COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

Case No. ________________

AFFORDABLE AERIAL PHOTOGRAPHY, INC.,

Plaintiff,

v.

PATRICK LETOURNEAU and DOUGLAS 

ELLIMAN FLORIDA, LLC,

Defendants.

COMPLAINT

Plaintiff Affordable Aerial Photography, Inc. (“Plaintiff”) sues defendants Patrick 

Letourneau (“Letourneau”) and Douglas Elliman Florida, LLC (“Douglas Elliman”) (collectively, 

the “Defendants”), and alleges as follows:

THE PARTIES

1. Plaintiff is a corporation organized and existing under the laws of the State of

Florida with its principal place of business located in Indian River County, Florida. 

2. Letourneau is an individual who is a citizen of the State of Florida residing at 801

S. Olive Avenue, Unit 828, West Palm Beach, FL 33401.

3. Douglas Elliman is a corporation organized and existing under the laws of the State

of Florida with its principal place of business located at 1111 Lincoln Road, Miami Beach, FL 

33139. Douglas Elliman’s agent for service of process is: CT Corporation System, 1200 South 

Pine Island Road, Plantation, FL 33324.

JURISDICTION AND VENUE

4. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 

9:22-cv-81078

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 1 of 31
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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

1331 and 1338(a).

5. This Court has personal jurisdiction over Defendants because they maintained 

sufficient minimum contacts with Florida such that the exercise of personal jurisdiction over them

would not offend traditional notions of fair play and substantial justice. Further, since at least 

2011, Douglas Elliman has operated a real estate business in this State and been licensed to do 

business in this State. Further, Letourneau is a licensed realtor in this State and, upon information 

and belief, owns real property in this State.

6. Venue properly lies in this district pursuant to 28 U.S.C. § 1400(a) because 

Defendants or their agents reside or may be found in this district. “A defendant ‘may be found’ 

in a district in which he could be served with process; that is, in a district which 

may assert personal jurisdiction over the defendant.” Palmer v. Braun, 376 F.3d 1254, 1259-60 

(11th Cir. 2004). “In other words, ‘if a court has personal jurisdiction over the defendants in a 

copyright infringement action, venue in that court’s district is proper.’” McGregor v. In Tune 

Music Grp., No. 15-62044-CIV-ZLOCH, 2016 U.S. Dist. LEXIS 190302, at *11 (S.D. Fla. July 

29, 2016) (quoting Store Decor Div. of Jas Int'l, Inc. v. Stylex Worldwide Indus., Ltd., 767 F. 

Supp. 181, 185 (N.D. Ill. 1991).

FACTS

I. Plaintiff’s Business and History

7. Plaintiff was created as a Florida corporation in June 2005. Plaintiff’s sole 

shareholder is Robert Stevens.

8. For the past sixteen (16) years, Mr. Stevens has been employed by Plaintiff as a 

high-end real estate photographer who specializes in aerial photography, stunning exterior and 

interior shots, as well as offering slide shows, virtual tours, and a full array of stock photography 

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 2 of 31
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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

for luxury real estate industries. 

9. Mr. Stevens is a pioneer of aerial real estate photography and has been engaging in 

creative and artistic means to capture such photographs long before today’s proliferation of 

consumer drone technology came to market. 

10. Mr. Stevens travels throughout the State of Florida, nationally, and internationally 

to photograph high-end real estate on behalf of Plaintiff’s clients. He has been contracted by over 

280 clients to take professional photographs of various real estate projects, including but not 

limited to the estates of numerous celebrities (such as Madonna, Don King, Greg Norman, Rod 

Stewart, Ivana Trump, James Patterson, Alexander Haig, Ann Downey, Frank McKinney, Chris 

Evert, and others). 

11. Plaintiff maintains a commercial website (www.robertstevens.com) which 

describes the photography services offered by Plaintiff, hosts a sample portfolio of photographs 

taken by Mr. Stevens, and invites prospective customers to contact Plaintiff to arrange for a 

professional photo shoot. 

12. Plaintiff owns the photographs taken by Mr. Stevens and serves as the licensing 

agent with respect to licensing such photographs for limited use by Plaintiff’s customers. To that 

end, Plaintiff’s standard terms include a limited, one-time license for use of any particular 

photograph by the customer only. Plaintiff’s license terms make clear that all copyright ownership 

remains with Plaintiff and that its customers are not permitted to transfer, assign, or sub-license 

any of Plaintiff’s photographs to another person/entity.

13. Generally, at the time Plaintiff creates its professional photography, it applies 

copyright management information to such photography consisting of “© AAP [year] all rights 

reserved” to the bottom left corner thereof. Plaintiff does this for added protection/assurance to 

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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

keep unauthorized persons from utilizing/displaying Plaintiff’s work. 

