Preview
Filing # 192155855 E-Filed 02/16/2024 03:48:29 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
Ally Bank
Vv. Case No:
Cameron C, Sohl
Defendant(s). —
VERIFIED COMPLAINT FOR REPLEVIN AND DAMAGES
The Plaintiff, Ally Bank (“Plaintiff"), sues the Defendant, Cameron C. Sohl (“Defendant”),
and states:
PARTIES AND VENUE
1 Venue for this action is appropriate in Hillsborough County since Defendant resides
in Hillsborough County and the property sought to be replevied is located in Hillsborough County.
GENERAL ALLEGATIONS
2 On or about November 23, 2021, Defendant Cameron C. Sohl (“Defendant
Borrower”) entered into a Retail Installment Contract and Security Agreement (the “Contract”) for
the purchase of a 2021 Dodge Charger (VIN No: 2C3CDXL96MH630163) (the “Vehicle”). A
copy of the Contract is attached hereto as Exhibit “A” and incorporated herein by reference.
3. The Contract was subsequently assigned to the Plaintiff. A copy of the assignment
is attached hereto as Exhibit “B” and incorporated herein by reference.
4 Ally Financial Inc. acts as collateral agent for Plaintiff pursuant to a Limited Power
of Attorney and, therefore, appears as lienholder of record for the Plaintiff's benefit. A copy of
the Limited Power of Attorney and Certificate of Title are attached hereto as Exhibits “C” and
“D”, respectively and incorporated herein by reference.
5 The Plaintiff owns and holds the Contract.
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6. Under the terms of the Contract, Defendant Borrower was required to make
monthly payments each in the amount of $1,411.25.
7 Defendant defaulted on one or more payments due.
8 The Defendant purchased and has possession of the Vehicle subject to a security
interest in favor of the Plaintiff.
9. Defendant failed to cure the default or relinquish possession of the Vehicle.
COUNT I
REPLEVIN OF PROPERTY
10. This is a cause of action under Florida Statutes Chapter 78 for replevin of property
having a value which exceeds $50,000.00, exclusive of interest.
11. Plaintiff repeats and incorporates the allegations contained in paragraphs | through
9 above as if same were more fully set forth herein.
12, As set forth above, the description of the property sought to be replevied is: 2021
Dodge Charger (VIN No: 2C3CDXL96MH630163) (“the Vehicle”).
13, To the best of Plaintiff's knowledge, information and belief, the value of the Vehicle
is $73,450.00.
14, Plaintiff is entitled to possession of the Vehicle under the Contract.
15. The Vehicle which is the subject of this action is believed to be in the possession
of the Defendant. Defendant’s address is 406 Down Pine Dr, Seffner, FL 33584-3719.
16. Defendant is unlawfully detaining and possessing the Vehicle contrary to the rights
of Plaintiff. As a result of the default under the Contract and the Plaintiff's security interest in the
Vehicle, Plaintiff is entitled to possession of the Vehicle.
17. The Vehicle has not been taken for any tax assessment of fine pursuant to law.
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18. The Vehicle has not been taken under any execution of attachment against Plaintiff
or Defendant.
19, All conditions precedent to the relief requested have occurred or have been waived.
WHEREFORE, Plaintiff demands that the court:
(1) enter a Replevin Order to Show Cause directing that Defendants show cause as to why
the Vehicle should not be immediately taken from their possession and delivered to
Plaintiff pursuant to Florida Statutes § 78.065;
(2) adjudicate that Plaintiff is entitled to take possession of the Vehicle pursuant to Florida
Statutes § 78.067;
3) enter an order directing that the Clerk of Court issue a Writ of Replevin commanding
that the Sheriff replevy the Vehicle from Defendant and deliver possession of same to
Plaintiff pursuant to Florida Statutes § 78.067;
4) enter judgment in favor of Plaintiff and against Defendant for replevin and the costs
Plaintiff has incurred in connection with this matter; and
(5) grant such other and further relief as the court deems just and proper.
COUNT IT
BREACH OF CONTRACT
20. This is a cause of action for damages which exceeds $50,000.00, exclusive of
interest.
21. Plaintiff repeats and incorporates the allegations contained in paragraphs | through
9 above as if same were more fully set forth herein.
22. As set forth above, Plaintiff and Defendant entered into a valid and enforceable
Contract.
23. Defendant breached the Contract by failing to make the payments required
thereunder.
24. As a result of Defendant's breach of contract, Plaintiff has suffered damages.
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25. As of December 12, 2023, there is now due and owing from the Defendant to the
Plaintiff the amount of $81,768.40, together with interest charges, late charges and costs.
26. All conditions precedent to the institution of this action have occurred, been met or
otherwise been waived.
WHEREFORE, Plaintiff requests that the court enter judgment against Defendant, in the
amount of $81,768.40, together with interest charges, late charges, and such other and further
relief as the court deems just and proper.
Dated: _ 2/15/2024
LOGS Legal Group LLP
Attorneys for the Plaintiff
750 Park of Commerce Blvd., Suite 130
Boca Raton, PL 33487
(813) 880-8888 (phone)
(813) 880-8800 (fax)
By: /s/ Jennifer Kopf, Esq. / FL Bar #50949
Patoowhay
POX BOOMKIKKAIKK
PRAGRAIRNGOM jkopf@logs.com
Pursuant to the Fair Debt Collection Practices Act, you are advised that this office may be
deemed a debt collector and any information obtained may be used for that purpose.
[VERIFICATION ON NEXT PAGE]
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VERIFICATION
1, JAMES SINGLETON. as AUTHORIZED REPRESENTATIVE of the Plaintiff,
Ally Bank, state the following
a) I have read this Verified Complaint for Replevin and Damages.
b) I have personal knowledge of the factual matters set forth herein; and
c) the allegations set forth herein are true and accurate
f=
STATE OF FLORIDA
HS
COUNTY OF DUVAL
The foregoing instrument was acknowledged before me on February ) 2024, by
JAMES SINGLETON, as AUTHORIZED REPRESENTATIVE of Ally Bank, who is
Personally knoviipto me or has produced as identification.
