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Filing # 97424563 E-Filed 10/17/2019 10:13:38 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR ORANGE COUNTY, FLORIDA
LRD MULTISERVICES, LLC,
a Florida limited liability company,
Plaintiff,
Case No.:
vs.
PARRAMORE CONSTRUCTION
COMPANY, INC., a Florida corporation;
PARKER DEVELOPMENT AND
CONSTRUCTION, LLC, a Florida limited
liability company; CAMERON PRESERVE II,
LLC, a Florida limited liability company; and
JIMMY SANCHEZ, an individual,
Defendants.
/
COMPLAINT FOR DAMAGES
Plaintiff, LRD Multiservices, LLC (“LRD”), by and through its undersigned counsel,
hereby sues Defendants, Parramore Construction Company, Inc. (“Parramore Construction”),
Parker Development and Construction, LLC (“Parker Development”), Cameron Preserve IJ, LLC
(“Cameron Preserve”), and Jimmy Sanchez (“Sanchez”) (collectively, “Defendants”), and alleges:
Parties, Jurisdiction, and Venue
1 The amount in controversy exceeds $15,000.00, exclusive of interest, costs, and
attorneys’ fees.
2. LRD is a Florida limited liability company with a principal place of business
located in Orange County, Florida.
3 Parramore Construction is a Florida corporation that maintains its principal place
of business in Osceola County, Florida. Parramore Construction is owned by Deion R. Lowery.
Page 1 of 11
At all times material, Parramore Construction served as a contractor at the Cameron Preserve
Apartments.
4 Parker Development is a Florida limited liability company that maintains its
principal place of business in Osceola County, Florida. At all times material, Parker Development
served as a contractor at the Cameron Preserve Apartments.
5 Cameron Preserve is a Florida limited liability company that maintains its principal
place of business in Orange County, Florida, and owns an apartment complex in Osceola County,
Florida, called the Cameron Preserve Apartments.
6 Leland Enterprises is a Florida corporation that maintains its principal place of
business in Osceola County, Florida. At all times material, Leland Enterprises served as the
apartment management company for the Cameron Preserve Apartments.
7 Emily Badger is one of the owners of Leland Enterprises and one of the two owners
of Cameron Preserve.
8 Deion R. Lowery, the owner of Parramore Construction, is also the owner of the
company DRL CP II LLC, and DRL CP II LLC is the other owner of Cameron Preserve.
9 Sanchez is an individual who, upon information and belief, resides in Osceola
County, Florida. Sanchez is the owner and Manager of Parker Development.
10. Venue is proper in Orange County, Florida because: (a) a substantial portion of the
events giving rise to this Complaint occurred in Orange County, Florida; (b) at least one of the
Defendants maintains a principal place of business in Orange County, Florida; and (c) the breach
of contract at issue in this lawsuit occurred in Orange County, Florida, due to Defendants’ failure
to pay LRD in Orange County, Florida.
Page 2 of 11
General Allegation:
11. Between October 2018 and February 2019, Sanchez (on behalf of himself, Parker
Development, Parramore Construction, and/or Cameron Preserve) requested that LRD perform,
and LRD in fact performed, various construction-related services at the Cameron Preserve
Apartments, including (but not limited to) installation of doors (including pocket doors), providing
materials for window sill installation, exterior painting of multiple buildings in the apartment
complex, painting stairwells, painting entrance doors, drywall repair, installation of kitchen range
hoods, installation of roof access doors on hallway ceilings, baseboard installation, closet shelf
installation, door knob installation, window blind installation, and providing paint and caulk
materials (the “Services”).
12. Cameron Preserve, the owner of the Cameron Preserve Apartments, directly and
substantially benefitted from LRD’s Services performed there.
13. After performing the Services at the Cameron Preserve Apartments, LRD timely
submitted invoices to Sanchez, Parramore, and Parker Development detailing LRD’s performance
of the Services, including description of the Services performed, the date that the Service was
performed, the rate, and the amount owed (subtracting any payments received).
14, LRD submitted the following invoices for the Services it performed for the
Properties:
Invoice No. Date of Service Service Invoice Amount Due
Description | Amount
1743 10/08/18 Yes $5,510.94 $5,390.03
1789 10/25/18 Yes $13,000.00 $4,000.00
1840 10/28/18 Yes $13,000.00 $4,000.00
Page 3 of11
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1940 11/20/18 Yes $1,500.00 $150.00
1941 11/20/18 Yes $5,400.00 $540.00
2101 12/30/18 Yes $500.00 $50.00
2122 01/03/19 Yes $1,800.00 $1,800.00
2163 01/10/19 Yes $10,000.00 $1,000.00
2191 01/13/19 Yes $1,350.00 $1,350.00
2192 01/14/19 Yes $1,000.00 $1,000.00
2291 02/04/19 Yes $4,200.00 $4,200.00
2292 02/04/19 Yes $900.00 $900.00
2293 02/04/19 Yes $1,200.00 $1,200.00
2294 02/04/19 Yes $1,600.00 $1,600.00
2296 02/04/19 Yes $4,320.00 $4,320.00
2367 02/12/19 Yes $3,248.19 $3,248.19
2383 02/14/19 Yes $1,520.00 $1,520.00
True and correct copies of the above-listed invoices (the “Invoices”) are attached as
Composite Exhibit “A”.
15. Portions of some of the Invoices were paid by Leland Enterprises, as the apartment
management company on behalf of Cameron Preserve, which left a balance due and owing to LRD
of $36,268.22 for its Services.
16. LRD has sent three demand letters regarding seeking payment for its Services: (a)
a June 19, 2019 demand letter to Sanchez and Parker Development; (b) a July 23, 2019 letter to
Cameron Preserve; and (c) a July 23, 2019 to Parramore Construction. True and correct copies of
Page 4 of 11
’
these Demand Letters (without their voluminous enclosures) are attached hereto as Exhibits “B”,
“C”, and “D”, respectively.
17. On July 10, 2019, in response to the June 19, 2019 demand letter, Sanchez claimed
that, despite his personal and direct contact with LRD to request the provided Services, he (whether
individually or through Parker Development) never actually hired LRD. According to Sanchez,
LRD was hired by Parramore Construction to perform the Services. Thus, LRD sent the other two
demand letters to Parramore Construction, Leland Enterprises, and Cameron Preserve. In any
event, Sanchez’s response has caused confusion over which principal he represented when
requesting the Services.
