Preview
ASSIGNED TO: EAST
PERSON TO BE SERVED:
}3
BREVARD COUNTY SHERIFF'S OFFICE
AFFIDAVIT OF SERVICE
RECEIPT NUMBER: 0001553-21
RECEIVE DATE: 06/16/2021
RECEIVE TIME: 11:38 AM
ae # 05-2021-CA- oat 713-XXXX-XXK
WILLIAM JACKSON 8
3500 N. RIVERSIDE DR. Sedo 8
INDIALANTIC, FIL 32903 i Ah iil s
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PLAINTIFF: HOMESAVIOR CONSULTANTS INC., C/O DAVID WATSON 2°
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DEFENDANT: ALBERTA JACKSON AND WILLIAM JACKSON
TYPE WRIT: OF
LIEN/COMPLAINT/AMENDED COMPLAINT/PROPERTY CLAIM SETTLEMENT/CERTIFICATE OF
SUMMONS/CIVIL COVER SHEET/CERTIFICATE OF SERVICE/ANSWER TO CONTEST
SERVICE
COURT: CIRCUIT/BREVARD COURT DATE:
CASE #: 2021CA021713 COURT TIME:
ATTEMPTS / COMMENTS COMPLETED SERVICE
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Possibly Ady Serv( TeIN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR BREVARD COUNTY
CIVIL DIVISION
Homesavior Consultants Inc C/O David Watson
Lienee, Plaintiff
vs. CASE NO.05-2021-CA-021713-X-
Alberta Jackson; William Jackson a “3
Lienee, Defendant
TO: Alberta Jackson; William Jackson :
3500 N Riverside Dr.
Indiatlantic, FL. 32903 “
THE STATE OF FLORIDA °
TO EACH SHERRIFF OF THE STATE
You are commanded to serve this Summons and a copy of the petition in this lawsuit on the
above named Defendant (s)
SUMMONS
PERSONAL SERVICE ON A NATURAL PERSON
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is
served on you to file a written response to the attached Complaint in this Court. A phone call will
not protect: your written response, including the above case number and named parties, must be
filed if you want the Court to hear your case. If you do not file your response on time, you may
lose the case and your wages, your money and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an attorney
referral service or a legal aid office. (Listed in phone book). If you choose to file a written
response yourself, at the time you file your written response to the Court you must also mail or
take a carbon copy or photocopy of your response to the Plaintiff pro se.
Homesavior Consultants Inc CO David Watson
408 Plantation Dr
Titusville, FL 32780ThA J
Witness, my hand and seal of this Court On the /@ day of iz
2021.
CLERK OF COUNTY COURT
Deputy Clerk
FILE NO:IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR BREVARD COUNTY
CIVIL DIVISION
Homesavior Consultants Inc C/O David Watson
Lienee, Plaintiff
vs. CASE NO.05-2021-CA-021713-X-
Alberta Jackson; William Jackson
Lienee, Defendant
TO: Alberta Jackson; William Jackson
3500 N Riverside Dr.
Indiatlantic, FL. 32903
THE STATE OF FLORIDA
TO EACH SHERRIFF OF THE STATE
You are commanded to serve this Summons and a copy of the petition in this lawsuit on the
above named Defendant (s)
SUMMONS
PERSONAL SERVICE ON A NATURAL PERSON
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is
served on you to file a written response to the attached Complaint in this Court. A phone call will
not protect: your written response, including the above case number and named parties, must be
filed if you want the Court to hear your case. If you do not file your response on time, you may
lose the case and your wages, your money and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an attorney
referral service or a legal aid office. (Listed in phone book). If you choose to file a written
response yourself, at the time you file your written response to the Court you must also mail or
take a carbon copy or photocopy of your response to the Plaintiff pro se.
Homesavior Consultants Inc CO David Watson
408 Plantation Dr
Titusville, FL 32780Witness, my hand and seal of this Court 0n the le day of June ;
2021.
CLERK OF COUNTY COURT
OEIORE TAYLOR
By:
Deputy Clerk
FILE NO:IN THE CIRCUIT COURT, EIGHTEENTH JUDICIAL CIRCUIT,
BREVARD COUNTY, FLORIDA
DIVISION: CIVIL CASE NUMBER: 05- 2021 - CA - 021713 -XXXX-XX
LAL
ae ee Consultants Inc CO David Watson.
vs.
ne
8
DEFENDANT .
