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Filing # 47269064 E-Filed 10/04/2016 04:32:47 PM
IN THE CIRCUIT COURT IN THE 17™ JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
ASSETS INTERNATIONAL, L.L.C., a Michigan limited
liability company,
Plaintiff, CASE NO: CACE 15-017691
v.
DENNIS K. RODMAN, an individual,
Defendant.
/
AMENDED COMPLAINT
(Amended to include Exhibits)
Plaintiff, ASSETS INTERNATIONAL, L.L.C. a Michigan limited liability company, (“Plaintiff’)by
and through the undersigned attorneys, sues Defendant, DENNIS K. RODMAN, (“Defendant”) and
alleges as follows:
PARTIES, VENUE AND JURISDICTION
1. This is an action for damages that is within this Court's jurisdictional limits. Therefore venue is
proper in this Court pursuant to Section 47.011 et seq., Fla. Stat.
2. Defendant, DENNIS K. RODMAN is a resident of the State of Florida and is over the age of 18
and otherwise sui juris.
3. Plaintiff is a Michigan limited liability company and is registered with the State of Florida Secretary
of State, Division of Corporations as a Foreign limited liability company. Plaintiff is in the
business of assisting unclaimed property owners in recovering their unclaimed property from
various federal, state, county and city treasuries.
4. All conditions precedent to bringing this action have been performed or have occurred or been
waived.
GENERAL ALLEGATIONS
5. Plaintiff re-alleges and incorporates paragraphs 1-4 as if fully stated herein.
6. On or about December 14, 2011, for value received Defendant, DENNIS K. RODMAN executed
and delivered to ASSETS INTERNATIONAL, INC., an agreement (“Agreement”) wherein
Defendant retained Plaintiff to recover unclaimed property (“Property”) that Plaintiff had
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 10/4/2016 4:32:47 PM.****10.
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12.
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discovered in exchange for thirty percent (30%) of the Property's value(“Commission”). Attached
hereto as Exhibit “A” is the Agreement.
The Property that Plaintiff located was Property that belonged to Defendant and was held by the
Michigan Department of Treasury's Unclaimed Property Division.
The Agreement provides that Defendant will promptly return to Plaintiff any papers that Plaintiff
sends to Defendant which are necessary for the Property's recovery. The Plaintiff electronically
mailed to Defendant’s representative documents necessary for the Property's recovery
(‘Documents’). Pursuant to the Agreement, these documents disclosed to Defendant the nature
and location of the Property. Attached hereto as Exhibit “B” is the electronic mailing.
Despite numerous attempts to obtain the Documents, Defendant has failed to cooperate with
Plaintiff by not returning the necessary documents, as required by the terms of the Agreement.
Defendant has breached the Agreement by refusing to cooperate with Plaintiff in returning the
necessary documents or otherwise in complying with the terms of the Agreement.
Furthermore, the Agreement provides that in the event Defendant recovers the Property without
Plaintiff's involvement, the Plaintiff is still entitled to the Commission.
Upon information and belief, through a Freedom of Information Act (“FOIA”) Request and
Response thereto, Plaintiff has determined Defendant has recovered the Property without
Plaintiff's involvement. Attached hereto as Exhibit is the request for information under the
FOIA and the Response thereto.
Defendant has breached the Agreement by failing to pay the Commission entitled to be paid to
Plaintiff, pursuant to the terms of the Agreement.
The Property's value is Ninety Six thousand Fifty and 47/100 Dollars ($96,050.47).
The Plaintiff's fee pursuant to the Agreement is thirty percent (30%) of Ninety Six thousand Fifty
and 47/100 Dollars ($96,050.47), to wit; Twenty Eight Thousand Eight Hundred Fifteen and
14/100 Dollars ($28,815.14)
WHEREFORE, Plaintiff demands judgment against the Defendant, DENNIS K. RODMAN, inthe amount of Twenty Eight Thousand Eight Hundred Fifteen and 14/100 Dollars ($28,815.14), together
with prejudgment interest and court costs, attorneys’ fees and for any other relief that this Honorable
Court deems just and proper.
Dated this 16TH day of SEPTEMBER, 2016.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic service or US Mail this 16TH day of SEPTEMBER, 2016 to the following parties:
Bradford Cohen Law, Bradford Cohen, Esq., service.bclaw@gmail.com
*Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiff's counsel hereby designates its
primary & alternate email address(es) for the purposes of e-mail service as: courm@weltman.com
and groatty@weltman.com
Respectfully submitted,
WELTMAN, WEINBERG & REIS, CO. LPA
3705 MARLANE DRIVE
GROVE CITY, OHIO 43123
TEL: (954) 933-7762
BY:___/s/ Cheryl L. Burm
CHERYL L. BURM, ESQ.
FLA. BAR NO. 527777
FOR THE FIRM
WWR20848635EXHIBIT AVMAS. 19:48 = 973-249-0837 PRINCE MARKETING ‘GRP PAGE 82/02
AN AWARD
rw Assets Gaei0
Inter ational “WINNING COMPANY
This Agreement is entered into as of
Assets Intemational, L.L.C. Us” or “We.
