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Filing # 124782640 E-Filed 04/12/2021 10:18:21 PM
IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT,
IN AND FOR MONROE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
GALWAY BAY MOBILE HOMEOWNERS CASE NO.: 17-CA-000166-MR
ASSOCIATION, INC.,
Plaintiff,
vs.
BIZA, CORP, d/b/a GALWAY BAY MOBILE
HOME PARK,
Defendant.
_________________________________________/
SUPPLEMENTAL EXHIBIT “A” TO
MOTION TO COMPEL AND FOR SANCTIONS
Defendant, BIZA, CORP, d/b/a GALWAY BAY MOBILE HOME PARK (“Defendant”),
by and through undersigned counsel, hereby files the attached Supplemental Exhibit “A” to the
Motion to Compel and for Sanctions (the “Sanctions Motion”). The original Exhibit “A” to the
Sanctions Motion included the spreadsheet prepared by the Plaintiff of its members deposits of
“disputed rent” into the registry thorough September of 2020.
The Supplemental Exhibit “A” includes Plaintiff’s members deposits of “disputed rent”
into the registry and directly to Defendant, Biza Corp. through March of 2021.
Dated: April 12, 2021
Respectfully submitted,
EDELBOIM LIEBERMAN REVAH
OSHINSKY PLLC
Attorneys for Defendant
Beacon Tower of Aventura
20200 W. Dixie Hwy., Suite 905
Miami, Florida 33180
Telephone: 305.768.9909
Facsimile: 305.928.1114
Email: brett@elrolaw.com
By: /s/ Brett D. Lieberman, Esq.
Brett D. Lieberman, Esq. (FBN 69583)
1
4/12/2021 10:18 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1
CERTIFICIATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was submitted through
the Florida E-Portal on April 12, 2021 and served on all parties authorized to receive notifications
via the Florida E-Portal generated service email.
/s/ Brett D. Lieberman
Brett D. Lieberman, Esq.
2
4/12/2021 10:18 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2
DEPOSITS MADE
Name Lot # 2017 Rent
18-May 18-Jun 18-Jul 18-Aug 18-Sep 18-Oct 18-Nov
Redfern, Carl A-1 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Michalski, Richard (and McDougall) A-2 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Mitchell, Dave & Dotty A-4 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Brodeur, Steve A-5 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Jackson, Pam A-8 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Kaczmerek, Jerry & Ruth A-11 $1,128.00 $175.00 $175.00 $175.00 $175.00 $175.00 $175.00 $175.00
Shell, Lois B-4 $1,153.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Amerman, George B-5 $1,153.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Chandler, Bill & Kim B-6 $1,153.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
O'Conner, Robert B-8 $1,153.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
At $172/ Month $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Soutiere, Jerry & Carol B-11 $1,153.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00
King, Rich & Carol C-3 $1,128.00 $501.00 $501.00 $501.00 $501.00 $501.00
Cosby, Scott & Sue C-8 $1,153.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00
At $176/Month $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00
Troph, Gary & Stacy D-4 $1,281.00 $1,560.00
Stephan, John D-5 $1,281.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
Rooney, Eugene D-7 $1,281.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
Hagemann, Ken & Fran / May, David D-8 $1,281.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
Grondin, Emile D-10 $1,281.00 $172.00
Dunn, Wayne & Janie D-11 $1,281.00 $195.00 $195.00 $195.00 $195.00
Childress, Helene D-12 $1,281.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
Koolen, Ricky D-13 $1,281.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
At $195/Month $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
Huddle, Dave & Collette G-8 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Wheeler, Ron & Kim G-16 $1,128.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
Key:
Red Cell Indicates No Payment
Blue Cell Indicates Payment Direct to Biza
No color indicates Payment to Registry
4/12/2021 10:18 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 3
18-Dec 19-Jan 19-Feb 19-Mar 19-Apr 19-May 19-Jun 19-Jul 19-Aug 19-Sep 19-Oct 19-Nov
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$688.00 $354.00 $354.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$175.00 $175.00 $175.00 $175.00 $175.00 $175.00 $1,265.00 $1,265.00 $1,265.00 $1,265.00 $175.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $4.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $354.00 - $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$176.00 $176.00 $176.00 $176.00 $1,087.50 $176.00 $175.00
$501.00
$176.00 $176.00 $176.00 $176.00
$176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$975.00 $1,199.00
$195.00 $195.00
$195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
4/12/2021 10:18 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 4
19-Dec 20-Jan 20-Feb 20-Mar 20-Apr 20-May 20-Jun 20-Jul 20-Aug 20-Sep 20-Oct 20-Nov 20-Dec
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$344.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$175.00 $175.00 $175.00 $175.00 $360.50 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $344.00 $172.00 $172.00 $344.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $192.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
$722.00 $176.00
$169 $169 $4,052.00 $169 $169
$176 $176 $196 $196 $196
$176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00 $176.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 SOLD
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 Home, no
$195.00 $195.00 $195.00 $195.00 $195.00 $390.00 $195.00
SOLD
$412.00 $616.50 Home, no
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00 $195.00
$172.00 $172.00 $172.00 $172.00 $172.00
$172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00 $172.00
4/12/2021 10:18 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 5
21-Jan 21-Feb 21-Mar Unpaid Disputed Rent
$172.00 $172.00 $172.00 $4,988.00 $1,052.00 Redfern, Carl
$172.00 $172.00 $172.00 $5,504.00 $536.00 Michalski, Richard
$172.00 $172.00 $172.00 $5,160.00 $880.00 Mitchell, Dave & Dotty
$172.00 $172.00 $3,804.00 $2,236.00 Brodeur, Steve
$172.00 $172.00 $172.00 $5,676.00 $364.00 Jackson, Pam
$172.00 $172.00 $172.00 $10,290.50 - Kaczmerek, Jerry & Ruth
$344.00 $172.00 $172.00 $5,508.00 $532.00 Shell, Lois
$172.00 $172.00 $172.00 $5,332.00 $708.00 Amerman, George
$172.00 $172.00 $4,654.00 $1,386.00 Chandler, Bill & Kim
$172.00 $172.00 $172.00 $4,988.00 $1,052.00 O'Conner, Robert
$172.00 $172.00 $172.00 $6,040.00
$4,272.50 $1,887.50 Soutiere, Jerry & Carol
$172.00 $169 $169 $8,244.00 - King, Rich & Carol
$800.00 $3,676.00 $2,484.00 Cosby, Scott & Sue
$176.00 $176.00 $176.00 $6,160.00
$195.00 $195.00 $6,435.00 $390.00 Troph, Gary & Stacy
$195.00 $195.00 $195.00 $6,630.00 $195.00 Stephan, John
Rooney, Eugene
$195.00 $195.00 $195.00 $5,655.00 $1,170.00 Hagemann, Ken & Fran / May, David
SOLD Grondin, Emile
Home, no Dunn, Wayne & Janie
$2,145.00 $4,680.00 Childress, Helene
$4,875.00 $1,950.00 Koolen, Ricky
$195.00 $195.00 $195.00 $6,825.00 At $195/Month
$3,612.00 $2,428.00 Huddle, Dave & Collette
$172.00 $172.00 $172.00 $5,676.00 $484.00 Wheeler, Ron & Kim
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