COMPOSITE

EXHIBIT A

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 1 of 42
MIAMI.DADE C(IUNTY CTERK (lF THE C(IURTS

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CIVIL. FAMILY AND PROBATE COURTS ONTINE SYSTEM

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JOSE PERAZA VS Et DORADO FURNITURE CORPORATION ET AILotalCase Number: 2022-017450-CA-01

StateCase Number: 132022CA017450000001

Consolidated Case No,: N/A

Cas Status: OPEN

I Parties

Party Description Party Name

Plaintiff PEMZA, JOSE

Defendant

Defendant

EL DORADO FURNITURE CORPOMTION

CAPO, LUIS

r\, Hearing Details

N Dockets

FllingDate: 09/11/2022

Judlcial Sectlon: CA21

Case flpe: Discrimination - Employment or Other

Total Of Parties: 3 -

Attorney lnformation Other Attorney(S)

F"#-i...IHer..Nu-mhsil533637

N;..,GttA[n.Fy.NAmg)Anthony M Georges-Pierre

Total Of Hearings: 0 *

Total Of Dockets:18 -

Event

Type Comments

UNOPPOSED ORDER ON DEFENDANTS' UNOPFOSED MOTION FOR

EXTENSION OF TIME TO RESPOND TO PTAINTIFF'S COMPTAINT

Event

Event

Docket

Booly'Page Entry

t17

f16

t1s

t14

f13

t12

Number Date

10/19/2022

10/19/?022

10/18/2022

10/18/2022

10/11/2022

10/11/2022

Notice of Event

Appearance

Notice of Event

Appearance

Motion for

Extension

of Time

Event

Order Event

Extending

Time for

Notice of

Change of

Firm Name

Affidavit of

Seruice

Affidavit of

Service f11 10/11/?022 Event

1t3

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 2 of 42
Docket Event

Number Date Booly'Page Entry Type Comments

f10 10/11/2022 Order Event

Setting CM

Deadline

09/21/2022 Receipt: Event RECEIPT#?3070191 AMT PAID:$2O.00 NAMEANTHONY M GEORGES-PIERRE

rl4 W FLAGLER ST STE 2200 MIAMI Ft 33130-5807 COMMENT

ArrocATtoN coDE QUANT|TY UN|T AMOUNT 313g-SUMMONS TSSUE FEE

1 $10.00 $10.00 3139-suMMoNs rssuE FEE 1 $10,00 il0.00 TENDER

TYPE:EFI tl NGS TEN D ER AMn$20.00 RECETVJ O Al Efig | 21 | 2022

REGISTER#:307 CASHIE&EFILINGUSER

09/20/2022 20Day

Summons

lssued

Service

f8 09/20/2022 ESummons Event RE: INDEX # 6.

20 Day Parties: CAPO LUIS

lssued

09/20/2022 20 Day

Summons

lssued

Service

f

09/20/2022 ESummons

20 Day

lssued

Event RE: INDEX # 5.

Parties: EL DORADO FURNITURE CORPORATION

f6 09/20/2022 (M) 20 Day

(P)

Summons

(sub)

Received

Event

fs 09/20/2022 (M) 20 Day

(c)

Summons

(Sub)

Received

Event

09/16/2022 Receipt: Event RE€EIPT#:3070345 AMT PAID:$.OI,00 NAMEANTHONY M GEORGESPIERRE 44 W FLAGTER ST STE 22OO MIAMI FL 33130.6807 COMMENN

AttocATloN coDE QuANTtw uNrT AMOUNT tloo-CtRCUtT FtLtNG FEE I

$401.0O i401.0O TENDER TYPE:EFltlNGS TENDERAMT:i.101,0O RECEIPT

DAI E O9l 1 61 2022 REGISTER#330? CASH IER:EFltl NGUSER

f2 09/11/2022 Complaint Event

09/11t2022 Civil Cover

Sheet -

Claim

Amount

Event

{( lrA,cK

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Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 3 of 42
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Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 4 of 42
Filing # 157151852 E-Filed 0911112022 12:01:25 PM

FORM I.997. CIVI COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing

and service of pleadings or other documents as required by law. This form must be filed by the

plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant

to section 25.075, Florida Statutes. (See instructions for completion.)

I. CASE STYLE

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

JOSE PERAZA

Plaintiff Case #

Judge

vs.

EL DORADO FURNITURE CORPORATION. LUIS CAPO

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of

the claim is requested for data collection and clerical processing purposes only. The amount of the claim

shall not be used for any other purpose.

n $8,000 or less

f] $8,001 - $30,000

x $30,001- $50,000

I $50,001- $75,000

I $75,001 - $100,000

n over $100,000.00

III. TYPE OF CASE (If the case fits more than one type of case, select the most

definitive category.) If the most descriptive label is a subcategory (is indented under a broader

category), place an x on both the main category and subcategory lines.

I

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 5 of 42
CIRCUIT CIVIL

tr Condominium

tr Contracts and indebtedness

! Eminent domain

n Auto negligence

n Negligence---other

n Business governance

U Business torts

! Environmental/Toxic tort

I Third party indemnification

n Construction defect

n Mass tort

I Negligent security

n Nursing home negligence

I Premises liability-commercial

n Premises liability-residential

tr Products liability

! Real Property/Tvlortgage foreclosure

n Commercial foreclosure

n Homestead residential foreclosure

tl Non-homestead residential foreclosure

n Other real property actions

tr Professional malpractice

n Malpractice-business

I Malpractice-medical

I Malpractice---other professional

x Other

I Antitrust/Trade regulation

n Business transactions

I Constitutional challenge-statute or ordinance

I Constitutional challenge-proposed amendment

n Corporate trusts

x Discrimination-employment or other

tr Insurance claims

! Intellectual property

I Libel/Slander

I Shareholder derivative action

I Securities litigation

n Trade secrets

n Trust litigation

COUNTY CIVI

fl Small Claims up to $8,000

n Civil

n Real property/Mortgage foreclosure

-2-

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 6 of 42
n Replevins

n Evictions

n ResidentialEvictions

n Non-residentialEvictions

n Other civil (non-monetary)

COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes n No X

IV. REMEDIES SOUGHT (check all thatapply)

X Monetary;

X Nonmonetary declaratory or injunctive relief;

X Punitive

V. NUMBER OF CAUSES OF ACTION:

(Specif,')

tl

5

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

n yes

Xno

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEENFILED?

Xno

! yes If "yes," list all related cases by name, case number, and court.

