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Filing # 49180951 E-Filed 11/22/2016 08:39:08 AM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY
STATE OF FLORIDA,
CIVIL DIVISION
Case No.: 2016-CA-8362-O
COMPLEX BUSINESS LITIGATION
Quality One Wireless, LLC,
Plaintiff,
v.
Liquid Image Co., LLC,
Defendant,
and
Wells Fargo Bank,
Garnishee.
_______________________________________/
WRIT OF GARNISHMENT
STATE OF FLORIDA:
TO ALL AND SINGULAR THE SHERIFFS OF THE STATE:
YOU ARE COMMANDED to summon garnishee, Wells Fargo Bank, 100 S. Ashley
Drive, Tampa, FL 33602, to serve an answer to this Writ on Plaintiff's attorney:
Mr. Charles C. Lane
Lau, Lane, Pieper, Conley & McCreadie, P.A.
Wells Fargo Center ~ Suite 1700
100 South Ashley Drive
Tampa, Florida 33602
(813) 229-2121 (P) | (813) 228-7710 (F)
E-mail: clane@laulane.com
within twenty (20) days after service on the garnishee, exclusive of the date of service, and
to file the original with the Clerk of this Court either before service on the attorney or
immediately thereafter, stating whether the garnishee is indebted to Defendant, Liquid Image
Co., LLC, whose address is 5610 Skylane Blvd., Suite D, Santa Rosa, CA 95403, at the time
of the answer or was indebted at the time of service of the Writ, plus sufficient time not to
exceed one (1) business day for Garnishee to act expeditiously on the Writ, or at any time
between such times, and in what sum and what tangible and intangible personal property of
the Defendant the garnishee has in its possession or control at the time of the answer or had
at the time of service of this Writ, or at any time between such times, and whether the
garnishee knows of any other person indebted to the Defendant or who may have any of the
property of the Defendant in its possession or control. The amount set in Plaintiff's motion is
$1,221,033.90.
WITNESS my hand and the seal of this Court on this _______ day of November,
2016.
Clerk Circuit & County Courts
ORANGE COUNTY, FLORIDA
By ________________________
Deputy Clerk
(Court Seal)
NOTICE TO DEFENDANT OF RIGHT AGAINST
GARNISHMENT OF WAGES, MONEY AND OTHER PROPERTY
The Writ of Garnishment delivered to you with this Notice means that wages, money and
other property belonging to you have been garnished to pay a court judgment against you.
HOWEVER, YOU MAY BE ABLE TO KEEP OR RECOVER YOUR WAGES, MONEY OR
PROPERTY. READ THIS NOTICE CAREFULLY.
State and federal laws provide that certain wages, money, and property, even if deposited
in a bank, savings and loan, or credit union, may not be taken to pay certain types of court
judgments. Such wages, money, and property are exempt from garnishment. The major
exemptions are listed below on the form for Claim of Exemption and Request for Hearing.
This list does not include all possible exemptions. YOU SHOULD CONSULT A LAWYER
FOR SPECIFIC ADVICE.
TO KEEP YOUR WAGES, MONEY AND OTHER PROPERTY FROM BEING
GARNISHED, OR TO GET BACK ANYTHING ALREADY TAKEN, YOU MUST
COMPLETE A FORM FOR CLAIM OF EXEMPTION AND REQUEST FOR
HEARING AS SET FORTH BELOW AND HAVE THE FORM NOTARIZED. YOU
MUST FILE THE FORM WITH THE CLERK’S OFFICE WITHIN 20 DAYS AFTER
THE DATE YOU RECEIVE THIS NOTICE OR YOU MAY LOSE IMPORTANT
RIGHTS. YOU MUST ALSO MAIL OR DELIVER A COPY OF THIS FORM TO
THE PLAINTIFF AND THE GARNISHEE AT THE ADDRESSES LISTED ON THE
WRIT OF GARNISHMENT.