CHERYL L. ROBINSON CQOOO
Pe)
CANS tS Sy.5
ee. Notary Public
E: State of Florida practi jotary Public)
com =
THES
Commi HH210605
Expires 12/21/2025 LL. LNSOn
(Printed Name of Notary Public)
Notary Public, State of . a
Commission No.
My commission expires: IAS.
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7505764576-DP505764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC.
53-FL-ARB-ea "
Exhibit *
RETAIL INSTALLMENT SALE CONTRACT — SIMPLE FINANCE CHARGE
{WITH ARBITRATION PROVISION)
Buyer Name and Address Co-Buyer Name and Address Seller - Creditor (Name and Address)
CAMERON C SOHL NIA Tampa J Automotive Management LLC
745 SPANISH MAIN IR 2966 N Dale Mabry Hwy
Apoilo Beach, FL 33572 HILLSBOROUGH Tampa, FL 33607
Buyer's Birth Month: Co-Buyer's Birth Month: N/A
You, the Buyer (and Co-Buyer, if any), may buy the vehicle below for cash or on credit, By signing this contract, you choose to buy the vehicle
‘on credit under the agreements in this contract. You agree to pay the Seller-Creditor (sometimes “we” or “us” in this contract) the Amount Financed and
Finance Chai ge in U.S. funds according to the payment schedule below. We will figure your finance charge on a daily basis at the Base Rate of
9.04 ‘% per year. The Truth-In-Lending Disclosures below are part of this contract.
You have thoroughly inspected, accepted, and approved the vehicle in all respects.
New/Used/ Weight
Demo Year Make and Model (lbs.) Vehicle Identification Number Primary Use For Which Purchased
Personal, family, or household unless
otherwise indicated below
New 2021 Dadge Charger NIA 2C3CDXL96MH630163 O business
Cl agricultural Oo NA,
You agree that we advised you whether, based on seller's knowledge, the vehicle was titled, registered, or used as a taxicab, police vehicle, short term rental or is
@ Vehicle that is rebuilt or assembled from parts, a kit car, a replica, a flood vehicle, or a manufacturer buy back,
retihce
FEDERAL TRUTH-IN-LENDING DISCLOSURES WARRANTIES SELLER DISCLAIMS
FINANCE Amount Total of roel isale Unless the Seller makes a written warranty, or
CHARGE Financed Payments
The dollar The amount of The amount you The total cost of
enters into a service contract within 90 days
‘The cost of amount the credit provided will have paid after your purchase on from the date of this contract, the Seller makes
your credit as credit will to qu OF you have made all credit, including no warranties, express or implied, on the
a yearly rate. cost you. ‘on your behalf. payments as your down vehicle, and there will be no implied warranties
scheduled. payment of ‘of merchantability or of fitness for a particular
2,046.07 is| purpose.
9.04 L$ 31,266.49 $ 87,278.51 $ 118,545.00 $ 120,591.07
This provision does not affect any warranties
Your Payment Schedule Will Be: {e) means an estimate covering the vehicle that the vehicle manufacturer
Number of Amountof ‘When Payments may provide.
Payments Payments jue
84 $ 1,411.25 Monthly beginning 91/09/2022 Returned Payment Charge: If any checkor other payment instrument you
give us is dishonored or any electronic payment you meke is returned
NIA NIA NIA ‘unpaid, you wil pay a charge of $25 if the payment amount is $50 of less;
$30 if the payment amount is over $50 but not more than $300; $40 if the
Or As Follows: ‘payment amiountis over $300; of such amount as permitted by law,
NIA Florida documentary stamp tax required by law in the amount of |
$. 305.55 has been paid or will be paid |&
Late Charge. If payment is not received in full within __ 10 days after it is due, you will pay a late charge directly to the Departmentof Revenue,
of 5_% of each installment. Certificate of Registration No, 22800397264, 7-c013166800.5,
Prepayment. If you pay early, you may have to pay a penalty.
Security Interest. You are giving a security interest in the vehicle being purchased. You assign all manufacturer rebates and cash back
incentives used as a downpayment on this contract to seller.
Additional Information: See this contract for more information including information about nonpayment,
You agree to complete all documents required for assignment
default, prepayment penalties, any required repayment in full before the scheduled date and security interest. of rebates and incentives.
Electronic Contracting and Signature Acknowledgment. You agree that (i) this contract is an electronic contract executed by
you using your electronic signature, (ii) your electronic signature signifies your intent to enter into this contract and that this
contract be legally valid and enforceable in accordance with its terms to the same extent as if you had executed this contract using
your written signature and (iii) the authoritative copy of this contract ("Authoritative Copy") shail be that electronic copy that resides
in a document management system designated by us for the storage of authoritative copies of electronic records, which shall be
deemed held by us in the ordinary course of business. Notwithstanding the foregoing, if the Authoritative Copy is converted by printing
a paper copy which is marked by us as the original (the "Paper Contract”), then you acknowledge and agree that (1) your signing of
this contract with your electronic signature also constitutes issuance and delivery of such Paper Contract, (2) your electronic signature
associated with this contract, when affixed to the Paper Contract, constitutes your legally valid and binding signature on the Paper
Contract and (3) subsequent to such conversion, your obligations will be evidenced by the Paper Contract alone.
LAW 553-FL-ARB-ea 9/19 vt Page 1 of 6
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2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 6
1509764576-DP505764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC.
ITEMIZATION OF AMOUNT FINANCED Used Car Buyers Guide. The information you
4. Cash Price (including $ 929.04 sales tax) $. 82, 3.01 (4) see on the window form for this vehicle is
2. Total Downpayment = part of this contract. Information on the
Gross Trade-In Allowance 69. 00 window form overrides any contrary
Lass Pay Off Made By Seller (e) 78,320.98 provisions in the contract of sale.
