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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN ADMIRALTY 

GREAT LAKES INSURANCE SE, 

vs. 

Plaintiff, 

CASE NO. 1:20-cv-22865-CMA 

SEA 21-21 LLC, 

Defendant. 

 / 

STATEMENT OF MATERIAL FACTS NOT IN DISPUTE 

IN SUPPORT OF PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 

COMES NOW the Plaintiff, GREAT LAKES INSURANCE SE (hereinafter “GREAT 

LAKES”), by and through its undersigned attorneys, and pursuant to Rule 56 of the Federal Rule of 

Civil Procedure and Rule 56.1 of the Local Rules of the United States District Court for the Southern 

District of Florida, file this its Statement of Material Facts Not in Dispute submitted in support of 

Plaintiff’s Motion for Summary Judgment, and further thereto would respectfully state as follows: 

1. Concept Special Risks Ltd. (hereinafter “Concept”) is GREAT LAKES’ managing general 

agent. Declaration of Beric Anthony Usher, dated August 19, 2021, a true and correct copy of which 

is attached hereto as Exhibit 1, at ¶6. 

2. Global Insurance Brokers, Inc. (hereinafter “Global”) (formerly “Specialty Broker 

Corporation”) was the agent of SEA 21-21 at all times relevant hereto. Ex. 1, at ¶16. 

3. On or about April 12, 2018, Defendant SEA 21-21 LLC (hereinafter “SEA 21-21”) submitted 

to the Plaintiff, via Defendant’s agent, an application (hereinafter “the Original Application”) for a 

policy of marine insurance on the 1996 65 ft Ocean Tech vessel named “LA BESTIA” (hereinafter 

“the Vessel”). ECF No.62, at ¶¶’s 7, 14. A true and correct copy of the Original Application was 

previously filed ECF No. 62-1. 

4. The Original Application represents that Jorge Fernandez is the beneficial owner of SEA 21-

21 as well as an operator of the Vessel. ECF No. 62, at ¶9; see ECF No. 62-1, at 1, 3. 

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5. The Original Application asks “Have you or any named operator been involved in a loss in 

the last 10 years (insured or not)” and the box for “No” is checked. ECF No. 62, at ¶12; see ECF No. 

62-1, at 4. 

6. The Original Application asks of each operator: “Have you been involved in a Loss in the last 

10 years (insured or not)? If YES, please give details” to which the response for operator Jorge 

Fernandez is “NO.” ECF No. 62, at ¶13; see ECF No. 62-1, at 4. 

7. The Original Application represents that the purchase price of the Vessel was $400,000. ECF 

No. 62, at ¶8; ECF No. 62-1, at 1. 

8. On or about March 19, 2018, Plaintiff issued to SEA 21-21 its Marine Insurance Policy No. 

CSRYP/166843 (hereinafter “the 2018 Policy”), affording Hull & Machinery coverage in the amount 

of $400,000.00 for a period of one (1) year commencing on March 5, 2018, on the Vessel. ECF No. 

62, at ¶14. 

9. Plaintiff agreed to issue the 2018 Policy based upon the representations set forth in and the 

material information disclosed in the Original Application. ECF No. 62, at ¶15. 

10. Concept assessed a 10% credit on the premium charged for the 2018 Policy in reliance on the 

Insured’s representations that he had had no losses in the previous ten (10) years. Ex. 1, at ¶26. 

11. On or about March 22, 2019, Defendant submitted to the Plaintiff, via Defendant’s agent, a 

Renewal Questionnaire for coverage of the Vessel. ECF No. 62, at ¶20. A true and correct copy of 

the Renewal Questionnaire was previously filed as ECF No. 62-4. 

12. The Renewal Questionnaire asks whether each operator “ha[d] been involved in a Loss in the 

last 10 year (insured or not)? If YES, please give details and amounts paid” to which the response for 

Jorge Fernandez is “No.” ECF No. 62, at ¶22; see ECF No. 62-4, at. 2. 

13. The Renewal Questionnaire asks “Have there been any other changes since your last signed 

application form? If so, please detail” to which the response is “No.” ECF No. 62, at ¶23; see ECF 

No. 62-4, at 3. 

14. The Original Application and Renewal Questionnaire state the same warning: “Any 

misrepresentation in this application for insurance will render insurance coverage null and void 

from inception.” ECF No. 62-4, at 3 (emphasis in original). 

