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Filing # 114133719 E-Filed 09/29/2020 03:15:41 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
FRANCES BARONE & GABRIEL BARONE,
Plaintiffs,
VS. CASE NO. 2017 CA 003882-0
ASHFORD TRS WQ LLC, a foreign limited
liability company d/b/a WORLD QUEST
RESORT a/k/a WORLDQUEST ORLANDO
RESORT, ASHFORD WQ LICENSEE, LLC,
a foreign limited liability company,
ASHFORD TRS CORPORATION, a foreign
profit corporation, WQ HOTEL
MANAGEMENT LLC, a foreign limited
liability company, WORLDQUEST RESORT CONDOMINIUM
ASSOCIATION, INC., a Florida not for profit
corporation
Defendants,
STIPULATION FOR LEAVE FOR PLAINTIFFS TO FILE THIRD AMENDED
COMPLAINT
The undersigned counsel hereby stipulate and agree that Plaintiffs FRANCES BARONE
and GABRIEL BARONE, should be granted leave to file their Third Amended Complaint
attached hereto as Exhibit A.
SMOAK, CHISTOLINI & BARNETT, PLLC ICARD, MERRILL, CULLIS, TIMM
320 W. Kennedy Blvd., 4"" Floor FUREN & GINSBURG, P.A.
Tampa, FL 33606 2033 Main Street, Suite 600
Sarasota, FL 34237
/s/ Chance C. Arias_/Date: 9/29/20 /s/ Anthony J. Manganiello /Date: 9/29/20
William G.K. Smoak, Esq. Anthony J. Manganiello, III, Esq.
Florida Bar No. 645028 Florida Bar No. 0052307
Chance C. Arias, Esq. Attorneys for Plaintiffs
FL Bar# 92682 amanganiello@icardmerrill.com
Attorneys for Defendants
billsmoak@flatrialcounsel.com
arias@flatrialcounsel.com
01216926-1
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
FRANCES BARONE & GABRIEL BARONE,
Plaintiffs,
VS. CASE NO. 2017 CA 003882-0
ASHFORD TRS WQ LLC, a foreign limited
liability company d/b/a WORLD QUEST
RESORT a/k/a WORLDQUEST ORLANDO
RESORT, ASHFORD WQ LICENSEE, LLC,
a foreign limited liability company,
ASHFORD TRS CORPORATION, a foreign
profit corporation, WQ HOTEL
MANAGEMENT LLC, a foreign limited
liability company, WORLDQUEST RESORT CONDOMINIUM
ASSOCIATION, INC., a Florida not for profit
corporation
Defendants,
/
THIRD AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
COMES NOW, the Plaintiffs, FRANCES BARONE and GABRIEL BARONE, by and
through their undersigned attorneys, and Amends their complaint to sue the Defendants,
ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT
a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE, LLC, a foreign limited liability
company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL
MANAGEMENT LLC, a foreign limited liability company, and WORLDQUEST RESORT
CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation all of which are
licensed to and conducting business in the State of Florida (hereinafter collectively “Defendants”
or "World Quest"), and states as follows:
(EXHIBIT “A”)
01216664-1
GENERAL ALLEGATIONS
1 This is an action for damages in excess of fifteen thousand dollars ($15,000.00),
exclusive of costs and interest.
2 At all times material herein, Plaintiff, FRANCES BARONE, was a resident of
New Port Richey, Florida and was married to GABRIEL BARONE.
3 At all times material herein, Plaintiff, GABRIEL BARONE, was a resident of
New Port Richey, Florida and was married to FRANCES BARONE.
4 At all times material herein, the World Quest Defendants, upon information and
belief, were active entities registered and licensed to do business in the State of Florida, and were
doing business as WORLDQUEST RESORT a/k/a WorldQuest Orlando Resort having a
business address of 8849 WorldQuest Blvd., Orlando, Florida 32821.
5 Venue is appropriate before the Ninth Judicial Circuit, as the cause of action
occurred in Orlando, Florida.
6 All conditions precedent to the bringing of this action have occurred or been met.
COUNT I- NEGLIGENCE OF WORLD QUEST DEFENDANTS
7 Plaintiffs reallege and adopt the general allegations numbered 1 through 6 of the
General Allegations, as if fully set forth herein.
8 Upon information and belief the World Quest Defendants, do now, and at all
times material herein, did own and/or operate and maintain a resort hotel facility in Orange
County, Florida, known as, "WorldQuest Orlando Resort," located at 8849 WorldQuest Blvd.,
Orlando, Florida 32821.
