1 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION 

CASE NO.: 1:20-cv-22816

BIG LEAGUE VENTURES, LLC.,

Plaintiff,

v.

CERTAIN UNDERWRITERS AT LLOYDS, 

LONDON, BRIT UW LIMITED (BY AND 

THROUGH SYNDICATE 2897), BEAZLEY 

UNDERWRITING LIMITED (BY AND 

THROUGH SYNDICATE 2623), CAITLIN 

SYNDICATE LIMITED (BY AND THROUGH

SYNDICATE 2003), CINCINNATI GLOBAL 

DEDICATED NUMBER 2 LIMITED (BY AND 

THROUGH SYNDICATE 0318)

Defendant.

/

COMPLAINT

COMES NOW, the Plaintiff, BIG LEAGUE VENTURES, LLC. (collectively referenced 

herein as “Plaintiff”), by and through undersigned counsel, and through this Complaint hereby sues 

Defendant, CERTAIN UNDERWRITERS AT LLOYDS, LONDON et al. (collectively referenced 

herein as “Defendant”), and alleges as follows: 

PARTIES, JURISDICTION AND VENUE

1. This is an action for damages that exceeds Seventy-Five Thousand Dollars

($75,000.00), exclusive of interest, costs and attorneys’ fees and the Court has diversity jurisdiction 

over the matter pursuant to 28 U.S.C. Section 1332. 

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2. This action has been brought in the proper venue, pursuant to 28 U.S.C Section

1391, as it concerns a commercial residential insurance dispute arising out of, accruing in, 

culminating in, and/or situated within this Court’s jurisdiction, including without limitation, MiamiDade County, Florida. 

3. At all times material hereto, the Plaintiff was and continues to be a Florida Limited

Liability Company and a lawfully registered Florida entity with the Secretary of State, who 

receives insurance benefits in relation to the commercial residential insurance claim that is further 

described supra. 

4. The Plaintiff, a Limited Liability Company, is comprised entirely of the following

four (4) members:

a. Yaakov Brafman a Citizen of Florida.

b. Eli Weberman a Citizen of Florida.

c. Meyer Muschel a Citizen of New York.

d. Avrohom Kagan a Citizen of Florida.

5. “[T]he legal relationship between the Names and the insured is a vertical one: it

is the individual Names, not the syndicate, who are directly liable in the event of loss, as if each 

Name had a contract with the Insured.” Underwriters at Lloyd’s, London v. Osting-Schwinn, 613 

F.3d 1079, 1085 (11th Cir. 2010).

6. At all times relevant hereto, the Defendant Names, subscribed to the subject policy

of insurance are as follows:

a. The policy is underwritten 47.6190% by Catlin Underwriting Agencies

Limited (Syndicate 2003) (“Catlin”). Catlin was acquired by XL Group plc in

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2015 and is a wholly-owned subsidiary of XL group Ltd., a Bermuda 

corporation with its principal place of business in Bermuda. In 2018, XL 

Group was acquired by AXA, now called AXA XL. AXA XL is incorporated 

in and domiciled in the United Kingdom, which is also its principal place of 

business. The syndicate securing the subject policy was a corporate entity 

incorporated in and domiciled in the either Bermuda, or the United Kingdom, 

which is also its respective principal place of business, having no individual or 

other names or members insuring the risk. 

b. The policy is underwritten 23.4286% by Syndicate 2623, an unincorporated

association duly organized and existing under the laws of the United Kingdom,

with its principal place of business located in London, England. The sole

member of Syndicate 2623 is Beazley Underwriting Limited, a corporation

organized and existing under the laws of England and Wales, with its principal

place of business located in London, England.

c. The policy is underwritten 14.2857% by Syndicate 2987, an unincorporated

association duly organized and existing under the laws of the United Kingdom,

with its principal place of business located in London, England. The sole

member of Syndicate 2987 is Brit UW Limited, a corporation organized and

existing under the laws of England and Wales, with its principal place of

business located in London, England.

d. The policy is underwritten 9.5238% by Syndicate 0318, an unincorporated

association duly organized and existing under the laws of the United Kingdom,

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with its principal place of business located in London, England. Syndicate 0318 

is comprised of 390 members, the largest being Cincinnati Global Dedicated 

No 2 Limited, a corporation organized and existing under the laws of England 

and Wales, with its principal place of business located in London, England. 

7. All conditions precedent to the filing of this lawsuit have occurred, have been

waived, have been performed, and or been forfeited pursuant to the inequitable conduct doctrine. 

