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Filing # 126965194 E-Filed 05/17/2021 04:33:40 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 50 2020 CA 011933 XXXX MB AN
JUDGE HOWARD COATES, JR.
SHOW CARS BOCA RATON, LLC, a Florida
limited liability company,
Plaintiff,
v.
MICHAEL FLYNN, JR., an __ individual,
HOLLYWOOD WHEELS, INC., a Florida profit
corporation, HOLLYWOOD WHEELS, LLC, a
Florida limited liability company, HOLLYWOOD
WHEELS AUCTIONS & SHOWS, INC., a Florida
profit corporation,
Defendant.
HOLLYWOOD WHEELS, INC.,
Counter-Plaintiff,
v.
SHOW CARS BOCA RATON, LLC, a Florida
limited liability company,
Counter-Defendant,
/
SECOND AMENDED COMPLAINT
Plaintiff/Counter-Defendant, SHOW CARS BOCA RATON, LLC, sues Defendants,
MICHAEL FLYNN, JR., HOLLYWOOD WHEELS, INC., HOLLYWOOD WHEELS, LLC,
and HOLLYWOOD WHEELS AUCTIONS & SHOWS, INC. (collectively “Defendants”), and
states:
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 05/17/2021 04:33:40 PMShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
PARTIES, JURISDICTION AND VENUE
1. This is an action for money damages in excess of $30,000.00, exclusive of
attorney fees, court costs, pre-judgment interest, and otherwise satisfies the subject matter
Jurisdiction requirements of this Court.
2. Plaintiff, SHOW CARS BOCA RATON, LLC (“Show Cars” or “Plaintiff”), is a
Florida limited liability company, with its principal place of business in Palm Beach County,
Florida, and at all times material has been and remains sui juris.
3. Defendant MICHAEL FLYNN, JR. (“Mr. Flynn”) is an individual, is over the age
of eighteen, and at all times material has been and remains sui juris.
4. Defendant, HOLLYWOOD WHEELS, INC. (“HWI”), is a Florida for-profit
corporation, has its principal place of business in Pinellas County, Florida, and at all times
material has been and remains sui juris.
5. Defendant, HOLLYWOOD WHEELS, LLC (“HWL”), is a Florida limited
liability company, has its principal place of business in Pinellas County, Florida, and at all times
material has been and remains sui juris.
6. Defendant, HOLLYWOOD WHEELS AUCTIONS & SHOWS, INC.
(“HWASI”), is a Florida for-profit corporation, has its principal place of business in Pinellas
County, Florida, and at all times material has been and remains sui juris.
7. Venue is proper in Palm Beach County the causes of action asserted herein
accrued in Palm Beach County, Florida. More specifically, a) all sums paid by the Defendants to
the Plaintiff under the oral agreement referred to herein as the “Agreement” were paid in Palm
Beach County, Florida; b) all sums which were supposed to be paid to the Plaintiff pursuant to
the Agreement but which the Defendants failed or refused to pay were due in Palm BeachShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
County, Florida; c) performance by the Defendants pertaining to delivery of specific vehicles
was to be made at the Plaintiffs principal place of business in Palm Beach County, Florida (as
identified in Exhibits attached hereto); and d) Mr. Flynn repeatedly travelled to the Plaintiff's
principal place of business in Palm Beach County, Florida for purposes of meeting with the
Plaintiff regarding, or taking action in performance under, the Agreement.
8. All conditions precedent to the initiation of this action and the assertion of the
claims as set forth herein have occurred or have otherwise been waived.
FACTS
9. The Plaintiffs business, located in Boca Raton, Florida, buys and sell luxury and
unique vehicles.
10. In late 2017, Defendant Mr. Flynn (acting individually and on behalf of HWI,
HWL, and HWASJ), entered into an oral agreement with the Plaintiff which entailed Mr. Flynn
and Mr. Flynn’s three entities, HWI, HWL, and HWASI (the “Hollywood Wheels” entities)
acting as an agent of the Plaintiff for purposes of locating, procuring, and reselling vehicles for
profit. This oral agreement is referred to herein as the “Agreement.”
11. At all times material hereto, Mr. Flynn has been, and has represented himself to
be, the president of HWI and HWASI, and the manager of HWL.
12. Pursuant to the Agreement, the Defendants agreed to act as agents of the Plaintiff
to acquire vehicles which possessed a potential for resale at a profit. With this objective in mind,
the Defendants would attend auctions (with or without employees of Show Cars present), and
would identify vehicles for potential purchase and subsequent resale for profit. The Defendants
would then contact the Plaintiff for authorization to purchase vehicles, and if verification and
authorization were given, the Plaintiff would then transfer funds to the Defendants sufficient toShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
purchase the vehicle or vehicles identified by the Defendants. Thereafter, the Defendants would
advertise, or seek out buyers for, the vehicles for subsequent resale.
13. Under the Agreement, the Defendants were to obtain the Plaintiffs express
consent before purchasing any vehicle in furtherance of the Agreement.
14. Per the terms of the Agreement, the Plaintiff agreed to pay the purchase price;
other acquisition costs; and expenses associated with the maintenance and/or subsequent listing
or advertisement of the vehicles for resale.
15. Per the terms of the Agreement, when a vehicle was ready to be resold, the
Defendants were to provide the Plaintiff with an itemized accounting of the purchase price and
all costs associated with the vehicle (as paid by the Plaintiff), as well as the final agreed upon
purchase price to be paid by the new purchaser of the vehicle. The Defendants were also required
to obtain the Plaintiff's express consent prior to consummating a proposed sale of a vehicle.
After a vehicle was sold, Plaintiff was to be reimbursed all of its expenses (specifically including
those associated with the acquisition, maintenance, and/or sale of a vehicle), and any remaining
profit was to be split equally between the Plaintiff and Mr. Flynn.
16. Additionally, per the terms of the Agreement, if any vehicle was to be resold at a
loss, then the Plaintiff was to absorb the loss. Any intended sale which would result in a loss was
only to occur after such a sale was expressly authorized by the Plaintiff.
17. Per the terms of the Agreement, if the Defendants paid any expense associated
with a vehicle (due to circumstances such as insufficient time to obtain pre-approval and
advanced payment from the Plaintiff), then the Defendants were to be reimbursed by the Plaintiff
for such expenses provided a) the expense or expenses incurred were incident to the purchase
and sale of vehicles pursuant to the Agreement; and b) the Defendants provided documentationShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
(such as receipts, invoices, etc.) identifying the expense incurred and the reason for which the
expense was incurred. Common examples of such expenses were: a) auction site’s fees; b)
vehicle transportation fees; c) hotel accommodations for attendance at auctions in furtherance of
the Agreement, and d) fuel.
18. Mr. Flynn was also provided credit cards for accounts owned by the Plaintiff, the
purpose of which was to facilitate the payment of expenses incurred in furtherance of the
Agreement. The credit cards were provided to alleviate the need for the Defendants to come out-
of-pocket for any expenses such as those noted above. Per the Agreement, the Defendants were
only authorized to use said credit cards for expenses incurred in furtherance of the Agreement
and were not authorized to use said credit cards for personal or other expenses unrelated to the
Agreement.
19. Pursuant to the Agreement, the Defendants were to regularly provide the Plaintiff
with receipts for, and any additional proof of, all expenses incurred. This specifically included
any expenses charged on the credit cards provided by the Plaintiff. The Defendants also agreed
to provide the Plaintiff with additional proof of, or support for, expenses incurred if such a
request was made by the Plaintiff. The Defendants agreed to these conditions at the time the
credit cards were provided.
20. At all times, the Plaintiff was to have full discretion over, and the absolute right of
authorization over, any purchase or sale transactions made by the Defendants in furtherance of
the Agreement. This was expressly agreed upon by the Defendants, as the Defendants were not
advancing any of the purchase prices paid for vehicles acquired pursuant to the Agreement.
21. Pursuant to the Agreement, the Defendants were to receive payment for services
rendered only from their equal share of profits generated from the resale of a given vehicle ifShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
such a sale generated a profit to be shared equally between the Plaintiff and the Defendants. The
allocation of the profit share was always supposed to be 50% to the Plaintiff, and 50% to the
Defendants.
22. Pursuant to the Agreement, if a resale were to result in an overall loss, the
Defendants did not bear any portion of the loss, but were not paid for any services rendered
incident to the purchase and subsequent sale of that given vehicle.
23. Aside from the equal sharing of profits, the Agreement did not account for, or call
for, any further payments from the Plaintiff to the Defendants for any services rendered in
connection with or in furtherance of the Agreement.
24. At no time under the Agreement did the Plaintiff ever agree to pay Mr. Flynn, or
any of the other Defendants, a commission, salary, representative fees, or a finder’s fee, for any
of the vehicles purchased or sold pursuant to the Agreement.
25. | The Agreement ended in July 2020 after the Plaintiff expressed its displeasure
with the Defendants’ practices and their failure and refusal to: a) follow instructions of the
Plaintiff; and b) provide documentation supporting payments for expenses requested by the
Defendants.
26. Initially, Mr. Flynn would regularly send the Plaintiff detailed information
regarding vehicles that were purchased or sold. As to purchases or sales of vehicles completed
via auction, Mr. Flynn would send the Plaintiff copies of auction documents showing the
purchase price paid for such vehicles, and as to sales, Mr. Flynn would send the Plaintiff checks
for the vehicle sales proceeds issued directly from auctioneers. However, after some months, Mr.
Flynn changed his course of conduct, instead depositing monies received from vehicle sales into
accounts held in the name of the other Defendants, and then sending checks from those accountsShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
to the Plaintiff. The Defendants also stopped sending complete information to the Plaintiff
regarding purchase prices paid for acquired vehicles, expenses incurred as to purchased vehicles,
expenses incurred in connection with the sale of vehicles, proof of the sale price paid by a new
buyer for a sold vehicle, or even backup documentation for expense reimbursement requests
made by the Defendants.
27. Shortly before the end of the Agreement in July of 2020, the Defendants stopped
sending back-up documentation to the Plaintiff altogether regarding purchase prices paid by new
buyers for vehicles sold in furtherance of the Agreement (leaving the Plaintiff guessing as to the
true price paid by a new buyer for a sold vehicle).
28. Despite repeated requests for back-up documentation and information which the
Defendants failed and refused to provide, the Plaintiff's requests continued to be disregarded, all
the way up to the initiation of this lawsuit.
29. Before the Agreement ended in July of 2020, and to avoid a complete breakdown
of the Agreement, the Plaintiff sought to work with the Defendants around the growing
information gap regarding purchased and sold vehicles. Mr. Flynn would contact the Plaintiff
with minimal information regarding a specific vehicle and would relay the purchase or sale price
and ask for authorization to purchase or sell the vehicle (often representing to the Plaintiff that if
the vehicle was to be sold that the sale would generate a profit), and if approval was given based
upon Mr. Flynn’s representations the given vehicle would be bought or sold. If the vehicle were
being purchased, the Plaintiff would send either a check or wire in the amount requested by Mr.
Flynn and which he represented as the “purchase price” for the vehicle. These sums would be
sent to either: a) Mr. Flynn; b) one of the Hollywood Wheels Defendants; or c) to the seller of
the vehicle itself (based upon Mr. Flynn’s instruction as to whom payment should be tendered).Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
30. If the transaction were to be a sale, Mr. Flynn would report back to the Plaintiff
that the vehicle had been sold and would then report the amount of profit he would be sending
the Plaintiff as its equal share of the profits generated from the vehicle sale.
31. After some time, and due to the Defendants’ refusal to provide back-up
documentation for a number of vehicles purchased and sold pursuant to the Agreement, the
Plaintiff began to suspect that the Defendants were falsely inflating purchase prices paid for
certain vehicles, and that the Defendants were falsely underrepresenting the sale prices of
vehicles sold pursuant to the Agreement.
32. The Plaintiff's suspicions were bolstered by certain actions taken by the
Defendants in derogation of direct instructions given by the Plaintiff, including the Defendants
use of the credit cards provided by the Plaintiff for wholly unrelated and personal expenses.
33. | The Defendants were routinely deceptive in their dealings with the Plaintiff; for
example, the Defendants’ refused to account for the whereabouts of a 1965 Chevrolet Corvette
purchased by the Defendants with the Plaintiffs funds. As to the 1965 Corvette, the Defendants
obtained a title for the vehicle in Defendant HWI’s name (which was not authorized by the
Plaintiff), and then the Defendants proceeded to hide the vehicle from the Plaintiff for months.
Despite demand for information regarding the status and whereabouts of the vehicle, the
Defendants refused to provide information, until approximately late June of 2020, when
Defendant Mr. Flynn openly admitted to the Plaintiff that the Defendants had spent months
hiding the 1965 Corvette based upon their desire to get it ready for a listing with “Bring a
Trailer”, a popular classic and exotic vehicle online registry.