II. The Work at Issue in this Lawsuit

14. In 2013, Plaintiff created a photograph titled “Esplande Grande pool AAP 2013, 

Feb. 8, 2013” (the “Work”). Consistent with Plaintiff’s general practices, the Work contains (in 

the bottom left corner) Plaintiff’s copyright management information as follows: “© AAP 02-

08,2013.” A copy of the Work is exhibited below:

15. The Work was registered by Plaintiff with the Register of Copyrights on July 16, 

2015 and was assigned Registration No. VA 1-967-718. A true and correct copy of the 

Certification of Registration pertaining to the Work is attached hereto as Exhibit “A.”

16. Plaintiff is the owner of the Work and has remained the owner at all times material 

hereto.

III. Defendants’ Unlawful Activities

17. Letourneau is a real estate agent primiarly servicing Palm Beach County, Florida. 

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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

18. Douglas Elliman is a subsidiary of Douglas Elliman Inc. and/or Douglas Elliman 

Realty, LLC, the sixth largest residential real estate brokerage in the United States. The Douglas 

Elliman family of companies do business across the country and maintain a substantial presence in 

New York, Florida, California, Connecticut, Colorado, Massachusetts, Texas, Nevada, and New 

Jersey. 

19. Letourneau is either an employee of Douglas Elliman or serves as an independent 

contractor that is associated with Douglas Elliman. 

20. As of the date of this Complaint, Letourneau is identified on Douglas Elliman’s

website as a “Realtor Associate” (see https://www.elliman.com/florida/associate/510-adf20092815175266031/patrick-letourneau). 

21. Douglas Elliman, the broker for Letourneau, appears as listing broker on the real 

estate listing where Letourneau committed the violations of Plaintiff’s exclusive rights under the 

Copyright Act.

22. Douglas Elliman is liable for the infringement by Letourneau because a Florida real 

estate broker is liable for the torts of its agents, even if those agents are treated as “independent 

contractors.”

23. A person licensed as a real estate sales associate may not operate as a sales associate 

without a broker that is registered as her or his employer. Fla. Stat. § 475.42(1)(B). Moreover, the 

terms “employ,” “employment,” “employer,” and “employee” when used to describe the 

relationship between a broker like Douglas Elliman and Letourneau, include an independent 

contractor relationship when such relationship is intended by and established between a broker 

(Douglas Elliman) and a sales associate (Letourneau), and furthermore the existence of an 

independent contractor relationship shall not relieve the broker (Douglas Elliman) of its duties, 

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 5 of 31
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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

obligations, or responsibilities, which include being responsible for the offences of Letourneau. 

See Fla. Stat. § 475.01(2).

24. As a result, even if Douglas Elliman designates its agents as “independent 

contractors,” Letourneau is an “employee” under the Florida Real Estate Code and the common law 

of principal/agent in Florida, Douglas Elliman is vicariously liable for its agents’ acts committed in 

connection with and in furtherance of Douglas Elliman’s real estate brokerage business.

25. On or about March 11, 2022 (after Plaintiff’s registration of the Work with the 

Copyright Office), Defendants listed for sale the real property located at 201 S. Narcissus Avenue, 

Unit 403, West Palm Beach., FL 33401 (the “Property”).

26. In doing so, Defendants created and published a Multiple Listing (MLS#: RX10784036) to market and sell the subject Property (the “MLS Listing”). 

27. Relevant hereto, the MLS Listing includes therein a copy of the Work amongst the 

various photographs selected by Defendants to market the Property, and all such photographs 

(including the copy of the Work) were then published and viewable across multiple websites 

(including www.realtor.com):

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 6 of 31
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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

28. A true and correct copy of screenshots of the MLS Listing and the third-party 

websites, displaying the copyrighted Work, is attached hereto as Exhibit “B.”

29. Defendants are not and have never been licensed to use or display the Work. 

Defendants never contacted Plaintiff to seek permission to use the Work in connection with the 

aforementioned MLS Listing– even though the Work that was copied clearly displays Plaintiff’s 

copyright management information and put Defendants on notice that the Work was not intended 

for public use. 

30. Defendants utilized the Work for commercial use – namely, in connection with 

their attempt to sell the Property. 

31. Through its ongoing diligent efforts to identify unauthorized use of its photographs, 

Plaintiff discovered Defendants’ unauthorized use/display of the Work in June 2022. Following 

Plaintiff’s discovery, Plaintiff notified Defendants in writing of such unauthorized use. To date, 

however, Plaintiff has been unable to negotiate a reasonable license for the past infringement of 

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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

its Work. 

