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Filing# 151222289 E-Filed 06/09/2022 07:39:12 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO: CACE-21-009694(1)
SOUTH FLAGLER CONDOMINIUM
ASSOCIATION, INC., a Florida not-for-
profitcorporation,
Plaintiff,
VS.
BENJAMIN VASQUEZ GODEN, MARIA
DEL CARMEN RUIZ, et. al.
Defendants.
DEFENDANTS' RESPONSE TO SUMMARY JUDGMENT AND DECLARATION
PURSUANT TO FL. STATUTE § 92.525(2)AND/OR RESPONSE IN OPPOSITION
TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
Defendants, BENJAMIN VASQUEZ GODEN and MARIA DEL CARMEN
RAMIREZ ("DEFENDANTS"), by and through undersigned counsel, file this Declaration
and/or Response in Opposition to Plaintiff's Undisputed Facts Motion for Summary.
INTRODUCTION
Plaintiff's motion for summary judgment is due to be denied for technical,factual and
legalgrounds.As a threshold matter, Plaintiff' s motion for summary judgment does not comport
with the new summaryjudgment rules adopted by the Florida Supreme Court last year. The motion
does not contain a Statement of Material Fact in compliance with the new rule as the motion for
parts of materials
summary judgment does not cite to particular in the records to support the facts
that cannot be genuinely disputed.On this basis alone, the motion is due to be denied.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/09/2022 07:39:12 PM.****
even the Plaintiff fails to refute the legallyvalid affirmative defenses in this
Additionally,
case. and
Specifically, as will be further addressed below, the Plaintiffs own actions in its failure
to pay its statutory requiredobligationsto maintain insurance led to the Defendants' mortgage
company placing a forced placed insurance which resulted in higher mortgage
significantly
in the pending foreclosure of the mortgage. Moreover, the
payments resulting Plaintiff's affidavit
in support of summary judgment is wholly insufficient as a matter of law and it fails to include the
Exhibit "A" referred to in the affidavit.
'.r
;The court shall grant summary judgment if the movant shows that there is no genuine
disputeas to any material fact and the movant is entitled to judgment as a matter of law." Fed. R.
Civ. P. 56(a);Celotex Corp. v. Catrett,477 U.S. 317,322, 106 S. Ct. 2548,2552,91 L. Ed. 2d 265
(1986).The movant "always bears the initial of informing the
responsibility district court of the
basis for its motion, and those portionsof
identifying 'the pleadings,depositions,answers to
and admissions on file,togetherwith the affidavits,if any,' which
interrogatories, it believes
demonstrate the absence of a genuine issue of material fact." Id at 323 (quotingFed. R. Civ. P.
56(c)(1)(A).Florida Rule of Civil Procedure 1.510(c)providesin part that summary judgment
shall be granted if:
..
[Tlhe pleadings,depositions, answers to interrogatories, admissions, affidavits,
and other materials as would be admissible in evidence on file show that there
is no genuine issue as to any material fact and that the moving party is entitled
to judgment as a matter of law.
Plaintiff failed to comply with the Motion for Summary Judgment standard, failed to
address the affirmative defenses, failed to provide ANY admissible evidence in support of its
motion, and therefore,summary judgment must be denied.
2
PROCEDURAL HISTORY
1. Undisputed.
2. Undisputed.
3. Disputed.The Defendants filed an Answer and Affirmative Defenses in this action.
The demonstrate that it was the Plaintiffthat failed to perform
affirmative defenses clearly
their duties. The Plaintiff failed to maintain adequate insurance as requiredby Florida
Statute 718.111 (11). This failure of duty led to the Defendants' first mortgage adding
force-placedinsurance to the mortgage payments of the Defendants increasingthe
mortgage payments by a largeamount. Furthermore, the Plaintiff has acted with bad faith
failing to provide statements, accountings, or very limited correspondence with
Defendants. (See Defendants' Affirmative Defenses.)
4. Disputed.The Defendants filed an Answer and Affirmative Defenses in this action.
According to the Defendants' Affirmative Defenses, the Plaintiff is the one who failed to
perform their duties such as the maintenance of adequateinsurance, the maintenance ofthe
common areas; and the maintenance of adequateand correct accountingand records. (See
Answer and Affirmative Defenses.)