ALBERTA; WILLIAM JACKSON =
Sos F SR
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oe FS
CIVIL COVER SHEET “26 Ff
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AMOUNT OF CLAIM
Please indicate the estimated amount of the claim, rounded to the nearest dollar.
$35,000.00 latwost, Coo & Fees
TYPE OF CASE (If the case fits more than one type of case, select the most definitive
category.) If the most descriptive label is a subcategory (is indented under a broader category),
place an X on both the main category and subcategory boxes.
CIRCUIT CIVIL
HI Condominium
Contracts and indebtedness
Eminent domain
im
L] Auto negligence
C1 Ne ligence — other
H Business governance
Business torts
C] Environmental/Toxic tort
C) Third party indemnification
C] Construction defect
C1) Mass tort
Ol Negligent security
H Nursing home negligence
Premises liability ~ commercial
Premises liability — residential
C1 Products liability
(1 Real roperty/Mortgage foreclosure
Commercial foreclosure
[) Homestead residential foreclosure
Non-homestead residential foreclosure
LJ Other real property actions
Law 122 / Rev. 01-01-2020
oOCIVIL COVER SHEET
CASE NUMBER: 05- 2021- CA - 021713 -KXXX-XX
C1 Professional malpractice
Malpractice — business
Malpractice — medical
Malpractice — other professional
000
0 other
Antitrust/Trade regulations
Business transactions
Constitutional challenge — statute or ordinance
Constitutional challenge — proposed amendment
Corporate trusts
Discrimination — employment or other
Insurance claims
Intellectual property
Libel/Slander
Shareholder derivative action
Securities litigation
Trade secrets
Trust litigation
OOOO
Oo
COUNTY CIVIL
Civil
oO Replevins
Evictions
Other civil (non-monetary)
REMEDIES SOUGHT
Monetary;
Nonmonetary declaratory or injunctive relief;
Punitive
NUMBER OF CAUSES OF ACTION [ 2 |
(Specify) 1. Breach of Contract
2. Presentment of worthless check (non payment)
IS THIS CASE A CLASS ACTION LAWSUIT?
Yes
No
HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?
[] No
CI yYes-if “Yes”, list all related cases by name, case number, and court.
Law 122 / Rev. 01-01-2020CIVIL COVER SHEET
CASE NUMBER: 05-2021 - CA - 021713 -XXXX-XX
IS JURY TRIAL DEMANDED IN COMPLAINT?
C1 Yes
No
I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my
knowledge and belief, and that I have read and will comply with the requirements of Florida
Rule of Judicial Administration 2.425.
Lowi Sexe:
Signature ‘ Cpe Fla. Bar #
Attorney or party (Bar # if attorney)
f
HOMESAVIOR CONSULTANTS INC CO DAVID WATSON ___6/ Goo
(type or print name) Date
Law 122/ Rev. 01-01-2020 3Homesavior Consultants inc / CO David Watson, pro se
408 Plantation Dr.
Titusvillé, FL32780 PH 321-298-7754
CERTIFICATE OF SERVICE
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| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by US Mail and or Personal Service to the Lienee, Alberta Jackson;
William Jacks :
thal bho 7/6 -2ea/
Byam eA Dev Core | ih | Bow!
Notary Public dy were Wye Wedree’4IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT OF THE STATE
OF FLORIDA, IN AND FOR BREVARD COUNTY
CIVIL DIVISION
Administrative number 05-2021-CA-014909-XXXX-XX
Homesavior Consultants Inc C/O David Watson
Heh y 91 por qage
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Lienor, Plaintiff.
vs.
Case# 05-2021-CA-021713-X-XXX-XX
Alberta Jackson; William Jackson
Lienee, Defendant.
ee |
Answer to Contest of Lien / Complaint/
ear G-(6~202f
“OM Phe
AMENDED sueione C&
Homesavior Consultants Lienor, Plaintiff; Answers defendant contest of lien and
sues Alberta Jackson Lienee, Defendant for money damages as a result of Breech
of Contract And Non Payment for Consulting Services states:
Jurisdictional Allegations
1. This is an action for money damages in excess of 15,000.00. excluding late
charges, costs to initiate lawsuit, Attorney fees and any other charges this
court deems necessary.