34. Additionally, towards the end of the Agreement the Plaintiff began to realize that
many of the expenses that were charged to the credit cards provided by the Plaintiff appeared toShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
be for the Defendants’ personal use. These expenses appeared wholly unrelated to activities in
furtherance of the Agreement, and many appeared to be related to the Defendants’ other business
activities conducted wholly outside the scope of the Agreement and performed for either: a) the
Defendants’ own benefit; or b) the benefit of other third-parties on whose behalf the Defendants
were working.
35. After an initial review of the credit card statements provided by the Defendants
for the months spanning from October 2019 through March 2020, the Plaintiff came to realize
that the Defendants did not provide any receipts for, or any explanation for, nearly $26,000.00 in
credit card charges. A copy of a compilation of credit card statements is attached hereto as
Exhibit “1” with the charges for which receipts and an explanation were never provided to the
Plaintiff highlighted.
36. | Towards the end of the Agreement, the Defendants refused to comply with the
Plaintiff's demands for delivery of certain vehicles that were purchased with the Plaintiffs
money. The Defendants also failed to pay Plaintiff for completed sales of vehicles which had
been purchased pursuant to the Agreement, including but not limited to a) $85,000.00 for a 1989
Porsche; b) $4,500.00 for a Yamaha golf cart; and c) $5,000.00 for an EZ Go golf cart.
37. Regarding the two golf carts, in or around May 2020, the golf carts were
purchased by Mr. Flynn with Show Cars’ money. The approximate value of the EZ Go golf cart
is $5,000.00, while the approximate value of the Yamaha golf cart is $4,500.00. A copy of an
invoice reflecting the amount paid by the Plaintiff for the two golf carts is attached hereto as
Exhibit “2.”
38. Despite the Plaintiff having wired the Defendants the money to acquire these
vehicles, the Defendants purchased them in a name other than that of the Plaintiff and did notShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
take any action to ready the vehicles for resale pursuant to the Agreement. Instead, Mr. Flynn
later told the Plaintiff's representatives that the golf carts were purchased for Mr. Flynn’s son.
39. | When the Plaintiff demanded the return of either a) its money; or b) the two golf
carts purchased with the Plaintiff's money, the Defendants (and specifically Mr. Flynn) told the
Plaintiff that it would be repaid immediately.
40. Despite Mr. Flynn’s representations, repayment was never tendered.
41. On July 26, 2020, after further demands were made by the Plaintiff for return of
the money that was used to purchase the two (2) golf carts, Mr. Flynn sent a text message to a
representative of the Plaintiff indicating that he would provide the Plaintiff with the money for
the golf carts later that week. The text messages also identified multiple other payments, or
vehicle deliveries, that the Defendants intended to complete. These text messages are
incorporated herewith as Exhibit “3.”
42. Again, despite Mr. Flynn’s express representations, no payment for the golf carts
was tendered.
43. After the Plaintiff's repeated demands for return of its monies used to purchase
the golf carts resulted in no payment from the Defendants, the Plaintiff made an express demand
for turnover and delivery of the golf carts purchased with the Plaintiffs funds. In response, the
Defendants, acting through Mr. Flynn, advised that the golf carts would be delivered to the
Plaintiff at its place of business in Boca Raton, Florida.
44. — Again, despite Mr. Flynn’s representations, the Defendants failed to perform, and
the golf carts were not delivered to the Plaintiffs place of business in Boca Raton, Florida.
45. This scenario, or scenarios very similar thereto, occurred with multiple additional
vehicles acquired pursuant to the Agreement and which were purchased with the Plaintiffs
10Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
money. Specifically, after being acquired with Show Cars’ money, and after the vehicles were
not sold by Mr. Flynn or the Hollywood Wheels Defendants, the Plaintiff demanded the return of
a) a 2001 American Eagle Motor Home; b) a 2010 PTJ VS Boat; c) a Boat Trailer; and d) a 2013
Cadillac. The Defendants only returned some of these vehicles or made payment to Show Cars
after sales of certain vehicles, after the passage of considerable time and then only after warnings
that legal action would be taken if the vehicles, or the equivalent of the amount of the Plaintiff's
money used to acquire the vehicles, were not delivered to the Plaintiff.
46. In addition to the 1965 Chevy Corvette (referenced above), a 1948 Crosley, and a
1957 Volkswagen 2-door were also withheld from the Plaintiff. The Defendants actions in hiding
the Corvette from the Plaintiff are admitted in Exhibit “3,” which also identified the
Defendants’ agreement and representation to deliver the Corvette to the Plaintiff if not sold on
Wednesday, July 29, 2020. The Corvette was not sold on July 29, 2020, nor was it immediately
thereafter delivered to the Plaintiff. After repeated demands and weeks of waiting, the Corvette
and the Volkswagen were finally delivered to the Plaintiff. However, the Crosley, which was
purchased with the Plaintiffs funds, was never delivered to Plaintiff, despite multiple demands
for its delivery. The original purchase of the Crosley was completed by the Defendants only after
the Defendants directly misled an employee of the Plaintiff into believing that the acquisition of
the vehicle had been authorized. Specifically, Mr. Flynn called the Plaintiff and represented that
the acquisition of the Crosley had already been approved by Howard Castleman, the principal
officer of the Plaintiff. This representation was patently false when made, and the falsity of the
representation was a) known to Mr. Flynn; and b) was not known to the Plaintiffs representative
to whom Mr. Flynn directed the false statement. The Plaintiff relied upon the statement not
knowing that the purchase had not in fact been authorized, and as such the purchase price for the
11Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
Crosley was sent to the Defendants, whereafter they purchased the vehicle, and then proceeded
to hide it from the Plaintiff.
47. — Regarding the 2013 Cadillac referenced above, during the period where the
Defendants withheld the vehicle and refused to deliver the vehicle to the Plaintiff, the
Defendants made personal use of the vehicle which was not in furtherance of the Agreement.
When the vehicle was finally delivered, the Defendants had put more than 3,000 miles on the
vehicle in a short period of time (i.e. between October 2019 and May 2020). The photograph and
Carfax report attached as Exhibit “4” show the additional 3,057 miles added to the vehicle’s
odometer between October 2019 and May 2020.
COUNT I- BREACH OF ORAL CONTRACT
48. Plaintiff realleges paragraphs 1 through 47 set forth above, and further alleges the
following:
49. A valid, binding, and enforceable oral agreement existed by and between the
Plaintiff and the Defendants as alleged herein.
50. Pursuant to the Agreement between Plaintiff and Defendants Mr. Flynn, HWI,
HWL and HWASI, Mr. Flynn was obligated to provide Show Cars with contemporaneous proof
of all purchases and sales of vehicles, and all expenditures associated therewith (specifically
including all use by the Defendants of the Plaintiffs monies and/or credit cards).
51. Additionally, the Defendants were to a) tender to the Plaintiff its share of profits
generated by the sale of all vehicles acquired and resold pursuant to the Agreement; and b) to
deliver the acquired vehicles to the Plaintiff upon demand if demand was made by the Plaintiff.
52. The Defendants breached the Agreement by way of the conduct alleged herein,
specifically including, but not being limited to, the following:
12Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
a. Despite the Agreement as set forth above, Mr. Flynn failed to comply with
his obligations to a) provide Show Cars with contemporaneous proof of
purchases and sales of vehicles; b) to deliver profits from vehicle sales to
the Plaintiff; c) to deliver reimbursement to the Plaintiff for expenses
incurred by, or paid by, the Plaintiff; and d) to deliver unsold vehicles
acquired with the Plaintiff's money to the Plaintiff upon demand made by
the Plaintiff.
b. The Defendants failed to provide the Plaintiff with an accurate accounting
for what was purchased, expenses associated with purchased and sold
vehicles, accurate purchase and sale pricing for associated vehicles, and an
accurate identification of profits generated by the sale of sold vehicles.
c. The Defendants furthermore failed to sell all vehicles purchased under the
Agreement, and then failed to deliver to the Plaintiff unsold vehicles
despite demand for delivery of the vehicles having been made by the
Plaintiff.
d. The Defendants obtained titles for purchased vehicles in names other than
that of the Plaintiff, in derogation of the parties’ agreement to have titles
issued in the name of the Plaintiff for any vehicles purchased under the
Agreement.
53. Asa direct and proximate result of the Defendants’ breaches as set forth above,
the Plaintiff has sustained monetary damages.
WHEREFORE Plaintiff, SHOW CARS BOCA RATON, LLC, demands judgment
against the Defendants, MICHAEL FLYNN, JR, HOLLYWOOD WHEELS, _INC.,
13Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
HOLLYWOOD WHEELS, LLC and HOLLYWOOD WHEELS AUCTION & SALE, INC., for
damages, court costs, pre-judgment and post-judgment interest, and all such other relief which the
Court may deem just and proper.
COUNT II - MONEY LENT
54. Plaintiff realleges paragraphs 1 through 9 and 11 set forth above, and further
alleges the following:
55. Separate and apart from the Parties’ Agreement, on February 20, 2020, the
Plaintiff lent Mr. Flynn and HWASI the sum of $40,000.00.
56. Specifically, Mr. Flynn asked the Plaintiff to make the loan. See Exhibit “5”
attached hereto, which consists of an email for wiring instructions for the loaned sums, as well as
wire transfer confirmation of the monies loaned to Mr. Flynn and HWASI for the intended use
stated by Mr. Flynn and HWASI.
57. As collateral securing repayment of the loan, Mr. Flynn and HWASI agreed to
deliver to the Plaintiff, at the Plaintiff's business address in Boca Raton, Florida, a Porsche
Tractor (with an estimated value of $30,000.00), for the Plaintiff to keep in its possession until
the loan was repaid in full by Mr. Flynn and HWASI.
58. The Plaintiff, Mr. Flynn, and HWASI agreed that the loaned sums were to be
repaid to the Plaintiff upon demand made by the Plaintiff, and upon repayment in full the
Porsche Tractor would be delivered by the Plaintiff to Mr. Flynn and HWASJ at a location
designated by them.
59. Mr. Flynn and HWASI received the loaned funds from the Plaintiff, but never a)
delivered the Porsche Tractor as collateral; or b) repaid the loan upon demand by the Plaintiff.
60. Despite multiple demands, the Defendants have failed to repay the loaned sums.
14Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al.
Case No. 50 2020 CA 011933 XXXX MB AN
61. Defendants owe Plaintiff $40,000.00 that is due for money lent by the Plaintiff to
the Defendants on February 20, 2020, together with interest thereupon at the prevailing statutory
prejudgment and post judgment interest rates.
WHEREFORE the Plaintiff, SHOW CARS BOCA RATON, LLC, demands judgment
for damages against the Defendants, MICHAEL FLYNN, JR, and HOLLYWOOD WHEELS
AUCTION & SALES, INC. for money lent in the amount of $40,000.00, as well as interest,
court costs, and such other and further relief that this Court deems just and proper.
Respectfully submitted,
PADULA BENNARDO LEVINE, LLP
Attorneys for Plaintiff/Counter-Defendant
3837 NW Boca Raton Blvd., Suite 200
Boca Raton, Florida 33431
Telephone No. 561.544.8900
Facsimile No. 561.544.8999
DATED: May 17, 2021
By: __/s/ Stephen J. Padula
STEPHEN J. PADULA
Florida Bar No. 182362
Email: SJP@PBL-Law.com
R. NATHAN PATE
Florida Bar No. 26737
Email: NP@PBL-Law.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
the Florida Courts E-Filing Portal via Email donschultz@netscape.net; don@lawus.com to:
Donald J. Schultz, Esquire, 535 Central Avenue, St. Petersburg, Florida 33701, on this 17th
day of May, 2021.