N/A

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

X yes

nno

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?

n yes

Xno

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of

my knowledge and belief, and that I have read and will comply with the requirements of

Florida Rule of Judicial Administration 2.425.

Signature: s/ Anthony M Georges-Pierre

Attorney or party

Anthony M Georges-Pierre

(type or print name)

Fla. Bar # 53363

Date

a

-J0911112022

(Bar # if attorney)

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 7 of 42
Filing # 157151852 E-Filed 0911112022 12:01:25 PM

JOSE PERAZA,

Plaintiff(s),

V

IN THE CIRCUIT COURT OF THE

l ITH JUDICIAL CIRCUIT IN AND FOR

MIAMI.DADE COLINTY, FLORIDA

CASE NO.:

EL DORADO FURNITURE CORPORATION,

And LUIS CAPO, individually,

Defendant(s)

COMPLAINT

(oPr-rN PURSUANT rO 29 U.S.C. $ 216(B))

COMES NOW, The Plaintiff JOSE PERAZA, ("Plaintiff'), by and through the

undersigned counsel, and pursuant to Rule 1.040, Florida Rules of Civil Procedure, hereby files

this Civil Action against, EL DORADO FURNITURE COnlOnnTION, and LUIS CAPO,

individually, individually, (collectively, "Defendants"), and in support avers as follows:

GENERAL ALLEGATIONS

l. This is an action by the Plaintiff for damages exceeding $30,000.00 excluding attorneys'

fees or costs resulting from Defendants' violations of the Fair Labor Standards Act,29

U.S.C. $$ 201-219 ("FLSA") to recover unpaid minimum wages, an additional equal

amount as liquidated damages, obtain declaratory relief, and reasonable attorneys' fees and

costs.

2. This Court has jurisdiction over Plaintiff s FLSA claims pursuant to 29 U.S.C. $ 216.

3. Plaintiff was at all times relevant to this action, and continues to be, a resident of Broward

County. Plaintiff is a covered employee for purposes of the FLSA.

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 8 of 42
4. Defendant, EL DORADO FURNITURE CORPORATION, having its main place of

business in Miami-Dade County, where Plaintiff worked for Defendant and at all times

material hereto was and is engaged in interstate commerce.

5. Defendant, LUIS CAPO, is a corporate officer of, and exercised operational control over

the activities of corporate Defendant, EL DORADO FURNITURE CORPORATION.

6. Venue is proper in Miarni-Dade County because all of the actions that form the basis of

this Complaint occurred within Miami-Dade County and payment was due in Miami-Dade

County.

7. All conditions precedent for the filing of this action before this Court have been previously

met, including the exhaustion of all pertinent administrative procedures and remedies.

FACTUAL ALLEGATIONS COMMON TO ALL COUNTS

8. Plaintiff was employed with Defendants for about twenty (20) years and was terminated

on or about March 6,2021.

9. At all times material hereto, Plaintiff and Defendant were engaged in agreement whereby

Plaintiff would be employed by Defendants and that Plaintiff would be properly paid as

provided for by, and not in violation of, the law of the United States and the State of

Florida.

10. Defendants failed to compensate Plaintiff for his sales and hours on or about March 5,

2021. Plaintiff executed a $25,000.00 sale on the same date and requested payment for his

hours and incentives to his Supervisor Susy.

11. Plaintiff was denied this request, to which he objected to and complained about the

Defendant's denial to cover the Plaintiff s wages and incentives/commissions.

2

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 9 of 42
12. The Plaintiff was then told his employment was terminated effective immediately, after

being employed with the Defendant for over twenty years.

13. Plaintiff complained to Defendant regarding his unpaid wages and immediately after

Plaintiff was retaliated against because of his complaints.

14. Plaintiff was paid a base rate as a sales associate and was provided an additionaI4.25%o -

8.00% incentive from sales executed by Plaintiff.

15. Plaintiff was terminated in retaliation for his complaints of Defendant's failure to pay

Plaintiff s due and owed wages and incentives.

COUNT I - BREACH OT' CONTRACT AGAINST EL DORADO F'URNITURE

CORPORATION

16. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-15 of this

complaint as if set out in fullherein.

17. Defendant breached its agreement with Plaintiff by failing to pay the amount due to Plaintiff

for services provided and performed under their agreement, and by not properly paying

Plaintiff for all hours worked and bonuses agreed upon in violation of the laws of the United

States and the State of Florida.

1 8. Plaintiff suffered damages as a result of Defendant' s breach of said agreement.

WHEREFORE, Plaintiff seeks damages from Defendant for breach of agreement,

exclusive of pre-judgment interest, costs, and attorneys' fees and any and all other relief that this

Honorable Court deems just and proper.

COUNT II. OUANTUM MERUIT AGAINST EL DORADO FURNITURE

CORPORATION

19. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-15 of this

complaint as if set out in full herein.

a

J

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 10 of 42
20. Plaintiff has conferred a benefit onto Defendant by performing and providing services for

Defendant.

21. Defendant has knowledge of the services performed and provided and the benefit provided by

Plaintiff.

22.Defendant accepted Plaintiff s services to Defendant.

23. Defendant retains an inequitable benefit from Plaintiff by not properly paying Plaintiff for all

hours worked and bonuses agreed upon in violation of the laws of the United States and the

State of Florida.

2L.Plaintiff seeks damages under quantum meruit that are the reasonable value of the services

rendered to, provided to, and performed for Defendant.

WHEREFORE, Plaintiff seeks a judgment under quantum meruit for damages for the

reasonable value of the services performed and provided for Defendant, interest and costs, and

other damages deemed just by this Honorable Court.

_ UNJUST ENRICHMENT

CORPORATION

25. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1-15 of this

complaint as if set out in full herein.

26. Plaintiff has conferred a benefit upon Defendant for services performed and provided to

Defendant.

2T.Defendant has knowledge of the services performed and provided by Plaintiff.

28. Defendant voluntarily accepted the services performed and provided by Plaintiff.

29. Defendant unjustly benefit from the services performed and provided by Plaintiff by not

properly paying Plaintiff for all hours worked and bonuses agreed upon in violation of the laws

of the United States and the State of Florida.

4

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 11 of 42
30. Plaintiff seeks damages for the value of the work performed to Defendant.

WHEREFORE, Plaintiff seeks a judgment for unjust enrichment against Defendant,

interest and costs, and other damages deemed just by this Honorable Court.

COUNT IV

FLSA Retaliation Against

EL DORADO FARNITURE CORPORATION

31. Plaintiffre-adopts each and every factual allegation as stated in paragraphs 1 through 15

of this complaint as if set out in full herein.

