Legal Document: MCHALE AS RECEIVER FOR JLL LOGISTIC INC, GERALD A JR vs. KNIGHTBROOK INSURANCE COMPANY

On May 02, 105 a MOTION - MOTION TO STAY was filed involving a dispute between Mchale As Receiver For Jll Logistic Inc, Gerald A Jr, and Boltrek, William Iii, Henderson Franklin Starnes & Holt P A, Knightbrook Insurance Company, for Contracts in the District Court of Charlotte County.

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Filing # 194148483 E-Filed 03/15/2024 04:51:07 PM

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

Case No.: 2020-000066-CA

GERARD A. MCHALE, JR., as Receiver for
JLL LOGISTIC, INC.,
Plaintiff,
Vv.

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

Defendants.

MOTION TO STAY

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

BOLTREK, III (collectively “Attorney-Defendants”), file this Motion to Stay Proceedings

pursuant to Fla. R. App. P. 9.110 and 9.310, and common law.

Summary

Plaintiff, Gerard A. McHale, Jr. (“Mr. McHale”) as Receiver for JLL Logistic, Inc. (“JLL”)

ostensibly obtained authority to exercise JLL’s alleged legal malpractice causes of action via an

Appointment Order in the Underlying Matter. In the Underlying Matter, the Attorney-Defendants

moved to intervene and to vacate the void order ostensibly appointing Mr. McHale, the Court

denied the motions, and the Attorney-Defendants filed a Notice of Appeal in the Underlying

Matter. Upon filing the Notice of Appeal, the Court in the Underlying Matter lost jurisdiction of

the Receivership. Accordingly, the Receiver has lost authority to prosecute the instant action for

the time being, since the Receiver is an agent of the Court and the principal — the Court — no longer
Case No.: 2020-000066-CA

retains jurisdiction of the Receivership. Thus, the instant action must be stayed by this Court

pending the issuance of a mandate in the Underlying Matter.

Memorandum of Law

1 In the Underlying Matter,' the Court entered a final order denying the Attorney-

Defendants’ motion to intervene and to vacate the void order appointing Mr. McHale Receiver for

JLL (“the Order”). Ex. A, Order Denying Motion to Intervene & Vacate Order Appointing Mr.

McHale; Litvak v. Scylla Properties, LLC, 946 So. 2d 1165, 1172 (Fla. 1st DCA 2006) (“An order

denying a motion to intervene is final as to and appealable by the movant.”) (citing City of Sunrise

v. Town of Davie, 472 So. 2d 458, 459 (Fla. 1985) (treating order denying motion to intervene as

a final order)); PC. v. Dep't of Children And Family Services, 963 So. 2d 302, 303 (Fla. 2d DCA

2007); JR. v. R.M., 679 So. 2d 64, 65 (Fla. 4th DCA 1996); Superior Fence & Rail of N. Florida

v. Lucas, 35 So. 3d 104, 105 (Fla. 5th DCA 2010).

2. A Notice of Appeal was filed to appeal the Order, thereupon jurisdiction of the

Receivership passed to the Sixth District Court of Appeal. Ex. B, Notice of Appeal; Holland v.

Courtesy Corp., 563 So. 2d 787, 788-89 (Fla. lst DCA 1990) (“As a general rule, once an appeal

of a final order or judgment has been perfected, the lower tribunal loses jurisdiction of the case

until all appellate proceedings have been completed and mandate has issued to that tribunal.”)

(emphasis in original); see also Lelekis v. Liles, 240 So. 2d 478, 479 (Fla. 1970) (“jurisdiction rests

in an appellate court upon the filing of a notice of appeal”).

3 More specifically, the subject of the appeal in the Underlying Matter is the validity

of the Receivership and the Receiver’s authority to maintain and prosecute the instant action, and

! William H. Schmitz, and Janice K. Schmitz v. JLL Logistic, Inc., et. al., CASE NO. 16-001754-
CA (Fla. 20th Cir, Ct.).
Case No.: 2020-000066-CA

“Tw]hen the jurisdiction of the appellate court attaches, it is exclusive as to the subject covered by

the appeal.” Willey v. W.J. Hoggson Corp., 89 Fla. 446, 105 So. 126, 128 (1925) (citing Holland v.