32. All conditions precedent to this action have been performed or have been waived.

COUNT I – COPYRIGHT INFRINGEMENT

(All Defendants)

33. Plaintiff re-alleges and incorporates paragraphs 1 through 32 as set forth above.

34. The Work is an original work of authorship, embodying copyrightable subject 

matter, that is subject to the full protection of the United States copyright laws (17 U.S.C. § 101 et 

seq.). 

35. Plaintiff owns a valid copyright in the Work, having registered the Work with the 

Register of Copyrights and owning sufficient rights, title, and interest to such copyright to afford 

Plaintiff standing to bring this lawsuit and assert the claim(s) herein. 

36. As a result of Plaintiff’s reproduction, distribution, public display, and/or prior 

licensing of the Work, Defendants had access to the Work prior to their own reproduction, 

distribution, and public display of the Work on the MLS Listing for the Property.

37. Defendants reproduced, distributed, and publicly displayed the Work without 

authorization from Plaintiff. 

38. By their actions, Defendants infringed and violated Plaintiff’s exclusive rights in 

violation of the Copyright Act, 17 U.S.C. § 501, by reproducing, distributing, and publicly 

displaying the Work for their own commercial purposes. 

39. Alternatively, to the extent Douglas Elliman did not directly infringe Plaintiff’s 

rights in the Work, Douglas Elliman is liable for vicarious infringement.

40. As Letourneau’s employer and the broker responsible for the subject MLS Listing, 

Douglas Elliman has the right and ability to control the infringing acts of Letourneau yet declined 

or failed to stop Letourneau from engaging in his infringing activity. Indeed, Letourneau could 

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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

not have published the subject MLS Listing without the approval and consent of his supervising 

broker (Douglas Elliman). 

41. Defendants’ infringement was willful as they acted with actual knowledge or 

reckless disregard for whether its conduct infringed upon Plaintiff’s copyright. As a licensed real 

estate broker and a real estate brokerage, Defendants clearly understand that high-end 

photography – especially that containing copyright management information such as the Work –

is generally paid for and cannot simply be copied from the internet. Further, Douglas Elliman’s 

willfulness is likewise established by the fact that Plaintiff previously sued Douglas Elliman for 

copyright infringement in 2020. See Affordable Aerial Photography, Inc. v. Douglas Elliman 

Florida, LLC et al., Case No.: 9:20-cv-81985 (S.D. Fla.). Notwithstanding that lawsuit, Douglas 

Elliman has failed to put in place policies or protocols to stop infringement (such as the one at 

issue in this lawsuit) from taking place. 

42. Plaintiff has been damaged as a direct and proximate result of Defendants’

infringement.

43. Plaintiff is entitled to recover its actual damages resulting from Defendants’

unauthorized use of the Work and, at Plaintiff’s election (pursuant to 17 U.S.C. § 504(b), Plaintiff 

is entitled to recover damages based on a disgorgement of Defendants’ profits from infringement 

of the Work, which amounts shall be proven at trial. 

44. Alternatively, and at Plaintiff’s election, Plaintiff is entitled to statutory damages 

pursuant to 17 U.S.C. § 504(c), in such amount as deemed proper by the Court. 

45. Pursuant to 17 U.S.C. § 505, Plaintiff is further entitled to recover its costs and 

attorneys’ fees as a result of Defendants’ conduct. 

46. Defendants’ conduct has caused and any continued infringing conduct will continue 

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COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

to cause irreparable injury to Plaintiff unless enjoined by the Court. Plaintiff has no adequate 

remedy at law. Pursuant to 17 U.S.C. § 502, Plaintiff is entitled to a permanent injunction 

prohibiting infringement of Plaintiff’s exclusive rights under copyright law. 

WHEREFORE, Plaintiff demands judgment against Defendants as follows: 

a. A declaration that Defendants have infringed Plaintiff’s copyrights in the Work;

b. A declaration that such infringement is willful;

c. An award of actual damages and disgorgement of profits as the Court deems proper or, at

Plaintiff’s election, an award of statutory damages for willful infringement up to

$150,000.00 for each infringement of the Work;

d. Awarding Plaintiff its costs and reasonable attorneys’ fees pursuant to 17 U.S.C. § 505;

e. Awarding Plaintiff interest, including prejudgment interest, on the foregoing amounts;

f. Permanently enjoining Defendants, their employees, agents, officers, directors, attorneys,

successors, affiliates, subsidiaries and assigns, and all those in active concert and

participation with Defendants, from directly or indirectly infringing Plaintiff’s copyrights

or continuing to display, transfer, advertise, reproduce, or otherwise market any works

derived or copied from the Work or to participate or assist in any such activity; and

g. For such other relief as the Court deems just and proper.

Demand For Jury Trial

Plaintiff demands a trial by jury on all issued so triable. 

Dated: July 24, 2022. 

