Composite

Exhibit B

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 1 of 26
3/9/23, 1:36 PM Job Details

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Details for Job 2022001911

General Information

Party To Be Served: THOMAS BRADY

Person To Be Served: THOMAS BRADY

Received Date/Time: 12/21/2022 10:50 AM

Documents To Be Served:

SUMMONS TO THOMAS BRADY, AMENDED COMPLAINT (20 DAYS), PLAINTIFFS'

FIRST REQUEST FOR ADMISSION TO THOMAS BRADY, PLAINTIFFS' FIRST SET

OF INTERROGATORIES TO THOMAS BRADY, PLAINTIFFS' FIRST SET OF

REQUEST FOR PRODUCTION TO THOMAS BRADY

Court Date/Time: None

Case Information

Case Number: 2022-0022900-CA-01

Judge: None

Plaintiff: MICHAEL NORRIS, ET AL.

Defendant: DAVID ORTIZ, ET AL.

Case Date Filed: None

Amended Date Filed: None

Service Information

Served: THOMAS BRADY

Date/Time Served: 12/27/2022 12:05 PM

Method of Service: NON SERVICE

Detailed Service Info: NON-SERVED: After due search, careful inquiry and diligent attempts I was unable to serve

the SUMMONS TO THOMAS BRADY, AMENDED COMPLAINT (20 DAYS), PLAINTIFFS'

FIRST REQUEST FOR ADMISSION TO THOMAS BRADY, PLAINTIFFS' FIRST SET OF

INTERROGATORIES TO THOMAS BRADY, PLAINTIFFS' FIRST SET OF REQUEST FOR

PRODUCTION TO THOMAS BRADY for the reason that I failed to find THOMAS BRADY

or information to allow further search.

Service Address: ONE BUC PLACE, TAMPA, FL 33607

Recipient Description: None

Servee Addresses

Address(es)

ONE BUC PLACE, TAMPA, FL 33607

588 RIVERA DR., TAMPA, FL

Comments

Show Location Column

Date/Time Body

1/2/2023

1:44 PM Assigned Type of Service: NON-SERVE - COMMENTS

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 2 of 26
3/9/23, 1:36 PM Job Details

https://www.pstprostatus.net/asp/jobdetail.aspx?ID=2022001911 2/2

Attempted on 12-21-2022 @ 3:17pm Server attempted provided address "ONE BUC PLACE, TAMPA"

and was advised by security Thomas May that subject was gone for the day and unknown when he

would return or could not provide any contact info, security called the legal department who advised

that no one from this department would be accepting the documents Attempted on 12-22-2022 @

6:15am Server attempted the provided address and met with security guard Mark Ostapowicz (w/m,

40+, 5’6, 170 LBS, brown hair and glasses) who stated that legal was not at the facility to accept the

papers and would need to come back another time. CHANGED SERVERS TO CONTINUE

ATTEMPTS. Attempted on 12-22-2022 @ 11:50am Different server attempted and was advised by

security (50+yrs., w/m, 5'8, 160 lbs.,blonde hair, glasses) subject was not here and the legal

department didn't come in today. Received call on 12-22-2022 Server received call from Chief Legal

Officer of the Buccaneers Dan Malasky requesting information on the summons so that he can get

authorization to accept service........server advised Mr. Malasky of the case and he advised server he

would call back. Attempted 2nd address "588 RIVIERA DR., TAMPA" RUSH on 12-22-2022 @

12:20Pm Server attempted 2nd address "588 RIVIERA DR., TAMPA" and there was a security gate at

entrance with a call box at and no response. Attempted 1ST ADDRESS "ONE BUC PLACE, TAMPA"

on 12/27/22 @ 12:05pm Facilities Director of Security Tom Rowan (55+yrs., w/m, 5'8, 175lbs, brown

hair, no glasses) advised subject isn't available to receive summons. He contacted legal and further

advised legal has servers information and is currently trying to contact Mr Brady's agent to get

authorization to receive summons

12/27/2022

8:40 PM

Attempted on 12/27/22 @ 12:05pm Jobs (5374) (5375) Thomas Brady Facilities Director of Security

Tom Rowan (55+yrs., w/m, 5'8, 175lbs, brown hair, no glasses) advised subject isn't available to

receive summons. He contacted legal and further advised legal has my information and is currently

trying to contact Mr Brady's agent to get authorization to receive summons.............WILL NON SERVE

PER CLIENT.

