UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.:________________________

JUAN LEONARDO RAUDEZ,

An Individual,

Plaintiff,

vs.

THE VILLAGE OF BISCAYNE PARK, 

a municipality of the State of Florida,

CHIEF RAIMUNDO ATESIANO, and

OFFICER GUILLERMO RAVELO, 

Individually, and in their official capacity,

Defendants.

_________________________________________

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, JUAN LEONARDO RAUDEZ, (Hereinafter, “RAUDEZ” and/or “Plaintiff”),

by and through the undersigned counsel, hereby sues Defendant, THE VILLAGE OF

BISCAYNE PARK, a municipality of the State of Florida, Defendant, POLICE CHIEF

RAIMUNDO ATESIANO, and Defendant, POLICE OFFICER GUILLERMO RAVELO,

Individually and in their official capacity, and states as follows:

JURISDICTION AND VENUE

1. Jurisdiction of this Court exists by virtue of claims under 42 U.S.C.§ 1983 for

violation of federal constitutional rights pursuant to 28 U.S.C.§ 1331 and § 1334(a)(3). This

Court has original jurisdiction over this action as it presents a “Federal Question”. 

2. Venue is proper in this Honorable Court under 28 U.S.C.§ 1391(b), as the events

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giving rise to the claims asserted herein occurred in Miami-Dade County, Florida.

3. All conditions precedent to the maintenance of this action, including those set

forth in Florida Statute § 768.28, have been performed, have occurred prior to its institution, or

have been waived. 

PARTIES

4. At all times pertinent Plaintiff, JUAN LEONARDO RAUDEZ, was and is a

resident of Miami-Dade County, Florida. 

5. At all times material hereto Defendant, THE VILLAGE OF BISCAYNE PARK,

is a municipal corporation and provides, among other services, a Police Department, (“Village of

Biscayne Park Police Department”), to protect its citizens, resident and the general public. At all

times relevant, THE VILLAGE employed the defendant police officers who are being sued

herein by Plaintiff. 

6. At all times material hereto Defendant, RAIMUNDO ATESIANO, (Hereinafter,

“ATESIANO”) was an employee and the Chief of Police of the Village of Biscayne Park Police

Department. As the Police Chief, ATESIANO established a policy for the Village of Biscayne

Park’s Police Department. Moreover, ATESIANO is/was responsible for the conduct of the

Police Officers serving under his leadership and command, ensuring they obey the laws of the

State of Florida and of the United States of America. Defendant, ATESIANO, is being sued in

his individual capacity. 

7. At all times material hereto, Defendant, GUILLERMO RAVELO, (Hereinafter,

“RAVELO”), was a Police Officer and full-time employee of the Village of Biscayne Park’s

Police Department, acting under color of law. Said officer, (RAVELO), is being sued in his

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individual capacity. 

8. The Defendants violated Plaintiff, JUAN LEONARDO RAUDEZ’s constitutional

rights under the Fourth and Fourteenth Amendments of the United States Constitution.

9. At all times material hereto, and in the all their acts described herein, Defendants

were acting under color of law, and color of their authority as public officials and public

employees. 

GENERAL ALLEGATIONS

10. On or about January 2014, Plaintiff, JUAN LEONARDO RAUDEZ, (Hereinafter,

“RAUDEZ” or “Plaintiff”), was a resident of the City of Miami, Miami-Dade County, Florida. 

11. Defendant, THE VILLAGE OF BISCAYNE PARK, was required to hire and

train law enforcement/police officers who were competent and law-abiding to protect citizens

and not violate federally protected rights of persons they encountered.

12. Defendant, THE VILLAGE OF BISCAYNE PARK failed to hire competent, lawabiding police officers and supervise them to enforce the law without violation of federally

protected rights of citizens. 

13. On January 26, 2014, there was an alleged burglary of a dwelling and the theft of

an Air Conditioning Unit (“A/C Unit”), from a property located at 1155 N.E. 119 Street,

Biscayne Park, Florida and/or 1153 N.E. 119 Street, Village of Biscayne Park, Florida.

