No Value: LOANDEPOT.COM LLC vs. UNKNOWN HEIRS OF DAVID PETRELLE

On February 13, 2023 a No Value was filed involving a dispute between Loandepot.Com Llc, and Hobbs, Twyla Jeans, Hoyle, Debra Ann, Petrelle, Coral D, Petrelle, Daniel Michael, Petrelle, David Eugene, Sacco, Crystal Marie, United States Of America Secretary Of Veterans, Unknown Heirs Of David Petrelle, Unknown Tenant 1, Unknown Tenant 2, Williams, Taylor, for Homestead Residential Foreclosure 50,001 - 250,000 in the District Court of Charlotte County.

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Filing # 179826453 E-Filed 08/16/2023 04:35:43 PM

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA

CASE NO. 20000066CA

GERARD A. MCHALE, JR., as receiver for
JLL Logistic, Inc.

Plaintiff,

Vv.

KNIGHTBROOK INSURANCE COMPANY,
HENDERSON, FRANKLIN STARNES &
HOLT, P.A. and WILLIAM BOLTREK, III,

Defendants.
/

DEFENDANTS’ HENDERSON, FRANKLIN, STARNES & HOLT, P.A. AND
WILLIAM BOLTREK, IIl’S REQUEST FOR ADMISSIONS FROM GERARD A.
MCHALE, JR, AS RECEIVER FOR JLL LOGISTIC, INC.

Defendants, HENDERSON, FRANKLIN, STARNES & HOLT, P.A. AND WILLIAM

BOLTREK, III, by and through undersigned counsel, and pursuant to Florida Rule of Civil

Procedure 1.370, hereby requests Plaintiff, Gerard A. McHale, as receiver for JLL Logistic, Inc.

admit the following statement of facts, applications of law to said statements of fact, and admit the

genuineness of any documents described in the request and attached to this pleading.

INSTRUCTIONS

If objection is made, the reasons shall be stated. The answer shall specifically deny the

matter or set forth in detail the reasons why you cannot truthfully admit or deny the matter. A

denial shall fairly meet the substance of the requested admission, and when good faith requires

that you qualify an answer or deny only a part of the matter of which an admission is requested,

you shall specify so much of it as is true and qualify or deny the remainder. You may not give lack
of information or knowledge as a reason for failure to admit or deny unless you state that you have

made reasonable inquiry and that the information known or readily obtainable by you is

insufficient to enable that party to admit or deny. If you consider that a matter of which an

admission has been requested presents a genuine issue for trial, then you may not object to the

request on that ground alone; you may only deny the matter or set forth reasons why you cannot

admit or deny it, subject to rule 1.380(c).

REQUE FOR ISSIONS

Exhibit A, is a true and correct copy of the Final Judgment in Case No. 16001754CA filed
in the Circuit Court of the Twentieth Judicial Circuit in and for Charlotte County filed on
January 29, 2018.

On February 28, 2018, the time for an appeal elapsed in Case No. 16001754CA, filed in
the Circuit Court of the Twentieth Judicial Circuit in and for Charlotte County, and
therefore William Boltrek, Esq.’s appearance on behalf of JLL Logistic, Inc. terminated
pursuant to FL ST GEN PRAC AND J ADMIN Rule 2.505(f)(3).

Exhibit B, is a true and correct copy of a motion to appoint Gerard A. McHale receiver for
JILL Logistic, Inc. filed on October 4, 2019, by William Schmitz and Janice Schmitz.

Exhibit C, is a true and correct copy of an amended motion to appoint Gerard A. McHale
receiver for JLL Logistic, Inc. filed on October 10, 2019, by William Schmitz and Janice
Schmitz.

Exhibit D, is a true and correct copy of an October 23, 2019, email from Michelle Keezel
of Goldberg Noone, LLC to the Charlotte County Circuit Civil Court judge with a proposed
order for appointing Gerard A. McHale receiver for JLL Logistic, Inc attached.

Exhibit D was an ex parte communication with the Charlotte County Circuit Civil Court.

Exhibit E, is a true and correct copy of the order appointing Gerard McHale receiver for
JLL Logistic, Inc. entered on October 28, 2019.

No notice of hearing was filed with the clerk or served on JLL Logistic, Inc. for Exhibit B
by William Schmitz and Janice Schmitz.

No notice of hearing was filed with the clerk or served on JLL Logistic, Inc. for Exhibit C
by William Schmitz and Janice Schmitz.
10. No hearing was held on Exhibit B, the motion to appoint Gerard A. McHale receiver for
JILL Logistic, Inc. filed on October 4, 2019, by William Schmitz and Janice Schmitz.