6, 2011, between Dennis K. Redman (*You"), and
What You Wilt Do
‘You wil) promptly sign and return to Us f ly papers We send to You that help Us recover these Assets.
In exchange for disclosing the nature and [boation of the Asscts; We will receive an assignment, of one-
third of the Assets’ value (the “Commissi¢n"}. You will not be responsible for any cost whatsoever.
If We are unsnocessful in recovering th You will owe Us vothing.
You may use the information we disclose tp verify our legitimacy. You may not use this information
to recover the Assets without our involventent. If You recover the Assets without our involvement,
You will still owe Us the Commission.
Miscellaneous Items
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ines that any portion of this Agreement is invalid, that decision will not affect the
¢ Agreement. If either party commences litigation to enforce its rights, the prevailing
titled to reimbursement of legal fees.
“Us”
‘By: Michael J. Zwick
Its: President
Date: /2- 14frotr Date: December 6; 2011
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2423 Greenfield Road, Quite 301 * Southfield. Michigan 48075
Cithee: 248-557-4960 To) Free: 877-327-4199 6 Faxr 298-957-4971
wud ssers-international.comEXHIBIT BKathryn Anderson a _
Subject: FW: Assets International/Dennis K. Rodman (Out File No: 109069}
Attachments: 409069 Rodman MI CLAIM FORM 1 6 12 CCH pdf; SPOA 1 11.12 jes.pdf
From: Kathryn Anderson [mailto:kanderson@assets-intemnational.com] it
Sent: Wednesday, January 11, 2012 2:48 PM
To: ‘dprince@princemarketinggroup.com’
Ce: 'jsadier@assets-international.com'
Subject: Assets International/Dennis K. Rodman {Our File No. 0. 109069]
Dear Mr. Prince:
In order for Assets International to recover the assets that belong to Dennis K. Rodman, please have him sign and return
to my office the following attached documents:
* Unclaimed Property Claim Form (requires notarized signature); and
* Special Power of Attorney (requires notarized signature).
Also, please provide a copy of the following from Mr. Rodman:
« Photo identification (e.g. Driver's License}
* Social security document (e.g. Social Security Card, Medicare Card or tax document with financial information
redacted)
Please do not hesitate to contact me if you have any questions.
Very truly yours,
Kathryn E. Anderson, Esq.
Associate Counsel
Assets International, LLC
24123 Greenfield Road, Suite 301
Southfield, MI 48075
Telephone: 248-557-4960
Facsimile: 248-557-4571SPECIAL POWER OF ATTORNEY
This Special Power of Attorney gives Assets International, L.L.C. and/or Michael
J. Zwick (hereinafier “AI”) the authority to act as the agent and the power to locate,
receive or handle the return of unclaimed or forgotten revenue funds.
1, Dennis K. Rodman (liereinafter “Owner”), being fully capable under the law, do
hereby appoint Al as my attorney-in-fact.
AI shall act on Owner's behalf and in Owner’s name, place and stead, having the
power to locate, demand, recover, receive and hold the unclaimed funds and interest that
are due, payable or belonging to Owner being held by the State of Michigan, banks,
holding companies, transfer agents and/or entities in similar situated. This power of
attorney shall extend to any and all properties to which Owner is entitled. This power
shall include the authority to obtain access to records of Owner’s account(s). including,
but not limited to. Eaton Vance Michigan Municipals Fund.
Al’s power shall include the power to perform such incidental acts as are
reasonably required to complete the transaction(s), to the extent stated, or as limited by
applicable agency law.
This Special Power of Attorney shall become effective at 12:01 a.m. on the date
of execution below and shall terminate immediately upon the receipt and disbursement of
funds from the aforementioned accounts.
If any provision of this Special Power of Attorney is held inoperable or invalid, it
is the intention that all of the remaining provisions hereof shall continue to be fully:
operative and effective.
Dennis K. Rodman Date
Subscribed and sworn. to before me on . in
County, State of
My commission expires:
Signature:7008 (Rev 10/08) S 611943
4
Page
STATE OF MICHIGAN :
DEPARTMENT OF TREASURY |e" Seotund secs
Unciaimed Property Division Est Shares 6.0000}
1, Claimant information
RODMAN DENNIS Claimant's SS#/ FEF
C/O MICHAEL ZWICK 6
pa GREENFIELD RD SUITE 307 i's S884 FER
UTHFIELD Mi 48078 Daytime Phone
Please review and complete claimant and owner information above and sign affidavit below.
All claims over $50 must be notarized. Please allow $0 days processing time.
2. Documentation Required
Submit copies of your drivers license (or other governmental photo ID}, Social Security card, and any additional
documents requested én the enclosed Unclaimed Property Claim Form instruction document.
3, Affidavit
Under penalties of pequry, I certify that the information provided -on this claim form is true, and all supporting
documents presented are either original of true, unaltered capes of the original documents. Upon payment af
this clam, said claimant wil indemnify and hold harmless the State of Michigan, its Officers and Employees from
any damages, claims or iosses.of any kind resulting in payment of properties included in this claim.