32.29 U.S.C. $ 215(aX3) of the FLSA states that it is a violation to "discharge or in any other

manner discriminate against any employee because such employee has filed any complaint

or instituted or caused to be instifuted any proceeding under or related to this Act, or has

testified or is about to testify in any such proceeding, or has served or is about to serve on

an industry committee."

33. Defendant's conduct as set forth above constitutes a violation of the FLSA's antiretaliation provision.

34. The motivating factor that caused Plaintiffs constructive discharge as described above

was Plaintiff s complaints regarding Defendants' unlawful pay practices and Defendants'

refusal to pay monies due and owing to him under the FLSA.

35. Defendant's conduct was in direct violation of the FLSA, and, as a direct result, Plaintiff

has been damaged.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant:

a. Adjudge and decree that Defendant has violated the FLSA and has done so willfully,

intentionally and with reckless disregard for Plaintiff s rights;

b. Award Plaintiff actual damages in the amount shown to be due for unpaid minimum

5

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 12 of 42
and/or overtime wages, with interest; and

c. Award Plaintiff an equal amount in double damages/liquidated damages; and

d. Award Plaintiff the costs of this action, together with reasonable attorney fees; and

e. Grant Plaintiff such additional relief as the Court deems just and proper under the

circumstances.

COUNT V

FLSA Retaliation Against La$ CAPO

36. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 15

of this Complaint as if set out in full herein.

37. Defendant, LUIS CAPO, was at all relevant times, a corporate officer of the Defendant, El

Dorado Furniture Corporation, and did exhibit control over the Corporate Defendant.

38.29 U.S.C. $ 215(a)(3) of the FLSA states that it is a violation to "discharge or in any other

manner discriminate against any employee because such employee has filed any complaint

or instituted or caused to be instituted any proceeding under or related to this Act, or has

testified or is about to testify in any such proceeding, or has served or is about to serve on

an industry committee."

39. Defendant's conduct as set forth above constitutes a violation of the FLSA's antiretaliation provision.

40. The motivating factor that caused Plaintiffls constructive discharge as described above

was Plaintiff s complaints regarding Defendants' unlawful pay practices and Defendants'

refusal to pay monies due and owing to him under the FLSA.

41. Defendant's conduct was in direct violation of the FLSA, and, as a direct result, Plaintiff

has been damaged.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant:

6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 13 of 42
42.

f. Adjudge and decree that Defendant has violated the FLSA and has done so willfully,

intentionally and with reckless disregard for Plaintiff s rights;

g. Award Plaintiff actual damages in the amount shown to be due for unpaid minimum

and/or overtime wages, with interest; and

h. Award Plaintiff an equal amount in double damages/liquidated damages; and

i. Award Plaintiff the costs of this action, together with reasonable attorney fees; and

j. Grant Plaintiff such additional relief as the Court deems just and proper under the

circumstances.

JURY DEMAND

Plaintiff demands trial by jury of all issues triable as of right by jury.

Dated: September 11,2022 Respectfully submitted,

h/ Joree L. Costa

Anthony M. Georges-Pierre, Esq.

Florida Bar No.: 533637

agp@repattorneys.com

Max L. Horowitz, Esq.

Florida Bar No.: 118269

mhorowitz@rgoattornelrs. com

Jorge L. Costa, Esq.

Florida Bar No.: 1031513

JCosta@rgpattorneys. com

REMER & GEORGES-PIERRE, PLLC

44 West Flagler Street, Suite 2200

Miami, FL 33130

Telephone: (305) 4 I 6-5000

Facsimile: (305) 4 1 6-5005

Counselfor Plaintiff

7

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 14 of 42
Filing # 1577 4071 I E-Fil ed 0912012022 09:47 :42 AM

IN THE CIRCUIT COURT OF THE

1lTH ruDICIAL CIRCUIT IN AND

MIAMI-DADE COI.]NTY, FLORIDA

JOSE PERAZA, Case No. : 2022-017 450-CA-0 1

Plaintiff

V

EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

Defendant.

SUMMONS IN A CIVIL CASE

TO: EL DORADO FURNITURE CORPORATION,

Through its Registered Agent:

LESLIE L. FLOREZ,

782 NW LE JEUNE ROAD

SUITE 350

MIAMI, FL 33T26

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY

ANTHONY M. GEORGES-PIERRE, ESQ.

REMER & GEORGES-PIERRE, PLLC.

44 WEST FLAGLER STREET, SUITE 22OO

MIAMI, FL 33130

an answer to the complaint which is herewith served upon you, within 20 davs after service of this

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will

be taken against you for the relief demanded in the complaint. You must also file your answer

with the Clerk of this Court within a reasonable period of time after service.

CLERK DATE

I

1

(BY) DEPUTY CLERK

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 15 of 42
Filing # 1577 4071 I E-Fil ed 0912012022 09:47:42 AM

IN THE CIRCUIT COURT OF THE

IITH ruDICIAL CIRCUIT IN AND

MIAMI-DADE COUNTY, FLORIDA

JOSE PERAZA, Case No. : 2022-017 450-CA-0 1

Plaintiff,

V

EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

Defendant

I

SUMMONS IN A CIVIL CASE

LUIS CAPO, Individually,

42OO N.W. 167 STREET

MIAMI GARDENS, FL 33054

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY

ANTHONY M. GEORGES-PIERRE, ESQ.

REMER & GEORGES-PIERRE, PLLC.

44 WEST FLAGLER STREET, SUITE 22OO

MIAMI, FL 33130

an answer to the complaint which is herewith served upon you, within 20 davs after service of this

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will

be taken against you for the relief demanded in the complaint. You must also file your answer

with the Clerk of this Court within a reasonable period of time after service.

CLERK DATE

(BY) DEPUTY CLERK

TO

1

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 16 of 42
Filing # 1577 407 I I E-Fil ed 0912012022 09:47 :42 AM

IN THE CIRCUIT COURT OF THE

1lTH ruDICIAL CIRCUIT IN AND

MIAMI-DADE COUNTY, FLORIDA

JOSE PERAZA, Case No. : 2022-017 450-CA-0 1

Plaintiff,

V

EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

Defendant.

SUMMONS IN A CIVI CASE

TO EL DORADO FURNITURE CORPORATION,

Through its Registered Agent:

LESLIE L. FLOREZ,

782 NW LE JEI.JNE ROAD

SUITE 350

MIAMI, FL 33126

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY

ANTHONY M. GEORGES-PIERRE, ESQ.

