RESPONSE TO: PLTS MOTION FOR SANCTIONS FOR THE INTENTIONAL SPOLIATION OF EVIDENCE F/B DFTS ALBERTO VENEZIA AND MICHELLA VENEZIA PRO SE - PLTS MOTION FOR SANCTIONS FOR THE INTENTIONAL SPOLIATION OF EVIDENCE F/B DFTS ALBERTO VENEZIA AND MICHELLA VENEZIA PRO SE - BAREJO USA INC V VENEZIA, ALBERTO

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On November 26, 2018 a business transaction case was filed by Barejo Usa Inc, represented by Meredith B Plummer, against Alberto Venezia, Bio Bubble Pets Llc, and Michella Venezia, in the jurisdiction of Palm Beach County. Judge Howard K. Coates, Jr. presiding.

                        
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                          Filing # 108395865 E-Filed 06/04/2020 02:09:02 PM

IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No.502018CA014820XXXXMB

BAREJO USA INC., a Delaware Corporation,
Plaintiff,

v.
ALBERTO VENEZIA and MICHELLA VENEZIA
and BIOBUBBLE PETS LLC, Nominal Defendant

Defendants.

DEFENDANTS ALBERTO VENEZIA AND MICHELLA VENEZIA
RESPONSE TO PLAINTIFF'S MOTION FOR SANCTIONS FOR THE

INTENTIONAL SPOLIATION OF EVIDENCE

Defendants Alberto Venezia and Michella Venezia, self represented parties, hereby file their
response to Plaintiff's Motion to for Sanctions for the Intentional Spoliation of Evidence which

is scheduled to be heard in Division AN on June 12, 2020 and in support state the following.

INTRODUCTION

1. On November 26, 2018, the Plaintiff, Barejo USA inc., filed a complaint naming the
Defendants, Mr. and Mrs. Venezia to an action for the Judicial Dissolution of a Company in
which the Plaintiff and the Defendants are both Members and Manager…