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¥ FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/22/2014 4:27:18 PM.***#*
Filing # 9438854 Electronically Filed 01/22/2014 04:27:20 PM
IN THE COUNTY COURT IN AND
FOR BROWARD COUNTY, FLORIDA
CHAPEL TRAIL ASSOCIATES, LLC., a Florida
Limited Liability Company, CASE NO, 12-22491 COCE 52
Plaintiff,
v.
SOUTH BEACH CONCESSIONS
INCORPORATED, a Florida Corporation; and AUTHENTICATING AFFIDAVIT IN
ERIC ADAMS, Individually. SUPPORT OF PLAINTIFF'S
MOTION FOR CONTEMPT
Defendants.
STATE OF FLORIDA )
COUNTY OF BROWARD )
BEFORE ME, the undersigned authority, personally appeared NICOLE MEDINA
("Affiant'), as Records Custodian for Russell D. Kaplan, P.A., attorneys for CHAPEL TRAIL
ASSOCIATI Fjorida Limited Liability Company (“CHAPEL TRAIL” or “Plaintiff’),
who being known to mer who presented as identification and who after
being duly cautioned and sworn, upon oath, deposes and says as follows:
1. Described in the table below and attached hereto are true copies of documents
and correspondence relating to the post-execution Settlement Agreement between the
parties.
TABLE OF CONTENTS - POST EXECUTION SETTLEMENT AGREEMENT
Exb. # Date Description/Title of Document
1 40/17/13 Defendants’ Emergency Motion Release Food Truck...
2 1073 Order denying Defendants' Emergency Motion to Release Food
Truck...
3 1273 Post-execution Settlement Stipulation embodied in email from
Defendants’ counsel attaching signed: (A) Joint Motion for Entry of
Agreed Order Adopting the Parties’ 12/17/13 Letter Agreement;
and (B) signed Letter Agreement.
4 12/17/13 Email from Plaintiff's counsel accepting the and agreeing to the
Post-execution Settlement Stipulation
5 1273 Email letter from Plaintiff's counsel's office to Sheriff cancelling
sale in accordance with Post-execution Settlement Stipulation
(Item 3B above)12/18/13
Agreed Order adopting Post-execution Settlement Stipulation
(Item 3B above)
12/24/13 -
12/26/13
Email exchange between counsel for both sides regarding
Defendants’ failure to comply with the Post-execution Settlement
Stipulation and discussing how to proceed
12/30/13
Email exchange between Plaintiff and Defendants modifying Post-
execution Settlement Stipulation, calling for Plaintiff to advance
storage fees and further protocol for delivery and iater sale of the
Food Truck
qTH4
Email exchange between Defendants and Plaintiff's counsel's
office whereby Defendant advised of the suspension of his drivers
license and Plaintiff's counsel's office suggesting a designated
driver
19
14114
Email from Defendants’ counsel to Defendants advising that
Plaintiff will advance $500 for the pick-up and delivery of the Food
Truck and title documents by 1/17/14
11
116/14
Email exchange between Plaintiff's counsel and the Defendant,
confirming that Defendants accept the $500 offer, have a
designated driver and will deliver the Food Truck the next day
(Friday 1/17/14)
12
47/14 -
2114
Text messages between Defendants and Nicole Medina at
Plaintiff's counsef's office regarding pick up of the Release from
the Sheriff, and delivery of the Food Truck.
13
1122/14
Defendants Motion to Suspend Stipulation Agreement (90) days
{although dated and filed on 1/6/14, not detivered to or received by
Plaintiff's counsel until 1/22/14 via email).
LL KAPLAN
Senior? EE 217514
Expires September 17, 2016
Bowed Tr Tn oi rare BOOBS TONS
‘YeCHAPEL TRAIL'Sant Beach ConcessoasLEVY (FOOD TRUCK ANIA Aisheenai NM#1In the County Court in and for Broward County, Florida
Chapel Trial Associates LLC
Plaintiff Case No: COCE-12-022491
vs.
Judge: Unassigned Division
South Beach Concessions Incorporated, et al Division: 52
Defendant
"\
Emmergen f Ran Ta Tk hn aly Die
epigeotns vl ions a
honorable court to fic Wr Glens = e Tollowing reason(s):
oS e Shace Ress Steed +e oped 1 coil hed my
Ge aes never to be doadsidered Collah Hera \ In
int Cee. Doe 4a the beilding was lensed and used te be
a Conkew Fe the Crby OF Rerbole Ares and only Secved as
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Was aed oF Doce Cov tA7IS Sw ind Pi, Miami , Elericte
3312 thi pico ate Fee over three Years eons
aareed and Issved a& Final Kagement Sprondadelthosbo =
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Cel obeys nay : yas
anno Ye Ip toes that E arranged monthly Payne
CH TERS In Done 2013. HE Paytzteo"” Morthly @hildsupfe
(arson tt seats and cortect spnestt of the foregoing was mailed to plaintiffidefendant
Tat fae Ly / |
Comes now,
one LL be whoo, 12-12-2013
Telephone =
BY 263 7777
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#19, 000 Ato 7 ce my hod trved. /,
Please rant the. order :
Me. a Chapel Trail Be responsible. tor fewing
and storage 4oea -Te Magni Dock Lowy Ir wrong ef
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eile me. Jor Ary ae posttiord BY DFS P02 S
Erie Adam? :
$2e-4 400/200'd eh
HOdd VPS? E102-Z1-190#2IN THE COUNTY COURT
INAND FOR Brow
COUNTY, FLORIDA
CHAR TCAIL FROLIATES,
itce.- CaseNo: | Q-aaYQ) CaLEe Sa
Plas ONE, )
Vv. )
Sour Seren ae
ane, er. al.
“Wheto tts,
ORDER
‘THIS CAUSE having come on to be heard on Defendant's/Plaintit's [O- 17+ tS
Ensrceny hear Hig,
Motion ‘ko eQeasse Loc] Truck “Plackt eecorys br hy se
and the Court having heard argument of counsel, and being otherwise advised Tous N44 Fh Kors.
in the Premises, it is hereupon,
ORDERED AND ADJUDGED. that said Motion be, and the same is hereby
denecl, ao The 4 ny lboal four: fe. ths pm tte,
DONE AND ORDERED in oO
this, LZ say ot _ OF / 2aAD
Copies turnished:
RUSE O- MalanjEX-
WAtnvAars -Page | of I
RDKPA
From: lenard@gormanpa.com
Sent: Tuesday, December 17, 2013 4:12 PM
To: RDKPA.
Ce: tusshome@bellsouth.net; Eric Adams (eadams2698@icloud.com)
Subject: south beach
Attachments: 2013_12_17_16_08_21.pdf 2013_12_17_16_08_58.pdf
Enclosed are signed motion and signed agreement.
Lenard H. Gorman, Esquire
Lenard H. Gorman, P.A.
One Datran Center, Suite 1800 (new suite no.)
9100 South Dadeland Boulevard
Miami, Florida 33156-7800
Tel. (305) 670-0876
Fax (305) 670-0347
This transmission (including any attachments) is intended to be
delivered only to the named addresse(s) and may contain information
which is confidential, proprietary, attorney work-product or attorney-
client privileged. If this notification is received by anyone other
than the intended recipient(s), the recipient{s) should immediately
notify the undersigned by E-MAIL and by telephone and obtain
instructions as to the disposal of the transmitted material. In no
event shall this material be read, used, copied, reproduced, stored or
retained by anyone other than the intended recipient(s) except with
the express written consent of the sender. Thank you.
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2013.0.3462 / Virus Database: 3658/6953 - Release Date: 12/27/13
1/22/2014IN THE COUNTY COURT IN AND
FOR BROWARD COUNTY, FLORIDA
CHAPEL TRAIL ASSOCIATES, LLC., a Florida
Limited Liability Company, CASE NO. 12-22491 COCE 52
Plaintiff,
v. INT Mi ORE)
SOUTH BEACH CONCESSIONS UnGPre vie eerie
INCORPORATED, a Florida Corporation; and
ERIC ADAMS, Individually. 12/17/13 LETTE
A ENT
Defendants.
/
Plaintiff, by and through its undersigned attorney and Defendants, file this Joint
Motion for Entry of Agreed Order Adopting the Parties’ 12/17/13 Letter Agreement, and
states as follows:
gorman, Esq., herein makes appearance on behaif of the Defendants
Motion as evidenced by his signing and dating here _ +2}
2 The parties have agreed to the entry of an Order in the form attached hereto
as Exhibit "A”.
Wherefore, Plaintiff and Defendants respectfully request this Honorable Court enter
an Order adopting the Parties' 12/17/13 Letter Agreement, retaining jurisdiction for
enforcement of same, and such other further relief as this Court deems just and
appropriate.
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
forwarded by E-Mail this___ day of December, 2013 To: Lenard H. Gorman, Esq.,One
Datran Center, Suite 1800, 9160 South Dadeland Boulevard, Miami, Florida 33156
(email: lenard@gormanpa.com).
