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Filing # 133142142 E-Filed 08/20/2021 06:24:09 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
VANSIA DINKINS-ANDERSON,
Plaintiff,
ve Case No. 2021-CA~ _
VICTOR ANTHONY DEXTER.
individually and derivatively on
behalf of Venom Motor Sports
LLC, and VENOM MOTOR
SPORTS LLC,
Defendants.
COMPLAINT AND JURY DEMAND
COMES NOW, Plaintiff, VANSIA DINKINS-ANDERSON (hereinafter referred to as
“Plaintiff’) and by through the undersigned counsel. hereby files her Complaint against
Defendants, VICTOR ANTHONY DEXTER, individually and derivatively on behalf of
Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC (hereinafter collectively
referred to as “Defendants”), and in support thereof states as follows:
THE PARTIES
1. VANSIA DINKINS-ANDERSON is an individual who resides at 5323 4" Street NW
Apt. #2, Washington, DC 20011-3175.
2, VICTOR ANTHONY DEXTER is an individual who resides at 14112 Lord Barclay
Drive, Orlando, Florida 32837 (See Exhibits A and B) and who also owns or resides at 725
Hudson Street, Kissimmee, Florida 34741. See Exhibits C and D.
wa
VENOM MOTOR SPORTS LLC is a business whose principal address is 101 East
Fletcher Street, Kissimmee, Florida 34744 and whose registered agent is Defendant, Victor
Anthony Dexter. See Exhibits E and F.
JURISDICTIONAL STATEMENT
Coe NE te
4, This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre-
judgment interest and attorneys’ fees.
Page 1 of 6wy
9,
ta
VENUE
Venue is proper in Osceola County, Florida because the contract in question occurred in
Osceola County, Florida and Defendant. VENOM MOTOR SPORTS L s located
in and conducts business in Osceola County, Florida. See Exhibits E and F.
GENERAL FACTS IN SUPPORT OF ALL CLAIMS
Around the end of January 2021, Plaintiff entered into an oral Investment Contract
(“Contract”) with Defendants wherein the parties agreed to go into business together for
the purpose of buying and flipping cars. Specifically, Defendants had business
relationships with car rental companies and needed money to buy the car rentals’ wrecked
vehicles and the parts needed to repair said vehicles. Defendant was going to perform the
labor needed to repair the cars to sell them for profit. Plaintiff was to invest the sum of
$60,000.00 because Defendant did not have the money needed to buy the vehicles and the
parts needed to repair them, A reasonable portion of all profits was to be directed to
Plaintiff until Plaintiff's initial investment was repaid in full.
Shortly thereafier, in reliance of the Contract, Plaintiff advanced Defendants a lump sum
of cash in the amount of $60,000.00 for her investment.
In March and April of 2021, Plaintiff demanded payment from Defendants and
Defendants notified Plaintiff that they were still in possession of Plaintiff's investment
funds.
As of May 31, 2021, Defendants had not rendered any full or partial payments toward the
debt they owed to Plaintiff for her investment in accord with the January 2021 Agreement
despite Plaintiff's demands for the return of same.
On June 18, 2021, Plaintiff sent Defendants a demand letter in an effort to resolve this
matter without the involvement of the court to his last known addresses.
As of August 20, 2021, Plaintiff has not received a return of her investment.
To date, despite the demands of Plaintiff, Defendants, VICTOR ANTHONY DEXTER
and VENOM MOTOR SPORTS LLC, have failed to return to Plaintiff her initial
investment of $60,000.00 in accord with the January 2021 oral Contract.
COUNT L- BREACH OF CONTRACT
Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 12
as though fully stated herein.
This is an action for damages which exceeds $50,000.00. exclusive of court costs, pre-
judgment interest and attorneys’ fees.
Defendant, VICTOR ANTHONY DEXTER, both as an individual and as owner and/or
Page 2 of 616.
17.
19.
20,
operator of VENOM MOTOR SPORTS LLC, entered into an oral Investment Contract
with Plaintiff in January of 2021. See Paragraphs 6 and 7 above.