COPYCAT LEGAL PLLC

3111 N. University Drive

Suite 301

Coral Springs, FL 33065

Telephone: (877) 437-6228

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 10 of 31
11

COPYCAT LEGAL PLLC

3111 N. UNIVERSITY DRIVE, SUITE 301 • CORAL SPRINGS, FL 33065

TELEPHONE (877) 437-6228

dan@copycatlegal.com

james@copycatlegal.com

lauren@copycatlegal.com

By: /s/ Daniel DeSouza, Esq.______

Daniel DeSouza, Esq.

Florida Bar No.: 19291

James D’Loughy, Esq.

Florida Bar No.: 0052700

Lauren Hausman, Esq.

Florida Bar No.: 1035947

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 11 of 31
Exhibit “A”

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 12 of 31
Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 13 of 31
Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 14 of 31
Exhibit “B”

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 15 of 31
Area: 5420 Geo Area: PB20 County: Palm Beach

Legal Desc: ESPLANADE GRANDE CONDOMINIUM UNIT 403

Subdivision: ESPLANADE GRANDE CONDO

Development Name:

Model

Name:

Waterfront: No

Lot SqFt:

HOPA:

No

Hopa

Zoning: FWD-5(

Gated

Community: No

Parcel ID: 74434322350044030

Waterfrontage:

Multiple Ofrs Acptd:

Taxes: 30,904.2

Tax Year: 2021

Special Assessment: No

Dock:

Membership Fee

Required: No

Front Exp: East

Garage Spaces: 2

Carport Spaces:

Total Covered

Spaces: 2

Private Pool: No

REO: No

Short Sale

Addendum: No

Short Sale: No

Owner/Agent: No

Virtual Tour: Click to View Virtual Tour

Dining Room 13 X14

Kitchen 12 X13

Living Room 20 X17.6

Family Room 17 X12

Other Room 13 X14

Bedroom 2 12 X16

Bedroom 3 17 X11

Master Bedroom 19 X16

LivSqFt: 3,002

SqFt - Total: 3,600

SqFt Source: Floor Plan

Yr Built: 2004

Builder Name:

Property Condition: Resale

Pets Allowed:Restricted

Total Bedrooms: 3

Main Level Bedrooms: 3

Baths - Full: 5

Baths - Half: 0

Baths - Total: 5

Main Level Baths: 5

HOA/POA/COA (Monthly): 2,116.75

Governing Bodies: HOA

Homeowners Assoc: Mandatory

Lease Times p/Year:

Application Fee: 100

Capital Contribution:

Capital Contribution Amount:

Bldg #:

Total Floors/Stories: 16

Total Units in Bldg: 60

Ttl Units in Complex:

Unit Floor #: 4

Membership Fee Amount:

Land Lease:

Recreation Lease:

Min Days to Lease:

Assoc Contact Phone:

Assoc Website:

Association Deposit: No

Mobile Home Size:

Decal #:

Serial #:

Brand Name:

Total Assessed Value:

Auction: No

Directions: Traveling south on Flagler, make a right on Datura and a left on Narcissus. Building is on corner. Valet available

Showing Instructions: Appointment Only; Call Listing Agent; LA Must Accompany; Pets on Premises

LO: pb802465 Douglas Elliman (Palm Beach) 561-655-8600

LM: 470501566 Patrick Letourneau 561-568-4688 patrick.letourneau@elliman.com

Com/BuyerAgt: 3% Comm/Non-Rep: $100 Trans Brk: 3% Bonus: No LD: 03/11/2022

Var/Dual Rate: No List Type: Ex Brk List Off Agency: Transaction Broker

Owner Name: WITHHELD

Broker Only Remarks: Please call/text Patrick with questions. Truly unique apartment to experience. Lives like a large home. Private elevator, 3 bedroom, 5

bathroom (his and her primary baths) plus media room. Soaring ceiling heights, multiple entertaining areas. Full service building with new lobby and building

exterior paint. This is an amazing boutique building. Perfect for an exceptional art collection/ entertainment

Any Broker Advertise: No

Design:

Construction: Concrete

Unit Desc:

Flooring: Marble

Furnished: Furniture Negotiable

Dining Area:

Master Bedroom/Bath: 2 Master Baths

Porch/Patio/Balcony: Balcony

Lot Description: East of US-1; Corner Lot

Storm Protection: Impact Glass: Complete

Restrict: Buyer Approval; Interview Required; Lease OK w/Restrict

Rooms: Family; Great; Laundry-Util/Closet; Media; Storage

View: City; Garden; Intracoastal

Waterfront Details: Intracoastal

Cooling: Central

Heating: Central

Security: Doorman; Gate - Manned; Lobby

Utilities: Public Sewer; Water Available

Special Info:

Terms Considered: Cash; Conventional

Parking: 2+ Spaces

Taxes: City/County

Equestrian Features:

Laundry Appliances Included: Washer and Dryer

Equip/Appl:Dishwasher; Dryer; Freezer; Range - Electric; Refrigerator; Washer; Washer/Dryer Hookup

SubdivInfo:Community Room; Elevator; Fitness Center; Manager on Site; Pool; Spa-Hot Tub; Whirlpool

Interior:None

Maintenance Fee Incl: Common Areas; Insurance-Bldg

Original List Price: $3,400,000

Days On Market: 84 Cumulative DOM: 84

Sold Price: Sold Price Sqft: Under Contract Date:

Buyer Office: Terms of Sale: Sold Date:

Buyer Agent:

Co-Buyer Office: Buyer Contributions Amount: Seller Concessions Amount:

Co-Buyer Agent:

Public Remarks:A rare offering in top level boutique building. 403 is an exceptionally large apartment featuring three bedrooms, five bathrooms, an extended

terrace and soaring ceilings heights. This is ideal for an art collector and entertaining. Master suite features corner south east exposure with access to the terrace

and two master bathrooms The second guest suite features a west exposure terrace with access to tranquil spa and club level amenities. An amazing layout with

dining room and numerous ''Feature walls'' ready for art and decor. Luxurious flooring, kitchen finishes and light fixtures add to the high ceilings and bright natural

light. The Esplanade Grande features only 60 apartments each with private elevator entrances, luxurious rooftop pool and spa. Valet parking & concierge service

Information is deemed to be reliable, but is not guaranteed. © 2022 MLS and FBS. Prepared by Mateusz Rymarski on Thursday, June 16, 2022 10:48 AM. The information

on this sheet has been made available by the MLS and may not be the listing of the provider.
History for MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

+ MLS # Status Price % Change Date DOM CDOM Address

- RX-10784036 Active $3,750,000 134.4% 04/01/2022 84 84

201 S

Narcissus

Avenue

403

- Price Change $3,750,000 10.3% 04/12/2022 65

Change by: Lauren Lerma

Change at 4:18 PM Eastern: changed List Price

Old Value: 3400000.00

New Value: 3750000.00

- Status $3,400,000 04/01/2022 76

Change by: Lauren Lerma

Change at 12:14 PM Eastern: changed Status

Old Value: Temp Off Market

New Value: Active

- Photos, etc. $3,400,000 04/01/2022 76

Change by: Lauren Lerma

Change at 12:14 PM Eastern: Listing put back on market

Change at 12:14 PM Eastern: changed Fallthrough Date

Old Value:

New Value: 4/1/2022

Change by: Patrick Letourneau

Change at 12:00 PM Eastern: changed Public Remarks

Old Value: coming soon

New Value: A rare offering in top level b

Change at 12:00 PM Eastern: changed Broker Only Remarks

Old Value: Photos coming soon. Please call/text Patrick with questions. Truly

unique apartment to experience. Lives like a large home. Private elevator, 3

bedroom, 5 bathroom (his and her primary baths) plus media room. Soaring

ceiling heights, multiple entertaining areas. Full service building with new lobby

and building exterior paint. This is an amazing boutique building. Perfect for an

exceptional art collection/ entertainment

New Value: Please call/text Patrick with

Change at 10:49 AM Eastern: Added photo "07_201SNarcissus"

Change at 10:46 AM Eastern: Added photo "10_201SNarcissus"

Change at 10:44 AM Eastern: Added photo "08_201SNarcissus"

Change at 10:42 AM Eastern: Added photo "09_201SNarcissus"

Change at 10:40 AM Eastern: Added photo "05_201SNarcissus"

Change at 10:40 AM Eastern: Added photo "06_201SNarcissus"

Change at 10:39 AM Eastern: Added photo "04_201SNarcissus"

Change at 10:39 AM Eastern: Added photo "23_201SNarcissus"

Change at 10:38 AM Eastern: Added photo "25_201SNarcissus"

Change at 10:37 AM Eastern: Added photo "03_201SNarcissus"

Change at 10:37 AM Eastern: Added photo "24_201SNarcissus"

Change at 10:36 AM Eastern: Added photo "02_201SNarcissus"

Change at 10:35 AM Eastern: Added photo "22_201SNarcissus"

Change at 10:35 AM Eastern: Added photo "21_201SNarcissus"

Change at 10:34 AM Eastern: Added photo "01_201SNarcissus"

Change at 10:33 AM Eastern: Added photo "20_201SNarcissus"

Change at 10:32 AM Eastern: Added photo "19_201SNarcissus"

Change at 10:32 AM Eastern: Added photo "15_201SNarcissus"

Change at 10:31 AM Eastern: Added photo "16_201SNarcissus"

Change at 10:30 AM Eastern: Added photo "11_201SNarcissus"

