EXHIBIT A 

Case 1:22-cv-24262-RKA Document 7-1 Entered on FLSD Docket 01/04/2023 Page 1 of 18
Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com 

UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

RICCARDO SILVA, 

Plaintiff, 

vs. 

JOHN DOE 1 (OWNER(S) OF WEBSITE 

SOSSILVA.ORG); 

JOHN DOE 2 (OWNER(S) OF REDDIT 

USERNAME @SOSILVA7); 

JOHN DOE 3 (OWNER(S) OF TWITTER 

HANDLE @SOSSILVA7); 

JOHN DOE 4; 

MOBILE BILLBOARDS, INC., 

 Defendants.

Case No.: 1:22-cv-24262-RKA 

 

COMPLAINT 

Plaintiff Riccardo Silva (“Silva”), hereby sues Defendants John Doe 1, John Doe 2, John 

Doe 3, and John Doe 4, all of whom may be a single person or may be more than one person (the 

“John Doe Defendant(s)”), and Mobile Billboards, Inc. (the “Mobile Billboard Defendant,” and 

together with the John Doe Defendant(s), the “Defendants”) and alleges: 

INTRODUCTION 

1. This case involves a defamatory campaign waged by the John Doe Defendant(s), 

with the assistance of the Mobile Billboard Defendant, against Mr. Silva, a successful 

businessman, a philanthropist, and a devoted husband and father, which campaign was designed 

to damage Mr. Silva both personally and professionally by publishing false and outrageous 

accusations of criminality against him. 

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2. The purpose of this defamatory campaign is unknown to Mr. Silva, as the John Doe 

Defendants have hidden their identity or identities, but the campaign was designed to cause—and 

has in fact caused—grave damage to Mr. Silva and his family. 

3. Indeed, the Defendants sent a mobile billboard around South Miami Beach during 

the weekend of Miami Art Basel featuring a large photo of Mr. Silva’s face with text knowingly 

falsely accusing Mr. Silva of being a “predator.” Mr. Silva was in Miami at the time with his wife 

and children, and his seventeen-year-old son saw the billboard. This has, not surprisingly, caused 

devastation to Mr. Silva and his family. 

4. The mobile billboard directed viewers’ attention to Twitter and Reddit pages, 

created by the John Doe Defendant(s), which contain additional knowingly false and defamatory 

statements. The John Doe Defendant(s) have also created a website that includes still more 

knowingly false and defamatory statements and accusations against Mr. Silva. 

5. The Defendants have caused and are continuing to cause grave damage to Mr. Silva 

by publishing this knowingly false and defamatory material accusing Mr. Silva of criminal and 

deviant conduct. Mr. Silva and his family are in fear of their safety and security as a result of the 

Defendants’ harassment and defamatory campaign. 

JURISDICTION AND VENUE

6. The Court has subject matter jurisdiction over this case because the amount of 

damages sought by Mr. Silva, exclusive of any attorney’s fees, costs, and expenses, exceeds 

$75,000.

7. This Court has personal jurisdiction over each of the Defendants in that, at all 

relevant times, they (a) resided in Florida and/or (b) committed tortious acts in Florida.

8. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(1) and/or 1391(b)(2) 

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because at least one of the Defendants reside in this District and all Defendants are residents of 

Florida, and/or because a substantial part of the events giving rise to the below claims occurred in 

this District.

THE PARTIES 

9. Mr. Silva is an individual whose domicile is London, United Kingdom. Mr. Silva 

owns a condominium in South Miami Beach. 

10. Defendant John Doe 1 is the owner of the website sossilva.org. Upon information 

and belief, John Doe 1 resides in the State of Florida. John Doe 1 committed the tortious acts 

described herein in the State of Florida. Notably, as the allegations infra show, John Doe 1 may 

be one or more individuals and may be the same individual as John Doe 2, 3, or 4. 

11. Defendant John Doe 2 is the owner of the Reddit username @SOSilva7. Upon 

information and belief, John Doe 2 resides in the State of Florida. John Doe 2 committed the 

tortious acts described herein in the State of Florida. Notably, as the allegations infra show, John 

Doe 2 may be one or more individuals and may be the same individual as John Doe 1, 3, or 4. 

12. Defendant John Doe 3 is the owner of the Twitter handle @SOSSilva7. Upon 

information and belief, John Doe 3 resides in the State of Florida. John Doe 3 committed the 

tortious acts described herein in the State of Florida. Notably, as the allegations infra show, John 

Doe 3 may be one or more individuals and may be the same individual as John Doe 1, 2 or 4. 

13. Defendant John Doe 4 is the individual who hired the billboard from the Mobile 

Billboard Defendant. Upon information and belief, John Doe 4 resides in the State of Florida. John 

Doe 4 committed the tortious acts described herein in the State of Florida. Notably, as the 

allegations infra show, John Doe 4 may be one or more individuals and may be the same individual 

as John Doe 1, 2, or 3. 

14. The Mobile Billboard Defendant is a Florida corporation with principal offices in 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

Parrish, Florida, and is duly authorized to conduct business in the State of Florida. The Mobile 

Billboard Defendant offers mobile billboard services—i.e., a billboard that is placed on the rear of 

a motor vehicle and is observable by other motorists and pedestrians. The Mobile Billboard 

Defendant committed the tortious acts described herein in the State of Florida.

FACTUAL BACKGROUND 

15. Mr. Silva is a husband, a father, and a renowned businessman and investor. He 

owns the investment company, Silva International Investments, an investment company that 

manages and invests in various sectors—media, technology, sports, entertainment, the arts, and 

real estate, to name a few. He also owns the model and talent agency, Select Model Management. 

In addition, he is the president and co-owner of the American professional soccer team, Miami FC, 

and an investor in and co-owner of AC Milan, one of the most successful soccer teams in the 

world. 

16. Mr. Silva is a devoted philanthropist, as well. He donates substantial time and 

money to various causes. He has made significant donations across a range of projects in Europe, 

Africa, and the United States (particularly, Miami, Florida), including to Florida International 

University (“FIU”), Mount Sinai Medical Center, Gulliver Schools, St. Stephen’s Episcopal Day 

School, the Bass Museum of Art, the New World Symphony, Play for Change, The Foundation 

for AIDS Research, Elton John AIDS Foundation, the Novak Djokovic Foundation, Movimiento 

Shalom, and the Bali Street Kids Project. In recognition of Mr. Silva’s contributions to FIU and, 

more generally, to the city of Miami, FIU named its football and soccer stadium—Riccardo Silva 

Stadium—after him.

17. Mr. Silva is an upstanding, law-abiding citizen. And yet, to his shock, the 

Defendants have recently set forth a damaging campaign against him, designed to damage him 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

personally and professionally by accusing him of conduct that is categorially false. Specifically, 

the Defendants have falsely accused Mr. Silva of serial sexual abuse and sexual harassment, 

bribery, and other falsely alleged conduct. Outrageously, the Defendants have falsely compared 

Mr. Silva to the likes of Jeffrey Epstein. 

18. Each and every one of these accusations against Mr. Silva is knowingly false—

fabricated by the Defendants to damage and destroy Mr. Silva’s personal and professional life. 

19. Mr. Silva seeks compensatory and punitive damages resulting from the harm that 

the Defendants’ defamatory campaign has caused him and will continue to cause him. 

The Website 

20. John Doe 1 created the website sossilva.org (the “Website”) on September 8, 2022. 

21. The Website contains only the following accusations: 

22. Each and every one of these accusations made by John Doe 1 on the Website against 

Mr. Silva is knowingly false, defamatory, and extreme and outrageous. 

The Reddit Campaign 

23. John Doe 2 created the Reddit username u/SOSilva7 on September 8, 2022—the 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

same day the Website was created. 

24. Throughout October 2022, u/SOSilva7 made the following post (the “Reddit 

Posts”) across several Reddit forums, including r/NYC, r/Miami, r/Florida, r/Chicago, r/Illinois, 

r/London, r/metoo, r/Modeling, r/sexualassault, r/TwoXChromosomes, r/abusesurvivors, 

r/emotionalabuse. Together, there are roughly 16.1 million members in these Reddit forums: 

“TW- my story of abuse and harassment. 

Hello All, 

I was in the industry for years and left after the incident I’ve described below. 

Currently, my goal is to make aspiring models and others interested in the industry 

aware that this behavior occurs and is far more commonplace than most think. 

Everything here happened to me and unfortunately was experienced by several 

people. 

A few years ago, I began working with Select Model Management. They had (and 

objectively have) a decent reputation in a industry where we all pretty much realize 

it is only a matter of time until we experience something creepy, unwelcomed or 

downright horrible. 