Plaintiff's total investment price was $60,000.00. See Paragraphs 6 and 7 above.
The purpose of this contract was for Plaintiff to advance the sum of $60,000.00 to
Defendants for the startup costs associated with buying, repairing and selling vehicles for
profit. To wit, Defendant, VICTOR ANTHONY DEXTER, with the assistance of
VENOM MOTOR SPORTS LLC and its resources, was to engage in the performance
of flipping cars and was to disburse a reasonable portion of the sales proceeds. This portion
was to be directed to Plaintiff until Plaintiff's initial investment was repaid in full. See
Paragraphs 6 and 7 above.
Asatesult of the contract entered into by Plaintiff and Defendants. VICTOR ANTHONY
DEXTER and VENOM MOTOR SPORTS LLC, a confidential relationship existed
between Plaintiff and Defendants. See Paragraphs 6 and 7 above.
Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC
were trusted by Plaintiff in the performance of the contract. See Paragraph 7 above.
Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC,
intentionally breached the contract. by failing to disburse to Plaintiff the agreed upon return
of $60,000,00. See Paragraphs 6 and 7 above.
As a result of the above contract breaches, the Plaintiff has been damaged in the amount of
at least $60,000.00. See Paragraph 7 above.
WHEREFORE, Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands
judgment against Defendants. VICTOR ANTHONY DEXTER individually and derivatively on
behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above
damages, for interest, attorney’s fees, costs, and for ali such other and further relief as this Court
deems just and proper, and demands a trial by jury.
i]
ies
COUNT I] —- FRAUDULENT MISREPRESENTATION
Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 12
as though fully stated herein.
This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre-
judgment interest and attorneys’ fees.
Defendant, VICTOR ANTHONY DEXTER, both as an individual and as owner and/or
Page 3 of 6operator of VENOM MOTOR SPORTS LLC, entered into an oral Investment Contract
with Plaintiff in January of 2021. See Paragraphs 6 and 7 above.
25. Plaintiff's total investment price was $60.000.00. See Paragraphs 6 and 7 above.
26, Defendants. VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC,
falsely misrepresented that they would repay Plaintiff for her initial investment of
$60,000.00 which was advanced to Defendants for the sole purpose of buying, repairing
and selling wrecked or damaged vehicles for profit. See Paragraphs 6 and ? above.
27. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS
LLC, knew that their representations were false. See Paragraphs 8, 9, 11. and 12 above.
28. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS
LLC. knew that there was no intention of ever repaying Plaintiff. See Paragraphs 8, 9, 11,
and 12 above.
29. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS
LLC, knew the Plaintiff would rely on their false misrepresentations. See Paragraph 6
above.
30. The Plaintiff relied on Defendants, VICTOR ANTHONY DEXTER and VENOM
MOTOR SPORTS LLC, false misrepresentations that they would repay Plaintiff for her
initial investment of $60,000.00. See Paragraph 7 above.
31. The false misrepresentations by Defendants, VICTOR ANTHONY DEXTER and
VENOM MOTOR SPORTS LLC. caused damages to the Plaintiff. See Paragraph 12
above.
)
he
As a result of the above fraudulent misrepresentations, the Plaintiff has been damaged in
the amount of at least $60,000.00. See Paragraphs 7 and 12 ahove.
WHEREFORE Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands
judgment against Defendants, VICTOR ANTHONY DEXTER individually and derivatively on
behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above
damages. for interest, attorney’s fees, costs, and for all such other and further relief as this Court
deems just and proper, and demands a trial by jury.
COUNT Hl — UNJUST ENRICHMENT
33. Plaintiff re-alleges and incorporate the allegations contained in Paragraphs 1 through 12 as
though fully stated herein.
Page 4 of 6we
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36.
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9
39.
40,
4l.
This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre-
judgment interest and attorneys’ fees.
Plaintiff has conferred a benefit upon Defendants who have knowledge of this benefit. See
Paragraph 7 above.
In reliance on the request from Defendants, Plaintiff advanced $60,000.00 to Defendant
for the sole purpose of buying, repairing and selling wrecked or damaged vehicles for
profit. See Paragraphs 6 and 7 above.