12/22/2022

2:41 PM

Attempted 2nd address "588 RIVIERA DR., TAMPA" RUSH on 12-22-2022 @ 12:20pm Jobs (5374)

(5375) Thomas Brady Server attempted 2nd address "588 RIVIERA DR., TAMPA" and there was a

security gate to entrance, and call box at entrance and no response

12/22/2022

2:15 PM

Received call on 12-22-2022 @ 1:50PM Jobs (5374) (5375) Thomas Brady Server received call from

Chief Legal Officer of the Buccaneers Dan Malasky requesting information on the summons so that he

can get authorization to accept service........server advised Mr. Malasky of the case and he advised

server he would call back

12/22/2022

1:18 PM

Attempted RUSH on 12-22-2022 @ 11:50am Jobs (5374) (5375) Thomas Brady Different server

attempted and was advised by security (50+yrs., w/m, 5'8, 160 lbs.,blonde hair, glasses) subject was

not here and the legal department didn't come in today

12/22/2022

7:25 AM

Attempted RUSH on 12-22-2022 @ 6:15am Jobs (5374) (5375) Thomas Brady Server attempted the

provided address and met with security guard Mark Ostapowicz (w/m, 40+, 5’6, 170 LBS, brown hair

and glasses) who stated that legal was not at the facility to accept the papers. Ostapowicz stated that I

would need to come back at another time and that he did not know when legal would be available.

12/22/2022

6:37 AM

Attempted RUSH on 12-21-2022 @ 3:17pm Jobs (5374) (5375) Thomas Brady Server attempted

provided address "ONE BUC PLACE, TAMPA" and was advised by security Thomas May that subject

was gone for the day and unknown when he would return or could not provide any contact info, security

called the legal department who advised that no one from this department would be accepting the

documents...........server will attempt again very early Thursday 12-22

12/21/2022

12:42 PM Assigned Job to our server.

Attachments

Purpose Description Format Show Attachment

N/A COMPLAINT FOR SERVICE Adobe PDF Show Attachment

N/A SERVICE DOCUMENTS Adobe PDF Show Attachment

Non Serve Affidavit Affidavit Adobe PDF Show Attachment

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 3 of 26
3/9/23, 1:35 PM Job Details

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Details for Job 2023000253

General Information

Party To Be Served: SHAQUILLE O'NEAL

Person To Be Served: None

Received Date/Time: 2/21/2023 6:06 PM

Documents To Be Served: SUMMONS & AMENDED COMPLAINT (21 DAYS)

Court Date/Time: None

Case Information

Case Number: 22-CV-23753-KMM

Judge: None

Plaintiff: EDWIN GARRISON, ET AL., ON BEHALF OF THEMSELVES AND ALL OTHERS

SIMILARLY SITUATED

Defendant: SAM BANKMAN-FRIED, ET AL.

Case Date Filed: 12/16/2022

Amended Date Filed: None

Service Information

N/A - Job is not finished.

Servee Addresses

Address(es)

(2ND ADD) 4012 SAHARA COURT, CARROLLTON, TX

Comments

Show Location Column

Date/Time Body

3/8/2023

3:41 PM

Another attempt to contact Leonard Armato, 310-545-1000. Left a voicemail. Rejane, do you think its a

good idea that you call him as well since you are from the law firm directly? I figured we could team up

and call him simultaneously. Let me know. I will keep trying regardless.

3/6/2023

12:15 PM

Service Type: Unsuccessful Attempt Description of Service: No answer at door. The call back card left

prior, is gone. Service Address 4012 Sahara Ct, Carrollton, TX 75010

3/6/2023

4:25 PM

I left a voice mail for Shannon. She is the executive assistant for Perry Rogers (702) 214-5570. He

represents Shaq. I will keep you posted. I also called the server to find out how many more attempts

he has made.