If you request a hearing, it will be held as soon as possible after your request is received
by the court. The plaintiff must file any objection within 8 business days, if you hand delivered
to the plaintiff a copy of the form for Claim of Exemption and Request for Hearing, or in
alternatively, 14 business days if you mailed a copy of the form for claim and request to the
plaintiff. If the plaintiff files an objection to your Claim for Exemption and Request for
Hearing, the clerk will notify you and the other parties of the time and date of the hearing. You
may attend the hearing with or without an attorney. If the plaintiff fails to file an objection, no
hearing is required, the writ of garnishment will be dissolved and your wages, money or property
will be released.
YOU SHOULD FILE THE FORM FOR CLAIM OF EXEMPTION IMMEDIATELY
TO KEEP YOUR WAGES, MONEY OR PROPERTY FROM BEING APPLIED TO
THE COURT JUDGMENT. THE CLERK CANNOT GIVE YOU LEGAL ADVICE.
IF YOU NEED LEGAL ASSISTANCE, YOU SHOULD SEE A LAWYER. IF YOU
CAN’T AFFORD A PRIVATE LAWYER, LEGAL SERVICES MAY BE
AVAILABLE. CONTACT YOUR LOCAL BAR ASSOCIATION OR ASK THE
CLERK’S OFFICE ABOUT ANY LEGAL SERVICES PROGRAM IN YOUR AREA.
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY
STATE OF FLORIDA,
CIVIL DIVISION
Case No.: 2016-CA-8362-O
COMPLEX BUSINESS LITIGATION
Quality One Wireless, LLC,
Plaintiff,
v.
Liquid Image Co., LLC,
Defendant,
and
Wells Fargo Bank,
Garnishee.
_______________________________________/
CLAIM OF EXEMPTION AND REQUEST FOR HEARING
I claim exemptions from garnishment under the following categories as checked:
_______ 1. Head of family wages. (Check either a. or b. below, if applicable)
_______ a. I provide more than one-half of the support for a child or
other dependent and have net earnings of $750 or less per
week.
_______ b. I provide more than one-half of the support for a child or
other dependent, have net earnings of $750 per week, but
have not agreed in writing to have my wages garnished.
_______ 2. Social Security benefits.
_______ 3. Supplemental Security Income benefits.
_______ 4. Public Assistance (welfare).
_______ 5. Workers’ Compensation.
1
_______ 6. Reemployment assistance or unemployment compensation.
_______ 7. Veterans’ benefits.
_______ 8. Retirement or profit-sharing benefits or pension money.
_______ 9. Life Insurance benefits or cash surrender value of a life insurance policy
or proceeds of annuity contract.
_______ 10. Disability income benefits.
_______ 11. Prepaid College Trust Fund or Medical Savings Account.
_______ 12. Other exemptions as provided by law. (Explain)
________________________________________________________________________
________________________________________________________________________
I request a hearing to decide the validity of my claim. Notice of the hearing
should be given to me at:
Address: ___________________________________________________________
___________________________________________________________
Telephone: ____________________________________________________________
I CERTIFY UNDER OATH AND PENALTY OF PERJURY that a copy of this CLAIM
OF EXEMPTION AND REQUEST FOR HEARING has been furnished by (circle one)
United States mail –or– hand delivery on _____________________, 2016, to:
Mr. Charles C. Lane
Lau, Lane, Pieper, Conley & McCreadie, P.A.
Wells Fargo Center ~ Suite 1700
100 South Ashley Drive
Tampa, Florida 33602
I FURTHER CERTIFY UNDER OATH AND PENALTY OF PERJURY that the
statements made in this request are true to the best of my knowledge and belief.