11. No hearing was held on Exhibit C, the amended motion to appoint Gerard A. McHale
receiver for JLL Logistic, Inc. filed on October 10, 2019, by William Schmitz and Janice
Schmitz.

12. Neither Exhibit B nor Exhibit C contain an affidavit.

13. Neither Exhibit B nor Exhibit C are a verified pleading.
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed

electronically and was sent by E-Mail through the Florida Courts’ E-Filing Portal system to counsel

Dale Swope, Angela E. Rodante, and Natalie Shoemaker (AngelaR@swopelaw.com;

eservice@swopelaw.com; team3eservice@swopelaw.com), Swope, Rodante P.A., 1234 East Sth

Ave., Tampa, FL 33605, and John W. Weihmuller and James M. Shaw, Jr.

(jweihmuller@butler.legal; jshaw@butler.legal) Butler, Weihmuller, Katz, Craig LLP, 400 N.

Ashley Drive, Suite 2300, Tampa, Fl 33602, Scot Goldberg and Michelle Keezel

(ScotGoldberg@goldberg-law.com; MichelleKeezel@goldberg-law.com) Goldberg, Noone,

Abraham, LLC., 1533 Hendry Street, Suite 200, Fort Meyers, FL 33901 on this 16th day of August,

2023.

Respectfully submitted,

DEMAHY LABRADOR DRAKE & CABEZA
Attorney for Defendants, Henderson, Franklin, Starnes &
Holt, P.A. And William Boltrek, III.
Douglas Entrance
806 Douglas Road, 12" Floor
Coral Gables, Florida 33134
Tel: (305) 443-4850
Fax: (305) 443-5960

By: s/Brandt Roen
Kenneth R. Drake, Esq.
Florida Bar Number: 375111
E-mail: kendrake@dldlawyers.com
Brandt Roen, Esq.
Florida Bar Number: 1033416
E-mail: broen@dldlawyers.com
EXHIBIT A
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT Z
IN AND FOR CHARLOTTE COUNTY, FLORIDA
So,
CIVIL ACTION a &
FO.S
WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, ADO
is a
OSs,
as Husband and Wife, Oo

Aor
Plaintiffs, 40
Ba
Vv CASE NO.: 16001754CA

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
/

FINAL JUDGMENT.

Pursuant to the Stipulation of the Parties in this action:

IT IS ADJUDGED that Plaintiffs, WILLIAM H. SCHMITZ, whose address is 3451

SE County Rd 760, Arcadia, Florida 34266, and JANICE K. SCHMITZ, whose address

is 3451 SE County Rd 760, Arcadia, Florida 34266, recover from Defendant, JLL

LOGISTICS INC, whose address is 2019 Warrington Way, Tampa, Florida 33619, the

sum of Three Million, Seven Hundred and Fifty Thousand Dollars ($3,750,000.00),

inclusive of taxable costs, with all parties to bear their own attorney's fees. The

judgment shall bear interest at a rate of 4.75% a year, for which let execution issue.

DONE and ORDERED in Chambers, Punta Gorda, Lee County, Florida on this

day of January, 2018.

Circuit Court Judge

cc: William Boltrek, Esquire
Michael M. Noone, Esquire
Deborah msharie
Judicial Assistant
JAN 29 2018
EXHIBIT B
Filing # 96776934 E-Filed 10/04/2019 02:51:13 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,

Vv CASE NO.: 16001754CA

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
|

MOTION TO APPOINT RECEIVER

COMES NOW the Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ,

by and through the undersigned counsel and moves this Court, pursuant to Fla. Stat.

§56.10, to appoint Gerald McHale to serve as Receiver for the defendant and judgment

debtor, JLL LOGISTIC INC., and granting Receiver all the powers and duties identified

within the proposed Order Appointing Receiver attached hereto as Exhibit A, and in

support thereof state as follows:

1 Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, initiated the

instant action on September 26, 2016 for injuries and consortium damages sustained in

a motor vehicle collision. Plaintiff, WILLIAM H. SCHMITZ brought a count for

negligence against Defendant ALEXMAR ’ PIMIENTA GARRIDO; the driver of tractor

trailer involved in the collision with Plaintiffs vehicle. Plaintiff brought a count for direct

or vicarious negligence against ROBERTO LI, the director of JLL LOGISTIC, INC. and a

registered owner of the truck. Plaintiff also brought a count for direct or vicarious
negligence against JLL LOGISTIC, IINC., registered owner of the truck and Mr.

Garrido’s employer. Plaintiff, JANICE K. SCHMITZ, brought claims for loss of

consortium against all three defendants.