9 On or about October 2, 2016, Plaintiff, FRANCES BARONE, was lawfully on the
premises as a registered guest/business invitee of the World Quest Defendants.
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10. Because of her business invitee status, the Defendants owed the following duties
to Plaintiff, FRANCES BARONE:
A To use ordinary care in keeping the premises in a reasonably safe
condition for its guests/business invitees generally and specifically control
the ongoing construction and ensure debris and foreign substances do not
collect in known areas of ingress and egress; and
To war of latent or impending perils that are known, or should be known
to the owner or its employees, of which the guests/business invitee is
unaware and which the business invitee cannot discover through the
exercise of reasonable care.
To provide a reasonably safe premises including reasonable protection
against injury to guests/business invitees, by its employees, agents and/or
other invitees.
D. To protect guests/business invitees from foreseeable physical injuries.
11 Defendants were negligent and breached the above obligations by, among other
things:
Failing to maintain their accommodations in a safe manner, free from
injury, harm or the threat of harm, and/or to take reasonable measures at
the premises to protect invitees during their stay at its facility;
Failing to warn guests/invitees of prior incidents arising from said
conditions, upon its grounds, and in the surrounding areas, including the
common business areas for general ingress/egress of guests/invitees;
Failing to implement procedures and safeguards to protect guests/invitees
from physical injury; and
Failing to maintain the common business areas for general ingress/egress
of guests/invitees in a safe condition, which would provide protection for
its guests/business invitees, and to keep hotel guests from slipping,
01216664-1
tripping and/or otherwise falling and injuring themselves while entering or
exiting the hotel, and/or causing other physical injuries presented by the
presence of slick and/or slippery materials and/or other construction-
related debris directly in the path of guests entering and exiting the hotel.
12. The incident and resulting injuries to the Plaintiff, FRANCES BARONE, were
reasonably foreseeable by World Quest Defendants, as a result of the following:
A Defendants’ knowledge or constructive knowledge of the conditions
present at the common, general ingress/egress entryway of the hotel, and
the presence of slick and/or slippery materials and/or other construction-
related debris and dangerous to any person walking over said areas of
ingress/egress, existed in said condition, prior to the arrival of the Plaintiff,
FRANCES BARONE.
Defendants’ actual or constructive knowledge that of the common, general
ingress/egress entryway of the hotel, because of its slick and/or slippery
condition and/or the presence of other construction-related debris, posed a
clear and dangerous risk to any and all invitees;
Defendants’ failure to follow industry standards for such establishments,
to require adequate protection for its guests/invitees; and
Defendants’ allowing and/or participating in known, open and notorious
dangerous conditions.
13, As a direct and proximate result of the careless and negligent conduct of the
Defendants, the Plaintiff, FRANCES BARONE, was injured in and about her body and
extremities and has sustained the following damages;
A. Significant and permanent loss of an important bodily function;
B Permanent injury within a reasonable degree of medical probability other
than scarring and disfigurement;
Bodily injury;
01216664-1
Pain and suffering;
Disability;
Scarring and disfigurement;
Mental anguish;
H. Loss of capacity for the enjoyment of life; and
I Medical and related expenses in seeking a cure for her injuries.
14, As a direct and proximate result of the carelessness and negligence of Defendants,
the Plaintiff, FRANCES BARONE, did slip and fall as she approached her vehicle in the
designated parking area when coming into contact with an unreasonably dangerous substance
Defendants had allowed to remain on the ground and as a result sustained serious and permanent
bodily injuries and has otherwise been rendered permanently disabled.
15. As a direct and proximate result of the careless and negligent conduct of the
Defendants, Plaintiff, FRANCES BARONE, was compelled to employ physicians, surgeons and
other health care professionals to otherwise treat the Plaintiff, FRANCES BARONE, for the
injuries sustained. Plaintiff is informed and believes, and based upon that information and belief
alleges, that it will further be necessary for Plaintiff to incur additional medical expenses in a
sum or sums now unknown to Plaintiff.
WHEREFORE, Plaintiff, FRANCES BARONE, demands a trial by jury and a judgment
against the Defendants, ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a
WORLD QUEST RESORT a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE,
LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit
corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, and
WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit
corporation jointly and severally, in an amount within the jurisdictional limits of this Court, to
wit: more than Fifteen Thousand Dollars ($15,000.00), and for such other relief to which the
Plaintiffs may be justly entitled.
