Exhibit 11

Case 9:22-cv-81731-DMM Document 43-11 Entered on FLSD Docket 04/07/2023 Page 1 of 4
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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CIVIL DIVISION

DEVIN FILIPPELLI as 

Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, CASE NO.: 9:22-cv81731

on behalf of the Estate and her Survivors, 

Plaintiff, 

v. 

GROW, LLC (d/b/a KD INCORPORATED 

and THE KRATOM DISTRO); and SEAN 

MICHAEL HARDER, individually. 

 Defendants.

___________________________________________/

DECLARATION OF DEVIN FILIPPELLI

I, Devin Filippelli, state the following in support of Plaintiff’s Motion for 

Entry of Final Default Judgment: 

1. My name is Devin Filippelli, and I am the eldest son of Krystal

Talavera.

2. My mom’s passing was the absolute worst thing that my family and I

experienced. 

3. I was 18 and getting ready to move away to college in two short

months. We had a plan in place for her to pay my living expenses so that I 

would be able to maintain focus on my schooling. 

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4. This was mainly possible due to the new job she had gotten just a 

couple of months prior. My mom had worked her way up the ladder as a nurse, 

to make the level of income to be able to do things like that for my brothers and 

me.

5. On June 20, 2021, all those plans were put on hold. I got a call saying 

she was in the hospital and it “didn’t look good.” 

6. I still had no idea what was going on, but the last thing I was 

expecting the day after my high school graduation was a phone call like that 

one. 

7. In the coming days, I had to plan a funeral, visit cemeteries, talk to 

investigators, etc. All while trying to find time to pack my things and move 

across the state to a new city where I knew almost nobody. 

8. The amount of mental taxation those few weeks took on me were

unimaginable. Not to mention, trying to assure my younger brothers that 

everything was going to be okay, while not even believing that statement 

myself. 

9. I moved to college, where I had absolutely zero financial assistance, 

and got a job the first day I was there to ensure I could pay for rent, classes, 

textbooks, and all the costs associated with living alone. 

10. I was working 50+ hours per week most weeks and, naturally, my 

performance in school started to slip. After just a semester in college, I had no 

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choice but to move in with my dad due to being unable to keep up with the load 

I had to take on. 

11. If my mom was still here, I wouldn’t have had to move. I would still 

be living the college experience with the people I met there. I would be a Junior 

in college about to graduate, and my younger brothers would have gotten to 

spend more time with her. 

12. Instead, all of that was ripped away from not just us, but our entire 

family. 

13. My mom was the nucleus of our family. She was the one who brought 

everyone together. She hosted Thanksgiving and Christmas every year. 

14. For all of that to be gone in just an instant has had a devastating 

impact on all of us, and will continue to do so for the rest of our lives.

I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE 

BEST OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT 

IS MADE FOR USE AS EVIDENCE IN COURT AND IS SUBJECT TO 

PENLATY FOR PERJURY.

Executed: April 6, 2023

______________________________

 Devin Filippelli

DocuSign Envelope ID: 90BD0382-84D7-4ED8-9C48-30B89C5FA6AB Case 9:22-cv-81731-DMM Document 43-11 Entered on FLSD Docket 04/07/2023 Page 4 of 4