2 Plaintiffs resolved their claims against Defendants, ALEXMAR PIMIENTA

GARRIDO and ROBERTO LI and their claims were dismissed with prejudice on May

23, 2017.

3 On January 29, 2018, this Court entered a stipulated Final Judgment in

the amount of $3,750,000.00 against JLL LOGISTIC INC. A copy of the Final Judgment

is attached hereto as Exhibit B.

4 In an effort to execute on the above-described Final Judgment, Plaintiffs

scheduled JLL LOGISTIC INC.’s Director, Mr. Roberto Li, for a deposition in aid of

execution on Friday February 8, 2019. A copy of the amended notice of deposition and

subpoena directed at Roberto Li are attached as a composite Exhibit C.

5. A process server with Accurate Serve of Fort Myers made nine attempts

to serve the subpoena on Roberto Li between December 24, 2018 and February 5,

2019. A copy of the Verified Return of Non-Service is attached as Exhibit D.

6 The deposition in aid of execution was then rescheduled for April 4, 2019.

A copy of the notice and subpoena for the April 4, 2019 deposition are attached as a

composite Exhibit E.

7 A~ process’ server with Accurate’ Serve -of~Fort~ Myers ~made four

unsuccessful attempts to serve the new subpoena on Mr. Li between March 5, 2019

and March 15, 2019. A copy of the Verified Return of Non-service is attached hereto as

Exhibit F.
8 A review of the corporate status of JLL LOGISTIC IINC on the Florida

Department of State, Division of Corporations website (sunbiz.org) shows that JLL

LOGISTIC INC is currently inactive and was administratively dissolved on September

23, 2016. A print-out of the Corporate detail for JLL LOGISTIC INC is attached as

Exhibit G.

9. Plaintiffs and their process server have been unable to locate or

personally serve the director of JLL LOGISTIC INC and JLL LOGISTIC INC appears to

now be a defunct corporation. Because of this, Plaintiffs are unable to obtain

information needed to execute on their final judgment.

10. Under these circumstances, this Court may appoint a receiver for the

corporate judgment debtor in the instant action, JLL LOGISTIC INC. See § 56.10, Fla.

Stat. (2019).
11. Attorney Gerald McHale of McHale, P.A. specializes in receiverships and

partnership and business restructuring, and he is willing and qualified to act as receiver

for JLL LOGISTIC INC.

WHEREFORE, Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ,

move this Court, pursuant to Fla. Stat. § 56.10, to appoint Gerald McHale to serve as

Receiver for Defendant and judgment debtor JLL LOGISTIC INC., and grant him all of

the powers and duties identified within the proposed Order Appointing Receiver

attached hereto-as “Exhibit A” and-for-any other relief this Honorable Court-deems just

proper.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished by U.S. mail upon: JLL LOGISTIC INC. 2019 Warrington Way, Tampa, Florida
33619, and William Boltrek, Ill, Esquire, HENDERSON, FRANKLIN, STARNES & HOLT, P.A.,
Attorneys for Defendants, Post Office Box 280, 1715 Monroe Street, Fort Myers, FL 33902-
0280, at the designated email address(es) of william.boltrek@henlaw.com and
brenda.sitar@henlaw.com, on this 4
A day of October, 2019.

GOLDBERG NOONE, LLC
Attorneys for Plaintiff
1533 Hendry Street, Suite 200
Fort Myers, FL 33902-0190
(239) 461-5508
(239) 461-3915 (Facsimile)

By
ichael, . Noone
Florida Bar No.: 0105139
Email: MikeNoone@goldberg-law.com
Elizete D. Velado
Florida Bar No.: 0099668
Email: lizeteVelado: joldberg-law.com

Email for Service of Court Documents:
service@goldberg-law.com
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,

Vv. CASE NO.: 16001754CA

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
/

ORDER APPOINTING RECEIVER

THIS CAUSE coming on before the Court on Plaintiffs’ Motion to Appoint

Receiver, and the Court having considered the Motion and argument of counsel and

being otherwise duly advised of the premises, it is here ORDERED and AJUDGED as

follows:

1 Gerald McHale is hereby appointed receiver, in accordance with Fla. Stat.

§ 56.10, of all real property, personal property, things in action, goods, chattels and any

other assets (the “Property”) of Defendant JLL LOGISTIC INC., a Florida Corporation.

2 Upon execution of this Order, the Receiver shall have the authority to take

exclusive possession, control and custody of the Property.

3. Defendant JLL LOGISTIC INC’s current and former officers, directors,

members, employees, agents and representatives (“Representatives”) are ordered to

immediately deliver to Receiver all of the Property and to fully cooperate with the

Receiver, including but not limited to providing the Receiver with all reasonably

requested documents, books, records, bank accounts, trust accounts, deposit accounts,
PLAINTIFF’S
EXHIBIT

-—
savings accounts, inventories, supplies, invoices, leases, deeds and any other

document and tangible thing owned by Defendant JLL LOGISTIC INC.

4 Any failure by Defendant JLL LOGISTIC INC. or its Representatives to

cooperate with the Receiver as provided herein shall render Defendant JLL LOGISTIC

INC. or its Representatives in contempt of this Order and subject to sanctions. The

Receiver may request supplemental authority from this Court upon proper motion.

5. The Receiver is hereby authorized to hire, employ, retain and terminate

professionals which the Receiver deems necessary to assist in the discharge of his

duties. The Receiver is further authorized to retain legal counsel to represent him and

assist him with the performance of his duties as set forth herein.

6 The Receiver shall be paid an hourly rate for the time he devotes to his

duties pursuant to this Order

7 The Receiver may execute and deliver in his own name as Receiver,

documents necessary and appropriate to consummate transactions, enter into contracts

and pay lawful debts of the Defendant JLL LOGISTIC INC.

8 The Receiver may prosecute all lawsuits as may be reasonably necessary

in the Receiver's judgment.

9 The Receiver shall hold and retain all money that may come into the

Receiver's possession by virtue of his appointment until further order of this Court.

10: Subject tothe: provisions~of-this Order; the Receiver~shall remain: in

exclusive control of the Property until further order of this Court.

11. Without limiting any other rights or immunities the Receiver may have at

law or in equity, the Receiver shall have no liability for acts or omissions made by or on
behalf of the Receiver, in his capacity as Receiver of the Property, so long as such acts

or omissions are made in good faith, without gross negligence and in a manner that the

Receiver reasonably believes is in the best interest of the Property.

12. This Court shall retain jurisdiction of all matters concerning the Receiver

and the relationship.

DONE AND ORDERED this day of , 2019.

LISA S. PORTER
Circuit Court Judge

Copies furnished to:
Michael M. Noone, Esq.
William Boltrek, Esq.
JLL LOGISTIC INC
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.
/

FINAL JUDGMENT

Pursuant to the Stipulation of the Parties in this actlon:

IT S ADJUDGED that Plaintiffs, WILLIAM H. SCHMITZ, whose address is 3454

SE County Rd 760, Arcadia, Florida 34266, and JANICE K, SCHMITZ, whose address

is 3451 SE County Rd 760, Arcadia, Florida 34266, recover from Defendant, JLL

LOGISTICS INC, whose address is 2019 Warrington Way, Tampa, Florida 33619, the

sum of Three Million, Seven Hundred and Fifty Thousand Dollars ($3,760,000.00),

inclusive of taxable costs, with all parties to bear their own attorney's fees. The

Judgment shall bear interest at a rate of 4.75% a year, for which let execution issue.

DONE and ORDERED In Chambers, Punta Gorda, Lee County, Florida on this
Original of this
day of January, 2018. document was signe!
JAN 29 2018
LISA S. PORTER sles &. Porlar
Circuit Court Judge
Clreutt Court Judge
ce: William Boltrek, Esquire
Michael M. Noone, Esquire

PLAINTIFF'S
EXHIBIT
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.: 16-CA-001754

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
/

AMENDED NOTICE OF TAKING DEPOSITION IN AID OF EXECUTION
{As to location only)

PLEASE TAKE NOTICE that the undersigned will take the deposition in aid of execution:

NAME: Roberto Li, as Last Director of JLL Logistic Inc.

DATE: Friday, February 8, 2019

TIME: 11:00 a.m.

PLACE: Johnson & Associates Court Reporters, Inc.
Regus Office Suites
7320 East Fletcher Avenue
Tampa, FL 33637
(813) 223-4960
At the above tine and place the Plaintiff will take the deposition by oral examination for

purposes of discovery, for use at trial, and for use as evidence in said cause or both.

Said deposition will be taken before Johnson & Associates Court Reporters, Inc., a Notary

Public or any officer authorized fo administer oaths by the laws of the State of Florida and a person

who is neither a relative nor employee nor attorney nor counsel of any of the parties nor of such

attorney or counsel and who is not financially interested In the action.

Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases

as provided. The said oral examination will continue from hour to hour and from day to day until

PLAINTIFF'S
EXHIBIT
completed. Deponent shail bring the following with him at said time and place:

4 Fact Information Sheet completed in accordance with the Florida Rules of Civil Procedure

1.560.

Any and all financial statements prepared by or JLL Logistic Inc hereinafter referred to as

“JLL” for the purpose of attempting to obtain loans from any person or institution for the

past five (8) years Including this year.