2/24/2023

12:28 PM Sent the server the 2nd address of 4012 Sahara Court, Carollton, TX. He will attempt it next week.

2/23/2023

6:36 PM

I ran a skip trace. He has not registered a new home address. I sent an email to https://prp-lv.com/

which I believe is his agent or publicist. I will let you know if they reach out to me. His skip trace is

attached.

I made an attempt this morning. There was no response at the door. No lights on either. There was a

black Honda in the driveway, but it did not have a license plate. There was also an Escalade with the

plate number PYS3074. The plate came back registered to Arnetta Yardbourgh. She is listed as a

resident and the car is registered at that address. I was surprised that there were no security gates or

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 4 of 26
3/9/23, 1:35 PM Job Details

https://www.pstprostatus.net/asp/jobdetail.aspx?ID=2023000253 2/2

a call box. Pictures attached. Need another address. Rejane do you want a skip trace for him or do

you have another address for him?

Attachments

Purpose Description Format Show Attachment

Picture Pictures JPG Picture Show Attachment

Picture Picture JPG Picture Show Attachment

N/A SKIP TRACE Adobe PDF Show Attachment

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 5 of 26
3/9/23, 1:36 PM Job Details

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Details for Job 2023000250

General Information

Party To Be Served: UDONIS HASLEM

Person To Be Served: None

Received Date/Time: 2/21/2023 3:32 PM

Documents To Be Served: SUMMONS AND AMENDED COMPLAINT (21 DAYS)

Court Date/Time: None

Case Information

Case Number: 22-CV-23753-KMM

Judge: None

Plaintiff: EDWIN GARRISON, ET AL., ON BEHALF OF THEMSELVES AND ALL OTHERS

SIMILARLY SITUATED

Defendant: SAM BANKMAN-FRIED, ET AL.

Case Date Filed: 12/16/2022

Amended Date Filed: None

Service Information

Served: UDONIS HASLEM

Date/Time Served: 2/28/2023 8:38 AM

Method of Service: SUBSTITUTE SERVICE (SPOUSE)

Detailed Service Info: SUBSTITUTE SERVED this SUMMONS AND AMENDED COMPLAINT (21 DAYS) on

FAITH HASLEM Spouse of the within named defendant, pursuant to F.S.48.031(2).(A).

Service Address: INTERSECTION OF WESTON ROAD AND GRIFFIN ROAD, SOUTHWEST RANCHES, FL

33332

Recipient Description: Age: 41, Sex: F, Race/Skin Color: BLACK, Height: N/A, Weight: 150, Hair: BLACK ,

Glasses: N

Servee Addresses

Address(es)

INTERSECTION OF WESTON ROAD AND GRIFFIN ROAD, SOUTHWEST RANCHES, FL 33332

5450 SW 192 TERRACE, SOUTHWEST RANCHES, FL 33332

Comments

Show Location Column

Date/Time Body

--After numerous attempts to reach an occupant of the property, I drove across the street to notate my

attempt. Shortly after, one of the vehicles from the property, a white BMW, FL tag AG65GL drove out of

the gate and passed me. The driver did not stop at the stop sign. I met the driver at the intersection of

Griffin Road and Weston Road. It was Faith Haslem, the defendant’s spouse. After identifying myself

and the reason for my attempt of service, Faith Haslem took pictures of my SPS badge and refused to

communicate. After reading the summons out loud, I placed it on her windshield as sufficient service. I

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 6 of 26
3/9/23, 1:36 PM Job Details

https://www.pstprostatus.net/asp/jobdetail.aspx?ID=2023000250 2/2

also ran the tag AG65GL and it came back to Faith Haslem. I Googled her name and it was the same

person I served.

2/28/2023

8:30 AM

--Attempted service at 5450 SW 192 TERRACE, SOUTHWEST RANCHES, FL 33332, Service location

is a gated single family residential property. Access is only granted through gate code or remote

access. I rang the doorbell at the gate, no response.

2/25/2023

7:49 PM

--Attempted service at 5450 SW 192 TERRACE, SOUTHWEST RANCHES, FL 33332, Service location

is a gated single family residential property. Access is only granted through gate code or remote

access. I rang the doorbell at the gat, an unidentified female individual responded. Communication

signal between the individual and I was scrambled, bad reception. I made multiple attempts to reach

the individual but no success.