15. On or about March 22, 2019, Plaintiff issued to SEA 21-21 its Marine Insurance Policy No. 

CSRYP/174282 (hereinafter “the 2019 Policy”), affording Hull & Machinery coverage in the amount 

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of $400,000.00 for a period of one (1) year commencing on March 5, 2019, on the Vessel. ECF No. 

62, at ¶25. A true and correct copy of the 2019 Policy was previously filed as ECF No. 62-5. 

16. Plaintiff agreed to issue the 2019 Policy based upon the representations set forth in and the 

material information disclosed in the Original Application and the Renewal Questionnaire. ECF No. 

62, at ¶26; Ex. 1, at ¶32. 

17. Concept assessed a 10% credit on the premium charged for the 2019 Policy in reliance on the 

Insured’s representations that he had had no losses in the previous ten (10) years. Ex. 1, at ¶33. 

18. On or about March 7, 2019, Defendant submitted to Plaintiff, via e-mail from Defendant’s 

agent, a request to increase insured hull value of “LA BESTIA” from $400,000 to $775,000. ECF 

No. 62, at ¶16; see ECF No. 62-2; Ex. 1, at ¶34. 

19. The 2019 Policy, like the 2018 Policy, is an “agreed value” policy. See ECF No. 62-5, at 4. 

(“‘Agreed Value’ means the sum insured under Section A of the insuring agreement declaration page 

or any endorsement to the same.”) 

20. In an e-mail exchange dated March 20, 2019, SEA 21-21 represented, via its agent, Beatriz 

Watson of Global, that receipts in support various upgrades/improvements did exist but would be 

difficult to provide as they were in “storage boxes.” In response, Alex Thomas of Concept requested 

“a spreadsheet showing the individual costs for the items.” A true and correct copy of the 

aforementioned e-mail exchange is attached hereto as Exhibit 2. 

21. In an email dated March 21, 2019, SEA 21-21, via its agent, provided a breakdown of the 

alleged upgrades/improvements made to the Vessel, totaling a cost of $324,185. ECF No. 62, at ¶18; 

see a true and correct copy of the aforementioned email previously filed as ECF No. 62-3, at 1-3. 

22. Excluding certain items which Concept deemed maintenance-related [see ECF No. 62-3, at 1 

(in which Ms. Thomas of Concept states “I have marked the ones I do not think we can include in 

red”)], Concept agreed to include the cost of the remaining alleged upgrades/improvements, totaling 

a cost of $176,510, in its consideration of SEA 21-21’s request to increase the insured value of the 

Vessel. Ex. 1, at ¶38. 

23. On or about April 5, 2019, Underwriters issued an endorsement increasing the agreed value 

of the hull sum insured to $560,000. ECF No. 62, at ¶28; see ECF No. 62-5, at 33. 

24. Plaintiff agreed to issue the above referenced endorsement based upon the representations set 

forth in, and the information disclosed in, communications from the Defendant, via its agent, 

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regarding the requested increase in hull value and alleged improvements to the Vessel. ECF No. 62, 

at ¶29; Ex. 1, at ¶39. 

25. On or around February 26, 2020, during the period of the 2019 Policy, the Vessel was 

involved in an incident in which it has been alleged that certain damage was sustained after the Vessel 

caught fire and sank while en route from Pompano Beach, FL to Bimini. ECF No. 62, at ¶30. See a 

Plaintiff’s first notice of the loss, previously filed as ECF No. 62-6. 

26. Upon receipt of the first notice of the February 26, 2020 loss described herein, Plaintiff caused 

an investigation to be made into the facts and circumstances surrounding the incident. ECF No. 62, 

at ¶32. 

27. In the course of investigating the February 26, 2020 loss described herein, Plaintiff became 

aware that Mr. Fernandez had a loss on or about May 9, 2018 under a different GREAT LAKES 

policy which had not been properly disclosed on the Renewal Questionnaire. Ex. 1, at ¶31. 

28. The aforementioned loss of May 9, 2018 involved a crew member named Erick Largacha who 

was injured while serving aboard the “ORANGE TWISTER,” insured under Plaintiff’s Policy No. 

CSRYP/161642. Ex. 1, at ¶9. 