Over the course of my work, I interacted with Riccardo Silva. He’s European 

(Italian I think) and married. Extremely wealthy. Multiple businesses and 

everything you’d expect. We were at several events together and he was always 

surrounding himself with my colleagues, other women from other agencies or just 

women in general. His vibe was . . . neutral but hostile? If that makes sense? Not a 

huge change from most in the industry, so I really just went about my work. 

Over time, I saw him at other events more frequently, we made small talk and that 

was about it. One time he touched my shoulder with unusual force, but I didn’t 

think much of it. Then he started reaching out. This was unsettling, because I 

certainly didn’t expect it and while the agency had all of my info, you don’t expect 

someone who is essentially your boss to reach out socially. 

It went from a normal, ‘hey, how are you’, and got weird immediately after. Asking 

me what I liked sexually. Telling me his body count and who specifically in our 

agency that he slept with. The ‘obvious benefits’ of me sleeping with him. My brain 

just blanked. I didn’t really respond initially. This had happened so often before at 

other places, and a quick ‘fck off!’ usually helped, but not with a person at this level 

and not there. I just didn’t know what to do. 

He kept it up, it became almost an everyday thing. I started to respond and tell him 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

this made me uncomfortable. He ignored it every time. When I saw him, he’d touch 

me and say things under his breath. If I was talking to other men, he’d interject 

himself into the conversation. All the while, he kept harassing me. I mentioned it 

to other people and they’d shrug, or nod, share their experience and tell me to stay 

as far away from him as possible. It made me physically sick. I lost weight, lost 

interest in a lot of things. One of the worst parts was seeing him present this image 

to the outside world that he was a good guy, pictures with his family playing soccer, 

art donations, etc. Meanwhile, he tormented me at the same time. 

He ramped it up and got angry. If I wouldn't sleep with him on my own, I'd ‘do it 

for money, of course’ Constant propositions, across phone, text, dm, etc. Shaming 

me. Saying he’d destroy me. Destroy my career. Shame my family, especially a 

family member that was very ill at the time. All the things I feared, however 

irrational, he pushed on and made me feel like shit. It came to a head when I saw 

him for the last time and he grabbed me so hard on my arm it left bruises. Told me 

he ‘wasn’t interested in trash like me’, that he just wanted to toy with me, that I 

wasn’t pretty enough anyway. 

I quit. Soon after, a flood of people reached out to me, sharing their experiences, 

which were identical to my own in some cases, and far, far, far worse in others. He 

harassed, intimidated, and violently abused several women. He abused his position 

of power to abuse others. 

My life was pretty beautiful, and it still is, but despite therapy and wonderful family 

and friends, Riccardo’s harassment and abuse changed who I am, and how I interact 

with people in every part of my life. 

It made me harder, but I’m determined to use that to help others. To make people 

like him know that they can't treat people like that and to call that abuse out for 

others. 

If you have experienced anything like this, I send you strength and love. Thank you 

all for reading.” 

25. In December 2022, John Doe 2 created and assigned itself as the moderator of the 

Reddit forum r/SOSSilvaSurvivors (the “Reddit Forum”). 

26. In the Reddit Forum, u/SOSilva7 made the following post: 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

27. Each and every one of these accusations made by John Doe 2 on Reddit against Mr. 

Silva is knowingly false, defamatory, and extreme and outrageous. 

The Twitter Campaign 

28. In September 2022, John Doe 3 created the Twitter account @SOSSilva7, which is 

based out of Miami, Florida, as the account’s Twitter page shows. The biography reads: 

“Survivors Of Silva- The survivors of sexual violence and intimidation at the hands of Riccardo 

Silva of Select Model Management/Silva International Investments”: 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

29. On December 3, 2022, John Doe 3 posted a five-tweet thread, tagging media 

entities, such as the Miami Herald, Miami New Times, and Miami Beach News, along with the 

Twitter account for the international arts festival, Art Basel, which is located in Miami, Florida. 

The thread contained similar defamatory and false accusations to those made by John Doe 1 on 

the Website and by John Doe 2 on Reddit: 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

30. Like the false accusations against Mr. Silva on the Website and on Reddit, John 

Doe 3’s accusations of grotesque conduct against Mr. Silva on Twitter are knowingly false, 

defamatory, and extreme and outrageous. 

The Mobile Billboard Campaign 

31. In or around December 2, 2022, Defendant John Doe 4 purchased a mobile 

billboard (the “Billboard”) from the Mobile Billboard Defendant. 