State, 15 Fla. 549, 552 (1876); State v. Phillips, 13 So. 920 (Fla. 1893); McMichael v. Eckman, 7

So. 365 (Fla. 1890).
4 Accordingly, the Receiver has lost authority to prosecute the instant action for the

time being, since the Receiver is an agent and officer of the Court, and the principal — the Court —

no longer retains jurisdiction of the Receivership. Knickerbocker Tr. Co. v. Green Bay Phosphate

Co., 56 So. 699, 702 (Fla. 1911) (“A receiver is the agent of the court, and those who deal with

him as such do so with reference to his authority as receiver, the nature and extent of which

authority those who so deal should take notice.”); Fugazy Travel Bureau, Inc. v. State by Dickinson,

188 So. 2d 842, 844 (Fla. 4th DCA 1966) (“The receiver is an officer of the court and is subject to

the supervision and control of the court.”); see also Eppes v. Dade Developers, 170 So. 875, 877

(Fla. 1936) (“The receiver is the officer of the court”); Matter of Prop. Mgmt. & Inv., 20 B.R. 319,

321 (Bankr. M.D. Fla. 1982) (‘the Receiver can neither sue nor be sued without the consent of the

court which appointed him.”) (citing 44 Fla. Jur 2d Receivers § 84 (updated citation)).

Conclusion

WHEREFORE, Attorney-Defendants respectfully request the Court stay this matter

pending the issuance of a mandate in the Underlying Matter.
Case No.: 2020-000066-CA.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via

electronic mail pursuant to Florida Rule of Judicial Administration 2.516 using Florida Court’s E-

Filing Portal to all counsel on: March 15, 2024.

By: Ss Brandt Ben
Kenneth R. Drake, Esq.
Florida Bar Number: 375111
E-Mail: kdrake@cmlawfirm.com
Brandt Roen, Esq.
Florida Bar Number: 1033416
E-mail: broen@cmlawfirm.com

CRUSER, MITCHELL, NOVITZ, SANCHEZ, GASTON
& ZIMET LLP
Attorneys for Henderson, Franklin, Starnes & Holt, P.A. and
William Boltrek, III
Douglas Entrance
806 Douglas Road, 12" Floor
Coral Gables, Florida 33134
Telephone: (305) 488-4950
Case No.: 2020-000066-CA.

SERVICE LIST

Co-Counsel
for Plaintiff/Appellee

[Angela E. Rodante, Esq.
[Dale Swope Esq.
[Brent Steinberg, Esq.
|Natalie Shoemaker, Esq.
Swope, Rodante P.A.
1234 E. 5" Avenue
Tampa, FL 33605
ITel: (813) 273-0017
Fax: (813) 223-3678
IE-mail: team2eservice@swopelaw.com;
leservice@swopelaw.com;
team3eservice@swopelaw.com

Filing # 191810470 E-Filed 02/13/2024 08:22:35 AM

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

WILLIAM H. SCHMITZ and
JANICE K. SCHMITZ,
as Husband and Wife,
CASE NO.: 16001754CA
Plaintiffs,

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC., and ROBERTO LI,
Defendants.
/
ORDER DENYING NON-PARTIES’ MOTION TO INTERVENE AND MOTION
TO VACATE VOID ORDER APPOINTING RECEIVER FOR JLL, LOGISTIC INC.

Before this Court is the Motion to Intervene and Motion to Vacate Void Order Appointing Receiver

for JLL, Logistic Inc. (“Motion”), filed by HENDERSON, FRANKLIN, STARNES & HOLT, P.A. and

WILLIAM BOLTREK, III (collectively “Non-Parties”) on November 9, 2023. A hearing on the Motion

was held December 21, 2023. This Court has considered the parties’ filings and the arguments of counsel.

Being fully advised in the premises, this Court finds as follows:

FACTS PRESENTED

On January 29, 2018, Plaintiffs obtained a consent judgment against the defendant, JLL Logistic,

Inc. (“JLL Logistic”) for $3,750,000, plus interest. See D.E. 72 (“Final Judgment”). After obtaining the

consent judgment, Plaintiffs made multiple attempts to obtain post-judgment discovery from JLL Logistic.