RUSSELL D. KAPLAN, P.A.
Attorneys for Plaintiff
750 Southeast 3rd Avenue, Suite 100
Fort Lauderdale, Florida 33316
954-763-7777ph 954-763-2920 fax
rtdkpa@bellsouth,net
By:
RUSSELL D. KAPLAN, ESQUIRE
Fla. Bar No. 500895Russ, as you know | represent South Beach Concessions, Inc. and Eric Adams (the
“Defendants"). | have their full and irrevocable authority to enter into this letter
agreement on behalf of the Defendants. You represent Chapel Trail Associates
LLC. (the "judgment creditor") and further represent that you have full and
irrevocable authority to enter into this letter agreement on behaif of the judgment
creditor. Please confirm that you agree to the terms of this letter agreement by
sending me a reply e-mail to that effect. The terms of this letter agreement are
as follows:
1. On or before 12/27/13, South Beach Concessions, Inc. will transfer title to the
food truck by Bill of Sale and Certificate of Title in blank to the judgment creditor,
Chapel Trail Associates, LLC, At the same time, the Defendants shall deliver to
the judgment creditor all keys to the food truck and all paperwork related to the
maintenance of the vehicle, the history of the vehicle and any improvements
constructed therein. Defendants warrant and represent that they have not, nor
will they: a] assign to others the rights to be transferred hereunder; b] remove
any property (tangible or intangible) from the food truck; or c] retain any keys or
paperwork related to the vehicle, following the above mentioned turnover of
same to the judgment creditor.
2. — The judicial sale of the food truck will be cancelled.
3. The judgment creditor will sell the food truck, and from the proceeds, it will be
paid the amount of the 9/25/13 judgment ("Judgment"), plus accrued interest, the
costs incurred with the Sheriff, inctuding any storage fees (which had been paid
at the time of pickup by the Defendants), its attorneys’ fees through the date of
sale, and the expenses of sale. From the sale proceeds, if no sales commission
is incurred, the judgment creditor shall receive an additional 20% from the net
sales proceeds (not the gross proceeds) for its efforts to sell same ("Marketing
Fee’). In the event that sales commissions are incurred, the Marketing Fee shall
be reduced to 15% of the net sales proceeds. The balance of the sale proceeds
shail be paid to the judgment debtor.
4. The vehicle shall be stored by the judgment creditor at no cost (for the first 45
days) during the sales period or delivered to a sales facility for sale. It is believed
that the best time to sell the food truck is in February 2014, and therefore, the
judgment creditor is authorized to wait until then to sell the vehicle. The
Defendants shall keep the vehicle fully insured through the end of February 2014
and provide proof of such insurance upon request.
5. Upon payment of the judgment creditor, a partial or full (as applicable)
Satisfaction of Judgment shall be issued.
6. An agreed order shall be entered authorizing and directing Eric Adams, as
President of South Beach Concessions, Inc., to transport the vehicle to a designated
focation. Under no circumstances are either of the Defendants authorized to transportthe vehicle to any other location or for any other journey. At or before the time of
transport, Defendants shall pay all outstanding storage and towing fees to the Sheriffs
designee. Defendants are advised to do so on or before 12/19/13, as the towing yard
(Dixie Transport) shuts down early for the Christmas holiday.
7. While the parties have been told that under the right circumstances the food truck
could be sold for an amount far in excess of the Judgment and related costs, neither of
the parties is in the position to represent or guaranty same. The parties acknowledge
the possibility that the proceeds from the sale of the truck might not be sufficient to
satisfy the judgment and related costs.
8. Except as otherwise provided below, neither the existence of this Agreement nor
any efforts on the part of the parties to sell the food truck shall serve to release the
Defendants from the amounts due Chapel Trail under the Judgment. Nor shall the
existence of this Agreement require Chapel Trail to forbear in the collection of the
amounts due from the Defendants.
9. Notwithstanding the fact that the sale of the food truck would benefit the parties,
under no circumstances shall the judgment creditor, its law firm, broker or any other
designees be liable to the Defendants or other persons or entities for any claims related
to their action or inaction in pursuit of the sale of the food truck. In all efforts to sell or
market the food truck, the Defendants shall provide their full cooperation. While the
judgment creditor may choose to consult with the Defendants regarding issues related
to the sale of the food truck, ultimately, the judgment creditor will have the final say.HAPage 1 of 2
RDKPA
From: ‘enard@gormanpa.com
Sent: Tuesday, December 17, 2013 4:38 PM
To: RDKPA
Ce: Eric Adams (eadams2698@icloud.com)
Subject: RE: south beach
Thank you
Lenard H. Gorman, Esquire
Lenard H. Gorman, P.A.
One Datran Center, Suite 1800 (new suite no.)
9100 South Dadeland Boulevard
Miami, Florida 33156-7800
Tel. (305) 670-0876
Fax (305) 670-0347
This transmission (including any attachments) is intended to be
delivered only to the named addresse(s) and may contain information
which is confidential, proprietary, attorney work-product or attorney-
client privileged. If this notification is received by anyone other
than the intended recipient(s), the recipient(s) should immediately
notify the undersigned by E-MAIL and by telephone and obtain
instructions as to the disposal of the transmitted material. In no
event shail this material be read, used, copied, reproduced, stored or
retained by anyone other than the intended recipient(s) except with
the express written consent of the sender. Thank you.
From: RDKPA [mailto:rdkpa@bellsouth.net]
Sent: Tuesday, December 17, 2013 4:28 PM
To: lenard@gormanpa.com
Cc: spot@chapeltrailleasing.com
Subject: RE: south beach
Len
Recived, Thank you for the signed Letter Agreement accurately reflecting the agreement between the parties.
You can consider this reply Mr. Kaplan’s agreement and acceptance of same. | will submit the Motion and Agreed
Order tomorrow for entry and send a letter to the Sheriff cancelling the sale now.
Sincerely,
SNieole Medina
Russell D. Kaplan, P.A.
750 SE 3rd Avenue, Suite 100
Ft. Lauderdale, FL 33316
Tel: 954-763-7777
Fax: 954-763-2920
Idkpa@pbelisouth.net
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If
you are not the intended recipient, you must not review, retransmit, convert te hard copy, copy, use or disseminate this e-mail or any
1/22/2014Page 2 of 2
attachments to it, If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-777 and
delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the
contents of this message or any attachments may not have been produced by the sender.
From: fenard@gormanpa.com [mailto:lenard@qormanpa.com]
Sent: Tuesday, December 17, 2013 4:12 PM
To: RDKPA
Cc: russhome@beilsouth.net; Eric Adams (eadams2698@icloud.com)
Subject: south beach
Enclosed are signed motion and signed agreement.
Lenard H. Gorman, Esquire
Lenard H. Gorman, P.A.
One Datran Center, Suite 1800 (new suite no.'
9100 South Dadeland Boulevard
Miami, Florida 33156-7800
Tel. (305) 670-0876
Fax (305) 670-0347
This transmission (including any attachments) is intended to be
delivered only to the named addresse(s) and may contain information
which is confidential, proprietary, attorney work-product or attorney-
client privileged. If this notification is received by anyone other
than the intended recipient(s), the recipient(s) should immediately
notify the undersigned by E-MAIL and by telephone and obtain
instructions as to the disposal of the transmitted material. In no
event shall this material be read, used, copied, reproduced, stored or
retained by anyone other than the intended recipient(s) except with
the express written consent of the sender. Thank you.
1/22/2014#5Page | of 1
RDKPA
From: RDKPA [rdkpa@bellsouth.net]
Sent: Tuesday, December 17, 2043 4:35 PM
To: ‘cjohnson@mdpd.com'
Ce: ‘lenard@gormanpa.com’
Subject: Chapel Trail v, South Beach Concessions - Cancellation of Levy of Food Truck scheduled for
12/18/13
Dear Chartean
Please consider this letter notice to cancel the Sheriff's Sale scheduled for tomorrow, 12/18/13, of the Food Truck
in connection with the above referenced Broward County case Number: 12-22491 COCE 52. Please prepare the
proper Reiease, releasing the Food Truck to the Defendant, Eric Adams, Authorized Agent of South Beach
Concessions, Inc., and forward same to Dixie Transport. Mr. Adams will make arrangements to pick-up the Food
Truck and pay the storage and towing fees upon pick-up on or before 12/23/13.
If you should need anything further, please contact me. Thank you very much for your assistance in this matter.
Sincerely,
Nicole Medina
Russell D. Kaplan, P.A.
750 SE 3rd Avenue, Suite 100
Ft. Lauderdale, FL 33316
Tal: 954-763-7777
Fax: 954-763-2920
rdkpa@bellsouth.net
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If
you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any
attachments to it. ff you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and
delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the
contents of this message or any attachments may not have been produced by the sender.
1/22/2014#6IN THE COUNTY COURT IN AND FOR
BROWARD COUNTY, FLORIDA
CHAPEL TRAIL ASSOCIATES, LLC., a Florida
Limited Liabitity Company, CASE NO. 12-22491 COCE 52
Plaintiff,
v.
