UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO. 9:20-mc-81409-RKA

KENNETH D. BELL IN HIS CAPACITY

AS COURT-APPOINTED RECEIVER FOR

REX VENTURE GROUP, LLC,

Plaintiff,

vs.

PATRICK ORLANDO,

Defendant,

and

PNC BANK, N.A.,

 Garnishee. /

ANSWER OF GARNISHEE AND DEMAND FOR

PAYMENT PURSUANT TO FLORIDA STATUTE 77.28

COMES NOW the Garnishee, PNC BANK, N.A., by and through its undersigned 

attorneys, and for its answer to the Writ of Garnishment served on the Garnishee on May

14, 2021, says as follows:

1. That between the time of this Answer and the time of service of said Writ, 

Garnishee, PNC BANK, N.A., was not indebted to the Defendant PATRICK ORLANDO, 

and that it did not have any goods, money, chattels or effects of said Defendant in its 

hands, possession or control at any time between said period.

2. That Garnishee does not know of any other persons indebted to said 

Defendant or who may have the effects of said Defendant in his hands, possession or 

control at any time between said period.

Case 9:20-mc-81409-RKA Document 7 Entered on FLSD Docket 05/17/2021 Page 1 of 3
KENNETH D. BELL IN HIS CAPACITY

AS COURT-APPOINTED RECEIVER

FOR REX VENTURE GROUP, LLC

vs.

PATRICK ORLANDO

CASE NO. 9:20-mc-81409-RKA

ANSWER OF GARNISHEE AND DEMAND FOR

PAYMENT PURSUANT TO FLORIDA STATUTE 77.28

Page 2

3. That the Defendant, PATRICK ORLANDO, is on file with Garnishee, PNC 

BANK, N.A., and the last known address on record is 8833 Marlamoor Lane, West Palm 

Beach, Florida 33412.

4. That Garnishee is obligated to pay its attorney a reasonable fee and requests 

an award of costs and a reasonable attorney's fee for expenses incurred by Garnishee in 

obtaining representation in and about this suit, as provided by law.

DEMAND FOR PAYMENT OF GARNISHEE ANSWER FEE

5. Garnishee, PNC BANK, N.A., demands payment, as partial payment of its 

attorney's fees, of $100.00 forthwith, as provided pursuant to Florida Statute Section 

77.28, payable to PRUITT & PRUITT, P.A. and mailed to PRUITT & PRUITT, P.A., Suite 

5, 3030 South Dixie Highway, West Palm Beach, Florida 33405-1539.

6. That in addition to the initial $100.00 partial payment to be paid by the 

party applying for the Writ of Garnishment, Garnishee asks the Court to determine

Garnishee's costs and expenses, including a reasonable attorney's fee, and in the event of

a Judgment in favor of the Plaintiff, that the amount be subject to offset by the Garnishee 

against the Defendant whose property or debt is being garnished. 

WHEREFORE, Garnishee, PNC BANK, N.A., prays, having fully answered said 

Writ of Garnishment, that the initial partial payment of attorney's fees be issued to 

Garnishee's attorney forthwith and payable to PRUITT & PRUITT, P.A.

Case 9:20-mc-81409-RKA Document 7 Entered on FLSD Docket 05/17/2021 Page 2 of 3
KENNETH D. BELL IN HIS CAPACITY

AS COURT-APPOINTED RECEIVER

FOR REX VENTURE GROUP, LLC

vs.

PATRICK ORLANDO

CASE NO. 9:20-mc-81409-RKA

ANSWER OF GARNISHEE AND DEMAND FOR

PAYMENT PURSUANT TO FLORIDA STATUTE 77.28

Page 3

I HEREBY CERTIFY that a true copy of the foregoing has been furnished by 

eservice to Alison N. Emery, Esq., EMERY LAW PLLC, alison@jaxlawyer.com and by 

electronic mail through the CM/ECF system to all those listed therein, this 17th day 

of May, 2021.

By /s/ William E. Pruitt

William E. Pruitt, Esq.

Florida Bar No. 273821

William B. Pruitt, Esq.

Florida Bar No. 127605

PRUITT & PRUITT, P.A.

Suite 5, 3030 South Dixie Highway

West Palm Beach, FL 33405

Tel. No. (561) 655-8080 x108

Fax No. (561) 655-4134

Primary e-mail: jknight@pruittpruittlaw.com

Secondary e-mails: wep@pruittpruittlaw.com

wb@pruittpruittlaw.com

Case 9:20-mc-81409-RKA Document 7 Entered on FLSD Docket 05/17/2021 Page 3 of 3