Preview
Filing # 111882733 E-Filed 08/17/2020 09:31:21 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
DIANA K. WINKLER and ) Case No.: 48-2018-CA-006581
MICHAEL J. WINKLER, )
Plaintiffs, )
v. )
)
CHRISTOPHER P. HANCOCK, et.al. )
Defendants, )
)
PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE
Pursuant to Sections 90.202(12) and 90.203, Florida Statutes,
Plaintiffs, by and through their undersigned counsel, hereby
request this Court to take judicial notice of the two items noted
below for use at the August 25, 2020 hearing on Defendant Michael
E. Morris’ Motion to Dismiss for Failure to State a Cause of Action
and Verified Motion to Strike Second Amended Complaint as Sham
Pleading (“Motion to Strike”), and any other allowable purposes,
as stated in Plaintiffs’ response in opposition to Defendant
Morris’ Motion to Strike.
The request is made as to certain facts: (1) of the assertion
in an Application for Registration of Fictitious Name of “The
Hancock Law Firm” registered with the Department of State in the
State of Florida on June 24, 2016, a certified copy of which is
attached hereto as Exhibit “A,” setting forth therein that the
owners of the name “The Hancock Law Firm” are two of the defendants
in this case, one of whom is Defendant Michael E. Morris; and (2)
that the other defendant identified as owner of “The Hancock Law
Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581
Plaintiffs’ Request for Judicial Notice; Page 2 of 5
Firm” is Defendant Hancock & Associates, P.A. (f/k/a Christopher
P. Hancock Law Firm, PA), with respect to whom there are admissions
by Mr. Hancock in an Answer and Affirmative Defenses filed in this
case that it received a transfer of assets from the Defendant
Hancock Law Group, P.A. law firm (f/k/a Morris & Hancock, P.A.).
This request is made not as to the truth of the assertions, but
rather, as to the fact that the assertions have been raised, which
give rise to genuine issues of material fact in this case, by which
it is proper to summarily dismiss Defendant Morris’ Motion to
Strike.
LEGAL STANDARD
Pursuant to § 90.202(12), Florida Statutes, a Court may take
judicial notice of facts that are not subject to dispute because
they are capable of accurate and ready determination by resort to
sources whose accuracy cannot be questioned. Furthermore,
pursuant to § 90.203, Florida Statutes, a Court shall take judicial
notice of any matter in § 90.202 when a party requests it and (1)
gives each adversary party timely written notice of their request,
proof of which is filed with the Court, to enable the adverse party
to prepare and meet their request; and (2) furnishes the Court
with sufficient information to enable the Court to take judicial
notice of the matter. With this filing, this criteria have been
met.
Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581
Plaintiffs’ Request for Judicial Notice; Page 3 of 5
DISCUSSION
Prior to filing Defendant Morris’ Motion to Strike, Defendant
Morris’ knew of a request being made by Plaintiffs for this Court
to take judicial notice of Defendant Morris’ 2016 ownership of a
certain fictitious name, The Hancock Law Firm. This occurred in
October of 2019 in anticipation of this Court’s consideration of
a prior motion to dismiss filed by various defendants, inclusive
of Defendant Morris, when Defendant Morris: (1) represented the
Defendant Hancock Law Group, P.A. (f/k/a Law Office of Michael E.
Morris, P.A.; f/k/a Morris & Hancock, P.A.) in these proceedings;
(2) individually and on behalf of Defendant Hancock Law Group,
P.A. sought to dismiss Plaintiffs’ First Amended Complaint, and in
opposition thereto, Plaintiffs made such request. It is repeated
again in the recently filed opposition. In this way, Defendant
Morris has timely notice of this request.