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COUNT Il - LOSS OF CONSORTIUM AS TO GABRIEL BARONE
16. The Plaintiffs re-allege and incorporate by reference hereto the allegations
contained in paragraphs | through 15 of the Allegations, as if fully set forth herein.
17. Plaintiff, GABRIEL BARONE, has suffered the loss of his wife’s care, comfort,
society, attention and consortium.
18. Plaintiff, GABRIEL BARONE, has been required to take over and will in the
future have to take over many of the duties/services of his wife due to her injuries and
discomfort, as alleged above.
19, At the time of the slip/trip and fall incident, Plaintiffs FRANCES BARONE and
GABRIEL BARONE, were legally married.
WHEREFORE, Plaintiff, GABRIEL BARONE, demands judgment for damages against
the Defendants, ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD
QUEST RESORT a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE, LLC, a
foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit
corporation and WQ HOTEL MANAGEMENT LLC, a foreign limited liability company and
WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit
corporation, jointly and severally, for loss of consortium damages in an amount in excess of the
minimum jurisdictional limits of this Court, to-wit: $15,000.00, exclusive of interest and costs
demands judgment therefore, and demands trial by jury of all issues so triable as a right by a
jury.
DEMAND FOR JURY TRIAL
Plaintiffs, FRANCES BARONE and GABRIEL BARONE, hereby demand trial by jury
concerning all issues in the above-styled cause of action.
01216664-1
DESIGNATION OF EMAIL ADDRESSES FOR SERVICE OF DOCUMENTS
Pursuant to Florida Rule of Judicial Administration 2.516(b)(1)(A), the undersigned counsel
gives notice of the following primary, secondary and tertiary e-mail addresses for service of pleadings in
this matter:
Primary Email Address: amanganicllo@icardmerrill.com
Secondary Email Address: rgrek@icardmerrill.cor
Tertiary Email Address: awynn@icardmerrill.com
DATED this OY a of September, 2020.
ICARD, MERRILL, CULLIS, TIMM,
FUREN & GINSBURG, P.A.
2033 Main Street, Suite 600
Postal Di ver 4195
Sarasot; lorida 34237
Go Phoned Odi) 366-6384 - Fax
HON . IT, ESQ.
la Bar No, 0052307
110 ys for Plaintiffs
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Filing # 114133719 E-Filed 09/29/2020 03:15:41 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION FRANCES BARONE & GABRIEL BARONE, Plaintiffs, VS. CASE NO. 2017 CA 003882-0 ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WORLDQUEST ORLANDO RESORT, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation Defendants, STIPULATION FOR LEAVE FOR PLAINTIFFS TO FILE THIRD AMENDED COMPLAINT The undersigned counsel hereby stipulate and agree that Plaintiffs FRANCES BARONE and GABRIEL BARONE, should be granted leave to file their Third Amended Complaint attached hereto as Exhibit A. SMOAK, CHISTOLINI & BARNETT, PLLC ICARD, MERRILL, CULLIS, TIMM 320 W. Kennedy Blvd., 4"" Floor FUREN & GINSBURG, P.A. Tampa, FL 33606 2033 Main Street, Suite 600 Sarasota, FL 34237 /s/ Chance C. Arias_/Date: 9/29/20 /s/ Anthony J. Manganiello /Date: 9/29/20 William G.K. Smoak, Esq. Anthony J. Manganiello, III, Esq. Florida Bar No. 645028 Florida Bar No. 0052307 Chance C. Arias, Esq. Attorneys for Plaintiffs FL Bar# 92682 amanganiello@icardmerrill.com Attorneys for Defendants billsmoak@flatrialcounsel.com arias@flatrialcounsel.com 01216926-1 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION FRANCES BARONE & GABRIEL BARONE, Plaintiffs, VS. CASE NO. 2017 CA 003882-0 ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WORLDQUEST ORLANDO RESORT, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation Defendants, / THIRD AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, the Plaintiffs, FRANCES BARONE and GABRIEL BARONE, by and through their undersigned attorneys, and Amends their complaint to sue the Defendants, ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, and WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation all of which are licensed to and conducting business in the State of Florida (hereinafter collectively “Defendants” or "World Quest"), and states as follows: (EXHIBIT “A”) 01216664-1 GENERAL ALLEGATIONS 1 This is an action for damages in excess of fifteen thousand dollars ($15,000.00), exclusive of costs and interest. 2 At all times material herein, Plaintiff, FRANCES BARONE, was a resident of New Port Richey, Florida and was married to GABRIEL BARONE. 3 At all times material herein, Plaintiff, GABRIEL BARONE, was a resident of New Port Richey, Florida and was married to FRANCES BARONE. 