32. Defendant John Doe 4 hired the Mobile Billboard Defendant to drive around the 

location of Mr. Silva’s condominium he owns in South Miami Beach on Saturday, December 3, 

2022, which was the weekend of Miami Art Basel, one of the busiest weekends of the year in 

Miami Beach. 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

33. On the Billboard, the Defendants falsely accused Mr. Silva of being a “predator on 

the loose in Miami.” Observers of the Billboard are further directed to the above-referenced 

Twitter handle, @SOSSilva7, and Reddit Forum, r/SOSSilvaSurvivors: 

34. The Defendants’ accusation that Mr. Silva is a “predator” is knowingly false, 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

defamatory, and extreme and outrageous. And, as alleged supra, the accusations against him on 

Twitter and Reddit are knowingly false, defamatory, and extreme and outrageous. 

35. The Mobile Billboard Defendant knew or should have known the accusations 

against him were false or, at least, the Mobile Billboard Defendant recklessly disregarded the 

falsity of the accusations.

36. Mr. Silva’s seventeen-year-old son witnessed the truck driving around the 

neighborhood of Mr. Silva’s South Beach condo. He was devasted to see his father portrayed in 

this way. This has caused extreme emotional distress to Mr. Silva and his family. 

37. Mr. Silva has suffered damages as a result of the Defendants’ knowingly false, 

defamatory, extreme and outrageous, and injurious campaign against him. In particular, Mr. Silva 

has suffered, and will continue to suffer, monetary damages, including in connection with his 

reputation and business interests, and severe emotional distress. In addition, Mr. Silva fears for 

his and his family’s safety and security, given the defamatory and harassing campaign against him. 

38. All conditions precedent to the maintenance of this action have occurred, been 

performed, complied with, or waived. 

COUNT I: DEFAMATION (LIBEL) 

(Against All Defendants)

39. Mr. Silva incorporates as if fully set forth herein paragraphs 1 through 38 above. 

40. The Defendants published to millions of third parties knowingly false, defamatory 

statements of and concerning Mr. Silva on the Website, Twitter, Reddit, and the Billboard, as 

outlined supra. 

41. The Defendants knew that said statements of and concerning Mr. Silva were false, 

recklessly disregarded the falsity of said statements, and/or were negligent as to the falsity of said 

statements. 

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42. As a result of the Defendants’ wide publication of the above false statements, Mr. 

Silva has suffered damages, including without limitation, monetarily, to his reputation, and to his 

business interests. 

WHEREFORE, Mr. Silva demands judgment against the Defendants for money damages, 

pre- and post-judgment interest, and such other relief as the Court deems just and proper. In 

addition, Mr. Silva seeks punitive damages pursuant to Fla. Stat. § 768.72. 

COUNT II: DEFAMATION (LIBEL) PER SE 

(Against All Defendants)

43. Mr. Silva incorporates as if fully set forth herein paragraphs 1 through 42 above. 

44. The Defendants published to millions of third parties knowingly false, defamatory 

statements of and concerning Mr. Silva on the Website, Twitter, Reddit, and the Billboard, as 

outlined supra. 

45. Those false, defamatory statements charged that Mr. Silva committed infamous 

crimes and/or felonies, including without limitation, sex crimes and bribery. In addition, the false, 

defamatory statements subject Mr. Silva to hatred, distrust, ridicule, contempt, and/or disgrace. 

Finally, the false, defamatory statements harm Mr. Silva in his many business ventures articulated 

supra. 

46. Accordingly, Mr. Silva has suffered damages, including without limitation, 

monetarily, to his reputation, and to his business interests. 

WHEREFORE, Mr. Silva demands judgment against the Defendants for money damages, 

pre- and post-judgment interest, and such other relief as the Court deems just and proper. In 

addition, Mr. Silva seeks punitive damages pursuant to Fla. Stat. § 768.72.

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COUNT III: DEFAMATION (LIBEL) BY IMPLICATION 

(Against All Defendants)

47. Mr. Silva incorporates as if fully set forth herein paragraphs 1 through 46 above. 

48. Mr. Silva asserts Count III in the alternative to Counts I and II. 

49. To the extent that one or more of the Defendants’ statements on the Website, 

Twitter, Reddit, and/or the Billboard, which were published to millions of people, are determined 

to be true, all resulting suggestions, impressions, and/or implications that Mr. Silva engaged in any 

criminal or deviant misconduct are false. 

50. The false suggestions, impressions, and/or implications that Mr. Silva engaged in 

any criminal or deviant misconduct have caused serious harm to Mr. Silva. 