Bank statements and bank books for any and all bank accounts (checking and savings)

in which JLL had an interest for the past five (5) years which have been closed.

Titles to any and all automobiles, trucks, boats, airplanes, and other vehicles owned by

JLL and documents reflecting encumbrances upon any of the sald vehicles,

Any and all deeds, leases or other documents reflecting interests in real property held by

JLL in the past 10 years and documents reflecting encumbrances upon any of the said

vehicles.

Any and all Federal income tax returns filed by JLL in the past five (6) years, including all

schedules and worksheets filed herewith.

Any and all promissory notes or other negotiable instruments reflecting amounts payable

by or to JILL. at the present time.

Any and all judgments reflecting amounts payable to JLL at the present time.

Any and all other documents reflecting obligations owed by or to JLL as of the present

date.

10. All stock certificates, bonds or other securities In the name of JLL as issued by any

governmental body, for the past five (5) years,

14 All books, records, monthly statements, statement of transactions and all other papers
and memoranda of stock brokerage accounts in the name of JLL in the past five (5) years.

CERTIFICATE OF SERVICE

| HEREBY CERTIFY that a true and correct copy of the above and foregoing has been

furnished by electronic mail upon Michael M. Noone, Esquire and Elizete D. Velado, Esquire,

Counsel for Plaintiffs, GOLDBERG NOONE, LLC, 1533 Hendry Street, Sulte 200, Fort Myers, FL

33901 at the designated email address of service@goldberg-law.com on this 14 day of

December, 2018.

STEVEN A. RAMUNNI, P.A
Co-CGounsel for Plaintit
P.O, Box 11
LaBelle,
(863) 2b:+2268
By
Steven A, mM!
Florid: ar No. esr02
Email: steve@sramunnipa.com
THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
GIVIL ACTION

WILLIAM H. SCHMITZ and JANICE K. SCHMITZ
As Husband and Wife,

Plaintiffs,

v, CASE NO.: 16-CA-001764

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO Li,

Defendants.
/

SUBPOENA FOR DEPOSITION IN AID OF EXECUTION

THE STATE OF FLORIDA,

TO: ROBERTO Ll, as Last Director of JLL LOGISTIC INC,
a Florida dissoived corporation
2019 WARRINGTON WAY
TAMPA, FL 33619
YOU ARE COMMANDED to appear before an associate and/or a person authorized by
law to take depositions: To-wit:

at: Johnson & Associates Court Reporters, Inc., 10150 Highland Manor Drive,
Tampa, FL 33610 (800) 239-4960 on Friday, February 8, 2019 at 11:00 a.m. for the taking of
your deposition in this action. Deponent is requested to have with him at that time and place the
following:

4 Fact Information Sheet completed in accordance with the Florida Rules of Civil
Procedure 1.560,

Any and all financial statements prepared by or JLL Logistic Inc hereinafter referred to
as “JLL” for the purpose of attempting to obtain loans from any person or institution for
the past five (5) years including this year.

Bank-statements-and-bank-books-for-any and-all-bank-accounts (checking-and-savings)
in which JLL had an Interest for the past five (5) years which have been closed.

Titles ta any and all automobiles, trucks, boats, airplanes, and other vehicles owned by
JLL and documents reflecting encumbrances upon any of the said vehicles.

Any and all deeds, leases or other documenis reflecting interests in real property held
by JLL in the past 10 years and documents reflecting encumbrances upon any of the
said vehicles.
Any and all Federal income tax returns filed by JLL in the past five (5) years, including
all schedules and worksheets filed herewith.

7, Any and all promissory notes or other negotlable instruments reflecting amounts
payable by or to JLL at the present time.

Any and ail judgments reflecting amounts payable fo JLL at the present time.

Any and all other documents reflecting obligations owed by or to JLL as of the present
date.

10. All stock certificates, bonds or other securitles In the name of JLL as Issued by any
governmental body, for the past five (5) years,

11 All books, records, monthly statements, statement of transactions and all other papers
and memoranda of stock brokerage accounts in the name of JLL in the past five (6)
years.

If you fail to appear, you may be In contempt of court.

You are subpoenaed to appear by the following attorneys and unless excused from this

subpoena by these attorneys or the Court, you shall respond to this

Dated this | a re day of December, 2018.