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 17 of 31
Change at 10:30 AM Eastern: Added photo "14_201SNarcissus"

Change at 10:29 AM Eastern: Added photo "18_201SNarcissus"

Change at 10:28 AM Eastern: Added photo "12_201SNarcissus"

Change at 10:28 AM Eastern: Added photo "13_201SNarcissus"

Change at 10:28 AM Eastern: Added photo "17_201SNarcissus"

- Status $3,400,000 03/24/2022 84

Change by: Lauren Lerma

Change at 3:49 PM Eastern: changed Status

Old Value: Active

New Value: Temp Off Market

- Temp Off Market Date $3,400,000 03/24/2022 84

Change by: Lauren Lerma

Change at 3:49 PM Eastern: changed Temp Off Market Date

Old Value:

New Value: 3/24/2022

- New $3,400,000 03/17/2022 91

Change by: Property Panorama

Change at 6:21 AM Eastern: changed Unbranded Tour

Old Value:

New Value: Add

Change by: BeachesMLS, Inc.

Change at 3:15 AM Eastern: Added new listing

- Status $3,400,000 03/17/2022 91

Change by: BeachesMLS, Inc.

Change at 3:15 AM Eastern: changed Status

Old Value: Coming Soon

New Value: Active

- Coming Soon $3,400,000 03/15/2022 93

Change by: Patrick Letourneau

Change at 3:38 PM Eastern: changed photographer

Old Value:

New Value: Removed

Change at 3:38 PM Eastern: changed Coming Soon

Old Value: New Coming Soon Listing

New Value: New Coming Soon Listing

- Primary_picture $3,400,000 03/13/2022 94

Change by: Patrick Letourneau

Change at 8:05 PM Eastern: Changed primary photo

- RX-10389181 Closed $1,600,000 -1.5% 10/12/2018 252 252

201 S

Narcissus

Avenue

403

- Status $1,750,000 10/12/2018

Change by: Julie DeCoste

Change at 4:10 PM Eastern: changed Status

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 18 of 31
Old Value: Pending

New Value: Closed

- Terms of Sale $1,750,000 10/12/2018

Change by: Julie DeCoste

Change at 4:10 PM Eastern: changed Buyer Agent

Old Value:

New Value: Christine Erika Dekant

Change at 4:10 PM Eastern: changed Sold Date

Old Value:

New Value: 10/11/2018

Change at 4:10 PM Eastern: changed Sold Price

Old Value:

New Value: 1600000.00

Change at 4:10 PM Eastern: changed Terms of Sale

Old Value:

New Value: Cash

- Status $1,750,000 08/27/2018

Change by: Julie DeCoste

Change at 10:04 AM Eastern: changed Status

Old Value: Active

New Value: Pending

- Under Contract Date $1,750,000 08/27/2018

Change by: Julie DeCoste

Change at 10:04 AM Eastern: changed Contingency

Old Value:

New Value: B

Change at 10:04 AM Eastern: changed Under Contract Date

Old Value:

New Value: 8/24/2018

- Virtual Tour, etc. $1,750,000 07/30/2018 25

Change by: Lisa A McKeon

Change at 10:22 AM Eastern: Changed Virtual Tour

Change at 10:22 AM Eastern: Changed Virtual Tour Unbranded

Change at 10:22 AM Eastern: Added Virtual Tour

Change at 10:22 AM Eastern: Added Virtual Tour Unbranded

Change at 10:21 AM Eastern: changed video_unbranded

Old Value: list_media

New Value: add

Change at 10:17 AM Eastern: Removed Virtual Tour

Change at 10:17 AM Eastern: Removed Virtual Tour Unbranded

Change at 10:16 AM Eastern: changed video

Old Value: list_media

New Value: remove

Change at 10:16 AM Eastern: Changed Virtual Tour

Change at 10:16 AM Eastern: Changed Virtual Tour Unbranded

Change at 10:16 AM Eastern: Changed Virtual Tour

Change at 10:16 AM Eastern: Changed Virtual Tour Unbranded

Change at 10:15 AM Eastern: Changed Virtual Tour

Change at 10:15 AM Eastern: Changed Virtual Tour Unbranded

Change at 10:15 AM Eastern: changed video_unbranded

Old Value: list_media

New Value: add

Change at 10:13 AM Eastern: changed video

Old Value: list_media

New Value: remove

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 19 of 31
Change at 10:12 AM Eastern: Added Virtual Tour

Change at 10:12 AM Eastern: Added Virtual Tour Unbranded

Change at 10:04 AM Eastern: changed video_unbranded

Old Value: list_media

New Value: add

- Photos $1,750,000 07/23/2018 32

Change by: Lisa A McKeon

Change at 10:30 AM Eastern: Added photo "LMT06"