The Plaintiff did so with the belief that if she paid this amount, she would receive
repayment of her initial investment from Defendants’ profits. See Paragraphs 6 and 7
above.
‘The Plaintiff believing that she would receive repayment of her investment, advanced the
sum of $60,000.00 cash to Defendants. See Paragraphs 6 and 7 above.
Defendants accepted and retained the conferred benefits. See Paragraph 7 above.
Since Defendants’ receipt of Plaintiff"s investment, Defendants have not made any attempt
to return to Plaintiff her investment. See Paragraphs 8, 9, 11, and 12 above.
Under the circumstances, it would be inequitable for Defendants to retain the benefits
conferred on them by Plaintiff without reimbursing Plaintiff for said benelits.
Defendants were unjustly enriched in the amount of at least $60,000.00. See Paragraphs 7
and 12 above.
WHEREFORE Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands
judgment against Defendants. VICTOR ANTHONY DEXTER individually and derivatively on
behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above
damages. for interest, attorney's fees, costs, and for all such other and further relief as this Court
deems just and proper, and demands a trial by jury.
Page 5 of 6EMAND FOR ATTORNEY’S FEES
DEMAND FOR ATTORNEYS
Plaintiff, VANSIA. DINKINS-ANDERSON, has retained the undersigned firm and is
indebted for a fee for which said Plaintiff seeks recovery from Defendants pursuant to Chapter
57.105 of the Florida Statutes.
Dated: August 20, 2021
/s/ Ronald A. Legendre, Esq.
Ronald A. Legendre, E.
Florida Bar No.: 0163260
Law Offices of Legendre & Legendre PLLC
P.O. Box 421405
Kissimmee, FL 32742-1405
Telephone: 407-944-0584
Facsimile: 407-944-0588
Primary Email: ronald@)
Secondary Email: anthony
and vanes:
Page 6 of 6EXHIBIT
APrint Date: 07/01/2021 System Refresh Date: 06/30/2021
14112 Lord Barclay Dr 32-24-29-3802-00-470
Name(s):
Dexter Victor
Mailing Address On File:
14112 Lord Barclay Dr
Orlando, FL32837-5401
incorrect Mailing Address?
‘View 2020 Property Record Card
Historical Value and Tax Benefits @
‘Tax Year Valves
2020 BAS
2019
2018 BSS
207 ECS
Tax Year Benafits
2020 Be
2019 Be
2018 e)
2017
Land
$65,000
$65,000
$55,000
$55,000
Postal City and Zip:
Orlando, FL 32837
Buildingis)
$218,641
$220,528
$274,890
$190,673,
Original Homestead
2020 Taxable Value and Certified Taxes @
Tax Year
Les Tee To]
Taxing Authority
Public Schools: By State Law (Rie)
Public Schools: By Local Board
General County
Unincorporated County Fire
Unincorporated Taxing District
Library - Operating Budget
South Florida Water Management District
South Florida Wmd Okeechobee Basin
South Florida Wmd Everglades Const
Totals
Non-Ad Valorem Assessments
2020 Non-Ad Valorem Assessments
g Authority
COUNTY SPECIAL ASSESSMENT
‘CGUNTY SPECIAL ASSESSMENT
Assd Value
$283,641
$283,641
$283,641
$283,641
$283,641
$283,641
$283,641
$283,641
$283,641
Physical Street Address:
44112 Lord Barclay Dr
Feature(s)
$0
$0
$0
$0
Additional Rx
Exemption
$0
$0
$0
$0
$0
0
$0
$0
40
Assessment Description
Property Use:
0103 - Single Fam Class 1
Municipality:
Un-incorporated
Market Value
$283,641
$285,528
$269,890
$245,673
Wiss
%
0.7%
5.8%
9.9%
NA
Other Exemptions
$0
$0
$0
$0
Tax Value Millage Rate
$283,641 3.6090
$203,641 3.2480
$283,641 4.4347
$283,641 2.2437
$283,641 1.8043
$283,641 0.3748
$283,641 0.1103
$283,641 0.1192
$283,641 0.0380
15.9820
ADVANCED DISP - GARBGE - (407)836-6601
STREET LIGHTS - LIGHT - (407)836-5770
Assessed Value
$283,641
$285,528
$262,643
$238,766
SOH CAP
% Taxes
“6.5% — $1,023.66
0.0% — $921.27
90% — $1,257.86
0.0% $636.41
