EXHIBIT A 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 1 of 8
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:18-cv-25337-KMM 

ANTONIO CABALLERO, 

Plaintiff, 

v. 

FUERZAS ARMADAS REVOLUCIONARIAS 

DE COLOMBIA, et al., 

Defendants. 

AFFIDAVIT OF LEON N. PATRICIOS 

PURSUANT TO SECTION 56.27(4), FLA. STAT. 

STATE OF FLORIDA 

COUNTY OF MIAMI-DADE 

) 

) 

) 

SS 

I, Leon N. Patricios as Attorney of Record for the Plaintiff/Levying Creditor, Antonio 

Caballero ("Caballero"), hereby affirm under oath the following: 

1. I am a resident of Miami-Dade County, Florida. I am over 18 years of age. 

2. I am an attorney at the law firm of Zumpano Patricios, P.A., and our firm represents 

Caballero in the above sty led action. 

3. I have personal knowledge of the facts stated herein. 

4. On May 20, 2020, the Honorable Michael K. Moore of the United States District 

Court for the Southern District of Florida entered a final judgment in favor of Caballero and against 

the Judgment Debtors in the amount of $46,729,667.00, which was trebled to $140,189,001.00 

pursuant to Section 18 U.S.C. § 2333, and which included post-judgment interest at the rate of 

0.15% from May 20, 2020, the date of the final judgment (the "Final Judgment"). 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 2 of 8
5. To date, the outstanding balance of the trebled damages awarded to Caballero in 

the Final Judgment is $121,491,252.99-calculated, without interest-as the amount of the debt 

to be levied upon. 

6. The real property that is the subject of the Writ of Execution issued by the Clerk of 

Court on May 31, 2022 (7043 Fisher Island Dr, Unit: 7043, Miami Beach, FL 33109-0064, Folio 

No. 02-4210-018-0170 (hereinafter the "Subject Property")) is valued by the Miami-Dade 

Property Appraiser at an estimated market value of $11,814,306. 

7. Per the information available for the Subject Property on the website for the MiamiDade County Office of the Property Appraiser the purported owner of the Subject Property is 

Planet 2 Reaching, Inc., a Delaware corporation, whose address is c/o Cosme de la Torriente, P.A. 

155 SW 25th Road, Miami, Florida 33129. 

8. When our law firm searched the name of Planet 2 Reaching, Inc. by using the 

function to search for a business entity on the website for the Delaware Department of State, 

Division of Corporations ( corp.delaware.gov) to see if any records were found for Planet 2 

Reaching, Inc., a message appeared stating that the requested function for Planet 2 Reaching, Inc. 

was unable to be performed and to contact the Division of Corporations for further assistance. 

Subsequently, the undersigned contacted the Delaware Division of Corporations and spoke with a 

representative who informed him that the records for Planet 2 Reaching, Inc. (file# 6167767) are 

unavailable to the public and that service of process on such entity may be completed by serving 

the Delaware Secretary of State. Additionally, our law firm searched the name of Planet 2 

Reaching, Inc. on the website for the Florida Department of State, Division of Corporations 

(Sunbiz.org) to see if any records were found for Planet 2 Reaching, Inc. as a registered foreign 

2 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 3 of 8
entity in Florida, such search returned no records for Planet 2 Reaching, Inc. as a registered foreign 

entity in Florida. 

9. Our law firm has reviewed the Official Records of the Miami-Dade County Clerk 

of Court (i.e., the records of the clerk of the court of the county where the Subject Property is 

situated per Fla. Stat. § 56.27( 4)(a)), and, in an abundance of caution, also reviewed the following 

additional online public records of-(1) the Miami-Dade County Tax Collector; (2) the Florida 

Department of State, Division of Corporations; (3) the Florida Secured Transaction Registry; and 

(4) the Florida Department of Revenue. Based upon my review of such records, I believe that the 

following information is true and correct: 

a. There appear to be no judgment liens recorded against the Subject Property. 