Equals Net Trade In 9,320.98
Spanish Translation: Guia para
compradores de vehiculos usados. La
+Cash 9,367.05
informacién que ve en el formulario de la
+ Other N/A NIA ventanilla para este vehiculo forma parte del
+ Other Rebates 2,000.00 presente contrato. La informacién del
(if totat downpayment is negative, enter “0” and see 8J below) 07 formulario de la ventanilla deja sin efecto
3 Unpaid Balance of Cash Price (4 minus 2) 80,726.94 (5) toda disposicién en contrario contenida en
4 Predelivery Service Fees el contrato de venta.
A Predelvery Service Charge 999,99
B Electronic Registration Filing Fee 199. OPTIONAL SERVICE CONTRACTS
¢ NU NIA You are not required to buy a service contract to
obtain credit. Your choice of service contract
These charges represent costs and profit to the dealer for items such as inspecting, providers for any service contracts you buy will
cleaning, and adjusting vehicles, and preparing documents related to the sale. not affect our decision to sell or extend credit to
Total Pradelivery Service Fees 18.99 (@) you.
5 Other Charges Including Amounts Paid to Others on Your Behalf
{Sellar may keep part of these amounts): REJECTION OR REVOCATION
‘A. Cost of Optional Credit Insurance Paid to Insurance Company or Companies. If you are permitted under Florida’s Uniform
NIA Commercial Code to reject or revoke
Disability § NIA NIA acceptance of the vehicle and you claim az
B _Verdar’s Single interest Insurance Paid to Insurance Company N/A
security interest in the vehicle because of this,
you must either: (a) post a bond in the amount 2
G Other Optional insurance Paid to Insurance Compzny or Companies NIA
of the disputed balance; or (b) deposit all>
o Optional Gap Contract 1,000.00 installment payments as they become due into 2
E Official Fees Paid to Goverment Agencies 8.50 the registry of a court of competent jurisdiction. $
FE Government Documentary Stamp Taxes a
5 305.55
G Government Taxes Not Included in Cash Price 263.18 SERVICING AND COLLECTION CONTACTS £
H Goverment License and/or Registration Fees You agree that we may try to contact you ink,
License and Registration Fee 266,35 writing, by e-mail, or using pre recorded/artificial &
Government Certificate of Title Fees NIA voice messages, text messages, and automatic 3
Other Charges (Seller must identify who is paid and describe purpose) telephone dialing systems, as the law allows. 2
toTD AUTO
You also agree that we may try to contact you in €
for Prior Creditor Lease Balance (e) NIA
these and other ways at any address or$
toFIDELITY for Service Contract 2,582.00 telephone number you provide us, even if the 2
toFIDELITY for Tire & Wheel 927.00 telephone number is a cell phone number or the
toN/A. for N/A
toN/A for WA
NYA
NIA
contact results in a charge to you.
3=
toN/A. for NIA APPLICABLE LAW z5
NIA
toN/A for N/A. NA Federal law and the law of the state of Florida a
8
toN/A
toN/A
for N/A
for N/A
NA apply to this contract.
3
NIA
toN/A for N/A. NIA
Total Other Charges and Amounts Paid to Others on Your Behalf 5,352.58 (5)
6 Loan Processing Fee Paid to Seller (Prepaid Finance Charge) NIA(6;
7 Amount Financed (3 plus 4plus ) 87,278.51 (7)
[ OPTION: [1 Youpay no finance charge if the Amount Financed, item 7, is paid in full on or before. NA ‘Year. NIA SELLER'S INTIS N/A |
OPTIONAL GAP CONTRACT. A gap contract ( cancellation contract) is not required to obtain credit and will not be provided unless sign below and agree
fo pay the extra charge. If you choose to buy a contract, the charge is shown in Item 5D of the Itemization of Amount Financed. jee your gap contract for
details on the terms and conditions it provides. It is a part of this contract.
Term 84 Mos. CARCO GAP
Name of Gap Contract
t want to buy a gap contract.
-
Buyer Signs X
NO COOLING OFF PERIOD
State law does not provide for a “cooling off” or cancellation period for this sale. After you sign this contract,
you may only cancel it if the seller agrees or for legal cause. You cannot cancel this contract simply because
you change your mind. This notice does not apply to home solicitation sales.
Agreement to Arbitrate: By signing below, you agree that, pursuant fo the Arbitration Provision on page 5 of this contract, you or we may elect to resolve any
dispute by neutral, binding arbitration and not by a court action. See the Arbitration Provision for additional information concernint afr eareement fo arbitrate.
Buyer Signs X Co-Buyer Signs X B
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7505764576-DP505764579_- THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELO BY ROUTEONE LLC.
Ingurance. You may buy the physical damage insurance this contract equires from anyone you choose whois acceptable to us. You may also provide the physical damage Insurance through
an existing policy owned or controiied by you thatis acce| ptable to us. You are not required to buy any other insurance to obtain credit unless the box indicating Vendor's Single interest
Insurance
is required is checked below. Your choice of insurance providers will not affect our decision to sell you the vehicle or extend credit fo you.
lf any insurance is checked below, policies or certificates from the named insurance companies will describe the terms and conditions,
Check the insurance you want and sign below:
Optional Credit Insurance
DB Crest Lite: CO Buyer (_} Co-Buyer _, Both LL] Credit Disabitty: [71 Buyer [EF Co-Buyer {|} Both
Term N/A Term NIA
Premium: Credit Life ¢ NA Credit Disabitity 5 N/A _
Insurance Company Name N/A. Home Office Address N/A
Credit life insurance and credit disability insurance are not re quired to obtain credit, Your decision to buy
approval process. They will not be arovid fed unless you sign and agree to pay the extra cost. If you chooseor thisnot insurance,
fo buy credit life insurance and credit disabllty insurance will not be a factor in the credit
1 original paymi rent schedule. This insurance may not payal you owe on this contract if you make thelate costpayments,
is shown in Item 5A of the ltemization of Amount Financed, Credit Ife
Credit cisablily insurance does
payment orn the ram ber of payments,
insurance is based on
not caver any Increase in your
f the box abave is checkes to indicate that you want credit life i insurance,
1. You understand that you have the option of a ssigning any elher policy orplease read and sign the folowing acknowledgments:
pocies you own or may procure fer the purpose of covering this extension of credit and that the policy need not be purchased
from us in order to obtain the extension of credit. l
x¢ NIA NIA x N/A NIA
Buyer Data Co.Buyer Date
2. You understand that the credit life coverage may be deferred iif,f , atthe time of application, you are unable to engage Fi employment or unable to perform normal acivties of a person of ike age and
sex. (You need not sign this acknowledgement if the proposed credit life insurance policy does not contain this restriction.