To the extent that this Court were to consider Defendant
Morris’ Motion to Strike Plaintiffs’ Second Amended Complaint as
a Sham Pleading, and take in evidence with respect to the same,
Plaintiffs respectfully ask that judicial notice be taken as to
identification herein of Defendant Morris’ as having joint
ownership of the fictitious name “The Hancock Law Firm” along with
Defendant Hancock & Associates, P.A. (“H & A” Law Firm)(f/k/a
Christopher P. Hancock Law Firm, PA). Plaintiffs also request that
if evidence is taken in with respect to the Defendant Morris’
Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581
Plaintiffs’ Request for Judicial Notice; Page 4 of 5
Motion to Strike that this Court also take judicial notice of the
fact that Defendant Hancock has filed an Answer and Affirmative
Defenses (“Defendant Hancock’s Answer”), in response to the
Plaintiffs’ Second Amended Complaint (a copy of Defendant
Hancock’s Answer is attached as Exhibit “B”), and that set forth
therein, Defendant Hancock has admitted to the following
allegations set forth in Paragraph 19 of Plaintiffs’ Second Amended
Complaint:
“19. Defendant H&A is a dissolved Florida
professional association, and on information and belief,
received assets otherwise belonging to the dissolved
M&H, by and through transfers made by HANCOCK without
regard to the claims arising against M&H from HANCOCK’s
actions prior to dissolution.”
As stated, request is not made as to the truth of these
statements; rather, that these assertions and admissions exist
in the pleadings or otherwise in this case.
Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581
Plaintiffs’ Request for Judicial Notice; Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing
Request for Judicial Notice was served on August 17, 2020, by e-
mail, to all attorneys of record, at their designated e-mail
addresses, inclusive of:
Christopher P. Hancock, cphancock82@gmail.com
Luxus Legal, LLC luxuslegal@gmail.com
Jeffrey Landau, Esq., jlandau@shutts.com
Sean McDonough, Esq., sean.mcdonough@wilsonelser.com
A. Donald Scott, Jr., Esq., A.DonaldScottJr@wilsonelser.com
Andrea McCreary, Esq., amccreary@wgworl.com
John Zielinski, Esq., john@nejamelaw.com
CPLS, P.A.
Attorneys|Consultants|Mediators
201 E. Pine Street, Suite 445
Orlando, Florida 32801
407-647-7887/407-647-5396 (Fax)
Attorney for Plaintiffs
CPLS File No.: 3838-1
Dated: August 17, 2020 /s/ T. Scott Tufts______________
T. Scott Tufts, Esq.
Florida Bar No. 0168841
stufts@cplspa.com
EXHIBIT A
EXHIBIT B
Filing # 103177612 E-Filed 02/12/2020 11:02:09 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR SEMINOLE COUNTY, FLORIDA
DIANA K. WINKLER and
MICHAEL J. WINKLER, INDIVIDUALLY,
And ON BEHALF OF THEMSELVES AND
ALL OTHER SIMILIARILY SITUATED AS
TO CLASS COUNTS AGAINST
HYATT LEGAL PLANS OF FLORIDA, INC.
Plaintiffs, CASE NO.: 2017-CA-002441
vs.
CHRISTOPHER P. HANCOCK, et. al.,
Defendants.
/
DEFENDANT, CHRISTOPHER P. HANCOCK’S ANSWER AND
AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, CHRISTOPHER P. HANCOCK (hereinafter “Defendant” or “Hancock”)
individually as pro se, hereby files his Answer and Affirmative Defenses to the Second Amended
Complaint filed by DIANA K. WINKLER and MICHEAL J. WINKLER, (“Plaintiffs” or
“Winklers”) and responds to the allegations as follows:
ANSWER
1. As for the allegations referenced in paragraph 2 and 19 is Admitted.
2. As for the allegations referenced in paragraphs 1, 3 through 15, 17 through 38, 40
through 87, 89, 93, 103, 104, 106 through 108, 110 through 143, 153 through 160, 186 through
250, 263 through 272, 285 through 349, 369 through 399 are Denied without knowledge
3. As for the allegations referenced in paragraphs 16, 88, 90 through 92, 94
1
through 102, 105, 109, 138, 139, 144 through 152, 160 through 185, 251 through 262, 273
through 284, 350 through 368 are Denied.