___________________________________ ________________________
Defendant’s Signature Date
2
STATE OF FLORIDA,
COUNTY OF _________________________,
SWORN TO AND SUBSCRIBED before me this ________ day of ___________, 2016
by ________________________________________, who personally appeared before me and is
___ personally known to me, or
___ produced identification,
type of identification produced __________________________________________
________________________________________
Notary Public
________________________________________
print, type, or stamp name of notary public
My commission expires: ____________________
#2427-19136
3
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Filing # 49180951 E-Filed 11/22/2016 08:39:08 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY STATE OF FLORIDA, CIVIL DIVISION Case No.: 2016-CA-8362-O COMPLEX BUSINESS LITIGATION Quality One Wireless, LLC, Plaintiff, v. Liquid Image Co., LLC, Defendant, and Wells Fargo Bank, Garnishee. _______________________________________/ WRIT OF GARNISHMENT STATE OF FLORIDA: TO ALL AND SINGULAR THE SHERIFFS OF THE STATE: YOU ARE COMMANDED to summon garnishee, Wells Fargo Bank, 100 S. Ashley Drive, Tampa, FL 33602, to serve an answer to this Writ on Plaintiff's attorney: Mr. Charles C. Lane Lau, Lane, Pieper, Conley & McCreadie, P.A. Wells Fargo Center ~ Suite 1700 100 South Ashley Drive Tampa, Florida 33602 (813) 229-2121 (P) | (813) 228-7710 (F) E-mail: clane@laulane.com within twenty (20) days after service on the garnishee, exclusive of the date of service, and to file the original with the Clerk of this Court either before service on the attorney or immediately thereafter, stating whether the garnishee is indebted to Defendant, Liquid Image Co., LLC, whose address is 5610 Skylane Blvd., Suite D, Santa Rosa, CA 95403, at the time of the answer or was indebted at the time of service of the Writ, plus sufficient time not to exceed one (1) business day for Garnishee to act expeditiously on the Writ, or at any time between such times, and in what sum and what tangible and intangible personal property of the Defendant the garnishee has in its possession or control at the time of the answer or had at the time of service of this Writ, or at any time between such times, and whether the garnishee knows of any other person indebted to the Defendant or who may have any of the property of the Defendant in its possession or control. The amount set in Plaintiff's motion is $1,221,033.90. WITNESS my hand and the seal of this Court on this _______ day of November, 2016. Clerk Circuit & County Courts ORANGE COUNTY, FLORIDA By ________________________ Deputy Clerk (Court Seal) NOTICE TO DEFENDANT OF RIGHT AGAINST GARNISHMENT OF WAGES, MONEY AND OTHER PROPERTY The Writ of Garnishment delivered to you with this Notice means that wages, money and other property belonging to you have been garnished to pay a court judgment against you. HOWEVER, YOU MAY BE ABLE TO KEEP OR RECOVER YOUR WAGES, MONEY OR PROPERTY. READ THIS NOTICE CAREFULLY. State and federal laws provide that certain wages, money, and property, even if deposited in a bank, savings and loan, or credit union, may not be taken to pay certain types of court judgments. Such wages, money, and property are exempt from garnishment. The major exemptions are listed below on the form for Claim of Exemption and Request for Hearing. This list does not include all possible exemptions. YOU SHOULD CONSULT A LAWYER FOR SPECIFIC ADVICE. TO KEEP YOUR WAGES, MONEY AND OTHER PROPERTY FROM BEING GARNISHED, OR TO GET BACK ANYTHING ALREADY TAKEN, YOU MUST COMPLETE A FORM FOR CLAIM OF EXEMPTION AND REQUEST FOR HEARING AS SET FORTH BELOW AND HAVE THE FORM NOTARIZED. YOU MUST FILE THE FORM WITH THE CLERK’S OFFICE WITHIN 20 DAYS AFTER THE DATE YOU RECEIVE THIS NOTICE OR YOU MAY LOSE IMPORTANT RIGHTS. YOU MUST ALSO MAIL OR DELIVER A COPY OF THIS FORM TO THE PLAINTIFF AND THE GARNISHEE AT THE ADDRESSES LISTED ON THE WRIT OF GARNISHMENT. If you request a hearing, it will be held as soon as possible after your request is received by the