SOUTH BEACH CONCESSIONS
INCORPORATED, a Florida Corporation; and ERIC
ADAMS, Individually. AGREED ORDER
Defendants.
i
THIS CAUSE having come before the Court pursuant to the 12/17/13 Joint Motion for entry
of this Order and the parties 12/17/13 Letter Agreement (the “Letter Agreement”), and the Court
being otherwise advised in the premises, the Court hereby finds and orders that:
1. Pursuant to the parties’ 12/17/13 Letter Agreement, Plaintiff cancelled the Sheriff's
Sale scheduled for 12/18/13. Defendants are ordered to pick up the Food Truck from Sheriff or
its designee, Dixie Transport, located at 5520 NE 4" Avenue, Miami, FL, and deliver to Plaintiff,
Chapel Trail Associates, LLC, at 21011 Johnson Street, Pembroke Pines, FL and do so no later
than December 23, 2013. Under no circumstances are either of the Defendants authorized to
transport the vehicle to any other location or for any other journey.
2. At the time of pickup, the Defendants shall pay the Sheriff, or its designee Dixie
Transport, any outstanding towing and storage charges. At! time of delivery, Defendants will
surrender to the judgment creditor all keys to the food truck and all paperwork related to the
maintenance of the vehicle, the history of the vehicle and any improvements constructed therein.
Defendants warrant and represent that they have not, nor by this Order shail they: a] assign to
others the rights to be transferred to the Plaintiff under the Letter Agreement; b] remove any
property (tangible or intangible) from the feod truck; or c] retain any keys or paperwork related to
the vehicle, following the above mentioned turnover of same to the judgment creditor,
3. The Defendants shall keep the vehicle fully insured through the end of February
2014 (unless otherwise agreed in writing) and provide proof of such insurance upon request.
| / DONE AND, ORDERED in Chambers at Fort Lauderdale, Broward County, Fiorida this
day of Hh Og , 2013,
COUNTY COURT JUDGE ©
Copies Furnished to: " ai 5
Russell D. Kaplan, Esq. Cy ”
Lenard H. Gorman, Esq Ae 8 ny,
es ?
ey
‘ePage | of 3
RDKPA
From: lenard@gormanpa.com
Sent: Thursday, December 26, 2013 7:33 PM
To: RDKPA
Ce: Eric Adams
Subject: Re: Eric
Follow Up Flag: Follow up
Flag Status: Compieted
No response yet. You need to proceed in the manner you deem appropriate.
Sent from my iPhone
On Dec 26, 2013, at 2:38 PM, "RDKPA" wrote:
Still no word?
And why should | not seek contempt sanctions?
Sincerely,
Raseelt Kaplan
Russel D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
(954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential
information that may be legally privileged. If you are not the intended recipient, you must not review,
retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you
have received this e-mail in error, please notify us immediately by return e-mail or by telephone at
954-763-7777 and delete this message. Please note that if this e-mail message contains a
forwarded message or is a reply to a prior message, some or all of the contents of this message or
any attachments may not have been produced by the sender.
From: lenar¢@gormanpa.com [mailto:lenard@gormanpa.com’
Sent: Tuesday, December 24, 2013 10:49 AM
To: RDKPA
Ce: Eric Adams
Subject: Re: Eric
No.
Sent from my iPhone
1/22/2014Page 2 of 3
On Dec 24, 2013, at 8:43 AM, "RDKPA” wrote:
1/22/2014
Or should | seek contempt sanctions?
Sincerely,
Russell Kaplan
Russell D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
(954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains
confidential information that may be legally privileged. If you are not the intended
recipient, you must not review, retransmit, convert to hard copy, copy, use or
disseminate this e-mail or any attachments to it. If you have received this e-mail in
error, please notify us immediately by return e-mail or by telephone at 954-763-7777
and delete this message. Please note that if this e-mail message contains a forwarded
message or is a reply to a prior message, some or all of the contents of this message
or any attachments may not have been produced by the sender.
From: lenard@qormanpa.com [mailto:lenard@gormanpa.com]
Sent: Tuesday, December 24, 2013 10:30 AM
To: RDKPA
Ce: Eric Adams
Subject: Re: Eric
I have not received a response from him.
Sent from my iPhone
On Dec 24, 2013, at 7:52 AM, "RDKPA" wrote:
Len, where are we on this?
Sincerely,
Russell Keplan
Russeil D. Kaplan, P.A.
750 S,E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 {phone)
(954} 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-maii
message contains confidential information that may be legally privileged.
If you are not the intended recipient, you must not review, retransmit,
convert te hard copy, copy, use or disseminate this e-mail or anyPage 3 of 3
attachments to it. If you have received this e-mail in error, please notify
us immediately by return e-mail or by telephone at 954-763-7777 and
delete this message. Please note that if this e-mail message contains a
forwarded message or is a reply to a prior message, some or all of the
contents of this message or any attachments may not have been
produced by the sender.
No virus found in this message.
Checked by AVG - www.avy.com
Version: 2013.0.3462 / Virus Database: 3658/6945 - Release Date: 12/23/13
No virus found in this message.
Checked by AVG - www.ayg.com
Version: 2013.0.3462 / Virus Database: 3658/6945 - Release Date: 12/23/13
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1/22/2014#8Page | of 4
RDKPA
From: Eric Adams [eadarms2698@gmail.com]
Sent; Monday, December 30, 2013 11:20 AM
To: RDKPA
Subject: Re: FW: south beach
I agree to the new modification embodied in the email.
On Mon, Dec 30, 2013 at 10:25 AM, RDKPA wrote:
Eric, we need to wrap this up today. If you have more questions, call me this morning.
Otherwise, please send me an e-mail agreeing to the Modification embodied in the e-mail
below.
Sincerely,
Raseelt Kaplan
Russell D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
(954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information
that may be tegally privileged. If you are not the intended recipient, you must not review, retransmit, convert to
hard copy. copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in
error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message.
Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or
all of the contents of this message or any attachments may not have been produced by the sender.
On Fri, Dec 27, 2013 at 11:51 AM, RDKPA wrote:
Dear Eric:
Leonard has authorized me to communicate with you directly regarding the parties’ recent settlement,
embodied in the three documents attached ("Settlement Agreement"). Both attorneys believe that they
had the absolute and irrevocable authority of their clients to enter into the Settlement Agreement. For
whatever reason, you have not acted in accordance with the Settlement Agreement, meanwhile
storage charges for the vehicle continue to accrue a $25 a day further eroding any equity in the vehicle.
Asan alternative to my asking the Court to enforce the Court Order (attached) and/or finding you in
contempt for violating same, | have authority from my client to offer you the following modification to
the Settlement Agreement {the “Modification”):
1] Storage Fees. Plaintiff (not you) would pay the storage charges necessary to release the vehicle,
provided: a] same would be reimbursed to the Plaintiff at the time of sale of the vehicle; b] Plaintiff's
Marketing Fee would remain at 20% regardless of whether a sales commission was paid to a third-
party; and c] you would pick up and deliver the vehicle to Chapel Trail within 48 hours of cur request.
1/22/2014Page 2 of 4
2] Delivery. Eric will delivering the truck, its contents, the keys and the paperwork (bill of sale and title
certificate endorsed in blank) during business hours within 48 hours of Plaintiff's request. Two hours
before delivery, Eric will give a “heads up" call to Chape! Trail (954-436-9000) and ask for Chris.
3] Minimum Sales Price. Through 2/15/14, Plaintiff will agree not to sell for less than the agreed-upon
minimum, give or take 10%. The agreed-upon minimum shall be $45,000 or the written valuation for the
vehicle given by a broker (selected by the Piaintiff) who has inspected the vehicle (or other expert hired
by the Plaintiff), whichever is less. If the vehicle does not sell for the agreed-upon minimum (give or take
40%) by 2/15/14, Plaintiff is free to seil the vehicle for whatever price Plaintiff deems appropriate.
4] Storage Charges. To the extent that it is necessary or advantageous to store the vehicle at
Plaintiffs location, Plaintiff agrees to provide such storage rent-free through 2/15/14. Thereafter, Plaintiff
shall be entitled to charge a reasonable rental charge not to exceed the monthly rental rate previously
paid by the Defendants to the Plaintiff.
5} Timely Acceptance. Defendants can accept this Modification by sending a reply e-mail saying
“agreed” or something to that effect and by doing so within 3 days of today. By accepting the
Modification, Defendants: a] ratify and agree to the Settlement Agreement (embodied in the three
documents attached), as changed by the Modification: and b] authorize the Plaintiff to submit a modified
Agreed Order to the Court, reflecting those changes. Should Defendants fail to timely and properly
accept the Modification, Defendants should consider the offer of the Modification to be withdrawn.
Sincerely,
Reuseld Kigolan
Russel! D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft, Lauderdale, Fiorida 33316
(954) 763-7777 (phone)
(954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential
information that may be legally privileged. If you are not the intended recipient, you must not review,
retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you
have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-
763-7777 and delete this message. Please note that if this e-mail message contains a forwarded
message or is a reply to a prior message, some or all of the contents of this message or any
attachments may not have been produced by the sender.
