1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.

LUIS ANTONIO QUIÑONES GARCIA,

Plaintiff,

vs.

AH ENTERTAINMENT, INC., and

ILIANES RUIZ,

Defendants.

_______________________________________/

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff LUIS ANTONIO QUIÑONES GARCIA, a resident and citizen of 

Carolina, Puerto Rico, sues Defendants AH ENTERTAINMENT, INC. (d/b/a Flow 

la Movie), a Florida Corporation, and ILIANES RUIZ, Florida resident, and alleges 

as follows: 

Nature of Case, Jurisdiction, and Venue

1. This case arises out of the conduct of Defendant AH Entertainment, 

Inc.’s (“AH”), through its alleged principal, Defendant Ilianes Ruiz (“Ilianes”), which 

has been directed at derailing Plaintiff Luis Antonio Quiñones Garcia’s musical career

and has caused AH to breach its contractual obligations towards Plaintiff and warrants 

the recission of the contract between the parties and the appointment of a receiver to 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 1 of 14
2

steward AH and ensure its compliance with its contractual obligations towards 

Plaintiff and others.

2. This Court has diversity jurisdiction under 28 U.S.C. § 1332, because the 

amount in controversy exceeds the jurisdictional threshold, exclusive of interest and 

costs, and is between a citizen of Puerto Rico and citizens of Florida. 

3. Venue is proper in this Court under 28 U.S.C. § 1391(b)(2), because a 

substantial part of the events or omissions giving rise to the Plaintiff’s claims occurred 

within this judicial district. Furthermore, venue is also proper pursuant to a Choice of 

Forum included in the Recording Agreement that is the subject of this lawsuit. 

Plaintiff Luis Antonio Quiñones Garcia

4. Plaintiff Luis Antonio Quiñones Garcia (“Nio”), better known as Nio 

Garcia, was born on April 3, 1989 in San Juan, Puerto Rico. He now resides in 

Carolina, Puerto Rico. 

5. Plaintiff is currently one of the most prominent reggaeton artists in the 

world. He has over 16.2 million monthly listeners on Spotify, 3 million followers on 

Instagram, over 1.4 million followers on Facebook, and over 232,000 followers on 

Twitter. 

6. He burst onto the music scene in 2017 with his hit single, “Te Bote” and 

cemented his status as a reggaeton superstar when he released “Te Bote (Remix)” in 

2019, which featured other reggaeton superstars, Bad Bunny, Ozuna, Nicky Jam, and 

Darrell. Since then he has released multiple hit records, including AM, AM (Remix), 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 2 of 14
3

Tus Poses, Travesuras, and Travesuras (Remix), which have amassed millions of 

streams and have catapulted him to worldwide success. 

7. All of the aforementioned singles were executively produced by Jose 

Angel Hernandez (“Flow”), better known as Flow La Movie, who tragically passed 

away on December 15, 2021. 

8. Nio is currently under an Exclusive Recording Contract with AH 

Entertainment, Inc., a company founded and led by Flow until his untimely death. 

See Exhibit 1. 

AH Entertainment, Inc.

9. Defendant AH Entertainment, Inc., d/b/a Flow La Movie, is a Florida 

for-profit corporation established in 2015 by Jose Angel Hernandez. AH’s principal 

place of business is located at 317 Clearwater Lane, Kissimmee, Florida 34759. Upon 

information and belief, at the time of his death, Flow was the President, Resident 

Agent, and sole shareholder of AH. 

10. AH is a record label primarily focused on commercializing and releasing 

music by Puerto Rican reggaeton artists. 

11. Nio is currently AH’s most prominent musical act and AH is under the 

obligation to use its best efforts to release and market Nio’s musical recordings in order 

to grow Nio’s career and pay Nio his corresponding royalties generated by the release 

of his musical recordings. 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 3 of 14
4

12. Upon information and belief, at the time of Flow’s death, Defendant 

Ilianes, his mother, was AH’s Vice-president. It is not clear whether her ascension to 

AH’s vice-presidency complied with Florida law. 

Ilianes Ruiz

13. Defendant Ilianes Ruiz is a resident of Kissimmee, Florida and is listed 

as Defendant AH’s President and Resident Agent. Upon information and belief, 

Ilianes unlawfully assigned herself those titles upon Flow’s untimely death. 

Ilianes’ Unlawful Seizure of Power over AH’s Affairs

14. On January 5, 2022, Ilianes filed an Annual Report with the Florida 

Division of Corporations listing herself as President and Resident Agent of Defendant 

AH. See Exhibit 2.