GENERAL ALLEGATIONS

8. At all times material hereto, in consideration of a premium paid by the Plaintiff,

there was in full force and effect a certain homeowners insurance policy issued by the Defendant

with a policy number of 77MBR-3017 (the “Policy”).

9. A certified copy of the Policy is attached hereto and incorporated by reference as

Exhibit 1. 

10. Per the terms of the policy, Defendant agreed to provide insurance coverage to

the Plaintiff’s property located at located at 1231 NW 58th Terrace, Miami, Florida 33142,

against direct physical loss to property. 

11. On or about October 4, 2017, while the Policy was in full force and effect, the

Property sustained a direct, physical, and covered loss as a result of a fire (the “Loss”) which as 

further described below, at the very onset of being reported, the Defendant had no basis to refuse 

performance by way of payment of the claim. 

12. Plaintiff timely notified Defendant of the loss and requested they open a claim, at

which time Defendant assigned claim number 916486 to the Loss and thereafter refused to issue 

payment per false, deceptive, malicious, fraudulent, and unethical insistence that payment would 

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only be made if the Plaintiff attested that the gross undervaluation of the loss in fact constituted 

full value of the claim. 

13. Consequently, the Plaintiff initiated this cause of action on January 18, 2018

and advised the Department of Financial Services, pursuant to the Civil Remedy Notice, of the bad 

faith claim handling practices of the Defendant. Subsequent thereto and pursuant to an illusory and 

deceptive effort to cure same, the Defendant moved to compel an “expedited appraisal” in 

combination with a stay of the litigation. 

14. On or about June 21, 2019, an appraisal award was entered and it was not until

July 19, 2019 that the Defendant performed pursuant to said award and the subject policy. In 

light of same, the instant action for bad faith has fully vested. 

15. It has been shown, in absolute, that the Defendant underpaid the claim by

hundreds of thousands of dollars and knew, or should have known, that the gross underpayment, 

failure to duly assess the loss, and the defenses of non-compliance with post-loss obligations, are 

without merit and serve to cause extra-contractual damages. 

16. More specifically, as a result of the Defendants’ breach, based upon information

and belief, the property has fallen into a state of disrepair, rendering it a total loss, estimating

roughly $300.00/square foot for teardown and rebuild for a total of $2,683,800.00. Moreover, 

the Plaintiff has lost business income in the amount of $234,325.00 and anticipates losing 

business income in the amount of roughly $120,000.00 per year. As such, the Plaintiff’s current 

Damages stand at $2,917,125.00, exclusive of attorney’s fees and costs. 

17. The Plaintiff has been obligated to retain the undersigned attorney for the

prosecution of this action and is entitled to a reasonable attorneys’ fees and costs pursuant to

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Florida Statute §§ 627.428, 626.9373, and 57.041. 

COUNT I

STATUTORY BAD FAITH CLAIM PURSUANT TO FLA. STAT. SEC. 624.155

18. The Plaintiff adopts and realleges paragraphs 1 through 17 as fully alleged herein.

19. Pursuant to Fla. Stat. Sec. 624.155, the Plaintiff has a statutory cause of action for bad

faith due to the Defendant’s general business practice of willful, wanton, immoral, unlawful, 

malicious, and/or deceptive claims handling practices (misconduct collectively referred to as “Bad 

Faith”).

20. The exhaustively stated basis for which this action is predicated is set forth in the civil

remedies notice (CRN) provides as follows:

The Complainant insured, Big League Ventures, LLC (“Complainant”), maintained 

a policy of insurance with Certain Underwriters of Lloyd’s, London (“Lloyd’s) at 

the time that it suffered a loss and damages in association with a sudden and 

accidental fire that occurred on October 4, 2017. That said, Lloyd’s knew, or should 

have known that the loss was covered from the onset, and for the reasons further 

outlined below and per the legal authorities cited, has engaged in a general business 

practice of bad faith claim handling policies, procedures, guidelines, protocol, 

valuation and payment of the claims. 1.) From the onset of the loss and adjustment, 

Lloyd’s had no basis to dispute coverage, yet, withheld payment of the undisputed 

amounts of the loss for no good cause. 2.) Lloyd’s agent, adjuster and/or authorized 

vendor, Bob Davis, who was tasked with adjusting the loss, admittedly was unduly 

delaying the payment of the covered loss due to the fact that he was inundated with 

claims. Mr. Davis and/or Lloyd’s unwillingness to make the necessary 

accommodation for the Complainant constitutes a gross disregard for the interest of 

the Complainant in relation to a loss that they knew had displaced multiple residents 

of the subject property. 3.) Matt Hoffman, another agent, adjuster and/or authorized 

vendor for Lloyd’s, acknowledged that Lloyd’s adjustment of the loss was based on 