29. The Named Insureds under Plaintiff’s Policy No. CSRYP/161642 were Sea 20-20 LLC and 

Jet Boat Miami LLC. See Policy Schedule for Plaintiff’s Policy No. CSRYP/161642, a true and 

correct copy of which it attached hereto as Exhibit 3, at 1. 

30. Mr. Fernandez was the owner, in whole or in part, of both Sea 20-20 LLC and Jet Boat Miami 

at the time of the May 9, 2018 loss involving Mr. Largacha and the “ORANGE TWISTER.” 

Deposition of Jorge Fernandez as Defendant’s Corporate Representative, dated March 26, 2021, 

previously filed as ECF No. 60-2, at 25:10-22; 29:2-9. 

31. Mr. Largacha made a claim against Sea 20-20 LLC and/o Jet Boat Miami LLC related to the 

injuries he sustained on May 9, 2018. ECF No. 60-2, at 29:2-12. 

32. Concept was not aware that this same insured, Jorge Fernandez, had suffered a loss under a 

different GREAT LAKES Policy until it was notified via email on April 22, 2020 by Nautilus 

Investigations, as they had assisted with both claims. Ex. 1, at ¶31. A true and correct copy of the 

aforementioned email of April 22, 2020 is attached hereto as Exhibit 4. 

33. In the course of litigation, Plaintiff became aware that the Insured had suffered four additional 

prior losses which had not been properly disclosed on either the Original Application or the Renewal 

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Questionnaire. ECF No. 62, at ¶¶’s 43-46; Ex. 1, at ¶11. 

34. In or around July 2016, the “LA BESTIA” suffered an incident resulting in the Vessel being 

placed in dry dock while it was repainted and the propellor was repaired. See e-mail from Jorge 

Fernandez, dated March 4, 2018, a true and correct copy of which is attached hereto as Exhibit 5, at 

2 (in which Mr. Fernandez references “I am attaching the list with all the repairs done on La Bestia, 

including the dry docking that was carried out in July 2016,” “paint used for the boat,” and “repair of 

the propellers.”) 

35. The “LA BESTIA” was put in dry dock for repairs in July 2016 because it had struck a 

sandbar. See email from Jose Figueroa of Global, dated May 24, 2021, a true and correct copy of 

which is attached hereto as Exhibit 6, at 1 (in which Mr. Figueroa states: “[t]o the best of my 

recollection, the July 2016 incident mentioned in 2018 by Mr. Fernandez ‘related to minor damages 

sustained when vessel went over a small sandbar raising-up at low tide.’ The minor repairs were 

completed....”) 

36. On or about August 6, 2016, a woman named Maria Cardoza was injured in an incident aboard 

a vessel owned by SEA 21-21 LLC and/or Jet Boat Miami LLC. Second Deposition of Jorge 

Fernandez as Defendant’s Corporate Representative, dated July 21, 2021, a true and correct copy of 

which is attached hereto as Exhibit 7, at 43:16- 44:1 and 45:15-46:6. 

37. Ms. Cardoza made a claim against SEA 21-21 and/or Jet Boat Miami LLC for damages related 

to the injuries she sustained on August 6, 2016. Id.; see also email and attached demand letter dated 

May 10, 2018 from Ben Dowers, Esq., a true and correct copy of which is attached hereto as Exhibit 

8, at 2 (in which Mr. Dowers states “[o]n August 6, 2016, Ms. Cardoza was injured while riding the 

banana boat which was pulled by a jet ski....”) 

38. On or about May 26, 2017, a woman named Mache Lanier was injured aboard a vessel owned 

in whole or in part by Jet Boat Miami, LLC. Ex. 7, at 19:7-20:13. See also e-mail from Mr. Fernandez, 

dated September 26, 2017, with referenced attachments, a true and correct copy of which is attached 

hereto as Exhibit 9, at 1 (in which Mr. Fernandez states “I am attaching the letter from the lawyer, 

the waiver, and the accident report for Mache Lanier case. The customer was on the banana boat on 

May 26, 2017” and “sa[id] she had dislocated her knee on the ride.”) 

39. Ms. Lanier made a claim against Jet Boat Miami, LLC for her injuries as a result of the May 

26, 2017 incident. See Ex. 9, at 7 (“You are hereby notified of her injury claim against you for this 

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this [sic] accident.”) 