5. Undisputed.
6. Undisputed.
B. CLAIMS AND DEFENSES
7. Undisputed that the Plaintiff seeks Summary Judgment, but disputedas to whether
Plaintiff is entitled to Summary Judgment.
8. Disputed to that the affidavits submitted by Plaintiff are sufficient for an entry of
Summary Judgment. The affidavit for indebtedness is not signed by employee or board
3
officer of the Plaintiff nor based on personal knowledge. The Affidavit of Indebtedness is
signedby Plaintiff' s counsel as generalcounsel for the association. The affiant states that
he has reviewed the ledger,the records of the Association. However, the Affiant does not
state that he knows how these ledgeror records are maintained. He does not state that the
records were made at time of the business transaction;
and does not include any records to
the affidavit. The affidavit is therefore insufficient.
9. Disputed. The Plaintiff failed to perform its duties. The Defendants continued to
pay after the Plaintiff failed to maintained insurance on the property and failed to maintain
the common grounds.
10. Undisputed that the Lien runs with the land and that Defendants must comply with
all rules However, the Plaintiff also owes duties to the Defendants, and
and regulations. all
other property owners. The Plaintiff failed to perform the duties including failure to
maintain insurance,failure to maintain the common grounds,and failure to maintain proper
records and accounting.See Florida Statute 718.111(11).
11. Undisputed as to the renderingofthe statute.
12. Disputed. The Plaintiff has not stricken the Defendants' affirmative defenses
includingthe Fifth Affirmative Defense which states that the claim of lien does not comply
with the statute.
13. Disputed. The Plaintiff has not stricken the Defendants' affirmative defenses
includingthe Fifth Affirmative Defense which states that the claim of lien does not comply
with the statute.
14. Disputed. The Defendants asserted several affirmative defenses, and none of the
affirmative defenses have been stricken and none were addressed in the Motion for
4
and
Summary Judgment. The Plaintiff failed to perform the duties that they are to required,
theybreached their commitment to the Defendants and other property owners. The Plaintiff
failed to maintain insurance, failed to maintain the common areas, and failed to maintain
adequaterecords and accountings.
15. Disputed.The lien is not valid for failure to comply with the
strictly Statute.
16. Disputed.The Defendants did respond. Answer and Affirmative Defenses were
filed,and none of the affirmative defenses have been stricken.
C. NEW SUMMARY JUDGMENT STANDARD
The Defendants do not disputethe Standard for Summary Judgment. However, the
Defendants assert that the Answer and Affirmative Defenses of the filed by the Defendants
have not been refuted,that the Plaintiff failed to comply with Rule 1.510 and failed to
include any admissible business records for the Court's consideration.
D. MOVING PARTIES CERTIFICATION
The Defendants has no statement on the moving partiescertification.
DEFENDANTS' STATEMENT OF FACTS AND ARGUMENTS
17. On August 27,2021, an Answer and Affirmative Defenses were filed by the
Defendants.
18. The Plaintiff filed a Motion for Summary Judgment on November 23,2021,
which has been scheduled for hearing on June 29,2022.
19. The Affidavit of Indebtedness was filed on November 29,2021.
20. None of the Affirmative Defenses have been stricken.
21. None of the Affirmative Defenses have been addressed in the Plaintiff's Motion
for Summary Judgment.
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22. The Affirmative Defenses show that the Plaintiff has breached its duty to the
Defendants to maintain property insurance,to maintain the common grounds,to maintain
proper accountingand records.
23. The Affidavit of Indebtedness is insufficient under the business records exception.
24. Therefore,the Plaintiff has failed to demonstrate that it has complied with the new
standard for Motion for Summary Judgment.