xD N/A NIA xD. NIA NIA
Buyer Date Co-Buyer Date
3. You understand thatthe benefits under the polcy will terminate when you reach a certain age and affirm that your age is accurataly represented on the application or poy.
xE NIA NIA xE N/A Ni
8 Baer Date Co-Buyer Date
Other Optional Insurance
NA NIA Premium § NIA
Type of Insurance Term
Insurance Company Name & Address
NIA
Oo NIA NIA Premium § N/A
‘Type of Insurance Term
i Insurance Company Name & Address
3] NIA
go NIA NWA Premium $ N/A
‘Type of Insurance: Term
8} insurance Company Name & Address
— NIA
Oo NA NIA Premium ¢ N/A.
Type of Insurance Term
Insurance Company Name & Address
N/A
o NIA N/A Premium $ N/A.
Type of Insurance Term
Insurance Company Name & Address
NA
Other optional insurance is not required te obtain credit. Your decision to buy or not ouy other optional insurance will note @ factor in the credit approval process, It will not be provided unless you sign
and agree to pay the extra cost.
| want the insurance checked above.
XF N/A N/A XF N/A N/A
Buyer Signature Date Co Buyer Signature Date
LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS NOT INCLUDED IN THIS CONTRACT.
(VENDOR'S SINGLE INTEREST INSURANCE (VSI insurance): if the preceding box is checked, the Creditor requires VSI insurance for the initial term of the contract to
protect the Creditor for loss or damage to the vehicle (collision, fire, theft, concealment, skip). VSI insurance is for the Creditor’s sole protection. This insurance does not protect
your interest in the vehicle, You may choose the insurance company through which the VSI insurance is obtained. If you elect to purchase VSI insurance through the
Creditor, the cost of this insurance is $ N/A, and is also shown in item 5B ot the itemization of Amount Financed. The coverage is for the initial term of the
contract,
You authorize us to purchase Vendor's or Lender's Single Interest Insurance.
Buyer SignsX G NIA Co-Buyer Signs X G NIA te: NIA
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1§764576-DPS0S764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC.
OTHER IMPORTANT AGREEMENTS
1. ete CHARGE AND PAYMENTS we may, if we choose, buy physical damage insurance. if we decide to buy
How we will figure Finance Charge, We will treat any PrepaidFinance physical damage insurance, we may either buy insurance that covers your
Charge as fully earned on the date of this contract. We will figure the rest interest and our interest in the vehicle, or buy insurance that covers only our
of the finance charge on a daily basis at the Base Rate on the unpaid part interest. If we buy either type of insurance, we wilt tell you which type and the
of your Principal Balance. Your Principal Balance is the sum of the Amount charge you must pay. The charge will be the premium for the insurance and
Financed and the Prepaid Finance Charge, if any. a finance charge at ihe highest rate the law permits. If the vehicle is lost or
How we will apply payments, We may apply each payment to the earned damaged, you agree that we may use any insurance settlement to reduce
and unpaid part of the Finance Charge, to the unpaid part of your Principal what you owe or repair the vehicle.
Balance and to other amounts you owe under this contract in any order we What happens to returned insurance, maintenance, service, or other
choose as the law allows. contract charges. If we obtain a refund of insurance, maintenance, service,
How late payments or early payments change what you must pay. We or other contract charges, you agree that we may subtract the refund from
based the Finance Charge, Total of Payments, and Tota! Sale Price shown what you owe.
on page 1 of this contract on the assumption that you will make every
payment on the day itis due. Your Finance Charge, Total of Payments, and 3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES
Total Sale Price will be more if you pay late and less if you pay early. a. You may owe late charges, You will pay a late charge on each late payment
Changes may take the form of a larger or smaller final payment or, at our as shown on page 1 of this contract. Acceptance of a late payment or late
option, more or fewer payments of the same amount as your scheduled charge does not excuse your late payment or mean that you may keep making
payment with a smaller final payment. We will send you a notice telling you late payments.
about these changes before the final scheduled payment is due. Ifyou pay late, we may also take the steps described below.
dq You may prepay. You may prepay all or part of your Principal Balance at b. ‘You may have to pay all you owe al once. If you break your promises
any time, If the contract is paid in full within six months aiter the date you (default), we may demand that you pay all you owe on this contract at once.
sign it, we may impose an acquisition charge, not exceeding $75, for Default means:
services performed on your behalf for processing this contract. If you . You do not pay any payment on time:
prepay, you must pay the earned and unpaid part of the Finance Charge . You give false, incomplete, or misleading information during edits
and all other amounts due up to the date of your payment. application;
e, You may ask for a payment extension. You may ask us for a deferral of You start 2 proceeding in bankruptcy or one is started against you oz
the scheduled due date of all or any partof a payment (extension). If we agree your property,or
to your request, wa may charge you a $15 extension fee. You must maintain . You break any agreements in this contract.