4 At all times material herein, the World Quest Defendants, upon information and belief, were active entities registered and licensed to do business in the State of Florida, and were doing business as WORLDQUEST RESORT a/k/a WorldQuest Orlando Resort having a business address of 8849 WorldQuest Blvd., Orlando, Florida 32821. 5 Venue is appropriate before the Ninth Judicial Circuit, as the cause of action occurred in Orlando, Florida. 6 All conditions precedent to the bringing of this action have occurred or been met. COUNT I- NEGLIGENCE OF WORLD QUEST DEFENDANTS 7 Plaintiffs reallege and adopt the general allegations numbered 1 through 6 of the General Allegations, as if fully set forth herein. 8 Upon information and belief the World Quest Defendants, do now, and at all times material herein, did own and/or operate and maintain a resort hotel facility in Orange County, Florida, known as, "WorldQuest Orlando Resort," located at 8849 WorldQuest Blvd., Orlando, Florida 32821. 9 On or about October 2, 2016, Plaintiff, FRANCES BARONE, was lawfully on the premises as a registered guest/business invitee of the World Quest Defendants. 01216664-1 Pee Ee cog na, tt a Pa) veah is a n Hed a4, a "i a es Shay a5 3. oo oe i | us ae 7 tig “0 a ie Py wh of af #sh hes: i a Pr, ose 6 fs 5 te ants ee re a he “a - oe oh a wae iy al : at eon be ad 6 Lk qv ad whe Ee a 53 ste i. oe oT stig Ey be ne a i Fe sae oe a* ot aS Rae a ‘ 3Hue fee # 7 es Ph fe ghee! os a An 4 wy ae i ie # et eefF ee £0gh a a: wi 2 bi a Bh ot Pe 8 a se we Me at a a0» at wll su ae abeSBT ote at1g i fae toate - a s ebay iE = uo | ee a e a 10. Because of her business invitee status, the Defendants owed the following duties to Plaintiff, FRANCES BARONE: A To use ordinary care in keeping the premises in a reasonably safe condition for its guests/business invitees generally and specifically control the ongoing construction and ensure debris and foreign substances do not collect in known areas of ingress and egress; and To war of latent or impending perils that are known, or should be known to the owner or its employees, of which the guests/business invitee is unaware and which the business invitee cannot discover through the exercise of reasonable care. To provide a reasonably safe premises including reasonable protection against injury to guests/business invitees, by its employees, agents and/or other invitees. D. To protect guests/business invitees from foreseeable physical injuries. 11 Defendants were negligent and breached the above obligations by, among other things: Failing to maintain their accommodations in a safe manner, free from injury, harm or the threat of harm, and/or to take reasonable measures at the premises to protect invitees during their stay at its facility; Failing to warn guests/invitees of prior incidents arising from said conditions, upon its grounds, and in the surrounding areas, including the common business areas for general ingress/egress of guests/invitees; Failing to implement procedures and safeguards to protect guests/invitees from physical injury; and Failing to maintain the common business areas for general ingress/egress of guests/invitees in a safe condition, which would provide protection for its guests/business invitees, and to keep hotel guests from slipping, 01216664-1 tripping and/or otherwise falling and injuring themselves while entering or exiting the hotel, and/or causing other physical injuries presented by the presence of slick and/or slippery materials and/or other construction- related debris directly in the path of guests entering and exiting the hotel. 12. The incident and resulting injuries to the Plaintiff, FRANCES BARONE, were reasonably foreseeable by World Quest Defendants, as a result of the following: A Defendants’ knowledge or constructive knowledge of the conditions present at the common, general ingress/egress entryway of the hotel, and the presence of slick and/or slippery materials and/or other construction- related debris and dangerous to any person walking over said areas of ingress/egress, existed in said condition, prior to the arrival of the Plaintiff, FRANCES BARONE. Defendants’ actual or constructive knowledge that of the common, general ingress/egress entryway of the hotel, because of its slick and/or slippery condition and/or the presence of other construction-related debris, posed a clear and dangerous risk to any and all invitees; Defendants’ failure to follow industry standards for such establishments, to require adequate protection for its guests/invitees; and Defendants’ allowing and/or participating in known, open and notorious dangerous conditions. 