40. At the time of the May 26, 2017 incident involving Ms. Lanier, Jet Boat Miami, LLC was 

owned in whole or in part by Mr. Fernandez. Ex. 7, at 48:5-17. 

41. On or about October 20, 2017, a woman named Andreana Diaz was injured aboard a vessel 

owned in whole or part by Jet Boat Miami LLC, an entity which Mr. Fernandez owned. Ex. 7, at 

30:16-31:17. 

42. Ms. Diaz made a claim against Jet Boat Miami LLC for her injuries as a result of the October 

20, 2017 incident. Id., at 31:3-9. See also email from Mr. Fernandez, dated October 27, 2017, a true 

and correct copy of which is attached hereto as Exhibit 10 (in which Mr. Fernandez states: “I just sent 

you a new claim for the client Andreana Diaz in another email with all the information on the case.”) 

43. None of the aforementioned four additional prior losses involved vessels insured with 

GREAT LAKES at the time of the loss itself. Ex. 1, at ¶23. 

44. Mr. Fernandez admits that Jet Boat Miami LLC lost its “claims free discount” with its 

previous insurer, Lloyd’s of London, due to the incidents involving Ms. Lanier and Ms. Diaz. Ex. 7, 

at 32:10-34:3. 

45. Mr. Usher, Concept’s Senior Underwriter, has had over 35 years of experience in the marine 

insurance industry. Ex. 1, at ¶¶’a 3-5. 

46. As a prudent and intelligent marine insurance underwriter, Mr. Usher considers the facts of 

an insured’s loss history among the most germane to deciding whether to issue a policy, what 

premium to charge, and what terms and conditions to require. Ex. 1, at ¶¶’s 43-45. 

47. Mr. Usher considers loss history to be material because these facts could and likely would 

influence the mind of a prudent and intelligent marine insurance underwriter in determining whether 

to accept the risk because these past events are the best (and only) indicators of future risk. Therefore, 

truthful answers to questions regarding loss history are material to his decisions as a prudent and 

intelligent underwriter because false answers would only result in a faulty evaluation of the risk. Id., 

¶44. 

48. The matter of an insured’s loss history, whether he or she was at the helm when such a loss 

occurred or not, is always of concern to Mr. Usher, and to any reasonable underwriter, as it is an 

indicator of the insured’s care and skill in managing and maintaining the vessel, and it is the best 

indicator of the likelihood of future losses. Id., at ¶45. 

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49. As stated in the Concept Underwriting Manual regarding “Owner/Operator Acceptability,” (a 

true and correct copy of which is attached hereto as Exhibit 11, at 3-4): 

Assuming that the owner and operators (they may not be the same person) meet all 

of the standards referred to above we must consider their past loss records on boats 

as well as on the land. Again, we are seeking patterns and we specifically ask about 

marine losses – insured or not – to establish if any pattern of incidents exist that 

may not have been the subject of an insurance claim but that would suggest if we 

were to issue a policy could well become one against our underwriters. For 

example, an owner could have had a number of small grounding incidents that 

caused damage to his vessel but not enough to impact a policy. This would suggest 

that sooner or later if the pattern continues, he will commit a major navigational 

error that will result in an expensive insurance claim. 

If an owner has had previous losses, these must be taken into consideration when 

deciding whether or not to offer terms and these will impact the price charged. [....] 

 

As far as other past losses are concerned, as a rule, one is unfortunate; two begins 

to look like carelessness. More than that and the owner is probably not insurable. 

There may be extenuating circumstances but if you have doubts either refer to a 

Director or do not quote. 

50. As stated in the Concept Special Risks Rating Guide V5 (a true and correct copy of which is 

attached hereto as Exhibit 12, at 5-6): “Experience Credit: This is a standard credit and does not vary. 

It is only offered where an operator has sufficient (two years or more) relevant experience with type 

of vessel and clean loss record.” 

51. Had SEA 21-21 truthfully disclosed just the July 2016 loss on either the Original Application 

or Renewal Questionnaire, Concept would have charged a higher premium for both the 2018 and 

2019 Policies by approximately 30%. Ex. 1, at ¶¶’s 48,51. 

52. Had SEA 21-21 truthfully disclosed just the August 6, 2016, the May 26, 2017, and the 

October 20, 2017 losses on the Original Application, Concept would have charged a higher premium 

for the 2018 Policy by approximately 30%. Id., at ¶49. 