2. At all times to this lawsuit Homesavior Consultants Inc. was a business
operating under CEO David Watson in Brevard County, Florida. At all times material to this lawsuit Defendant (s) Alberta/ William Jackson
were residents in Brevard County, Florida
. All acts necessary or precedent to bringing this lawsuit occurred or accrued
in Brevard County, Florida
. This Court has Jurisdiction.
General Factual Allegations
. On November 3, 2020 Alberta Jackson / William (Bill) Jackson entered into a—
written agreement with Johnny T Weidmann Roofing Inc and Homesavior
Consultants Inc. CEO David Watson, whereby defendant promises to pay
Homesavior Consultants Inc. directly for any supplements and 20%
overhead and profit on the insurance claim # 005245214-006 USAA
Insurance.
. Acopy of Pre - Final Supplement Invoice AND contract, And Insurance
scope 23 pages dated sept.4, 2020 is attached Exhibit A Homesavior Invoice
at time of contract pre supplements , A-1 Contract Agreement ,And A-
1a,insurance scope dated Dec.15,2020, 20 pages Final Insurance scope, All
of which itemize the financials for entire contract agreement.
. attached exhibit A Invoice with contract, A-1 And A-1a
. Defendant Alberta Jackson paid Homesavior Consultants Inc. on Dec.1,2020
$7500.00 A draw payment for tear off and dry inn work performed per
contract agreement.
10. Check # 1141 for 7500.00 Exhibit B.
11. Defendant issued a Reduced Final payment on Dec. 22, 2020 in the amount
of 34,500.98 per the contract agreement.
12. Check #1144 34,500.98 attached Exhibit C
13. Defendant stopped payment on the check issued as final payment of
34,500.98 [ Check attached Exhibit C ] on Dec. 22, 2020,
WELLS FARGO BANK TELLER VERIFIED Stop payment 12/22/2020
13.As a result of Defendant issuing a worthless check # 1144, have original
check (prima facia evidence) in my possession. Homesavior Consultants Inc.
prepared a Final Invoice per the Approved Insurance scope per HomesaviorConsultants Inc. Supplement request invoice submitted to Insurance. For
entire money owing, Sent Via Email to bill@wajcoa.com on 12/23/2020
14. Homesavior Consultants Inc Final Invoice FROM Insurance Scope Prior to
receiving check # 1146 from Johnny T Weidmann, includes all approved
supplements and 20% O&P from final Revised Insurance Scope, Dated Dec.
15, 20220. Attached Exhibit D-1 Homesavior Invoice 41,392.59 to Alberta/
William Jackson.
15. Defendant issued a check paid to Johnny T Weidmann for money owed to
Homesavior Consultants Inc. in order to defraud actual Balance owing, in
the amount of $5953.87.
16. Check # 1146 attached Exhibit D
17. Homesavior Consulting Inc. prepared a revised invoice after receiving
payment of 5953.87 from Johnny T Weidmann and sent via US Certified
Mail Demand letter for Balance owing sent out to Defendant on January
10,2021
18. Copy of demand letter attached Exhibit E-1, and E, Final Invoice
19.Homesavior Consultants Inc Filed a Lien for outstanding Balance owing on
January 12, 2021
20. Defendant filed a Notice of Contest of lien.
21. Homesavior Consultants Inc / CO David Watson file Answer / complaint to
Notice of Contest of Lien.
Wherefore Plaintiff HomeSavior Consultants Inc. / CO David Watson demands
Judgement for money damages against and accrued from Alberta Jackson /
William Jackson defendants, together with such other and further relief as the
court may deem reasonable and i, under the circumstances.