0.0% © SSIL7T
0.0% — $106.31
43% $31.29
“A3% $33.81
43% © $10.78
$4,833.16
Units Rates
1.00 245,00
1.00 9751
%
0.7%
8.7%
10.0%
N/A
‘Tax Savings
$0
$0
$66
$63
Tax Breakclown
23%
20%
28%
14%
1%
2%
1%
1%
Assessment
$245.00
$97.51
$342.51
2020 Gross Tax Total: $4,875.67
2020 Tax Savings Tax Savings
Your taxes without exemptions would be: $4,533.16
Your ad-valorem tax with exemptions is: « $4,533.16
V2EXHIBIT
BTIN2024 ZIP Code™ Lookup | USPS
ZIP Code™ by Address ZIP Code™ by City and State Cities by ZIP Code™ FAQs
‘Soom onan
Look Up a ZIP Code™ ros
Go to
ZIP Code™ by Address
You entered:
14112 LORD BARCLAY DRIVE
ORLANDO FL
If more than one address matches the information provided, try narrowing your search
by entering a street address and, if applicable, a unit number. Edit and search again.
14112 LORD BARCLAY DR
ORLANDO FL 32837-5401
CARRIER ROUTE
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DELIVERY POINT CODE
CHECK DIGIT
COMMERCIAL MAIL RECEIVING AGENCY
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wtEXHIBIT
CTHI2021 Property Search | Osceola County Property Appraiser
Osceola County Property Appraiser
Katrina S. Scarborough, CFA, CCF, MCF
Basic Search Advanced Search Sales Search Search Results Parcel Result Map Help
Parcel Result
Parcel: 292529112400010060
‘Map View E-Mail Parcel, NEW Bird's Eye View
‘Owner Name. DEXTER VICTOR.
Mailing Address: 14112 LORD BARCLAY DR
ORLANDO, FL 32837
Physical Address: 725 HUDSON ST, KISSIMMEE FL 34744
Description MULTI-FAMILY-IMPROVED less than 10 units
Tax District 200 - KISSIMMEE
Current Value represents working appraised values as of 06/30/2021, Certified Value represents certified values that appeared on the tar
which are subject to change prior to certification roll as of 02/04/2021
jLand $20,000 Land $16,500
|AG Benefit $0 AG Benefit $0
Extra Features $1,300 Extra Features $1,400
Buildings $57,300 Buildings $56,300
Appraised(Just) $78,600 Appraised(just) $74,200
|Assessed(estimated) $78,600 Assessed” $72,721
Exemption(estimated) $0 Exemption $0
Taxable(estimated) $78,600 Taxable $72,721
* Assessed Values Reflect Adjustments for Agricultural Classification * Assessed Values Reflect Adjustments for Agricultural
and/or the Save Our Homes Cap Classification and/or the Save Our Homes Cap
4933-2342 $0 2013-06-11 Quit Claim Deed (ac)
0
1 4355-0295 $100 2042-11-23 Quit Claim Deed (ac)
2 4279-0714 $100 2012-06-04 Quit Claim Deed ac)
3 4085-2059 $43,800 2011-01-20 Warranty Deed (wo)
4 1898-1539 $85,000 2001-07-03 Warranty Deed wo)
5 1469-0814 $87,500 1994-01-24 Warranty Deed (wo)
6 0818-1619 $50,500 1986-10-15 Warranty Deed (wo)
7 0471-0366. $34,500 1980-02-29 Warranty Deed (wo)
3 0368-0676 $0 1977-08-09 Warranty Deed wo)
9 0343-0865 $0 1976-10-29 Certificate of Title (CT)
[RESIDENTIAL
AIC-WALL UNIT GOOD 2 1974 $400
|CONCRETE PADIPATIO AVERAGE 390 4990 $310
(WOOD FENCE-6 FT HIGH AVERA\ 2014 $582
es —
Preview
Filing # 133142142 E-Filed 08/20/2021 06:24:09 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA VANSIA DINKINS-ANDERSON, Plaintiff, ve Case No. 2021-CA~ _ VICTOR ANTHONY DEXTER. individually and derivatively on behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, Defendants. COMPLAINT AND JURY DEMAND COMES NOW, Plaintiff, VANSIA DINKINS-ANDERSON (hereinafter referred to as “Plaintiff’) and by through the undersigned counsel. hereby files her Complaint against Defendants, VICTOR ANTHONY DEXTER, individually and derivatively on behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC (hereinafter collectively referred to as “Defendants”), and in support thereof states as follows: THE PARTIES 1. VANSIA DINKINS-ANDERSON is an individual who resides at 5323 4" Street NW Apt. #2, Washington, DC 20011-3175. 