Mr. Davis recommendations. 4.) It is without dispute that in advance of Mr. Davis 

preparation of an estimate, Lloyd’s knew, or should have known, that monies were 

promptly owed and needed by the Complainant for loss of rental income, moisture 

assessments, moisture remediation, costs associated with fire/soot remediation and 

assessment, etc. Irrespective of adjusting all amounts owed for the loss under 

various sections of the policy, Lloyd’s had a duty to immediately issue payment. 

That said, Lloyd’s disregarded said duty, and as part of its bad faith general business 

practices, waited until the 11th hour to demand upon the Complainant that it execute 

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a sworn proof of loss which attested to the fact that the Complainant did not dispute 

the assessed scope and value of the loss which was presented for the first-time 

months after the loss occurred. Payment was said to be contingent on the sworn 

proof of loss, which completely defies common sense and industry standards, since, 

the purpose of a sworn proof of loss is to obtain an insured’s (as opposed to 

insurer’s own self-serving position) representation as to, inter alia, the scope and 

value of the loss. It is apparent that Lloyd’s is utilizing this practice to unlawfully 

shield itself from litigation and liability under false, deceptive, immoral and 

unlawful pretenses, and it certainly should know that coercionary conduct is 

patently unacceptable. 5.) To draw greater specifics in reference to the 

considerations set forth above, undersigned counsel was obliged to send 

correspondence to Matt Hoffman on January 5, 2018, which stated as follows: 

From: Jose Font Sent: Friday, January 05, 2018 10:20 PM To: 

'mhoffman@pibadjusters.com' <mhoffman@pibadjusters.com> Cc: Caroline 

Carollo <ccarollo@fontnelson.com>; Bianca Diener <bdiener@fontnelson.com>; 

Amanda Sanichar <asanichar@fontnelson.com>; Sara Ortiz 

<sortiz@fontnelson.com>; Vanessa Gomez <vgomez@fontnelson.com>; Nicole 

Kronen <nkronen@fontnelson.com>; Pleadings <pleadings@fontnelson.com>; 

Jennifer Wilds <jwilds@fontnelson.com>; Nicole Kronen 

<nkronen@fontnelson.com> Subject: FW: 916486 Big League Ventures LLC - Fire 

Claim - Estimate Importance: High Good Evening, As an initial matter, thank you 

for disclosing today that you were going to advise the insurer that you are of the 

position that coverage has been established and that monies are due and owing per 

various sections of the policy. That said, and to be clear, I also acknowledge your 

representation that the insurer is free to reject your recommendations 

notwithstanding the fact that they have retained your company to serve as their 

representative and adjuster throughout the protracted claim process. To avoid any 

misunderstandings moving forward, I will further set for today’s discussions below: 

1.) You stated that as a condition to payment the insurer is now requesting for the 

first time that the insured execute a sworn proof of loss that corresponds with your 

estimate that was just submitted. Furthermore, you stated that the sworn proof of 

loss needed to include my client’s attestation that the amounts set forth constituted 

an undisputed agreement on their part with your estimate and payment 

recommendations. Respectfully, we reject the conditions to payment as presented. 

To the extent conveyed throughout this process, and is it relates to the various 

sections of coverage under the policy, it is my understanding that at this point the 

insurer has no basis in fact and/or law to dispute that monies are presently due and 

owing. If there is a basis to conclude to the contrary, please advise of same in 

response to this email. Otherwise, and as clearly provided for by law, including the 

adjuster code of ethics, we must insist that: the insurer immediately confirm that 

payment will be issued; the insurer reveal the time, method, basis, considerations 

and amount upon which payment is going to be issued; delivery be had to my 

Firm’s address as listed below and without listing my Firm (or any other Firm) as an 

additional payee; and the insurer disclose, along with their licensing or certification, 

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all personnel/vendors utilized to determine the equitable, prompt and full payment 

for this covered loss. 2.) Due to a multitude of actions and inactions on the part of 

the insurer, a suit was filed in this matter last week. 3.) Although you called and 

spoke to our client directly today, please refrain from any ex-parte communication 

with our client. 4.) Since litigation is pending, any and all further agreements that 

are to be reached need to take place through counsel as mandated by governing law. 