PLAINTIFF CANNOT PREVAIL ON SUMMARY JUDGMENT
A. Affirmative Defenses Still Exist
"-
First "when a party raises affirmative defenses, a summary judgment should not be granted
where there are issues of fact raised by the affirmative defenses which have not been effectively
challengedand refuted." Alejandre
factually v. Deutsche Bank Trust Company, 44 So. 3d 1288
(Fla.4th DCA 2010). Woodrum v. Wells Fargo Mortg. Bank, N.A.,73 So.3d 873 (Fla.4th DCA
2011) (findingthat it is error to enter summary judgment where the bank fails to refute affirmative
defenses raised in opposing affidavit or show that Under Florida
they are legallyinsufficient).
law, it remains Plaintiffs burden to show that any defenses offered by Defendant are legally
insufficient. See Corya v. Sanders, 76 So.3d 31 (Fla.4th DCA 2011); see also Bryson v. Branch
Banking and Trust Co., 75 So.3d 783 (Fla.2d DCA 2011). Thus, in order for Plaintiff to obtain a
summary judgment when affirmative defenses are asserted,the burden is on the Plaintiff,as the
moving party, to either disprove those defenses by evidence or by establishingthe legal
of those defenses. The Defendant has
insufficiency filed an Answer and Affirmative Defenses to
the Complaint. The Plaintiff fails to even discuss, much less refute them in the Motion for
Summary Judgment, but none of the Affirmative Defenses have been stricken.
6
B. Plaintiff has failed to provide any admissible evidence or business records in order
to obtain Summary Judgment
There is no evidence from anyone with personalknowledge regardingany allegation
in the
Complaint or the Motion for Summary Judgment. Therefore, while the Plaintiff makes
same
conclusionaryallegations, is not supportedby documentation and is non-admissible hearsay.
See Fla. R. Civ. P. 1.510(e)(2020); §§ 90.801, 90.802, 90.803,90.901, Fla. Stat. (2018);Sas v.
Fannie Mae, 112 So. 3d 778 (Fla.
2d DCA 2013) (holding
that the trialcourt abused itsdiscretion
by allowingthe witness to about the contents of business records to prove the amount of a
testify
debt without having first admitted the business records);Thompson v. State,705 So. 2d 1046, 1048
(Fla.4th DCA 1998) (holdingthat business record exception to hearsay did not authorize hearsay
the value of merchandise stolen when
testimony about the contents of business record reflecting
the business record was not admitted into evidence); Cullimore v. Barnett Bank qfJacksonville,
386 So. 2d 894, 895 (Fla. 1 st DCA 1980) (holding that the business records exception is
inapplicablebecause there were no records or reports offered into evidence); Coleman v.
Grandma's Place, Inc.,63 So. 3d 929 (Fla.4th DCA 2011) (holdingthat documents upon which
See also Heller
the affiant relied should be sworn and attached to the affidavit); v. Bank ofAm.,
NA., 209 So. 3d 641,645 (Fla.2d DCA 2016); Miller v. Bank ofAm., N.A., 101 So. 3d 1286, 1288
(Fla.2d DCA 2016); Helton v. Bank of Am., N.A., 187 So. 3d 245, 247 (Fla.5th DCA 2016);
Kenney v. HSBCBank USA, N.A.,175 So. 3d 377,378-9 (Fla.4th DCA 2015. As an affidavit for
summary judgment purposes is taking the place of trial evidence, this predicatemust be set forth
priorto acceptingthe testimony as true.
Here, there is no affidavit which is based on personal knowledge and there are no records
attached to the affidavit. Therefore, summary judgment must be denied.
7
WHEREFORE, Defendants pray that this Honorable Court deny the Motion for
Summary Judgment, award attorneys fees and award Defendants such other relief as this Court
deems justand proper.
DECLARATION PURSUANT TO FL. STATUTE § 92.525(2)
Under penalties of perjury,I declare that I have read the foregoing declaration and that the facts stated
in it are true.
-/s./Beniamin Vasquez Goden
Benjamin Vasquez Goden
Date 06/09/2022
/s/ Maria Del Carmen Ramirez-
Maria Del Carmen Ramirez
Date 06/09/2022
8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the foregoingwas sent on June 9,
2022, to all via the ePortal and
parties to JOHN PAUL ARCIA, P.A. at service@arcialaw.com.
CORONA LAW FIRM, P.A.