FOR THE COURT:

Michael M. Noone, Esquire L ~~
Counsel for Plaintiffs: Steven A. Ri junni
Goldberg Noone, LLC Co-Counsel for Plaintlffs
1533 Hendry Street, Suite 200 P.O. Box 1118
Fort Myers, FL 33901 LaBelle, FL 33975
(239) 461-5508 (863) 230-2268
(239) 461-3915 (Facsimile) Email: steve@sramunnipa.com
Email: service@goldberg-law.com
VERIFIED RETURN OF NON-SERVICE Job # 19442

Client Info:
Goldberg Noone, LLC.
1533 Hendry Street, Svite 200
Fort Myers, Fl, 33901.

Case Info:
PLAINTIFF: CIRCUIT COURT
WILLIAM H, SCHMITZ AND JANICE K, SCHMITZ AS HUSBAND AND Court Division: CIVIL ACTION
WIFE
sversus- County of Charlotte, Florida
DEFENDANT: rt Case # 16-CA-001754
ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC AND ROBERTO LI
Service Info:
Date Recelved by Accurate Serve: 12/20/2018 at 10:31 PM
Service: 1 Non-Served ROBERTO LI, as Last Director of JLL Loglstic Inc, a Florida Dissolved Corporation
SUBPOENA FOR DEPOSITION IN AID OF EXECUTION, AMENDED NOTICE OF TAKING DEPOSITION IN AID OF
EXECUTION
At Residence 2019 WARRINGTON WAY TAMPA, FL 33619
On 2/5/2019 at 07:36 PM
Manner of Service:
£X] Non-service: After due search, careful inquiry and diligent attempts at the address(es) listed below, I have been unable to effect
‘the process upon the person/entity being served because of the following reason(s):
[X] Other: See attempts for details of non serve

Service was Attempted on:
(1) 12/24/2018 at 09:01 AM, by Selma Adams Loc: 2019 Warrington Way, Tampa, FL 33619 _Latitude:27,927890
Longitude:-82,365321
Notes: no answer, no lights on, no nolse Inside, no movement Inside, dogs barking inside, GMC Yukon Florida Ilcense plate BRNC86
also. Dodge Ram truck Florida Ilcense plate BADC66 parked In the driveway along with a Toyota, Mercedes, and Honda, no plates on
those three vehldes

(2), 12/28/2018 at 12:05 PM, by Selma Adams Loc: 2019 Warrington Way, Tampa, FL. 33619. Latitude:27,927968
Longltude:-82,365457
Notes: no answer, no lights on, no nolse Inside, no movement Inside GMC Yukon FL. license plate BRNC86 and Dodge Ram FL license
plates BADC66

(3) 12/29/2018 at 08:50 AM, by Selma Adams Loc: 2019 Warririgton Way, Tampa, FL. 33619__Latitude:27.927894
Longitude:-82,365364
Notes: unable to gain access, gate closed and locked, honked the horn, left card with note to call

(4) 1/2/2019 at 07:28 PM, by Selma Adams Loc: 2019 Warrington Way, Tampa, FL33619 —_Latitude:27.927995
Longitude:-82.365340
Notes: spoke with Giselle Hispanic female, approximately 18 years old, with brown hair, weighing approximately 120 lb,
approximately 5'7 a co-resident of the residence not a current or former employee of jll Logistics Inc, left my card for the subject to
call me

(5) 1/5/2019 at 09:39 AM, by Selma Adams Loc: 2019 Warrington Way, Tampa, FL33619 _Latitude:27.927906
Longitude:-82,365280
Notes: no answer, no lights on Inside, no noise inside, no Movement Inside, GMC" Yukon Florida license plate BRNC86 and Dodge
‘Rant license plate BADC66 parked in the driveway ~ - —

(6) 1/31/2019 at 10:51 AM, by Selma Adams Loc: 4629 Driesler Circle, Tampa, FL 33634 Latitude:27.986575
Longitude: -82,554432
Notes: no answer, no lights on side, no moving Inside, no noise Inside, no cars parked in the driveway

(7) 2/2/2019 at 11:06 AM, by Selma Adams Loc: 4629 Driesler Circle, Tampa, FL 33634 Latitude:27,986580
Longitude: -82.55421
Notes: no answer, no lights on inside, no nolse Inside, No moving Inside, dogs barking Inside, no cars parked in the driveway

(8) 2/4/2019 at 12:22 PM, by Selma Adams Loc: 4629 Driester Circle, Tampa, FL33634 _Latitude:27.986391

ae RIES ADA
Lof2

PLAINTIFF’S
EXHIBIT

pb
Job # 19442

Longitude;-82.554321
Notes: no answer, no lights on inside, no nolse inside, no movement Inside, server left note with call back number
for subject
(9) 2/5/2019 at 07:36 PM, by Selma Adams Loc; 4629 Drlesler Circle, Tampa, FL 33634 Latitude:27.986507
Longitude: -82.55435:
Notes: spoke with Katya Sanchez, the tenant of the home she stated that she rents the home from the subject,
she also stated that
the subject does not come around, that he sends his daughter to pick up the rent,

