1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

SCOTT FINEMAN, an individual; 

MOHAMMED WAQAS MALIK, an 

individual; CRISTIAN SILVA, an 

individual; and JAMES MCGRIFF, 

an individual.

Individually and on Behalf of All 

Others Similarly Situated,

Plaintiffs,

v.

FERRAGAMO USA Inc., a New York

corporation; S-FER INTERNATIONAL 

INCORPORATED, a New York 

corporation; SATOR REALTY INC., a 

New York corporation; SAKS FIFTH 

AVENUE LLC, a Massachusetts 

limited liability company; and THE 

NEIMAN MARCUS GROUP LLC, a 

Delaware limited liability company.

 Defendants.

CASE NO:

CLASS ACTION

CLASS ACTION COMPLAINT AND JURY TRIAL DEMAND

Plaintiffs SCOTT FINEMAN (“Fineman”), MOHAMMED WAQAS MALIK 

(“Malik”), CRISTIAN SILVA (“Silva”), and JAMES MCGRIFF (“McGriff”)

(collectively, “Plaintiffs”), on behalf of themselves and all others similarly situated, 

allege as follows:

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I. INTRODUCTION

1. This is a nationwide class action seeking monetary damages, 

restitution, injunctive and declaratory relief from Defendants FERRAGAMO USA 

INC. (“Ferragamo USA”), S-FER INTERNATIONAL INCORPORATED (“S-FER”), 

SATOR REALTY INC. (“Sator”), SAKS FIFTH AVENUE LLC (“SFA”), and THE 

NEIMAN MARCUS GROUP LLC (“Neiman Marcus”) (collectively “Defendants”), 

arising from their advertising, marketing, and sale of purportedly high quality, 

“luxury” designer belts and belt buckles which quickly become worthless for their 

intended purpose as fashion accessories, due to a defect in the buckle design and/or 

manufacture.

2. Defendants Ferragamo USA and its subsidiaries S-FER and Sator are

part of the Salvatore Ferragamo Group, whose parent company Salvatore 

Ferragamo S.p.A. designs, manufactures, and distributes a collection of designer

belts which include a “signature” metal buckle (the “Ferragamo Belt Buckles.”) The 

Ferragamo Belt Buckles can be purchased both as part of a belt and on their own. 

3. Ferragamo USA distributes and promotes the Ferragamo Belt Buckles

throughout the United States and sells the Ferragamo Belt Buckles through retail 

stores operated by its subsidiaries S-FER and Sator, as well as through retail 

partners, including Defendants SFA and Neiman Marcus. Belts which include the 

Ferragamo Belt Buckles are regularly sold for many hundreds of dollars, and the 

Belt Buckles themselves are listed by Ferragamo’s website as selling for nearly 

$300.

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4. To justify these significant prices, the Defendants market both the 

supposed superior quality and luxury status of the Ferragamo Belt Buckles. For 

example, Ferragamo USA’s parent company boasts on its website that “Ferragamo’s 

exclusive features of craftsmanship, quality of materials, elegance and 

functionality take the shape of a vast collection of belts [sic] designs, merging 

elegant buckles and high-end materials, for a contemporary look that speaks 

understated luxury.”1 (emphasis added). A website operated by SFA’s sister entity 

Saks.com LLC and marketing SFA’s stores identifies Ferragamo as “the standard 

of classic Italian elegance and legendary craftsmanship ....”2 (emphasis added).

And Neiman Marcus’ website describes Ferragamo as “synonymous with

premium luxury goods, such as handbags, accessories, jewelry, timepieces, 

eyewear, and fragrances ... Beyond bags, Salvatore Ferragamo offers a number of 

luxury accessories, including slim leather belts with the iconic Gancini buckle, 

silk printed scarves, and chic sunglasses.”3 (emphasis added).

1 https://www.ferragamo.com/shop/us/en/men/wallets-small-leather-goods/beltsman.

2 https://www.saksfifthavenue.com/brand/salvatoreferragamo?site_refer=360i+G+TR&kw_refer=$G_Saks_Trademark_Designer+Term

s_New+Customers_BMM$G_Saks_Trademark_Designer+Terms_Ferragamo_BMM

$ferragamo+saks&gclid=Cj0KCQiAsdKbBhDHARIsANJ6-

jf5lIwcXhtoY2xz0arTjZad_qkeD4hvSyQCC1nyoP5TB6tT2KOGckIaAv0qEALw_wcB

&gclsrc=aw.ds

3 https://www.neimanmarcus.com/c/designers-salvatore-ferragamocat43330758?navpath=cat000730_cat65280767_cat000488_cat43330758&source=lef

tNav

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5. In fact, the Ferragamo Belt Buckles are defectively manufactured 

and/or designed, such that the “iconic” metal buckle quickly becomes discolored 

and/or tarnished, rendering it unsightly, aesthetically unappealing, and ultimately 

useless for its intended purpose of providing a “luxurious” fashion accessory:

6. Plaintiffs bring this action pursuant to Rule 23 of the Federal Rules of 

Civil Procedure to redress Defendants’ failure to disclose and provide adequate 

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warning to their customers that the Ferragamo Belt Buckles are defective and unfit 

for their ordinary and intended use, and for their sale of the defective “luxury” goods 

to unwitting consumers.