6700 SW 38 Street
Miami, Florida 33155
Telephone: (305) 547-1234
Facsimile: (305) 266-1151
Primary Email: foreclosure@coronapa.com
Secondary Email: ricky@coronapa.com
By: /s/ America Alvarez
RICARDO R. CORONA
Attorney for Defendants
Florida Bar No: 111333
Ricardo Corona
Florida Bar No: 107684
America Alvarez
Florida Bar No: 0716080
9
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Filing# 151222289 E-Filed 06/09/2022 07:39:12 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-009694(1) SOUTH FLAGLER CONDOMINIUM ASSOCIATION, INC., a Florida not-for- profitcorporation, Plaintiff, VS. BENJAMIN VASQUEZ GODEN, MARIA DEL CARMEN RUIZ, et. al. Defendants. DEFENDANTS' RESPONSE TO SUMMARY JUDGMENT AND DECLARATION PURSUANT TO FL. STATUTE § 92.525(2)AND/OR RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Defendants, BENJAMIN VASQUEZ GODEN and MARIA DEL CARMEN RAMIREZ ("DEFENDANTS"), by and through undersigned counsel, file this Declaration and/or Response in Opposition to Plaintiff's Undisputed Facts Motion for Summary. INTRODUCTION Plaintiff's motion for summary judgment is due to be denied for technical,factual and legalgrounds.As a threshold matter, Plaintiff' s motion for summary judgment does not comport with the new summaryjudgment rules adopted by the Florida Supreme Court last year. The motion does not contain a Statement of Material Fact in compliance with the new rule as the motion for parts of materials summary judgment does not cite to particular in the records to support the facts that cannot be genuinely disputed.On this basis alone, the motion is due to be denied. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/09/2022 07:39:12 PM.**** even the Plaintiff fails to refute the legallyvalid affirmative defenses in this Additionally, case. and Specifically, as will be further addressed below, the Plaintiffs own actions in its failure to pay its statutory requiredobligationsto maintain insurance led to the Defendants' mortgage company placing a forced placed insurance which resulted in higher mortgage significantly in the pending foreclosure of the mortgage. Moreover, the payments resulting Plaintiff's affidavit in support of summary judgment is wholly insufficient as a matter of law and it fails to include the Exhibit "A" referred to in the affidavit. '.r ;The court shall grant summary judgment if the movant shows that there is no genuine disputeas to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a);Celotex Corp. v. Catrett,477 U.S. 317,322, 106 S. Ct. 2548,2552,91 L. Ed. 2d 265 (1986).The movant "always bears the initial of informing the responsibility district court of the basis for its motion, and those portionsof identifying 'the pleadings,depositions,answers to and admissions on file,togetherwith the affidavits,if any,' which interrogatories, it believes demonstrate the absence of a genuine issue of material fact." Id at 323 (quotingFed. R. Civ. P. 56(c)(1)(A).Florida Rule of Civil Procedure 1.510(c)providesin part that summary judgment shall be granted if: .. [Tlhe pleadings,depositions, answers to interrogatories, admissions, affidavits, and other materials as would be admissible in evidence on file show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law. Plaintiff failed to comply with the Motion for Summary Judgment standard, failed to address the affirmative defenses, failed to provide ANY admissible evidence in support of its motion, and therefore,summary judgment must be denied. 2 PROCEDURAL HISTORY 1. Undisputed. 2. Undisputed. 3. Disputed.The Defendants filed an Answer and Affirmative Defenses in this action. The demonstrate that it was the Plaintiffthat failed to perform affirmative defenses clearly their duties. The Plaintiff failed to maintain adequate insurance as requiredby Florida Statute 718.111 (11). This failure of duty led to the Defendants' first mortgage adding force-placedinsurance to the mortgage payments of the Defendants increasingthe mortgage payments by a largeamount. Furthermore, the Plaintiff has acted with bad faith failing to provide statements, accountings, or very limited correspondence with Defendants. (See Defendants' Affirmative Defenses.) 