ea Plaintiff signatureApmin es-goal- Ch ~O/F@}
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CASE LB OS - 20217 CA ~ OR | TB —K~VWLK~ XK
Under penalty of perjury, | certify that a copy of the foregoing was provided by
regular mail to the Defendant Alberta Jackson and William Jackson acting Power
of Attorney at 3500 N Riverside Dr. Indiatlantic, FL 32903
Certificate of Service
Attached docs. Answer to contest of lien/complaint filed on March 23,2021
All Exhibits: A, A-1, B,C,D-1,D,E-1,E
ALL DOCS FILED WITH COURT March 24,2021 and on April 5,2021
Moy,
State of Florida
Brevard County,
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Before m personally appeared Homesavior Consultants Inc CO David Watson,
who being duly sworn and Identified in accordance with | pig execute the
foregoing in my presence this [ day of i ,2021
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Case # 05-2021-CA-021713-XXXX-XX
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United Services Automobile Association, {e
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ALBERTA M JACKSON
3500 N RIVERSIDE DR
INDIALANTIC FL 32903-4422 as &. s
“4 ts
Review Your Claim
September 4, 2020
Dear Mrs, Jackson,
We've issued a check in the amount of $24,217.54 for the following claim:
Claim number: 005245214-006
Date of toss: March 26, 2019
Loss location: Indialantic, Florida
Here's how we determined your payment:
Replacement cost $147,839.07
Less recoverable depreciation $-63,486.07
Less non-recoverable depreciation $-6,159.73
Less Amount Above Limits $-51,975.73
Less deductible $-2,000.00
Actual cash value settlement $24,217.54
What Is Recoverable Depreciation?
The Loss Settlement Provision of your policy provides payment for the reasonable and necessary cost to repair or
replace property involved in a covered loss, Because this policy benefit depends upon actual restoration of the property,
your initial payment may consist of the actual cash value only, such as the amount after deduction for depreciation.
Recoverable depreciation refers to the potential reimbursement amount upon completion of repair or replacement.
After repair or replacement is complete, we calculate your recoverable depreciation as the lesser of the amount
necessary to repair or replace the damaged property or the amount you actually spent, minus your deductible and any
amount already paid for the damaged property.
What Documentation Is Required to Claim Recoverabie Depreciation?
Please send us copies of the repair contract, invoice, repair bill and any receipts. These documents should provide:
© Anitemized list of the work done and description of any items replaced.
© Documentation of all costs.
o The completion date for work done and replacement date of any items replaced.
005245214 - 006 - 1243 - 06 54582-0820
Page 1 of 2United Services Automobile Association.
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INDIALANTIC FL 32903-4422
Review Information About Your Claim
December 15, 2020
Dear Mrs. Jackson,
’'m writing regarding the claim referenced below.
USAA policyholder: Alberta M Jackson
Claim number:
Date of loss:
Loss location:
005245214-006
March 26, 2019
Indialantic, Florida
Attached you will find the revised estimate for storm damage repairs. The total for the roofing, siding and the deck
railing is $144,906,94. | have sent a o(eeaaateal the release of the recoverable depreciation via check, being
mailed to your home in the amount 0 $84,091.80) y, op femmect Praff CL coke
The remaining recoverable denréciation on the claim is $7; 932, 78 for the replacement of the window screens, security
storm shutter (roll up) and the interior work to the entry/foyer and dining room.
if you have any questions, please let me know.
You may submit correspondence or questions to me using one of the following options:
usaa.com or our mobile app: Upload documents or post a secure message to your claim file
through the Claim Communication Center.
&| © Address: USAA Claims Department
P.O. Box 33490
San Antonio, TX 78265
Fax: 1-800-531-8669
Phone: 1-800-531-8722
x
Ns
005245214 - 006 - 1243 - 06 54577-1020
Page 1 of 2Homesavior Consultants Inc / CO David Watson, pro se
408 Plantation Dr.
Titusville, FL 32780 PH 321-298-7754
homesavior777@gmail.com
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CERTIFICATE OF SERVICE $ ;
furnished by US Mail and or Personal Service to the Lienee, Alberta Jackson;
William Jackson
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Notary Public Jerwrorn. Wo Beare. “lwloos!