2/24/2023

9:44 AM THIS WILL BE ATTEMPTED TOMORROW SATURDAY.

Attachments

Purpose Description Format Show Attachment

Affidavit/Proof Affidavit Adobe PDF Show Attachment

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 7 of 26
3/9/23, 1:35 PM Job Details

https://www.pstprostatus.net/asp/jobdetail.aspx?ID=2023000251 1/2

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Details for Job 2023000251

General Information

Party To Be Served: NAOMI OSAKA

Person To Be Served: None

Received Date/Time: 2/21/2023 3:32 PM

Documents To Be Served: SUMMONS AND COMPLAINT (21 DAYS)

Court Date/Time: None

Case Information

Case Number: 22-CV-23753-KMM

Judge: None

Plaintiff: EDWIN GARRISON, ET AL., ON BEHALF OF THEMSELVES AND ALL OTHERS

SIMILARLY SITUATED

Defendant: SAM BANKMAN-FRIED, ET AL.

Case Date Filed: 12/16/2022

Amended Date Filed: None

Service Information

Served: NAOMI OSAKA

Date/Time Served: 3/6/2023 5:54 PM

Method of Service: NON SERVICE

Detailed Service Info: NON-SERVED: After due search, careful inquiry and diligent attempts I was unable to serve

the SUMMONS AND COMPLAINT (21 DAYS) for the reason that I failed to find NAOMI

OSAKA or information to allow further search.

Service Address: 9621 ARBY DRIVE, BEVERLY HILLS, CA 90210

Recipient Description: None

Servee Addresses

Address(es)

9621 ARBY DRIVE, BEVERLY HILLS, CA 90210

Comments

Show Location Column

Date/Time Body

3/6/2023

4:15 PM

I spoke to Cary at Ground Control Business Management. She said the NAOMI OSAKA is a client of

theirs but they are not lawyers. I asked her if she could provide me with the information for her legal

representation or an agent. She told me she would have someone call me. Will let you know when I

hear back from them. (310) 315-6200

3/6/2023

1:24 PM See attachment for service notes.

2/27/2023

5:39 PM Checking on service.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 8 of 26
3/9/23, 1:35 PM Job Details

https://www.pstprostatus.net/asp/jobdetail.aspx?ID=2023000251 2/2

2/23/2023

4:33 PM

Sent this out on 2/21/23. Still out for routine service. Will send status once the server makes the

attempt.

Attachments

Purpose Description Format Show Attachment

Non Serve Affidavit Signed affidavit. Adobe PDF Show Attachment

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 9 of 26
1

Rejane Passos

Subject: FW: Garrison, Yang, Huang, Shetty, Livieratos

From: Andrew.Clubok@lw.com <Andrew.Clubok@lw.com>

Sent: Monday, December 5, 2022 3:14 PM

To: Adam Moskowitz <Adam@moskowitzͲlaw.com>; Joseph Kaye <joseph@moskowitzͲlaw.com>;

dboies@bsfllp.com; szack@bsfllp.com; uungaro@bsfllp.com; rmcid@podhurst.com;

jose@markmigdal.com; xboies@gmail.com; lcarlsen@bsfllp.com; Howard Bushman

<Howard@moskowitzͲlaw.com>

Cc: Susan.Engel@lw.com; Jessica.StebbinsBina@lw.com; Bob@colson.com; Marvin.Putnam@lw.com;

michele.johnson@lw.com

Subject: RE: Garrison, Yang, Huang, Shetty, Livieratos

Adam:

Thanks much for getting back to me. Yes, we (Latham attorneys, along with Bob Martinez) will be

working together, and we will also be defense counsel in the federal action(s) for at least some of the

defendants. And we definitely agree that an orderly process is preferable! How about we try to schedule

a call in the next few days or so as you develop your plans, etc. etc. Hopefully they don’t involve

unnecessarily ruining anybody’s holidays! We will definitely work with you on that shared goal!

In any event, we certainly look forward to working with you and your colleagues.