14. On January 26, 2014, Police Officer RAVELO, made a routine traffic stop of the

Plaintiff, inside the Village of Biscayne Park’s jurisdiction. During what would normally

otherwise be a routine traffic stop, Defendant, ATESIANO, acting as the Chief of Police for the

VILLAGE OF BISCAYNE PARK, came to the scene where Plaintiff was the subject of said

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routine traffic stop that was initiated by RAVELO. 

15. Chief of Police, ATESIANO, alleged that Plaintiff confessed to the commission

of an act of burglary of a dwelling and to the theft of an A/C Unit from a property located at 1155

N.E. 119 Street, Biscayne Park, Florida.

16. Plaintiff, RAUDEZ, is a Black male of African descent, and had a criminal record

prior to the January 26, 2014, traffic stop and arrest that was effectuated by Defendants,

RAVELO and ATESIANO. Plaintiff, RAUDEZ, fit the racial profile of people to be arrested

pursuant to the Policy in effect by Defendant, ATESIANO, as Chief of Police .

17. Chief of Police ATESIANO alleged that Plaintiff, RAUDEZ, confessed to the

unsolved burglary that occurred at 1155 N.E. 119 Street, in the Village of Biscayne Park. 

18. Defendants, ATESIANO and RAVELO, did not audiotape, videotape, or

otherwise record or memorialize RAUDEZ’s alleged confession to the burglary of 1155 NE 119

Street, for which RAUDEZ was arrested. 

19. Defendants, ATESIANO and RAVELO, signed affidavit(s) under oath that

RAUDEZ did in fact confess to the burglary. RAUDEZ, facing years in jail/prison for a crime

that he did not commit if he were to be convicted of the charge by a jury, resulted in RAUDEZ’s

agreeing to plead nolo contendere and thereafter, was sentenced and served nearly twenty-four

(24) months of imprisonment, some of which time was spent in “The Box”, a term used within

the prison to refer to the policy where an inmate would serve part of his sentence in “solitary

confinement”), to be followed by one year of probation. In addition, court costs were imposed on

the Plaintiff. 

20. Defendant, RAVELO, signed an affidavit for the arrest of the Plaintiff for the

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alleged crime of burglary and of theft of an A/C Unit without “Probable Cause”. Plaintiff was

charged by the State of Florida/Office of the Miami-Dade County State Attorney, under Case

Number F14-002202. However, the Court dismissed Count I, “Burglary of the Dwelling”,

because of insufficient information. 

21. Plaintiff was involved a traffic stop for driving without a valid Florida Tag that

ordinarily would simply result in the imposition of a monetary fine, but because of the criminal

conviction in Case Number F14-002202, RAUDEZ ’s probation officer filed a motion alleging

that Plaintiff had violated the terms and conditions of his probation. As a result of that violation,

the Court terminated Plaintiff’s probation and caused Plaintiff to be incarcerated for about a

period of twenty four (24) months. 

22. Plaintiff, RAUDEZ, served the prison term for a crime he did not commit, and for

which there was no “Probable Cause” to arrest him. RAUDEZ was released from prison on

April 2018. 

23. As a result of the Policy of Defendant, THE VILLAGE BISCAYNE PARK’s

Police Department, Plaintiff, RAUDEZ, spent almost two years in prison and lost almost two

years of his life wrongfully incarcerated for a crime he did not commit.

24. Plaintiff, RAUDEZ, lost two years of time to spend with his child while he

(Plaintiff) was incarcerated for a crime that he did not commit. 

25. While in prison for a crime he did not commit, Plaintiff, RAUDEZ, suffered

mental anguish, humiliation, pain and suffering and the loss of enjoyment of life, and was unable

to earn a living.

26. Despite arresting Plaintiff, RAUDEZ, under false pretenses (without “Probable

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Cause”), Defendant, ATESIANO, proudly pointed his Police Department’s 100% burglary

clearance rates in years 2013 and 2014 to the leaders of Defendant, VILLAGE OF BISCAYNE

PARK, in order to demonstrate what an excellent job ATESIANO, as Police Chief, was doing so

as to further advance and monetize his professional career while also enhancing the image of the

VILLAGE OF BISCAYNE PARK as a “crime-free” place to live. 