Preview
ASSIGNED TO: EAST PERSON TO BE SERVED: }3 BREVARD COUNTY SHERIFF'S OFFICE AFFIDAVIT OF SERVICE RECEIPT NUMBER: 0001553-21 RECEIVE DATE: 06/16/2021 RECEIVE TIME: 11:38 AM ae # 05-2021-CA- oat 713-XXXX-XXK WILLIAM JACKSON 8 3500 N. RIVERSIDE DR. Sedo 8 INDIALANTIC, FIL 32903 i Ah iil s G> t ab Pood == PLAINTIFF: HOMESAVIOR CONSULTANTS INC., C/O DAVID WATSON 2° -VS- cn rR DEFENDANT: ALBERTA JACKSON AND WILLIAM JACKSON TYPE WRIT: OF LIEN/COMPLAINT/AMENDED COMPLAINT/PROPERTY CLAIM SETTLEMENT/CERTIFICATE OF SUMMONS/CIVIL COVER SHEET/CERTIFICATE OF SERVICE/ANSWER TO CONTEST SERVICE COURT: CIRCUIT/BREVARD COURT DATE: CASE #: 2021CA021713 COURT TIME: ATTEMPTS / COMMENTS COMPLETED SERVICE b LL COW Cap v4 INDIVIDUAL kr cord ZLveh ted on SUBSTITUTE POSTED CORPORATE ror. ya 2 | Om No Mawes A a FOUND OTHER le \ ie {t ud 3 wider | aan Tok on yiye ine A) bag iH a / "Relationship ~or= Title) DATE T- Z7U cme: Oh oe 5 309M pokeAg. BBH, CIVIL cupaxd4 ot Jo ia deb Nome on COMMENTS: ae. - \ pn DAY a. Guano ef q li & puy (mM wine: ft Of w | ) NDF ee One 290? wr lb lar a let Cas Possibly Ady Serv( TeIN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR BREVARD COUNTY CIVIL DIVISION Homesavior Consultants Inc C/O David Watson Lienee, Plaintiff vs. CASE NO.05-2021-CA-021713-X- Alberta Jackson; William Jackson a “3 Lienee, Defendant TO: Alberta Jackson; William Jackson : 3500 N Riverside Dr. Indiatlantic, FL. 32903 “ THE STATE OF FLORIDA ° TO EACH SHERRIFF OF THE STATE You are commanded to serve this Summons and a copy of the petition in this lawsuit on the above named Defendant (s) SUMMONS PERSONAL SERVICE ON A NATURAL PERSON IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached Complaint in this Court. A phone call will not protect: your written response, including the above case number and named parties, must be filed if you want the Court to hear your case. If you do not file your response on time, you may lose the case and your wages, your money and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney referral service or a legal aid office. (Listed in phone book). If you choose to file a written response yourself, at the time you file your written response to the Court you must also mail or take a carbon copy or photocopy of your response to the Plaintiff pro se. Homesavior Consultants Inc CO David Watson 408 Plantation Dr Titusville, FL 32780ThA J Witness, my hand and seal of this Court On the /@ day of iz 2021. CLERK OF COUNTY COURT Deputy Clerk FILE NO:IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR BREVARD COUNTY CIVIL DIVISION Homesavior Consultants Inc C/O David Watson Lienee, Plaintiff vs. CASE NO.05-2021-CA-021713-X- Alberta Jackson; William Jackson Lienee, Defendant TO: Alberta Jackson; William Jackson 3500 N Riverside Dr. Indiatlantic, FL. 32903 THE STATE OF FLORIDA TO EACH SHERRIFF OF THE STATE You are commanded to serve this Summons and a copy of the petition in this lawsuit on the above named Defendant (s) SUMMONS PERSONAL SERVICE ON A NATURAL PERSON IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached Complaint in this Court. A phone call will not protect: your written response, including the above case number and named parties, must be filed if you want the Court to hear your case. If you do not file your response on time, you may lose the case and your wages, your money and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney referral service or a legal aid office. (Listed in phone book). If you choose to file a written response yourself, at the time you file your written response to the Court you must also mail or take a carbon copy or photocopy of your response to the Plaintiff pro se. Homesavior Consultants Inc CO David Watson 408 Plantation Dr Titusville, FL 32780Witness, my hand and seal of this Court 0n the le day of June ; 2021. CLERK OF COUNTY COURT OEIORE TAYLOR By: Deputy Clerk FILE NO:IN THE CIRCUIT COURT, EIGHTEENTH JUDICIAL CIRCUIT, BREVARD COUNTY, FLORIDA