15. Her seizure of AH’s presidency and resident agency was unlawful at the 

time it was done, insofar as Flow was AH’s sole shareholder, president, and resident 

agent at the time of his death and Ilianes did not have the legal authority to act on 

AH’s behalf after Flow’s death. 

16. Under Florida law, upon Flow’s death, Flow’s estate automatically 

became AH’s sole shareholder. 

17. The matter of who constitutes Flow’s estate, however, is currently being 

litigated in probate case no. 2022CP0022700000XX, pending before the Polk County 

Circuit Court.

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 4 of 14
5

18. Specifically, on June 24, 2022, Ilianes, through counsel, filed a Petition for 

Administration and Establishment and Probate of Lost or Destroyed Will and Appointment of 

Personal Representative. 

19. The document Ilianes now alleges is Flow’s Last Will and Testament is 

dubious in many respects. 

20. Firstly, the original document is lost and only a copy exists. 

21. Second, the will was purportedly executed in or around July 2016, while 

Flow was detained pending trial in a Florida state court case and, most importantly, 

at a time when Flow was penniless and had no assets to bequeath to his heirs.1

22. Third, and most importantly, despite Flow having two underage 

daughters at the time his alleged Last Will and Testament was executed, the will only 

names Ilianes as Flow’s heir. 

23. On August 22, 2022, Flow’s only surviving daughter, Keigelyan 

Hernandez-Pena (“Keigelyan”), filed a Declaration that Proceeding is Adversary and a 

Motion for Extension of Time to Respond or Reply to Ilianes’ Petition.

24. Upon information and belief, Keigelyan intends to challenge the validity 

of what Ilianes claims to be her father’s Last Will and Testament and her request to be 

named Flow’s personal representative. 

1 Flow was later acquitted of all charges in this case. 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 5 of 14
6

25. If Keigelyan succeeds, an outcome that appears likely based on 

information and belief, Flow will be deemed to have died intestate and Keigelyan will 

be named his sole heir and, accordingly, AH’s sole shareholder. 

26. Ilianes will, therefore, have no valid claim over Flow’s estate and, 

accordingly, no legal authority to act on AH’s behalf. 

Ilianes’ Unfitness to Preside over AH’s Affairs

27. After unlawfully seizing control of AH’s affairs, Ilianes has demonstrated 

an obvious unfitness to steward AH, as well as a general lack of knowledge of how the 

music industry operates. 

28. Her lack of fitness to run AH is best evidenced by her clear manifestation 

of her intent to derail Nio’s career and her actions geared towards accomplishing that 

goal, such as constantly posting derogatory and disparaging remarks about Nio and 

his team on her, and AH’s, social media accounts. 

29. Specifically, Ilianes and her cohorts have published upwards of 40 social 

media posts directed at Nio where they insult, threaten, and disparage him publicly. 

In other words, Ilianes has made it a point to display her vindictive feelings towards 

Nio as publicly as possible.

30. In more private communications, Ilianes has constantly disparaged and 

ridiculed Nio, referring to him as a “pendejo” (asshole) and a “vendio” (sellout). 

31. In one particular instance, Ilianes refused to approve the budget, air 

transportation and accommodations for Nio’s live performance at the Premios Lo 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 6 of 14
7

Nuestro awards show, a prominent awards show for the music industry, thus causing 

Nio to lose a golden opportunity to promote new music and further his brand.

32. In a more recent instant of clear unfitness, Ilianes’ questionable status as 

a member of Flow’s estate has caused a multi-million-dollar sale of AH’s catalog to 

stall, representing a substantial loss of income for Plaintiff, as well as for related entities 

The Orchard and Get Low Records LLC (d/b/a Glad Empire LLC), as well as 

recording artist, Julio Cruz Garcia, better known as Casper Magico. 

The Exclusive Recording Agreement

33. On January 27, 2021, Nio and AH, represented by Flow, entered into 

an Exclusive Recording Agreement (“the Agreement”).

34. Pursuant to the Agreement, Nio was to render his services and talents as 

a performing artist exclusively to AH in exchange for a Recording Advance of one 

million dollars ($1,000,000) and royalties of 16% of the master recordings delivered 

and commercialized. 

35. In turn, AH’s duty was the commercialization and marketing of Nio’s

music, along with the payment of corresponding royalties after recoupment of the 

Recording Advance. 

36. AH also has a duty under the Agreement to accountings of Nio’s royalties 

as of each June 30th and December 31st for the prior 6 months for each period where 

transactions occur on which royalties are payable to Nio.

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 7 of 14
8

37. The Agreement required Nio to deliver AH a minimum of 30 master 

recordings and/or the equivalent of one LP, provided the master recordings and/or 

the LP were commercially satisfactory to AH. 