However, the following notices regarding claims of lien are recorded against the 

Subject Property: 

i. Claim of Lien for Assessments of PALAZZO DEL SOL/DELLA LUNA 

AT FISHER ISLAND CONDOMINIUM ASSOCIATION, INC., whose 

address is 7000 Fisher Island Dr., Fisher Island FL 33109, for 

approximately $54,400.76. See Claim of Lien for Assessments, MiamiDade County Clerk of the Courts, County Recorder's Official Records, 

Clerk's File Number 2019 R 256288, April 25, 2019; see also, Amended 

Claim of Lien for Assessments, Miami-Dade County Clerk of the Courts, 

County Recorder's Official Records, Clerk's File Number 2019 R 298886, 

May 14, 2019. 

ii. Claim of Lien of PALAZZO DEL SOL/DELLA LUNA AT FISHER 

ISLAND CONDOMINIUM ASSOCIATION, INC., whose address is 7000 

Fisher Island Dr., Fisher Island FL 33109, for approximately $580,994.82. 

See Claim of Lien, Miami-Dade County Clerk of the Courts, County 

Recorder's Official Records, Clerk's File Number 2022 R 179247, March 

3, 2022. 

ni. Notice of Lis Pendens (regarding relief sought as to the Subject Property to 

foreclose a claim of lien) of PALAZZO DEL SOL/DELLA LUNA AT 

FISHER ISLAND CONDOMINIUM ASSOCIATION, INC., whose 

counsel at the time such notice was recorded (i.e., GURSKY RAGAN, 

P.A.) was subsequently substituted with SACHS SAX CAPLAN, P.L., 

3 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 4 of 8
6111 Broken Sound Parkway NW, Suite 200, Boca Raton, FL 33487. See 

Notice of Lis Pendens, Miami-Dade County Clerk of the Courts, County 

Recorder's Official Records, Clerk's File Number 2022 R 194483, March 

7, 2022; see also, Stipulation and Consent for Substitution of Counsel, 

PALAZZO DEL SOL/DELLA LUNA AT FISHER ISLAND 

CONDOMINIUM ASSOCIATION, INC VS PLANET 2 REACHING, INC 

ET AL, Case No. 2022-004165-CA-01 (Fla. 11th Jud. Cir. Ct., Miami-Dade 

Cnty. May 17, 2022), Doc. No. 34. 

b. There is no mortgage recorded against the Subject Property. 

c. There are no financing statements recorded against the Subject Property. 

d. There appear to be no tax warrants recorded against the Subject Property. However, 

a Notice of Application for Tax Deed of MIKON FINANCIAL SERVICES INC 

AND OCEAN BANK, holder of Certificate number 8695 issued on June 1, 2019, 

is recorded against the Subject Property. See Notice of Application for Tax Deed, 

Miami-Dade County Clerk of the Courts, County Recorder's Official Records, 

Clerk's File Number 2021R630276, August 25, 2021. 

e. There are no other liens (or notices regarding other possible liens) recorded against 

the Subject Property. 

f. The Subject Property 1s subject to all assessments levied by the 

Condominium/Homeowner Association. 

g. Real property taxes are owed to Miami-Dade County Tax Collector for tax year 

2021 in the approximate amount of $262,837.70 (if paid between June 30, 2022 

through August 31, 2022). Such taxes are payable to Miami-Dade Tax Collector, 

200 NW 2nd Avenue, Miami, FL 33128. 

10. Caballero does have another levy in process but believes in good faith that the total 

value of the property under execution does not exceed the outstanding amount to be levied upon. 

4 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 5 of 8
FURTHER SA YETH AFFIANT NAUGHT 

Leon N. Patricios 

STATE OF FLORIDA ) 

) SS 

COUNTY OF MIAMI-DADE ) 

SWORN TO AND SUBSCRIBED before me by means o~hysical presence or D online 

notarization this June ;2,, "~ 2022 by Leon N. Patricios. He is personally known to me or has 

produced as identification. 