REMER & GEORGES-PIERRE, PLLC.

44 WEST FLAGLER STREET, SUITE 22OO

MIAMI, FL 33130

an answer to the complaint which is herewith served upon you, within 20 davs after service of this

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will

be taken against you for the relief demanded in the complaint. You must also file your answer

with the Clerk of this Court within a reasonable period of time after service.

Harvey Ruvin,

Clerk of Courts

912012022

CLERK

I

1

(BY) DEPUTY CLERK

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 17 of 42
Filing # 15774071 I E-Filed 0912012022 09:47:42 AM

IN THE CIRCUIT COURT OF THE

l ITH JUDICIAL CIRCUIT IN AND

MIAMI-DADE COUNTY, FLORIDA

JOSE PERAZA, Case No. : 2022-017 450-CA-0 1

Plaintiff,

v

EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

Defendant.

SUMMONS IN A CIVI CASE

LUIS CAPO, Individually,

42OO N.W. 167 STREET

MIAMI GARDENS, FL 33054

YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY

ANTHONY M. GEORGES-PIERRE, ESQ.

REMER & GEORGES-PIERRE, PLLC.

44 WEST FLAGLER STREET, SUITE 22OO

MIAMI, FL 33130

an answer to the complaint which is herewith served upon you, within 20 davs after service of this

summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will

be taken against you for the relief demanded in the complaint. You must also file your answer

with the Clerk of this Court within a reasonable period of time after service.

Harvey Ruvin,

Clerk of Courts 9t20t2022

CLERK DATE

(BY)

I

TO

I

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 18 of 42
Filing # 158956461 E-Filed 10/1t12022 09:50:43 AM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI.DADE COUNTY, FLORIDA

CASE NO: 2022-0 I 7450-CA-0 I

SECTION: CA2T

JUDGE: David C. Miller

JOSE PERAZA

Plaintiff(s)

vs.

EL DORADO FURNITURE CORPORATION et al

Defendant(s)

I

ORDER TO COMPLETE AND COMPLY WITH CASE SCHEDULING AND

MANAGEMENT ORDER

THIS CAUSE came before the Court to review and do case management. Based on the review

of the file, and pursuant to Rule 2.545, Fla. R. Jud. Admin., the Parties, with the Court's

assistance. if necessary, will establish a Completed Case Scheduling/Management Order.

Therefore, it is;

ORDERED and ADJUDGED as follows:

1. The Pafties shall determine and complete the CASE SCHEDULE below, to extent they can

agree on one or all of the To-Dos in this matter and set the Deadlines for as many as can be

agreed on. If there is/are any Deadlines for the Parties To-Dos that cannot be agreed on, the

Plaintiff s Counsel shall set a hearing if necessary for the Court to decide the

Deadlines.

2. The Plaintiff s Counsel shall file the entire completed Scheduling/Management Order

as a Completed Case Scheduling/fuIsnagement Order through Court Map for execution

and rendering by the Court within 60 days of the entry of the Order or the appearance of

the Jirst Defendant whichever occurs last. The Plaintiff s Counsel will bear the burden

of ensuring this Order is complied with and the entire scheduling/management order with

completed table of to dos and deadlines is filed, but that will not determine who may be

ultimately responsible for any lack of compliance with this Order.

3. The Parties shall strictly comply with the deadlines in the Schedule (which shall supersede

any contrary or different Trial Order Deadline - not as to the trial date or date of the

calendar call which are determined by the Trial Order) and should expect that the case

will be tried during the anticipated trial period specified, without continuances. The parties

cannot agree to extend the deadlines and cannot agree to waive any portion of the provisions

of this Order. If your case does not go to Trial, it will most probably be sent to Non-Binding

Case No: 2022-017 450-CA-01 Page I of6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 19 of 42
Arbitration.

4. Procedural Requirements: In addition to strict adherence to the Florida Rules of Civil

Procedure and the Administrative Orders of the Court, the parties will be required to strictly

comply with the Completed Case Scheduling/lVlanagement Order.

5. The parties may not agree to extend any of the deadlines contained in the Completed Case

Scheduling/Management Order. Deadlines may only be altered by the Court where the

interests ofjustice so require, upon i11g.

6. The following To-Dos and Deadlines are to be determined by Agreement of the

Parties, filled in, and returned to the Court for execution and rendering OR the Court

will determine and fill in such To-Dos and Deadlines:

CASE SCHEDULE

Case No: 2022-017 450-CA-01 Page2 of 6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 20 of 42
CASE MANAGEMENT PROCEDURES

7. Duty to Communicate: Prior to filing any Motion, counsel shall confer with each other

directly in good faith, not through staff, to affempt to narrow or resolve issues. "In good

faith" means you are professional and temperate in your communications, you retum phone

calls and emails in a timely manner, and you do not set unreasonable deadlines for responses.

8. Scheduling of Hearings: Motions filed (other than dispositive motions or those requiring

testimony) must be noticed for hearing on the first available motion calendar. The Court may

rule upon the Motions on the papers filed for the Court's review.

9. Compelling Discovery where there has been no response: The parties are to comply with

Administrative Order 06-09 when moving to cornpel production of propounded discovery.

These Motions shall be submitted via CourtMAP with supporting documents and shall not be

placed on Motion Calendar,

10. Motions for Protective Order: Motions for Protective Order must be filed as soon as the

grounds are known. Counsel should be coordinating deposition dates for specific

parties/witnesses and have a duty to confer regarding any issues that would be the subject

of a rnotion for protective order prior to scheduling the deposition. The filing of the motion

must not be delayed until immediately prior to the scheduled deposition. A motion for

protective order does not automatically stay the deposition and the deposition shall proceed

unless an order granting the motion is entered by the Court.

ll.Motions for Extension: All Motions for Extension of Time SHALL BE SET TO BE

HEARD WITHIN 7 DAYS OF THE MOTION BEING FILED and the Motion must state

with specificitv the reason why Extension is needed, the anticipated deadline for completion,

and any extraordinary or compelling reasons to grant relief. The Court may rule upon

submission of the Motion without a hearing. All Motions for Extension of Time must be

preceded by a meet and confer with opposing counsel and absent agreement, be set for

hearing immediately upon filing. Counsel should be prepared to respond promptly if the

Motion is Denied. The failure to timely set the Motion for Extension to be heard will be

deemed a waiver of any attempt to get an Extension.