4. Disputed.The Defendants filed an Answer and Affirmative Defenses in this action. According to the Defendants' Affirmative Defenses, the Plaintiff is the one who failed to perform their duties such as the maintenance of adequateinsurance, the maintenance ofthe common areas; and the maintenance of adequateand correct accountingand records. (See Answer and Affirmative Defenses.) 5. Undisputed. 6. Undisputed. B. CLAIMS AND DEFENSES 7. Undisputed that the Plaintiff seeks Summary Judgment, but disputedas to whether Plaintiff is entitled to Summary Judgment. 8. Disputed to that the affidavits submitted by Plaintiff are sufficient for an entry of Summary Judgment. The affidavit for indebtedness is not signed by employee or board 3 officer of the Plaintiff nor based on personal knowledge. The Affidavit of Indebtedness is signedby Plaintiff' s counsel as generalcounsel for the association. The affiant states that he has reviewed the ledger,the records of the Association. However, the Affiant does not state that he knows how these ledgeror records are maintained. He does not state that the records were made at time of the business transaction; and does not include any records to the affidavit. The affidavit is therefore insufficient. 9. Disputed. The Plaintiff failed to perform its duties. The Defendants continued to pay after the Plaintiff failed to maintained insurance on the property and failed to maintain the common grounds. 10. Undisputed that the Lien runs with the land and that Defendants must comply with all rules However, the Plaintiff also owes duties to the Defendants, and and regulations. all other property owners. The Plaintiff failed to perform the duties including failure to maintain insurance,failure to maintain the common grounds,and failure to maintain proper records and accounting.See Florida Statute 718.111(11). 11. Undisputed as to the renderingofthe statute. 12. Disputed. The Plaintiff has not stricken the Defendants' affirmative defenses includingthe Fifth Affirmative Defense which states that the claim of lien does not comply with the statute. 13. Disputed. The Plaintiff has not stricken the Defendants' affirmative defenses includingthe Fifth Affirmative Defense which states that the claim of lien does not comply with the statute. 14. Disputed. The Defendants asserted several affirmative defenses, and none of the affirmative defenses have been stricken and none were addressed in the Motion for 4 and Summary Judgment. The Plaintiff failed to perform the duties that they are to required, theybreached their commitment to the Defendants and other property owners. The Plaintiff failed to maintain insurance, failed to maintain the common areas, and failed to maintain adequaterecords and accountings. 15. Disputed.The lien is not valid for failure to comply with the strictly Statute. 16. Disputed.The Defendants did respond. Answer and Affirmative Defenses were filed,and none of the affirmative defenses have been stricken. C. NEW SUMMARY JUDGMENT STANDARD The Defendants do not disputethe Standard for Summary Judgment. However, the Defendants assert that the Answer and Affirmative Defenses of the filed by the Defendants have not been refuted,that the Plaintiff failed to comply with Rule 1.510 and failed to include any admissible business records for the Court's consideration. D. MOVING PARTIES CERTIFICATION The Defendants has no statement on the moving partiescertification. DEFENDANTS' STATEMENT OF FACTS AND ARGUMENTS 17. On August 27,2021, an Answer and Affirmative Defenses were filed by the Defendants. 18. The Plaintiff filed a Motion for Summary Judgment on November 23,2021, which has been scheduled for hearing on June 29,2022. 19. The Affidavit of Indebtedness was filed on November 29,2021. 20. None of the Affirmative Defenses have been stricken. 21. None of the Affirmative Defenses have been addressed in the Plaintiff's Motion for Summary Judgment. 5 22. The Affirmative Defenses show that the Plaintiff has breached its duty to the Defendants to maintain property insurance,to maintain the common grounds,to maintain proper accountingand records. 23. The Affidavit of Indebtedness is insufficient under the business records exception. 