53. Had SEA 21-21 truthfully disclosed just the August 6, 2016, the May 26, 2017, the October 

20, 2017, and the May 9, 2018 losses on the Renewal Questionnaire, Concept would have charged a 

higher premium or declined to issue the 2019 Policy due to the number of losses. Id., at ¶52. 

54. SEA 21-21 admitted that it received a $50,000 reduction in the $400,000 purchase price of 

the Vessel for money that would be used to make repairs to the Vessel’s center engine. ECF No. 60-

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2, at 44:13-46:7. See also Marine Note, Security Agreement & Power of Attorney, signed by Mr. 

Fernandez on a true and correct copy of which is attached hereto as Exhibit 13, at 9 (where it is 

handwritten: “$50,000 deferred due to oil analysis of center engine. Any monies not applied to center 

engine are due to lender 120 days from signing....”) 

55. As part of its Fed.R.Civ.P 26 Initial Disclosures, Defendant produced the document entitled 

“Engine Repair Costs.” A true and correct copy of the aforementioned document is attached hereto 

as Exhibit 14. 

56. SEA 21-21 claims to have spent approximately $43,881.42 to repair the center engine of the 

Vessel. ECF No. 60-2, at 62:15-25 (referring to “Engine Repair Costs.”) 

57. In the course of discovery, Plaintiff served on Defendant a Request for Production per 

Fed.R.Civ.P 34 seeking, among other things, “[a]ny and all receipts, logs, records and similar 

documents which in any way demonstrate that Defendants caused any work, upgrading and/or 

maintenance to be conducted or performed with respect to the vessel insured under Plaintiff’s Policy 

No. CSRYP/174282 at any time after that vessel’s purchase,” in response to which the Defendant 

produced 1) a 25-page document entitled “Transaction Detail” showing SEA 21-21’s expenses 

between March 2016 and January 2020, and 2) a 197-page collection of various receipts and invoices 

entitled “La Bestia Repair and Maint-Invoices.” See Defendant’s Responses To Plaintiff’s Request 

for Production, dated Jan 6, 2021, a true and correct copy of which is attached hereto as Exhibit 15, 

at 3. 

58. On or about March 30, 2021, Plaintiff retained Revel Boulon, CMS accredited marine 

surveyor and adjuster with Sedgwick with more than 14 years of experience as a USCG Licensed 

Chief Engineer, and provided him with copies of the documents produced by the Defendant, 

including, but not limited to, the aforementioned “Transaction Detail,” the 197 pages of receipts and 

invoices entitled “La Bestia Repair and Maint-Invoices,” and the document entitled “Engine Repair 

Costs,” as well as the list of various upgrades/improvements SEA 21-21 claims to have performed on 

the Vessel with associated costs as stated in Ms. Watson’s email of March 21, 2019 (ECF No. 62-3, 

Bates-stamped Sea 21-21_UF000061 to Sea 21-21_UF000063), for his review and analysis. 

Declaration of Revel Boulon, dated August 19, 2021, a true and correct copy of which is attached 

hereto as Exhibit 16, at ¶6. 

59. In general, Mr. Boulon has opined that much of the work which SEA 21-21 claims to have 

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performed lacks supporting documentation, and where supporting documentation could be found, 

“the represented costs were significantly higher for most line items where there was documented 

receipts or invoices.” Id., at ¶8. 

60. Mr. Boulon has opined that, of the $43,881.42 which SEA 21-21 claims to have spent on 

repairs to the Vessel’s center engine, the documents produced by SEA 21-21 support a showing of 

no more than $20,758.58 being spent on such repairs. Ex. 16, at ¶10, pp.’s 6-7 (Table 2). 

61. As stated by Mr. Usher in his Declaration, the Original Application specifically inquired into 

the Vessel’s purchase price because, as a prudent and intelligent marine insurance underwriter, he 

considers purchase price to be among the most germane facts when deciding whether to issue a policy, 

what premium to charge, and what terms and conditions to require. Concept would never agree to 

issue a policy insuring a vessel for more than its purchase price plus the cost of investment, as doing 

so would create a moral hazard whereby the vessel was insured for more than had been invested in 

it. Ex. 1, at ¶46. 