1 Selma Adams acknowledge that I am authorized to serve process, In good standing in the jurisdiction wherein the process was
served and 1 have no interest in the above
that the facts stated In It are true,
Signature of Server:
Selma Adams
APS 15488
fe
Accurate Serve of Fort Myers
4600 Summerlin Road, Suite C-2-411
Fort Myers, FL 33919

Client # 9482
Job # 19442

a —

a Bt eA
2o0f2
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,
Vv CASE NO.: 16-GA-001754

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
/

2 AMENDED NOTICE OF TAKING DEPOSITION IN AID OF EXECUTION

PLEASE TAKE NOTICE that the undersigned will take the deposition in aid of execution:

NAME: Roberto Li, as Last Director of JLL Logistic Inc,

DATE: Thursday, April 4, 2019

TIME: 11:00 a.m.

PLACE: Bailey & Associates Reporting
1021 Ives Dairy Road, Suite 115
North Miami, FL 33179
(954) 358-9090

At the above time and place the Plaintiff will take the deposition by oral examination for

purposes of discovery, for use at trial, and for use as evidence in said cause or both.

Said deposition will be taken before Bailey & Associates Reporting, a Notary Public or any

officer authorized to administer oaths by the laws of the State of Florida and a person who is neither

atelative nor employee nor attorney nor counsel of any of the parties nor of such attorney or counsel

and who is not financially interested in the action.

Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases

as provided. The said oral examination will continue from hour to hour and from day to day until

PLAINTIFF'S
completed. Deponent shall bring the following with him at said time and place:

1 Fact Information Sheet completed In accordance with the Florida Rules of Civil Procedure

1.560,

Any and all financial statements prepared by or JLL Logistic Inc hereinafter referred to as

"JLL’ for the purpose of aitempting to obtain loans from any person or institution for the

past five (6) years Including this year.

Bank statements and bank books for any and all bank accounts (checking and savings)

In which JLL had an interest for the past five (5) years which have been closed.

Titles to any and all automobiles, trucks, boats, airplanes, and other vehicles owned by

JLL and documents reflecting encumbrances upon any of the said vehicles.

Any and all deeds, leases or other documents reflecting interests in real property held by

JLL in the past 10 years and documents reflecting encumbrances upon any of the said

vehicles,
Any and all Federal income tax returns filed by JL. in the past five (5) years, Including all

schedules and worksheets filed herewith.

Any and all promissory notes or other negotiable instruments reflecting amounts payable

by or to JLL at the present time.

Any and all judgments reflecting amounts payable to JLL at the present time,

Any and all other documents reflecting obligations owed by or to JLL as of the present

date,

10 All stock certificates, bonds or other securities in the name of JLL as issued by any

governmental body, for the past five (6) years,

14 All books, records, monthly statements, statement of transactions and all other papers
and memoranda of stock brokerage accounts in the name of JLL in the past five (5) years.

CERTIFICATE OF SERVIC.

| HEREBY CERTIFY that a true and correct copy of the above and foregoing has been

furnished by electronic mail upon Michael M. Noone, Esquire and Elizete D. Velado, Esquire,

Counsel for Plaintiffs, GOLDBERG NOONE, LLC, 1533 Hendry Street, Suite 200, ” Myers, FL

33901 at the designated email address of service@goldberg-law.com on this AY day of

February, 2049.

STEVEN A, RAMUNNI, P.A.

oo
Co-Counseltfor Plaintiffs
P.O.By 414
Lal le, FL 333975
(863) 230,2268

By:
Steve A munni
Florida Bar lo.: 386702
Email: steve@sramunnipa.com

ce: shari@baileyassociatesreporting.com
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,

Vv. CASE NO.: 16-CA-001754

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,

Defendants.
/

su! ENA FOR DEPOSITION IN AID OF EXECUTION

THE STATE OF FLORIDA,

TO: ROBERTO Li, as Last Director of JEL LOGISTIC INC,
a Florida dissolved corporation
195 NW 50" AVENUE
MIAMI, FL 33426

YOU ARE COMMANDED to appear before an associate and/or a person authorized by
law to take depositions: To-wit:

at: Bailey & Associates Reporting, 1021 tves Dairy Road, Suite 115, North Miami, FL
33179 (954) 358-9090 on Thursday, April 4, 2019 at 11:00 a.m. for the taking of your deposition
in this action. Deponent is requested to have with him at that time and place the following:
4
Fact Information Sheet completed in accordance with the Florida Rules of Civil
Procedure 1.560.