Sincerely,
Russell Kiplan
Russel! D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
{954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential
information that may be legally privileged. If you are not the intended recipient, you must not review,
retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you
have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-
763-7777 and delete this message. Please note that if this e-mail message contains a forwarded
message or is a reply to a prior message, some or all of the contents of this message or any
attachments may not have been produced by the sender.
1/22/2014Page 3 of 4
From: lenard@gormanpa.com [mailto:lenard@gormanpa.com]
Sent: Tuesday, December 17, 2013 4:12 PM
To: RDKPA
Cc: russhome@bellsouth.net; Eric Adams (eadams2698@icloud.com)
Subject: south beach
Enclosed are signed motion and signed agreement.
Lenard H. Gorman, Esquire
Lenard H. Gorman, P.A.
One Datran Center, Suite 1800 (new suite no.)
9100 South Dadeland Boulevard
Miami, Florida 33166-7800
Tel. {305} 670-0876
Fax (305) 670-0347
This transmission (including any attachments) is intended to be
delivered only to the named addresse(s) and may contain
information which is confidential, proprietary, attorney work-
product or attorney-client privileged. If this notification is
received by anyone other than the intended recipient(s), the
recipient (s) should immediately notify the undersigned by E-MAIL
and by telephone and obtain instructions as to the disposal of
the transmitted material. In no event shall this material be
read, used, copied, reproduced, stored or retained by anyone
ether than the intended recipient(s) except with the express
written consent of the sender. Thank you.
No virus found in this message.
Checked by AVG - www.ave.com
Version: 2013.0.3462 / Virus Database: 3658/6953 - Release Date: 12/27/13
1/22/2014#9Page 1 of 4
RDKPA
From: RDKPA [rdkpa@bellsouth.net]
Sent: Tuesday, January 07, 2014 11:33 AM
To: "Eric Adams’
Ce: spot@chapeltrailleasing.com; ‘lenard@gormanpa.com'
Subject: RE: FW: south beach
Hi Eric
In tight of your new drivers license issue, and due to the fact that you have beein directed by Cout Order to deliver
the truck to chapel Trail, we ask that you find a friend to drive together with you and deliver the truck to Chapel
Trail? Piease get back to me promptly to confirm when you can accomplish this either today or tomorrow. Thank
you.
Sincerely,
Nicole Medina
Russell D. Kaplan, P.A.
750 SE 3rd Avenue, Suite 100
Ft. Lauderdale, FL 33316
Tel: 954-763-7777
Fax: 954-763-2920
rdkpa@bellsouth net
NOTICE: This e-mail message and any attachment to this e-mail message contains confidentiat information that may be legally privileged. If
you are not the intended recipient, you must not review, retransmit, convert to hard copy. copy, use or disseminate this e-mail or any
attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and
delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the
contents of this message or any attachments may not have been produced by the sender.
From: Eric Adams [mailto:eadams2698@gmail.com]
Sent: Monday, January 06, 2014 10:56 AM
To: lenard@gormanpa.com
Cc: RDKPA; spot@chapeltrailleasing.com
Subject: Re: FW: south beach
Hello to all: ] am advised by the Florida department of children and family that my driving license
suspended due to failure to keep up with child support as of 09/2013. And to make matters worst
Florida department of revenue advised that a judgment tax lien has been filed against me and south
beach concession. I am headed to family court now. Will keep u up to date of the ffollowing.
On Monday, December 30, 2013, lenard@gormanpa.com wrote:
> J glad to see that this is resolved.
>
>
>
> Lenard H. Gorman, Esquire
>
> Lenard H. Gorman, P.A.
>
> One Datran Center, Suite 1800 (new suite no.)
1/22/2014Page | of 1
RDKPA
From: lenard@gormanpa.com
Sent: Tuesday, January 14, 2014 12:33 PM
To: Eric Adams (eadams2698@icloud.com)
Ce: RDKPA
Subject: south beach
Follow Up Flag: Follow up
Flag Status: Purple
the landlord is willing to advance you up to $500 for you to pick up the truck and deliver it as agreed. the monies
will be paid upon delivery of the truck, together with the title documents. please contact russell kaplan to
arrange the foregoing. this must be accomplished by friday, january 17.
Lenard H. Gorman, Esquire
Lenard H. Gorman, P.A.
One Datran Center, Suite 1800
9100 South Dadeland Boulevard
Miami, Florida 33156-7800
Tel. (305) 670-0876
Fax (305) 670-0347
This transmission (including any attachments) is intended to be delivered
only to the named addresse(s) and may contain information which is
confidential, proprietary, attorney work-product or attorney-client
privileged. If this notification is received by anyone other than the
intended recipient(s), the recipient(s) should immediately notify the
undersigned by E-MAIL and by telephone and obtain instructions as to the
disposal of the transmitted material. In no event shall this material be
read, used, copied, reproduced, stored or retained by anyone other than the
intended recipient(s) except with the express written consent of the sender.
Thank you.
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2013.0.3462 / Virus Database: 3658/6999 - Release Date: 01/13/14
1/22/2014#11Page 1 of 2
RDKPA
From: RDKPA [rdkpa@bellsouth. net]
Sent: Thursday, January 16, 2014 3:15 PM
To: "Eric Adams’
Ce: ‘lenard@gormanpa.com’; ‘spot@chapeltrailleasing.com’; 'Teresa Rourke’
Subject: Delivery of the Food Truck Tomorrow
Eric and Michael:
Here is the protoco! that you will follow regarding tomorrow's delivery of the vehicle:
1] Eric, 30 minutes before you expect to arrive at Chapel Trail, you wiil call Chape! Trail (954-436-9000) and give
them your ETA;
2] Eric, you will drive the truck to unit #122 (20911 Johnson St.);
3) Marty or John from Chapel Trail wi!l meet you at unit#1 22 at the ETA you specified;
4) Eric will show Marty or John the VIN number on the vehicle and how it matches with the VIN number on
the Title Certificate;
5] Eric will park the truck in unit #122;
6] Eric will give Marty or John, the Bill of Sale and vehicle Title Certificate, both endorsed in blank (the "Title
Documents");
7] Marty or John will e-mail me (Russ) copies (front and back) of the Titled Documents for me to confirm that they
are in order;
8) Once t (Russ), confirm that the Title Documents are in order, Eric will give Marty or John the keys to the vehicle
and they in turn will give Eric the $500 promised.
Does everyone understand?
Sincerely,
Featael!, ‘Kiyolan
Russell D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
{954) 763-2920 (fax)
NOTICE; This e-mail message and any attachment to this e-mail message contains confidential information that
may be Jegaily privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard
copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error,
please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message, Please
note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the
contents of this message or any attachments may not have been produced by the sender.
From: Eric Adams [mailto:eadams2698@gmail.com)
Sent: Thursday, January 16, 2014 1:30 PM.
To: RDKPA
Subject:
I have someone who can drive the truck. I accept the offer for $500 it will assist me n the delivery of the
1/22/2014Page 2 of 2
truck. He can deliver the truck tomorrow.
No virus found in this message.
Checked by AVG - www.avz.com
Version: 2013.0.3462 / Virus Database: 3681/7007 - Release Date: 01/16/14
1/22/2014Page t of 2
RDKPA
From: eadams2698 feadams2688@gmail.com]
Sent: Thursday, January 16, 2014 3:49 PM
To: RDKPA
Ce: lenard@gormanpa.com; spot@chapeltrailleasing.com; "Teresa Rourke’
Subject: RE: Delivery of the Food Truck Tomorrow
I will not be driving the truck as to the status of my driving license. I need to review the bill of sale
Please send thanks. stave ssooneplauet deve i
woes Original message --------
From: RDKPA.
Date:01/16/2014 3:14 PM (GMT-05;00)
To: ‘Eric Adams‘
Ce: lenard@gormanpa.com,spot@chapeltrailleasing.com,'Teresa Rourke’
Subject: Delivery of the Food Truck Tomorrow
Eric and Michael:
Here is the protocol that you will follow regarding tomorrow's delivery of the vehicle:
1] Eric, 30 minutes before you expect to arrive at Chapel Trail, you will call Chapel Trail (954-436-9000) and give
them your ETA;
2] Eric, you will drive the truck to unit #122 (20911 Johnson St);
3] Marty or John from Chapel Trail will meet you at unit#122 at the ETA you specified;
4) Eric will show Marty or John the VIN number cn the vehicle and how it matches with the VIN number on
the Title Certificate;
5] Eric wil! park the truck in unit #122;
6] Eric will give Marty or John, the Bill of Sale and vehicle Title Certificate, both endorsed in blank (the ‘Title
Documents");
7] Marty or John will e-mail me (Russ) copies (front and back) of the Titled Documents for me to confirm that they
are in order;
8] Once | (Russ), confirm that the Title Documents are in order, Eric will give Marty or John the keys to the vehicle
and they in turn will give Eric the $500 promised.