2, VICTOR ANTHONY DEXTER is an individual who resides at 14112 Lord Barclay Drive, Orlando, Florida 32837 (See Exhibits A and B) and who also owns or resides at 725 Hudson Street, Kissimmee, Florida 34741. See Exhibits C and D. wa VENOM MOTOR SPORTS LLC is a business whose principal address is 101 East Fletcher Street, Kissimmee, Florida 34744 and whose registered agent is Defendant, Victor Anthony Dexter. See Exhibits E and F. JURISDICTIONAL STATEMENT Coe NE te 4, This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre- judgment interest and attorneys’ fees. Page 1 of 6wy 9, ta VENUE Venue is proper in Osceola County, Florida because the contract in question occurred in Osceola County, Florida and Defendant. VENOM MOTOR SPORTS L s located in and conducts business in Osceola County, Florida. See Exhibits E and F. GENERAL FACTS IN SUPPORT OF ALL CLAIMS Around the end of January 2021, Plaintiff entered into an oral Investment Contract (“Contract”) with Defendants wherein the parties agreed to go into business together for the purpose of buying and flipping cars. Specifically, Defendants had business relationships with car rental companies and needed money to buy the car rentals’ wrecked vehicles and the parts needed to repair said vehicles. Defendant was going to perform the labor needed to repair the cars to sell them for profit. Plaintiff was to invest the sum of $60,000.00 because Defendant did not have the money needed to buy the vehicles and the parts needed to repair them, A reasonable portion of all profits was to be directed to Plaintiff until Plaintiff's initial investment was repaid in full. Shortly thereafier, in reliance of the Contract, Plaintiff advanced Defendants a lump sum of cash in the amount of $60,000.00 for her investment. In March and April of 2021, Plaintiff demanded payment from Defendants and Defendants notified Plaintiff that they were still in possession of Plaintiff's investment funds. As of May 31, 2021, Defendants had not rendered any full or partial payments toward the debt they owed to Plaintiff for her investment in accord with the January 2021 Agreement despite Plaintiff's demands for the return of same. On June 18, 2021, Plaintiff sent Defendants a demand letter in an effort to resolve this matter without the involvement of the court to his last known addresses. As of August 20, 2021, Plaintiff has not received a return of her investment. To date, despite the demands of Plaintiff, Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, have failed to return to Plaintiff her initial investment of $60,000.00 in accord with the January 2021 oral Contract. COUNT L- BREACH OF CONTRACT Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 12 as though fully stated herein. This is an action for damages which exceeds $50,000.00. exclusive of court costs, pre- judgment interest and attorneys’ fees. Defendant, VICTOR ANTHONY DEXTER, both as an individual and as owner and/or Page 2 of 616. 17. 19. 