DIVISION: CIVIL CASE NUMBER: 05- 2021 - CA - 021713 -XXXX-XX LAL ae ee Consultants Inc CO David Watson. vs. ne 8 DEFENDANT . ALBERTA; WILLIAM JACKSON = Sos F SR P5> pp w oe FS CIVIL COVER SHEET “26 Ff Ae F S = 3 AMOUNT OF CLAIM Please indicate the estimated amount of the claim, rounded to the nearest dollar. $35,000.00 latwost, Coo & Fees TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the most descriptive label is a subcategory (is indented under a broader category), place an X on both the main category and subcategory boxes. CIRCUIT CIVIL HI Condominium Contracts and indebtedness Eminent domain im L] Auto negligence C1 Ne ligence — other H Business governance Business torts C] Environmental/Toxic tort C) Third party indemnification C] Construction defect C1) Mass tort Ol Negligent security H Nursing home negligence Premises liability ~ commercial Premises liability — residential C1 Products liability (1 Real roperty/Mortgage foreclosure Commercial foreclosure [) Homestead residential foreclosure Non-homestead residential foreclosure LJ Other real property actions Law 122 / Rev. 01-01-2020 oOCIVIL COVER SHEET CASE NUMBER: 05- 2021- CA - 021713 -KXXX-XX C1 Professional malpractice Malpractice — business Malpractice — medical Malpractice — other professional 000 0 other Antitrust/Trade regulations Business transactions Constitutional challenge — statute or ordinance Constitutional challenge — proposed amendment Corporate trusts Discrimination — employment or other Insurance claims Intellectual property Libel/Slander Shareholder derivative action Securities litigation Trade secrets Trust litigation OOOO Oo COUNTY CIVIL Civil oO Replevins Evictions Other civil (non-monetary) REMEDIES SOUGHT Monetary; Nonmonetary declaratory or injunctive relief; Punitive NUMBER OF CAUSES OF ACTION [ 2 | (Specify) 1. Breach of Contract 2. Presentment of worthless check (non payment) IS THIS CASE A CLASS ACTION LAWSUIT? Yes No HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? [] No CI yYes-if “Yes”, list all related cases by name, case number, and court. Law 122 / Rev. 01-01-2020CIVIL COVER SHEET CASE NUMBER: 05-2021 - CA - 021713 -XXXX-XX IS JURY TRIAL DEMANDED IN COMPLAINT? C1 Yes No I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. Lowi Sexe: Signature ‘ Cpe Fla. Bar # Attorney or party (Bar # if attorney) f HOMESAVIOR CONSULTANTS INC CO DAVID WATSON ___6/ Goo (type or print name) Date Law 122/ Rev. 01-01-2020 3Homesavior Consultants inc / CO David Watson, pro se 408 Plantation Dr. Titusvillé, FL32780 PH 321-298-7754 CERTIFICATE OF SERVICE % % Poa = #66 310758 = D3, & eZ Yd pendeg WO er SS RT RRS Ss “iy fle, SIE “i | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by US Mail and or Personal Service to the Lienee, Alberta Jackson; William Jacks : thal bho 7/6 -2ea/ Byam eA Dev Core | ih | Bow! Notary Public dy were Wye Wedree’4IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR BREVARD COUNTY CIVIL DIVISION Administrative number 05-2021-CA-014909-XXXX-XX Homesavior Consultants Inc C/O David Watson Heh y 91 por qage S oOo 3 7 “ Lienor, Plaintiff. vs. Case# 05-2021-CA-021713-X-XXX-XX Alberta Jackson; William Jackson Lienee, Defendant. ee | Answer to Contest of Lien / Complaint/ ear G-(6~202f “OM Phe AMENDED sueione C& Homesavior Consultants Lienor, Plaintiff; Answers defendant contest of lien and sues Alberta Jackson Lienee, Defendant for money damages as a result of Breech of Contract And Non Payment for Consulting Services states: Jurisdictional Allegations 1. This is an action for money damages in excess of 15,000.00. excluding late charges, costs to initiate lawsuit, Attorney fees and any other charges this court deems necessary. 2. At all times to this lawsuit Homesavior Consultants Inc. was a business operating under CEO David Watson in Brevard County, Florida. At all times material to this lawsuit Defendant (s) Alberta/ William Jackson were residents in Brevard County, Florida . All acts necessary or precedent to bringing this lawsuit occurred or accrued in Brevard County, Florida . This Court has Jurisdiction. General Factual Allegations . On November 3, 2020 Alberta Jackson / William (Bill) Jackson entered into a— written agreement with Johnny T Weidmann Roofing Inc and Homesavior Consultants Inc. CEO David Watson, whereby defendant promises to pay Homesavior Consultants Inc. directly for any supplements and 20% overhead and profit on the insurance claim # 005245214-006 USAA Insurance. . Acopy of Pre - Final Supplement Invoice AND contract, And Insurance scope 23 pages dated sept.4, 2020 is attached Exhibit A Homesavior Invoice at time of contract pre supplements , A-1 Contract Agreement ,And A- 1a,insurance scope dated Dec.15,2020, 20 pages Final Insurance scope, All of which itemize the financials for entire contract agreement. . attached exhibit A Invoice with contract, A-1 And A-1a . Defendant Alberta Jackson paid Homesavior Consultants Inc. on Dec.1,2020 $7500.00 A draw payment for tear off and dry inn work performed per contract agreement. 10. Check # 1141 for 7500.00 Exhibit B. 11. Defendant issued a Reduced Final payment on Dec. 22, 2020 in the amount of 34,500.98 per the contract agreement. 12. Check #1144 34,500.98 attached Exhibit C 13. Defendant stopped payment on the check issued as final payment of 34,500.98 [ Check attached Exhibit C ] on Dec. 22, 2020, WELLS FARGO BANK TELLER VERIFIED Stop payment 12/22/2020 13.As a result of Defendant issuing a worthless check # 1144, have original check (prima facia evidence) in my possession. Homesavior Consultants Inc. prepared a Final Invoice per the Approved Insurance scope per HomesaviorConsultants Inc. Supplement request invoice submitted to Insurance. For entire money owing, Sent Via Email to bill@wajcoa.com on 12/23/2020 14. Homesavior Consultants Inc Final Invoice FROM Insurance Scope Prior to receiving check # 1146 from Johnny T Weidmann, includes all approved supplements and 20% O&P from final Revised Insurance Scope, Dated Dec. 15, 20220. Attached Exhibit D-1 Homesavior Invoice 41,392.59 to Alberta/ William Jackson. 15. Defendant issued a check paid to Johnny T Weidmann for money owed to Homesavior Consultants Inc. in order to defraud actual Balance owing, in the amount of $5953.87. 16. Check # 1146 attached Exhibit D 17. Homesavior Consulting Inc. prepared a revised invoice after receiving payment of 5953.87 from Johnny T Weidmann and sent via US Certified Mail Demand letter for Balance owing sent out to Defendant on January 10,2021 18. Copy of demand letter attached Exhibit E-1, and E, Final Invoice 19.Homesavior Consultants Inc Filed a Lien for outstanding Balance owing on January 12, 2021 20. Defendant filed a Notice of Contest of lien. 21. Homesavior Consultants Inc / CO David Watson file Answer / complaint to Notice of Contest of Lien. Wherefore Plaintiff HomeSavior Consultants Inc. / CO David Watson demands Judgement for money damages against and accrued from Alberta Jackson / William Jackson defendants, together with such other and further relief as the court may deem reasonable and i, under the circumstances. ea Plaintiff signatureApmin es-goal- Ch ~O/F@} SKK CASE LB OS - 20217 CA ~ OR | TB —K~VWLK~ XK Under penalty of perjury, | certify that a copy of the foregoing was provided by regular mail to the Defendant Alberta Jackson and William Jackson acting Power of Attorney at 3500 N Riverside Dr. Indiatlantic, FL 32903 Certificate of Service Attached docs. Answer to contest of lien/complaint filed on March 23,2021 All Exhibits: A, A-1, B,C,D-1,D,E-1,E ALL DOCS FILED WITH COURT March 24,2021 and on April 5,2021 Moy, State of Florida Brevard County, ne Maw d Welin Abc Meener Coos Meh duc Lene Sf Before m personally appeared Homesavior Consultants Inc CO David Watson, who being duly sworn and Identified in accordance with | pig execute the foregoing in my presence this [ day of i ,2021 naros he YOQop per Notary Public / PELE 7) DE Vere s My commission expires: phaf a Fr 2222 voy, a My en Eben, 4 eset! %, oF SF Zs, Oy hn Sondes She SS 4 so nhieteate es gy rege blen MypBLIC, TES WWW Case # 05-2021-CA-021713-XXXX-XX Docu tiie | 661* *33422\ wa f Co WO o ka : 1 Lorine [oe Oo! y* United Services Automobile Association, {e . Sea Pm nee ing le . -| rn aa spy . : Ex vel Adee a CASE HHos-209[- CA ~O2ZITIG ~K- a a op we . J o OS- ZOL-C, ALBERTA M JACKSON 3500 N RIVERSIDE DR INDIALANTIC FL 32903-4422 as &. s “4 ts Review Your Claim September 4, 2020 Dear Mrs, Jackson, We've issued a check in the amount of $24,217.54 for the following claim: Claim number: 005245214-006 Date of toss: March 26, 2019 Loss location: Indialantic, Florida Here's how we determined your payment: Replacement cost $147,839.07 Less recoverable depreciation $-63,486.07 Less non-recoverable depreciation $-6,159.73 Less Amount Above Limits $-51,975.73 Less deductible $-2,000.00 Actual cash value settlement $24,217.54 What Is Recoverable Depreciation? The Loss Settlement Provision of your policy provides payment for the reasonable and necessary cost to repair or replace property involved in a covered loss, Because this policy benefit depends upon actual restoration of the property, your initial payment may consist of the actual cash value only, such as the amount after deduction for depreciation. Recoverable depreciation refers to the potential reimbursement amount upon completion of repair or replacement. After repair or replacement is complete, we calculate your recoverable depreciation as the lesser of the amount necessary to repair or replace the damaged property or the amount you actually spent, minus your deductible and any amount already paid for the damaged property. What Documentation Is Required to Claim Recoverabie Depreciation? Please send us copies of the repair contract, invoice, repair bill and any receipts. These documents should provide: © Anitemized list of the work done and description of any items replaced. © Documentation of all costs. o The completion date for work done and replacement date of any items replaced. 005245214 - 006 - 1243 - 06 54582-0820 Page 1 of 2United Services Automobile Association. : pe DEK” \ 7 -) “L a ) £,! raph, PE . me > — : cox Ose Zf as~- LOR /- CA = OR N73 HK CLT oe ALBERTA M JACKSON CK = YO 3500 N RIVERSIDE DR KKK KX INDIALANTIC FL 32903-4422 Review Information About Your Claim December 15, 2020 Dear Mrs. Jackson, ’'m writing regarding the claim referenced below. USAA policyholder: Alberta M Jackson Claim number: Date of loss: Loss location: 005245214-006 March 26, 2019 Indialantic, Florida Attached you will find the revised estimate for storm damage repairs. The total for the roofing, siding and the deck railing is $144,906,94. | have sent a o(eeaaateal the release of the recoverable depreciation via check, being mailed to your home in the amount 0 $84,091.80) y, op femmect Praff CL coke The remaining recoverable denréciation on the claim is $7; 932, 78 for the replacement of the window screens, security storm shutter (roll up) and the interior work to the entry/foyer and dining room. if you have any questions, please let me know. You may submit correspondence or questions to me using one of the following options: usaa.com or our mobile app: Upload documents or post a secure message to your claim file through the Claim Communication Center. &| © Address: USAA Claims Department P.O. Box 33490 San Antonio, TX 78265 Fax: 1-800-531-8669 Phone: 1-800-531-8722 x Ns 005245214 - 006 - 1243 - 06 54577-1020 Page 1 of 2Homesavior Consultants Inc / CO David Watson, pro se 408 Plantation Dr. Titusville, FL 32780 PH 321-298-7754 homesavior777@gmail.com nnn oy RAM. Oey APs ont AG Ncssslon gy Rp % ML 2. , Oe 4 amare CERTIFICATE OF SERVICE $ ; furnished by US Mail and or Personal Service to the Lienee, Alberta Jackson; William Jackson ZlhooDL Wnt c VE [oe 2/ py, WA mua 0 \De dees Notary Public Jerwrorn. Wo Beare. “lwloos!