27. The Policy began to unravel shortly thereafter when police officer or police

officers informed the Manager of Defendant, VILLAGE OF BISCAYNE PARK, about this

Policy. The divulgence of this said information to the City Manager set off a chain of events that

ultimately prompted an investigation by Internal Affairs. Internal Affairs’ investigation would

bring about Police Chief ATESIANO’s resignation from office in mid 2014. 

28. As a result of the police officer or police officers’ informing Defendant,

VILLAGE OF BISCAYNE PARK about the Policy put in place by Police Chief ATESIANO and

that was executed by ATESIANO’s underlings, Defendant, VILLAGE OF BISCAYNE PARK ,

knew or should have known that its employee police officers had violated RAUDEZ’s

Constitutional and Civil Rights which resulted in RAUDEZ’s unconstitutional incarceration. 

29. Despite being on notice of the Policy and what its police officers pursuant to said

Policy had done to men of Color, particularly those of African descent, like Plaintiff RAUDEZ, 

Defendant, VILLAGE OF BISCAYNE PARK, made no effort to help free Plaintiff RAUDEZ

from the illegal incarceration. 

30. Defendants were part of a conspiracy to make false arrests to satisfy THE

VILLAGE OF BISCAYNE PARK that crime was being eliminated. Plaintiff, RAUDEZ, did not

know of this conspiracy nor had reason to know of the conspiracy to violate his Constitutional

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and Civil Rights until the matter was fully investigated. 

31. On or about July 31, 2019, the Criminal Division of the Eleventh Judicial Circuit

Court, in and for Miami-Dade County, entered an Order Vacating the Judgment And Sentence

Based Upon Newly Discovered Evidence in both criminal/felony cases against Plaintiff, (Case

No.: F14-1928 & Case No.: 14-002202), and thereby exonerating Plaintiff, RAUDEZ. (See,

Comp. Exh. “1"). 

32. On June 07, 2018, an Indictment was filed against the VILLAGE OF BISCAYNE

PARK’s Chief of Police, RAIMUNDO ATESIANO, et al. (See, Exh. “2" Indictment of

Atesiano and others)

33. On April 05, 2018, an Indictment was filed against VILLAGE OF BISCAYNE

PARK’S Police Officer, GUILLERMO RAVELO, (See, Exh. “3" Indictment of Ravelo).

34. They (ATESIANO & RAVELO) were charged with conspiracy to violate the civil

rights of various persons in which the United States of America laid out the case against

Defendant, ATESIANO, and others, while charges against co-conspirator, RAVELO, were filed

in a separate case. Together, ATESIANO and RAVELO were charged for conspiring to deprive

citizens of their Constitutional Rights under Color of Law. 

35. The indictment charged Police Chief, ATESIANO, since he caused the

conspiracy and encouraged officers under his supervision and command to arrest civilians of

Color and/or of African descent, including Plaintiff, without legal basis for such arrests, with the

goal of creating a clear record of all burglaries within in the municipality of the Village of

Biscayne Park. Upon information and belief, Defendants, ATESIANO and underling, RAVELO,

conspired to falsely arrest, and deprive Plaintiff, as well as others similarly situated, of their

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Constitutional Rights under Color of Law for unsolved residential burglaries and other

violations. This Policy was devised, implemented, and executed with racial animus, evil intent

and malice. 

36. On July 26, 2018, a Superseding Indictment was filed charging Defendant,

ATESIANO, with a broader conspiracy involving other people of African descent who were the

victims of the conspiracy. (See, Exh. “5", “Superseding Indictment”)

37. Defendant, RAVELO, was indicted under Case No. 18-20255-CR-ALTONAGA,

for crimes, including conspiracy against civil rights, and deprivation of rights under color of law.

38. On July 26, 2018, Defendant, RAVELO entered a GUILTY plea to these charges.

(See, Comp. Exh. “4", “Plea Agreement/Factual Proffer”).

39. Defendant, ATESIANO, was indicted under Case No.: 18-20479-CR-MOORE,

for crimes, including conspiracy against civil rights, and deprivation of rights under color of law.

