UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

SOLARJUICE CO., LTD., as successor

in interest to PETERSENDEAN

ROOFING AND SOLAR SYSTEMS, INC.,

Plaintiff,

v. Case No. 9:22-cv-80799

TRAVELERS CASUALTY AND 

SURETY COMPANY OF AMERICA,

Defendants.

_____________________________________/

COMPLAINT

Plaintiff SolarJuice Co., Ltd., as successor in interest, to PetersenDean Roofing and Solar 

Systems, Inc. (“PetersenDean”), files this Complaint against Defendant Travelers Casualty and 

Surety Company of America (“Surety”) and alleges: 

1. This is an action for damages in excess of $75,000.00, exclusive of interest, 

attorneys, fees, and costs.

2. PetersenDean is a Florida corporation authorized to conduct business in the State 

of Florida. 

3. Surety is a foreign profit corporation authorized to do business in the State of 

Florida and who issued a bond for the Project at issue. 

4. Venue is proper in this court pursuant to Chapter 47, Florida Statutes, because the 

cause of action occurred in Palm Beach County.

5. All conditions precedent to bringing this action have occurred, been performed 

or been waived.

6. Upon information and belief, on about September 1, 2019, Current Builders, 

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Inc. (“Current Builders”) entered into a construction contract with RCA Blvd JV, LLC 

(“Owner”), under which Current Builders acted as the prime contractor for the construction 

of the Arcadia Gardens, located in Palm Beach Gardens, Florida (the “Project”). The Project 

consisted of two, 5-story apartment buildings with independent senior living apartments. 

7. On about September 27, 2019, Surety issued a payment bond on behalf of 

Current Builders in connection with the Project, Bond No. 106978945 (the “Bond”). A copy 

of the Bond is attached as Exhibit “A.”

8. On January 30, 2020, Current Builders and PetersenDean entered into a 

subcontract for the Project, under which PetersenDean was to perform, among others, work 

related to the installation of roofs and other related materials and services at the Project (the 

“Subcontract”). A copy of the Subcontract is attached as Exhibit “B.” 

9. PetersenDean satisfactorily performed its work and furnished all labor, materials, 

and supplies necessary to complete its work, including certain change orders and extras for said 

work as requested and directed by Surety’s principal, Current Builders, on the Project. All such 

work, labor, materials, and supplies have been accepted by Current Builders. Amounts are due to 

PetersenDean which remain unpaid by Current Builders on the Project.

10. On June 4, 2021, PetersenDean recorded its Claim of Lien, in the amount of 

$488,965.32, in the Public Records of Palm Beach County at OR BK 32551, Page 1906. A copy 

of the Claim of Lien is attached as Exhibit “C.” On June 16, 2021, Current Builders issued its 

Notice of Bond in the Public Records of Palm Beach County at OR BK 32593, Page 1658. A 

copy of the Notice of Bond is attached as Exhibit “D.”

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COUNT I: CLAIM AGAINST PAYMENT BOND

11. PetersenDean re-alleges and incorporates Paragraphs 1 through 10 above as if 

fully set forth herein.

12. Surety’s failure to pay PetersenDean the amount owed to PetersenDean on the 

Project is a breach of the Bond.

13. PetersenDean has been damaged by such breach in the amount of $488,965.32.

14. The last date that PetersenDean furnished materials, services, and labor to the 

Project was on or about May 31, 2021.

15. PetersenDean retained the undersigned counsel to prosecute this action on its 

behalf, and has become obligated to pay its attorneys a reasonable fee. The Surety is obligated to 

compensate PetersenDean for those attorneys’ fees pursuant to Florida Statutes Section 627.428 

and applicable Florida law. 

WHEREFORE, PetersenDean demands judgment for damages against Surety, together 

with attorneys’ fees, interest, and costs, and such other and further relief as the Court deems just 

and proper.

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury of all issues so triable.

Dated this 31st day of May, 2022.

Respectfully submitted,

/s/ Michael J. Friedman 

Michael J. Friedman

Florida Bar No. 650854

Nicole D. Moss 

Florida Bar No. 1003075

FRIEDMAN LEGAL

1001 Yamato Road, Suite 311

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Boca Raton, FL 33431

Telephone: (561) 320-7788

mfriedman@friedmanlegalfl.com

nmoss@friedmanlegalfl.com

pleadings@friedmanlegalfl.com

Attorneys for Plaintiff

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