See D.E. 81, paras. 4-7 (“Amended Motion to Appoint Receiver”). The company was, however, defunct,

and Plaintiffs’ efforts to obtain the post-judgment discovery were unsuccessful. See id. at paras. 8-9.

Thereafter, Plaintiffs filed motions on October 4, 2019 and October 10, 2019 to appoint Gerard

McHale as receiver for JLL Logistic, pursuant to section 56.10, Florida Statutes. See D.E. 80 & 81.

Plaintiffs provided notice to Non-Parties and JLL Logistic that they were secking appointment of a receiver.

See D.E. 80 & D.E. 81, Certificates of Service. Neither JLL Logistic nor Non-Parties objected to Plaintiffs’

motions secking appointment of a receiver. Further, no hearing was set concerning Plaintiffs’ request.
Subsequently, on October 28, 2019, this Court entered an order appointing Mr. McHale as receiver for JLL

Logistic, pursuant to section 56.10, Florida Statutes. See D.E. 82. The Order Appointing Receiver was

emailed to both Mr. Boltrek at William.Boltrek@henlaw.com and sent via U.S. Mail to JLL Logistic’s

physical address. See D.E. 82.

On January 23, 2020, Mr. McHale, in his capacity as receiver for JLL Logistic, filed a separate

insurance bad faith claim against JLL Logistic’s insurance carrier, KnightBrook Insurance Company, and

a legal malpractice action against Non-Parties. See Charlotte County Circuit Court Case Number 20-

000066-CA. More than three years later, on November 9, 2023, Non-Parties filed the instant Motion,

seeking both to intervene in this action and for this Court to vacate its October 28, 2019 Order appointing

Mr. McHale as receiver for JLL Logistic. See DE. 83. Non-Parties’ filed the Motion for the purpose of

undermining their former client, JLL Logistic’s, separate suit against them for malpractice. See D.E. 83,

pp. 12-13.
ISSUES

Non-Parties’ Motion involves primarily two issues. The first is whether Non-Parties are entitled to

intervene in this litigation pursuant to Florida Rule of Civil Procedure 1.230. The second is whether this

Court must vacate its Order Appointing Receiver because no hearing was held prior to entry of that order.

LAW AND ANALYSIS

For the reasons discussed further below, this Court finds that Non-Parties are not entitled to

intervene in this litigation, nor are they entitled to an Order vacating the Order Appointing Receiver.

I Non-Parties are not Entitled to Intervene in this Action

Non-Parties are not parties to this action. Accordingly, the threshold issue for this Court’s

consideration is whether Non-Partics may intervene in this litigation. The standard applicable to the

intervention of a non-party is found in Florida Rule of Civil Procedure 1.230. In relevant part, this Rule

provides that “[a]nyone claiming an interest in pending litigation may at any time be permitted to assert a

right by intervention .. . .” See Fla. R. Civ. P. 1.230. In interpreting this standard, the Supreme Court of

Florida has held:
[T]he interest which will entitle a person to intervene . . . must be in the
matter in litigation, and of such a direct and immediate character that the
intervener will either gain or lose by the direct legal operation and effect
of the judgment. In other words, the interest must be that created by a claim
to the demand in suit or some part thereof, or a claim to, or lien upon, the
property or some part thereof, which is the subject of litigation.’

Union Cent. Life Ins. Co. v. Carlisle, 593 So.2d 505, 507 (Fla.1992) (quoting Morgareidge v. Howey, 78

So. 14, 15 (1918))(emphasis added). Further, while intervention may be granted post-judgment when the

ends of justice require it, the Courts consider such intervention both “extraordinary and disfavored.” See

Ezem v. Fed. Nat. Mortg., 153 So. 3d 341, 344 (Fla.1st DCA 2014).

Non-Parties argue that they are entitled to intervene, because they have an interest in not being sued

“by an illegitimate Receiver” and that vacating the order appointing the Receiver would directly and

immediately affect their interest. See D.E. 83, p. 12. Specifically, they argue that “[u]pong vacating the

void order, the Receiver will lose standing to maintain the legal malpractice action against the Attorney-

Defendants and the malpractice case will necessarily be dismissed.” See D.E. 83, pp. 12-13.

Non-Parties’ argument is without merit. Specifically, the matter litigated in this action was the

Court’s appointment of a receiver. Here, the Court’s entry of the Order Appointing a Receiver in October

28, 2019 did not automatically trigger the imposition of liability on Non-Parties in this or the separate

malpractice action. See Kissoon v. Araujo, 849 So. 2d 426, 429 (Fla. Ist DCA 2003)(denying intervention

where “[a] judgment in favor of defendants will not automatically trigger an investigation, nor can it impose

liability on Dr. Kissoon.”); see also Harbor Specialty Ins. Co. v. Schwartz, 932 So. 2d 383, 387-88 (Fla.

2d DCA 2006)(denying intervention where, “[a]lthough a bad faith action could be initiated by Schwartz

on behalf of English as a result of the final judgment, the final judgment will not automatically result in

such an action being filed.”). Accordingly, Non-Parties lacked the kind of “direct” and “immediate” interest

“in the matter in litigation” required for intervention. For this reason, Non-Parties’ request to intervene is

denied.

I. Non-Parties are not Entitled to have the Order Appointing Receiver Vacated
Non-Parties’ Motion contends that this Court’s Order Appointing Receiver is void because

Plaintiffs neither set their motion for appointment of a receiver for hearing nor provided notice of any such

hearing. See D.E. 83, pp. 1,7. The Motion argues that, because the order is void, this Court must vacate it

pursuant to Florida Rule of Civil Procedure 1.540. See D-E. 83, pp. 1, 9.

Non-Parties’ argument is without merit. As discussed further below, this Court’s Order Appointing

Receiver is not void. Moreover, Non-Parties’ Motion is untimely under the express terms of Rule 1.540.

A. The Order Appointing Receiver is not Void

In State ex rel. Fulton Bag & Cotton Mills v. Burnside, 153 Fla. 599, 602 (1943), the Supreme

Court of Florida articulated the legal standard for determining when an order is void. Specifically, in

Burnside, the Supreme Court of Florida explains:

It is settled law that where it appears that a court is legally organized and
has jurisdiction of the subject matter and the adverse parties are given an
opportunity to be heard as required by law, errors or irregularities, or even
wrong doing in the proceedings, short of an illegal deprivation of an
opportunity to be heard, will not render the judgment void.

See Burnside, 153 Fla. 599 at 602 (emphasis added). In other words, whether an order is “void” depends

on whether (a) this Court is legally organized, (b) whether this Court has jurisdiction of the subject matter,

there has been an illegal deprivation of an opportunity to be heard.

Here, it is undisputed that the Court is legally organized and the Court has jurisdiction over the

subject matter. Accordingly, the only issues are whether adverse parties were given an opportunity to be

heard as required by law and/or whether there has been an illegal deprivation of an opportunity to be heard.

In this case, neither the applicable statute nor the rules of procedure required a hearing prior to

entry of the Order Appointing Receiver. First, Plaintiffs’ motions for appointment of a receiver were made

pursuant to section 56.10, Florida Statutes. Nothing in Section 56.10 requires a hearing for the appointment

of areceiver. See Fla. Stat. 56.10. Second, Florida Rule of Civil Procedure 1.620(a) concerns applications

for the appointment of a receiver. See Fla. R. Civ. P. 1.620(a). However, the plain language of Rule

1.620(a) only speaks to when notice is required. It does specify nor incorporate by reference requirements
for when a hearing is required. See Fla. R. Civ. P. 1.620(a)(“The provisions of rule 1.610 as to notice shall

apply to applications for the appointment of receivers.”).

Finally, there has been no illegal deprivation of an opportunity to be heard which would render

void the Order Appointing Receiver. Constitutional due process only requires the provision of notice and

a meaningful opportunity to be heard, where a parties’ life, liberty, and property are at stake. See Morrissey

v. Brewer, 408 U.S. 471, 481 (1972)(“Whether any procedural protections are due depends on “whether the

nature of the interest is one within the contemplation of the ‘liberty or property’ language of the Fourteenth

Amendment.”); see also U.S. Const. amend. XIV, § | (“. . . nor shall any State deprive any person of life,

liberty, or property, without due process of law . . . .”); Fla. Const. art. I, § 9 (“No person shall be deprived

of life, liberty or property without due process of law... .”).

Further, constitutional rights, including the right to due process, are personal and may be waived.

See Epstein v. Bank of Am., 162 So. 3d 159, 162 (Fla. 4th DCA 2015)(quoting Broadrick v. Oklahoma, 413

US. 601, 610, 93 S.Ct. 2908, 37 L.Ed.2d 830 (1973)); see also Pierce v. Somerset Ry., 171 U.S. 641, 648

(1898)(“A person may, by his acts or omission to act, waive a right which he might otherwise have under

>)
the constitution of the United States Constitutional due process rights may not be asserted

vicariously by another party to render an order void. See Epstein , 162 So. 3d at 162.

Here, Non-Parties, themselves, were not entitled to due process prior to entry of the Order

Appointing Receiver, because they had no life, liberty, or property interest at stake in that proceeding.

Furthermore, Non-Parties are without standing to assert JLL Logistic's constitutional due process rights to

render the subject order void.

In sum, neither the statute nor the procedural rules required a noticed hearing on Plaintiffs’ motion

to appoint a receiver. Moreover, Non-Parties had no constitutional right to due process with respect to the

appointment of a receiver and cannot assert JLL Logistic’s right to due process to render the subject order

void. Accordingly, the subject Order to Appoint Receiver is not void. Therefore, Non-Parties’ Motion is

denied.

B. Non-Parties’ Motion to Vacate Is Untimely under Rule 1.540(b)
Again, Plaintiffs moved for the appointment of Mr. McHale as receiver for JLL Logistic on October

4, 2019 and October 10, 2019. This Court entered its order granting Plaintiffs’ motion on October 28, 2019.

The court file demonstrates that Non-Parties had notice of these filings at about the time they were made.

More than four years later, Non-Parties now seek to vacate the Order Appointing Receiver, pursuant to

Florida Rule of Civil Procedure 1.540, on the ground that it is “void.”

Rule 1.540(b) states: “[o]n motion and upon such terms as are just, the court may relieve a party or

a party's legal representative from a final judgment, decree, order, or proceeding for the following reasons:

. . (4) that the judgment, decree, or orderis void... .” The Rule further provides that such motions “shall

be filed within a reasonable time as ” See Fla. R. Civ. P. 1.540(b)(underline added). As such, the plain

language of Rule 1.540(b) mandates that motions under it be “filed within a reasonable time.”

In this case, Non-Parties had notice of the filings related to the appointment of the receiver in

October of 2019. In light of that notice, Non-Parties’ decision to wait more than four years before filing its

Motion was unreasonable. Because the Court’s record demonstrates that Non-Parties did not file their

Motion within a “reasonable time,” as required by Rule 1.540, Non-Parties’ motion to vacate is also denied.

It is, therefore, ORDERED and ADJUDGED that Non-Parties’ Motion to Intervene and Motion

to Vacate Void Order Appointing Receiver for JLL, Logistic Inc., filed November 9, 2023 is DENIED.

Done and Ordered.

TY
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Electronic Service List
Angela E Rodante , ,

Natalie Isabella Shoemaker ,
,
Brent G Steinberg ,
Brandt Roen ,
Reba Abraham Pearce
Angela Rodante
Scot D Goldberg ,
John W. Weihmuller , ,

James M Shaw Jr. , ,

Curtright C. Truitt
Elizete D Velado
Kenneth R Drake ,
Michael M. Noone ,
Natalie Isabella Shoemaker , ,

Richard Lee Brooks II ,
John W. Weihmuller
Julia Newton
Steven A Ramunni , ,

KENNETH RUSSELL DRAKE
KENNETH RUSSELL DRAKE

Filing # 193953982 E-Filed 03/13/2024 03:32:22 PM

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

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

Non-Parties/ Appellants,

CASE NO. 16-001754-CA
WILLIAM H. SCHMITZ
and JANICE K. SCHMITZ,
as Husband and Wife,
NOTICE OF APPEAL

Plaintiffs/ Appellees,

ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC.,
and ROBERTO LI,

Defendants/ Appellees.

NOTICE IS GIVEN that HENDERSON FRANKLIN STARNES &

HOLT, P.A., and WILLIAM BOLTREK, III, Non-Parties/Appellant,

appeals to the Sixth District Court of Appeal, the order of this court

rendered February 23, 2024 (the “Order”), pursuant to Fla. R. App.
P. 9.110(a)(1). The nature of the order is a final order! denying the

Non-Parties’/ Appellants’ motion to intervene (the “Motion”) to vacate

a void order appointing a Receiver for Defendant/Appellee, JLL

LOGISTIC INC.2 The Motion was opposed by the Receiver, Gerard A.

McHale, in his ostensible capacity as Receiver for JUL LOGISTIC INC.

and Plaintiffs/Appellees, WILLIAM H. SCHMITZ and JANICE K.

SCHMITZ. Defendants/Appellees, ALEXMAR PIMIENTA GARRIDO,

and ROBERTO LI have been dismissed from this matter.

A conformed copy of the Order is attached hereto as

Attachment A.

1 Litvak v. Scylla Properties, LLC, 946 So. 2d 1165, 1172 (Fla. lst DCA
2006) (“An order denying a motion to intervene is final as to and
appealable by the movant.”) (citing City of Sunrise v. Town of Davie,
472 So. 2d 458, 459 (Fla. 1985) (treating order denying motion to
intervene as a final order); P.C. v. Dep't of Children And Family
Services, 963 So. 2d 302, 303 (Fla. 2d DCA 2007); J.R. v. R.M., 679
So. 2d 64, 65 (Fla. 4th DCA 1996); Superior Fence & Rail of N. Florida
v. Lucas, 35 So. 3d 104, 105 (Fla. 5th DCA 2010).

2 Alternatively, this appeal is made pursuant to Fla. R. App. P.
9.110(a)(3)(D).
CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the

foregoing was served via electronic mail pursuant to Florida Rule of

Judicial Administration 2.516 using Florida Court’s E-Filing Portal

to all counsel on: March 13, 2024.

By: Ss Bande Ren

Kenneth R. Drake, Esq.
Florida Bar Number: 375111
E-Mail: kdrake@cmlawfirm.com
Brandt Roen, Esq.
Florida Bar Number: 1033416
E-mail: broen@cmlawfirm.com

CRUSER, MITCHELL, NOVITZ, SANCHEZ,
GASTON & ZIMET LLP
Attorneys for Non-Parties/ Appellants,
Henderson, Franklin, Starnes & Holt, P.A.
and William Boltrek, IT
Douglas Entrance
806 Douglas Road, 12t» Floor
Coral Gables, Florida 33134
Telephone: (305) 488-4950
SERVICE LIST

Co-Counsel for Plaintiff/ Appellee Co-Counsel for Plaintiff/ Appellee

[Angela E. Rodante, Esq. Reba Abraham Pearce, Esq.
Dale Swope Esq. St. Augustine Law Group, P.A.
Brent Steinberg, Esq. 2740 U.S. Highway 1 South
Natalie Shoemaker, Esq. St. Augustine, FL 332086
Swope, Rodante P.A. E-Mails:
1234 E. 5th Avenue reba@staugustinelawgroup.com;
(Tampa, FL 33605 info@staugustinelawgroup.com).
Tel: (813) 273-0017
Fax: (813) 223-3678
E-mail:
Iteam2eservice@swopelaw.com;
leservice@swopelaw.com;
lteam3eservice@swopelaw.com

Co-Counsel for Plaintiff/ Appellee

Scot Goldberg, Esq.
Michelle Keezel, Esq.
Goldberg, Noone, Abraham, LLC
1533 Hendry Street
Suite 200
Fort Meyers, Florida, 33901
E-Mails:
iscotgoldberg@goldberg-law.com;
imichellekeezel@goldberg-
llaw.com.
ATTACHMENT
A
Filing # 191810470 E-Filed 02/13/2024 08:22:35 AM