12. Dispositive Motions: Motions which may dispose of specific issues, portions of the case or

the entire case should be filed and set for hearing as soon as possible. Parties wishing to

pursue a dispositive motion should target the essential discovery promptly. Parties should

conf€r to assure necessary discovery is scheduled to be completed and will be completed

prior to a special set hearing date. Last minute cancellations are NOT ALLOWED.

Case No: 2022-017 450-CA-01 Page 3 of6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 21 of 42
13. Amendment of Pleadings: Motions to amend should be filed so as not to affect the date of

trial. Although the Court recognizes the rule of liberality with regard to amendment of

pleadings, liberality declines with an approaching trial date unless the amendment involves

newly discovered information not previously available. Review your pleadings for necessary

amendment(s) early, not as part of last-minute trial preparation.

14. Objections: If objections to written discovery involve the phrasing of the request or time

frame of any discovery request, these objections may not be extended even if the parties

agree and are due at the time the initial response is due. Failure to timely file these

objections shall be deemed an express waiver of the objection. Parties shall comply with

the "Duty to Communicate" above, prior to setting timely made objections for hearing.

15. Documents made available for inspection and copying: If discovery responses provide

that the documents are available for inspection and copyingata mutually convenient time

and place, the responding party shall immediately (within 48 hours) provide three alternative

dates and times that the documents are available for inspection and copying. All of the dates

shall be within ten (10) days. Failure to provide the dates and times shall constitute a failure

to respond to discovery. Review shall occur within fifteen (15) days of the response, absent

extraordinary circumstances. Examples of "extraordinary circumstances" include a sole

practitioner in trial on another case, a medical emergency, prepaid vacation, and a death in

the family.

16. Privilege Logs: Privilege logs are due at the time of the response and may not be reserved to

be provided later, Privilege logs must specifically identify the document in accordance with

Rule 1.280(bX6), Fla.R.Civ.P, AND The item must at least be described by Author.

primarily Recipient and all those copied. date. nature of document. and the same

information as to all attachments printed out or opened in records for view.

17. The failure to timely provide the privilege log will result in the waiver of the privilege.

This procedure requires preparation of a privilege log with respect to all documents,

electronically stored information, things and oral communications withheld on the basis of a

claim of privilege or work product except the following: written and oral communications

between a party and their counsel after commencement of the action and work product

material created after commencement of the action and solely kept between them and staff,

experts, etc.

Parties are instructed that where they believe that the divulgence of the logging information

would necessarily cause disclosure of the allegedly privileged information, they must

identify that the item exists and that in camera review by the court will be sought.

However, if the Court determines that there is nothing inherent in the divulgence of the

existence of the document or the logging information required that would violate privilege,

the Court will impose sanctions for any in camera request determined to be frivolous. In

cazera requests by the part.v claiming the privilege must be signed by both the

requesting attorney and the client. to assure that alt are aware of the request and the

consequences.

Case No: 2022-017 450-CA-0 I Page 4 of6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 22 of 42
18. Exnert Disclosure: Parties should furnish opposing counsel with the names and addresses

of all expert witness under Rule 1.390(a) to be called at trial and all information regarding

expert testimony that is required by Rule 1.280(bX5). Each party is limited to one expert per

specialty. No other expert testimony should be permitted at trial. Information furnished

pursuant to this paragraph should be timely filed.

19. Depositions: The parties are ordered to block time now for necessary depositions to be set in

this case Expert deposition time should be coordinated and blocked as soon as experts are

known to ensure compliance with this schedule. Depositions may commence at any time.

Refer to the above regarding motions for protective order.

20. Witness and Exhibit Lists: The parties shall timely exchange their witness and exhibit

lists. The lists shall include complete proper names and addresses. If counsel chooses to list

their bar address as the witness' address, counsel is deemed to have agreed to produce the

witness voluntarily as they have withheld the information necessary for a witness subpoena,

and counsel will be responsible for assuring that witness' presence attrial.

21. Mediation: Parties must mediate by the Court's deadline. The parties are responsible for

assuring that they have all the necessary information to value their position prior to

mediation. If the parties fail to mediate before the mediation deadline, sanctions will be

imposed by the Court. Failure to Mediate will not constitute just cause for a Trial

Continuance.

22. "Frustrated Lawyer/Pro-Se Ruleoo

Please see the llth Judicial Circuit in and for Miami-Dade Countv Division 21 website

- for assistance scheduling anything the other(s) in the file are making difficult.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 11th day of October.

2022.

:35 -$

2022-017 450-C A-01 l0-l I -2022 9 :3 5 ltM

Hon. David C. Miller

CIRCUIT COURT JUDGE

Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

Anthony M George s-P i erre, agp @r gpattorneys. com

Case No: 2022-017 450-CA-01 Page 5 of6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 23 of 42
Anthony M Georges-Pierre, jcosta@rgpattomeys.com

Anthony M Georges-Pierre, mhorowitz @r gpattomeys. com

Physically Served:

Case No: 2022-017 450-CA-0 I Page 6 of6

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 24 of 42
Filing # 158960165 E-Filed 10/1 112022 10:17:54 AM

State of Florida

RETURN OF SERVICE

Gounty of MIAMI DADE Circuit Court

Case N umb er: 2022-0 17450-CA-0 1

iltIilililIffiil]ilililIililfl]t

ROD2022000362

Plaintiff:JOSE PERAZA

VS.

Defendant: EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

For:

ANTHONY GEORGES-PIERRE

REMER & GEORGES-PIERRE PLLC

44 WEST FLAGLER

SUITE 22OO

MIAMI, FL 33130

Received by Due Process, LLC on the 29th day of September, 2022 at 10:32 pm to be served on El Dorado

Furniture Gorporation Through lts Registered Agent: LESLIE L. FLOREZ, 782 NW LEJEUNE ROAD,

sutTE 350, MtAMt, FL 33126.

l, BERNIE GUTIERREZ, do hereby affirm that on the 30th day of September,2022 at 1:20 pm, l:

served a GORPORATION by delivering a true copy of the Summons and Complaint with the date and

hour of service endorsed thereon by me, to: KENNETH SPILLER as ATTORNEY for El Dorado

Furniture Gorporation Through lts Registered Agent:, at the address of: 782 NW LEJEUNE ROAD,

SUITE 350, MlAMl, FL 33126, and informed said person of the contents therein, in compliance with state

statutes.

Additional lnformation pertaining to this Service:

913012022 1:21 pm Attorneys Kenneth Spiller authorized to accept documents excepted documents for El

Dorado furniture corporation.