By: __/s/ Stephen J. Padula
STEPHEN J. PADULA
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QB4101GENERWROACZ SHEETZ 00008431 HARRIOBURG PA
TOICO4SEROSHT2UJA GABRIELLA ITALIAN REST HARRISBURG PA
Tesaenienssesosay DODGE CITY USAING HARRISBURG PA
oatoreeTmAZzTDOL _BHERTZ 00008208 MUNCY PA
TSAOAN1CTESENMGYX _ SKEBTERSBSQ_1 SHAMOKIN DAM PA
SS492600TSSZIHRGZ ___INTUN‘SYUNZERO AUTO 843.3427030 FL
GpaessreTsteLHkoV = HOTELHARRINGTON DUSHORE PA
0.08,
0.000
{te
{ses74\
Viel
280,007)
OHBOKIN carota FOLIO #410498
CHBCKAN 0110988 FOLIO #xxxxnaxxnx
Ov.at 0807 © GeaatEASGERNate8s © DEST WOTRNPREM-THEONTR HARRISBURG PA ‘itaisaa}
CHECKIN OT/2840 ___oLio #1103088 ra
06.06 ot07 EBAEUETEGSSCQHMWO HOTEL HARRINGTON DUSHORE FA Yaead,
GHECKAN 0410 FOLIO texxvxnxnne
08-07 C808 _O8AIOINEVEFXUNPCA GHERTZ 00009840 FISHBRGVILLE VA (siti)
0.07 04.00 _custorveveaooRFVe GHEETZ 90008900 NUNOY PA re
O807 0808 SUSTEOLEWHLWYLEKG BPOOZBEAISKENLY 96 GPS HENLY NG Vaasis'
06-08 0f08 G8ANETEXADRFSGZF HAMPTON INNS FLORENCE BC Ta)
04-46 c2908s7eXOOHBGPHZ SPERDWAY 06637 BROGKAVILLE FL. Vane
bet ‘SMELL OWL 910020784QF5 FOOLER GA Avisaaal
ant INTIIN*STUNZERD AUTO _613-9127030 FL 260.00]
0846 INTN *BTUNZERD AUTO _013-9827039 FL 250.007
0816 08s Se4azser2BVZHLPIE INTHN*BTUNZHED AUTO 613-9127038 FL
08-20 082 dsators7asHeaAtos WAWA 6140 00061482 87, PETERSOUR PL
0824 08.22 ES487027AZQOMLBSS —— COKERTIRECO-MO 0002816998 TH
Q8-at _ob-a2 SSde7OATAZQOMLTPA — COKERTIREGO-MO — o00zs102998_ TH
08-21 08-22 S8438877AGDW973JG HILTON GARDEN INN WEST PALM BCH FL
CHECKIN o/2tito FOLIO #296303
O8ad OS410187AIHOZMDSS —— WAWA STORE 81800081984 MANATEE CITY FL
08.23 68432867A5SYIRB. INTIN‘STUNZEED AUTO _013-9127030 FL
08-29 68432867A88YIRG INTAN*BTUNZEED AUTO 819-9427039 FL
06.25 SBS087872FXGHFKHM © GHELL OIL 67843704100 OKEECHOBES FL
MIGHAEL J FLYNN JT
TOTAL ES | 97,015.27
FINANCE ending ANNUAL
Fewseate nate (nay very) CHARGE ENTAGE RATE
Purchases 0.00 .05055% v 0.00 10.40%
Cash Advances 0.00 “05887% v 0.00 24.40%
| Combined Annual Percentage Rato for this Billing Cyclo 21.40%Statement Closing Dato: 09/26/2019
: Account une:
Pego2of2
Your Business Credit Card Statement
TRANSACTIONS
‘Tags Post
Det Bate Merchant Namo or Tronsaoven Daserpton
ADVANCH AUTO FARTS #91 BOCARATON FL
GOLD AIR DISTRIBUTORS 861.3140808 FL 5
Oat6%s, S84szb0b205INOZIP AMZN MKTP US*4OZB287V3 AMZN.OOM/BILL WA.
oots degszseassslyaeae AMZN MKTP U8*3146T4J83 AMZN.COMIDILL WA.“
oady egebIgeseTaRITD AMZN NKTP Uorzee0L9099 AMZN.CON/BILLWA
Ob? _S848370RAZSNAWHV ADVANOW AUTO PARTO #01 BOGA RATON FL.
SeAgO7TESSCVVUIEH CHAMPION PORBOHN _eesazsdiz6 FL
GBASCITESAPOTAFTY, COLD AIR OLSTRIGUTORG,«B01-9146008 FL.
CUA2OUOLALWEAEQEP \ ZIPREGRUITER, INO," 8647470403 OA
Sesaaserssvovensw THE TIRE RACK.” 000.420-09801N
QBSTONSITSNAWSF ADVANUEAUTO PARTS #91 BOGA RATON FL.
S8409700817SNGWHS ADVANGE AUTO PARTS #04 BOOA RATON FL
MOUATAGTLISYFES —_OOLDAIR DISTRIBUTORS 801.9148008 FL.
ASBRTESTLIGAFRZ "COLD AIR DIBTRIBUTORD, 664-9140808 PL
SUBITOSTATSHBWHD ADVANCE AUTO PARTS #04 BOD RATON FL 22.74
S84S¢OTOTTLMUPRTH __OOLD AIR DISTRIBUTORS _661-9140¥06.FL
Ss200BEARQEEGWOE _ O'AKILLY AUTO PARTS €4 BOGARATON FL’
GOLD AIR DIGTRIQUTORS #61-3560608 FL Soe,
PRIF MART 199 BOCA RATON FL Me
GOLD AIR DISTRIBUTORS 864-3146808 FL
OTEPHEN GALZMAN
TOTAL NS 910,445.62
08-23 0828 68808297Q14YD0KZ — HAMPTON INN OCALA FL
CHECKIN 08/2910 FOLIO azzsest
QB27 08-28 GS4SZNSTFOVIOORIF INTHN*BTUNZEHD AUTO o19-3127090 FL m4
08-28 0829 SS4SZE67GSEQIHIKK NTN *STUNZEED AUTO 619-3127090 FL 125.00"
B8432807G88Q9H7L8 ——INTHN*BTUNZBED AUTO 013-3127030 FL 78.00]
Se4saseTNSGRITTET WNTIN*STUNZBED AUTO 049-3127039 FL 40.00
BOAS280TNSSRITIFA _INT*N*STUNZEEO AUTO _619-3127030 FL 40.00
INTIN*BTUNZHED AUTO 843-3127020 FL 300,007
427030 FL
00:08 08-06 _86492887REGNXSLOK
ZZ
OS41O1N7YIHOMIEXY — WAWAS141 00051417 LARGO PL.
GS847O07VELUSODKN WALKER FORD CLEARWATER FL
GORQEBVWAR O'REILLY AUTO PARTS 44 LARGO PL
BIRQEAVWOR O'REILLY AUTO PARTS 44 LARGO PL.
TITAN *STUNZEED AUTO 019-9127030 FLL '
Ln fes.are ve d
“Wt
09-46 SNT*IN*STUNZBED AUTO _813-127030 FL.
Ode16 88TH STREET AUTO PARTS LARGO FL
2080 Osa101eBssHeANNJS —_ WAWA5200_00062089 BRADENTON FL
Qs4seeTSO4E4HGSJL «= HAMPTON INNS WEST PALM BGH FL
OHECKAN o9/terte FOLIO #354003
O18 O89 O290897SSEPLHFATY _ T8T* GUACAMOLE TAQUERI JUPITER FL.
0848 0820 OSMOKENSIFRAGEVZ ——PRIP MART 189 BOCARATON FL
Oot 08.20 S2304868C0RWVIHHT — SUNOOO 0788760201 GPE JUPITER FL
09-20 00-22 Osetoses7JHSAREBS — WAWAS248_ 00062489 SEMINOLE FL
09.23 08-24 Os4tONNeAJHOZAIY _— WAWAS218 0002160 GEMINOLE FL
09-23 08-24 | O8Z2702SAGPKRATHZ © JOY NOODLES AND RICE WEBY PALM GOH FL.
MICHAEL J FLYNN JR
TOTAL $4,417.02
lodii FINANCE Corresponding ANNUAL
Bat Broo at may very) CHARGE PERUENTA ERATE
Finance Charge
Dotall
Chenannn aon Ieee ees nae‘Statement Closing Date: 1728/2010
‘Account Number:
‘Your Business Credit Card Statemont
o{ TRAneAoTIONS
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ateasrenniranavey
eeasrexianave
rausramriroraee
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‘COLD AIR DISTRIBUTORS.
nova BOCA RATON FL
S00ARATON nL
HOCARATON FL
couoam oy¥Aibyrons sevszeoe re
Tat noufburor Nayeorinay a14gH 7
coun oa TABUYoRs, statins 7
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‘WORLURS AUTO PARTS
"AUTQUONS £040 DELRAY BAGH PL
ADVANGE AUTO PARTE DBT BOOA BATON FL.
ota AIR OIATRIDUTORS
ATEPHEN GALEUAN
101
sugeatapatarurat,
LONECKAN eui28/0
eexreavaneceenste
nayguranDexHeNoa4,
WAMPTON INNS WABY PALM DOH FL
Fouio asnetae
‘GUN OLUS CAFE WE6T PALM GHA FL
‘OREINFONOOREENSEORO NO
‘AB@ TIRES AND AUTO PINELLAS PARI FL
WAWA STONS G{4GCE43064 MANATEE CITY FL.
seat RELUTICUNGONSTARR__TAVERNAKYMAGOOARATON FL
too WeasraLearasaeW—WAWPTON INNA WAST PALM ACH PL
OHEGKIN two Powe.
G]OUITIKEPLMDAYA TAT: OUAGAMOLE TAQUARI JUPITER FL
aan
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‘CARUINE @ RESTAURANT TAUPA FL
030 WORLOWIDEAVOTIONBERS 2400208780 1
ereigieepanesiere _ WAWACRIG_c09sz160 OuitINOLE FL
AUUUACUREPUYESY__ ALLEQNT/TRAVEL
“raaterrevenvwar
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rasaeeayave
OHEOKAN surtaiee
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(OAA GLASEIO CANE, LLG ONEENSBORO NO
‘FAIRFIELO NW & OUITEO NERGTIBY PA
Fouio vseeats
Tena Tee exuavrz mzeuean ALA RENT-AGAR RETA IODLATONN FA inav|
atateneese AYAN OTY MIODLEYOWH =|
2-10 aHHnaTNGHOLPANTO TOWANDATAIRPIRLD IN TOWANDA PA Veal
CHECKIN sorters FOLIO s100006 |
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ears ’
Pogadel 3 foes 2000 cao cort
tous oxeiete es)Staloment Glostig Date: 10/26/2019 ° 2
7 Account Number; a
7 Pago 3of3
Your Business Credit Card Statement
TRANSACTIONS
Post ‘Amount
Dato Reference Number Merchant Name of Transaction Doscription frodh Chur
1047 INTAN *OTUNZEEO AUTO _613-3127038 FL
10.17 40.20 ABO TIRES AND AUTO PINELLAS PARK FL. 3.00 |
$048 40-01 ASABONSOSIGITNWES HILTON ROCKVILLE MD ROCKVILLE ND rages
CHROKIN 4071010 Fouio #700374
10-20 10-21 S843887083V88ZJHH = HAMPTON ING LUMBERTON NO teeny,
CHECKIN $0/20/19 FOLIO #125633 :
10-29 10682 26247sORNOSPWAHGF =~ HAMPTON INN SAVANNAH GA 32.74)
CHECKIN 40/7119 Foto vocoozs98
f0-22 40-29 osasotea7sHerReLs WAWA 5215 00002189 SEMINOLE FL
1022 10026 NASOAR CAR WASH + 82MI SEMINOLE FL
1026 10028 O2090EBZKVHPW STH STREET AUTO PARTS LARGO PL.
MICHAHLU FLYNN JR
TOT, $14,
ch lc ding ANNUAL
reegegre [vasa] amtaeay | SUANSE | ene
Purchases 0.00 04927% v 0.00 17.89%
Cash Advances 0.00 .06740% Vv 0.00 20.00%
[ Combined Annual Percentage for this Billing Cyclo 20.09% |
IMPORTANT NEWS.