18. Despite the multiple demand letters, LRD has received no other payments to date.
Currently, the balance due and owing;to LRD for its Services is $36,268.22.
19. All conditions precedent to bringing this action have been performed, have been
waived, or have otherwise occurred.
Count I- Open Account
20. LRD realleges and incorporates herein paragraphs 1 through 19 above.
21. This is an action for open account (per Fla. R. Civ. P. Form 1.932).
22. Parramore Construction still owes LRD $36,268.22 according to the account
documents, i.e., Invoices, attached hereto as Exhibit “A”.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Parramore Construction, awarding LRD damages and interest, awarding LRD costs
and attorneys’ fees,! and awarding such other relief that this Court deems just and equitable.
1 See Caufield v. Canitele, 837 So. 2d 371, 379-80 (Fla. 2002) (“We also hold that the contractual
or statutory basis for the attorney fee need not be specifically pled and failure to so plead does not
result in a waiver of the claim.”).
Page 5 of11
Count II ~ Open Account
23. LRD realleges and incorporates herein paragraphs 1 through 19 above.
24, This is an action for open account (per Fla. R. Civ. P. Form 1.932).
25. Cameron Preserve still owes LRD $36,268.22 according to the account documents,
i.e., Invoices, attached hereto as Exhibit “A”.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Cameron Preserve, awarding LRD damages and interest, awarding LRD costs and
attorneys’ fees,” and awarding such other relief that this Court deems just and equitable.
Count III —- Open Account
26. LRD realleges and incorporates herein paragraphs 1 through 19 above.
27. This is an action for open account (per Fla. R. Civ. P. Form 1.932).
28. Parker Development still owes LRD $36,268.22 according to the account
documents, i.e., Invoices, attached hereto as Exhibit “A”.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Parker Development, awarding LRD damages and interest, awarding LRD costs and
attorneys’ fees, and awarding such other relief that this Court deems just and equitable.
Count IV — Open Account
29. LRD realleges and incorporates herein paragraphs 1 through 19 above.
30. This is an action for open account (per Fla. R. Civ. P. Form 1.932).
2 See Footnote 1.
3 See Footnote 1.
Page 6 of 11
31. Sanchez still owes LRD $36,268.22 according to the account documents, i.e.,
Invoices, attached hereto as Exhibit “A”.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Sanchez, awarding LRD damages and interest, awarding LRD costs and attorneys’
fees,’ and awarding such other relief that this Court deems just and equitable.
Count V - Unjust Enrichment
32. LRD realleges and incorporates herein paragraphs 1 through 19 above.
33. This is a cause of action against Cameron Preserve for-unjust enrichment.
34, LRD conferred a benefit upon Cameron Preserve, namely by performing the
requested Services at the Cameron Preserve Apartments.
35. Cameron Preserve had knowledge of this conferred benefit.
36. Cameron Preserve voluntarily accepted and retained this conferred benefit, as the
Services were performed at and improved the apartment complex owned by Cameron Preserve.
37. Because Cameron Preserve has failed and refused to pay LRD for its Services, it
would be inequitable for Cameron Preserve to retain the benefit conferred without having to pay
LRD for same. Indeed, Cameron Preserve’s retention of the conferred benefit without having to
pay LRD for it would unjustly enrich Cameron Preserve and damage LRD.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Cameron Preserve, awarding LRD damages, interest, costs, attorneys’ fees,> and such
other relief that this Court deems just and equitable.
4 See Footnote 1.
5 See Footnote 1.
Page 7 of 11
Count VI — Account Stated
38. LRD realleges and incorporates herein paragraphs 1 through 19 above.
39. This is a cause of action against Cameron Preserve for account stated.
40. Before the institution of this action, LRD and Cameron Preserve had a business
transaction between them between about October 2018 and February 2019.
Al, LRD provided Invoices for the resulting balance to LRD, and Cameron Preserve
did not object to them.
42. Therefore, because Cameron Preserve failed to object to the Invoices, Cameron
Preserve agreed that the balance reflected in the Invoices was correct and due.
43, Cameron Preserve made an express or implied promise to pay for the Services
provided.
44. Cameron Preserve owes $36,268.22 to LRD as set forth in the Invoices.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Cameron Preserve, awarding LRD damages and interest, awarding LRD costs and
attorneys’ fees, and awarding such other relief that this Court deems just and equitable.
Count VII - Account Stated
45. LRD realleges and incorporates herein paragraphs 1 through 19 above.
46. This is a cause of action against Parramore Construction for account stated.
47. Before the institution of this action, LRD and Parramore Construction had a
business transaction between them between about October 2018 and February 2019.
48. LRD provided Invoices for the resulting balance to LRD, and Parramore
Construction did not object to them.
Page 8 of 11
49. Therefore, because Parramore Construction failed to object to the Invoices,
Parramore Construction agreed that the balance reflected in the Invoices was correct and due.
50. Parramore Construction made an express or implied promise to pay for the Services
provided.
51. Parramore Construction owes $36,268.22 to LRD as set forth in the Invoices.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Parramore Construction, awarding LRD damages and interest, awarding LRD costs
and attorneys’ fees, and awarding such other relief that this Court deems just and equitable.
Count VIII —- Account Stated
52. LRD realleges and incorporates herein paragraphs 1 through 19 above.
353. This is a cause of action against Parker Development for account stated.
34, Before the institution of this action, LRD and Parker Development had a business
transaction between them between about October 2018 and February 2019.
55. LRD provided Invoices for the resulting balance to LRD, and Parker Development
did not object to them.
56. Therefore, because Parker Development failed to object to the Invoices, Parker
Development agreed that the balance reflected in the Invoices was correct and due.
357. Parker Development made an express or implied promise to pay for the Services
provided.
58. Parker Development owes $36,268.22 to LRD as set forth in the Invoices.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and
against Parker Development, awarding LRD damages and interest, awarding LRD costs and
attorneys’ fees, and awarding such other relief that this Court deems just and equitable.
Page 9 of 11
i, OO
Count IX — Account Stated
59. LRD realleges and incorporates herein paragraphs 1 through 19 above.
60. This is a cause of action against Sanchez for account stated.
61. Before the institution of this action, LRD and Sanchez had a business transaction
between them between about October 2018 and February 2019.