the physical damage insurance required by this contract (see 2.d.) during any The amount you will owe will be the unpaid partof your Principal Balance plus: 3a
extension. If you do not have this insurance, we may buyit and charge you for the earned and unpaid partof the Finance Charge, any late charges, and anys
itas this contract says. You may extend the term of any optional insurance
you amounts due because you defaulted,
bought with this contract to cover the extension if the insurance company or You may have to pay colle
Preview
Filing # 192155855 E-Filed 02/16/2024 03:48:29 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA Ally Bank Vv. Case No: Cameron C, Sohl Defendant(s). — VERIFIED COMPLAINT FOR REPLEVIN AND DAMAGES The Plaintiff, Ally Bank (“Plaintiff"), sues the Defendant, Cameron C. Sohl (“Defendant”), and states: PARTIES AND VENUE 1 Venue for this action is appropriate in Hillsborough County since Defendant resides in Hillsborough County and the property sought to be replevied is located in Hillsborough County. GENERAL ALLEGATIONS 2 On or about November 23, 2021, Defendant Cameron C. Sohl (“Defendant Borrower”) entered into a Retail Installment Contract and Security Agreement (the “Contract”) for the purchase of a 2021 Dodge Charger (VIN No: 2C3CDXL96MH630163) (the “Vehicle”). A copy of the Contract is attached hereto as Exhibit “A” and incorporated herein by reference. 3. The Contract was subsequently assigned to the Plaintiff. A copy of the assignment is attached hereto as Exhibit “B” and incorporated herein by reference. 4 Ally Financial Inc. acts as collateral agent for Plaintiff pursuant to a Limited Power of Attorney and, therefore, appears as lienholder of record for the Plaintiff's benefit. A copy of the Limited Power of Attorney and Certificate of Title are attached hereto as Exhibits “C” and “D”, respectively and incorporated herein by reference. 5 The Plaintiff owns and holds the Contract. LLG# 23-330541 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 1 6. Under the terms of the Contract, Defendant Borrower was required to make monthly payments each in the amount of $1,411.25. 7 Defendant defaulted on one or more payments due. 8 The Defendant purchased and has possession of the Vehicle subject to a security interest in favor of the Plaintiff. 9. Defendant failed to cure the default or relinquish possession of the Vehicle. COUNT I REPLEVIN OF PROPERTY 10. This is a cause of action under Florida Statutes Chapter 78 for replevin of property having a value which exceeds $50,000.00, exclusive of interest. 11. Plaintiff repeats and incorporates the allegations contained in paragraphs | through 9 above as if same were more fully set forth herein. 12, As set forth above, the description of the property sought to be replevied is: 2021 Dodge Charger (VIN No: 2C3CDXL96MH630163) (“the Vehicle”). 13, To the best of Plaintiff's knowledge, information and belief, the value of the Vehicle is $73,450.00. 14, Plaintiff is entitled to possession of the Vehicle under the Contract. 15. The Vehicle which is the subject of this action is believed to be in the possession of the Defendant. Defendant’s address is 406 Down Pine Dr, Seffner, FL 33584-3719. 16. Defendant is unlawfully detaining and possessing the Vehicle contrary to the rights of Plaintiff. As a result of the default under the Contract and the Plaintiff's security interest in the Vehicle, Plaintiff is entitled to possession of the Vehicle. 17. The Vehicle has not been taken for any tax assessment of fine pursuant to law. LLG# 23-330541 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 2 18. The Vehicle has not been taken under any execution of attachment against Plaintiff or Defendant. 19, All conditions precedent to the relief requested have occurred or have been waived. WHEREFORE, Plaintiff demands that the court: (1) enter a Replevin Order to Show Cause directing that Defendants show cause as to why the Vehicle should not be immediately taken from their possession and delivered to Plaintiff pursuant to Florida Statutes § 78.065; (2) adjudicate that Plaintiff is entitled to take possession of the Vehicle pursuant to Florida Statutes § 78.067; 3) enter an order directing that the Clerk of Court issue a Writ of Replevin commanding that the Sheriff replevy the Vehicle from Defendant and deliver possession of same to Plaintiff pursuant to Florida Statutes § 78.067; 4) enter judgment in favor of Plaintiff and against Defendant for replevin and the costs Plaintiff has incurred in connection with this matter; and (5) grant such other and further relief as the court deems just and proper. COUNT IT BREACH OF CONTRACT 20. This is a cause of action for damages which exceeds $50,000.00, exclusive of interest. 21. Plaintiff repeats and incorporates the allegations contained in paragraphs | through 9 above as if same were more fully set forth herein. 22. As set forth above, Plaintiff and Defendant entered into a valid and enforceable Contract. 23. Defendant breached the Contract by failing to make the payments required thereunder. 24. As a result of Defendant's breach of contract, Plaintiff has suffered damages. LLG# 23-330541 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 3 25. As of December 12, 2023, there is now due and owing from the Defendant to the Plaintiff the amount of $81,768.40, together with interest charges, late charges and costs. 26. All conditions precedent to the institution of this action have occurred, been met or otherwise been waived. WHEREFORE, Plaintiff requests that the court enter judgment against Defendant, in the amount of $81,768.40, together with interest charges, late charges, and such other and further relief as the court deems just and proper. Dated: _ 2/15/2024 LOGS Legal Group LLP Attorneys for the Plaintiff 750 Park of Commerce Blvd., Suite 130 Boca Raton, PL 33487 (813) 880-8888 (phone) (813) 880-8800 (fax) By: /s/ Jennifer Kopf, Esq. / FL Bar #50949 Patoowhay POX BOOMKIKKAIKK PRAGRAIRNGOM jkopf@logs.com Pursuant to the Fair Debt Collection Practices Act, you are advised that this office may be deemed a debt collector and any information obtained may be used for that purpose. [VERIFICATION ON NEXT PAGE] LLG# 23-330541 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 4 VERIFICATION 1, JAMES SINGLETON. as AUTHORIZED REPRESENTATIVE of the Plaintiff, Ally Bank, state the following a) I have read this Verified Complaint for Replevin and Damages. b) I have personal knowledge of the factual matters set forth herein; and c) the allegations set forth herein are true and accurate f= STATE OF FLORIDA HS COUNTY