ABC

From: Adam Moskowitz <Adam@moskowitzͲlaw.com>

Sent: Monday, December 5, 2022 2:53 PM

To: Clubok, Andrew (DC) <Andrew.Clubok@lw.com>; Joseph Kaye <joseph@moskowitzͲlaw.com>;

dboies@bsfllp.com; szack@bsfllp.com; uungaro@bsfllp.com; rmcid@podhurst.com;

jose@markmigdal.com; David Boies2 <xboies@gmail.com>; Linda Carlsen <lcarlsen@bsfllp.com>;

Howard Bushman <Howard@moskowitzͲlaw.com>

Cc: Engel, Susan (DC) <Susan.Engel@lw.com>; Stebbins Bina, Jessica (CC)

<Jessica.StebbinsBina@lw.com>; Bob@colson.com

Subject: RE: Garrison, Yang, Huang, Shetty, Livieratos

Thank you so much Andrew and we are always glad to see you great Firm involved in our class cases. We

met last week with the many participants in the various state court FTX cases and decided that before

we serve any of the Defendants, we are going to file one Consolidated Amended Complaint and dismiss

the other individual cases, so that we narrow and focus our state court cases. We still also have our FTX

federal class action cases (and will be filing one more), so please let us know if you are going to serve as

defense counsel in any of those federal actions and we can coordinate the service with you. We

certainly also want to try and organize those few federal cases, to the best that we can, so that we do

not have the same litigation proceeding before different federal judges. I hope – from your emailͲͲthis

also means that Bobby Martinez may be involved in these cases because he has always been a good

friend and he is a great lawyer/person. Thanks, Adam

Adam M. Moskowitz

The Moskowitz Law Firm

2 Alhambra Plaza

Suite 601

Coral Gables, Fl 33134

305.740.1423 main

786.309.9561 direct

adam@moskowitzͲlaw.com<mailto:adam@moskowitzͲlaw.com>

www.MoskowitzͲLaw.com<http://www.MoskowitzͲLaw.com>

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 10 of 26
2

From: Andrew.Clubok@lw.com <Andrew.Clubok@lw.com>

Sent: Monday, December 5, 2022 2:21 PM

To: Adam Moskowitz <Adam@moskowitzͲlaw.com>; Joseph Kaye <joseph@moskowitzͲlaw.com>;

dboies@bsfllp.com; szack@bsfllp.com; uungaro@bsfllp.com; rmcid@podhurst.com;

jose@markmigdal.com

Cc: Susan.Engel@lw.com; Jessica.StebbinsBina@lw.com; Bob@colson.com

Subject: Garrison, Yang, Huang, Shetty, Livieratos

All:

I hope all is well. We are going to be representing several of the defendants in the aboveͲcaptioned (and

related) suits. Is somebody available to talk about the matters including service, etc.?

Thanks

ABC

Andrew Clubok

Latham and Watkins LLP

202-637-3323

212-906-1272

_________________________________

This email may contain material that is confidential, privileged and/or attorney work product for the sole

use of the intended recipient. Any review, disclosure, reliance or distribution by others or forwarding

without express permission is strictly prohibited. If you are not the intended recipient, please contact

the sender and delete all copies including any attachments.

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requirements. Any personal information contained or referred to within this electronic communication

will be processed in accordance with the firm's privacy notices and Global Privacy Standards available at

www.lw.com.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 11 of 26
From: Zaili Perdomo

To: Rejane Passos

Cc: Joseph Kaye

Subject: Re: Status: Shohei Ohtani + Naomi Osaka + Shaquille O’Neal

Date: Wednesday, March 1, 2023 4:36:05 PM

Made attempt at 4012 Sahara Ct. in Carrollton on 2/28/23 @ 2:30 pm. for Shaq. No answer. Cameras

everywhere. Left my card.

On Wednesday, March 1, 2023, Rejane Passos <rejane@moskowitz-law.com> wrote:

Sorry. Terry Prince is for Shohei Ohtani and not Noami. All good. Sorry for the confusion.