62. LRD provided Invoices for the resulting balance to LRD, and Sanchez did not
object to them.
63. Therefore, because Sanchez failed to object to the Invoices, Sanchez agreed that
the balance reflected in the Invoices was correct and due.
64. Sanchez made an express or implied promise to pay for the Services provided.
65. Sanchez owes $36,268.22 to LRD as set forth in the Invoices.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Sanchez, awarding LRD damages and interest, awarding LRD costs and attorneys’
fees, and awarding such other relief that this Court deems just and equitable.
Count X — Breach of Oral Contract
66. LRD realleges and incorporates herein paragraphs 1 through 19 above.
67. This is a cause of action against Sanchez, Parramore Construction, Parker
Development, and Cameron Preserve for breach of oral contract.
68. LRD had an oral contract with Sanchez, Parramore Construction, Parker
Development, and/or Cameron Preserve to perform the Services at the Cameron Preserve
Apartments in exchange for the payment of LRD’s Invoices for the Services upon completion.
Page 10 of 11
69. Sanchez, acting on behalf of himself, Parramore Construction, Parker
Development, and/or Cameron Preserve, requested (with actual or apparent authority) that LRD
perform the Services at the Cameron Preserve Apartments.
70. Pursuant to the oral contract, LRD performed said Services and submitted Invoices
for same.
71. Leland, the property management company for Cameron Preserve paid some, but
not all, of the Invoices.
72. The failure of Sanchez, Parramore Construction, Parker Development, and/or
Cameron Preserve to pay the Invoices in full materially breached the oral agreement.
2B. The material breach of the oral contract has damaged LRD.
WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor
and against Sanchez, Parramore Construction, Parker Development, and/or Cameron Preserve
awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such
other relief that this Court deems just and equitable.
Respectfully submitted this 16th day of October, 2019.
/s/ Brandon W. Banks
Brandon W. Banks, Esq.
Florida Bar No.: 587461
Brian M. Walsh, Esq.
Florida Bar No,: 10968
WALSH BANKS LAW
P.O. Box 2271
Orlando, FL 32802
Ph: (407) 259-2426
Fx: (407) 391-3626
Email: brandon.banks@walshbanks.com
Email: brian.walsh@walshbanks.com.
Secondary Email: service@walshbanks.com
Page 11 of 11
Composite
Exhibit “A”
.
of IRD
1970 E. Osceola Pkwy Suite 328
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Jimy Sanchez
Ferramore Construction
1627 Bast Vine ST Fen ayy
Suite 201
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a Cameron
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10/08/2018 Lsbor 18 300.00 5,400.00
For installation of room doors and closet doors first part of Building 2. For 18
ween eee. loom
out of 36_ open: ae - ae ee a ee poets ee seen e ee em =
10/08/2018 MATERIALS 55.47 110,94 ,
Materials for windows sills installation (marbles) Caulking (see attachment
enclosed)
PAYMENT IS DUE WITUIN 30 DAYS. PAYMENT 120,91
PLEASE INCLUDE INVOICE # ON YCUR CHECK.
*TWANK, YOU FOR YOUR BUSINESS!
1970 B, Osceola Pkwy Suite 328
— munSersinestte Kissimmee, FL 34743
40?-257-0990
rdnsuktiservices Jic@etnail.com
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Jimmy Sanchez,
Parrumore Construction
1627 East Vine ST 3 Buea ibe
Suite 26% :
Kissimmee, FL 34744
Ssyy Ua i rn
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10/25/2018 Paint Service:Paint Services 0.00
Exterior Paint for all apartment buildings
*Prepare area (cover windows and surrounding areas)
*Paint of 3 exterior apartment building with 36 units
ee Paint all breezeways of 7 apartment buildiags ae a ~ awe
10/25/2018 Paint Steiways 0.00 0.00
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10/25/2018 Paint Service:Peint 36 9.00
Paint all entrance doors on 36 units (price per door is ouly if complete job is
granted) ae. ree ew ce lee a ——
10/25/2018 Paint Service:Paint Services 1 0.00
Exterior Paint of 1 Amenities Buildings (at a minimal charge as part of the
whole paint job)
*Leasing Building
*Pool Area/I aundry
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*Maintanance Building
*Pavilion
“ Hl amenities entrance
doors included in price*?*_ eee ae ae ee ctl ew
————
10/25/2018 Labor& Maieris! ° 13,000.00 13,000.00
Labor and Material included as part ofthe price
PAYMENT IS DUE WITHIN 30 DAYS. PAYMENT 9,000.00
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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“THANK YOU FOR YOUR BUSINESS!
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10/28/2018 Paint Steireaye 0.00 0,00
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10/28/2018 Paint Service:Peint Services 36 0.00
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10/28/2018 Paint Service:Paint Servioss 1 0.00
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1028/2018 Labor & Material 1 13,000.00 13,000.00
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PAYMEN? IS DUE WITHIN 30 DAYS. PAYMENT 9,000.00
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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“THANK YOU FOR YOUR BUSINESS!
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1970 B. Osceola Pkrv Suite 328
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Parramore Construction
1627 East Vine ST a
Suite 201
Kissimmee, FL: 34744
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BY
11/20/2018 Repeir:Drywell
- Single Repair 20 75.00 1,500.00
For Cameron Project in Kissimmee, FL
*PARTIAL, installation of: interior closet wite shelves in FOR 20 UNITS ON
Building -i
* Labor ONLY
>All materials to be providedby Contractor
PAYMENT !S DUR WITHIN 30 DAYS. PAYMENT 1,350.00
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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Parte reas
*THANK YOu FOR YOUR BUSINESS!
ERD Multiservions
LUC.
Lap Serine ae
1970 E. Osceola Pkwy Suite 328
Kissimmee, FL 34743
407-257-0990
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BILL TO
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Parramore Construction
1627 East Vine ST i
Suite 201
Kissimmes, FL 34744
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08/24/2018 ‘Labor & Material
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For installation of room doors and close doors Second part of Building 2. For
J8 room out of 36
PAYMENT 1S DUE WITHIN 30 DAYS.. PAYMENT 4,860.00
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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“THANK YOU FUR YOUR BUSINESS!
ma LRD Maltisecvioes
LLC,
1970 E. Osceola Pkwy Suite 328
crt Ben Garvires 10 kissmmee, FL 24753
407-257-0996
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Parramore Construction
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PAYMENT IS DUE WITHIN 30 DAYS. PAYMENT 450.00
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*THANK YOUFOR YOUR BUSINESS!
fi Lhe 1976 E. Osceola Pkwy Suite 328
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*For 100 Apartment units bathrooms or 200 mirrors
*Tncludes the office and all amenities bathrooms mirrors
Partial invoice for 36 Units out of the 100 for the whole project.