‘The Service Members Civil Rellef Act (SCRA) provides
Important financial and legal protactions to service members ~
Including cape on Interest rates, stays on certaln legal
protection from eviction, and termination of leases without
Tepercussions. Learn more at www.milltaryonesource.mit
(search for'SCRAY),
Nothing saya easy like hendling g your Business Credit Gard
with SunTrust Business Cerd Online. You can manage your
expenses, limit employee spending, schedule payments end make
‘changes to your account at your conventence, Learn more at
Bunirust.com/ebeo or call ue at 066-674-2429,Stelement Closing Datos 11/26/2019
Account Number
Pagezets
Your Business Cradit Card Statement
‘TRANSACTIONS,
suajateyntenviaen
acacsronyyranaiax
CARAQU TIAE, errr
‘oot AiR DISTRIBUTORS 191-9144 aa4t
a uf
tuu7iorranat0n
ateravranon.pt avo an cinta
nuceHeyyNRT —_eannouL TY” ergzEanE
aASTHTHKWRAE_eekO AN OSTABUTONE asra:44E
3
GHTAALHM RAHN _80U-89740GA NCUA
teuraenatrnanynovghon auto rante
nAgRLBFAWED
equesreqai7aynera
AMEN UXT? US*GANUITUN) AMZN OOABILL VA,
"ANZN HKTP US°RGVIBEITS ANZN.COMPBILL WA
‘GOHUUAGHER PARTS OROUP_BU1-1049400 FL.
eqeusrearirawoto
euUUsTOATITINELI
ESCISTOAT I TIN
tone Wad HEAMNITANTMEOHLAG —_COLOAIB DISTAIDUTORS BOGARATON FL.
srerien ntzunn aed
321A, SV, 8)
jean oat _ouetwranrwernirza —naanraaoure « 7m
$Q34 TEMNCTEFGIKPHEQL ZUGOARELLNS ITALIAN A WEST PALL DEA PL Nia |
AOS SUATEITIOURHIZIKG HAMPTON INttO WEOT PALM BON FL anf
eucogie wine rouon (use
HAVAMA RUGTAURANT WEGT PALY DEA PL ai
GHARHASVEP ‘HAMPTONINNS WEST PALM BOM FL “pe | \
Chtcem (usu rouge fl
ieee WAIOAR oan Wadii-anu/aenmnane Fo saat
N03 14-05 SnaeaTeUHAXHMOAVE — QHALE OM a7easeazz0¢ OKEECHODOE FL £ aaa, (|
(ear tea _euasersenumeayaya _ WAWA@TONG stuodoatese WANATER CITY FL Fave
$4.02 44t4 _onateieeKsHeasAch _ WAWASI11_eae4asie WaOT PALI BHA PL dates
1402. (180 SLASEUTEKIEXZAKDO—_HANPTON INO WHST PALS COU PL 2
CHECKIN G4mpRie FOO BINA?
AGE 11-47 ECAUOTTONETKWOIED__ BELLATTAIARESTAURAN LARGO FL
Site toe TeMGNHPALNERMPR —_CANLIOLE EVENTS CARLIOLE PA
S007 {140 _eHTUNDEROIMOFEGH NASCAR GAN WABH Gai AEMINOLE FL
wort tas , Pagonet 3 019 2000 cto 0010 a8 OLnIRATZtaLStetemont Closing Date; 11/26/2019 a
. Account hunt aT
Poqo3ota
Your Business Credit Gard Statement
‘TRANSACTIONS
Tene Pe ‘Amount
Bate Number creat" Chars
00844 ISCIOAMRIHEZHLOT WAWASI20 _cooutzea aT. Asus
M18 Mito soaasezeramsesissTIKANIG 87 PETERSBURG FL. RYTEY}
Meta 44668 cuatoronvsHezaKer __WAWASIIE _¢0 ENINOLR FL Ni
St10 A180 _ONA1OtDASINERNO? — WAWA STORM 1001 Gaia
Mf0 4401 aBStbZAMLRULAVAT [iora,
OnEORAN 4118019
TORUNAIAUKYKETIZE
Nast
30414 AYIA 621 51888 BRADENTON PL
A4H0__ thet A042tugAsR@Qubras. PAYPAL *ERAY CAR PART 4040307793 OA
$4680 412 GS31020AILKJ2YMV1—_HOLIDAYINN. wosesroaco FL
OHACKAN 41/401 Foun atratey
19640 ase HOLIDAY INN angnorseoo et.
NOZOANLKIZORIT
QuROKIN 4tHOHe FOU wirete2
Stat 44.92 _ ss4nnnoatnrooaay PAYPAL ‘EBAY FORALLEYE 402037739 OA
Meat tha ‘COURTYARD BY MARRIOTT. W PALM BCH PL
ounotin 110810 Fouo s3a800
Meat _ 1424 a0zeatUANDIVEPCDY NASCAR OAR WASH» SEMI SEMINOLE FL
123 14:3h__ SGN0EAANWOELHEWA__GABYS FAMILY RESTAURAN CLEARWATER FL.
{4-83 1400 TESCH(SARLHONETEZ MIDDLE GROUNDS ORNL SAINT PETARSD FL
MICHAEL J FLYNN JR
TOTAL $1,757.70
e iC ding ANNUAL
Finance Charge Average Dally Seance PERCENTAGE RATE
cs 000 v 0.00 17.98%
Cash Advances 0.00 v 0.00 20.09%
10 Rate for thia Billing Cyole 20.09%
[combined ‘Annual Percent
IMPORTANT NEWS:
‘Tho Sarvica Members Civ! Rellef Act (SCRA) provides
Important fnanctal and tegel protections to service members »
Including caps on Interest rates, slays on certain legal
rotactlon from eviction, end termination of leases without
Tepercussions, Learn mora at www.militaryonesource.mil
(search for SCRA).‘Slatamont Glslng Date: 2726/2010
Account Numbers
Your Business Credit Card Statement
Pagezota
‘TRANBAOTIONS
us pou
Merron Name
Frontscten
~SOLB AIR 117 BOCARATON Ft
ATOUNHUALENAoPHES _TIREWUA (06 FT LAUDEAD 0
1-08 WeensTOAMITINGIIL ADVANCE AUTO PANTS 581 BOCARATON Px
a WUXONUOER _4767103B00A BATON €L
so wreruraranionon coin an vir agcanstou eg”
stad eeatateanirinaros ABVANON AUTO Panta ant Boca aAfaN PL,
sso \presaeantranaza Aovanon auro pare sn g0oWAaton eb
tuto Rguarantranaiva _apvanor auro panre ent apfoanaron ne
tsa suyyeancruarye fAOOA RAYON vt
dito ecansTbgrarinazza ADVANGE AUTO PARVC#ITBOGARATON FL
ui UT BOONAATON FL
at FOMPANG BEAGH PL,
sat TEATITINQION, _AOVANC AUS PARTE
att
eat
sean
eT
[PR PUANT 104 BOSARATON TL.
phi WARE (01 BOCARATON PL
oT ye eMPKIE TH
1244 OLD AIR 117 BOB RATON FL.
$244 _wuatenerrinoiyy” _ADVANOH AUTO FARYQ.G1 BOOA RATON FL
AUUESTOARITINGEtU_— ADVANON AUTO PARTO 104 DOOARATON FL
(ow th
a1quabawsranasts ADVANGE AUTO PARTE £91 BOCA ATOR)
biaveariaway “GOHUMAGHER PARTE OROUP_HH4seteae
afltssrazexrvaan _oreice onporsesoca Raton
[GOLOAIR 117 BOCARATON FL
GOLD AIR {17 BOCA RATON FL
[PAYPAL *HEAY JOAPART _ 462138773304
[PUBLIY STEH BOCA RATON PL.
‘SOHUMACHER PARTS GROUP cot-asezete PL
‘STEPHAW BALZUAN,
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31
104
3000
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Mae ar (NABGAR GAR AGH. SEMI, 07 Glad. toy
Hote star WILLS STARTEG AND ALY OAINT POTERGO FL
Hae tae ‘SHELL On e7e4e¢a0e47 LARGO FL
M437 _ 4 C0aGUUTAGRATONXDN —O'RRILLY AUTO PARTO.AGLARGO FL L
tara \GRGUBKXEZ O'REILLY AUTO PARTS 44LARGO FL.
Moe ae
1203
i209
1243 FRREMIERAUOTION OROUP aU4nenTING NG
1208 AWA NAHE 22 PINELLAB FL.
a8 WAWA I216 BMINOLE FL
$244 AULCTUOARUUGHIOSY ___ITALIAAT RIVER ITY PUNTA QORDA FL
200 tnte “ANELL OW 7440421807 LARGO FL
EXRONMOBIL ¢7EI7120 ARAGOTA PL.
'ATHBNIAN OARDEN SAINT PETERS
‘CLUBHOUSE RESTAURANTLARGO PL
[QRNTLLY AUTO PART@ 44 4ARGO FL
InOy Sut OM ereeatta eagvaavinal WY.
"ARPLIGO RACING THCIINGL CLEARWATER FL.
[WARGOA PABIONT TOOLS (LAROG PL.
QURRILLY AUTO PARTS 48 4ARGO FL
‘O'REILLY AUTO PARTS 44 4ARGO PL |
‘GeerotantoMerKuss —_ WAWACIIS _ob LTE D>
<@
Mike Flynn»ain r I »
phone el LTE
@
Mike Flynn >
Sat, Jun 20, 6:20 PM
We spent four months
hiding that 66 Corvette
and preparing it by get-
ting all the documenta-
tions and all the inspec-
tions completed. | told
you | was working on a
deal with bring a traller
and the car was set to
_ launch also had been.
talking to Rob about
putting it In thelr ontine
Monterey auction Instead
today we threw it on
eBay like it's Just another
used car. Now neither
RM or bring a trailer Will
excent it...oh well.EXHIBIT “4”8/11/2020 CARFAX Vehicle History Report for this 2013 CADILLAG ESCALADE ESV LUXURY: 1GYS4HEF7DR298041
This report provided free of charge by: '
Show Cars of Boca Raton EXHIBIT "4"
1871 NW 1st Ct, Boca Raton, FL 33432
561-250-0780
Vehicle History Report”
2013 CADILLAC ESCALADE ESV No accldents reported to CARFAX
LUXURY
VIN: 1GYS4HEF7DR298941
4 DOOR WAGON/SPORT UTILITY vA CARFAX
6.2L V8F OHV 16V lA No damage reported to
FLEX FUEL jewmratents [io eeneeecem nnd mee ee eeee memes tate nee
ALL WHEEL DRIVE
2 Previous owners
14 Service history records
SB Hypes of owners: Commercial,
ersonal .
This CARFAX Report Provided by:
Show Cars of Boca Raton i
Last reported odometer
32,478 reading
Eres Dea scalded le
This CARFAX Vehicle History Report Is based only on Information supplied to CARFAX and avallable as of 8/11/20 at 9:09:46 AM (cov).
Other Information about this vehicle, Including problems, may not have been reported to CARFAX. Use this report as one Important tool,
along with a vehicle inspection and test drive, to make a better decision about your next used car,
Ownership History :
a Syrs, 5 mo.
| Last reported odometer reading 7 _ 26,840 7 32,473
i (cAIRIF| x] Title History
QOwnert By Ovmer 2
|
|
7
'
{_.CARFAX guarantees the formetonin ds ection iene i
Salvage | Junk | Rebuilt | Fire | Flood | Hall | Lemon | a Guaranteed FA Guarantecd
val Fall i Guaranteed pq Guaranteed
i Kd NoProblem No Problem
GUARANTEED - None of these major title problems were reported by a state Department of Motor
Vehicles (DMV). If: you find that any of these title problems were reported by aDMV and not Included In this
report, CARFAX will buy this vehicle back,
t
Not Actual Mileage | Exceeds Mechanical Limits
j-
|
|
t Register | View Terms | View Certificate
hitpsvAvww.carfaxoniine.comlaplrepont?vin=1GYS4HEF7DR298041 &lrack=true
158/11/2020
i
_Notal altace accidents / issues are Feported | to GAREAX
“Total Loss:
“Structural Damage
“05/24/2013
05/81/2013
09/21/2013
| 09/23/2013
No total loss reported to tot CARFAX,
No structural damage teported to 0 CARFAX.
Airbag Deployment
No alrbag g deployment r reported to CARFAX, Reported -
Odometer Check Nolssues No Issues
4] Indicated Indicated
No indication of an odometer rollback.