OF DUVAL The foregoing instrument was acknowledged before me on February ) 2024, by JAMES SINGLETON, as AUTHORIZED REPRESENTATIVE of Ally Bank, who is Personally knoviipto me or has produced as identification. CHERYL L. ROBINSON CQOOO Pe) CANS tS Sy.5 ee. Notary Public E: State of Florida practi jotary Public) com = THES Commi HH210605 Expires 12/21/2025 LL. LNSOn (Printed Name of Notary Public) Notary Public, State of . a Commission No. My commission expires: IAS. LLG# 23-330541 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 5 7505764576-DP505764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC. 53-FL-ARB-ea " Exhibit * RETAIL INSTALLMENT SALE CONTRACT — SIMPLE FINANCE CHARGE {WITH ARBITRATION PROVISION) Buyer Name and Address Co-Buyer Name and Address Seller - Creditor (Name and Address) CAMERON C SOHL NIA Tampa J Automotive Management LLC 745 SPANISH MAIN IR 2966 N Dale Mabry Hwy Apoilo Beach, FL 33572 HILLSBOROUGH Tampa, FL 33607 Buyer's Birth Month: Co-Buyer's Birth Month: N/A You, the Buyer (and Co-Buyer, if any), may buy the vehicle below for cash or on credit, By signing this contract, you choose to buy the vehicle ‘on credit under the agreements in this contract. You agree to pay the Seller-Creditor (sometimes “we” or “us” in this contract) the Amount Financed and Finance Chai ge in U.S. funds according to the payment schedule below. We will figure your finance charge on a daily basis at the Base Rate of 9.04 ‘% per year. The Truth-In-Lending Disclosures below are part of this contract. You have thoroughly inspected, accepted, and approved the vehicle in all respects. New/Used/ Weight Demo Year Make and Model (lbs.) Vehicle Identification Number Primary Use For Which Purchased Personal, family, or household unless otherwise indicated below New 2021 Dadge Charger NIA 2C3CDXL96MH630163 O business Cl agricultural Oo NA, You agree that we advised you whether, based on seller's knowledge, the vehicle was titled, registered, or used as a taxicab, police vehicle, short term rental or is @ Vehicle that is rebuilt or assembled from parts, a kit car, a replica, a flood vehicle, or a manufacturer buy back, retihce FEDERAL TRUTH-IN-LENDING DISCLOSURES WARRANTIES SELLER DISCLAIMS FINANCE Amount Total of roel isale Unless the Seller makes a written warranty, or CHARGE Financed Payments The dollar The amount of The amount you The total cost of enters into a service contract within 90 days ‘The cost of amount the credit provided will have paid after your purchase on from the date of this contract, the Seller makes your credit as credit will to qu OF you have made all credit, including no warranties, express or implied, on the a yearly rate. cost you. ‘on your behalf. payments as your down vehicle, and there will be no implied warranties scheduled. payment of ‘of merchantability or of fitness for a particular 2,046.07 is| purpose. 9.04 L$ 31,266.49 $ 87,278.51 $ 118,545.00 $ 120,591.07 This provision does not affect any warranties Your Payment Schedule Will Be: {e) means an estimate covering the vehicle that the vehicle manufacturer Number of Amountof ‘When Payments may provide. Payments Payments jue 84 $ 1,411.25 Monthly beginning 91/09/2022 Returned Payment Charge: If any checkor other payment instrument you give us is dishonored or any electronic payment you meke is returned NIA NIA NIA ‘unpaid, you wil pay a charge of $25 if the payment amount is $50 of less; $30 if the payment amount is over $50 but not more than $300; $40 if the Or As Follows: ‘payment amiountis over $300; of such amount as permitted by law, NIA Florida documentary stamp tax required by law in the amount of | $. 305.55 has been paid or will be paid |& Late Charge. If payment is not received in full within __ 10 days after it is due, you will pay a late charge directly to the Departmentof Revenue, of 5_% of each installment. Certificate of Registration No, 22800397264, 7-c013166800.5, Prepayment. If you pay early, you may have to pay a penalty. Security Interest. You are giving a security interest in the vehicle being purchased. You assign all manufacturer rebates and cash back incentives used as a downpayment on this contract to seller. Additional Information: See this contract for more information including information about nonpayment, You agree to complete all documents required for assignment default, prepayment penalties, any required repayment in full before the scheduled date and security interest. of rebates and incentives. Electronic Contracting and Signature Acknowledgment. You agree that (i) this contract is an electronic contract executed by you using your electronic signature, (ii) your electronic signature signifies your intent to enter into this contract and that this contract be legally valid and enforceable in accordance with its terms to the same extent as if you had executed this contract using your written signature and (iii) the authoritative copy of this contract ("Authoritative Copy") shail be that electronic copy that resides in a document management system designated by us for the storage of authoritative copies of electronic records, which shall be deemed held by us in the ordinary course of business. Notwithstanding the foregoing, if the Authoritative Copy is converted by printing a paper copy which is marked by us as the original (the "Paper Contract”), then you acknowledge and agree that (1) your signing of this contract with your electronic signature also constitutes issuance and delivery of such Paper Contract, (2) your electronic signature associated with this contract, when affixed to the Paper Contract, constitutes your legally valid and binding signature on the Paper Contract and (3) subsequent to such conversion, your obligations will be evidenced by the Paper Contract alone. LAW 553-FL-ARB-ea 9/19 vt Page 1 of 6 ‘T505764576-DPS05764579 - THIS CUSTOMER COMPLETED COPY WAS CREATED ON 1112472021 02:07:59 PM GM 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 6 1509764576-DP505764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC. ITEMIZATION OF AMOUNT FINANCED Used Car Buyers Guide. The information you 4. Cash Price (including $ 929.04 sales tax) $. 82, 3.01 (4) see on the window form for this vehicle is 2. Total Downpayment = part of this contract. Information on the Gross Trade-In Allowance 69. 