***Customer to provide all materials needed for installation
PAYMENT 18 DUE WITHIN 3C DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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01/10/2019 Paint Service:Labor 1 10,000.00 10,000.00
Partial payment from pending balance of $47,000 discussed in the meeting
from 01/07/19 at the office.
PAYMENT IS DUE WITHIN 30 BAYS. PAYMENT 000.00
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
*THANK YOU FOR YOUR BUSINESS!
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PAYMENT [S DUE WITUIN 30 DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
“THANK YOU FOR YOUR BUSINESSI
ERD Muliisorvices LLO.
1970 E. Csceola Pkwy Suite 325
Beaters: Kissimmee, FL 34743
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Parremose Construction
1627 East Vine ST Sr ey
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02/04/2019 4 300.00 4200.00
BASE BOARDS / DOORS INSTALLATION
“partial payment from original project units100 unit*
Still Pending only 4 units and the gym arca (we are waiting for the OK to
complete)
PAYMENT IS DUE WITHIN 36 DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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SHANK YOU FOR YOUK BUSINESS:
LRD Multiserviess
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Parramore Constroction
1627 East Vine ST EL
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02/04/2019 Labor 36 25.00 900.00
RANGE HOODS INSTALLATION
*Partial invoice from 100 units*
Still pending 44 unitsto be completed (as soon as material are available)
PAYMENT JS DUE WITHIN 30 DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
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02/04/2019 Lebor 16 75.00 1,200.00
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PAYMENT IS DUE WITHIN 30 DAYS.
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Parramore Construction
1627 East Vive ST oS= Ce
Surte 261 |
Kissuamee, FL 34744
YX AOE
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02/04/2019 20 80.00 1,600.00
DOOR NOBS INSTALLATION
*Partial invoice of 20 units from 100 units, still pending 44 units (to be
completed as soo as material are available)
PAYMENTS IS DUB WITHIN 30 DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK,
“THANK YOU POR YOUR BUSINESS!
pone, LRD TLL.
#8&& 1B 1970 E, Osceola Plowy Suite 228
yi kissizamee, FL 34743
er AN7-257-00590
Ldinulticerviows cGigmeit.com
BILL TO
Jimmy Sanchez.
Parramore Construction
1627 East Vine ST LSBU VeLY
Suite 203
Kissimmee, FL. 34744
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02/04/2019 Labor 36 120.00 4,320.00
WINDOW BLINDS INSTALLATION
*Partial invoice of 36 units out of 100, still pending 44 unit to complete the job.
(we are waiting for materials to be available)
PAYMENT JS DUE WITHIN 30 DAYS.
PLEASE INCLUDE INVOICE # ON YOUR CHECK.
is
Uo
“THANK YOU ‘YUUK BUSINESS!
‘LRD Mubiserviees LLC.
1970E. Osceola Pkwy & 32
Baki Sercives te kissiramee, FL 34743
AQ7-257-0990
Jedmutisorvices licgmail.cem
BLL TO
Jinamy Sanchez
Parramore Construction a
1627 Easi Vine ST SDs. ee
Suite 201
‘Kissimmee, FL 34744
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02/12/2019 MATERIALS 2,526.68 2526.68
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02/12/2019 MATERIALS 1 144.48 144,48
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Preview
Filing # 97424563 E-Filed 10/17/2019 10:13:38 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA LRD MULTISERVICES, LLC, a Florida limited liability company, Plaintiff, Case No.: vs. PARRAMORE CONSTRUCTION COMPANY, INC., a Florida corporation; PARKER DEVELOPMENT AND CONSTRUCTION, LLC, a Florida limited liability company; CAMERON PRESERVE II, LLC, a Florida limited liability company; and JIMMY SANCHEZ, an individual, Defendants. / COMPLAINT FOR DAMAGES Plaintiff, LRD Multiservices, LLC (“LRD”), by and through its undersigned counsel, hereby sues Defendants, Parramore Construction Company, Inc. (“Parramore Construction”), Parker Development and Construction, LLC (“Parker Development”), Cameron Preserve IJ, LLC (“Cameron Preserve”), and Jimmy Sanchez (“Sanchez”) (collectively, “Defendants”), and alleges: Parties, Jurisdiction, and Venue 1 The amount in controversy exceeds $15,000.00, exclusive of interest, costs, and attorneys’ fees. 2. LRD is a Florida limited liability company with a principal place of business located in Orange County, Florida. 3 Parramore Construction is a Florida corporation that maintains its principal place of business in Osceola County, Florida. Parramore Construction is owned by Deion R. Lowery. Page 1 of 11 At all times material, Parramore Construction served as a contractor at the Cameron Preserve Apartments. 4 Parker Development is a Florida limited liability company that maintains its principal place of business in Osceola County, Florida. At all times material, Parker Development served as a contractor at the Cameron Preserve Apartments. 5 Cameron Preserve is a Florida limited liability company that maintains its principal place of business in Orange County, Florida, and owns an apartment complex in Osceola County, Florida, called the Cameron Preserve Apartments. 6 Leland Enterprises is a Florida corporation that maintains its principal place of business in Osceola County, Florida. At all times material, Leland Enterprises served as the apartment management company for the Cameron Preserve Apartments. 7 Emily Badger is one of the owners of Leland Enterprises and one of the two owners of Cameron Preserve. 8 Deion R. Lowery, the owner of Parramore Construction, is also the owner of the company DRL CP II LLC, and DRL CP II LLC is the other owner of Cameron Preserve. 9 Sanchez is an individual who, upon information and belief, resides in Osceola County, Florida. Sanchez is the owner and Manager of Parker Development. 