From: Rejane Passos

Sent: Wednesday, March 1, 2023 3:56 PM

To: Zaili Perdomo <pidmcm@gmail.com>

Cc: Joseph Kaye <joseph@moskowitz-law.com>

Subject: RE: Status: Shohei Ohtani + Naomi Osaka + Shaquille O’Neal

Did the process server tried to contact Terry Prince by phone?

From: Zaili Perdomo <pidmcm@gmail.com>

Sent: Wednesday, March 1, 2023 3:29 PM

To: Rejane Passos <rejane@moskowitz-law.com>

Cc: Joseph Kaye <joseph@moskowitz-law.com>

Subject: Re: Status: Shohei Ohtani + Naomi Osaka + Shaquille O’Neal

Naomi Osaka attempted 3 times. No answer. On 2 attempts the gate was closed. On one

attempt the gate was open. There was a black Tesla. No answer at the door. The server is on

the road but will send me dates and times later today.

On Wednesday, March 1, 2023, Zaili Perdomo <pidmcm@gmail.com> wrote:

I received a phone call from Ms. Shepherd at the office in LA for Shohei Ohtani. The server

is on his way to serve her at 11:30 am LA time.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 12 of 26
Thank you.

Zaili Perdomo

PI Services

1430 South Dixie Highway

Suite 105, #157

Coral Gables, Florida 33146

(305) 666-0142 Office

On Wed, Mar 1, 2023 at 12:45 PM Rejane Passos <rejane@moskowitz-law.com> wrote:

Awesome. Thanks.

From: Zaili Perdomo <pidmcm@gmail.com>

Sent: Wednesday, March 1, 2023 12:43 PM

To: Rejane Passos <rejane@moskowitz-law.com>

Cc: Joseph Kaye <joseph@moskowitz-law.com>

Subject: Re: Status: Shohei Ohtani + Naomi Osaka + Shaquille O’Neal

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 13 of 26
I just spoke to Terry Prince he said someone in his L.A. office is going to accept today for

Shohei Ohtani. He is going to call me back to confirm.

Will let you know about the rest.

Thank you.

Zaili Perdomo

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 14 of 26
1

Rejane Passos

Subject: FW: Garrison, et al. v. Bankman-Fried, et al., No. 1:22-cv-23753-KMM -- Shaquille O'Neal Request for 

Waiver of Service

From: Reid, Benjamine

Sent: Wednesday, March 8, 2023 1:27 PM

Subject:

We do not represent Mr. O’Neal and I am unaware of any counsel who does.

Benjamine Reid

Carlton Fields, P.A.

305.205.2780 (c)

305.539.7222(o)

[cid:imagefa3d7c.PNG@87de7f4c.48a67bcc]<http://>

Benjamine Reid

Attorney at Law

2 MiamiCentral

700 NW 1st Avenue, Ste. 1200

Miami, Florida 33136Ͳ4118

Direct: 305.539.7222 | Mobile: 305.205.2780

breid@carltonfields.com<mailto:breid@carltonfields.com> | www.carltonfields.com<http://www.carltonfields.com>

bio<https://www.carltonfields.com/team/r/benjamineͲreid> |

vcard<https://www.carltonfields.com/Libraries/CarltonFields/Media/Attorney%20Vcards/BenjamineͲReid.vcf?ext=.vcf>

Carlton Fields is ISO 27001:2013 certified

Confidential: This eͲmail contains a communication protected by the attorneyͲclient privilege or constitutes work

product. If you do not expect such a communication please delete this message without reading it or any attachment

and then notify the sender of this inadvertent delivery.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 15 of 26
From: Joseph Kaye

To: breid@carltonfields.com; cgruhn@carltonfields.com; jacohen@carltonfields.com

Cc: Adam Moskowitz; dboies@bsfllp.com; aboies@bsfllp.com; Brooke Alexander; Stephen N. Zack; Rejane Passos

Subject: Re: Garrison, et al. v. Bankman-Fried, et al., No. 1:22-cv-23753-KMM -- Shaquille O"Neal Request for Waiver of