WHEREFORE, Defendant, CHRISTOPHER P. HANCOCK, denies that Plaintiff is
entitled to the relief sought in Count IV, Count VI and Count XII and Count V of the Second
Amended Complaint, and requests that a judgment be entered in favor of Defendant, and that this
Court award reasonable attorney’s fees and costs, and for such other relief this Court deems just
and proper.
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DEFENDANT, CHRISTOPHER HANCOCK’S AFFIRMATIVE DEFENSES
First Affirmative Defense as to Count IV and Count IV
(Statute of Limitations)
The statute of limitations governing legal malpractice actions is section 95.11(4)(a), Florida Statutes,
(2019). See Peat, Marwick, Mitchell Co. v. Lane, 565 So.2d 1323, 1325 (Fla. 1990). Section 95.11(4)(a),
provides in pertinent part:
(4) WITHIN TWO YEARS. —
(a) An action for professional malpractice, other than medical malpractice, whether
founded on contract or tort; provided that the period of limitations shall run from the time
the cause of action is discovered or should have been discovered with the exercise of due
diligence.
For purposes of determining when the limitations period begins to run, section 95.031(1), Florida
Statutes (2019) provides that "[a] cause of action accrues when the last element constituting the cause of action
occurs." A legal malpractice action has three elements: 1) the attorney's employment; 2) the attorney's neglect of
a reasonable duty; and 3) the attorney's negligence as the proximate cause of loss to the client. Law Office of
David J. Stern, P. A v. Sec. Nat'l. Servicing Corp., 969 So.2d 962, 966 (Fla. 2007) (citing Kates v. Robinson, 786
So.2d 61, 64 (Fla. 4th DCA 2001)). The Florida Supreme Court recognized that "[generally, a cause of action
for negligence does not accrue until the existence of a redressable harm or injury has been established and the
injured party knows or should know of either the injury or the negligent act." Peat, Marwick, 565 So.2d at
1325; Glucksman v. Persol N. Am., Inc., 813 So.2d 122, 125 (Fla. 4th DCA 2002).
Further, paragraph 259 of Plaintiff’s Second Amended Complaint states, “…the foregoing negligence
resulted in, and was the proximate cause of, significant additional damages suffered by the WINKLERS, the
stress of years of unnecessary litigation over their home, as had a direct physical impact of the physical and
mental health of the WINKLERS.” The purported “unnecessary litigation” referred to, concluded June 9, 2016.
Plaintiffs filed this cause of action on June 11, 2018, more than two years after Plaintiff’s knew of should have
3
known of either their injury or the negligent act. As a result, Plaintiff is barred from pursuing a malpractice
claim.
Second Affirmative Defense as to Count XII
(Failure to State a Cause of Action)
Count XII of Plaintiffs’ Second Amended Complaint is for “Liability under F.S. § 607.1407(4)
PERSONAL LIABILITY FOR SHAREHOLDERS OF A DISSOLVED PROFESSIONAL
ASSOCIATION.” Paragraph 351 of Plaintiffs’ Second Amended Complaint states, “Hancock further
abandoned his practice, as constituted at M&H, when he looked in December, 2016 to dissolve the
professional association, without complying with
F.S. § 607.1407(4), thereby setting forth additional wrongful acts.”
Plaintiffs appear to allege a cause of action pursuant to section 607.1407(4) Florida Statutes,
however, section 607.1407(4) Florida Statutes, does not exist.
Third Affirmative Defense
(No Damages)
Plaintiff should be barred from bringing these causes of action because although the Plaintiff
alleges that it has sustained damages, Plaintiff does not allege any facts or otherwise as to how
Plaintiff has been or will be damaged.
WHEREFORE, Defendant, CHRISTOPHER HANCOCK, requests that this Court enter
judgment against in favor of Defendant, dismiss the cause of action with prejudice, award attorney’s
fees and costs, and grant any other relief that this Court deems just and proper.
4
FLORIDA COURTS E-FILING
PORTAL CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
electronically and was delivered by hand delivery to the following parties, this Wednesday,
February 12, 2020.