40. On September 14, 2018, Defendant, ATESIANO, entered a GUILTY plea to these

charges. (See, Comp. Exh. “6", “Plea Agreement/Factual Proffer”).

41. All of the VILLAGE OF BISCAYNE PARK’s employees who were Defendants

in the criminal indictments have been sentenced to prison and are/were incarcerated.

COUNT I - MALICIOUS PROSECUTION 42 U.S.C. § 1983

(AS TO DEFENDANT VILLAGE OF BISCAYNE PARK)

42. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein pursuant to 42 U.S.C. § 1983.

43. The Defendant, THE VILLAGE OF BISCAYNE PARK, in furtherance of the

policy of racial discrimination unlawfully and without probable cause instituted criminal

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proceeding against Plaintiff.

44. The Arrest Affidavit charging Plaintiff was fraudulent and issued with malice and

bad intent of the part of the Defendant. 

45. The actions of the Defendant, THE VILLAGE OF BISCAYNE PARK, violated

the Constitution of the United States of America and the right to be free from unreasonable

illegal seizure which is violative of the Fourth Amendment and Fourteenth Amendment. 

46. There was a bona fide termination of the criminal charges in favor of Plaintiff. 

47. As a direct and proximate result of the foregoing acts the Defendant, Plaintiff

has and will continue to suffer great mental anguish. 

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgement against

Defendant, THE VILLAGE OF BISCAYNE PARK, for damages, including attorney’s fees,

prejudgment interest and all costs of these proceedings, and he further demands a trial by jury of

all issues so triable. 

COUNT II - FALSE ARREST/IMPRISONMENT 42 U.S.C. § 1983

(AS TO DEFENDANT VILLAGE OF BISCAYNE PARK)

48. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein pursuant to 42 U.S.C. § 1983.

49. Defendant, VILLAGE OF BISCAYNE PARK, unlawfully and with malice

arrested, and caused Plaintiff to be confined against his will without color authority. The

detention was unreasonable and unwarranted under the circumstances and was committed with

the intention to cause Plaintiff’s confinement or with substantial certainty that his confinement

would result. 

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50. The proceedings against Plaintiff were terminated in his favor and no probable

cause justified the Defendant’s act under color of law.

51. The false arrest by the Defendant was violative of the Constitution of the United

States, and said seizure violates the right to be free from illegal seizures guaranteed by the Fourth

Amendment as a clear restraint on Plaintiff’s freedom of movement, the result of which was to

cause Plaintiff to suffer great mental pain and anguish.

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgment against

Defendant, VILLAGE OF BISCAYNE PARK, for damages, including attorney’s fees,

prejudgment interest and all cost of these proceedings and demands a trial by jury of all issues so

triable. 

COUNT III - ABUSE OF PROCESS 42 U.S.C. § 1983

(AS TO DEFENDANT VILLAGE OF BISCAYNE PARK)

52. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein pursuant to 42 U.S.C. § 1983.

53. Defendant, VILLAGE OF BISCAYNE PARK, willfully and intentionally misused

the criminal legal process for some ulterior, and unlawful object or collateral purpose which was

unwarranted and unauthorized. Specifically, the Defendant misused the criminal legal process to

issue excessive traffic violations, and issue false arrest affidavits to enhance the Village of

Biscayne Park’s clearance rate for unsolved burglaries. 

62. Defendant’s abuse of process is violative of the Constitution of the United States

Of America and contrary to the protections embodied in the Fourth Amendment of Due Process.

63. As a direct and proximate result of the foregoing acts of the Defendant, the

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Plaintiff has and will continue suffer great mental anguish.

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgment against

Defendant, VILLAGE OF BISCAYNE PARK, for damages, including attorney’s fees,

prejudgment interest and all cost of these proceedings and demands a trial by jury of all issues so

triable. 

COUNT IV - VIOLATION OF CONSTITUTIONAL RIGHTS

(AS TO DEFENDANT VILLAGE OF BISCAYNE PARK)

63. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 42 as though fully set forth herein pursuant to 42 U.S.C. § 1983.