~~ . NOTARYP ~~OFFLORIDA 

/ 

My Commission Expires: G6 q 137'f5 

~· p .. ~ 

/~"'m ~ "®;,, INA MUNA.GORRI i'iii:. . • J Notary Public· Stat' of Florida ~ f Commission fl GG 97J79S ·· ., f,\ ' My Comm. Expires Mar 26 202., 

Bonded through National Nota,.Y Assn. 

5 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 6 of 8
Mailing List (for the certified mailings required by section 56.21, Fla. Stat.) 

1. FARC-EP 

c/o Juvenal Ovidio Ricardo Palmera Pineda a/k/a/ "Simon Trinidad" 

Member ofFARC-EP 

BOP Register No. 27896-016 

USP Florence ADMAX 

5880 Hwy 67 South 

Florence, CO 81226 

2. FARC-EP 

c/o Juvenal Ovidio Ricardo Palmera Pineda a/k/a/ "Simon Trinidad" 

Member of F ARC-EP 

BOP Register No. 27896-016 

USP Florence ADMAX 

U.S. Penitentiary 

P.O. Box 8500 

Florence, CO 81226 

3. NDVC 

c/o Diego Leon Montoya Sanchez 

Member of NORTH VALLEY CARTEL 

BOP Register No. 04171-748 

FCI Petersburg Medium 

Federal Correctional Institution 

1060 River Road 

Hopewell, VA 23860 

4. NDVC 

c/o Diego Leon Montoya Sanchez 

Member of NORTH VALLEY CARTEL 

BOP Register No. 04171-748 

FCI Petersburg Medium 

Federal Correctional Institution 

P.O. Box 1000 

Petersburg, VA 23804 

5. PALAZZO DEL SOL/DELLA LUNA AT FISHER ISLAND CONDOMINIUM 

ASSOCIATION, INC., 7000 Fisher Island Dr., Fisher Island, FL 33109 

6. SACHS SAX CAPLAN, P.L., on behalf of PALAZZO DEL SOL/DELLA LUNA 

AT FISHER ISLAND CONDOMINIUM ASSOCIATION, INC., at: 6111 Broken 

Sound Parkway NW, Suite 200, Boca Raton, FL 33487 

Page 1 of2 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 7 of 8
7. MIKON FINANCIAL SERVICES INC c/o its Registered Agent, Richard Capote, 

at: 6405 N.W. 36 ST. STE 125, Miami, FL 33166 

8. OCEAN BANK c/o its Registered Agent, Interamerican Corporate Services LLC, 

at: 2525 Ponce de Leon Blvd, Suite 1225, Coral Gables, FL 33134 

9. Miami-Dade County Tax Collector, 200 NW 2nd Avenue, Miami, FL 33128 

10. Planet 2 Reaching, Inc., 7043 Fisher Island Dr., Unite 7043, Miami Beach, FL 

33109-0064 

11. Planet 2 Reaching, Inc. c/o Secretary of State for Delaware, 401 Federal Street, 

Suite 4, Dover, DE 19901 1 

12. Planet 2 Reaching, Inc. c/o Cosme de la Torriente, P.A. 155 SW 25th Road, Miami, 

FL 33129 

13. Howard Srebnick, BLACK SREBNICK, P.A., on behalf of Raul Gorrin, at: 201 

South Biscayne Blvd., Suite 1300, Miami, Florida 33131 

14. Ed Wilson, Venable, LLP, on behalf of Raul Gorrin, at: 600 Massachusetts Avenue, 

NW Washington, DC 20001 

1 Pursuant to the requirements of the Secretary of State of Delaware for substitute service. 

Page 2 of2 

Case 1:21-cv-23103-BB Document 122-1 Entered on FLSD Docket 01/19/2023 Page 8 of 8