Does everyone understand?
Sincerely,
Rasell, ‘Kiplan
Russell D. Kaplan, P.A.
750 S.E. 3rd Avenue, Suite 100
Ft. Lauderdale, Florida 33316
(954) 763-7777 (phone)
(954) 763-2920 (fax)
NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that
may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard
copy, copy, use or disseminate this e-mail or any attachments to it. ff you have received this e-mail in error,
please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please
note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the
1/22/2014Page 2 of 2
contents of this message or any attachments may not have been produced by the sender.
From: Eric Adams [mailto:eadams2698@gmail.com]
Sent: Thursday, January 16, 2014 1:30 PM
To: RDKPA
Subject:
I have someone who can drive the truck. ] accept the offer for $500 it will assist me n the delivery of the
truck. He can deliver the truck tomorrow.
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2013.0.3462 / Virus Database: 3681/7007 - Release Date: 01/16/14
No virus found in this message.
Checked by AVG - www.ayg.com
Version: 2013.0,3462 / Virus Database: 3681/7007 - Release Date: 01/16/14
1/22/2014#12< Back (1) (954) 288-7025 — Contact
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Preview
¥ FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/22/2014 4:27:18 PM.***#* Filing # 9438854 Electronically Filed 01/22/2014 04:27:20 PM IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CHAPEL TRAIL ASSOCIATES, LLC., a Florida Limited Liability Company, CASE NO, 12-22491 COCE 52 Plaintiff, v. SOUTH BEACH CONCESSIONS INCORPORATED, a Florida Corporation; and AUTHENTICATING AFFIDAVIT IN ERIC ADAMS, Individually. SUPPORT OF PLAINTIFF'S MOTION FOR CONTEMPT Defendants. STATE OF FLORIDA ) COUNTY OF BROWARD ) BEFORE ME, the undersigned authority, personally appeared NICOLE MEDINA ("Affiant'), as Records Custodian for Russell D. Kaplan, P.A., attorneys for CHAPEL TRAIL ASSOCIATI Fjorida Limited Liability Company (“CHAPEL TRAIL” or “Plaintiff’), who being known to mer who presented as identification and who after being duly cautioned and sworn, upon oath, deposes and says as follows: 1. Described in the table below and attached hereto are true copies of documents and correspondence relating to the post-execution Settlement Agreement between the parties. TABLE OF CONTENTS - POST EXECUTION SETTLEMENT AGREEMENT Exb. # Date Description/Title of Document 1 40/17/13 Defendants’ Emergency Motion Release Food Truck... 2 1073 Order denying Defendants' Emergency Motion to Release Food Truck... 3 1273 Post-execution Settlement Stipulation embodied in email from Defendants’ counsel attaching signed: (A) Joint Motion for Entry of Agreed Order Adopting the Parties’ 12/17/13 Letter Agreement; and (B) signed Letter Agreement. 4 12/17/13 Email from Plaintiff's counsel accepting the and agreeing to the Post-execution Settlement Stipulation 5 1273 Email letter from Plaintiff's counsel's office to Sheriff cancelling sale in accordance with Post-execution Settlement Stipulation (Item 3B above)12/18/13 Agreed Order adopting Post-execution Settlement Stipulation (Item 3B above) 12/24/13 - 12/26/13 Email exchange between counsel for both sides regarding Defendants’ failure to comply with the Post-execution Settlement Stipulation and discussing how to proceed 12/30/13 Email exchange between Plaintiff and Defendants modifying Post- execution Settlement Stipulation, calling for Plaintiff to advance storage fees and further protocol for delivery and iater sale of the Food Truck qTH4 Email exchange between Defendants and Plaintiff's counsel's office whereby Defendant advised of the suspension of his drivers license and Plaintiff's counsel's office suggesting a designated driver 19 14114 Email from Defendants’ counsel to Defendants advising that Plaintiff will advance $500 for the pick-up and delivery of the Food Truck and title documents by 1/17/14 11 116/14 Email exchange between Plaintiff's counsel and the Defendant, confirming that Defendants accept the $500 offer, have a designated driver and will deliver the Food Truck the next day (Friday 1/17/14) 12 47/14 - 2114 Text messages between Defendants and Nicole Medina at Plaintiff's counsef's office regarding pick up of the Release from the Sheriff, and delivery of the Food Truck. 13 1122/14 Defendants Motion to Suspend Stipulation Agreement (90) days {although dated and filed on 1/6/14, not detivered to or received by Plaintiff's counsel until 1/22/14 via email). LL KAPLAN Senior? EE 217514 Expires September 17, 2016 Bowed Tr Tn oi rare BOOBS TONS ‘YeCHAPEL TRAIL'Sant Beach ConcessoasLEVY (FOOD TRUCK ANIA Aisheenai NM#1In the County Court in and for Broward County, Florida Chapel Trial Associates LLC Plaintiff Case No: COCE-12-022491 vs. Judge: Unassigned Division South Beach Concessions Incorporated, et al Division: 52 Defendant "\ Emmergen f Ran Ta Tk hn aly Die epigeotns vl ions a honorable court to fic Wr Glens = e Tollowing reason(s): oS e Shace Ress Steed +e oped 1 coil hed my Ge aes never to be doadsidered Collah Hera \ In int Cee. Doe 4a the beilding was lensed and used te be a Conkew Fe the Crby OF Rerbole Ares and only Secved as Storing sare AIEVER My Food Tr Trock, My Faod trock Was aed oF Doce Cov tA7IS Sw ind Pi, Miami , Elericte 3312 thi pico ate Fee over three Years eons aareed and Issved a& Final Kagement Sprondadelthosbo = Mes ZolB x Kecther ay vel5) My Food-teuck Is my Sovree a} [nome a pres Sey Cel obeys nay : yas anno Ye Ip toes that E arranged monthly Payne CH TERS In Done 2013. HE Paytzteo"” Morthly @hildsupfe (arson tt seats and cortect spnestt of the foregoing was mailed to plaintiffidefendant Tat fae Ly / | Comes now, one LL be whoo, 12-12-2013 Telephone = BY 263 7777 30% y got Sted 200/00d ZrP-L WOUS MVPS! E102-21-190Settle BY Florida. almost Sats) jerss never cleFastted “These last sia Months bussiness red very Slo. AE adoced. Blaogel TA Adberney RosseR Pethe came, TE Cold not pay ah this Ly nee “Jadae, wthot my Foodtveek Plan wrtheck any Income. ach day my frock pemarns (a the eased, Miami a lode. Baorty Shen SFMce - Plecee Release ny Food+truck to me ln and cace Dor my Fossly Ortho Fr everrthings Aerovtts : Abaldsugg ort PTR Vere [Rent ete. Taek rows how Attorney sossek Koplow dod necd =e werk Decacsa “he eot Arron IY Asuck » pdbocrey & Koplow >robed 1 plow -te de al cas to ork you be Knewas FE canct GRech an Actborney te Rost back . =e reve. o G2) from lense by trehay Wowkks “ete 00 OF ahect now total ater Fees to Ghee trax an it be air. Alot In this Baty. oS ane Dees hat GA #19, 000 Ato 7 ce my hod trved. /, Please rant the. order : Me. a Chapel Trail Be responsible. tor fewing and storage 4oea -Te Magni Dock Lowy Ir wrong ef QS Scout AS 105 Sf 7 : eile me. Jor Ary ae posttiord BY DFS P02 S Erie Adam? : $2e-4 400/200'd eh HOdd VPS? E102-Z1-190#2IN THE COUNTY COURT INAND FOR Brow COUNTY, FLORIDA CHAR TCAIL FROLIATES, itce.- CaseNo: | Q-aaYQ) CaLEe Sa Plas ONE, ) Vv. ) Sour Seren ae ane, er. al. “Wheto tts, ORDER ‘THIS CAUSE having come on to be heard on Defendant's/Plaintit's [O- 17+ tS Ensrceny hear Hig, Motion ‘ko eQeasse Loc] Truck “Plackt eecorys br hy se and the Court having heard argument of counsel, and being otherwise advised Tous N44 Fh Kors. in the Premises, it is hereupon, ORDERED AND ADJUDGED. that said Motion be, and the same is hereby denecl, ao The 4 ny lboal four: fe. ths pm tte, DONE AND ORDERED in oO this, LZ say ot _ OF / 2aAD Copies turnished: RUSE O- MalanjEX- WAtnvAars -Page | of I RDKPA From: lenard@gormanpa.com Sent: Tuesday, December 17, 2013 4:12 PM To: RDKPA. Ce: tusshome@bellsouth.net; Eric Adams (eadams2698@icloud.com) Subject: south beach Attachments: 2013_12_17_16_08_21.pdf 2013_12_17_16_08_58.pdf Enclosed are signed motion and signed agreement. Lenard H. Gorman, Esquire Lenard H. Gorman, P.A. One Datran Center, Suite 1800 (new suite no.) 9100 South Dadeland Boulevard Miami, Florida 33156-7800 Tel. (305) 670-0876 Fax (305) 670-0347 This transmission (including any attachments) is intended to be delivered only to the named addresse(s) and may contain information which is confidential, proprietary, attorney work-product or attorney- client privileged. If this notification is received by anyone other than the intended recipient(s), the recipient{s) should immediately notify the undersigned by E-MAIL and by telephone and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the intended recipient(s) except with the express written consent of the sender. Thank you. No virus found in this message. Checked by AVG - www.avg.com Version: 2013.0.3462 / Virus Database: 3658/6953 - Release Date: 12/27/13 1/22/2014IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CHAPEL TRAIL ASSOCIATES, LLC., a Florida Limited Liability Company, CASE NO. 12-22491 COCE 52 Plaintiff, v. INT Mi ORE) SOUTH BEACH CONCESSIONS UnGPre vie eerie INCORPORATED, a Florida Corporation; and ERIC ADAMS, Individually. 