10. Venue is proper in Orange County, Florida because: (a) a substantial portion of the events giving rise to this Complaint occurred in Orange County, Florida; (b) at least one of the Defendants maintains a principal place of business in Orange County, Florida; and (c) the breach of contract at issue in this lawsuit occurred in Orange County, Florida, due to Defendants’ failure to pay LRD in Orange County, Florida. Page 2 of 11 General Allegation: 11. Between October 2018 and February 2019, Sanchez (on behalf of himself, Parker Development, Parramore Construction, and/or Cameron Preserve) requested that LRD perform, and LRD in fact performed, various construction-related services at the Cameron Preserve Apartments, including (but not limited to) installation of doors (including pocket doors), providing materials for window sill installation, exterior painting of multiple buildings in the apartment complex, painting stairwells, painting entrance doors, drywall repair, installation of kitchen range hoods, installation of roof access doors on hallway ceilings, baseboard installation, closet shelf installation, door knob installation, window blind installation, and providing paint and caulk materials (the “Services”). 12. Cameron Preserve, the owner of the Cameron Preserve Apartments, directly and substantially benefitted from LRD’s Services performed there. 13. After performing the Services at the Cameron Preserve Apartments, LRD timely submitted invoices to Sanchez, Parramore, and Parker Development detailing LRD’s performance of the Services, including description of the Services performed, the date that the Service was performed, the rate, and the amount owed (subtracting any payments received). 14, LRD submitted the following invoices for the Services it performed for the Properties: Invoice No. Date of Service Service Invoice Amount Due Description | Amount 1743 10/08/18 Yes $5,510.94 $5,390.03 1789 10/25/18 Yes $13,000.00 $4,000.00 1840 10/28/18 Yes $13,000.00 $4,000.00 Page 3 of11 tS) 1940 11/20/18 Yes $1,500.00 $150.00 1941 11/20/18 Yes $5,400.00 $540.00 2101 12/30/18 Yes $500.00 $50.00 2122 01/03/19 Yes $1,800.00 $1,800.00 2163 01/10/19 Yes $10,000.00 $1,000.00 2191 01/13/19 Yes $1,350.00 $1,350.00 2192 01/14/19 Yes $1,000.00 $1,000.00 2291 02/04/19 Yes $4,200.00 $4,200.00 2292 02/04/19 Yes $900.00 $900.00 2293 02/04/19 Yes $1,200.00 $1,200.00 2294 02/04/19 Yes $1,600.00 $1,600.00 2296 02/04/19 Yes $4,320.00 $4,320.00 2367 02/12/19 Yes $3,248.19 $3,248.19 2383 02/14/19 Yes $1,520.00 $1,520.00 True and correct copies of the above-listed invoices (the “Invoices”) are attached as Composite Exhibit “A”. 15. Portions of some of the Invoices were paid by Leland Enterprises, as the apartment management company on behalf of Cameron Preserve, which left a balance due and owing to LRD of $36,268.22 for its Services. 16. LRD has sent three demand letters regarding seeking payment for its Services: (a) a June 19, 2019 demand letter to Sanchez and Parker Development; (b) a July 23, 2019 letter to Cameron Preserve; and (c) a July 23, 2019 to Parramore Construction. True and correct copies of Page 4 of 11 ’ these Demand Letters (without their voluminous enclosures) are attached hereto as Exhibits “B”, “C”, and “D”, respectively. 17. On July 10, 2019, in response to the June 19, 2019 demand letter, Sanchez claimed that, despite his personal and direct contact with LRD to request the provided Services, he (whether individually or through Parker Development) never actually hired LRD. According to Sanchez, LRD was hired by Parramore Construction to perform the Services. Thus, LRD sent the other two demand letters to Parramore Construction, Leland Enterprises, and Cameron Preserve. In any event, Sanchez’s response has caused confusion over which principal he represented when requesting the Services. 18. Despite the multiple demand letters, LRD has received no other payments to date. Currently, the balance due and owing;to LRD for its Services is $36,268.22. 19. All conditions precedent to bringing this action have been performed, have been waived, or have otherwise occurred. Count I- Open Account 20. LRD realleges and incorporates herein paragraphs 1 through 19 above. 21. This is an action for open account (per Fla. R. Civ. P. Form 1.932). 22. Parramore Construction still owes LRD $36,268.22 according to the account documents, i.e., Invoices, attached hereto as Exhibit “A”. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Parramore Construction, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees,! and awarding such other relief that this Court deems just and equitable. 1 See Caufield v. Canitele, 837 So. 2d 371, 379-80 (Fla. 2002) (“We also hold that the contractual or statutory basis for the attorney fee need not be specifically pled and failure to so plead does not result in a waiver of the claim.”). Page 5 of11 Count II ~ Open Account 23. LRD realleges and incorporates herein paragraphs 1 through 19 above. 24, This is an action for open account (per Fla. R. Civ. P. Form 1.932). 25. Cameron Preserve still owes LRD $36,268.22 according to the account documents, i.e., Invoices, attached hereto as Exhibit “A”. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Cameron Preserve, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees,” and awarding such other relief that this Court deems just and equitable. Count III —- Open Account 26. LRD realleges and incorporates herein paragraphs 1 through 19 above. 27. This is an action for open account (per Fla. R. Civ. P. Form 1.932). 28. Parker Development still owes LRD $36,268.22 according to the account documents, i.e., Invoices, attached hereto as Exhibit “A”. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Parker Development, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Count IV — Open Account 29. LRD realleges and incorporates herein paragraphs 1 through 19 above. 