Complaint,Petition: JENNA RENNERT VS DANIEL ADLER

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                                Filing # 50047900 E-Filed 12/14/2016 02:14:05 PM

IN THE CIRCUIT COURT OF THE 117%
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

JENNA RENNERT, CASE NO
Plaintiff,
vs. COMPLAINT FOR
DECLARATORY RELIEF
DANIEL ADLER,
Defendant
/

Plaintiff, Jenna Rennert (“Rennert”), sues Defendant, Daniel Adler (“Adler”), and says:
GENERAL ALLEGATIONS

1. Plaintiff is over the age 18 and is sui juris.

2. Defendant, Adler, is over the age of 18 and is sui juris. Venue is proper in this Court
and this Court has personal jurisdiction over Adler because (i) the property in litigation (as later
described in this Complaint) is located in Miami-Dade County, Florida; (ii) Adler engages in
substantial and not isolated activity in Florida, including Miami-Dade County, Florida, by
conducting his business there; (iii) prior to Adler’s actions which give rise to this action, Adler
traveled to Miami-Dade County, Florida to, among other things, attend business related
conventions and meet with distributors and customers, join Rennert’s family for holiday
celebrations, assist in planning of the wedding and for vacation; and (iv) all causes of action against
Adler accrued in Miami-Dade County, Florida.

3. Since Rennert was 20 years old, she and Adler were involved in an exclusive
girlfriend/boyfriend relationship. Two years later, Rennert and Adler lived together after Rennert
graduated college. Prior to and during 2014, Rennert and Adler had multiple discussions regarding

their future together, including becoming engaged and married and specifically about the

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210Complaint for Declaratory Relief and Damages

Jenna Renmnert v. Daniel Adler,

Case No.:

Page 2

characteristics of the ring Adler would gift to Rennert upon the announcement of their commitment

to be married. Rennert was raised in Bal Harbour, Florida and her parents still reside in Bal
Harbour, Florida.

4. In November 2014, while in Miami, Florida, Adler informed Rennert’s father that
Adler and Rennert were discussing marriage and that Adler thought Rennert and he would
announce their commitment to be married within the next four months, coinciding with Adler’s
30" birthday in March 2015. In January 2014, Adler and Rennert began the process of locating
and purchasing an engagement ring, including requesting that Rennert’s parents introduce them to
a jeweler and otherwise assist in the selection process.

5. Rennert’s parents introduced Rennert and Adler to a Miami-Dade County, Florida
based jeweler with whom Rennert’s parents had an existing relationship. Thereafter, Adler, with
the assistance of Rennert’s parents and the jeweler, identified two separate stones that the jeweler
had in inventory to show Rennert (both of which stones were located in Miami-Dade County,
Florida). Rennert flew to Miami-Dade County to review and select a stone. With her parents and
the jeweler present, at her parents’ home in Bal Harbour, Florida, she discussed in detail with her
parents and the jeweler the two stones. After much discussion of the availability of stones
generally and about the two stones in particular, Rennert selected one of the two stones for the
ring. Then with the assistance of the jeweler, she designed the setting for the ring using the stone
she had selected

6. The jeweler then discussed with Rennert and Rennert’s parents the timing and costs
associated with the delivery of the ring selected and designed by Rennert. The jeweler then
informed Rennert and Rennert’s parents that while Adler had told him that Adler intended to gift

the ring to Rennert, he would only pay a certain amount for the ring and that the remainder amount

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210Complaint for Declaratory Relief and Damages
Jenna Renmnert v. Daniel Adler,

Case No.:

Page 3

would need to be covered by them. Since the cost of the ring exceeded what Adler intended to
spend, Rennert’s parents paid the jeweler the remaining balance of the purchase price. All monies
for the ring (paid by Adler and by Rennert’s parents) were delivered to the jeweler in Florida.

7. After Adler and Rennert formally agreed to announce their commitment to be married,
Adler gifted the ring to Rennert and, both decided that their wedding would take place in Miami-
Dade County, Florida. From that point forward, both Adler and Rennert were involved in multiple
meetings in Miami-Dade County, Florida with wedding vendors, including selecting a wedding
venue, caterer, florist and band.

8. Rennert and Adler’s wedding was planned for Saturday, November 26, 2016 in Miami-
Dade County at Fairchild Tropical Botanic Garden. Up until Friday, November 4, 2016, Adler
never expressed to Rennert that he was having any doubts whatsoever about the wedding. To the
contrary, as one would expect any fiancé would act, Adler consistently reassured Rennert about
their future together by repeatedly expressing his excitement for the wedding day and professing
his love and commitment to her.