Subscribed and swor before me this Signature(s} of Claimant(s}
day-6f __. 26.
Notary Public County State
My commission expires
Issued under PA # 29 of 1995. Filing is voluntary. No refund will be issued unless this form is completed
and filed.
Office use only:
Approval 1 203 4 §
Please retum claim form and aff require documents fo.
Michigan Department of Treasury
Uncisimed Property, Division
P.O Box 30758
Lansing, Mi 48909
beste 1472012 7.46:24AM a eaClaim 1D: 611943
Page 2
STATE OF MICHIGAN
UNCLAIMED PROPERTY CLAIM FORM eee
Reporting Company 48 DISTRICT COURT Property 1D 2168981
Property Type. OTHER COURT DEPOSITS Last Activity Date 12/31/1989
Account ¢ 847005
Besctation BONO Property Share Value
Check number Property Cash Value. $106.00
Name of Qvinet's ROOMAN DENNIS KEITH
Reporting Company EATON VANCE MICHIGAN MMUNICIPALS FUND Provertv ID 10320217
Property Type MUTUAL FUND SHARES: Last Actwnty Date 03/21/2005
Account # EATON VANCE MICHIGAN MUNI GL A #140
Desorption MICHIGAN AUNICIPALS FUND CL Property Share Value
Check umber Property Cash Value $95.545.07
Name of Owner's RODMAN DENNIS K
Réporting Company «—- MICHIGAN NATIONAL BANK CORP Property IO 2438870
Propeny Type SAVINGS ACCOUNTS Last Achaty Date” 0862/7990
Acaount # s02t2a67 34
Desenption STATEMENT SAVINGS Property Share Vaiue
Check number Property Gash Value. $5.40
Name of Owner's RODMAN DENNIS
Reporing Company OAKLAND UNIVERSITY Proper 10 2148807
Propety Type ROYALTIES PAYMENTS: Last Activity Date ‘wei2g/7989
Agcount ViZ924
Description CHECK Property Share Vaiue
‘Check pumber Property Cash Value: $400.00
Name of Owner's RODMAN DENNIS
Total Shares Claimed 0.00 Total Cash Claimed $96,050.47
besic 1412012 7.46 24AM eaeClaim
UNCLAIMED PROPERTY CLAIM FORM INSTRUCTIONS
SECTION 1 Make any necessary corrections to the name and eddress.
Print or type the claimant's social security number or FE# and telephone number
SECTION 2 Review the information in this section of the claim form and please provide the required
documentation for the items checked
4 Nedocumentation is necessary for this section at this time, (Skip to Section 3}
___ 8 Provide copies of each claimant's driver license and social security card. if you
do not have a driver license, provide any government photo ID such as a passport.
military 1D of State 1D tard. If you do not have a social security card, provide other
documents listing your social security number such as a pay stub, health insurance
card ar V¥-2 form. (if deceased, provide a copy of the death certificate.}
___ ©. List ALL Michigan addresses you have used, including business addresses.
Be sure to include route numbers and post office box numbers.
__. 0. Send written documentation showing the owner was due these funds from the reporting
comeany onthe last activity date shown {i.2.,. account staternents, employment records,
contracts, safe deposit box statements or receipts, Michigan tax records or home heating
cred records)
___ = DEMUTUALIZED INSURANCE COMPANIES ~ Sen documentation, verifying ownership of
ihe demutualization funds from.
MetLife 1-800-638-9852. Prudentiat 1-600-243-1701, John Hancock 1-800-732-5543
___F. SECURITIES — Send the ORIGINAL stock or bond certificate along with the completed
claim form You may wish to return them by certified or registered mail
- if you are no longer in possession of the original certificate, provide a written: explanation
plus documentation. you owned the security (i e., 1099 forms)
- You may also be required to obtain. a surety bond for the amount you are Claiming,
_1.& Send a copy of your mutual fund account statement or 1099 form
___H. VENDOR. PAYROLL OR OTHER CHECKS - Send the original check along with the
completed claim form. OR. if you do not have the original check, provide supporting
documents associating you with the issuer of the check on the last activity date shown fie.
1099 cr W-2 farms. contracts. tax returns. invoices, etc.).
__i CERTIFIED CHECKS, CASHIER'S CHECKS AND MONEY ORDERS ~ Send the originat
check along with the completed claim form
Jj
SECTION 3 Clamant must sigh where indicated ALL owners must sign joint claims. Claims over $50 or
claims for shares of stock must be notarized.
We must receive the ORIGINAL claim form: a copy is not acceptable. All completed claims, regardless of the
numer of times previously submitted, are processed in the order they are received in our office
When you have completed your claim, piease mail it and the documentation checked above to the address below
Please allow 90 days for processing
Michigan Department of Treasury, Unclaimed Property Division, P.O. Box 30756, Lansing MI 48909
Monday — Friday, 10.00 a.m. - 4:30 p.m., (517) 636-5320
out