13, As a direct and proximate result of the careless and negligent conduct of the Defendants, the Plaintiff, FRANCES BARONE, was injured in and about her body and extremities and has sustained the following damages; A. Significant and permanent loss of an important bodily function; B Permanent injury within a reasonable degree of medical probability other than scarring and disfigurement; Bodily injury; 01216664-1 Pain and suffering; Disability; Scarring and disfigurement; Mental anguish; H. Loss of capacity for the enjoyment of life; and I Medical and related expenses in seeking a cure for her injuries. 14, As a direct and proximate result of the carelessness and negligence of Defendants, the Plaintiff, FRANCES BARONE, did slip and fall as she approached her vehicle in the designated parking area when coming into contact with an unreasonably dangerous substance Defendants had allowed to remain on the ground and as a result sustained serious and permanent bodily injuries and has otherwise been rendered permanently disabled. 15. As a direct and proximate result of the careless and negligent conduct of the Defendants, Plaintiff, FRANCES BARONE, was compelled to employ physicians, surgeons and other health care professionals to otherwise treat the Plaintiff, FRANCES BARONE, for the injuries sustained. Plaintiff is informed and believes, and based upon that information and belief alleges, that it will further be necessary for Plaintiff to incur additional medical expenses in a sum or sums now unknown to Plaintiff. WHEREFORE, Plaintiff, FRANCES BARONE, demands a trial by jury and a judgment against the Defendants, ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, and WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation jointly and severally, in an amount within the jurisdictional limits of this Court, to wit: more than Fifteen Thousand Dollars ($15,000.00), and for such other relief to which the Plaintiffs may be justly entitled. 01216664-1 oo uw s bh @ # Ee a ef eeth itt ie 3 iy oo & fh sean rh ad the!Le ae ie Bae a al pe : ta oe ay w a w iy ie eis ey fi oe oe " wt pe ee oe ihe at te ua ay 8 +s 7 tye, ie a yey a . - 7 yn - he # ie iy we Se ie i Lae Se a 7 os 1 aE 2 te be eh ei ts H ee 72h a Se a an, a ota esH 28 ey 7 we Y rp ies & 1b a es 44 w ri 7Hh Ae a aai tn if . Hat 2 eu ub *t wh te es s ee # ee ie bet I vs is i i ei ee ie & ey i y a fe ha HW bee si a i tee 4 = we ual he g ce As a W tste ey eb s ee fe +i oh # COUNT Il - LOSS OF CONSORTIUM AS TO GABRIEL BARONE 16. The Plaintiffs re-allege and incorporate by reference hereto the allegations contained in paragraphs | through 15 of the Allegations, as if fully set forth herein. 17. Plaintiff, GABRIEL BARONE, has suffered the loss of his wife’s care, comfort, society, attention and consortium. 18. Plaintiff, GABRIEL BARONE, has been required to take over and will in the future have to take over many of the duties/services of his wife due to her injuries and discomfort, as alleged above. 19, At the time of the slip/trip and fall incident, Plaintiffs FRANCES BARONE and GABRIEL BARONE, were legally married. WHEREFORE, Plaintiff, GABRIEL BARONE, demands judgment for damages against the Defendants, ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WorldQuest Orlando Resort, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation and WQ HOTEL MANAGEMENT LLC, a foreign limited liability company and WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation, jointly and severally, for loss of consortium damages in an amount in excess of the minimum jurisdictional limits of this Court, to-wit: $15,000.00, exclusive of interest and costs demands judgment therefore, and demands trial by jury of all issues so triable as a right by a jury. DEMAND FOR JURY TRIAL Plaintiffs, FRANCES BARONE and GABRIEL BARONE, hereby demand trial by jury concerning all issues in the above-styled cause of action. 01216664-1 DESIGNATION OF EMAIL ADDRESSES FOR SERVICE OF DOCUMENTS Pursuant to Florida Rule of Judicial Administration 2.516(b)(1)(A), the undersigned counsel gives notice of the following primary, secondary and tertiary e-mail addresses for service of pleadings in this matter: Primary Email Address: amanganicllo@icardmerrill.com Secondary Email Address: rgrek@icardmerrill.cor Tertiary Email Address: awynn@icardmerrill.com DATED this OY a of September, 2020. ICARD, MERRILL, CULLIS, TIMM, FUREN & GINSBURG, P.A. 2033 Main Street, Suite 600 Postal Di ver 4195 Sarasot; lorida 34237 Go Phoned Odi) 366-6384 - Fax HON . IT, ESQ. la Bar No, 0052307 110 ys for Plaintiffs 01216664-1 oe i eS ar ui oe 4 a * es ra es i ee J # sy Pay a, ss ud“i ws i i a ge he ey it fl BEN ial . ope “ et a et iy ea