I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process

Seruer, in good standing, in the judicial circuit in which fhe process uvas seryed. Under the perjury, I

declare that I have read the foregoing document and the facts in it are true. NO NOTARY REQUIRED

PU RS UANT TO F. 5.92. 525(2)

BERNIE GUTIERREZ

cPS3 10050

Due Process, LLC

PO BOX 612576

MtAMt, FL 33261

(305) 916-07s7

Our Job Serial Number: ROD-2022000362

Copyright @ 1992-2022 Database Servicos, lnc. - Process Seruer's Toolbox V8.2i

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 25 of 42
Filing # 158960165 E-Filed 10/1 112022 l0:17:54 AM

RETURN OF SERVICE

State of Florida

Case Numb er: 2022-017450-CA-01

Plaintiff:JOSE PERAZA

VS,

County of MIAMI DADE Gircuit Gourt

ilr Iil ililIll]il]ililililt iltI]t

ROD2022000363

Defendant: EL DORADO FURNITURE

CORPORATION,

And LUIS CAPO, individually

For:

ANTHONY GEORGES-PIERRE

REMER & GEORGES-PIERRE PLLC

44 WEST FLAGLER

SUITE 22OO

MtAMt, FL 33130

Received by Due Process, LLC on the 29th day of September, 2022 al l0:32 pm to be served on LUIS

CAPO,42OO NW 167TH STREET, MIAMI GARDENS, FL 33054

I, DAVE ANDREW, do hereby affirm that on the 3rd day of October, 2022 at 11 :06 am, l:

INDIVIDUALLY/PERSONALLY served by delivering a true copy of the Summons and Gomplaint with

the date and hour of service endorsed thereon by me, to: LUIS CAPO at the address of: 4200 NW 167TH

STREET, MIAMI GARDENS, FL 33054, and informed said person of the contents therein, in compliance

with state statutes.

Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United

States of America.

Marital Status: Based upon inquiry of party served, Defendant is married.

Additional lnformation pertaining to this Service:

101512022 5:21 pm Attempted service at4200 NW 167TH STREET, MIAMIGARDENS, FL 33054, per

Rita/assistant the defendant is not in

101312022 1 1:06 am lndivually served.. 60, m, h, 5'6, 170, black hair and yes glasses

I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process

Server, in good standing, in the judicial circuit in which fhe process was served. Under the perjury, I

declare that I have read the foregoing document and the facts in it are true. NO NOIARY REQUIRED

PU RSUANT TO F. 5.92. 525(2)

(U-/w'<

DAVE ANDREW

cPS # 1556

Due Process, LLC

PO BOX 612576

MtAMt, FL 33261

(30s) e16-0757

Our Job Serial Number: ROD-2022000363

Copyright @ 1992-2022 Oatabase S€ruicos, Inc. - Process Seruer's Toolbox V8.2i

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 26 of 42
Filing # 15901 1295 E-Filed I0lIIl2022 03:49:37 PM

IN THE CIRCUIT COURT FOR THE 1lTH

JUDICIAL CIRCUIT, IN AND FOR

MIAMI-DADE COLINTY, FLORIDA

JOSE PERAZA,

GENERAL ruRISDICTION DIVIS ION

Plaintiff,

vs. Case No. : 2022-017 450-CA-0 1

EL DORADO FURNITURE CORPORATION,

Defendant.

NOTICE OF CHANGE OF FIRM NAME AND ADDRESS

TO THE HONORABLE ruDGE OF SAID COURT:

The undersigned attorney files this Notice of Change of Firm Name and Address and

requests that the Court's docket in the above styled cause be updated accordingly.

From: Remer & Georges-Pierre. PLLC. /o Remer, Georges-Pierre & Hoogerwoerd. PLLC.

Former address: Courthouse Tower,44 West Flaeler Street, Suite 2200 Miami. Fl33l30

New Address: 2745Ponce De Leon Boulevard, Coral Gables, Florida 33134

Remainder of page intentionally left blank

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 27 of 42
DATED this 1lth day of October,2022

Respectfully submitted,

By : &^tt-,g fr, &ng*- fi"-.

Anthony M. Georges-Pierre, Esquire

Florida Bar No.: 0533637

E-Mail : asp@rgpattorneys. com

Max L. Horowitz, Esquire

FloridaBarNo.: 118269

E-Mail : mhorowitz @rgpattomeys.com

Jorge Costa, Esquire

Florida Bar No.: 1031513

E-Mail : j costa@rgpattorneys. com

2745 Ponce De Leon Blvd.

Coral Gables, FL 33134

Telephone: (305) 4l 6-5000

Facsimile: (305) 4 I 6-5005

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 28 of 42
CERTIFICATE OF SERVICE

I hereby certify that on October 11,2022,I electronically filed the foregoing document

with the Clerk of the Court. I also certify that the foregoing document is being served this day

on all counsel of record or pro se parties, either via transmission of Notices of Electronic Filing

or in some other authorized manner for those counsel or parties who are not authorizedto receive

electronically Notices of Electronic Filing.

By: &rtf""g ffi, 9*rl*-ft"rr"

Anthony M. Georges-Pierre, Esq.

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 29 of 42
Filing # 159458092 E-Filed 10/1812022 03:32:36PM

IN THE CIRCUIT COURT OF THE l ITH

JUDICIAL CIRCUIT IN AND FOR MIAMI

DADE COUNTY, FLORIDA

CASE NO: 2022-0017450-CA-01 (CA2l)

JOSE PERAZA,

Plaintiff,

V

EL DORADO FURNITURE CORPORATION

and LUIS CAPO, individually,

Defendants.

DEF'ENDANTS' UNOPPOSED MOTION X'OR EXTENSION Of,'TIME

TO RESPOND TO PLAII\TIX'F'S COMPLAINT

Defendants, EL DORADO FURNITURE CORPORATION and LUIS CAPO (collectively,

"Defendants"), by and through their undersigned counsel and pursuant to Rule 1.090(bxl)(A) of the

Florida Rules of Civil Procedure, hereby files this Unopposed Motion for Extension of Time to

Respond to PlaintifPs Complaint ("Unopposed Motion"), and states:

l. On September I l, 2022, Plaintiff filed his Complaint.

2. On September 30, 2022, Defendant El Dorado Furniture Corporation was served with

the Complaint.

3. On October 7,2022, Defendant Luis Capo was served with the Complaint.

4. Therefore, Defendant El Dorado Fumiture Corporation's response to Plaintiffs

Complaint is currently due on October 20,2022, and Defendant Luis Cap's response to Plaintiff s

Complaint is currently due on October 27,2022.