7 Nolssues 7 Issues
FA te d ted
ecall BEE ; :
NoRecalls rz No Recalls
No open recall e reported to CARFAX, Check for open recalls on GM 7]
_ehales at recalsomcom. EEL ' EE heer : a 7 ere :
Basle Warranty ‘Warranty Bed Warranty Eat I
‘rina waranty estmsted to have oxlred,
GAnGoK Detailed Hi is story
Owner 1 a A “Commercial Vehicle
Purchased: | Low mileage! This owner drove less than 6,336 mi/yr
2013 the Industry average of 15,000 miles per
year,
Mileage Source Comments 7
| Orginal OnStar Vato equipped with onstar 7
Equipment
Get 3 free months of premlum OnStar with Automatic
Crash Response, Roadside Assistance and Remote
Door Unlock by pressing the blue OnStar button Learn
a a asa ee eee mel te te Et
04/02/2013 Dealer Inventory Vehicle offered for sale
8
; 1247 Missourl Mechanical Issue reported
https:/Avww.carfaxonline.com/apl/report?vin=1 GYS4HEF7DR298041 &track=true
CARFAX Vehicle History Report for this 2013 CADILLAC ESCALADE ESV LUXURY: 1GYS4HEF7DR208041
Additional History owner GOvmer 2
No Issues
Reported
Nolssues
4\ Reported
Nol issues
Reported
No Issues
n Sales Company
Springfield, MO
Pi 7 356-661 1
thompsonsales.com
tr 4.6/5.0
158 Verified Reviews @
y 185 Customer Favorites |
“451 Thompson Sales Company ”Vehicte sold ~
Springfield field, Mo !
thompsonsales.com |
fr 4.6/5.0 ;
158 Verified Reviews @ ;
y 185 anid Favorites |
Service Facllity + Vehicle tower
: Thompso
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Filing # 126965194 E-Filed 05/17/2021 04:33:40 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2020 CA 011933 XXXX MB AN JUDGE HOWARD COATES, JR. SHOW CARS BOCA RATON, LLC, a Florida limited liability company, Plaintiff, v. MICHAEL FLYNN, JR., an __ individual, HOLLYWOOD WHEELS, INC., a Florida profit corporation, HOLLYWOOD WHEELS, LLC, a Florida limited liability company, HOLLYWOOD WHEELS AUCTIONS & SHOWS, INC., a Florida profit corporation, Defendant. HOLLYWOOD WHEELS, INC., Counter-Plaintiff, v. SHOW CARS BOCA RATON, LLC, a Florida limited liability company, Counter-Defendant, / SECOND AMENDED COMPLAINT Plaintiff/Counter-Defendant, SHOW CARS BOCA RATON, LLC, sues Defendants, MICHAEL FLYNN, JR., HOLLYWOOD WHEELS, INC., HOLLYWOOD WHEELS, LLC, and HOLLYWOOD WHEELS AUCTIONS & SHOWS, INC. (collectively “Defendants”), and states: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 05/17/2021 04:33:40 PMShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN PARTIES, JURISDICTION AND VENUE 1. This is an action for money damages in excess of $30,000.00, exclusive of attorney fees, court costs, pre-judgment interest, and otherwise satisfies the subject matter Jurisdiction requirements of this Court. 2. Plaintiff, SHOW CARS BOCA RATON, LLC (“Show Cars” or “Plaintiff”), is a Florida limited liability company, with its principal place of business in Palm Beach County, Florida, and at all times material has been and remains sui juris. 3. Defendant MICHAEL FLYNN, JR. (“Mr. Flynn”) is an individual, is over the age of eighteen, and at all times material has been and remains sui juris. 4. Defendant, HOLLYWOOD WHEELS, INC. (“HWI”), is a Florida for-profit corporation, has its principal place of business in Pinellas County, Florida, and at all times material has been and remains sui juris. 5. Defendant, HOLLYWOOD WHEELS, LLC (“HWL”), is a Florida limited liability company, has its principal place of business in Pinellas County, Florida, and at all times material has been and remains sui juris. 6. Defendant, HOLLYWOOD WHEELS AUCTIONS & SHOWS, INC. (“HWASI”), is a Florida for-profit corporation, has its principal place of business in Pinellas County, Florida, and at all times material has been and remains sui juris. 7. Venue is proper in Palm Beach County the causes of action asserted herein accrued in Palm Beach County, Florida. More specifically, a) all sums paid by the Defendants to the Plaintiff under the oral agreement referred to herein as the “Agreement” were paid in Palm Beach County, Florida; b) all sums which were supposed to be paid to the Plaintiff pursuant to the Agreement but which the Defendants failed or refused to pay were due in Palm BeachShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN County, Florida; c) performance by the Defendants pertaining to delivery of specific vehicles was to be made at the Plaintiffs principal place of business in Palm Beach County, Florida (as identified in Exhibits attached hereto); and d) Mr. Flynn repeatedly travelled to the Plaintiff's principal place of business in Palm Beach County, Florida for purposes of meeting with the Plaintiff regarding, or taking action in performance under, the Agreement. 8. All conditions precedent to the initiation of this action and the assertion of the claims as set forth herein have occurred or have otherwise been waived. FACTS 9. The Plaintiffs business, located in Boca Raton, Florida, buys and sell luxury and unique vehicles. 10. In late 2017, Defendant Mr. Flynn (acting individually and on behalf of HWI, HWL, and HWASJ), entered into an oral agreement with the Plaintiff which entailed Mr. Flynn and Mr. Flynn’s three entities, HWI, HWL, and HWASI (the “Hollywood Wheels” entities) acting as an agent of the Plaintiff for purposes of locating, procuring, and reselling vehicles for profit. This oral agreement is referred to herein as the “Agreement.” 11. At all times material hereto, Mr. Flynn has been, and has represented himself to be, the president of HWI and HWASI, and the manager of HWL. 12. Pursuant to the Agreement, the Defendants agreed to act as agents of the Plaintiff to acquire vehicles which possessed a potential for resale at a profit. With this objective in mind, the Defendants would attend auctions (with or without employees of Show Cars present), and would identify vehicles for potential purchase and subsequent resale for profit. The Defendants would then contact the Plaintiff for authorization to purchase vehicles, and if verification and authorization were given, the Plaintiff would then transfer funds to the Defendants sufficient toShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN purchase the vehicle or vehicles identified by the Defendants. Thereafter, the Defendants would advertise, or seek out buyers for, the vehicles for subsequent resale. 13. Under the Agreement, the Defendants were to obtain the Plaintiffs express consent before purchasing any vehicle in furtherance of the Agreement. 14. Per the terms of the Agreement, the Plaintiff agreed to pay the purchase price; other acquisition costs; and expenses associated with the maintenance and/or subsequent listing or advertisement of the vehicles for resale. 15. Per the terms of the Agreement, when a vehicle was ready to be resold, the Defendants were to provide the Plaintiff with an itemized accounting of the purchase price and all costs associated with the vehicle (as paid by the Plaintiff), as well as the final agreed upon purchase price to be paid by the new purchaser of the vehicle. The Defendants were also required to obtain the Plaintiff's express consent prior to consummating a proposed sale of a vehicle. After a vehicle was sold, Plaintiff was to be reimbursed all of its expenses (specifically including those associated with the acquisition, maintenance, and/or sale of a vehicle), and any remaining profit was to be split equally between the Plaintiff and Mr. Flynn. 16. Additionally, per the terms of the Agreement, if any vehicle was to be resold at a loss, then the Plaintiff was to absorb the loss. Any intended sale which would result in a loss was only to occur after such a sale was expressly authorized by the Plaintiff. 17. Per the terms of the Agreement, if the Defendants paid any expense associated with a vehicle (due to circumstances such as insufficient time to obtain pre-approval and advanced payment from the Plaintiff), then the Defendants were to be reimbursed by the Plaintiff for such expenses provided a) the expense or expenses incurred were incident to the purchase and sale of vehicles pursuant to the Agreement; and b) the Defendants provided documentationShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN (such as receipts, invoices, etc.) identifying the expense incurred and the reason for which the expense was incurred. Common examples of such expenses were: a) auction site’s fees; b) vehicle transportation fees; c) hotel accommodations for attendance at auctions in furtherance of the Agreement, and d) fuel. 18. Mr. Flynn was also provided credit cards for accounts owned by the Plaintiff, the purpose of which was to facilitate the payment of expenses incurred in furtherance of the Agreement. The credit cards were provided to alleviate the need for the Defendants to come out- of-pocket for any expenses such as those noted above. Per the Agreement, the Defendants were only authorized to use said credit cards for expenses incurred in furtherance of the Agreement and were not authorized to use said credit cards for personal or other expenses unrelated to the Agreement. 19. Pursuant to the Agreement, the Defendants were to regularly provide the Plaintiff with receipts for, and any additional proof of, all expenses incurred. This specifically included any expenses charged on the credit cards provided by the Plaintiff. The Defendants also agreed to provide the Plaintiff with additional proof of, or support for, expenses incurred if such a request was made by the Plaintiff. The Defendants agreed to these conditions at the time the credit cards were provided. 20. At all times, the Plaintiff was to have full discretion over, and the absolute right of authorization over, any purchase or sale transactions made by the Defendants in furtherance of the Agreement. This was expressly agreed upon by the Defendants, as the Defendants were not advancing any of the purchase prices paid for vehicles acquired pursuant to the Agreement. 21. Pursuant to the Agreement, the Defendants were to receive payment for services rendered only from their equal share of profits generated from the resale of a given vehicle ifShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN such a sale generated a profit to be shared equally between the Plaintiff and the Defendants. The allocation of the profit share was always supposed to be 50% to the Plaintiff, and 50% to the Defendants. 22. Pursuant to the Agreement, if a resale were to result in an overall loss, the Defendants did not bear any portion of the loss, but were not paid for any services rendered incident to the purchase and subsequent sale of that given vehicle. 23. Aside from the equal sharing of profits, the Agreement did not account for, or call for, any further payments from the Plaintiff to the Defendants for any services rendered in connection with or in furtherance of the Agreement. 24. At no time under the Agreement did the Plaintiff ever agree to pay Mr. Flynn, or any of the other Defendants, a commission, salary, representative fees, or a finder’s fee, for any of the vehicles purchased or sold pursuant to the Agreement. 25. | The Agreement ended in July 2020 after the Plaintiff expressed its displeasure with the Defendants’ practices and their failure and refusal to: a) follow instructions of the Plaintiff; and b) provide documentation supporting payments for expenses requested by the Defendants. 