62. Had SEA 21-21 truthfully disclosed in the Original Application that it had received a $50,000 

reduction in the $400,000 purchase price of the Vessel for repairs to the center engine and that SEA 

21-21 had spent no more than approximately $20,758.58 for such repairs, Concept would not have 

agreed to insure the Vessel for the stated purchase price of $400,000 or any amount in excess of the 

amount invested in it by the insured. Ex. 1, at ¶50. 

63. Mr. Boulon has opined that, of the $176,510 which SEA 21-21 claims to have spent on various 

upgrades/improvements to “LA BESTIA” and which Concept deemed to be non-maintenance related, 

the documents produced by SEA 21-21 support a showing of no more than $37,754.49 having been 

spent on such work. Ex. 16, at ¶9, pp.’s 3-6 (Table 1). 

64. When Mr. Fernandez was questioned regarding the list of upgrades/improvements allegedly 

made to the Vessel and costs for the same as stated Ms. Watson’s email of March 21, 2019 (ECF No. 

62-3), he sought to distance himself from the information contained within it, stating “I didn’t create 

it. I don’t know what is on that list,” and later “maybe they added things, I don’t know,” and “[a]sk 

Beatriz Watson, the person that created this.” ECF No. 60-2, at 75:7-76:3. 

65. Had SEA 21-21 truthfully disclosed in the communications regarding its request to increase 

the insured value of “LA BESTIA” based on various upgrades/improvements that it had spent no 

more than $37,754.49 on such work, Concept would not have agreed to issue the endorsement 

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increasing the insured value by $160,000, nor would Concept have agreed to insure the Vessel at any 

amount in excess of the amount invested in it by the Insured because to do so would create a “moral 

hazard.” Ex. 1, at ¶¶’s 47, 46, 53. 

66. As stated in the Concept Underwriting Manual (Ex. 11, at 3) regarding vessel purchase price, 

the purpose of insurance is to enable someone to be put back into the condition they 

enjoyed prior to a loss, therefore, we do not insure vessels for more than their 

purchase price to the current owner without evidence in the form of receipts of 

genuine investment to increase the vessel’s value (as opposed to the cost of routine 

maintenance such as bottom painting etc.) 

67. The 2019 Policy (ECF No. 62-5, at 16) contains a choice of law clause which states: 

It is hereby agreed that any dispute arising hereunder shall be adjudicated according 

to well established, entrenched principles and precedents of substantive United 

States Federal Admiralty law and practice but where no such well established, 

entrenched precedent exists, this insuring agreement is subject to the substantive 

laws of the State of New York. 

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Dated: August 20, 2021 

Fort Lauderdale, Florida 

GOLDMAN & HELLMAN 

Attorneys for Plaintiff 

8751 W. Broward Boulevard 

Suite 404 

Fort Lauderdale, Florida 33324 

Tel (954) 356-0460Fax (954) 832-0878 

By: /s/ Steven E. Goldman 

STEVEN E. GOLDMAN, ESQ. 

FLA. BAR NO. 345210 

Case 1:20-cv-22865-EGT Document 69 Entered on FLSD Docket 08/20/2021 Page 11 of 12
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on August 20, 2021 I electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system which will send an electronic Notice of Filing 

to all counsel of record: 

Christopher J. Lynch, Esq. 

Hunter Lynch Law 

Attorneys for Defendant 

6915 Red Road, Suite 208 

Coral Gables, FL 33143 

Tel: 305-443-6200 

Clynch@hunterlynchlaw.com 

Lmartinez@hunterlynchlaw.com

Henry Marinello, Esq.

LAW OFFICE OF HENRY MARINELLO, 

P.A. 

Co-Counsel for Sea 21-21 LLC 

P.O. Box 562516 

Miami, Florida 33256 

Telephone 305-670-5688 

Fax 305-238-5553 

Email hmarinello@hemlegal.com

Respectfully submitted, 

GOLDMAN & HELLMAN 

Attorneys for Plaintiff 

8751 W. Broward Boulevard 

Suite 404 

Fort Lauderdale, FL 33324 

Tel (954) 356-0460 

Fax (954) 832-0878 

By: /s/ Steven E. Goldman 

STEVEN E. GOLDMAN 

FLA. BAR. NO. 345210 

Case 1:20-cv-22865-EGT Document 69 Entered on FLSD Docket 08/20/2021 Page 12 of 12