T. Scott Tufts, Esq.
stufts@cplspa.com
Attorney for Plaintiffs
Respectfully Submitted,
By: /s/ Christopher P. Hancock
CHRISTOPHER HANCOCK
Defendant, Pro Se
Primary Email: cphancock82@gmail.com
5
Preview
Filing # 111882733 E-Filed 08/17/2020 09:31:21 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DIANA K. WINKLER and ) Case No.: 48-2018-CA-006581 MICHAEL J. WINKLER, ) Plaintiffs, ) v. ) ) CHRISTOPHER P. HANCOCK, et.al. ) Defendants, ) ) PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE Pursuant to Sections 90.202(12) and 90.203, Florida Statutes, Plaintiffs, by and through their undersigned counsel, hereby request this Court to take judicial notice of the two items noted below for use at the August 25, 2020 hearing on Defendant Michael E. Morris’ Motion to Dismiss for Failure to State a Cause of Action and Verified Motion to Strike Second Amended Complaint as Sham Pleading (“Motion to Strike”), and any other allowable purposes, as stated in Plaintiffs’ response in opposition to Defendant Morris’ Motion to Strike. The request is made as to certain facts: (1) of the assertion in an Application for Registration of Fictitious Name of “The Hancock Law Firm” registered with the Department of State in the State of Florida on June 24, 2016, a certified copy of which is attached hereto as Exhibit “A,” setting forth therein that the owners of the name “The Hancock Law Firm” are two of the defendants in this case, one of whom is Defendant Michael E. Morris; and (2) that the other defendant identified as owner of “The Hancock Law Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581 Plaintiffs’ Request for Judicial Notice; Page 2 of 5 Firm” is Defendant Hancock & Associates, P.A. (f/k/a Christopher P. Hancock Law Firm, PA), with respect to whom there are admissions by Mr. Hancock in an Answer and Affirmative Defenses filed in this case that it received a transfer of assets from the Defendant Hancock Law Group, P.A. law firm (f/k/a Morris & Hancock, P.A.). This request is made not as to the truth of the assertions, but rather, as to the fact that the assertions have been raised, which give rise to genuine issues of material fact in this case, by which it is proper to summarily dismiss Defendant Morris’ Motion to Strike. LEGAL STANDARD Pursuant to § 90.202(12), Florida Statutes, a Court may take judicial notice of facts that are not subject to dispute because they are capable of accurate and ready determination by resort to sources whose accuracy cannot be questioned. Furthermore, pursuant to § 90.203, Florida Statutes, a Court shall take judicial notice of any matter in § 90.202 when a party requests it and (1) gives each adversary party timely written notice of their request, proof of which is filed with the Court, to enable the adverse party to prepare and meet their request; and (2) furnishes the Court with sufficient information to enable the Court to take judicial notice of the matter. With this filing, this criteria have been met. Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581 Plaintiffs’ Request for Judicial Notice; Page 3 of 5 DISCUSSION Prior to filing Defendant Morris’ Motion to Strike, Defendant Morris’ knew of a request being made by Plaintiffs for this Court to take judicial notice of Defendant Morris’ 2016 ownership of a certain fictitious name, The Hancock Law Firm. This occurred in October of 2019 in anticipation of this Court’s consideration of a prior motion to dismiss filed by various defendants, inclusive of Defendant Morris, when Defendant Morris: (1) represented the Defendant Hancock Law Group, P.A. (f/k/a Law Office of Michael E. Morris, P.A.; f/k/a Morris & Hancock, P.A.) in these proceedings; (2) individually and on behalf of Defendant Hancock Law Group, P.A. sought to dismiss Plaintiffs’ First Amended Complaint, and in opposition thereto, Plaintiffs made such request. It is repeated again in the recently filed opposition. In this way, Defendant Morris has timely notice of this request. To the extent that this Court were to consider