26. Initially, Mr. Flynn would regularly send the Plaintiff detailed information regarding vehicles that were purchased or sold. As to purchases or sales of vehicles completed via auction, Mr. Flynn would send the Plaintiff copies of auction documents showing the purchase price paid for such vehicles, and as to sales, Mr. Flynn would send the Plaintiff checks for the vehicle sales proceeds issued directly from auctioneers. However, after some months, Mr. Flynn changed his course of conduct, instead depositing monies received from vehicle sales into accounts held in the name of the other Defendants, and then sending checks from those accountsShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN to the Plaintiff. The Defendants also stopped sending complete information to the Plaintiff regarding purchase prices paid for acquired vehicles, expenses incurred as to purchased vehicles, expenses incurred in connection with the sale of vehicles, proof of the sale price paid by a new buyer for a sold vehicle, or even backup documentation for expense reimbursement requests made by the Defendants. 27. Shortly before the end of the Agreement in July of 2020, the Defendants stopped sending back-up documentation to the Plaintiff altogether regarding purchase prices paid by new buyers for vehicles sold in furtherance of the Agreement (leaving the Plaintiff guessing as to the true price paid by a new buyer for a sold vehicle). 28. Despite repeated requests for back-up documentation and information which the Defendants failed and refused to provide, the Plaintiff's requests continued to be disregarded, all the way up to the initiation of this lawsuit. 29. Before the Agreement ended in July of 2020, and to avoid a complete breakdown of the Agreement, the Plaintiff sought to work with the Defendants around the growing information gap regarding purchased and sold vehicles. Mr. Flynn would contact the Plaintiff with minimal information regarding a specific vehicle and would relay the purchase or sale price and ask for authorization to purchase or sell the vehicle (often representing to the Plaintiff that if the vehicle was to be sold that the sale would generate a profit), and if approval was given based upon Mr. Flynn’s representations the given vehicle would be bought or sold. If the vehicle were being purchased, the Plaintiff would send either a check or wire in the amount requested by Mr. Flynn and which he represented as the “purchase price” for the vehicle. These sums would be sent to either: a) Mr. Flynn; b) one of the Hollywood Wheels Defendants; or c) to the seller of the vehicle itself (based upon Mr. Flynn’s instruction as to whom payment should be tendered).Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN 30. If the transaction were to be a sale, Mr. Flynn would report back to the Plaintiff that the vehicle had been sold and would then report the amount of profit he would be sending the Plaintiff as its equal share of the profits generated from the vehicle sale. 31. After some time, and due to the Defendants’ refusal to provide back-up documentation for a number of vehicles purchased and sold pursuant to the Agreement, the Plaintiff began to suspect that the Defendants were falsely inflating purchase prices paid for certain vehicles, and that the Defendants were falsely underrepresenting the sale prices of vehicles sold pursuant to the Agreement. 32. The Plaintiff's suspicions were bolstered by certain actions taken by the Defendants in derogation of direct instructions given by the Plaintiff, including the Defendants use of the credit cards provided by the Plaintiff for wholly unrelated and personal expenses. 33. | The Defendants were routinely deceptive in their dealings with the Plaintiff; for example, the Defendants’ refused to account for the whereabouts of a 1965 Chevrolet Corvette purchased by the Defendants with the Plaintiffs funds. As to the 1965 Corvette, the Defendants obtained a title for the vehicle in Defendant HWI’s name (which was not authorized by the Plaintiff), and then the Defendants proceeded to hide the vehicle from the Plaintiff for months. Despite demand for information regarding the status and whereabouts of the vehicle, the Defendants refused to provide information, until approximately late June of 2020, when Defendant Mr. Flynn openly admitted to the Plaintiff that the Defendants had spent months hiding the 1965 Corvette based upon their desire to get it ready for a listing with “Bring a Trailer”, a popular classic and exotic vehicle online registry. 34. Additionally, towards the end of the Agreement the Plaintiff began to realize that many of the expenses that were charged to the credit cards provided by the Plaintiff appeared toShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN be for the Defendants’ personal use. These expenses appeared wholly unrelated to activities in furtherance of the Agreement, and many appeared to be related to the Defendants’ other business activities conducted wholly outside the scope of the Agreement and performed for either: a) the Defendants’ own benefit; or b) the benefit of other third-parties on whose behalf the Defendants were working. 35. After an initial review of the credit card statements provided by the Defendants for the months spanning from October 2019 through March 2020, the Plaintiff came to realize that the Defendants did not provide any receipts for, or any explanation for, nearly $26,000.00 in credit card charges. A copy of a compilation of credit card statements is attached hereto as Exhibit “1” with the charges for which receipts and an explanation were never provided to the Plaintiff highlighted. 36. | Towards the end of the Agreement, the Defendants refused to comply with the Plaintiff's demands for delivery of certain vehicles that were purchased with the Plaintiffs money. The Defendants also failed to pay Plaintiff for completed sales of vehicles which had been purchased pursuant to the Agreement, including but not limited to a) $85,000.00 for a 1989 Porsche; b) $4,500.00 for a Yamaha golf cart; and c) $5,000.00 for an EZ Go golf cart. 37. Regarding the two golf carts, in or around May 2020, the golf carts were purchased by Mr. Flynn with Show Cars’ money. The approximate value of the EZ Go golf cart is $5,000.00, while the approximate value of the Yamaha golf cart is $4,500.00. A copy of an invoice reflecting the amount paid by the Plaintiff for the two golf carts is attached hereto as Exhibit “2.” 38. Despite the Plaintiff having wired the Defendants the money to acquire these vehicles, the Defendants purchased them in a name other than that of the Plaintiff and did notShow Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN take any action to ready the vehicles for resale pursuant to the Agreement. Instead, Mr. Flynn later told the Plaintiff's representatives that the golf carts were purchased for Mr. Flynn’s son. 39. | When the Plaintiff demanded the return of either a) its money; or b) the two golf carts purchased with the Plaintiff's money, the Defendants (and specifically Mr. Flynn) told the Plaintiff that it would be repaid immediately. 40. Despite Mr. Flynn’s representations, repayment was never tendered. 41. On July 26, 2020, after further demands were made by the Plaintiff for return of the money that was used to purchase the two (2) golf carts, Mr. Flynn sent a text message to a representative of the Plaintiff indicating that he would provide the Plaintiff with the money for the golf carts later that week. The text messages also identified multiple other payments, or vehicle deliveries, that the Defendants intended to complete. These text messages are incorporated herewith as Exhibit “3.” 42. Again, despite Mr. Flynn’s express representations, no payment for the golf carts was tendered. 43. After the Plaintiff's repeated demands for return of its monies used to purchase the golf carts resulted in no payment from the Defendants, the Plaintiff made an express demand for turnover and delivery of the golf carts purchased with the Plaintiffs funds. In response, the Defendants, acting through Mr. Flynn, advised that the golf carts would be delivered to the Plaintiff at its place of business in Boca Raton, Florida. 44. — Again, despite Mr. Flynn’s representations, the Defendants failed to perform, and the golf carts were not delivered to the Plaintiffs place of business in Boca Raton, Florida. 45. This scenario, or scenarios very similar thereto, occurred with multiple additional vehicles acquired pursuant to the Agreement and which were purchased with the Plaintiffs 10Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN money. Specifically, after being acquired with Show Cars’ money, and after the vehicles were not sold by Mr. Flynn or the Hollywood Wheels Defendants, the Plaintiff demanded the return of a) a 2001 American Eagle Motor Home; b) a 2010 PTJ VS Boat; c) a Boat Trailer; and d) a 2013 Cadillac. The Defendants only returned some of these vehicles or made payment to Show Cars after sales of certain vehicles, after the passage of considerable time and then only after warnings that legal action would be taken if the vehicles, or the equivalent of the amount of the Plaintiff's money used to acquire the vehicles, were not delivered to the Plaintiff. 46. In addition to the 1965 Chevy Corvette (referenced above), a 1948 Crosley, and a 1957 Volkswagen 2-door were also withheld from the Plaintiff. The Defendants actions in hiding the Corvette from the Plaintiff are admitted in Exhibit “3,” which also identified the Defendants’ agreement and representation to deliver the Corvette to the Plaintiff if not sold on Wednesday, July 29, 2020. The Corvette was not sold on July 29, 2020, nor was it immediately thereafter delivered to the Plaintiff. After repeated demands and weeks of waiting, the Corvette and the Volkswagen were finally delivered to the Plaintiff. However, the Crosley, which was purchased with the Plaintiffs funds, was never delivered to Plaintiff, despite multiple demands for its delivery. The original purchase of the Crosley was completed by the Defendants only after the Defendants directly misled an employee of the Plaintiff into believing that the acquisition of the vehicle had been authorized. Specifically, Mr. Flynn called the Plaintiff and represented that the acquisition of the Crosley had already been approved by Howard Castleman, the principal officer of the Plaintiff. This representation was patently false when made, and the falsity of the representation was a) known to Mr. Flynn; and b) was not known to the Plaintiffs representative to whom Mr. Flynn directed the false statement. The Plaintiff relied upon the statement not knowing that the purchase had not in fact been authorized, and as such the purchase price for the 11Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN Crosley was sent to the Defendants, whereafter they purchased the vehicle, and then proceeded to hide it from the Plaintiff. 47. — Regarding the 2013 Cadillac referenced above, during the period where the Defendants withheld the vehicle and refused to deliver the vehicle to the Plaintiff, the Defendants made personal use of the vehicle which was not in furtherance of the Agreement. When the vehicle was finally delivered, the Defendants had put more than 3,000 miles on the vehicle in a short period of time (i.e. between October 2019 and May 2020). The photograph and Carfax report attached as Exhibit “4” show the additional 3,057 miles added to the vehicle’s odometer between October 2019 and May 2020. COUNT I- BREACH OF ORAL CONTRACT 48. Plaintiff realleges paragraphs 1 through 47 set forth above, and further alleges the following: 49. A valid, binding, and enforceable oral agreement existed by and between the Plaintiff and the Defendants as alleged herein. 