If you draw disagreement with our discussions as memorialized above, please 

advise of same in a meaningful, specific, substantive and written form. Also, and to 

further effectuate a prompt, final and equitable resolution, we also request that you 

provide the contact information for the insurer’s retained counsel. On a final note, 

please be advised that I will be serving as lead counsel, and that my Partner, Ms. 

Carollo, will also be working on this matter along with the other lawyers and 

paralegals copied on this email. Have a great weekend. Best Regards, Jose P. Font, 

Esq. 6.) The subject property has three floors and 18 units, and the loss occurred in 

unit 9, which is located on the second floor and has a series of units above and 

below it that were clearly exposed to soot throughout the interior sections of the 

walls and ceilings. However, Lloyd’s afforded no regard for the fact that the

Complainant would have to incur the costs of retaining a specialized fire remediator 

to implement IICRC and industry guidelines to duly remediate the soot. 7.) Lloyd’s, 

it agents and/or vendors, know, or should know, that failing to allow for proper 

fire/soot remediation serves to the detriment of the insured on a multitude of levels 

beyond underpayment, which includes, but is not limited to, creating toxic 

conditions that can serve to cause health hazards and concealed damages that 

continue to accrue unbeknownst to the insured over the course of time. 8.) If 

Lloyd’s had bothered to implement proper fire remediation protocol, it would have 

known that the piece meal repairs as set forth for the subject units constitute an 

objective and undeniably gross underpayment of the claim which forced the 

Complainant into a position of having to incur further delay and consequential 

damages, including, attorney’s fees, costs, loss income, contractual and extracontractual. Either Mr. Davis, Mr. Hoffman and/or Lloyd’s assigned personnel were 

not qualified to adjust the fire loss, or they grossly and/or intentionally disregarded 

the Complainant’s interests. 9.) The only cost-effective means to remediate soot 

under the circumstances described was to allow for a complete tear out of all 

building materials throughout all the neighboring units that were exposed to soot as 

indicated. As such, Lloyd’s new that it was required to pay the costs associated with 

the removal and replacement of all materials throughout. 10.) The structural support 

for the floors throughout the second and third floor consists of wood, that per open 

and obvious conditions and considerations, had been compromised in a multitude of 

units for which such repair costs were not appropriated. 11.) Lloyd’s has 

implemented as a general business practice the arbitrary appropriation of substantial 

depreciation deductions for which they know, or should know, are unlawful, 

deceptive, unfair, immoral and/or false means to underpay their insureds Lloyd’s 

knows that depreciation assessments need to be assessed on an item by item basis, 

and in instead of doing so, Lloyd’s disregards the insured’s interest and utilizes a 

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formulaic process that it knows, or should know, would be inadmissible in a court 

of law due to its inherently unreliable nature. To duly appropriate depreciation in a 

reliable fashion, Lloyd’s knows that it would have to incur substantial costs in the 

form of a qualified expert, who, would be charged with: gathering sufficient facts 

and data to formulate an opinion; develop reliable principles and methods; and 

apply the reliable principles and methods to gathered facts and data. In this case, 

depreciation appropriated allowed for a significant underpayment and breach of the 

policy as governed by Florida Law. 12.) As a function of extinguishing the fire, the 

insured property was exposed to significant moisture within the interior of various 

residential units. That said, Lloyd’s knows, or should know, that they had a duty to 

issue payment for necessary water/moisture assessment and remediation. Moreover, 

at a bare minimum, the cost of assessing mold and other toxic conditions that 

naturally develop within a residence when exposed to moisture for a few days. As a 

general business practice, and in the aggregate probably serving to save Lloyd’s 

millions of dollars in payouts, Lloyd’s pays no regard for the subject course of work 

that they know to be necessary. 13.) The valuations and scope of repair throughout 

the estimate, and per a calculated means of improperly utilizing a software system 

to underpay their insureds, Lloyd’s knows that the amounts appropriated are 

deficient at least in part. 14.) The nature of the damage in question necessitated 

substantial electrical repairs to be performed, to which, Lloyd’s paid little regard for 

the Complainant’s interest in terms of payment and/or otherwise. All indications are 

that Lloyd’s did not retain a qualified electrician to duly assess the scope and value 

of the repair, and for financial gain, such general business practice is implemented 

as a matter of course even when there is an admitted electrical issue for which their 