12/17/13 LETTE A ENT Defendants. / Plaintiff, by and through its undersigned attorney and Defendants, file this Joint Motion for Entry of Agreed Order Adopting the Parties’ 12/17/13 Letter Agreement, and states as follows: gorman, Esq., herein makes appearance on behaif of the Defendants Motion as evidenced by his signing and dating here _ +2} 2 The parties have agreed to the entry of an Order in the form attached hereto as Exhibit "A”. Wherefore, Plaintiff and Defendants respectfully request this Honorable Court enter an Order adopting the Parties' 12/17/13 Letter Agreement, retaining jurisdiction for enforcement of same, and such other further relief as this Court deems just and appropriate. | HEREBY CERTIFY that a true and correct copy of the foregoing has been forwarded by E-Mail this___ day of December, 2013 To: Lenard H. Gorman, Esq.,One Datran Center, Suite 1800, 9160 South Dadeland Boulevard, Miami, Florida 33156 (email: lenard@gormanpa.com). RUSSELL D. KAPLAN, P.A. Attorneys for Plaintiff 750 Southeast 3rd Avenue, Suite 100 Fort Lauderdale, Florida 33316 954-763-7777ph 954-763-2920 fax rtdkpa@bellsouth,net By: RUSSELL D. KAPLAN, ESQUIRE Fla. Bar No. 500895Russ, as you know | represent South Beach Concessions, Inc. and Eric Adams (the “Defendants"). | have their full and irrevocable authority to enter into this letter agreement on behalf of the Defendants. You represent Chapel Trail Associates LLC. (the "judgment creditor") and further represent that you have full and irrevocable authority to enter into this letter agreement on behaif of the judgment creditor. Please confirm that you agree to the terms of this letter agreement by sending me a reply e-mail to that effect. The terms of this letter agreement are as follows: 1. On or before 12/27/13, South Beach Concessions, Inc. will transfer title to the food truck by Bill of Sale and Certificate of Title in blank to the judgment creditor, Chapel Trail Associates, LLC, At the same time, the Defendants shall deliver to the judgment creditor all keys to the food truck and all paperwork related to the maintenance of the vehicle, the history of the vehicle and any improvements constructed therein. Defendants warrant and represent that they have not, nor will they: a] assign to others the rights to be transferred hereunder; b] remove any property (tangible or intangible) from the food truck; or c] retain any keys or paperwork related to the vehicle, following the above mentioned turnover of same to the judgment creditor. 2. — The judicial sale of the food truck will be cancelled. 3. The judgment creditor will sell the food truck, and from the proceeds, it will be paid the amount of the 9/25/13 judgment ("Judgment"), plus accrued interest, the costs incurred with the Sheriff, inctuding any storage fees (which had been paid at the time of pickup by the Defendants), its attorneys’ fees through the date of sale, and the expenses of sale. From the sale proceeds, if no sales commission is incurred, the judgment creditor shall receive an additional 20% from the net sales proceeds (not the gross proceeds) for its efforts to sell same ("Marketing Fee’). In the event that sales commissions are incurred, the Marketing Fee shall be reduced to 15% of the net sales proceeds. The balance of the sale proceeds shail be paid to the judgment debtor. 4. The vehicle shall be stored by the judgment creditor at no cost (for the first 45 days) during the sales period or delivered to a sales facility for sale. It is believed that the best time to sell the food truck is in February 2014, and therefore, the judgment creditor is authorized to wait until then to sell the vehicle. The Defendants shall keep the vehicle fully insured through the end of February 2014 and provide proof of such insurance upon request. 5. Upon payment of the judgment creditor, a partial or full (as applicable) Satisfaction of Judgment shall be issued. 6. An agreed order shall be entered authorizing and directing Eric Adams, as President of South Beach Concessions, Inc., to transport the vehicle to a designated focation. Under no circumstances are either of the Defendants authorized to transportthe vehicle to any other location or for any other journey. At or before the time of transport, Defendants shall pay all outstanding storage and towing fees to the Sheriffs designee. Defendants are advised to do so on or before 12/19/13, as the towing yard (Dixie Transport) shuts down early for the Christmas holiday. 7. While the parties have been told that under the right circumstances the food truck could be sold for an amount far in excess of the Judgment and related costs, neither of the parties is in the position to represent or guaranty same. The parties acknowledge the possibility that the proceeds from the sale of the truck might not be sufficient to satisfy the judgment and related costs. 8. Except as otherwise provided below, neither the existence of this Agreement nor any efforts on the part of the parties to sell the food truck shall serve to release the Defendants from the amounts due Chapel Trail under the Judgment. Nor shall the existence of this Agreement require Chapel Trail to forbear in the collection of the amounts due from the Defendants. 9. Notwithstanding the fact that the sale of the food truck would benefit the parties, under no circumstances shall the judgment creditor, its law firm, broker or any other designees be liable to the Defendants or other persons or entities for any claims related to their action or inaction in pursuit of the sale of the food truck. In all efforts to sell or market the food truck, the Defendants shall provide their full cooperation. While the judgment creditor may choose to consult with the Defendants regarding issues related to the sale of the food truck, ultimately, the judgment creditor will have the final say.HAPage 1 of 2 RDKPA From: ‘enard@gormanpa.com Sent: Tuesday, December 17, 2013 4:38 PM To: RDKPA Ce: Eric Adams (eadams2698@icloud.com) Subject: RE: south beach Thank you Lenard H. Gorman, Esquire Lenard H. Gorman, P.A. One Datran Center, Suite 1800 (new suite no.) 9100 South Dadeland Boulevard Miami, Florida 33156-7800 Tel. (305) 670-0876 Fax (305) 670-0347 This transmission (including any attachments) is intended to be delivered only to the named addresse(s) and may contain information which is confidential, proprietary, attorney work-product or attorney- client privileged. If this notification is received by anyone other than the intended recipient(s), the recipient(s) should immediately notify the undersigned by E-MAIL and by telephone and obtain instructions as to the disposal of the transmitted material. In no event shail this material be read, used, copied, reproduced, stored or retained by anyone other than the intended recipient(s) except with the express written consent of the sender. Thank you. From: RDKPA [mailto:rdkpa@bellsouth.net] Sent: Tuesday, December 17, 2013 4:28 PM To: lenard@gormanpa.com Cc: spot@chapeltrailleasing.com Subject: RE: south beach Len Recived, Thank you for the signed Letter Agreement accurately reflecting the agreement between the parties. You can consider this reply Mr. Kaplan’s agreement and acceptance of same. | will submit the Motion and Agreed Order tomorrow for entry and send a letter to the Sheriff cancelling the sale now. Sincerely, SNieole Medina Russell D. Kaplan, P.A. 750 SE 3rd Avenue, Suite 100 Ft. Lauderdale, FL 33316 Tel: 954-763-7777 Fax: 954-763-2920 Idkpa@pbelisouth.net NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert te hard copy, copy, use or disseminate this e-mail or any 1/22/2014Page 2 of 2 attachments to it, If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. From: fenard@gormanpa.com [mailto:lenard@qormanpa.com] Sent: Tuesday, December 17, 2013 4:12 PM To: RDKPA Cc: russhome@beilsouth.net; Eric Adams (eadams2698@icloud.com) Subject: south beach Enclosed are signed motion and signed agreement. Lenard H. Gorman, Esquire Lenard H. Gorman, P.A. One Datran Center, Suite 1800 (new suite no.' 9100 South Dadeland Boulevard Miami, Florida 33156-7800 Tel. (305) 670-0876 Fax (305) 670-0347 This transmission (including any attachments) is intended to be delivered only to the named addresse(s) and may contain information which is confidential, proprietary, attorney work-product or attorney- client privileged. If this notification is received by anyone other than the intended recipient(s), the recipient(s) should immediately notify the undersigned by E-MAIL and by telephone and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the intended recipient(s) except with the express written consent of the sender. Thank you. 1/22/2014#5Page | of 1 RDKPA From: RDKPA [rdkpa@bellsouth.net] Sent: Tuesday, December 17, 2043 4:35 PM To: ‘cjohnson@mdpd.com' Ce: ‘lenard@gormanpa.com’ Subject: Chapel Trail v, South Beach Concessions - Cancellation of Levy of Food Truck scheduled for 12/18/13 Dear Chartean Please consider this letter notice to cancel the Sheriff's Sale scheduled for tomorrow, 12/18/13, of the Food Truck in connection with the above referenced Broward County case Number: 12-22491 COCE 52. Please prepare the proper Reiease, releasing the Food Truck to the Defendant, Eric Adams, Authorized Agent of South Beach Concessions, Inc., and forward same to Dixie Transport. Mr. Adams will make arrangements to pick-up the Food Truck and pay the storage and towing fees upon pick-up on or before 12/23/13. If you should need anything further, please contact me. Thank you very much for your assistance in this matter. Sincerely, Nicole Medina Russell D. Kaplan, P.A. 750 SE 3rd Avenue, Suite 100 Ft. Lauderdale, FL 33316 Tal: 954-763-7777 Fax: 954-763-2920 rdkpa@bellsouth.net NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. ff you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. 