30. This is an action for open account (per Fla. R. Civ. P. Form 1.932). 2 See Footnote 1. 3 See Footnote 1. Page 6 of 11 31. Sanchez still owes LRD $36,268.22 according to the account documents, i.e., Invoices, attached hereto as Exhibit “A”. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Sanchez, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees,’ and awarding such other relief that this Court deems just and equitable. Count V - Unjust Enrichment 32. LRD realleges and incorporates herein paragraphs 1 through 19 above. 33. This is a cause of action against Cameron Preserve for-unjust enrichment. 34, LRD conferred a benefit upon Cameron Preserve, namely by performing the requested Services at the Cameron Preserve Apartments. 35. Cameron Preserve had knowledge of this conferred benefit. 36. Cameron Preserve voluntarily accepted and retained this conferred benefit, as the Services were performed at and improved the apartment complex owned by Cameron Preserve. 37. Because Cameron Preserve has failed and refused to pay LRD for its Services, it would be inequitable for Cameron Preserve to retain the benefit conferred without having to pay LRD for same. Indeed, Cameron Preserve’s retention of the conferred benefit without having to pay LRD for it would unjustly enrich Cameron Preserve and damage LRD. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Cameron Preserve, awarding LRD damages, interest, costs, attorneys’ fees,> and such other relief that this Court deems just and equitable. 4 See Footnote 1. 5 See Footnote 1. Page 7 of 11 Count VI — Account Stated 38. LRD realleges and incorporates herein paragraphs 1 through 19 above. 39. This is a cause of action against Cameron Preserve for account stated. 40. Before the institution of this action, LRD and Cameron Preserve had a business transaction between them between about October 2018 and February 2019. Al, LRD provided Invoices for the resulting balance to LRD, and Cameron Preserve did not object to them. 42. Therefore, because Cameron Preserve failed to object to the Invoices, Cameron Preserve agreed that the balance reflected in the Invoices was correct and due. 43, Cameron Preserve made an express or implied promise to pay for the Services provided. 44. Cameron Preserve owes $36,268.22 to LRD as set forth in the Invoices. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Cameron Preserve, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Count VII - Account Stated 45. LRD realleges and incorporates herein paragraphs 1 through 19 above. 46. This is a cause of action against Parramore Construction for account stated. 47. Before the institution of this action, LRD and Parramore Construction had a business transaction between them between about October 2018 and February 2019. 48. LRD provided Invoices for the resulting balance to LRD, and Parramore Construction did not object to them. Page 8 of 11 49. Therefore, because Parramore Construction failed to object to the Invoices, Parramore Construction agreed that the balance reflected in the Invoices was correct and due. 50. Parramore Construction made an express or implied promise to pay for the Services provided. 51. Parramore Construction owes $36,268.22 to LRD as set forth in the Invoices. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Parramore Construction, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Count VIII —- Account Stated 52. LRD realleges and incorporates herein paragraphs 1 through 19 above. 353. This is a cause of action against Parker Development for account stated. 34, Before the institution of this action, LRD and Parker Development had a business transaction between them between about October 2018 and February 2019. 55. LRD provided Invoices for the resulting balance to LRD, and Parker Development did not object to them. 56. Therefore, because Parker Development failed to object to the Invoices, Parker Development agreed that the balance reflected in the Invoices was correct and due. 357. Parker Development made an express or implied promise to pay for the Services provided. 58. Parker Development owes $36,268.22 to LRD as set forth in the Invoices. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Parker Development, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Page 9 of 11 i, OO Count IX — Account Stated 59. LRD realleges and incorporates herein paragraphs 1 through 19 above. 60. This is a cause of action against Sanchez for account stated. 61. Before the institution of this action, LRD and Sanchez had a business transaction between them between about October 2018 and February 2019. 62. LRD provided Invoices for the resulting balance to LRD, and Sanchez did not object to them. 63. Therefore, because Sanchez failed to object to the Invoices, Sanchez agreed that the balance reflected in the Invoices was correct and due. 64. Sanchez made an express or implied promise to pay for the Services provided. 65. Sanchez owes $36,268.22 to LRD as set forth in the Invoices. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Sanchez, awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Count X — Breach of Oral Contract 66. LRD realleges and incorporates herein paragraphs 1 through 19 above. 67. This is a cause of action against Sanchez, Parramore Construction, Parker Development, and Cameron Preserve for breach of oral contract. 68. LRD had an oral contract with Sanchez, Parramore Construction, Parker Development, and/or Cameron Preserve to perform the Services at the Cameron Preserve Apartments in exchange for the payment of LRD’s Invoices for the Services upon completion. Page 10 of 11 69. Sanchez, acting on behalf of himself, Parramore Construction, Parker Development, and/or Cameron Preserve, requested (with actual or apparent authority) that LRD perform the Services at the Cameron Preserve Apartments. 