Change at 10:29 AM Eastern: Added photo "LMT05"

Change at 10:29 AM Eastern: Added photo "LMT04"

Change at 10:29 AM Eastern: Added photo "LMT03"

Change at 10:29 AM Eastern: Added photo "LMT02"

Change at 10:29 AM Eastern: Added photo "LMT01"

- Extension $1,750,000 06/13/2018 72

Change by: Julie DeCoste

Change at 3:24 PM Eastern: Extended listing

- Expiration Date $1,750,000 06/13/2018 72

Change by: Julie DeCoste

Change at 3:24 PM Eastern: changed Expiration Date

- Open House $1,750,000 06/02/2018 83

Change by: Lisa A McKeon

Change at 12:28 PM Eastern on 06/02/2018: This Open House was Added.

- Price Change $1,750,000 -6.7% 05/01/2018 115

Change by: Julie DeCoste

Change at 10:05 AM Eastern: changed List Price

Old Value: 1875000.00

New Value: 1750000.00

- Text, etc. $1,875,000 03/10/2018 167

Change by: Lisa A McKeon

Change at 10:59 AM Eastern: changed Public Remarks

Old Value: One of a kind 3 bedroom 5 bath. Private elevator opens into your

private foyer where you are met with architectural details that follow you thru out

this one of a kind residence. The foyer features a Lumicast mural featuring a

Japanese Seagrass which begins your journey thru zen and a tranquil

environment. As you open the double door entry you are introduced to the

soaring 14 foot ceilings which are only featured on this floor. There are many

ceiling details and niches that allow you to showcase your art collection. The

light fixture in the residence dining area was specially commissioned by a New

York artist CeC LePage. lepagny.com. The home is complimented by

spectacular views of the Intracoastal, Palm Beach and the Ocean. Oh and did I

mention the walkability to all of Downtown

New Value: One of a kind 3 bedroom 5 bath

- Price Change $1,875,000 -3.8% 02/13/2018 192

Change by: Julie DeCoste

Change at 11:47 AM Eastern: changed List Price

Old Value: 1950000.00

New Value: 1875000.00

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 20 of 31
- Tour $1,950,000 01/31/2018 205

Change by: Julie DeCoste

Change at 10:43 AM Eastern on 01/31/2018: This Tour was Added.

- Text, etc. $1,950,000 12/19/2017 248

Change by: Lisa A McKeon

Change at 9:15 AM Eastern: changed Public Remarks

Old Value: One of a kind 3 bedroom 5 bath. Private elevator opens into your

private foyer where you are met with architectural details that follows you thru

out this one of a kind residence. The foyer features a Lumicast mural featuring a

Japanese Seagrass which begins your journey thru zen and a tranquil

environment. As you open the double door entry you are introduced to the

soaring 14 foot ceilings which are only featured on this floor. There are many

ceiling details and niches that allow you to showcase your art collection. The

light fixture in the residence dining area was specially commissioned by a New

York artist CeC LePage. lepagny.com. The home is compliments by spectacular

views of the Intracoastal, Palm Beach and the Ocean. Oh and did I mention the

walkability to all of Downtown

New Value: One of a kind 3 bedroom 5 bath

- Approved By MLS $1,950,000 12/15/2017 252

Change by: Julie DeCoste

Change at 12:32 PM Eastern: Removed photo

Change at 12:32 PM Eastern: Listing approved by the MLS

Change at 12:32 PM Eastern: Listing approved

- Photos $1,950,000 12/14/2017 253

Change by: Raushan J Hasan

Change at 11:49 AM Eastern: Added photo "21_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "20_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "19_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "18_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "17_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "16_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "15_201SNarcissus"

Change at 11:49 AM Eastern: Added photo "14_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "13_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "12_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "11_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "10_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "09_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "08_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "07_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "06_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "05_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "04_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "03_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "02_201SNarcissus"

Change at 11:48 AM Eastern: Added photo "01_201SNarcissus"

- New $1,950,000 12/13/2017 254

Change by: Julie DeCoste

Change at 11:09 AM Eastern: Added new listing

- RX-3129334 Expired $1,625,000 10.2% 08/02/2011 364 364

201 S

Narcissus

Avenue

403

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 21 of 31
- Status $1,625,000 08/02/2011

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Expired

- Status $1,625,000 08/01/2011 0

Change by: Tim K Harris

Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Expired

- Status $1,625,000 06/21/2011 41

Change by: Tim K Harris

Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Withdrawn

- New $1,625,000 08/02/2010 364

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: Added new listing

- RX-3083659 Cancelled $1,475,000 -20.3% 04/02/2010 61 61

201 S

Narcissus

Avenue

403

- Status $1,475,000 04/02/2010 0

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Cancelled

- Price Change $1,475,000 -14.5% 02/19/2010 42

Change by: Tim K Harris

Change at 1:24 PM Eastern: changed List Price

Old Value:

New Value: 1475000

- New $1,725,000 01/31/2010 61

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: Added new listing

- RX-3000420 Expired $1,850,000 08/20/2009 175 175

201 S

Narcissus

403

- Status $180,000 08/20/2009

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Expired

- Status $180,000 08/19/2009 0

Change by: Tim K Harris

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 22 of 31
Change at 1:00 AM Eastern: changed Status

Old Value:

New Value: Expired

- Price Change $180,000 -90.3% 05/22/2009 89

Change by: Tim K Harris

Change at 1:28 PM Eastern: changed List Price

Old Value:

New Value: 180000

- Price Change $1,850,000 -5.1% 05/22/2009 89

Change by: Tim K Harris

Change at 1:28 PM Eastern: changed List Price

Old Value:

New Value: 1850000

- Price Change $1,950,000 5.4% 05/22/2009 89

Change by: Tim K Harris

Change at 1:28 PM Eastern: changed List Price

Old Value:

New Value: 1950000

- Price Change $1,850,000 -5.1% 05/22/2009 89

Change by: Tim K Harris

Change at 1:28 PM Eastern: changed List Price

Old Value:

New Value: 1850000

- New $1,950,000 02/25/2009 175

Change by: BeachesMLS, Inc.

Change at 1:00 AM Eastern: Added new listing

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 23 of 31
Photos for MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

Esplande Grande Exterior Entry way

Private elevator entry Double door foyer

Entry Way Wall Feature

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 24 of 31
MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

Den Den/ family room

Dining room Expansive kitchen

Kitchen Kitchen with Dining area

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 25 of 31
MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

Kitchen into Den Open Airy Layout

Dining area Living Room

Living Room with Terrace Living Room opens to extended Terrace

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 26 of 31
MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

Master Suite Exceptional Master

Office/Bedroom Office Bedroom with Terrace access

Guest Bedroom Guest Bedroom with Terrace

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 27 of 31
MLS # RX-10784036 201 S Narcissus Avenue 403, West Palm Beach, FL 33401 $3,750,000

Extended Terrace Large extended terrace

Direct east Pool Overlooking PBI

403 Floorplan

Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 28 of 31
Contact Agent Save Buy Share Sell Rent Hide Mortgage Find Realtors My Home News & Insights Manage rentals Advertise Log in Sign up 

Back Florida Palm Beach County West Palm Beach 201 S Narcissus Ave Apt 403 

Presented by: Patrick Letourneau 

Brokered by: Douglas Elliman - Palm Beach 

More about this property 

I have served in the U.S. Military. 

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number you provided, including marketing by autodialer and 

prerecorded and artificial voice, and email, from realtor.com 

and others about your inquiry and other home-related For Sale 

matters, but not as a condition of any purchase; this applies 

regardless of whether you check, or leave un-checked, any $3,750,000 Est. $22,849 /mo box above. More... 

3 bed 5 bath 3,002 sqft 

Street 201 S Narcissus Ave Apt 403, West Palm Beach, FL 33401 View 

Condo 70 Days $2160/mo 

Property Type Time on realtor.com HOA Fees Commute Time: Add a commute 

$1249 2004 

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Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 29 of 31
Learn more about 201 S Narcissus Ave Apt 403 

Ask a question 

I have served in the U.S. Military. 

Get pre-approved by a lender. 

Email Agent 

By proceeding, you consent to receive calls and texts at the number you 

provided, including marketing by autodialer and prerecorded and artificial 

voice, and email, from realtor.com and others about your inquiry and other 

home-related matters, but not as a condition of any purchase; this applies 

regardless of whether you check, or leave un-checked, any box above. 

More... 

Presented by : Broker Location: Palm Beach, FL 

Patrick Letourneau 

# SL3478161 Data Source: PalmBeachFL 

Brokered by : Source's Property ID: 22-608 

Douglas Elliman - Palm Beach ©2022 Palm Beach Board of REALTORS®. All rights Data Source Copyright: reserved. (561) 655-8600 

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Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 30 of 31
Additional Information About 201 S Narcissus Ave Apt 403, West Palm Beach, FL 33401 

201 S Narcissus Ave Apt 403, West Palm Beach, FL 33401 is a condo for sale listed on the market for 71 days. 201 S Narcissus Ave Apt 403, West Palm Beach, FL 33401 is in the Southend neighborhood, which has a 

median listing home price of $899500. The schools near 201 S Narcissus Ave Apt 403, include U. B. Kinsey/Palmview Elementary School , Conniston Middle School and Forest Hill Community High School . 

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Case 9:22-cv-81078-AMC Document 1 Entered on FLSD Docket 07/24/2022 Page 31 of 31