1/22/2014#6IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CHAPEL TRAIL ASSOCIATES, LLC., a Florida Limited Liabitity Company, CASE NO. 12-22491 COCE 52 Plaintiff, v. SOUTH BEACH CONCESSIONS INCORPORATED, a Florida Corporation; and ERIC ADAMS, Individually. AGREED ORDER Defendants. i THIS CAUSE having come before the Court pursuant to the 12/17/13 Joint Motion for entry of this Order and the parties 12/17/13 Letter Agreement (the “Letter Agreement”), and the Court being otherwise advised in the premises, the Court hereby finds and orders that: 1. Pursuant to the parties’ 12/17/13 Letter Agreement, Plaintiff cancelled the Sheriff's Sale scheduled for 12/18/13. Defendants are ordered to pick up the Food Truck from Sheriff or its designee, Dixie Transport, located at 5520 NE 4" Avenue, Miami, FL, and deliver to Plaintiff, Chapel Trail Associates, LLC, at 21011 Johnson Street, Pembroke Pines, FL and do so no later than December 23, 2013. Under no circumstances are either of the Defendants authorized to transport the vehicle to any other location or for any other journey. 2. At the time of pickup, the Defendants shall pay the Sheriff, or its designee Dixie Transport, any outstanding towing and storage charges. At! time of delivery, Defendants will surrender to the judgment creditor all keys to the food truck and all paperwork related to the maintenance of the vehicle, the history of the vehicle and any improvements constructed therein. Defendants warrant and represent that they have not, nor by this Order shail they: a] assign to others the rights to be transferred to the Plaintiff under the Letter Agreement; b] remove any property (tangible or intangible) from the feod truck; or c] retain any keys or paperwork related to the vehicle, following the above mentioned turnover of same to the judgment creditor, 3. The Defendants shall keep the vehicle fully insured through the end of February 2014 (unless otherwise agreed in writing) and provide proof of such insurance upon request. | / DONE AND, ORDERED in Chambers at Fort Lauderdale, Broward County, Fiorida this day of Hh Og , 2013, COUNTY COURT JUDGE © Copies Furnished to: " ai 5 Russell D. Kaplan, Esq. Cy ” Lenard H. Gorman, Esq Ae 8 ny, es ? ey ‘ePage | of 3 RDKPA From: lenard@gormanpa.com Sent: Thursday, December 26, 2013 7:33 PM To: RDKPA Ce: Eric Adams Subject: Re: Eric Follow Up Flag: Follow up Flag Status: Compieted No response yet. You need to proceed in the manner you deem appropriate. Sent from my iPhone On Dec 26, 2013, at 2:38 PM, "RDKPA" wrote: Still no word? And why should | not seek contempt sanctions? Sincerely, Raseelt Kaplan Russel D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) (954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. From: lenar¢@gormanpa.com [mailto:lenard@gormanpa.com’ Sent: Tuesday, December 24, 2013 10:49 AM To: RDKPA Ce: Eric Adams Subject: Re: Eric No. Sent from my iPhone 1/22/2014Page 2 of 3 On Dec 24, 2013, at 8:43 AM, "RDKPA” wrote: 1/22/2014 Or should | seek contempt sanctions? Sincerely, Russell Kaplan Russell D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) (954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. From: lenard@qormanpa.com [mailto:lenard@gormanpa.com] Sent: Tuesday, December 24, 2013 10:30 AM To: RDKPA Ce: Eric Adams Subject: Re: Eric I have not received a response from him. Sent from my iPhone On Dec 24, 2013, at 7:52 AM, "RDKPA" wrote: Len, where are we on this? Sincerely, Russell Keplan Russeil D. Kaplan, P.A. 750 S,E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 {phone) (954} 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-maii message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert te hard copy, copy, use or disseminate this e-mail or anyPage 3 of 3 attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. No virus found in this message. Checked by AVG - www.avy.com Version: 2013.0.3462 / Virus Database: 3658/6945 - Release Date: 12/23/13 No virus found in this message. Checked by AVG - www.ayg.com Version: 2013.0.3462 / Virus Database: 3658/6945 - Release Date: 12/23/13 No virus found in this message. Checked by AVG ~ www.avg.com Version: 2013.0.3462 / Virus Database: 3658/6953 - Release Date: 12/27/13 1/22/2014#8Page | of 4 RDKPA From: Eric Adams [eadarms2698@gmail.com] Sent; Monday, December 30, 2013 11:20 AM To: RDKPA Subject: Re: FW: south beach I agree to the new modification embodied in the email. On Mon, Dec 30, 2013 at 10:25 AM, RDKPA wrote: Eric, we need to wrap this up today. If you have more questions, call me this morning. Otherwise, please send me an e-mail agreeing to the Modification embodied in the e-mail below. Sincerely, Raseelt Kaplan Russell D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) (954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be tegally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy. copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. On Fri, Dec 27, 2013 at 11:51 AM, RDKPA wrote: Dear Eric: Leonard has authorized me to communicate with you directly regarding the parties’ recent settlement, embodied in the three documents attached ("Settlement Agreement"). Both attorneys believe that they had the absolute and irrevocable authority of their clients to enter into the Settlement Agreement. For whatever reason, you have not acted in accordance with the Settlement Agreement, meanwhile storage charges for the vehicle continue to accrue a $25 a day further eroding any equity in the vehicle. Asan alternative to my asking the Court to enforce the Court Order (attached) and/or finding you in contempt for violating same, | have authority from my client to offer you the following modification to the Settlement Agreement {the “Modification”): 1] Storage Fees. Plaintiff (not you) would pay the storage charges necessary to release the vehicle, provided: a] same would be reimbursed to the Plaintiff at the time of sale of the vehicle; b] Plaintiff's Marketing Fee would remain at 20% regardless of whether a sales commission was paid to a third- party; and c] you would pick up and deliver the vehicle to Chapel Trail within 48 hours of cur request. 1/22/2014Page 2 of 4 2] Delivery. Eric will delivering the truck, its contents, the keys and the paperwork (bill of sale and title certificate endorsed in blank) during business hours within 48 hours of Plaintiff's request. Two hours before delivery, Eric will give a “heads up" call to Chape! Trail (954-436-9000) and ask for Chris. 3] Minimum Sales Price. Through 2/15/14, Plaintiff will agree not to sell for less than the agreed-upon minimum, give or take 10%. The agreed-upon minimum shall be $45,000 or the written valuation for the vehicle given by a broker (selected by the Piaintiff) who has inspected the vehicle (or other expert hired by the Plaintiff), whichever is less. If the vehicle does not sell for the agreed-upon minimum (give or take 40%) by 2/15/14, Plaintiff is free to seil the vehicle for whatever price Plaintiff deems appropriate. 4] Storage Charges. To the extent that it is necessary or advantageous to store the vehicle at Plaintiffs location, Plaintiff agrees to provide such storage rent-free through 2/15/14. Thereafter, Plaintiff shall be entitled to charge a reasonable rental charge not to exceed the monthly rental rate previously paid by the Defendants to the Plaintiff. 5} Timely Acceptance. Defendants can accept this Modification by sending a reply e-mail saying “agreed” or something to that effect and by doing so within 3 days of today. By accepting the Modification, Defendants: a] ratify and agree to the Settlement Agreement (embodied in the three documents attached), as changed by the Modification: and b] authorize the Plaintiff to submit a modified Agreed Order to the Court, reflecting those changes. Should Defendants fail to timely and properly accept the Modification, Defendants should consider the offer of the Modification to be withdrawn. Sincerely, Reuseld Kigolan Russel! D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft, Lauderdale, Fiorida 33316 (954) 763-7777 (phone) (954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954- 763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. Sincerely, Russell Kiplan Russel! D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) {954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954- 763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. 