00 window form overrides any contrary Lass Pay Off Made By Seller (e) 78,320.98 provisions in the contract of sale. Equals Net Trade In 9,320.98 Spanish Translation: Guia para compradores de vehiculos usados. La +Cash 9,367.05 informacién que ve en el formulario de la + Other N/A NIA ventanilla para este vehiculo forma parte del + Other Rebates 2,000.00 presente contrato. La informacién del (if totat downpayment is negative, enter “0” and see 8J below) 07 formulario de la ventanilla deja sin efecto 3 Unpaid Balance of Cash Price (4 minus 2) 80,726.94 (5) toda disposicién en contrario contenida en 4 Predelivery Service Fees el contrato de venta. A Predelvery Service Charge 999,99 B Electronic Registration Filing Fee 199. OPTIONAL SERVICE CONTRACTS ¢ NU NIA You are not required to buy a service contract to obtain credit. Your choice of service contract These charges represent costs and profit to the dealer for items such as inspecting, providers for any service contracts you buy will cleaning, and adjusting vehicles, and preparing documents related to the sale. not affect our decision to sell or extend credit to Total Pradelivery Service Fees 18.99 (@) you. 5 Other Charges Including Amounts Paid to Others on Your Behalf {Sellar may keep part of these amounts): REJECTION OR REVOCATION ‘A. Cost of Optional Credit Insurance Paid to Insurance Company or Companies. If you are permitted under Florida’s Uniform NIA Commercial Code to reject or revoke Disability § NIA NIA acceptance of the vehicle and you claim az B _Verdar’s Single interest Insurance Paid to Insurance Company N/A security interest in the vehicle because of this, you must either: (a) post a bond in the amount 2 G Other Optional insurance Paid to Insurance Compzny or Companies NIA of the disputed balance; or (b) deposit all> o Optional Gap Contract 1,000.00 installment payments as they become due into 2 E Official Fees Paid to Goverment Agencies 8.50 the registry of a court of competent jurisdiction. $ FE Government Documentary Stamp Taxes a 5 305.55 G Government Taxes Not Included in Cash Price 263.18 SERVICING AND COLLECTION CONTACTS £ H Goverment License and/or Registration Fees You agree that we may try to contact you ink, License and Registration Fee 266,35 writing, by e-mail, or using pre recorded/artificial & Government Certificate of Title Fees NIA voice messages, text messages, and automatic 3 Other Charges (Seller must identify who is paid and describe purpose) telephone dialing systems, as the law allows. 2 toTD AUTO You also agree that we may try to contact you in € for Prior Creditor Lease Balance (e) NIA these and other ways at any address or$ toFIDELITY for Service Contract 2,582.00 telephone number you provide us, even if the 2 toFIDELITY for Tire & Wheel 927.00 telephone number is a cell phone number or the toN/A. for N/A toN/A for WA NYA NIA contact results in a charge to you. 3= toN/A. for NIA APPLICABLE LAW z5 NIA toN/A for N/A. NA Federal law and the law of the state of Florida a 8 toN/A toN/A for N/A for N/A NA apply to this contract. 3 NIA toN/A for N/A. NIA Total Other Charges and Amounts Paid to Others on Your Behalf 5,352.58 (5) 6 Loan Processing Fee Paid to Seller (Prepaid Finance Charge) NIA(6; 7 Amount Financed (3 plus 4plus ) 87,278.51 (7) [ OPTION: [1 Youpay no finance charge if the Amount Financed, item 7, is paid in full on or before. NA ‘Year. NIA SELLER'S INTIS N/A | OPTIONAL GAP CONTRACT. A gap contract ( cancellation contract) is not required to obtain credit and will not be provided unless sign below and agree fo pay the extra charge. If you choose to buy a contract, the charge is shown in Item 5D of the Itemization of Amount Financed. jee your gap contract for details on the terms and conditions it provides. It is a part of this contract. Term 84 Mos. CARCO GAP Name of Gap Contract t want to buy a gap contract. - Buyer Signs X NO COOLING OFF PERIOD State law does not provide for a “cooling off” or cancellation period for this sale. After you sign this contract, you may only cancel it if the seller agrees or for legal cause. You cannot cancel this contract simply because you change your mind. This notice does not apply to home solicitation sales. Agreement to Arbitrate: By signing below, you agree that, pursuant fo the Arbitration Provision on page 5 of this contract, you or we may elect to resolve any dispute by neutral, binding arbitration and not by a court action. See the Arbitration Provision for additional information concernint afr eareement fo arbitrate. Buyer Signs X Co-Buyer Signs X B ‘1505764578-DP505764579 - THIS CUSTOMER COMPLETED COPY WAS CREATED ON 11/24/2021 02:07:89 PM GMT LAW 553-FL-ARB-ea 9/19 v1 Page 2 of 6 2/16/2024 3:48 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 7 7505764576-DP505764579_- THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELO BY ROUTEONE LLC. Ingurance. You may buy the physical damage insurance this contract equires from anyone you choose whois acceptable to us. You may also provide the physical damage Insurance through an existing policy owned or controiied by you thatis acce| ptable to us. You are not required to buy any other insurance to obtain credit unless the box indicating Vendor's Single interest Insurance is required is checked below. Your choice of insurance providers will not affect our decision to sell you the vehicle or extend credit fo you. lf any insurance is checked below, policies or certificates from the named insurance companies will describe the terms and conditions, Check the insurance you want and sign below: Optional Credit Insurance DB Crest Lite: CO Buyer (_} Co-Buyer _, Both LL] Credit Disabitty: [71 Buyer [EF Co-Buyer {|} Both Term N/A Term NIA Premium: Credit Life ¢ NA Credit Disabitity 5 N/A _ Insurance Company Name N/A. Home Office Address N/A Credit life insurance and credit disability insurance are not re quired to obtain credit, Your decision to buy approval process. They will not be arovid fed unless you sign and agree to pay the extra cost. If you chooseor thisnot insurance, fo buy credit life insurance and credit disabllty insurance will not be a factor in the credit 1 original paymi rent schedule. This insurance may not payal you owe on this contract if you make thelate costpayments, is shown in Item 5A of the ltemization of Amount Financed, Credit Ife Credit cisablily insurance does payment orn the ram ber of payments, insurance is based on not caver any Increase in your f the box abave is checkes to indicate that you want credit life i insurance, 1. You understand that you have the option of a ssigning any elher policy orplease read and sign the folowing acknowledgments: pocies you own or may procure fer the purpose of covering this extension of credit and that the policy need not be purchased from us in order to obtain the extension of credit. l x¢ NIA NIA x N/A NIA Buyer Data Co.Buyer Date 2. You understand that the credit