20, operator of VENOM MOTOR SPORTS LLC, entered into an oral Investment Contract with Plaintiff in January of 2021. See Paragraphs 6 and 7 above. Plaintiff's total investment price was $60,000.00. See Paragraphs 6 and 7 above. The purpose of this contract was for Plaintiff to advance the sum of $60,000.00 to Defendants for the startup costs associated with buying, repairing and selling vehicles for profit. To wit, Defendant, VICTOR ANTHONY DEXTER, with the assistance of VENOM MOTOR SPORTS LLC and its resources, was to engage in the performance of flipping cars and was to disburse a reasonable portion of the sales proceeds. This portion was to be directed to Plaintiff until Plaintiff's initial investment was repaid in full. See Paragraphs 6 and 7 above. Asatesult of the contract entered into by Plaintiff and Defendants. VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, a confidential relationship existed between Plaintiff and Defendants. See Paragraphs 6 and 7 above. Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC were trusted by Plaintiff in the performance of the contract. See Paragraph 7 above. Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, intentionally breached the contract. by failing to disburse to Plaintiff the agreed upon return of $60,000,00. See Paragraphs 6 and 7 above. As a result of the above contract breaches, the Plaintiff has been damaged in the amount of at least $60,000.00. See Paragraph 7 above. WHEREFORE, Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands judgment against Defendants. VICTOR ANTHONY DEXTER individually and derivatively on behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above damages, for interest, attorney’s fees, costs, and for ali such other and further relief as this Court deems just and proper, and demands a trial by jury. i] ies COUNT I] —- FRAUDULENT MISREPRESENTATION Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 12 as though fully stated herein. This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre- judgment interest and attorneys’ fees. Defendant, VICTOR ANTHONY DEXTER, both as an individual and as owner and/or Page 3 of 6operator of VENOM MOTOR SPORTS LLC, entered into an oral Investment Contract with Plaintiff in January of 2021. See Paragraphs 6 and 7 above. 25. Plaintiff's total investment price was $60.000.00. See Paragraphs 6 and 7 above. 26, Defendants. VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, falsely misrepresented that they would repay Plaintiff for her initial investment of $60,000.00 which was advanced to Defendants for the sole purpose of buying, repairing and selling wrecked or damaged vehicles for profit. See Paragraphs 6 and ? above. 27. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, knew that their representations were false. See Paragraphs 8, 9, 11. and 12 above. 28. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC. knew that there was no intention of ever repaying Plaintiff. See Paragraphs 8, 9, 11, and 12 above. 29. The Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, knew the Plaintiff would rely on their false misrepresentations. See Paragraph 6 above. 30. The Plaintiff relied on Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC, false misrepresentations that they would repay Plaintiff for her initial investment of $60,000.00. See Paragraph 7 above. 31. The false misrepresentations by Defendants, VICTOR ANTHONY DEXTER and VENOM MOTOR SPORTS LLC. caused damages to the Plaintiff. See Paragraph 12 above. ) he As a result of the above fraudulent misrepresentations, the Plaintiff has been damaged in the amount of at least $60,000.00. See Paragraphs 7 and 12 ahove. WHEREFORE Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands judgment against Defendants, VICTOR ANTHONY DEXTER individually and derivatively on behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above damages. for interest, attorney’s fees, costs, and for all such other and further relief as this Court deems just and proper, and demands a trial by jury. COUNT Hl — UNJUST ENRICHMENT 33. Plaintiff re-alleges and incorporate the allegations contained in Paragraphs 1 through 12 as though fully stated herein. Page 4 of 6we » ws nr 36. we ™ we 9 39. 