24. Therefore,the Plaintiff has failed to demonstrate that it has complied with the new standard for Motion for Summary Judgment. PLAINTIFF CANNOT PREVAIL ON SUMMARY JUDGMENT A. Affirmative Defenses Still Exist "- First "when a party raises affirmative defenses, a summary judgment should not be granted where there are issues of fact raised by the affirmative defenses which have not been effectively challengedand refuted." Alejandre factually v. Deutsche Bank Trust Company, 44 So. 3d 1288 (Fla.4th DCA 2010). Woodrum v. Wells Fargo Mortg. Bank, N.A.,73 So.3d 873 (Fla.4th DCA 2011) (findingthat it is error to enter summary judgment where the bank fails to refute affirmative defenses raised in opposing affidavit or show that Under Florida they are legallyinsufficient). law, it remains Plaintiffs burden to show that any defenses offered by Defendant are legally insufficient. See Corya v. Sanders, 76 So.3d 31 (Fla.4th DCA 2011); see also Bryson v. Branch Banking and Trust Co., 75 So.3d 783 (Fla.2d DCA 2011). Thus, in order for Plaintiff to obtain a summary judgment when affirmative defenses are asserted,the burden is on the Plaintiff,as the moving party, to either disprove those defenses by evidence or by establishingthe legal of those defenses. The Defendant has insufficiency filed an Answer and Affirmative Defenses to the Complaint. The Plaintiff fails to even discuss, much less refute them in the Motion for Summary Judgment, but none of the Affirmative Defenses have been stricken. 6 B. Plaintiff has failed to provide any admissible evidence or business records in order to obtain Summary Judgment There is no evidence from anyone with personalknowledge regardingany allegation in the Complaint or the Motion for Summary Judgment. Therefore, while the Plaintiff makes same conclusionaryallegations, is not supportedby documentation and is non-admissible hearsay. See Fla. R. Civ. P. 1.510(e)(2020); §§ 90.801, 90.802, 90.803,90.901, Fla. Stat. (2018);Sas v. Fannie Mae, 112 So. 3d 778 (Fla. 2d DCA 2013) (holding that the trialcourt abused itsdiscretion by allowingthe witness to about the contents of business records to prove the amount of a testify debt without having first admitted the business records);Thompson v. State,705 So. 2d 1046, 1048 (Fla.4th DCA 1998) (holdingthat business record exception to hearsay did not authorize hearsay the value of merchandise stolen when testimony about the contents of business record reflecting the business record was not admitted into evidence); Cullimore v. Barnett Bank qfJacksonville, 386 So. 2d 894, 895 (Fla. 1 st DCA 1980) (holding that the business records exception is inapplicablebecause there were no records or reports offered into evidence); Coleman v. Grandma's Place, Inc.,63 So. 3d 929 (Fla.4th DCA 2011) (holdingthat documents upon which See also Heller the affiant relied should be sworn and attached to the affidavit); v. Bank ofAm., NA., 209 So. 3d 641,645 (Fla.2d DCA 2016); Miller v. Bank ofAm., N.A., 101 So. 3d 1286, 1288 (Fla.2d DCA 2016); Helton v. Bank of Am., N.A., 187 So. 3d 245, 247 (Fla.5th DCA 2016); Kenney v. HSBCBank USA, N.A.,175 So. 3d 377,378-9 (Fla.4th DCA 2015. As an affidavit for summary judgment purposes is taking the place of trial evidence, this predicatemust be set forth priorto acceptingthe testimony as true. Here, there is no affidavit which is based on personal knowledge and there are no records attached to the affidavit. Therefore, summary judgment must be denied. 7 WHEREFORE, Defendants pray that this Honorable Court deny the Motion for Summary Judgment, award attorneys fees and award Defendants such other relief as this Court deems justand proper. DECLARATION PURSUANT TO FL. STATUTE § 92.525(2) Under penalties of perjury,I declare that I have read the foregoing declaration and that the facts stated in it are true. -/s./Beniamin Vasquez Goden Benjamin Vasquez Goden Date 06/09/2022 /s/ Maria Del Carmen Ramirez- Maria Del Carmen Ramirez Date 06/09/2022 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoingwas sent on June 9, 2022, to all via the ePortal and parties to JOHN PAUL ARCIA, P.A. at service@arcialaw.com. CORONA LAW FIRM, P.A. 6700 SW 38 Street Miami, Florida 33155 Telephone: (305) 547-1234 Facsimile: (305) 266-1151 Primary Email: foreclosure@coronapa.com Secondary Email: ricky@coronapa.com By: /s/ America Alvarez RICARDO R. CORONA Attorney for Defendants Florida Bar No: 111333 Ricardo Corona Florida Bar No: 107684 America Alvarez Florida Bar No: 0716080 9