70. Pursuant to the oral contract, LRD performed said Services and submitted Invoices for same. 71. Leland, the property management company for Cameron Preserve paid some, but not all, of the Invoices. 72. The failure of Sanchez, Parramore Construction, Parker Development, and/or Cameron Preserve to pay the Invoices in full materially breached the oral agreement. 2B. The material breach of the oral contract has damaged LRD. WHEREFORE, LRD respectfully requests that this Court enter a judgment in its favor and against Sanchez, Parramore Construction, Parker Development, and/or Cameron Preserve awarding LRD damages and interest, awarding LRD costs and attorneys’ fees, and awarding such other relief that this Court deems just and equitable. Respectfully submitted this 16th day of October, 2019. /s/ Brandon W. Banks Brandon W. Banks, Esq. Florida Bar No.: 587461 Brian M. Walsh, Esq. Florida Bar No,: 10968 WALSH BANKS LAW P.O. Box 2271 Orlando, FL 32802 Ph: (407) 259-2426 Fx: (407) 391-3626 Email: brandon.banks@walshbanks.com Email: brian.walsh@walshbanks.com. Secondary Email: service@walshbanks.com Page 11 of 11 Composite Exhibit “A” . of IRD 1970 E. Osceola Pkwy Suite 328 ye eprires UE Kissimmee, FL 34743 Se caer 407-257-0990 frémultiservices Ho@igraail.cont BILL TO ix) Jimy Sanchez Ferramore Construction 1627 Bast Vine ST Fen ayy Suite 201 Kissirnmee, Fi. 34744 varval rut Pes ud 08/24/2018 Labor & Material 0.00 0.00 a Cameron at Preserve located at 1650 Yates rd KissimmeeFL,Lee te ee wee bee ee 10/08/2018 Lsbor 18 300.00 5,400.00 For installation of room doors and closet doors first part of Building 2. For 18 ween eee. loom out of 36_ open: ae - ae ee a ee poets ee seen e ee em = 10/08/2018 MATERIALS 55.47 110,94 , Materials for windows sills installation (marbles) Caulking (see attachment enclosed) PAYMENT IS DUE WITUIN 30 DAYS. PAYMENT 120,91 PLEASE INCLUDE INVOICE # ON YCUR CHECK. *TWANK, YOU FOR YOUR BUSINESS! 1970 B, Osceola Pkwy Suite 328 — munSersinestte Kissimmee, FL 34743 40?-257-0990 rdnsuktiservices Jic@etnail.com BILL TO Ki) Jimmy Sanchez, Parrumore Construction 1627 East Vine ST 3 Buea ibe Suite 26% : Kissimmee, FL 34744 Ssyy Ua i rn ict Vee, 10/25/2018 Paint Service:Paint Services 0.00 Exterior Paint for all apartment buildings *Prepare area (cover windows and surrounding areas) *Paint of 3 exterior apartment building with 36 units ee Paint all breezeways of 7 apartment buildiags ae a ~ awe 10/25/2018 Paint Steiways 0.00 0.00 eee ays (pric luded as part of jote) 10/25/2018 Paint Service:Peint 36 9.00 Paint all entrance doors on 36 units (price per door is ouly if complete job is granted) ae. ree ew ce lee a —— 10/25/2018 Paint Service:Paint Services 1 0.00 Exterior Paint of 1 Amenities Buildings (at a minimal charge as part of the whole paint job) *Leasing Building *Pool Area/I aundry *Pool Area/Fitness Center *Maintanance Building *Pavilion “ Hl amenities entrance doors included in price*?*_ eee ae ae ee ctl ew ———— 10/25/2018 Labor& Maieris! ° 13,000.00 13,000.00 Labor and Material included as part ofthe price PAYMENT IS DUE WITHIN 30 DAYS. PAYMENT 9,000.00 PLEASE INCLUDE INVOICE # ON YOUR CHECK. Rey “THANK YOU FOR YOUR BUSINESS! tom, LRD Multiservioss LLO, 1970 E. Osceola Fiawy Suite 323 Uptierviens ee kissimmes, FL. 34743 Ne 407-257-0990 Indenultiservives Ue@ipmail.com BILLTO cay Jimmy Sanchez Parramove Construction = 1627 Gast Vine ST PLY.Vas RIL Suite 201 Kissimmee, PL 34744- HEIO) caw Non a Bie) eu ae {Ops 10/28/2018 Paint Service:Peint Services 0,00 Exterior Paint for all apartment buildings *Prepare area (cover windows and surrounding areas) *Paint of 3 exterior apartment building with 36 units wen ee *Paint all breezewaysof 7 apartment buildings | _ - on ano a ~ ae 10/28/2018 Paint Steireaye 0.00 0,00 ee Paint all stairways (price included as part of the Quote) _ ae fa nei eee aoe a 10/28/2018 Paint Service:Peint Services 36 0.00 Paint all entrance doors on 36 units (price per door is only if complete job is ee a BM e ne ce ne 10/28/2018 Paint Service:Paint Servioss 1 0.00 Exterior Paint of 1 Amenities Buildings (at a minimal charge as part of the whole paint job) *Leasing Building *Pool Area/Laundry *Pool Area/Fitness Center *Maintanance Buildiug *Pavilion ser A] 2 in price*** en Soe eo ee nn a 1028/2018 Labor & Material 1 13,000.00 13,000.00 _ Labor and Materia] incluced as part of the price PAYMEN? IS DUE WITHIN 30 DAYS. PAYMENT 9,000.00 PLEASE INCLUDE INVOICE # ON YOUR CHECK. ro eeu “THANK YOU FOR YOUR BUSINESS! fa é et P Rabe cr eviens TU 1970 B. Osceola Pkrv Suite 328 Kissimmee, FL 407-257-9999 34744 idrultiservices McGgmail.com BLL TO Jirmmy Sanchez Parramore Construction 1627 East Vine ST a Suite 201 Kissimmee, FL: 34744 eneeraeN BY 11/20/2018 Repeir:Drywell - Single Repair 20 75.00 1,500.00 For Cameron Project in Kissimmee, FL *PARTIAL, installation of: interior closet wite shelves in FOR 20 UNITS ON Building -i * Labor ONLY >All materials to be providedby Contractor PAYMENT !S DUR WITHIN 30 DAYS. PAYMENT 1,350.00 PLEASE INCLUDE INVOICE # ON YOUR CHECK. aN Parte reas *THANK YOu FOR YOUR BUSINESS! ERD Multiservions LUC. Lap Serine ae 1970 E. Osceola Pkwy Suite 328 Kissimmee, FL 34743 407-257-0990 tdmuttiservices.lic@:gmail.com @: BILL TO dimmy Sanchez, Parramore Construction 1627 East Vine ST i Suite 201 Kissimmes, FL 34744 vite me ma ray ma ea oe Beye SPECSLee NA (E) 08/24/2018 ‘Labor & Material a a _Cameronat Preserve located at 1650 Yates rd KissimmeeFL _ - Se ~ , 11/20/2018 Labor 18 300.00 5,400.00 For installation of room doors and close doors Second part of Building 2. For J8 room out of 36 PAYMENT 1S DUE WITHIN 30 DAYS.. PAYMENT 4,860.00 PLEASE INCLUDE INVOICE # ON YOUR CHECK. see) “THANK YOU FUR YOUR BUSINESS! ma LRD Maltisecvioes LLC, 1970 E. Osceola Pkwy Suite 328 crt Ben Garvires 10 kissmmee, FL 24753 407-257-0996 