71. This cause of action pursuant to 42 U.S.C. § 1983.

72. The Defendant, VILLAGE OF BISCAYNE PARK, through the actions of its

Police Chief, ATESIANO, as the final decision-maker for the Police Department, and officers

acting at his behest, violated, and deprived Plaintiff, RAUDEZ, of his constitutional rights.

Specifically, Defendant, VILLAGE OF BISCAYNE PARK, violated Plaintiff’s right to be free

from illegal seizure, his right to be free from police harassment and intimidation as provided by

the Constitution of the United States; and Plaintiff, RAUDEZ’s right to be free from malicious

prosecution, malicious abuse of process and unlawful seizure as provided in the Fourth

Amendment and Fourteenth Amendments to the Constitution of the United States of America. 

73. As a direct and proximate result of the foregoing acts of the Defendant, 

Plaintiff has and will continue to suffer great mental anguish.

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgment against

Defendant, VILLAGE OF BISCAYNE PARK, for damages, including attorney’s fees,

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prejudgment interest and all cost of these proceedings and demands a trial by jury of all issues so

triable. 

COUNT V- 42 U.S.C. § 1983 DUE PROCESS VIOLATION

(AGAINST DEFENDANT ATESIANO)

74. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein pursuant to 42 U.S.C. § 1983.

75. This cause of action pursuant to 42 U.S.C. § 1983.

76. The Defendant, ATESIANO, was acting under the color of law in his individual

capacity, he violated and deprived Plaintiff, RAUDEZ, of his constitutional rights. Specifically, 

Defendant ATESIANO violated Plaintiff’s right to be free from illegal seizure, the Plaintiff’s

right to be free from police harassment and intimidation as provided by the Constitution of the

United States; and Plaintiff, RAUDEZ’s right to be free from malicious prosecution, malicious

abuse of process and unlawful seizures as provided in the Fourth and Fourteenth Amendments of

the Constitution of the United States of America. 

77. The conduct of the Defendant in racial profiling and targeting Plaintiff is clearly

reprehensible to a great degree. 

78. The Defendant’s conduct was motivated by evil intent, and/or callousness

indifference towards the federally protected rights of the Plaintiff while acting under color of law. 

79. Even more pernicious, Defendant’s conduct was racially motivated, and was

repeatedly and intentionally directed towards people of African descent and/or minority due to

the policy of the Village. 

80. The gross recklessness of Defendant’s conduct should shock the conscience

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of the Court and deference requires imposition of punitive damages.

81. In the manner described more fully above, Defendant, ATESIANO, in

furtherance of the Policy, deliberately ordered police officers of the Defendant, THE VILLAGE

OF BISCAYNE PARK to fabricate false arrest reports, affidavits, and other evidence of guilty

against, Plaintiff, RAUDEZ, thereby misleading and misdirecting the criminal prosecution of

RAUDEZ. Absent this egregious misconduct, the prosecution of RAUDEZ could not and would

not have been pursued. 

82. Defendant, ATESIANO’s misconduct also directly resulted in the unjust criminal

conviction through the coerced guilty plead of RAUDEZ, thereby denying RAUDEZ his

constitutional right to a fair trial, and a fair appeal thereof, in violation of the Due Process Clause

of the Fifth and Fourteenth Amendment to the United States Constitution. 

83 As a direct and proximate result of the foregoing acts of the Defendant,

 ATESIANO, the Plaintiff has and will continue to suffer great mental, emotional distress,

humiliation, emotional anguish, and loss of enjoyment of life as heretofore alleged. 

84. 42 U.S.C. § 1983 provides a remedy for violation of these rights. 

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgement against

Defendant, RAIMUNDO ATESIANO, for damages, including attorney’s fees, prejudgment

interest, all cost of these proceedings, punitive damages as well as any other relief this Court

deems proper and demands a trial by jury of all issues so triable. 

COUNT VI - 42 U.S.C. § 1983 AGAINST DEFENDANT RAVELO

85. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein pursuant to 42 U.S.C. § 1983. 

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86. This cause of action pursuant to 42 U.S.C. § 1983.

87. Defendant, RAVELO, was acting under the color of law in his individual

capacity when he violated and deprived Plaintiff, RAUDEZ, of his constitutional rights.

