UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE No. 22-CV-22862-Williams

MIRACLE LIFE FARM LLC, a Florida 

limited liability company, 

Plaintiff,

Vs.

HIALEAH TOMATOES AND FRESH 

PRODUCE, INC., a Florida corporation; 

and JORGE GONZALEZ, an individual,

Defendants;

EASTERN NATIONAL BANK,

Garnishee,

_______________________________________/

ANSWER OF GARNISHEE

COMES NOW Garnishee, EASTERN NATIONAL BANK, through its undersigned 

attorney, and hereby answers the Writ of Garnishment served on January 4, 2023, by Plaintiff in this 

action, as follows:

1. At the time of this Answer and at the time of the service of the Writ, and at all

times between those periods, Garnishee, EASTERN NATIONAL BANK, was not indebted (zero 

dollars) to Defendant, HIALEAH TOMATOES AND FRESH PRODUCE, INC., for any sum of 

money because Defendant, HIALEAH TOMATOES AND FRESH PRODUCE, INC have two loans 

with a principal and interest balance of $3,290,759.43 as of January 4, 2023, that were in default

prior to January 4, 2023, pursuant to the terms of the Promissory Notes. Therefore Garnishee, 

EASTERN NATIONAL BANK claims a set-off for all funds in the two checking accounts of 

Case 1:22-cv-22862-KMW Document 24 Entered on FLSD Docket 01/06/2023 Page 1 of 3
Defendant, HIALEAH TOMATOES AND FRESH PRODUCE, INC., which contained the 

aggregate amount of $32,031.79, in both accounts as of the time of filing of this Answer. 

2. At the time of this Answer and at the time of the service of the Writ, and at all times

between those periods, Garnishee, EASTERN NATIONAL BANK, had no other goods, money, 

chattels, effects, or other tangible or intangible property of Defendant in its possession or control.

3. Garnishee EASTERN NATIONAL BANK, knows of no person who may be

indebted to or who has possession or control of any tangible or intangible personal property of 

Defendant.

4. Garnishee has retained the undersigned attorneys to represent its interest in this matter 

and is obligated to pay them reasonable attorneys’ fees for their services herein. Garnishee requests 

the Clerk to disburse the $100.00 attorneys’ fee deposited by Plaintiff pursuant to Florida Statute §

77.28, or any larger amount as reasonably expended by the Garnishee pursuant to Florida Statute §

77.28 and demands judgment for all additional costs and attorneys’ fees incurred in this proceeding 

against the party liable.

Respectfully Submitted,

The Law Offices of 

Carrillo & Carrillo, P.A. 

Attorney for Garnishee

1313 Ponce de Leon Boulevard

Suite 300

Coral Gables, FL 33134

(T): 305-460-6001

(F): 305-460-6002

fcarrillo@carrillolawyers.com

lcarrillo@carrillolawyers.com

_/s/ Felix R. Carrillo___

Felix R. Carrillo, Esq.

FLORIDA BAR NO. 957460

Case 1:22-cv-22862-KMW Document 24 Entered on FLSD Docket 01/06/2023 Page 2 of 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 6, 2023, I electronically filed the foregoing document 

with the Clerk of the Court using the CM/ECF, which should automatically serve Karel Suarez, Esq., 

ksuarez@legalteamservices.com, The Legal Team, PLLC, Counsel for Plaintiff/Garnishor, 1815 SW 

85th Court, Miami, FL 33155.

Case 1:22-cv-22862-KMW Document 24 Entered on FLSD Docket 01/06/2023 Page 3 of 3