II. THE PARTIES

7. Plaintiff Fineman is an adult resident of the state of Florida who 

resides in Royal Palm Beach, Palm Beach County.

8. Plaintiff Malik is an adult resident of the state of Florida who resides 

in Naples, Collier County.

9. Plaintiff Silva is an adult resident of the state of Florida who resides 

in North Miami Beach, Miami-Dade County.

10. Plaintiff McGriff is an adult resident of the state of Florida who resides 

in Deerfield Beach, Broward County.

11. Plaintiffs are informed and believe and thereon allege that Defendant 

Ferragamo USA is a New York corporation with its principal place of business at 

663 Fifth Avenue, New York, New York. Plaintiffs are informed and believe and 

thereon allege that Defendants S-FER and Sator are subsidiaries of Ferragamo 

USA, and also organized as New York corporations with their principal place of 

business at 663 Fifth Avenue, New York, New York. Ferragamo USA conducts 

extensive business throughout the United States where it distributes, promotes and 

sells its products to consumers through brick-and-mortar retail stores directly 

managed by S-FER and Sator, including seven stores located in Florida.

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12. Plaintiffs are informed and believe and thereon allege that Defendant 

SFA is a Massachusetts limited liability company with its principal place of business 

at 225 Liberty Street, 31st Floor, New York, New York. SFA owns and operates 

several dozen large retail stores throughout the United States and Canada, 

including eight locations in Florida.

13. Plaintiffs are informed and believe and thereon allege that Defendant 

Neiman Marcus is a Delaware limited liability company with its principal place of 

business at One Marcus Square, 1618 Main Street, Dallas, Texas. Neiman Marcus 

owns and operates several dozen large retail stores in the United States, including 

five stores in Florida.

III. JURISDICTION AND VENUE

14. This Court has subject matter jurisdiction under the Class Action

Fairness Act of 2005 (“CAFA”), 28 U.S.C. §§1332(d)(2) and (6) because (i) the 

aggregate amount in controversy exceeds $5,000,000.00 exclusive of interest and 

costs, and (ii) there is minimal diversity because members of the proposed Class 

(including Plaintiffs) are citizens of a State different from that of any Defendant.

15. This Court has personal jurisdiction over Defendants by virtue of their

doing substantial business in this Judicial District, including the operation of 

multiple brick and mortar retail locations in the District.

16. Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391. 

Defendants conducted, and continue to conduct, business in this District, and a 

substantial part of the acts and omissions giving rise to the claims occurred, at least 

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in part, within this District. Defendants market, advertise, and sell the defective 

products and otherwise conduct extensive business within this District.

IV. FACTUAL ALLEGATIONS

A. Facts Relevant to All Claims and Parties:

17. As alleged above, Defendants represent to the public that the 

Ferragamo Belt Buckles – which are sold for hundreds of dollars on their own and 

as a key component of belts which sell for even more – are high quality fashion 

accessories, fit for such purposes. Thus, Defendants are impliedly warranting that 

the Ferragamo Belt Buckles are suitable for regular and expected use as a fashion 

accessory.

18. The Ferragamo Belt Buckles, however, are unfit for such use, because 

their metal buckles quickly become discolored and/or tarnished, ruining the 

aesthetic purpose behind purchasing such a purportedly “high quality” designer 

accessory. This discoloration and/or tarnishing occurs regardless of the way in which 

customers use and care for the Belt Buckles and cannot be blamed on the consumers 

– it is a defect in the design or manufacturing of the Belt Buckles themselves.

19. Moreover, customers who purchased the defective Ferragamo Belt

Buckles have no easy option to either receive a full refund or an exchange once the 

defect becomes apparent. Instead, Defendants typically require Plaintiffs to pay 

even more money to replace the defective Ferragamo Belt Buckles.

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B. Facts Specific to Plaintiffs:

20. Fineman is a resident of Royal Palm Beach, Florida. In or about earlyto-mid 2021, Fineman purchased a Ferragamo Belt Buckle as part of a belt from a

retail store in Aventura, Florida, managed by Ferragamo USA through its 

subsidiaries S-FER and/or Sator. Within approximately four months of the 

purchase, the Belt Buckle began showing obvious discoloration and/or tarnishing of 

the Belt Buckle’s metal.

21. Malik is a resident of Naples, Florida. In or about late 2020, Malik 

purchased a Ferragamo Belt Buckle as part of a belt from SFA’s retail store in 

Naples, Florida. Within approximately one year of the purchase, the Belt Buckle 

began showing obvious discoloration and/or tarnishing of the Belt Buckle’s metal.

22. