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Filing # 70883281 E-Filed 04/18/2018 12:11:04 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
FRANCESCO CATALDI and
ANTONELLA DE NARDO,
Plaintiffs, CASE NO: 2015-CA-009128-O
vs. Division: 33
LEONE ALFANO, a/k/a
LEONE ALFANO LA CAVA,
GOLDEN INVESTMENT INC., a/k/a
GOLDEN INVESTMENT REALTY, INC.,
ORLANDO TRUST INVESTMENT PROPERTIES INC.,
and VIKTORIYA JOHNSON,
Defendants.
/
REQUESTS FOR ADMISSIONS
Plaintiffs, FRANCESCO CATALDI and ANTONELLA DE NARDO, by and through
their undersigned counsel, and pursuant to Rule 1.370, Fla. R. Civ. P., hereby requests Defendant,
LEONE ALFANO, to admit or deny the following:
1. Leone Alfano made representations of fact which were false to the Plaintiffs,
Francesco Cataldi and Antonella De Nardo, with the intention they rely upon the representations.
2. Leone Alfano knowingly made false representations to the Plaintiffs, to induce
them to pay money for properties which were not for sale.
3. Leone Alfano lead the Plaintiffs into believing they had purchased, through Blue
American Studio, Inc., the property located at 155 South Court Ave., Unit 2208, Orlando, Florida,
32801 for a purchase price of $139,000.00.
4. Leone Alfano converted the $139,000.00 paid by the Plaintiffs for his own use.
5. Leone Alfano lead Plaintiffs to believe they had purchased property located at 1431
Harmon Avenue, Winter Park, Florida 32789 for a purchase price of $210,000.00.
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6. Leone Alfano, converted the $210,000.00 for his own use, rather than purchase
property on behalf of the Plaintiffs.
7. Leone Alfano, never had any intention of using funds paid by the Plaintiffs to
purchase property.
8. All monies paid by the Plaintiffs for the purchase of property was converted by
Leone Alfano for his own use.
DATED: April 18, 2018.
/s/ Brian L. Wagner
BRIAN L. WAGNER
Florida Bar Number 142727
Mateer & Harbert, P.A.
225 East Robinson Street, Suite 600
Post Office Box 2854
Orlando, Florida 32802-2854
Telephone: (407) 425-9044
Facsimile: (407) 423-2016
Primary: bwagner@mateerharbert.com
Secondary: phouck@mateerharbert.com
Attorneys for Plaintiffs
CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing with the Clerk of the Court by using
the State of Florida E-Filing system, which will send a notice of electronic filing to the following:
Alberto E. Lugo-Janer, Esquire, Attorney for Defendant, Leone Alfano (alugo-
janer@cplspa.com); and F. Wesley Blankner, Jr. Esquire, Attorney for Defendant, Viktoriya
Johnson (blanknergroup@aliblankner.com, RFiore@aliblankner.com); this 18th day of April,
2018.
/s/ Brian L. Wagner
BRIAN L. WAGNER
Florida Bar Number 142727
4850-6797-7568, v. 1
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Filing # 70883281 E-Filed 04/18/2018 12:11:04 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA FRANCESCO CATALDI and ANTONELLA DE NARDO, Plaintiffs, CASE NO: 2015-CA-009128-O vs. Division: 33 LEONE ALFANO, a/k/a LEONE ALFANO LA CAVA, GOLDEN INVESTMENT INC., a/k/a GOLDEN INVESTMENT REALTY, INC., ORLANDO TRUST INVESTMENT PROPERTIES INC., and VIKTORIYA JOHNSON, Defendants. / REQUESTS FOR ADMISSIONS Plaintiffs, FRANCESCO CATALDI and ANTONELLA DE NARDO, by and through their undersigned counsel, and pursuant to Rule 1.370, Fla. R. Civ. P., hereby requests Defendant, LEONE ALFANO, to admit or deny the following: 1. Leone Alfano made representations of fact which were false to the Plaintiffs, Francesco Cataldi and Antonella De Nardo, with the intention they rely upon the representations. 2. Leone Alfano knowingly made false representations to the Plaintiffs, to induce them to pay money for properties which were not for sale. 3. Leone Alfano lead the Plaintiffs into believing they had purchased, through Blue American Studio, Inc., the property located at 155 South Court Ave., Unit 2208, Orlando, Florida, 32801 for a purchase price of $139,000.00. 4. Leone Alfano converted the $139,000.00 paid by the Plaintiffs for his own use. 5. Leone Alfano lead Plaintiffs to believe they had purchased property located at 1431 Harmon Avenue, Winter Park, Florida 32789 for a purchase price of $210,000.00. 1 6. Leone Alfano, converted the $210,000.00 for his own use, rather than purchase property on behalf of the Plaintiffs. 7. Leone Alfano, never had any intention of using funds paid by the Plaintiffs to purchase property. 8. All monies paid by the Plaintiffs for the purchase of property was converted by Leone Alfano for his own use. DATED: April 18, 2018. /s/ Brian L. Wagner BRIAN L. WAGNER Florida Bar Number 142727 Mateer & Harbert, P.A. 225 East Robinson Street, Suite 600 Post Office Box 2854 Orlando, Florida 32802-2854 Telephone: (407) 425-9044 Facsimile: (407) 423-2016 Primary: bwagner@mateerharbert.com Secondary: phouck@mateerharbert.com Attorneys for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that I electronically filed the foregoing with the Clerk of the Court by using the State of Florida E-Filing system, which will send a notice of electronic filing to the following: Alberto E. Lugo-Janer, Esquire, Attorney for Defendant, Leone Alfano (alugo- janer@cplspa.com); and F. Wesley Blankner, Jr. Esquire, Attorney for Defendant, Viktoriya Johnson (blanknergroup@aliblankner.com, RFiore@aliblankner.com); this 18th day of April, 2018. /s/ Brian L. Wagner BRIAN L. WAGNER Florida Bar Number 142727 4850-6797-7568, v. 1