ledmultiservices ile gmail.cens BLL TO hl Jimmy Sanchez Parramore Construction 1627 East Vine ST eee : Suste 204 Kissizmiee, FI. 34744 SES BES CE CAITR TSE naz Oey mE 5 cmPE BSA DeegEa iN pa U Epc (ENEG T2808 Labor 20 25.00 500.00 Install 20 kitchen range hoods out of the 100 ou. Building one. PAYMENT IS DUE WITHIN 30 DAYS. PAYMENT 450.00 PLEASE INCLUDE INVGICE # ON YOUR CHECK... *THANK YOUFOR YOUR BUSINESS! fi Lhe 1976 E. Osceola Pkwy Suite 328 Ey ebateries ue kissimmwe, FL 34743 Rone 407-257-0906 Irdmultiservices gmail.com: PILL TC Jimmy Sanchez, Perramore Construction 627 East Vine ST ay Suite.201 Kissiramee, PL 34744 1M Ory a poe EIS 82 SRNR EOE mR 6) 6) 01/03/2019 Labor 36 50.00 3,800.00 Building 2 (36 units) Basic laborto install mirrors with favorable site conditions. *For 100 Apartment units bathrooms or 200 mirrors *Tncludes the office and all amenities bathrooms mirrors Partial invoice for 36 Units out of the 100 for the whole project. ***Customer to provide all materials needed for installation PAYMENT 18 DUE WITHIN 3C DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK. hoyt ie, oo WKN) i *THANK YOU.FOR YOUR BUSINESS! as 1970 E, Oxceola Pkwy Suite 328 & HaedservinesHe simmer, FL. 34743 57-0990 irdmubisarvices No@grsalewn BILL TO ra hx) Jinmy Sanchez Parramore Construction 1627 Hast Vioe ST Ey Suite 201 Kissimmee, PL 34744 sea PUNhe ESPewe a EET TENTS 52 a es ouky oa es 01/10/2019 Paint Service:Labor 1 10,000.00 10,000.00 Partial payment from pending balance of $47,000 discussed in the meeting from 01/07/19 at the office. PAYMENT IS DUE WITHIN 30 BAYS. PAYMENT 000.00 PLEASE INCLUDE INVOICE # ON YOUR CHECK. *THANK YOU FOR YOUR BUSINESS! LED Multiservions LLC. ee ‘Bie LER 1970 B. Ospeola Phwy Sui: 328 seiy A ‘Kssummeo, 61. 34743 17-25 7-990 isdmiuliiservices.tl msiLecm BLLTO Jimmy Sanchez Pasramore Construction 1627 Past Vine ST bs) mr sa Suite 201 Kissimmee, PL 34744 LOsoh Fy ycRE TZ AES Lae Lae ET PRES mE a us Fi SewEt 01/13/2019 Paint Service:Lebor 9 150.00 1,350.00 Installed 9 roof access doors on hallways ceiling area. Labor Only PAYMENT [8 DUE WITHIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK, ESP) *TEANK YOU FOR YOUR BUSINESS! LED Multiscavioas LLC. TE 1970 B. Osceola Pkwy Suite 328 ii wines HE Kissimmee, FL 34743 ee 407-257-0990 Indmultiservices eo emaiLcom BILL TC bi Jimmy Sanchez Parramore Cousiruction 1627 East Vine 8T * i Suite 201 Kissimnice, PF}. 34744 Wi Tele ony ES [Xe a Ousyy 01/14/2019 Paint ServicedLabor 4 250.00 1,000.00 Installed 4 Pocket doors *Open area in order to install door. *Installation Only *No Drywall work after installation PAYMENT [S DUE WITUIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK. “THANK YOU FOR YOUR BUSINESSI ERD Muliisorvices LLO. 1970 E. Csceola Pkwy Suite 325 Beaters: Kissimmee, FL 34743 Fone? 407-257-0990 Indmultiservices.tle@ gmail com Yi BELL TO Jimny Sanchez Parremose Construction 1627 East Vine ST Sr ey Suite 201 Kissimmee, PL 34744 HO)SEND IN she nm cae eee mama ao nem a Es 02/04/2019 4 300.00 4200.00 BASE BOARDS / DOORS INSTALLATION “partial payment from original project units100 unit* Still Pending only 4 units and the gym arca (we are waiting for the OK to complete) PAYMENT IS DUE WITHIN 36 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK. ny eA SHANK YOU FOR YOUK BUSINESS: LRD Multiserviess LLC. Bs LAD 1970 E. Osceola Pkwy Suite 328 HiuteSerwees NO Kissimmee, FL 34743 - 407-257-0990 Indmultiservices.le:pmasLeont BILL TO PLD Jinamy Sanchez Parramore Constroction 1627 East Vine ST EL Suite 201 Kissimmee, FL 34744 ete) rere 02/04/2019 Labor 36 25.00 900.00 RANGE HOODS INSTALLATION *Partial invoice from 100 units* Still pending 44 unitsto be completed (as soon as material are available) PAYMENT JS DUE WITHIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK. Tt) "THANK YOU FOR YOUR BUSINESS! cn 1970 E, Osceola Plawy Suite 328 ea eestions WP Kissimmen, FL. 34743 A0T, fedtani vices Ne@pmailcons BILL TO Jimmy Sanchez Parramore Construction 1627 East Vine ST Wet re) Suite 201, Kissimmes, FL 34744 esp EWU CRUE ny popes REE rn aOR Get SURED ny 02/04/2019 Lebor 16 75.00 1,200.00 CLOSET SHELVES INSTALLATION * Partial invoice of 16 unit from 106 units (still pending 44 to be completed as soon as material is available) PAYMENT IS DUE WITHIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR C1 HECK. oe a a “THANE YOU FOR YOUR BUSINESS! ‘LAD Maitiserviess TLC. Lae 1976 E. Osceata Pkwy Suite 324 Beh eericas 1 kissimmee, PL 34753 eae (0990 Iedenul vices llei@lgaiail.com BILLTO Wy Jimmy Sanchez Parramore Construction 1627 East Vive ST oS= Ce Surte 261 | Kissuamee, FL 34744 YX AOE 3 02/04/2019 20 80.00 1,600.00 DOOR NOBS INSTALLATION *Partial invoice of 20 units from 100 units, still pending 44 units (to be completed as soo as material are available) PAYMENTS IS DUB WITHIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK, “THANK YOU POR YOUR BUSINESS! pone, LRD TLL. #8&& 1B 1970 E, Osceola Plowy Suite 228 yi kissizamee, FL 34743 er AN7-257-00590 Ldinulticerviows cGigmeit.com BILL TO Jimmy Sanchez. Parramore Construction 1627 East Vine ST LSBU VeLY Suite 203 Kissimmee, FL. 34744 erage por a Te gst 02/04/2019 Labor 36 120.00 4,320.00 WINDOW BLINDS INSTALLATION *Partial invoice of 36 units out of 100, still pending 44 unit to complete the job. (we are waiting for materials to be available) PAYMENT JS DUE WITHIN 30 DAYS. PLEASE INCLUDE INVOICE # ON YOUR CHECK. is Uo “THANK YOU ‘YUUK BUSINESS! ‘LRD Mubiserviees LLC. 1970E. Osceola Pkwy & 32 Baki Sercives te kissiramee, FL 34743 AQ7-257-0990 Jedmutisorvices licgmail.cem BLL TO Jinamy Sanchez Parramore Construction a 1627 Easi Vine ST SDs. ee Suite 201 ‘Kissimmee, FL 34744 PONT i eee ; Sy 02/12/2019 MATERIALS 2,526.68 2526.68 ~ ee Paint, - = meet a nee. ae a 02/12/2019 MATERIALS 1 144.48 144,48 eee _Paint a en we re —— - 02/12/2019 M