Specifically, Defendant violated Plaintiff’s right to be free from illegal seizures, Plaintiff’s right

to be free from police harassment and intimidation as provided by the Constitution of the United

States; and Plaintiff’s right to be free from malicious prosecution, malicious abuse of process and

unlawful seizures, as guaranteed under the Fourth and Fourteenth Amendments of the

Constitution of the United States of America. 

88. The conduct of Defendant in racial profiling and targeting Plaintiff is clearly

reprehensible to a great degree. 

89. Defendant’s conduct was motivated by evil intent, and/or callousness

indifference towards the federally protected rights of the Plaintiff while acting under color of law. 

90. Even more pernicious, Defendant’s conduct was racially motivated, and was

repeatedly and intentionally directed towards people of African descent and/or minority due to

the policy of the Village. 

91. The gross recklessness of Defendant’s conduct should shock the conscience

of the Court and deference requires imposition of punitive damages.

92. As a direct and proximate result of the foregoing acts of Defendant, 

Plaintiff has and will continue to suffer great mental and emotional anguish, and loss of

enjoyment of life as heretofore alleged. 

93. 42 U.S.C. § 1983 provides a remedy for violation of these rights. 

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgment against

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Defendant, GUILLERMO RAVELO, for damages, including attorney’s fees, prejudgment

interest and all cost of these proceedings and demands a trial by jury of all issues so triable. 

VII - CIVIL CONSPIRACY AGAINST ALL DEFENDANTS

94. Plaintiff , RAUDEZ, re-alleges and reaffirms each and every allegation contain in

paragraph 1 through 41, as though fully set forth herein.

95. This is a cause of action pursuant to 42 U.S.C. § 1985.

96. Defendant, VILLAGE OF BISCAYNE PARK, through the actions of its

employees, POLICE CHIEF ATESIANO, OFFICER RAVELO and others, engaged in a

conspiracy to deprive Plaintiff, RAUDEZ of his constitutional rights.

97. Defendants engaged in overt acts in furtherance of their conspiracy by

falsifying arrest affidavits to charge Plaintiff with burglary, theft and traffic violations that he did

not commit.

98. Plaintiff was exonerated of the charges but nevertheless injured by the overt

acts and concert of acts of Defendants. 

99. Defendant VILLAGE OF BISCAYNE PARK had a custom and policy initiated by

the Police Chief to falsify arrests to clear crime statistics in violation of Plaintiff’s guaranteed

Constitutional Rights.

100. Defendant engaged in a policy and practice of racial discrimination against

persons of Color and of African descent, within the Village of Biscayne Park and said practices

are pernicious to the Constitutional rights of the Plaintiff.

101. Defendant acted in agreement to commit illegal acts, based upon racial

animus, and deprived the Plaintiff of his constitutional rights by falsifying arrest records and

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evidence.

102. The Police Officers, including Defendants, ATESIANO and RAVELO, have been

indicted and pled guilty to federal crime as a result of their participation in the conspiracy of

racial discrimination against people of African descent.

103. As a direct and proximate result of the foregoing acts of Defendants, Plaintiff has

and will continue to suffer great mental anguish. 

WHEREFORE, Plaintiff, JUAN LEONARDO RAUDEZ, prays for judgment against

Defendants, THE VILLAGE OF BISCAYNE PARK, CHIEF RAIMUNDO ATESIANO,

and OFFICER GUILLERMO RAVELO for damages, including attorney’s fees, prejudgment

interest and all cost of these proceedings and demands a trial by jury of all issues so triable. 

DEMAND FOR JURY TRIAL

Plaintiff, JUAN LEONARDO RAUDEZ, requests a trial by jury on all issues so triable

as a matter of right.

Date: May 12, 2020.

 James Jean-Francois, /s/ 

JAMES JEAN-FRANCOIS, ESQ.

Fla. Bar. No.: 0495115 

Law Offices of James Jean-Francois, P.A.

Duty Free Americas, Suite 211

6100 Hollywood Boulevard

Hollywood, FL 33024

Phone: (954) 987-8832

Fax: (954) 987-2622

e-address: (P): jamesjeanfrancoisesq@hotmail.com

 (S): jjonlaw@hotmail.com

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