1/22/2014Page 3 of 4 From: lenard@gormanpa.com [mailto:lenard@gormanpa.com] Sent: Tuesday, December 17, 2013 4:12 PM To: RDKPA Cc: russhome@bellsouth.net; Eric Adams (eadams2698@icloud.com) Subject: south beach Enclosed are signed motion and signed agreement. Lenard H. Gorman, Esquire Lenard H. Gorman, P.A. One Datran Center, Suite 1800 (new suite no.) 9100 South Dadeland Boulevard Miami, Florida 33166-7800 Tel. {305} 670-0876 Fax (305) 670-0347 This transmission (including any attachments) is intended to be delivered only to the named addresse(s) and may contain information which is confidential, proprietary, attorney work- product or attorney-client privileged. If this notification is received by anyone other than the intended recipient(s), the recipient (s) should immediately notify the undersigned by E-MAIL and by telephone and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone ether than the intended recipient(s) except with the express written consent of the sender. Thank you. No virus found in this message. Checked by AVG - www.ave.com Version: 2013.0.3462 / Virus Database: 3658/6953 - Release Date: 12/27/13 1/22/2014#9Page 1 of 4 RDKPA From: RDKPA [rdkpa@bellsouth.net] Sent: Tuesday, January 07, 2014 11:33 AM To: "Eric Adams’ Ce: spot@chapeltrailleasing.com; ‘lenard@gormanpa.com' Subject: RE: FW: south beach Hi Eric In tight of your new drivers license issue, and due to the fact that you have beein directed by Cout Order to deliver the truck to chapel Trail, we ask that you find a friend to drive together with you and deliver the truck to Chapel Trail? Piease get back to me promptly to confirm when you can accomplish this either today or tomorrow. Thank you. Sincerely, Nicole Medina Russell D. Kaplan, P.A. 750 SE 3rd Avenue, Suite 100 Ft. Lauderdale, FL 33316 Tel: 954-763-7777 Fax: 954-763-2920 rdkpa@bellsouth net NOTICE: This e-mail message and any attachment to this e-mail message contains confidentiat information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy. copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. From: Eric Adams [mailto:eadams2698@gmail.com] Sent: Monday, January 06, 2014 10:56 AM To: lenard@gormanpa.com Cc: RDKPA; spot@chapeltrailleasing.com Subject: Re: FW: south beach Hello to all: ] am advised by the Florida department of children and family that my driving license suspended due to failure to keep up with child support as of 09/2013. And to make matters worst Florida department of revenue advised that a judgment tax lien has been filed against me and south beach concession. I am headed to family court now. Will keep u up to date of the ffollowing. On Monday, December 30, 2013, lenard@gormanpa.com wrote: > J glad to see that this is resolved. > > > > Lenard H. Gorman, Esquire > > Lenard H. Gorman, P.A. > > One Datran Center, Suite 1800 (new suite no.) 1/22/2014Page | of 1 RDKPA From: lenard@gormanpa.com Sent: Tuesday, January 14, 2014 12:33 PM To: Eric Adams (eadams2698@icloud.com) Ce: RDKPA Subject: south beach Follow Up Flag: Follow up Flag Status: Purple the landlord is willing to advance you up to $500 for you to pick up the truck and deliver it as agreed. the monies will be paid upon delivery of the truck, together with the title documents. please contact russell kaplan to arrange the foregoing. this must be accomplished by friday, january 17. Lenard H. Gorman, Esquire Lenard H. Gorman, P.A. One Datran Center, Suite 1800 9100 South Dadeland Boulevard Miami, Florida 33156-7800 Tel. (305) 670-0876 Fax (305) 670-0347 This transmission (including any attachments) is intended to be delivered only to the named addresse(s) and may contain information which is confidential, proprietary, attorney work-product or attorney-client privileged. If this notification is received by anyone other than the intended recipient(s), the recipient(s) should immediately notify the undersigned by E-MAIL and by telephone and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the intended recipient(s) except with the express written consent of the sender. Thank you. No virus found in this message. Checked by AVG - www.avg.com Version: 2013.0.3462 / Virus Database: 3658/6999 - Release Date: 01/13/14 1/22/2014#11Page 1 of 2 RDKPA From: RDKPA [rdkpa@bellsouth. net] Sent: Thursday, January 16, 2014 3:15 PM To: "Eric Adams’ Ce: ‘lenard@gormanpa.com’; ‘spot@chapeltrailleasing.com’; 'Teresa Rourke’ Subject: Delivery of the Food Truck Tomorrow Eric and Michael: Here is the protoco! that you will follow regarding tomorrow's delivery of the vehicle: 1] Eric, 30 minutes before you expect to arrive at Chapel Trail, you wiil call Chape! Trail (954-436-9000) and give them your ETA; 2] Eric, you will drive the truck to unit #122 (20911 Johnson St.); 3) Marty or John from Chapel Trail wi!l meet you at unit#1 22 at the ETA you specified; 4) Eric will show Marty or John the VIN number on the vehicle and how it matches with the VIN number on the Title Certificate; 5] Eric will park the truck in unit #122; 6] Eric will give Marty or John, the Bill of Sale and vehicle Title Certificate, both endorsed in blank (the "Title Documents"); 7] Marty or John will e-mail me (Russ) copies (front and back) of the Titled Documents for me to confirm that they are in order; 8) Once t (Russ), confirm that the Title Documents are in order, Eric will give Marty or John the keys to the vehicle and they in turn will give Eric the $500 promised. Does everyone understand? Sincerely, Featael!, ‘Kiyolan Russell D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) {954) 763-2920 (fax) NOTICE; This e-mail message and any attachment to this e-mail message contains confidential information that may be Jegaily privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message, Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. From: Eric Adams [mailto:eadams2698@gmail.com) Sent: Thursday, January 16, 2014 1:30 PM. To: RDKPA Subject: I have someone who can drive the truck. I accept the offer for $500 it will assist me n the delivery of the 1/22/2014Page 2 of 2 truck. He can deliver the truck tomorrow. No virus found in this message. Checked by AVG - www.avz.com Version: 2013.0.3462 / Virus Database: 3681/7007 - Release Date: 01/16/14 1/22/2014Page t of 2 RDKPA From: eadams2698 feadams2688@gmail.com] Sent: Thursday, January 16, 2014 3:49 PM To: RDKPA Ce: lenard@gormanpa.com; spot@chapeltrailleasing.com; "Teresa Rourke’ Subject: RE: Delivery of the Food Truck Tomorrow I will not be driving the truck as to the status of my driving license. I need to review the bill of sale Please send thanks. stave ssooneplauet deve i woes Original message -------- From: RDKPA. Date:01/16/2014 3:14 PM (GMT-05;00) To: ‘Eric Adams‘ Ce: lenard@gormanpa.com,spot@chapeltrailleasing.com,'Teresa Rourke’ Subject: Delivery of the Food Truck Tomorrow Eric and Michael: Here is the protocol that you will follow regarding tomorrow's delivery of the vehicle: 1] Eric, 30 minutes before you expect to arrive at Chapel Trail, you will call Chapel Trail (954-436-9000) and give them your ETA; 2] Eric, you will drive the truck to unit #122 (20911 Johnson St); 3] Marty or John from Chapel Trail will meet you at unit#122 at the ETA you specified; 4) Eric will show Marty or John the VIN number cn the vehicle and how it matches with the VIN number on the Title Certificate; 5] Eric wil! park the truck in unit #122; 6] Eric will give Marty or John, the Bill of Sale and vehicle Title Certificate, both endorsed in blank (the ‘Title Documents"); 7] Marty or John will e-mail me (Russ) copies (front and back) of the Titled Documents for me to confirm that they are in order; 8] Once | (Russ), confirm that the Title Documents are in order, Eric will give Marty or John the keys to the vehicle and they in turn will give Eric the $500 promised. Does everyone understand? Sincerely, Rasell, ‘Kiplan Russell D. Kaplan, P.A. 750 S.E. 3rd Avenue, Suite 100 Ft. Lauderdale, Florida 33316 (954) 763-7777 (phone) (954) 763-2920 (fax) NOTICE: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. ff you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 954-763-7777 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the 1/22/2014Page 2 of 2 contents of this message or any attachments may not have been produced by the sender. From: Eric Adams [mailto:eadams2698@gmail.com] Sent: Thursday, January 16, 2014 1:30 PM To: RDKPA Subject: I have someone who can drive the truck. ] accept the offer for $500 it will assist me n the delivery of the truck. He can deliver the truck tomorrow. No virus found in this message. Checked by AVG - www.avg.com Version: 2013.0.3462 / Virus Database: 3681/7007 - Release Date: 01/16/14 No virus found in this message. Checked by AVG - www.ayg.com Version: 2013.0,3462 / Virus Database: 3681/7007 - Release Date: 01/16/14 1/22/2014#12< Back (1) (954) 288-7025 — Contact SAN V4, 2014 Text Message Friday 9:39 AM I'm having a little< Back (1) (954) 288-7025 — Contact Friday (0:56 AM I'm having a little transportation issues right now on a call you when | get it all together Hours< Back (1) (954) 288-7025 Contact Friday (2005 Pi Hours Trying Lol | got it... no worries. he /e chapel cir an ay€ Back (1) (954) 288-7025 = Contact Lol | got it... no worries. 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