38. The Agreement would terminate 12 months after the date of the initial 

commercial release of the last applicable master recording and/or LP, although AH 

reserved the right to exercise 5 optional periods under the same terms outlined above.

39. Regarding breaches, the Agreement provides that Nio most provide 30 

days written notice of any breach of the Agreement. If AH fails to cure that breach, 

Nio has the right to seek termination of the Agreement or seek damages in a competent 

court of law. 

Nio’s Unreleased LP

40. At some time prior to Flow’s tragic death, Nio provided Flow with a 15-

song LP (“LP”). Flow enthusiastically approved the LP for release. 

41. In fact, Flow individually approved every master recording that formed 

part of the LP and approved the production of 3 music videos, 2 of which had already 

been filmed prior to his death. The third video was scheduled to be filmed in Miami, 

Florida the week after Flow’s untimely demise. Flow also approved the cover art for 

the LP. 

42. Prior to his death, Flow, Nio, and the rest of Nio’s distribution team, Get 

Low Records LLC (“Get Low”) and Orchard Enterprises (“Orchard”), had agreed 

that the LP was to be released sometime during the first trimester of 2022. In fact, 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 8 of 14
9

Flow, Get Low and Orchard had agreed to distribute and market the LP and Orchard 

had advanced two million dollars ($2,000,000) to distribute and market the LP. 

AH’s Contractual Breaches

43. After Ilianes assumed control of AH’s affairs, she has stonewalled the 

release of Nio’s LP, refusing to honor Flow’s approval of the recordings, music videos, 

and release date. This is despite her duty, as AH’s principal, to engage in good faith, 

commercially reasonable efforts to commercialize Nio’s music and grow Nio’s career. 

44. Moreover, despite the Agreement being signed in January 2021, AH has 

failed to provide the requisite accounting of royalties for the two periods that have 

elapsed since the inception of the Agreement. 

45. Both of these breaches constitute cause for Nio to rescind his contract 

with AH and for the recovery of damages resulting from those breaches. 

46. As a result, Nio notified AH of its breaches and requested AH cure the 

contractual breaches discussed above via letter sent to the law firm that claims to 

represent AH and Ilianes, Singh, Singh & Trauben, LLP.

47. All conditions precedent to this suit have occurred or been performed. 

COUNT I

Breach of Contract

48. Plaintiff incorporates the allegations in paragraphs 1 through 47 as if fully 

set forth herein. 

49. As set out in detail above, Nio and AH entered into an Exclusive 

Recording Agreement on January 27, 2021. 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 9 of 14
10

50. Nio has performed all his obligations under the Agreement. 

51. All conditions required by the Agreement for AH to perform its duties 

under the contract have occurred. 

52. AH materially breached its obligations to Nio by, inter alia, 1) arbitrarily

failing to release his LP, despite Flow having determined that it was commercially 

satisfactory; 2) arbitrarily failing to release Nio’s music videos, despite Flow having 

determined they were commercially satisfactory; 3) maliciously disparaging Nio 

through AH’s social media accounts and the social media accounts of its principal, 

Ilianes Ruiz; and 4) failing to provide the periodic accountings required by the 

Agreement. 

53. Nio’s career is suffering irreparable harm as a result of AH’s breaches of 

the Agreement. 

WHEREFORE, Plaintiff demands judgment against AH for all his damages in 

an amount to be determined at trial, but no fewer than three million dollars 

($3,000,000), plus pre-judgment and post-judgment interest and costs of this suit, and 

for such other and further relief as this Court deems just and proper. 

COUNT II

Recission of the Exclusive Recording Agreement

54. Plaintiff incorporates the allegations in paragraphs 1 through 47 as if fully 

set forth herein. 

55. As set out in detail above, Nio and AH entered into an Exclusive 

Recording Agreement on January 27, 2021. 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 10 of 14
11

56. Nio has performed all his obligations under the Agreement. 

57. All conditions required by the Agreement for AH to perform its duties 

under the contract have occurred. 

58. AH materially breached its obligations to Nio by, inter alia, 1) arbitrarily 

failing to release his LP, despite Flow having determined that it was commercially 

satisfactory; 2) arbitrarily failing to release Nio’s music videos, despite Flow having 

determined they were commercially satisfactory; 3) maliciously disparaging Nio 

through AH’s social media accounts and the social media accounts of its principal, 

Ilianes Ruiz; and 4) failing to provide the periodic accountings required by the 

Agreement. 