51. Accordingly, Mr. Silva has suffered damages, including without limitation, 

monetarily, to his reputation, and to his business interests. 

WHEREFORE, Mr. Silva demands judgment against the Defendants for money damages, 

pre- and post-judgment interest, and such other relief as the Court deems just and proper. In 

addition, Mr. Silva seeks punitive damages pursuant to Fla. Stat. § 768.72.

COUNT IV: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 

(Against All Defendants)

52. Mr. Silva incorporates as if fully set forth herein paragraphs 1 through 51 above. 

53. The Defendants engaged in extreme and outrageous conduct, including without 

limitation, by setting forth an internet and billboard campaign to falsely accuse Mr. Silva of 

heinous, criminal conduct—being compared to the likes of Jeffrey Epstein. Engaging in a 

campaign to publish knowingly false and defamatory accusations of the most grotesque order goes 

beyond all possible bounds of decency and such ruthless attacks are intolerable in a civilized 

society. 

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54. The Defendants engaged in such extreme and outrageous conduct with the intent to 

ruin Mr. Silva’s personal and professional life, and thus to cause him severe emotional distress. 

55. At the very least, the Defendants’ extreme and outrageous conduct was done with 

reckless disregard to the probability of causing Mr. Silva severe emotional distress. 

56. Mr. Silva has suffered severe emotional distress, and will continue to suffer severe 

emotional distress, as a result of the Defendants’ extreme and outrageous conduct. In addition, the 

mobile billboard was seen by Mr. Silva’s seventeen-year-old son, a likely, and indeed intended, 

consequence of having the mobile billboard driven outside of Mr. Silva’s condominium. Mr. 

Silva’s son was extremely distraught by what he saw, which has caused Mr. Silva severe emotional 

distress at the damage this defamatory publication has inflicted on his entire family. 

WHEREFORE, Mr. Silva demands judgment against the Defendants for money damages, 

pre- and post-judgment interest, and such other relief as the Court deems just and proper. In 

addition, Mr. Silva seeks punitive damages pursuant to Fla. Stat. § 768.72. 

COUNT V: INJUNCTION – STALKING, § 784.0485(1), FLA. STAT. 

(Against All Defendants)

57. Mr. Silva incorporates as if fully set forth herein paragraphs 1 through 56 above. 

58. The Defendants have willfully, maliciously, and repeatedly harassed Mr. Silva 

through their harassment and defamatory campaign against him, both online and in person. 

59. Mr. Silva has suffered severe emotional distress, and will continue to suffer severe 

emotional distress, as a result of the Defendants’ campaign. In addition, Mr. Silva and his family 

have suffered from grave concerns to their safety and security as a result of the Defendants’ 

harassment and defamatory campaign. 

60. The Defendants’ harassment and defamatory campaign serves no legitimate 

purpose, as it is based on knowing falsehoods. 

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Greenberg Traurig, P.A.  333 S.E. 2nd Avenue, Suite 4400  Miami, Florida 33131  Tel 305.579.0500  Fax 305.579.0717  www.gtlaw.com

61. Mr. Silva has a clear legal right to not be harassed and defamed in violation of the 

law. 

62. There is no adequate remedy at law for the further violation of this right, 

necessitating this Court’s intervention to enjoin the Defendants from continuing their campaign. 

63. Should the Court fail to permanently enjoin the Defendants from continuing their 

campaign, Mr. Silva will continue to suffer severe emotional distress and he and his family will 

continue to be in grave fear for their safety and security. 

WHEREFORE, Mr. Silva demands an order permanently enjoining the Defendants from 

continuing their harassment and defamatory campaign, and such other relief as the Court deems 

just and proper. 

Dated: January 4, 2023 Respectfully submitted, 

By: /s/ Joshua M. Mandel 

GREENBERG TRAURIG, PA 

333 S.E. 2nd Avenue, Suite 4400 

Miami, Florida 33131 

Telephone: (305) 579-0570 

Facsimile: (305) 961-5702 

THOMAS R. HEISLER 

Florida Bar No. 1029852 

heislert@gtlaw.com 

BENJAMIN GREENBERG 

Florida Bar No. 192732 

greenbergb@gtlaw.com

JOSHUA M. MANDEL 

Florida Bar No. 1031396 

mandelj@gtlaw.com 

cruzm@gtlaw.com 

fernandezf@gtlaw.com 

FLService@gtlaw.com 

Counsel for Plaintiff Riccardo Silva

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