life coverage may be deferred iif,f , atthe time of application, you are unable to engage Fi employment or unable to perform normal acivties of a person of ike age and sex. (You need not sign this acknowledgement if the proposed credit life insurance policy does not contain this restriction. xD N/A NIA xD. NIA NIA Buyer Date Co-Buyer Date 3. You understand thatthe benefits under the polcy will terminate when you reach a certain age and affirm that your age is accurataly represented on the application or poy. xE NIA NIA xE N/A Ni 8 Baer Date Co-Buyer Date Other Optional Insurance NA NIA Premium § NIA Type of Insurance Term Insurance Company Name & Address NIA Oo NIA NIA Premium § N/A ‘Type of Insurance Term i Insurance Company Name & Address 3] NIA go NIA NWA Premium $ N/A ‘Type of Insurance: Term 8} insurance Company Name & Address — NIA Oo NA NIA Premium ¢ N/A. Type of Insurance Term Insurance Company Name & Address N/A o NIA N/A Premium $ N/A. Type of Insurance Term Insurance Company Name & Address NA Other optional insurance is not required te obtain credit. Your decision to buy or not ouy other optional insurance will note @ factor in the credit approval process, It will not be provided unless you sign and agree to pay the extra cost. | want the insurance checked above. XF N/A N/A XF N/A N/A Buyer Signature Date Co Buyer Signature Date LIABILITY INSURANCE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS IS NOT INCLUDED IN THIS CONTRACT. (VENDOR'S SINGLE INTEREST INSURANCE (VSI insurance): if the preceding box is checked, the Creditor requires VSI insurance for the initial term of the contract to protect the Creditor for loss or damage to the vehicle (collision, fire, theft, concealment, skip). VSI insurance is for the Creditor’s sole protection. This insurance does not protect your interest in the vehicle, You may choose the insurance company through which the VSI insurance is obtained. If you elect to purchase VSI insurance through the Creditor, the cost of this insurance is $ N/A, and is also shown in item 5B ot the itemization of Amount Financed. The coverage is for the initial term of the contract, You authorize us to purchase Vendor's or Lender's Single Interest Insurance. Buyer SignsX G NIA Co-Buyer Signs X G NIA te: NIA LAW 553-FL-ARB-ea 9/19 vt Page 3 of 6 '7505764576-DP505764579 - THIS CUSTOMER COMPLETED COPY WAS CREATED ON 41/24/2021 02:07:59 PM GMT 2/16/2024 3:48 PM Electronically Filed: Hillsborough C ounty/13th J udicial Circuit Page 8 1§764576-DPS0S764579 - THIS IS A CUSTOMER COMPLETED COPY OF THE SIGNED ELECTRONIC FORM HELD BY ROUTEONE LLC. OTHER IMPORTANT AGREEMENTS 1. ete CHARGE AND PAYMENTS we may, if we choose, buy physical damage insurance. if we decide to buy How we will figure Finance Charge, We will treat any PrepaidFinance physical damage insurance, we may either buy insurance that covers your Charge as fully earned on the date of this contract. We will figure the rest interest and our interest in the vehicle, or buy insurance that covers only our of the finance charge on a daily basis at the Base Rate on the unpaid part interest. If we buy either type of insurance, we wilt tell you which type and the of your Principal Balance. Your Principal Balance is the sum of the Amount charge you must pay. The charge will be the premium for the insurance and Financed and the Prepaid Finance Charge, if any. a finance charge at ihe highest rate the law permits. If the vehicle is lost or How we will apply payments, We may apply each payment to the earned damaged, you agree that we may use any insurance settlement to reduce and unpaid part of the Finance Charge, to the unpaid part of your Principal what you owe or repair the vehicle. Balance and to other amounts you owe under this contract in any order we What happens to returned insurance, maintenance, service, or other choose as the law allows. contract charges. If we obtain a refund of insurance, maintenance, service, How late payments or early payments change what you must pay. We or other contract charges, you agree that we may subtract the refund from based the Finance Charge, Total of Payments, and Tota! Sale Price shown what you owe. on page 1 of this contract on the assumption that you will make every payment on the day itis due. Your Finance Charge, Total of Payments, and 3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES Total Sale Price will be more if you pay late and less if you pay early. a. You may owe late charges, You will pay a late charge on each late payment Changes may take the form of a larger or smaller final payment or, at our as shown on page 1 of this contract. Acceptance of a late payment or late option, more or fewer payments of the same amount as your scheduled charge does not excuse your late payment or mean that you may keep making payment with a smaller final payment. We will send you a notice telling you late payments. about these changes before the final scheduled payment is due. Ifyou pay late, we may also take the steps described below. dq You may prepay. You may prepay all or part of your Principal Balance at b. ‘You may have to pay all you owe al once. If you break your promises any time, If the contract is paid in full within six months aiter the date you (default), we may demand that you pay all you owe on this contract at once. sign it, we may impose an acquisition charge, not exceeding $75, for Default means: services performed on your behalf for processing this contract. If you . You do not pay any payment on time: prepay, you must pay the earned and unpaid part of the Finance Charge . You give false, incomplete, or misleading information during edits and all other amounts due up to the date of your payment. application; e, You may ask for a payment extension. You may ask us for a deferral of You start 2 proceeding in bankruptcy or one is started against you oz the scheduled due date of all or any partof a payment (extension). If we agree your property,or to your request, wa may charge you a $15 extension fee. You must maintain . You break any agreements in this contract. the physical damage insurance required by this contract (see 2.d.) during any The amount you will owe will be the unpaid partof your Principal Balance plus: 3a extension. If you do not have this insurance, we may buyit and charge you for the earned and unpaid partof the Finance Charge, any late charges, and anys itas this contract says. You may extend the term of any optional insurance you amounts due because you defaulted, bought with this contract to cover the extension if the insurance company or You may have to pay colle