59. These breaches have frustrated the purpose of the Agreement, insofar as 

they have fractured the parties’ relationship to a degree that working together to further 

Nio’s career is not feasible. 

60. These breaches have also made performance of the obligations set forth 

in the Agreement impossible, insofar as they have fractured the parties’ relationship to 

a degree that working together to further Nio’s career is not feasible.

61. There exists no adequate remedy at law to properly remedy the damages 

caused to Nio by AH’s breaches of the Agreement. 

WHEREFORE, Plaintiff demands judgment against AH rescinding the parties’ 

obligations and returning the parties to their condition prior to the execution of the 

Exclusive Recording Agreement, plus pre-judgment and post-judgment interest and 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 11 of 14
12

costs of this suit, and for such other and further relief as this Court deems just and 

proper.

COUNT III

Breach of Fiduciary Duty 

62. Plaintiff incorporates the allegations in paragraphs 1 through 47 as if fully 

set forth herein. 

63. Nio deposited his trust in AH and Flow to manage his career and grow 

his brand when he signed the Agreement in January 2021. 

64. Ilianes, as AH’s alleged principal and sucessor, has a fiduciary duty to 

act in the best interest of Nio, the artist AH represents. 

65. Ilianes has breached her fiduciary duty to Nio by, inter alia, 1) arbitrarily 

failing to release his LP, despite Flow having determined that it was commercially 

satisfactory; 2) arbitrarily failing to release Nio’s music videos, despite Flow having 

determined they were commercially satisfactory; 3) and maliciously disparaging Nio 

through AH’s social media accounts and her personal social media accounts of its 

principal, Ilianes Ruiz. 

66. These actions are contrary to Nio’s interests and work against his growth 

as a recording artist. 

67. Nio’s career is suffering irreparable harm as a result of Ilianes’ breaches 

of her fiduciary duty to Nio. 

WHEREFORE, Plaintiff demands judgment against AH for all his damages in 

an amount to be determined at trial, but no fewer than three million dollars 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 12 of 14
13

($3,000,000), plus pre-judgment and post-judgment interest and costs of this suit, and 

for such other and further relief as this Court deems just and proper.

COUNT IV

Plaintiff Requests AH be Placed into Temporary Receivership

68. Plaintiff incorporates the allegations in paragraphs 1 through 47 as if fully 

set forth herein. 

69. Plaintiff has a valid claim of breach of contract against AH, has valid 

allegations that Ilianes is unfit to lead AH, and has good reason to believe Ilianes has 

illegally seized control over AH’s affairs. 

70. There is a high probability that Ilianes has engaged in fraudulent conduct 

to place herself at the helm of AH’s affairs. 

71. If the Court fails to appoint a receiver, Ilianes will continue to act in a 

way that will irreparably harm Nio’s musical career. 

72. The typical legal remedies available to Plaintiff, such as damages and 

recission, are inadequate to address the imminent threat to Nio’s career. 

73. There is no less drastic equitable remedy that will ensure Nio’s career is 

not irreparably harmed by AH and Ilianes’ conduct. 

74. The appointment of a receiver will do more good than harm to AH’s 

affairs and to Plaintiff’s’ career, as it will ensure that a properly appointed individual, 

with AH’s and Plaintiff’s best interests in mind, will steward the company until such 

a time as the person with proper authority to act on AH’s behalf is determined by the 

Polk County probate court. 

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 13 of 14
14

WHEREFORE, Plaintiff requests the Court appoint a temporary Receiver to 

manage AH’s affairs until such time as the matter of who constitutes Flow’s estate is 

resolved.

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury trial on all his claims.

RESPECTFULLY SUBMITTED.

In Miami, Florida this September 8th, 2022.

 By: /s/Edwin Prado-Galarza 

Edwin Prado-Galarza, Esq.

PRADO LAW OFFICES, LLC

 513 W. Colonial Dr, Unit 5.

 Orlando, FL, 32804

 Tel. (407) 420-7926 / (787) 977-1411

 E-Mail: pradolaw10@gmail.com

 Florida Bar No. 1008115

and

Javier F. Micheo Marcial, Esq. (FBN 1009694)

javier.micheo@dmralaw.com

Juan C. Ramos-Rosado, Esq. (FBN 1002562)

juan.ramos@dmralaw.com

Manuel A. Franco, Esq. (FBN 126443)

manuel.franco@dmralaw.com

DMRA LAW LLC

1111 Brickell Avenue, Ste. 1550

Miami, FL 33131

Telephone: 305-548-8666

Case 1:22-cv-22858-KMM Document 1 Entered on FLSD Docket 09/08/2022 Page 14 of 14