court. The plaintiff must file any objection within 8 business days, if you hand delivered to the plaintiff a copy of the form for Claim of Exemption and Request for Hearing, or in alternatively, 14 business days if you mailed a copy of the form for claim and request to the plaintiff. If the plaintiff files an objection to your Claim for Exemption and Request for Hearing, the clerk will notify you and the other parties of the time and date of the hearing. You may attend the hearing with or without an attorney. If the plaintiff fails to file an objection, no hearing is required, the writ of garnishment will be dissolved and your wages, money or property will be released. YOU SHOULD FILE THE FORM FOR CLAIM OF EXEMPTION IMMEDIATELY TO KEEP YOUR WAGES, MONEY OR PROPERTY FROM BEING APPLIED TO THE COURT JUDGMENT. THE CLERK CANNOT GIVE YOU LEGAL ADVICE. IF YOU NEED LEGAL ASSISTANCE, YOU SHOULD SEE A LAWYER. IF YOU CAN’T AFFORD A PRIVATE LAWYER, LEGAL SERVICES MAY BE AVAILABLE. CONTACT YOUR LOCAL BAR ASSOCIATION OR ASK THE CLERK’S OFFICE ABOUT ANY LEGAL SERVICES PROGRAM IN YOUR AREA. IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY STATE OF FLORIDA, CIVIL DIVISION Case No.: 2016-CA-8362-O COMPLEX BUSINESS LITIGATION Quality One Wireless, LLC, Plaintiff, v. Liquid Image Co., LLC, Defendant, and Wells Fargo Bank, Garnishee. _______________________________________/ CLAIM OF EXEMPTION AND REQUEST FOR HEARING I claim exemptions from garnishment under the following categories as checked: _______ 1. Head of family wages. (Check either a. or b. below, if applicable) _______ a. I provide more than one-half of the support for a child or other dependent and have net earnings of $750 or less per week. _______ b. I provide more than one-half of the support for a child or other dependent, have net earnings of $750 per week, but have not agreed in writing to have my wages garnished. _______ 2. Social Security benefits. _______ 3. Supplemental Security Income benefits. _______ 4. Public Assistance (welfare). _______ 5. Workers’ Compensation. 1 _______ 6. Reemployment assistance or unemployment compensation. _______ 7. Veterans’ benefits. _______ 8. Retirement or profit-sharing benefits or pension money. _______ 9. Life Insurance benefits or cash surrender value of a life insurance policy or proceeds of annuity contract. _______ 10. Disability income benefits. _______ 11. Prepaid College Trust Fund or Medical Savings Account. _______ 12. Other exemptions as provided by law. (Explain) ________________________________________________________________________ ________________________________________________________________________ I request a hearing to decide the validity of my claim. Notice of the hearing should be given to me at: Address: ___________________________________________________________ ___________________________________________________________ Telephone: ____________________________________________________________ I CERTIFY UNDER OATH AND PENALTY OF PERJURY that a copy of this CLAIM OF EXEMPTION AND REQUEST FOR HEARING has been furnished by (circle one) United States mail –or– hand delivery on _____________________, 2016, to: Mr. Charles C. Lane Lau, Lane, Pieper, Conley & McCreadie, P.A. Wells Fargo Center ~ Suite 1700 100 South Ashley Drive Tampa, Florida 33602 I FURTHER CERTIFY UNDER OATH AND PENALTY OF PERJURY that the statements made in this request are true to the best of my knowledge and belief. ___________________________________ ________________________ Defendant’s Signature Date 2 STATE OF FLORIDA, COUNTY OF _________________________, SWORN TO AND SUBSCRIBED before me this ________ day of ___________, 2016 by ________________________________________, who personally appeared before me and is ___ personally known to me, or ___ produced identification, type of identification produced __________________________________________ ________________________________________ Notary Public ________________________________________ print, type, or stamp name of notary public My commission expires: ____________________ #2427-19136 3