50. Pursuant to the Agreement between Plaintiff and Defendants Mr. Flynn, HWI, HWL and HWASI, Mr. Flynn was obligated to provide Show Cars with contemporaneous proof of all purchases and sales of vehicles, and all expenditures associated therewith (specifically including all use by the Defendants of the Plaintiffs monies and/or credit cards). 51. Additionally, the Defendants were to a) tender to the Plaintiff its share of profits generated by the sale of all vehicles acquired and resold pursuant to the Agreement; and b) to deliver the acquired vehicles to the Plaintiff upon demand if demand was made by the Plaintiff. 52. The Defendants breached the Agreement by way of the conduct alleged herein, specifically including, but not being limited to, the following: 12Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN a. Despite the Agreement as set forth above, Mr. Flynn failed to comply with his obligations to a) provide Show Cars with contemporaneous proof of purchases and sales of vehicles; b) to deliver profits from vehicle sales to the Plaintiff; c) to deliver reimbursement to the Plaintiff for expenses incurred by, or paid by, the Plaintiff; and d) to deliver unsold vehicles acquired with the Plaintiff's money to the Plaintiff upon demand made by the Plaintiff. b. The Defendants failed to provide the Plaintiff with an accurate accounting for what was purchased, expenses associated with purchased and sold vehicles, accurate purchase and sale pricing for associated vehicles, and an accurate identification of profits generated by the sale of sold vehicles. c. The Defendants furthermore failed to sell all vehicles purchased under the Agreement, and then failed to deliver to the Plaintiff unsold vehicles despite demand for delivery of the vehicles having been made by the Plaintiff. d. The Defendants obtained titles for purchased vehicles in names other than that of the Plaintiff, in derogation of the parties’ agreement to have titles issued in the name of the Plaintiff for any vehicles purchased under the Agreement. 53. Asa direct and proximate result of the Defendants’ breaches as set forth above, the Plaintiff has sustained monetary damages. WHEREFORE Plaintiff, SHOW CARS BOCA RATON, LLC, demands judgment against the Defendants, MICHAEL FLYNN, JR, HOLLYWOOD WHEELS, _INC., 13Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN HOLLYWOOD WHEELS, LLC and HOLLYWOOD WHEELS AUCTION & SALE, INC., for damages, court costs, pre-judgment and post-judgment interest, and all such other relief which the Court may deem just and proper. COUNT II - MONEY LENT 54. Plaintiff realleges paragraphs 1 through 9 and 11 set forth above, and further alleges the following: 55. Separate and apart from the Parties’ Agreement, on February 20, 2020, the Plaintiff lent Mr. Flynn and HWASI the sum of $40,000.00. 56. Specifically, Mr. Flynn asked the Plaintiff to make the loan. See Exhibit “5” attached hereto, which consists of an email for wiring instructions for the loaned sums, as well as wire transfer confirmation of the monies loaned to Mr. Flynn and HWASI for the intended use stated by Mr. Flynn and HWASI. 57. As collateral securing repayment of the loan, Mr. Flynn and HWASI agreed to deliver to the Plaintiff, at the Plaintiff's business address in Boca Raton, Florida, a Porsche Tractor (with an estimated value of $30,000.00), for the Plaintiff to keep in its possession until the loan was repaid in full by Mr. Flynn and HWASI. 58. The Plaintiff, Mr. Flynn, and HWASI agreed that the loaned sums were to be repaid to the Plaintiff upon demand made by the Plaintiff, and upon repayment in full the Porsche Tractor would be delivered by the Plaintiff to Mr. Flynn and HWASJ at a location designated by them. 59. Mr. Flynn and HWASI received the loaned funds from the Plaintiff, but never a) delivered the Porsche Tractor as collateral; or b) repaid the loan upon demand by the Plaintiff. 60. Despite multiple demands, the Defendants have failed to repay the loaned sums. 14Show Cars Boca Raton, LLC y. Michael Flynn, Jr., et al. Case No. 50 2020 CA 011933 XXXX MB AN 61. Defendants owe Plaintiff $40,000.00 that is due for money lent by the Plaintiff to the Defendants on February 20, 2020, together with interest thereupon at the prevailing statutory prejudgment and post judgment interest rates. WHEREFORE the Plaintiff, SHOW CARS BOCA RATON, LLC, demands judgment for damages against the Defendants, MICHAEL FLYNN, JR, and HOLLYWOOD WHEELS AUCTION & SALES, INC. for money lent in the amount of $40,000.00, as well as interest, court costs, and such other and further relief that this Court deems just and proper. Respectfully submitted, PADULA BENNARDO LEVINE, LLP Attorneys for Plaintiff/Counter-Defendant 3837 NW Boca Raton Blvd., Suite 200 Boca Raton, Florida 33431 Telephone No. 561.544.8900 Facsimile No. 561.544.8999 DATED: May 17, 2021 By: __/s/ Stephen J. Padula STEPHEN J. PADULA Florida Bar No. 182362 Email: SJP@PBL-Law.com R. NATHAN PATE Florida Bar No. 26737 Email: NP@PBL-Law.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by the Florida Courts E-Filing Portal via Email donschultz@netscape.net; don@lawus.com to: Donald J. Schultz, Esquire, 535 Central Avenue, St. Petersburg, Florida 33701, on this 17th day of May, 2021. 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QF3$__ 0734 TASALODDOQIPM RAT OOMPORYINN RIVERF BAOYSAVINGS NY TesaesieLagesenez DODON CITY USA ING HARRISBURG PA SOA9I006L8STSOPMB INTHN*TUNZEED AUTO 619-3127099 FL 432006MEAWENSRE OUTBACK 3915 HARRISBURG PA T4S0NOOOOAPTF ROT OUTBACK 3918 EASYSAVINGS NY TESOO4S¢NOQMDETGP GABRIELLA ITALIAN REST HARRISBURG PA QB4101GENERWROACZ SHEETZ 00008431 HARRIOBURG PA TOICO4SEROSHT2UJA GABRIELLA ITALIAN REST HARRISBURG PA Tesaenienssesosay DODGE CITY USAING HARRISBURG PA oatoreeTmAZzTDOL _BHERTZ 00008208 MUNCY PA TSAOAN1CTESENMGYX _ SKEBTERSBSQ_1 SHAMOKIN DAM PA SS492600TSSZIHRGZ ___INTUN‘SYUNZERO AUTO 843.3427030 FL GpaessreTsteLHkoV = HOTELHARRINGTON DUSHORE PA 0.08, 0.000 {te {ses74\ Viel 280,007) OHBOKIN carota FOLIO #410498 CHBCKAN 0110988 FOLIO #xxxxnaxxnx Ov.at 0807 © GeaatEASGERNate8s © DEST WOTRNPREM-THEONTR HARRISBURG PA ‘itaisaa} CHECKIN OT/2840 ___oLio #1103088 ra 06.06 ot07 EBAEUETEGSSCQHMWO HOTEL HARRINGTON DUSHORE FA Yaead, GHECKAN 0410 FOLIO texxvxnxnne 08-07 C808 _O8AIOINEVEFXUNPCA GHERTZ 00009840 FISHBRGVILLE VA (siti) 0.07 04.00 _custorveveaooRFVe GHEETZ 90008900 NUNOY PA re O807 0808 SUSTEOLEWHLWYLEKG BPOOZBEAISKENLY 96 GPS HENLY NG Vaasis' 06-08 0f08 G8ANETEXADRFSGZF HAMPTON INNS FLORENCE BC Ta) 04-46 c2908s7eXOOHBGPHZ SPERDWAY 06637 BROGKAVILLE FL. Vane bet ‘SMELL OWL 910020784QF5 FOOLER GA Avisaaal ant INTIIN*STUNZERD AUTO _613-9127030 FL 260.00] 0846 INTN *BTUNZERD AUTO _013-9827039 FL 250.007 0816 08s Se4azser2BVZHLPIE INTHN*BTUNZHED AUTO 613-9127038 FL 08-20 082 dsators7asHeaAtos WAWA 6140 00061482 87, PETERSOUR PL 0824 08.22 ES487027AZQOMLBSS —— COKERTIRECO-MO 0002816998 TH Q8-at _ob-a2 SSde7OATAZQOMLTPA — COKERTIREGO-MO — o00zs102998_ TH 08-21 08-22 S8438877AGDW973JG HILTON GARDEN INN WEST PALM BCH FL CHECKIN o/2tito FOLIO #296303 O8ad OS410187AIHOZMDSS —— WAWA STORE 81800081984 MANATEE CITY FL 08.23 68432867A5SYIRB. INTIN‘STUNZEED AUTO _013-9127030 FL 08-29 68432867A88YIRG INTAN*BTUNZEED AUTO 819-9427039 FL 06.25 SBS087872FXGHFKHM © GHELL OIL 67843704100 OKEECHOBES FL MIGHAEL J FLYNN JT TOTAL ES | 97,015.27 FINANCE ending ANNUAL Fewseate nate (nay very) CHARGE ENTAGE RATE Purchases 0.00 .05055% v 0.00 10.40% Cash Advances 0.00 “05887% v 0.00 24.40% | Combined Annual Percentage Rato for this Billing Cyclo 21.40%Statement Closing Dato: 09/26/2019 : Account une: Pego2of2 Your Business Credit Card Statement TRANSACTIONS ‘Tags Post Det Bate Merchant Namo or Tronsaoven Daserpton ADVANCH AUTO FARTS #91 BOCARATON FL GOLD AIR DISTRIBUTORS 861.3140808 FL 5 Oat6%s, S84szb0b205INOZIP AMZN MKTP US*4OZB287V3 AMZN.OOM/BILL WA. oots degszseassslyaeae AMZN MKTP U8*3146T4J83 AMZN.COMIDILL WA.“ oady egebIgeseTaRITD AMZN NKTP Uorzee0L9099 AMZN.CON/BILLWA Ob? _S848370RAZSNAWHV ADVANOW AUTO PARTO #01 BOGA RATON FL. SeAgO7TESSCVVUIEH CHAMPION PORBOHN _eesazsdiz6 FL GBASCITESAPOTAFTY, COLD AIR OLSTRIGUTORG,«B01-9146008 FL. CUA2OUOLALWEAEQEP \ ZIPREGRUITER, INO," 8647470403 OA Sesaaserssvovensw THE TIRE RACK.” 000.420-09801N QBSTONSITSNAWSF ADVANUEAUTO PARTS #91 BOGA RATON FL. S8409700817SNGWHS ADVANGE AUTO PARTS #04 BOOA RATON FL MOUATAGTLISYFES —_OOLDAIR DISTRIBUTORS 801.9148008 FL. ASBRTESTLIGAFRZ "COLD AIR DIBTRIBUTORD, 664-9140808 PL SUBITOSTATSHBWHD ADVANCE AUTO PARTS #04 BOD RATON FL 22.74 S84S¢OTOTTLMUPRTH __OOLD AIR DISTRIBUTORS _661-9140¥06.FL Ss200BEARQEEGWOE _ O'AKILLY AUTO PARTS €4 BOGARATON FL’ GOLD AIR DIGTRIQUTORS #61-3560608 FL Soe, PRIF MART 199 BOCA RATON FL Me GOLD AIR DISTRIBUTORS 864-3146808 FL OTEPHEN GALZMAN TOTAL NS 910,445.62 08-23 0828 68808297Q14YD0KZ — HAMPTON INN OCALA FL CHECKIN 08/2910 FOLIO azzsest QB27 08-28 GS4SZNSTFOVIOORIF INTHN*BTUNZEHD AUTO o19-3127090 FL m4 08-28 0829 SS4SZE67GSEQIHIKK NTN *STUNZEED AUTO 619-3127090 FL 125.00" B8432807G88Q9H7L8 ——INTHN*BTUNZBED AUTO 013-3127030 FL 78.00] Se4saseTNSGRITTET WNTIN*STUNZBED AUTO 049-3127039 FL 40.00 BOAS280TNSSRITIFA _INT*N*STUNZEEO AUTO _619-3127030 FL 40.00 INTIN*BTUNZHED AUTO 843-3127020 FL 300,007 427030 FL 00:08 08-06 _86492887REGNXSLOK ZZ OS41O1N7YIHOMIEXY — WAWAS141 00051417 LARGO PL. GS847O07VELUSODKN WALKER FORD CLEARWATER FL GORQEBVWAR O'REILLY AUTO PARTS 44 LARGO PL BIRQEAVWOR O'REILLY AUTO PARTS 44 LARGO PL. TITAN *STUNZEED AUTO 019-9127030 FLL ' Ln fes.are ve d “Wt 09-46 SNT*IN*STUNZBED AUTO _813-127030 FL. Ode16 88TH STREET AUTO PARTS LARGO FL 2080 Osa101eBssHeANNJS —_ WAWA5200_00062089 BRADENTON FL Qs4seeTSO4E4HGSJL «= HAMPTON INNS WEST PALM BGH FL OHECKAN o9/terte FOLIO #354003 O18 O89 O290897SSEPLHFATY _ T8T* GUACAMOLE TAQUERI JUPITER FL. 0848 0820 OSMOKENSIFRAGEVZ ——PRIP MART 189 BOCARATON FL Oot 08.20 S2304868C0RWVIHHT — SUNOOO 0788760201 GPE JUPITER FL 09-20 00-22 Osetoses7JHSAREBS — WAWAS248_ 00062489 SEMINOLE FL 09.23 08-24 Os4tONNeAJHOZAIY _— WAWAS218 0002160 GEMINOLE FL 09-23 08-24 | O8Z2702SAGPKRATHZ © JOY NOODLES AND RICE WEBY PALM GOH FL. MICHAEL J FLYNN JR TOTAL $4,417.02 lodii FINANCE Corresponding ANNUAL Bat Broo at may very) CHARGE PERUENTA ERATE Finance Charge Dotall Chenannn aon Ieee ees nae‘Statement Closing Date: 1728/2010 ‘Account Number: ‘Your Business Credit Card Statemont o{ TRAneAoTIONS “eecesrowvirausn ateasrenniranavey eeasrexianave rausramriroraee Seeuseevenr eae |aTeEUPHINOTY saya, eesroneraswe ouatoutsuszauats, ‘COLD AIR DISTRIBUTORS. nova BOCA RATON FL S00ARATON nL HOCARATON FL couoam oy¥Aibyrons sevszeoe re Tat noufburor Nayeorinay a14gH 7 coun oa TABUYoRs, statins 7 agrGwsonan ranre onod sntatet ovmaimeurneurone ety r ‘WORLURS AUTO PARTS "AUTQUONS £040 DELRAY BAGH PL ADVANGE AUTO PARTE DBT BOOA BATON FL. ota AIR OIATRIDUTORS ATEPHEN GALEUAN 101 sugeatapatarurat, LONECKAN eui28/0 eexreavaneceenste nayguranDexHeNoa4, WAMPTON INNS WABY PALM DOH FL Fouio asnetae ‘GUN OLUS CAFE WE6T PALM GHA FL ‘OREINFONOOREENSEORO NO ‘AB@ TIRES AND AUTO PINELLAS PARI FL WAWA STONS G{4GCE43064 MANATEE CITY FL. seat RELUTICUNGONSTARR__TAVERNAKYMAGOOARATON FL too WeasraLearasaeW—WAWPTON INNA WAST PALM ACH PL OHEGKIN two Powe. G]OUITIKEPLMDAYA TAT: OUAGAMOLE TAQUARI JUPITER FL aan rae mean ‘CARUINE @ RESTAURANT TAUPA FL 030 WORLOWIDEAVOTIONBERS 2400208780 1 ereigieepanesiere _ WAWACRIG_c09sz160 OuitINOLE FL AUUUACUREPUYESY__ ALLEQNT/TRAVEL “raaterrevenvwar “eauerrivenwox evarorcaweeeniuag enateagaxteceante rasaeeayave OHEOKAN surtaiee im (GAA LAReIO CARE, LLG GREENEDORO NC (OAA GLASEIO CANE, LLG ONEENSBORO NO ‘FAIRFIELO NW & OUITEO NERGTIBY PA Fouio vseeats Tena Tee exuavrz mzeuean ALA RENT-AGAR RETA IODLATONN FA inav| atateneese AYAN OTY MIODLEYOWH =| 2-10 aHHnaTNGHOLPANTO TOWANDATAIRPIRLD IN TOWANDA PA Veal CHECKIN sorters FOLIO s100006 | Tae wr masnenearanann teri -oTvuneno AITO _eTvauaT eae ears ’ Pogadel 3 foes 2000 cao cort tous oxeiete es)Staloment Glostig Date: 10/26/2019 ° 2 7 Account Number; a 7 Pago 3of3 Your Business Credit Card Statement TRANSACTIONS Post ‘Amount Dato Reference Number Merchant Name of Transaction Doscription frodh Chur 1047 INTAN *OTUNZEEO AUTO _613-3127038 FL 10.17 40.20 ABO TIRES AND AUTO PINELLAS PARK FL. 3.00 | $048 40-01 ASABONSOSIGITNWES HILTON ROCKVILLE MD ROCKVILLE ND rages CHROKIN 4071010 Fouio #700374 10-20 10-21 S843887083V88ZJHH = HAMPTON ING LUMBERTON NO teeny, CHECKIN $0/20/19 FOLIO #125633 : 10-29 10682 26247sORNOSPWAHGF =~ HAMPTON INN SAVANNAH GA 32.74) CHECKIN 40/7119 Foto vocoozs98 f0-22 40-29 osasotea7sHerReLs WAWA 5215 00002189 SEMINOLE FL 1022 10026 NASOAR CAR WASH + 82MI SEMINOLE FL 1026 10028 O2090EBZKVHPW STH STREET AUTO PARTS LARGO PL. MICHAHLU FLYNN JR TOT, $14, ch lc ding ANNUAL reegegre [vasa] amtaeay | SUANSE | ene Purchases 0.00 04927% v 0.00 17.89% Cash Advances 0.00 .06740% Vv 0.00 20.00% [ Combined Annual Percentage for this Billing Cyclo 20.09% | IMPORTANT NEWS. ‘The Service Members Civil Rellef Act (SCRA) provides Important financial and legal protactions to service members ~ Including cape on Interest rates, stays on certaln legal protection from eviction, and termination of leases without Tepercussions. Learn more at www.milltaryonesource.mit (search for'SCRAY), Nothing saya easy like hendling g your Business Credit Gard with SunTrust Business Cerd Online. You can manage your expenses, limit employee spending, schedule payments end make ‘changes to your account at your conventence, Learn more at Bunirust.com/ebeo or call ue at 066-674-2429,Stelement Closing Datos 11/26/2019 Account Number Pagezets Your Business Cradit Card Statement ‘TRANSACTIONS, suajateyntenviaen acacsronyyranaiax CARAQU TIAE, errr ‘oot AiR DISTRIBUTORS 191-9144 aa4t a uf tuu7iorranat0n ateravranon.pt avo an cinta nuceHeyyNRT —_eannouL TY” ergzEanE aASTHTHKWRAE_eekO AN OSTABUTONE asra:44E 3 GHTAALHM RAHN _80U-89740GA NCUA teuraenatrnanynovghon auto rante nAgRLBFAWED equesreqai7aynera AMEN UXT? US*GANUITUN) AMZN OOABILL VA, "ANZN HKTP US°RGVIBEITS ANZN.COMPBILL WA ‘GOHUUAGHER PARTS OROUP_BU1-1049400 FL. eqeusrearirawoto euUUsTOATITINELI ESCISTOAT I TIN tone Wad HEAMNITANTMEOHLAG —_COLOAIB DISTAIDUTORS BOGARATON FL. srerien ntzunn aed 321A, SV, 8) jean oat _ouetwranrwernirza —naanraaoure « 7m $Q34 TEMNCTEFGIKPHEQL ZUGOARELLNS ITALIAN A WEST PALL DEA PL Nia | AOS SUATEITIOURHIZIKG HAMPTON INttO WEOT PALM BON FL anf eucogie wine rouon (use HAVAMA RUGTAURANT WEGT PALY DEA PL ai GHARHASVEP ‘HAMPTONINNS WEST PALM BOM FL “pe | \ Chtcem (usu rouge fl ieee WAIOAR oan Wadii-anu/aenmnane Fo saat N03 14-05 SnaeaTeUHAXHMOAVE — QHALE OM a7easeazz0¢ OKEECHODOE FL £ aaa, (| (ear tea _euasersenumeayaya _ WAWA@TONG stuodoatese WANATER CITY FL Fave $4.02 44t4 _onateieeKsHeasAch _ WAWASI11_eae4asie WaOT PALI BHA PL dates 1402. (180 SLASEUTEKIEXZAKDO—_HANPTON INO WHST PALS COU PL 2 CHECKIN G4mpRie FOO BINA? AGE 11-47 ECAUOTTONETKWOIED__ BELLATTAIARESTAURAN LARGO FL Site toe TeMGNHPALNERMPR —_CANLIOLE EVENTS CARLIOLE PA S007 {140 _eHTUNDEROIMOFEGH NASCAR GAN WABH Gai AEMINOLE FL wort tas , Pagonet 3 019 2000 cto 0010 a8 OLnIRATZtaLStetemont Closing Date; 11/26/2019 a . Account hunt aT Poqo3ota Your Business Credit Gard Statement ‘TRANSACTIONS Tene Pe ‘Amount Bate Number creat" Chars 00844 ISCIOAMRIHEZHLOT WAWASI20 _cooutzea aT. Asus M18 Mito soaasezeramsesissTIKANIG 87 PETERSBURG FL. RYTEY} Meta 44668 cuatoronvsHezaKer __WAWASIIE _¢0 ENINOLR FL Ni St10 A180 _ONA1OtDASINERNO? — WAWA STORM 1001 Gaia Mf0 4401 aBStbZAMLRULAVAT [iora, OnEORAN 4118019 TORUNAIAUKYKETIZE Nast 30414 AYIA 621 51888 BRADENTON PL A4H0__ thet A042tugAsR@Qubras. PAYPAL *ERAY CAR PART 4040307793 OA $4680 412 GS31020AILKJ2YMV1—_HOLIDAYINN. wosesroaco FL OHACKAN 41/401 Foun atratey 19640 ase HOLIDAY INN angnorseoo et. NOZOANLKIZORIT QuROKIN 4tHOHe FOU wirete2 Stat 44.92 _ ss4nnnoatnrooaay PAYPAL ‘EBAY FORALLEYE 402037739 OA Meat tha ‘COURTYARD BY MARRIOTT. W PALM BCH PL ounotin 110810 Fouo s3a800 Meat _ 1424 a0zeatUANDIVEPCDY NASCAR OAR WASH» SEMI SEMINOLE FL 123 14:3h__ SGN0EAANWOELHEWA__GABYS FAMILY RESTAURAN CLEARWATER FL. {4-83 1400 TESCH(SARLHONETEZ MIDDLE GROUNDS ORNL SAINT PETARSD FL MICHAEL J FLYNN JR TOTAL $1,757.70 e iC ding ANNUAL Finance Charge Average Dally Seance PERCENTAGE RATE cs 000 v 0.00 17.98% Cash Advances 0.00 v 0.00 20.09% 10 Rate for thia Billing Cyole 20.09% [combined ‘Annual Percent IMPORTANT NEWS: ‘Tho Sarvica Members Civ! Rellef Act (SCRA) provides Important fnanctal and tegel protections to service members » Including caps on Interest rates, slays on certain legal rotactlon from eviction, end termination of leases without Tepercussions, Learn mora at www.militaryonesource.mil (search for SCRA).‘Slatamont Glslng Date: 2726/2010 Account Numbers Your Business Credit Card Statement Pagezota ‘TRANBAOTIONS us pou Merron Name Frontscten ~SOLB AIR 117 BOCARATON Ft ATOUNHUALENAoPHES _TIREWUA (06 FT LAUDEAD 0 1-08 WeensTOAMITINGIIL ADVANCE AUTO PANTS 581 BOCARATON Px a WUXONUOER _4767103B00A BATON €L so wreruraranionon coin an vir agcanstou eg” stad eeatateanirinaros ABVANON AUTO Panta ant Boca aAfaN PL, sso \presaeantranaza Aovanon auro pare sn g0oWAaton eb tuto Rguarantranaiva _apvanor auro panre ent apfoanaron ne tsa suyyeancruarye fAOOA RAYON vt dito ecansTbgrarinazza ADVANGE AUTO PARVC#ITBOGARATON FL ui UT BOONAATON FL at FOMPANG BEAGH PL, sat TEATITINQION, _AOVANC AUS PARTE att eat sean eT [PR PUANT 104 BOSARATON TL. phi WARE (01 BOCARATON PL oT ye eMPKIE TH 1244 OLD AIR 117 BOB RATON FL. $244 _wuatenerrinoiyy” _ADVANOH AUTO FARYQ.G1 BOOA RATON FL AUUESTOARITINGEtU_— ADVANON AUTO PARTO 104 DOOARATON FL (ow th a1quabawsranasts ADVANGE AUTO PARTE £91 BOCA ATOR) biaveariaway “GOHUMAGHER PARTE OROUP_HH4seteae afltssrazexrvaan _oreice onporsesoca Raton [GOLOAIR 117 BOCARATON FL GOLD AIR {17 BOCA RATON FL [PAYPAL *HEAY JOAPART _ 462138773304 [PUBLIY STEH BOCA RATON PL. ‘SOHUMACHER PARTS GROUP cot-asezete PL ‘STEPHAW BALZUAN, YOTA Cri} wastas 31 104 3000 as? se 10.10 1a0 eat i030 tae wae nae or. waste ‘OURANLY AUTO PARTS L4LARGO FL Mae ar (NABGAR GAR AGH. SEMI, 07 Glad. toy Hote star WILLS STARTEG AND ALY OAINT POTERGO FL Hae tae ‘SHELL On e7e4e¢a0e47 LARGO FL M437 _ 4 C0aGUUTAGRATONXDN —O'RRILLY AUTO PARTO.AGLARGO FL L tara \GRGUBKXEZ O'REILLY AUTO PARTS 44LARGO FL. Moe ae 1203 i209 1243 FRREMIERAUOTION OROUP aU4nenTING NG 1208 AWA NAHE 22 PINELLAB FL. a8 WAWA I216 BMINOLE FL $244 AULCTUOARUUGHIOSY ___ITALIAAT RIVER ITY PUNTA QORDA FL 200 tnte “ANELL OW 7440421807 LARGO FL EXRONMOBIL ¢7EI7120 ARAGOTA PL. 'ATHBNIAN OARDEN SAINT PETERS ‘CLUBHOUSE RESTAURANTLARGO PL [QRNTLLY AUTO PART@ 44 4ARGO FL InOy Sut OM ereeatta eagvaavinal WY. "ARPLIGO RACING THCIINGL CLEARWATER FL. [WARGOA PABIONT TOOLS (LAROG PL. QURRILLY AUTO PARTS 48 4ARGO FL ‘O'REILLY AUTO PARTS 44 4ARGO PL | ‘GeerotantoMerKuss —_ WAWACIIS _ob LTE D> <@ Mike Flynn»ain r I » phone el LTE @ Mike Flynn > Sat, Jun 20, 6:20 PM We spent four months hiding that 66 Corvette and preparing it by get- ting all the documenta- tions and all the inspec- tions completed. | told you | was working on a deal with bring a traller and the car was set to _ launch also had been. talking to Rob about putting it In thelr ontine Monterey auction Instead today we threw it on eBay like it's Just another used car. Now neither RM or bring a trailer Will excent it...oh well.EXHIBIT “4”8/11/2020 CARFAX Vehicle History Report for this 2013 CADILLAG ESCALADE ESV LUXURY: 1GYS4HEF7DR298041 This report provided free of charge by: ' Show Cars of Boca Raton EXHIBIT "4" 1871 NW 1st Ct, Boca Raton, FL 33432 561-250-0780 Vehicle History Report” 2013 CADILLAC ESCALADE ESV No accldents reported to CARFAX LUXURY VIN: 1GYS4HEF7DR298941 4 DOOR WAGON/SPORT UTILITY vA CARFAX 6.2L V8F OHV 16V lA No damage reported to FLEX FUEL jewmratents [io eeneeecem nnd mee ee eeee memes tate nee ALL WHEEL DRIVE 2 Previous owners 14 Service history records SB Hypes of owners: Commercial, ersonal . This CARFAX Report Provided by: Show Cars of Boca Raton i Last reported odometer 32,478 reading Eres Dea scalded le This CARFAX Vehicle History Report Is based only on Information supplied to CARFAX and avallable as of 8/11/20 at 9:09:46 AM (cov). Other Information about this vehicle, Including problems, may not have been reported to CARFAX. Use this report as one Important tool, along with a vehicle inspection and test drive, to make a better decision about your next used car, Ownership History : a Syrs, 5 mo. | Last reported odometer reading 7 _ 26,840 7 32,473 i (cAIRIF| x] Title History QOwnert By Ovmer 2 | | 7 ' {_.CARFAX guarantees the formetonin ds ection iene i Salvage | Junk | Rebuilt | Fire | Flood | Hall | Lemon | a Guaranteed FA Guarantecd val Fall i Guaranteed pq Guaranteed i Kd NoProblem No Problem GUARANTEED - None of these major title problems were reported by a state Department of Motor Vehicles (DMV). If: you find that any of these title problems were reported by aDMV and not Included In this report, CARFAX will buy this vehicle back, t Not Actual Mileage | Exceeds Mechanical Limits j- | | t Register | View Terms | View Certificate hitpsvAvww.carfaxoniine.comlaplrepont?vin=1GYS4HEF7DR298041 &lrack=true 158/11/2020 i _Notal altace accidents / issues are Feported | to GAREAX “Total Loss: “Structural Damage “05/24/2013 05/81/2013 09/21/2013 | 09/23/2013 No total loss reported to tot CARFAX, No structural damage teported to 0 CARFAX. Airbag Deployment No alrbag g deployment r reported to CARFAX, Reported - Odometer Check Nolssues No Issues 4] Indicated Indicated No indication of an odometer rollback. 7 Nolssues 7 Issues FA te d ted ecall BEE ; : NoRecalls rz No Recalls No open recall e reported to CARFAX, Check for open recalls on GM 7] _ehales at recalsomcom. EEL ' EE heer : a 7 ere : Basle Warranty ‘Warranty Bed Warranty Eat I ‘rina waranty estmsted to have oxlred, GAnGoK Detailed Hi is story Owner 1 a A “Commercial Vehicle Purchased: | Low mileage! This owner drove less than 6,336 mi/yr 2013 the Industry average of 15,000 miles per year, Mileage Source Comments 7 | Orginal OnStar Vato equipped with onstar 7 Equipment Get 3 free months of premlum OnStar with Automatic Crash Response, Roadside Assistance and Remote Door Unlock by pressing the blue OnStar button Learn a a asa ee eee mel te te Et 04/02/2013 Dealer Inventory Vehicle offered for sale 8 ; 1247 Missourl Mechanical Issue reported https:/Avww.carfaxonline.com/apl/report?vin=1 GYS4HEF7DR298041 &track=true CARFAX Vehicle History Report for this 2013 CADILLAC ESCALADE ESV LUXURY: 1GYS4HEF7DR208041 Additional History owner GOvmer 2 No Issues Reported Nolssues 4\ Reported Nol issues Reported No Issues n Sales Company Springfield, MO Pi 7 356-661 1 thompsonsales.com tr 4.6/5.0 158 Verified Reviews @ y 185 Customer Favorites | “451 Thompson Sales Company ”Vehicte sold ~ Springfield field, Mo ! thompsonsales.com | fr 4.6/5.0 ; 158 Verified Reviews @ ; y 185 anid Favorites | Service Facllity + Vehicle tower : Thompso