5. The undersigned law firm was recently retained to represent the Defendants and is still

in the process of investigating the allegations, Therefore, Defendants require additional time to

respond to Plaintiffs Complaint.

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 30 of 42
6. The undersigned would also prefer for both Defendants to respond to Plaintiffs

Complaint on the same date.

7. Defendants respectfully request a brief extension of time, through and including

November 1,2022, to file their response to Plaintiff s Complaint.

8. Defendants have not filed this Unopposed Motion for purposes of undue delay or to

prejudice any party.

9. Undersigned counsel for Defendants confened with Plaintifls counsel about the

extension of time to respond to the Complaint and was advised that Plaintiff does not oppose the

requested extension.

10. A proposed Agreed Order is attached hereto as Exhibit "A."

WHEREF''ORE, for the foregoing reasons, Defendants, El Dorado Furniture Corporation and

Luis Capo, respectfully request this Court grant this Unopposed Motion, enter the proposed Agreed

Order, extend the time for Defendants to file their response to Plaintiffs Complaint, through and

including November 1,2022, and grant any other and further relief the Court deems just and proper.

Dated: October 18,2022 Respectfully submitted,

By: .r/ Stenhonie Turk

ROBERT S. TURK, ESQ.

Florida Bar No.: 261343

E-Mail : rturk@ste,arnslveaver.com

STEPHANIE TURK, ESQ.

Florida BarNo.: 99138

E-mail: pt\rrk@steamsweavgr.com

STEARNS WEAVER MILLER WEISSLER

ALHADEFF & SITTERSON, P.A.

Museum Tower, Suite 2200

150 West Flagler Street

Miami, Florida 33130

Telephone: (305) 789-3200

Facsimile: (305) 789-3395

Counselfor Defendants El Dorado Furniture

Corporation and Luis Capo

)

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 31 of 42
CERTTFT9ATE,OE SERVICE

I HEREBY CERTIFY that on October 18,zlz2,undersigned counsel has electronically filed

the foregoing document with the Clerk of the Court using the Florida Courts E-Portal. Pursuant to

Fla. R. Gen. Prac. & Jud. Admin. 2.516(b), I also certifu that the foregoing document has been

furnished to all counsel of record or pro se parties identified on the attached Service List in the manner

specified, either via transmission ofNotices of Service of Court Document generated by the E-Portal

or in some other authorized manner for those counsel or parties who are excused from email service.

By: .s/ Stenhanic Turk

Stephanie Turk, Esq.

sERVrpE LrST

Anthony M. Georges-Pierre, Esq.

Florida Bar No. 533637

E-Mail : agE@rgpattorneys. com

Max L. Horowitz, Esq.

Florida Bar No. 118269

E-Mail : m horowi tz-@repattorneys. oom

Jorge L. Costa, Esq.

Florida Bar No. 10315 13

E-Mai I : i costa{O.rgpattornevs. co- n[

Remer & Georges-Pierre, PLLC

44 West Flagler Street, Suite 2200

Miami, Florida 33130

Telephone: 305-4 I 6-5000

Facsimile: 305-41 6-5000

C ouns e I for Pl aintiff Jo s e P er az a

3

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 32 of 42
EXHIBIT A

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 33 of 42
IN THE CIRCUIT COURT OF THE llTH

JUDICIAL CIRCUIT IN AND FOR MIAMI

DADE COUNTY, FLORIDA

CASE NO: 2022-0017450-CA-01 (CA21)

JOSE PERAZA,

Plaintiff,

v

EL DORADO FURNITURE

CORPORATION and LUIS CAPO,

individually,

Defendants.

ORDER ON pEFEIIDANTS: UNOPPOSEp MOTTON FOR EXTENSION OF TIME

TO RESPOND TO PLAINTIF'X''S COMPLAINT

THIS CAUSE came before the Court upon Defendants', El Dorado Furniture Corporation

and Luis Capo, Unopposed Motion For Extension of Time To Respond to Plaintiff s Complaint

(the "Unopposed Motion'). The Court, noting that it is an Unopposed Motion and being otherwise

fully advised, hereby ORDERS and ADJUDGES as follows:

1. The Unopposed Motion is GRANTED.

2. Defendants, El Dorado Furniture Corporation and Luis Capo, shall have through and

including November 1,2022, to respond to Plaintiff s Complaint.

DONE AND ORDERED this day of

County, Florida.

2022, in Miami-Dade

THE HONORABLE DAVID C. MILLER

CIRCUIT COURT JUDGE

Copies furnished to All Counsel of Record

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 34 of 42
Filing # 159488699 E-Filed 10/1812022 07:30:00 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI.DADE COUNTY, FLORIDA

CASE NO: 2022-0 I 7450-CA-0 I

SECTION: CA}I

JUDGE: David C. Miller

JOSE PERAZA

Plaintiff(s)

vs.

EL DORADO FURNITURE CORPORATION et al

Defendant(s)

I

COURT MODIFIED* UNOPPOSED ORDER ON DEFENDANTS' UNOPPOSED MOTION

FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT

THIS CAUSE came before the Court upon Defendants', El Dorado Furniture Corporation

and Luis Capo. Unopposed Motion For Extension of Time To Respond to Plaintiffs Complaint

(the "Unopposed Motion"). The Court, noting that it is an Unopposed Motion and being otherwise

fully advised, hereby ORDERS and ADJUDGES as follows:

1. The Unopposed Motion is GRANTED.

2.Defendants, El Dorado Furniture Corporation and Luis Capo, shall have through and

including November 1.. 2022, to respond to Plaintiff s Complaint.

3. * This deadline may not be extended by agreement and the mere filing of a

Motion for Rehearing/Reconsideration and/or Motion to Extend this

deadline will NOT toll the time to fully comply with this Order. The

failure to timely comply will result in the entry of a Court Default without

further Notice or Hearin&

This is the Notice.

Case No: 2022-017 450-CA-0 I Page I of2

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 35 of 42
DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 18th day of October.

2022.