retained vendor/agent/adjuster is known to be unequipped to draw a duly qualified 

opinion. 15.) There were a significant number of windows that were damaged due 

to the subject loss, to which, Lloyd’s paid little regard for the Complainant’s interest 

in terms of payment and/or otherwise. All indications are that Lloyd’s did not retain 

a licensed window contractor to determine the reasonable and necessary scope, 

value and form of replacing the windows in question. Lloyd’s knows that their 

retained adjusters are legally obliged to retain experts if the adjustment necessitates 

same, but as a general business practice as alluded to, said obligation is disregarded 

in an effort to advance their own financial interest in a form that serves to the 

detriment of insureds such as the Complainant. 16.) Lloyd’s knew that in order to 

maintain continuity as provided for by law and the governing policy, the 

Complainant was entitled to the costs associated with refinishing all of the exterior 

walls. They disregarded this duty by allowing for piece meal repairs to only the 

immediate areas wherein there was damage. 17.) Due to the nature of the loss as 

described, Lloyd’s knew that the Complainant would have to incur substantial costs 

associated with replumbing the affected areas. Once again, Lloyd’s did not bother to 

retain licensed contractors to duly indemnify the Complainant for the covered loss. 

18.) As a consequence of Lloyd’s bad faith practices, the Complainant was forced to 

retain counsel to seek relief by way of a suit for breach of contract and declaratory 

relief. That said, and even though obliged to do so pursuant to Fla. Stat. Sec. 

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627.428 and 57.041, Lloyd’s has failed to exercise reasonable efforts to assess the 

scope and amount of the reasonable attorney’s fees and costs incurred so that the 

undisputed amount thereof could be issued to the Complainant’s counsel. Moreover, 

they have failed to issue a payment as recommended per the only known adjusters 

that were charged with assessing the scope and value of the loss. 19.) Knowing that 

it was not so, Lloyd’s adjuster recommended payment that was predicated on the 

ability to remove and reset (as opposed to replace) various materials throughout the 

property that were exposed to soot and simply not subject to being reutilized due to 

the cost prohibitive nature of the associated labor considerations and/or otherwise. 

20.) Without any consideration for true market values, Lloyd’s appropriated labor 

costs for various licensed contractors that they knew, or should have known, fell 

grossly below market values. 21.) Although admittedly covered and owed based on 

an actual cash value basis, Lloyd’s adjuster did not appropriate any monies for 

taxes, insurance, permits and fees. 22.) Although there was an appropriation made 

of $2,500.00 for architectural/drafting fees, said item is listed as a “bid item” and 

would require an actual licensed engineer to equitably assess the value of same per 

the totality of the circumstances at issue. The reality is that there are a multitude of 

licensed contractors/experts that are needed to work in conjunction with an engineer 

and general contractor to duly assess the necessary engineering and permitting, and 

Lloyd’s has left the Complainant to fend for itself due to their interest in delaying 

payment, avoiding expert/contractor fees, and forcing the Complainant into the 

dilemma of having to perform inadequate and/or ultimately duplicative repairs, or in 

turn, face consequential and extra-contractual damages in relation thereto. 23.) 

Lloyd’s investigation, adjustment and payment of a claim as a matter of course is 

affected by whether an insured is represented by a public adjuster and/or a lawyer is 

retained to file suit to secure the insured’s rights. In other words, and only when 

pressed to issue payment by way of a suit or a public adjuster, Lloyd’s refuses to 

fulfill its obligations to the insured in accordance with the policy/contract and their 

own admissions per payments associated with similarly situated clams. To cure the 

above stated immoral, deceptive, unlawful and generally described bad faith 

conduct which is part of a general business practice that is knowingly, or with a 

reckless disregard for the insured’s interest, being utilized by Lloyd’s for financial 

gain, Lloyd’s must confess error in the legal proceedings that were initiated by the 

Complainant in relation thereto, and in so doing, also: stipulate to the Complainant’s 

entitlement to attorney’s fees and costs pursuant to Fla. Stat. Sec. 627.428 and 

57.041; stipulate that the Complainant is not legally obliged to conditions that have 

been; issue payment to the Complaint per an amount that corresponds with its duty 

to duly adjust and issue payment of the undisputed amount of the loss; stipulate that 

the Complainant is entitled to judgment in its favor as it relates to its petition for 

declaratory relief that is currently pending; issue payment for the statutory interest 

that applies to the claim when paid, and to the extent that any remaining dispute as 

to law or fact remains as to the amounts owed, exercise a good faith effort to reach 

an equitable settlement.

