouse.
WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against
Defendant, JLL LOGISTIC INC, to the extent permitted under Florida law, as well as post-
judgment interest and the costs of bringing this action as allowed by law, and other relief this
Honorable Court deems just and proper.
COUNT IH: CONSORTIUM CLAIM
(As to ROBERTO LI)
36. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through
eighteen (18) and paragraphs twenty-five (25) through twenty-nine (29) as if fully set forth
herein.
37. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H.
SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a
family relationship.
38. As a direct and proximate result of the above-described incident, Plaintiff,
JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following
damages:
a Loss of said spouse's consortium.
Loss of said spouse’s services.
The cost and expense of having medical care, attention and treatment for
said spouse, the cost of travel necessary to secure said medical case,
attention for said spouse and the cost of related medical expense for said
spouse.
WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against
Defendant, ROBERTO LI, to the extent permitted under Florida law, as well as post-judgment
interest and the costs of bringing this action as allowed by law, and other relief this Honorable
Court deems just and proper.
DEMAND FOR JURY TRIAL
Plaintiffs demand a trial by jury by all issues so triable.
Dated: This Wt day of September, 2016
Respectfully submitted,
GOLDBERG, RACILA,
D'ALESSANDRO & NOONE, LLC
Attorneys for Plaintiffs
Post Office Box 190
Fort Myers, Florida 33902-0190
(239) 461-5508
(239) 461-3915 (Facsimile)
on ESO. Vllocos
Michael/M. Noone
Florida ar No.: 0105139
Email: MikeNoone oldberg-law.com
ervice@goldberg-law.com
Elizete D, Velado
Florida Bar No.: 0099668
Email: lizeteVelador joldberg-law.com
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Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and Wife, Plaintiffs, v CASE NO.: 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL COME NOW the Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, and sue the Defendants, ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, and allege: JURISDICTION AND VENUE 1 This is an action for damages in excess of Fifteen Thousand ($15,000.00) Dollars, exclusive of costs, interest and attorneys’ fees. 2. At all times material hereto, Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, were residents of Arcadia, DeSoto County, Florida. 3. At all times material hereto, the Defendant, ALEXMAR PIMIENTA GARRIDO, was a resident of Tampa, Hillsborough County, Florida. 4. Defendant, JLL LOGISTIC INC, a Corporation, is now, and at all times herein mentioned was, a corporation duly organized and existing under the laws of the State of Florida and duly authorized and licensed to do business in the State of Florida. 5. At all times material hereto, the Defendant, ROBERTO LI, was a resident of Tampa, Hillsborough County, Florida and is the owner of the Defendant vehicle. 6 All incidents giving rise to the causes of action set forth herein occurred in Punta Gorda, Charlotte County, Florida. GENERAL ALLEGATIONS 7. On November 24, 2015, Defendant, ALEXMAR PIMIENTA GARRIDO, operated a 1999 Volvo truck (Vehicle Identification Number: 4VG7DARJ9XN769587) that was owned by Defendants, JLL LOGISTIC INC and ROBERTO LI, (hereinafter “the Subject Vehicle’). The Subject Vehicle was an instrumentality that is peculiarly dangerous in its operation. 8. At all times material hereto, the Subject Vehicle was being used at the direction of Defendants, JLL LOGISTIC INC and ROBERTO LI, on their behalf. The Subject Vehicle was an instrumentality that is peculiarly dangerous in its operation. 9. On November 24, 2015, Defendant, ALEXMAR PIMIENTA GARRIDO, was operating the Subject Vehicle and was traveling on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County, Florida. 10. On November 24, 2015, Plaintiff, WILLIAM H. SCHMITZ, owned and operated a 2004 Dodge Ram (Vehicle identification Number: 3D7KA28C54G272437) and was also traveling on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County, Florida. 41. At that time and place, Defendant, ALEXMAR PIMIENTA GARRIDO, operated, maintained, and/or used the Subject Vehicle in such a negligent manner as to cause a collision involving the motor vehicle operated by Plaintiff, WILLIAM H. SCHMITZ, resulting in injuries to Plaintiff, WILLIAM H. SCHMITZ and other damages as hereinafter described. COUNT 1: NEGLIGENCE (As to ALEXMAR PIMIENTA GARRIDO) 12. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through eleven (11) as if fully set forth herein. 13. On November 24, 2015, and at all times material hereto, ALEXMAR PIMIENTA GARRIDO was in possession, custody and control of the Subject Vehicle. 14. At all times material hereto, ALEXMAR PIMIENTA GARRIDO owed a duty to exercise reasonable care in the operation, maintenance, and/or use of the Subject Vehicle for the benefit of other individuals on public roadways. 15. On November 24, 2015, ALEXMAR PIMIENTA GARRIDO breached his duty of care to other individuals on the above-described public roadway, and in particular to Plaintiff, WILLIAM H. SCHMITZ, as he was negligent and careless in the operation, maintenance, and/or use of the Subject Vehicle. 16. ALEXMAR PIMIENTA GARRIDO was negligent in his: a. Failure to operate the Subject Vehicle in a safe and reasonable manner; b. Failure to operate the Subject Vehicle in compliance with state and local traffic laws; Failure to keep headlights or other lights on the Subject Vehicle on at night; Failure to keep an adequate and proper lookout for oncoming traffic; Failure to avoid the collision with Plaintiff's vehicle; or f. Other acts of negligence to be determined through discovery. 47. As a direct and proximate result of ALEXMAR PIMIENTA GARRIDO's negligence, Plaintiff, WILLIAM H. SCHMITZ, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, loss of or damage to property, and/or aggravation of a previously existing condition. 18. The losses are permanent and continuing in nature and Plaintiff will suffer such losses in the future. WHEREFORE, Piaintiff, WILLIAM H. SCHMITZ, demands judgment for damages against Defendant, ALEXMAR PIMIENTA GARRIDO, in excess of $15,000, as well as post- judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. COUNT II - NEGLIGENCE (As to JLL LOGISTIC INC) 19. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through eighteen (18) as if fully set forth herein. 20. On November 24, 2015, and at all times material hereto, the Subject Vehicle was being used by ALEXMAR PIMIENTA GARRIDO while in the course and scope of his employment, at the direction of JLL LOGISTIC INC, and on JLL LOGISTIC INC’s behalf. 21. At all times material hereto, JLL LOGISTIC INC owed a duty to exercise reasonable care in the operation and/or use of the subject vehicle for the benefit of other individuals on the public roadways. 22. At all times material hereto, JLL LOGISTIC INC, breached its duty of care to other individuals on the above described public roadways, and in particular to Plaintiff, it was negligent and careless in the operation and/or maintenance and/or use of the Subject Vehicle. 23. JLL LOGISTIC INC was negligent, directly and/or through the conduct of ALEXMAR PIMIENTA GARRIDO. 24. As a direct and proximate result of JLL LOGISTIC INC’s negligence, directly or through the conduct of ALEXMAR PIMIENTA GARRIDO, Plaintiff, WILLIAM H. SCHMITZ, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, loss of or damage to property, and/or aggravation of a previously existing condition. WHEREFORE, Plaintiff, WILLIAM H. SCHMITZ, demands judgment for damages against Defendant, JLL LOGISTIC INC, in excess of $15,000, as well as post-judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. COUNT Il - NEGLIGENCE (As to ROBERTO LI) 25. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through eighteen (18) as if fully set forth herein. 26. At all times material hereto, ROBERTO LI owed a duty to exercise reasonable care in the operation and/or use of the subject vehicle for the benefit of other individuals on the public roadways. 27. At all times material hereto, ROBERTO LI, breached his duty of care to other individuals on the above described public roadways, and in particular to Plaintiff, it was negligent and careless in the operation and/or maintenance and/or use of the Subject Vehicle. 28. ROBERTO LI was negligent, directly and/or through the conduct of ALEXMAR PIMIENTA GARRIDO. 29. As a direct and proximate result of ROBERTO LI’s negligence, directly or through the conduct of ALEXMAR PIMIENTA GARRIDO, Plaintiff, WILLIAM H. SCHMITZ, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, loss of or damage to property, and/or aggravation of a previously existing condition. WHEREFORE, Plaintiff, WILLIAM H. SCHMITZ, demands judgment for damages against Defendant, ROBERTO LI, in excess of $15,000, as well as post-judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. COUNT Ill: CONSORTIUM CLAIM {As to ALEXMAR PIMIENTA GARRIDO) 30. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through eighteen (18) as if fully set forth herein. 31. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H. SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a family relationship. 32. As a direct and proximate result of the above-described incident, Plaintiff, JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following damages: Loss of said spouse’s consortium. Loss of said spouse’s services. The cost and expense of having medical care, attention and treatment for said spouse, the cost of travel necessary to secure said medical case, attention for said spouse and the cost of related medical expense for said spouse. WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against Defendant, ALEXMAR PIMIENTA GARRIDO, to the extent permitted under Florida law, as well as post-judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. COUNT III: CONSORTIUM CLAIM (As to JLL LOGISTIC INC) 33. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through twenty-four (24) as if fully set forth herein. 34. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H. SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a family relationship. 35. As a direct and proximate result of the above-described incident, Plaintiff, JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following damages: a Loss of said spouse's consortium. b Loss of said spouse’s services, C. The cost and expense of having medical care, attention and treatment for said spouse, the cost of travel necessary to secure said medical case, attention for said spouse and the cost of related medical expense for said spouse. WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against Defendant, JLL LOGISTIC INC, to the extent permitted under Florida law, as well as post- judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. COUNT IH: CONSORTIUM CLAIM (As to ROBERTO LI) 36. Plaintiffs reallege the allegations set forth above in paragraphs one (1) through eighteen (18) and paragraphs twenty-five (25) through twenty-nine (29) as if fully set forth herein. 37. Plaintiff, JANICE K. SCHMITZ, was the spouse of the Plaintiff, WILLIAM H. SCHMITZ, and resided with said spouse on November 24, 2015, and they were enjoying a family relationship. 38. As a direct and proximate result of the above-described incident, Plaintiff, JANICE K. SCHMITZ, has in the past and will in the future suffer and incur the following damages: a Loss of said spouse's consortium. Loss of said spouse’s services. The cost and expense of having medical care, attention and treatment for said spouse, the cost of travel necessary to secure said medical case, attention for said spouse and the cost of related medical expense for said spouse. WHEREFORE, Plaintiff, JANICE K. SCHMITZ, demands judgment for damages against Defendant, ROBERTO LI, to the extent permitted under Florida law, as well as post-judgment interest and the costs of bringing this action as allowed by law, and other relief this Honorable Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiffs demand a trial by jury by all issues so triable. Dated: This Wt day of September, 2016 Respectfully submitted, GOLDBERG, RACILA, D'ALESSANDRO & NOONE, LLC Attorneys for Plaintiffs Post Office Box 190 Fort Myers, Florida 33902-0190 (239) 461-5508 (239) 461-3915 (Facsimile) on ESO. Vllocos Michael/M. Noone Florida ar No.: 0105139 Email: MikeNoone oldberg-law.com ervice@goldberg-law.com Elizete D, Velado Florida Bar No.: 0099668 Email: lizeteVelador joldberg-law.com