2022-017 450 -CA-01 10-18-2022 7 :19 PM

Hon. David C. Miller

CIRCUIT COURT JUDGE

Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

Anthony M George s -P i erre, agp @r gp attorneys. com

Anthony M Georges-Pierre, jcosta@rgpattorneys.com

Anthony M Georges-Pierre, mhorowitz @rgpattomeys.com

Stephanie L Turk, sturk@stearnsweaver.com

Stephanie L Turk, amorell@stearnsweaver.com

Physically Served:

Case No: 2022-017 450-CA-0 I Page2 of 2

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 36 of 42
Filing # 159562730 E-Filed 1011912022 03:06:41 PM

IN THE CIRCUIT COURT OF THE 1lTH

JUDICIAL CIRCUIT IN AND FOR MIAMI

DADE COUNTY, FLORIDA

CASE NO: 2022-0017450-CA-01 (CA21)

JOSE PERAZA,

Plaintifl

V

EL DORADO FURNITURE

CORPORATION and LUIS CAPO,

individually,

Defendants

NOTICE OF APPEARANCE AND DESIGNATION OF E.MAIL ADDRESSES

The law firm of Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A., by Stephanie

Turk, Esq., hereby files this Notice of Appearance in the above-styled cause as counsel for

Defendants, El Dorado Furniture Corporation and Luis Capo, and requests that copies of all

motions, notices, orders, correspondence, and other papers be served on the undersigned.

In accordance with Rule 2.516(bX1XA) of the Florida Rules of General Practice and

Judicial Administration, undersigned counsel hereby designates the following email addresses for

service of pleadings and documents:

Primary email address:

Secondary email address:

sturk @ stearnsweaver. com

amorell @ stearnsweaver. com

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 37 of 42
Dated: October 19,2022 Respectfu lly submitted,

By: s/ Stephanie Turk

ROBERT S. TURK, ESQ.

Florida Bar No.: 261343

E-Mail: rturk @ stearnsweaver.com

STEPHANIE TURK, ESQ.

Florida Bar No.: 99138

E-mail: sturk@stearnsweaver.com

STEARNS WEAVER MILLER WEISSLER

ALHADEFF & SITTERSON, P.A.

Museum Tower, Suite 2200

150 West Flagler Street

Miami, Florida 33130

Telephone: (305) 789-3200

Facsimile: (305) 789-3395

Counsel for Defendants El Dorado Furniture

Corporation and Luis Capo

CERTIFICATE OF SERVICE

I I{EREBY CERTIFY that on October 19, 2022, undersigned counsel has electronically

filed the foregoing document with the Clerk of the Court using the Florida Courts E-Portal.

Pursuant to Fla. R. Gen. Prac. & Jud. Admin. 2.516(b), I also certify that the foregoing document

has been furnished to all counsel of record or pro se parties identified on the attached Service List

in the rnnner specified, either via transmission of Notices of Service of Court Document generated

by the E-Portal or in some other authorized manner for those counsel or parties who are excused

from email service.

By s/ Stephanie Turk

Stephanie Turk, Esq

2

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 38 of 42
SERVICE LIST

Anthony M. Georges-Pierre, Esq.

Florida Bar No. 533637

E-Mail: agp @rgpattorneys.com

Max L. Horowitz, Esq.

Florida Bar No. 118269

E-Mail: mhorowitz@rgpattorneys.com

Jorge L. Costa, Esq.

Florida Bar No. 1031513

E-Mail: jcosta @rgpattorneys.com

Remer & Georges-Pierre & Hoogerwoerd, PLLC

2745 Ponce De Leon Blvd.

Coral Gables, Florida 33134

Telephone: 305-4 16-5000

Facsimile: 305-416-5000

Counsel for Plaintiff Jose Peraza

a

J

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 39 of 42
Filing # 159563691 E-Filed 1011912022 03:12:05 PM

IN TFIE CIRCUIT COURT OF TIIE I lTH

JUDICIAL CIRCUIT IN AND FOR MIAMI

DADE COUNTY, FLORIDA

CASE NO: 2022-0017450-CA-01 (CA2l)

JOSE PERAZA,

Plaintifl

v

EL DORADO FURNITURE

CORPORATION and LUIS CAPO,

individually,

Defendants.

NOTICE OF APPEARANCE AND DESIGNATION OF E.MAIL ADDRESSES

The law firm of Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A., by Robert S.

Turk, Esq., hereby files this Notice of Appearance in the above-styled cause as counsel for

Defendants, El Dorado Furniture Corporation and Luis Capo, and requests that copies of all

motions, notices, orders, correspondence, and other papers be served on the undersigned.

In accordance with Rule 2.516(bXlXA) of the Florida Rules of General Practice and

Judicial Administration, undersigned counsel hereby designates the following email addresses for

service of pleadings and documents:

Primary email address:

Secondary email address:

rturk @ stearnsweaver.com

ntorres @ stearnsweaver.com

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 40 of 42
Dated: October 19,2022 Respectfu lly submitted,

By: s/ Robert S.

ROBERT S. TURK, ESQ.

Florida Bar No.: 261343

E-Mail: rturk@ stearnsweaver.com

STEPHANIE TURK, ESQ.

Florida Bar No.: 99138

E-mail: sturk@stearnsweaver.com

STEARNS WEAVER MILLER WEISSLER

ALHADEFF & SITTERSON, P.A.

Museum Tower, Suite 2200

150 West Flagler Street

Miami, Florida 33130

Telephone: (305) 789-3200

Facsimile: (305) 789-3395

Counsel for Defendants EI Dorado Furniture

Corporation and Luis Capo

CERTIFICATB OF SERVICE

I I{EREBY CERTIFY that on October 19, 2022, undersigned counsel has electronically

filed the foregoing document with the Clerk of the Court using the Florida Courts E-Portal.

Pursuant to Fla. R. Gen. Prac. & Jud. Admin.2.5l6(b),I also certify that the foregoing document

has been furnished to all counsel of record or pro se parties identified on the attached Service List

in the manner specified, either via transmission of Notices of Service of Court Document generated

by the E-Portal or in some other authorized manner for those counsel or parties who are excused

from email service.

By: c/ Rnhert .l Trt

Robert S. Turk, Esq.

2

Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 41 of 42
SERVICE LIST

Anthony M. Georges-Pierre, Esq.

Florida Bar No. 533637

E-Mail: agp @rgpattorneys.com

Max L. Horowitz, Esq.

Florida Bar No. 118269

E-Mail: mhorowitz@rgpattorneys.com

Jorge L. Costa, Esq.

Florida Bar No. 1031513

E-Mail: jcosta@rgpattorneys.com

Remer & Georges-Pierre & Hoogerwoerd, PLLC

2745 Ponce De Leon Blvd.

Coral Gables, Florida 33134

Telephone: 305-4 I 6-5000

Facsimile: 305-4 I 6-5000

Counsel for Plaintiff Jose Peraza

3

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Case 1:22-cv-23539-KMM Document 1-2 Entered on FLSD Docket 10/31/2022 Page 42 of 42