40, 4l. This is an action for damages which exceeds $50,000.00, exclusive of court costs, pre- judgment interest and attorneys’ fees. Plaintiff has conferred a benefit upon Defendants who have knowledge of this benefit. See Paragraph 7 above. In reliance on the request from Defendants, Plaintiff advanced $60,000.00 to Defendant for the sole purpose of buying, repairing and selling wrecked or damaged vehicles for profit. See Paragraphs 6 and 7 above. The Plaintiff did so with the belief that if she paid this amount, she would receive repayment of her initial investment from Defendants’ profits. See Paragraphs 6 and 7 above. ‘The Plaintiff believing that she would receive repayment of her investment, advanced the sum of $60,000.00 cash to Defendants. See Paragraphs 6 and 7 above. Defendants accepted and retained the conferred benefits. See Paragraph 7 above. Since Defendants’ receipt of Plaintiff"s investment, Defendants have not made any attempt to return to Plaintiff her investment. See Paragraphs 8, 9, 11, and 12 above. Under the circumstances, it would be inequitable for Defendants to retain the benefits conferred on them by Plaintiff without reimbursing Plaintiff for said benelits. Defendants were unjustly enriched in the amount of at least $60,000.00. See Paragraphs 7 and 12 above. WHEREFORE Plaintiff, VANSIA DINKINS-ANDERSON, respectfully demands judgment against Defendants. VICTOR ANTHONY DEXTER individually and derivatively on behalf of Venom Motor Sports LLC, and VENOM MOTOR SPORTS LLC, for the above damages. for interest, attorney's fees, costs, and for all such other and further relief as this Court deems just and proper, and demands a trial by jury. Page 5 of 6EMAND FOR ATTORNEY’S FEES DEMAND FOR ATTORNEYS Plaintiff, VANSIA. DINKINS-ANDERSON, has retained the undersigned firm and is indebted for a fee for which said Plaintiff seeks recovery from Defendants pursuant to Chapter 57.105 of the Florida Statutes. Dated: August 20, 2021 /s/ Ronald A. Legendre, Esq. Ronald A. Legendre, E. Florida Bar No.: 0163260 Law Offices of Legendre & Legendre PLLC P.O. Box 421405 Kissimmee, FL 32742-1405 Telephone: 407-944-0584 Facsimile: 407-944-0588 Primary Email: ronald@) Secondary Email: anthony and vanes: Page 6 of 6EXHIBIT APrint Date: 07/01/2021 System Refresh Date: 06/30/2021 14112 Lord Barclay Dr 32-24-29-3802-00-470 Name(s): Dexter Victor Mailing Address On File: 14112 Lord Barclay Dr Orlando, FL32837-5401 incorrect Mailing Address? ‘View 2020 Property Record Card Historical Value and Tax Benefits @ ‘Tax Year Valves 2020 BAS 2019 2018 BSS 207 ECS Tax Year Benafits 2020 Be 2019 Be 2018 e) 2017 Land $65,000 $65,000 $55,000 $55,000 Postal City and Zip: Orlando, FL 32837 Buildingis) $218,641 $220,528 $274,890 $190,673, Original Homestead 2020 Taxable Value and Certified Taxes @ Tax Year Les Tee To] Taxing Authority Public Schools: By State Law (Rie) Public Schools: By Local Board General County Unincorporated County Fire Unincorporated Taxing District Library - Operating Budget South Florida Water Management District South Florida Wmd Okeechobee Basin South Florida Wmd Everglades Const Totals Non-Ad Valorem Assessments 2020 Non-Ad Valorem Assessments g Authority COUNTY SPECIAL ASSESSMENT ‘CGUNTY SPECIAL ASSESSMENT Assd Value $283,641 $283,641 $283,641 $283,641 $283,641 $283,641 $283,641 $283,641 $283,641 Physical Street Address: 44112 Lord Barclay Dr Feature(s) $0 $0 $0 $0 Additional Rx Exemption $0 $0 $0 $0 $0 0 $0 $0 40 Assessment Description Property Use: 0103 - Single Fam Class 1 Municipality: Un-incorporated Market Value $283,641 $285,528 $269,890 $245,673 Wiss % 0.7% 5.8% 9.9% NA Other Exemptions $0 $0 $0 $0 Tax Value Millage Rate $283,641 3.6090 $203,641 3.2480 $283,641 4.4347 $283,641 2.2437 $283,641 1.8043 $283,641 0.3748 $283,641 0.1103 $283,641 0.1192 $283,641 0.0380 15.9820 ADVANCED DISP - GARBGE - (407)836-6601 STREET LIGHTS - LIGHT - (407)836-5770 Assessed Value $283,641 $285,528 $262,643 $238,766 SOH CAP % Taxes “6.5% — $1,023.66 0.0% — $921.27 90% — $1,257.86 0.0% $636.41 0.0% © SSIL7T 0.0% — $106.31 43% $31.29 “A3% $33.81 43% © $10.78 $4,833.16 Units Rates 1.00 245,00 1.00 9751 % 0.7% 8.7% 10.0% N/A ‘Tax Savings $0 $0 $66 $63 Tax Breakclown 23% 20% 28% 14% 1% 2% 1% 1% Assessment $245.00 $97.51 $342.51 2020 Gross Tax Total: $4,875.67 2020 Tax Savings Tax Savings Your taxes without exemptions would be: $4,533.16 Your ad-valorem tax with exemptions is: « $4,533.16 V2EXHIBIT BTIN2024 ZIP Code™ Lookup | USPS ZIP Code™ by Address ZIP Code™ by City and State Cities by ZIP Code™ FAQs ‘Soom onan Look Up a ZIP Code™ ros Go to ZIP Code™ by Address You entered: 14112 LORD BARCLAY DRIVE ORLANDO FL If more than one address matches the information provided, try narrowing your search by entering a street address and, if applicable, a unit number. Edit and search again. 14112 LORD BARCLAY DR ORLANDO FL 32837-5401 CARRIER ROUTE COUNTY DELIVERY POINT CODE CHECK DIGIT COMMERCIAL MAIL RECEIVING AGENCY LAc™ eLOoT™ eLOT ASCENDING/DESCENDING INDICATOR RECORD TYPE CODE PMB DESIGNATOR PMB NUMBER DEFAULT FLAG EWS FLAG DPV CONFIRMATION INDICATOR co73 ORANGE 12 wtEXHIBIT CTHI2021 Property Search | Osceola County Property Appraiser Osceola County Property Appraiser Katrina S. Scarborough, CFA, CCF, MCF Basic Search Advanced Search Sales Search Search Results Parcel Result Map Help Parcel Result Parcel: 292529112400010060 ‘Map View E-Mail Parcel, NEW Bird's Eye View ‘Owner Name. DEXTER VICTOR. Mailing Address: 14112 LORD BARCLAY DR ORLANDO, FL 32837 Physical Address: 725 HUDSON ST, KISSIMMEE FL 34744 Description MULTI-FAMILY-IMPROVED less than 10 units Tax District 200 - KISSIMMEE Current Value represents working appraised values as of 06/30/2021, Certified Value represents certified values that appeared on the tar which are subject to change prior to certification roll as of 02/04/2021 jLand $20,000 Land $16,500 |AG Benefit $0 AG Benefit $0 Extra Features $1,300 Extra Features $1,400 Buildings $57,300 Buildings $56,300 Appraised(Just) $78,600 Appraised(just) $74,200 |Assessed(estimated) $78,600 Assessed” $72,721 Exemption(estimated) $0 Exemption $0 Taxable(estimated) $78,600 Taxable $72,721 * Assessed Values Reflect Adjustments for Agricultural Classification * Assessed Values Reflect Adjustments for Agricultural and/or the Save Our Homes Cap Classification and/or the Save Our Homes Cap 4933-2342 $0 2013-06-11 Quit Claim Deed (ac) 0 1 4355-0295 $100 2042-11-23 Quit Claim Deed (ac) 2 4279-0714 $100 2012-06-04 Quit Claim Deed ac) 3 4085-2059 $43,800 2011-01-20 Warranty Deed (wo) 4 1898-1539 $85,000 2001-07-03 Warranty Deed wo) 5 1469-0814 $87,500 1994-01-24 Warranty Deed (wo) 6 0818-1619 $50,500 1986-10-15 Warranty Deed (wo) 7 0471-0366. $34,500 1980-02-29 Warranty Deed (wo) 3 0368-0676 $0 1977-08-09 Warranty Deed wo) 9 0343-0865 $0 1976-10-29 Certificate of Title (CT) [RESIDENTIAL AIC-WALL UNIT GOOD 2 1974 $400 |CONCRETE PADIPATIO AVERAGE 390 4990 $310 (WOOD FENCE-6 FT HIGH AVERA\ 2014 $582 es —