Defendant Morris’ Motion to Strike Plaintiffs’ Second Amended Complaint as a Sham Pleading, and take in evidence with respect to the same, Plaintiffs respectfully ask that judicial notice be taken as to identification herein of Defendant Morris’ as having joint ownership of the fictitious name “The Hancock Law Firm” along with Defendant Hancock & Associates, P.A. (“H & A” Law Firm)(f/k/a Christopher P. Hancock Law Firm, PA). Plaintiffs also request that if evidence is taken in with respect to the Defendant Morris’ Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581 Plaintiffs’ Request for Judicial Notice; Page 4 of 5 Motion to Strike that this Court also take judicial notice of the fact that Defendant Hancock has filed an Answer and Affirmative Defenses (“Defendant Hancock’s Answer”), in response to the Plaintiffs’ Second Amended Complaint (a copy of Defendant Hancock’s Answer is attached as Exhibit “B”), and that set forth therein, Defendant Hancock has admitted to the following allegations set forth in Paragraph 19 of Plaintiffs’ Second Amended Complaint: “19. Defendant H&A is a dissolved Florida professional association, and on information and belief, received assets otherwise belonging to the dissolved M&H, by and through transfers made by HANCOCK without regard to the claims arising against M&H from HANCOCK’s actions prior to dissolution.” As stated, request is not made as to the truth of these statements; rather, that these assertions and admissions exist in the pleadings or otherwise in this case. Winkler, et al., v. Hancock, et al.; Case No.: 2018-CA-006581 Plaintiffs’ Request for Judicial Notice; Page 5 of 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Request for Judicial Notice was served on August 17, 2020, by e- mail, to all attorneys of record, at their designated e-mail addresses, inclusive of: Christopher P. Hancock, cphancock82@gmail.com Luxus Legal, LLC luxuslegal@gmail.com Jeffrey Landau, Esq., jlandau@shutts.com Sean McDonough, Esq., sean.mcdonough@wilsonelser.com A. Donald Scott, Jr., Esq., A.DonaldScottJr@wilsonelser.com Andrea McCreary, Esq., amccreary@wgworl.com John Zielinski, Esq., john@nejamelaw.com CPLS, P.A. Attorneys|Consultants|Mediators 201 E. Pine Street, Suite 445 Orlando, Florida 32801 407-647-7887/407-647-5396 (Fax) Attorney for Plaintiffs CPLS File No.: 3838-1 Dated: August 17, 2020 /s/ T. Scott Tufts______________ T. Scott Tufts, Esq. Florida Bar No. 0168841 stufts@cplspa.com EXHIBIT A EXHIBIT B Filing # 103177612 E-Filed 02/12/2020 11:02:09 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR SEMINOLE COUNTY, FLORIDA DIANA K. WINKLER and MICHAEL J. WINKLER, INDIVIDUALLY, And ON BEHALF OF THEMSELVES AND ALL OTHER SIMILIARILY SITUATED AS TO CLASS COUNTS AGAINST HYATT LEGAL PLANS OF FLORIDA, INC. Plaintiffs, CASE NO.: 2017-CA-002441 vs. CHRISTOPHER P. HANCOCK, et. al., Defendants. / DEFENDANT, CHRISTOPHER P. HANCOCK’S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, CHRISTOPHER P. HANCOCK (hereinafter “Defendant” or “Hancock”) individually as pro se, hereby files his Answer and Affirmative Defenses to the Second Amended Complaint filed by DIANA K. WINKLER and MICHEAL J. WINKLER, (“Plaintiffs” or “Winklers”) and responds to the allegations as follows: ANSWER 1. As for the allegations referenced in paragraph 2 and 19 is Admitted. 2. As for the allegations referenced in paragraphs 1, 3 through 15, 17 through 38, 40 through 87, 89, 93, 103, 104, 106 through 108, 110 through 143, 153 through 160, 186 through 250, 263 through 272, 285 through 349, 369 through 399 are Denied without knowledge 3. As for the allegations referenced in paragraphs 16, 88, 90 through 92, 94 1 through 102, 105, 109, 138, 139, 144 through 152, 160 through 185, 251 through 262, 273 through 284, 350 through 368 are Denied. WHEREFORE, Defendant, CHRISTOPHER P. HANCOCK, denies that Plaintiff is entitled to the relief sought in Count IV, Count VI and Count XII and Count V of the Second Amended Complaint, and requests that a judgment be entered in favor of Defendant, and that this Court award reasonable attorney’s fees and costs, and for such other relief this Court deems just and proper. 