Any and all financial statements prepared by or JLL Logistic Inc hereinafter referred to
as “JLL" for the purpose of attempting to obtain loans from any person or institution for
the past five (5) years including this year.

Bank statements and bank books for any and all bank accounts (checking and savings)
in-which JLI. had-an-interest-for-the-past five-(5)-years which-have-been-closed-

Titles to any and all automobiles, trucks, boats, airplanes, and other vehicles owned by
JLL and documents reflecting encumbrances upon any of the said vehicles.

Any and all deeds, leases or other documents reflecting interests in real property held
by-JLL in the past 10 years and documents reflecting encumbrances upon any of the
said vehicles.
Any and all Federal income tax returns filed by JLL in the past five (5) years, including
all schedules and worksheets filed herewith.

Any and all promissory notes or other negotiable instruments reflecting amounts
payable by or to JLL at the present time.

Any and all judgments reflecting amounts payable to JLL at the present time,

Any and all other documents reflecting obligations owed by or to JLL as of the present
date.

10. All stock certificates, bonds or other securities in the name of JLL as issued by any
governmental body, for the past five (5) years.

11 All books, records, monthly statements, statement of transactions and all other papers
and memoranda of stock brokerage accounts in the name of JLL in the past five (5)
years,
If you fail to appear, you may be in contempt of court.

You are subpoenaed to appear by the following attorneys and unless excused from this

subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.

Dated this ee AV day of February, 2019.

FOR THE COURT:

Michael M. Noone, Esquire
Counsel for Plaintiffs: Stéven A. Ramunni
Goldberg Noone, LLC Co-Counsel for Plaintiffs
1533 Hendry Street, Suite 200 P.O. Box 1118
Fort Myers, FL 33901 LaBelle, FL 33975
(239) 461-5508 (863) 230-2268
{239) 461-3915 (Facsimile) Email: steve@sramunnipa.com
Email: service@goldberg-law.com
VERIFIED RETURN OF NON-SERVICE dob # 2019001343

Client Info:
Goldberg Noone, LLC
Michael Noone
PO Box 190
Fort Myers, FL 33902

Casa Infor
PLAINTIFF: CIRCUIT COURT
WILLIAM H. SCHMITZ AND JANICE K. SCHMITZ AS HUSBAND AND Court Division: CIVIL ACTION
WIFE Court Date: 4/4/2019 Time: 11:00 AM
versus County of Chartotte, Florida
DEFENDANT: Court Case # 16-CA-001754
EXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC., AND ROBERTO.

Service Info:
Date Received by Accurate Serve of Fort Myers: 3/4/2019 at 10:03 AM
Service: I Non-Served ROBERTO LI, as Last Director of JLL Logistic Inc,, a Florida Dissolved Corporation
SUBPOENA FOR DEPOSITION IN AID OF EXECUTION, 2ND AMENDED NOTICE OF TAKING DEPOSITION IN AID OF
EXECUTION
At Residence 195 NW 50TH AVE. MIAMI, FL 33126
On 3/15/2019 at 09:25 PM
Manner of Service:
[X} Non-service: After due search, careful in

Case Info

Judge

GENTILE, GEOFFREY H Track Judge’s New Case

Case No.

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Document Filed Date

November 15, 2064

Case Filing Date

February 13, 2023

County

Parties

GENTILE, GEOFFREY H Judge
HOBBS, TWYLA JEANS Defendant
HOYLE, DEBRA ANN Defendant
LANNING, PETER E Attorney
LOANDEPOT.COM LLC Plaintiff
LOPEZ-RIVERA, ISABEL Attorney
PASSER, JAY Attorney
PETRELLE, CORAL D Defendant
PETRELLE, DANIEL MICHAEL Defendant
PETRELLE, DAVID EUGENE Defendant
ROSENBERG, ANNA J. Attorney
RUDY III, JOHN F Attorney
SACCO, CRYSTAL MARIE Defendant
UNITED STATES OF AMERICA SECRETARY OF VETERANS Defendant
UNKNOWN HEIRS OF DAVID PETRELLE Defendant
UNKNOWN TENANT 1 Defendant
UNKNOWN TENANT 2 Defendant
WILLIAMS, TAYLOR Defendant
Shawn Yesner Attorney
John Brock Attorney
Anna Jiménez Attorney
Sears Steele Attorney
William Boltrek Attorney
Kenneth Drake Attorneys for Defendants
Michael Noone Attorneys for Defendants
Lisa Porter Attorney

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No Value: LOANDEPOT.COM LLC vs. UNKNOWN HEIRS OF DAVID PETRELLE

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