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21. In turn, Defendant responded to the CRN, as set forth in Exhibit 2, and for which

the evidence that will be presented will establish that said response is without merit, as further 

substantiated by the subsequent appraisal award. 

22. Ultimately, and as set forth as Exhibit 3, the Defendant’s own appraiser agreed that,

at a very minimum, an additional $177,562.21 were due and owing, executed an appraisal order on 

or about June 21, 2019 and it wasn’t until July 19, 2019, which was twenty (20) months after the 

loss that the Defendant issued payment. 

23. It is without dispute that in advance of Defendant’s preparation of a pre-suit

estimate of damages, and even at the time that its appraiser executed an appraisal award, Defendant

knew, or should have known, that monies were promptly owed for interest, rental value, cost 

associated with soot and mold assessment, damages that were left unaccounted for as a 

consequence of not performing the necessary diagnostics and assessments, the cost of temporary 

repairs, and additional law and ordinance. 

24. Pursuant to the aforementioned award, as well as the Defendant’s representations

that liability is not in dispute, the Plaintiff’s bad faith action is ripe. Cammarata v. State Farm 

Florida Ins. Co., 152 So. 3d 606, 613 (Fla. 4th DCA 2014) (finding “the appraisal award 

‘constitute[d] a ‘favorable resolution’ of an action for insurance benefits, so that [the Plaintiff] ... 

satisfied the necessary prerequisite to filing a bad faith claim”); Sammy Sterling Holdings, LLC v. 

United States Aircraft Ins. Group, 16-CIV-21230, 2016 WL 8679130, at *4 (S.D. Fla. June 23, 

2016) (“[I]t is well established that a plaintiff may bring a section 624.155 action against an insurer 

without obtaining a precise determination of damages in prior coverage action, and the amount of 

damages may be determined may be determined in the section 624.155 action.”) 

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25. The predicate CRN was duly filed with the Florida Department of Financial Services

on January 16, 2018, and was served upon the Defendant by way of, inter alia, service of the State 

Court Breach of Contract Complaint on or about January 18, 2018. 

26. For the above stated reasons, the Plaintiff is entitled to punitive damages, attorneys’

fees, extra-contractual damages, and costs. 

WHEREFORE, the Plaintiff, pursuant to Fla. Stat. Secs. 624.155, 626.9541, 57.041, 55.03 

627.428, 626.9373, 627.70131 and governing Florida Law, respectfully demands judgment be 

entered against the Defendant and in the Plaintiff’s favor as follows:

a. Full payment of direct, actual and/or indirect extra-contractual damages;

b. An award of punitive damages;

c. An award for reasonable attorneys’ fees and costs for obtaining a judgment, order or decree

adverse to the Defendant and/or in favor of the Plaintiff’s rights under the Policy;

d. Payment of statutory, prejudgment and post-judgment interest; and/or

e. Any other relief the Court deems just and proper.

JURY DEMAND

The Plaintiff demands a trial by jury of all issues so triable pursuant to Rule 38 of the Federal 

Rules of Civil Procedure.

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Respectfully submitted,

FONT & NELSON, PLLC 

Attorney for Plaintiff

200 South Andrews Ave., Suite 501, 

Ft. Lauderdale, Florida 33301 

Tel: (954) 248-2920 

Fax: (954) 248-2134 

Email: pleadings@fontnelson.com 

BY: /s/ Adam Friedman 

JOSE P. FONT, ESQ.

Florida Bar #: 0738719 

ADAM M. FRIEDMAN, ESQ.

Florida Bar #: 0099408 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 9th day of July, 2020, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing 

document is being served this day on all counsel of record or pro se parties identified on the List 

below in the manner specified, either via transmission of Notices of Electronic Filing generated by 

CM/ECF or in some other authorized manner for those counsel or parties who are not 

authorized to receive electronically Notices of Electronic Filing. 

BERK, MERCHANT & SIMS, PLC

William S. Berk / FBN: 349828 

Illon R. Kantro / FBN: 26296 

Austin J. North / FBN: 111683 

2 Alhambra Plaza, Suite 700 

Coral Gables, Florida 33134 

Telephone: (786) 338-2900 

Facsimile: (786) 338-2888 

E-Mail: wberk@berklawfirm.com

ikantro@berklawfirm.com

lspaulding@berklawfirm.com

anorth@berklawfirm.com

kmendez@berklawfirm.com

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