9. Then, after a one year and eight-month engagement, with less than twenty-two days
left until the November 26, 2016 wedding, Adler called Rennert on her cellphone, just after
Rennert had, with her parents, finished the final walk-through with all of the wedding vendors at
the Fairchild venue, and for the first time indicated that he had decided not to marry Rennert. This
was a complete and utter shock to Rennert. Notwithstanding Adler’s actions, since Rennert
thought that Adler was just having cold feet, she still wanted to marry Adler and Rennert wanted
to proceed with the November 26, 2016 wedding. Despite multiple attempts by Rennert to
reconcile, Adler’s decision was final and, the next day, over the cellphone, he unilaterally and

definitively broke off the engagement and cancelled the wedding while Rennert was in Miami-

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210Complaint for Declaratory Relief and Damages

Jenna Renmnert v. Daniel Adler,

Case No.:

Page 4

Dade County, Florida. After learning of Adler’s final decision, Rennert removed the ring from

her finger and left it in Bal Harbour, Florida at her parents’ house. The ring is still located in Bal
Harbour, Florida.

10. All conditions precedent to filing this lawsuit have occurred, been performed, waived
or excused.

COUNT I- DECLARATORY RELIEF

11. Rennert repeats paragraphs 1 through 10 above.

12. This is an action for declaratory relief of Rennert and Adler’s respective rights over the
personal property described in this count.

13. Adler gave Rennert the ring as a gift. Once given, Adler lost all dominion and control
over the ring and Rennert is entitled to retain possession of the ring. Additionally, since Adler
unilaterally terminated the engagement, and such termination was not by the mutual consent of
both Adler and Rennert, Rennert also is entitled to ownership and possession of the ring.

14. Notwithstanding Rennert’s lawful ownership and possessory rights to the ring, Adler
has unlawfully demanded that Rennert return possession of the ring to Adler and has threatened to
prosecute legal action against her if she does not honor his demand.

15. There is a bona fide dispute between Rennert and Adler with respect to their respective
ownership rights to the ring. Rennert and Adler have a justiciable question as to the existence or
non-existence of some right, status, immunity, power or privilege, or as to some fact upon which
the existence of such right, status, immunity, power or privilege does or may depend. Rennert and
Adler are in doubt as to the right, status, immunity, power or privilege. There is a bona fide, actual,

present need for the declaration

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210Complaint for Declaratory Relief and Damages
Jenna Renmnert v. Daniel Adler,
Case No.:
Page 5
16. Rennert requests that the Court enter a declaratory judgment declaring that she has
lawful ownership and possession of the ring.
WHEREFORE, Rennert demands entry of a Final Judgment declaring that she has rightful
ownership and possession of the ring, plus taxation of Rennert’s prevailing costs against Adler;

and for such other and further relief as this Court deems just and proper.

COUNT Il—- DECLARATORY RELIEF
(IN THE ALTERNATIVE TO COUNT 1)

17. Rennert repeats paragraphs 1 through 10 above.

18. This is an action for declaratory relief of Rennert and Adler’s respective rights over the
ring.

19. In the unlikely event that the Court decides that Adler is entitled to ownership and
possession of the ring under Count I of the Complaint, Rennert is nevertheless entitled to
imposition of an equitable lien over the ring in the amount of the financial contribution that
Rennert’s parents contributed to Adler’s purchase of the ring. Rennert’s parents assigned to
Rennert their right to an equitable lien over the ring proceeds.

20. There is a bona fide dispute between Rennert and Adler with respect to Rennert’s claim
for imposition of an equitable lien over the respective ownership rights to the ring. Rennert has a
justiciable question as to the existence or non-existence of some right, status, immunity, power or
privilege, or as to some fact upon which the existence of such right, status, immunity, power or
privilege does or may depend. Rennert is in doubt as to the right, status, immunity, power or
privilege. There is a bona fide, actual, present need for the declaration.

21. Rennert requests that the Court enter a declaratory judgment declaring that she has an

equitable lien over the ring.

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210Complaint for Declaratory Relief and Damages

Jenna Renmnert v. Daniel Adler,

Case No.:

Page 6

WHEREFORE, Rennert demands entry of a Final Judgment declaring that she has an
equitable lien over the ring, plus taxation of Rennert’s prevailing costs against Adler; and for such

other and further relief as this Court deems just and proper.

COUNT III -FORECLOSURE OF EQUITABLE LIEN
(IN THE ALTERNATIVE TO COUNT 1)

22. Rennert repeat paragraphs | through 10 and 19-21 above.

23. In the event that Rennert prevails under Count II of the Complaint, then this is an action
for foreclosure of their equitable lien.

WHEREFORE, Rennert demands entry of a Final Judgment foreclosing the equitable lien;
plus taxation of Rennert’s prevailing costs against Adler; and for such other and further relief as
this Court deems just and proper.

DEMAND FOR TRIAL BY JURY

Plaintiffs demand a trial by jury on all issues so triable.

BLUESTEIN AND WAYNE, P.A.
Attorneys for Jenna Rennert

4000 Ponce de Leon Boulevard
Suite 770

Coral Gables, Florida 33146

(305) 859-9200
docservice@bw-pa.com

By:___/s/ Barry M. Wayne
BARRY M. WAYNE, ESQ.

Florida Bar No.: 604399

BLUESTEIN and WAYNE, P.A.
4000 PONCE DE LEON BOULEVARD : SUITE 770 + CORAL GABLES, FLORIDA 33146 + (305) 859-9200 » FACSIMILE (305) 859-9210