Service

Date: Monday, March 6, 2023 6:33:11 PM

Attachments: Garrison v. Bankman-Fried - Waiver Request - Shaquille O"Neal.pdf

Garrison v. Bankman-Fried - Waiver Return - Shaquille O"Neal.pdf

D.E. 16 Amended Complaint.pdf

Good afternoon Messrs. Reid, Gruhn, and Cohen,

We represent Plaintiffs and the putative classes in the above-referenced action. A copy of

the operative complaint is attached. I am reaching out to you with a Notice of

Commencement of Action and Request for Waiver of Service for your client, Shaquille

O’Neal (both forms attached). We know Mr. O’Neal is aware of the complaint

(https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paidspokesperson.html) and are in the process of personally serving him, but wanted to send

this along to you in order to expedite the process and avoid the cost of personal service to

the extent possible. Please let me know if you have any questions or wish to discuss, thank

you. 

Best,

Joseph M. Kaye, P.A.

Partner

The Moskowitz Law Firm, PLLC

P.O. Box 141609

Coral Gables, FL 33114

For Hand Deliveries Use:

251 Valencia Ave #141609

Coral Gables, FL 33114

Office: (305) 740-1423

Direct: (786) 309-9585

Note: The information in this email is confidential and intended to be legally privileged. If

you are not the intended recipient, you must not read, use or disseminate the information

contained herein; please advise the sender immediately by reply email and delete this

message and any attachments without retaining a copy. Although this email and any

attachments are believed to be free of any viruses or other defects that may affect any

computer system into which it is received and opened, it is the responsibility of the

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Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 17 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 1/7

Shaquille O’Neal Scott Mlyn | CNB Scott Mlyn | CNBC

How this 39-year-old earns $26,000 a year in

California

An 85-year Harvard study found the No. 1

thing that makes us happy in life: It...

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Shaq distances himself from crypto and FTX collapse:

‘I was just a paid spokesperson’

Published Thu, Dec 15 2022•11:16 AM EST Updated Mon, Dec 19 2022•3:48 AM EST

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 18 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 2/7

FTX collapse ensnares celeb investors

Shaquille O’Neal wants to make one thing clear: He doesn’t believe in crypto, if he

ever did.

That’s after being named in a class-action lawsuit against now-bankrupt

cryptocurrency exchange FTX last month, for promoting the company in a June

commercial.

In an interview with CNBC Make It this week, the 50-year-old businessman and

Basketball Hall of Famer took questions about his relationship with FTX while

discussing his other business ventures.

O’Neal has a long history of investing in companies he promotes, including his

current enterprise, Shaq’s Fun House, an annual part-festival, part-carnival event.

Those investments often pan out: O’Neal makes more off the court than he did as an

NBA star, he told HBO’s “Real Sports with Bryant Gumbel” in 2018.

But when it comes to FTX, he says, he was merely a celebrity in an ad.

“A lot of people think I’m involved, but I was just a paid spokesperson for a

commercial,” O’Neal says.

On Tuesday, the U.S. Securities and Exchange Commission accused FTX founder and

former CEO Sam Bankman-Fried of orchestrating a “brazen” years-long fraud,

misusing customer funds to benefit himself and his crypto hedge fund, Alameda

Research.

Bankman-Fried was arrested on Monday by Bahamian authorities, likely leading to

extradition and a U.S. trial, CNBC reported. He’ll face at least eight charges from

federal prosecutors in the Southern District of New York, including several counts of

conspiracy and fraud.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 19 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 3/7

‘I don’t understand [crypto], so I will probably stay away’

 9:56

FTX’s collapse is shaking crypto to its core. The pain may not be over

Customers have been unable to withdraw funds from FTX since the company

declared bankruptcy last month. As many as one million creditors, according to an

FTX bankruptcy filing, are unsure if they’ll ever get their money back.

The class-action lawsuit naming O’Neal is a legal proceeding separate from the

federal government’s charges. It alleges that FTX’s spokespeople “either controlled,

promoted, assisted in [or] actively participated” in a plot to “aggressively market” the

company.

Other athletes and celebrities from FTX’s commercials — including Steph Curry, Tom

Brady, and comedian Larry David — were also named in the lawsuit. Texas is now

separately investigating some celebrity FTX endorsers for potentially violating state

securities laws, according to Bloomberg.

The ex-basketball star’s commercial was somewhat of a surprise: Last year, O’Neal

told CNBC Make It that he was actively avoiding cryptocurrency.



Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 20 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 4/7

“I don’t understand it, so I will probably stay away from it until I get a full

understanding of what it is,” he said, adding: “From my experience, it is too good to

be true.”

O’Neal told Front Office Sports last year that he’d declined promotional offers from

various crypto entities.

“I always get these companies that say, ‘Hey, we’ll give you $900,000 in crypto to

send out a tweet,’” O’Neal said. “So I have to say, ‘OK, if you’re going to give me a

million dollars worth of crypto, then why do you need me?’”

He may have had a change of heart in late 2021, though: Over the past year, O’Neal

changed his Twitter display name to “SHAQ.ETH” and “SHAQ.SOL” to promote NFT

collections underpinned by the Ethereum and Solana cryptocurrency platforms.

“I’m excited to be partnering with FTX to help make crypto accessible to everyone,”

O’Neal said in the June commercial. “I’m all in. Are you?”

Today, O’Neal cites his friendship with Curry as a reason he consented to appear in

the ad. A spokesperson for Curry declined to comment.

In the ad, O’Neal told viewers that he checked his FTX account daily. But when

asked now if he’s bullish on crypto, he offers a simple response: “No.”

“People know I’m very, very honest,” O’Neal says. “I have nothing to hide. If I was

heavily involved, I would be at the forefront saying, ‘Hey.’ But I was just a paid

spokesperson.”

It’s unclear how much money O’Neal made from his FTX endorsement deal. Investor

and entrepreneur Kevin O’Leary, who also endorsed FTX and is named in the suit,

told CNBC’s “Squawk Box” last week that he was paid $15 million by FTX, and lost it

all: $9.7 million that he’d invested with FTX, more than $1 million in FTX equity and

approximately $4 million in taxes and agent fees.

O’Leary said the money he lost was his alone. “We need to get to the bottom of

what happened at FTX, but we can’t let its collapse cause us to abandon the great

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 21 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 5/7

promise and potential of crypto,” he testified to the Senate Banking Committee on

Wednesday.

Sign up now: Get smarter about your money and career with our weekly newsletter

Don’t miss: Harvard-educated deception expert: 4 red flags can show when people

like Sam Bankman-Fried are lying

 1:00

Here’s what Shaquille O’Neal did with his first check — and his advice for young people

Trending Now

1 I was VP at Google for 10 years. Here’s the No. 1 skill I looked for at job

interviews—few people had it

2 29-year-old nurse got a ‘once-in-a-lifetime opportunity’ to make $187K and

work only 9 months a year



Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 22 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 6/7

3 33-year-old with six-figure side hustle: ‘People underestimate how much it

takes to be very successful’

4 Kids who do these 12 things have ‘highly sensitive’ brains—why parenting

experts say it’s an advantage

5 You can live on this cruise ship for $30,000/year—less than the average

cost of rent in NYC

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 23 of 26
3/9/23, 1:27 PM Shaq on crypto, FTX, post-collapse: 'I was just a paid spokesperson'

https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftx-post-collapse-i-was-just-a-paid-spokesperson.html 7/7

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Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 24 of 26
From: Zaili Perdomo

To: Rejane Passos; Joseph Kaye

Subject: Re: Return of service Affidavit || UDONIS HASLEM + STEPHEN CURRY

Date: Wednesday, March 8, 2023 7:33:48 AM

Good morning,

I found out that Shaq was in Georgia last night. I found his agent Leonard Armato. His phone

number is -1000. I left him a voicemail. Hopefully this will be the one that gets him

served.

Thank you.

Zaili Perdomo

PI Services

1430 South Dixie Highway

Suite 105, #157

Coral Gables, Florida 33146

(305) 666-0142 Office

On Fri, Mar 3, 2023 at 6:29 AM Zaili Perdomo <pidmcm@gmail.com> wrote:

Same thing for Shaquille O'Neal. His house is like a fortress. I reached out to his agent but

never heard back. Let me know if you have any additional information on him.

Thank you.

Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 25 of 26
Case 1:22-cv-23753-KMM Document 88-2 Entered on FLSD Docket 03/09/2023 Page 26 of 26