2 DEFENDANT, CHRISTOPHER HANCOCK’S AFFIRMATIVE DEFENSES First Affirmative Defense as to Count IV and Count IV (Statute of Limitations) The statute of limitations governing legal malpractice actions is section 95.11(4)(a), Florida Statutes, (2019). See Peat, Marwick, Mitchell Co. v. Lane, 565 So.2d 1323, 1325 (Fla. 1990). Section 95.11(4)(a), provides in pertinent part: (4) WITHIN TWO YEARS. — (a) An action for professional malpractice, other than medical malpractice, whether founded on contract or tort; provided that the period of limitations shall run from the time the cause of action is discovered or should have been discovered with the exercise of due diligence. For purposes of determining when the limitations period begins to run, section 95.031(1), Florida Statutes (2019) provides that "[a] cause of action accrues when the last element constituting the cause of action occurs." A legal malpractice action has three elements: 1) the attorney's employment; 2) the attorney's neglect of a reasonable duty; and 3) the attorney's negligence as the proximate cause of loss to the client. Law Office of David J. Stern, P. A v. Sec. Nat'l. Servicing Corp., 969 So.2d 962, 966 (Fla. 2007) (citing Kates v. Robinson, 786 So.2d 61, 64 (Fla. 4th DCA 2001)). The Florida Supreme Court recognized that "[generally, a cause of action for negligence does not accrue until the existence of a redressable harm or injury has been established and the injured party knows or should know of either the injury or the negligent act." Peat, Marwick, 565 So.2d at 1325; Glucksman v. Persol N. Am., Inc., 813 So.2d 122, 125 (Fla. 4th DCA 2002). Further, paragraph 259 of Plaintiff’s Second Amended Complaint states, “…the foregoing negligence resulted in, and was the proximate cause of, significant additional damages suffered by the WINKLERS, the stress of years of unnecessary litigation over their home, as had a direct physical impact of the physical and mental health of the WINKLERS.” The purported “unnecessary litigation” referred to, concluded June 9, 2016. Plaintiffs filed this cause of action on June 11, 2018, more than two years after Plaintiff’s knew of should have 3 known of either their injury or the negligent act. As a result, Plaintiff is barred from pursuing a malpractice claim. Second Affirmative Defense as to Count XII (Failure to State a Cause of Action) Count XII of Plaintiffs’ Second Amended Complaint is for “Liability under F.S. § 607.1407(4) PERSONAL LIABILITY FOR SHAREHOLDERS OF A DISSOLVED PROFESSIONAL ASSOCIATION.” Paragraph 351 of Plaintiffs’ Second Amended Complaint states, “Hancock further abandoned his practice, as constituted at M&H, when he looked in December, 2016 to dissolve the professional association, without complying with F.S. § 607.1407(4), thereby setting forth additional wrongful acts.” Plaintiffs appear to allege a cause of action pursuant to section 607.1407(4) Florida Statutes, however, section 607.1407(4) Florida Statutes, does not exist. Third Affirmative Defense (No Damages) Plaintiff should be barred from bringing these causes of action because although the Plaintiff alleges that it has sustained damages, Plaintiff does not allege any facts or otherwise as to how Plaintiff has been or will be damaged. WHEREFORE, Defendant, CHRISTOPHER HANCOCK, requests that this Court enter judgment against in favor of Defendant, dismiss the cause of action with prejudice, award attorney’s fees and costs, and grant any other relief that this Court deems just and proper. 4 FLORIDA COURTS E-FILING PORTAL CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically and was delivered by hand delivery to the following parties, this Wednesday, February 12, 2020. T. Scott Tufts, Esq. stufts@cplspa.com Attorney for Plaintiffs Respectfully Submitted, By: /s/ Christopher P. Hancock CHRISTOPHER HANCOCK Defendant, Pro Se Primary Email: cphancock82@gmail.com 5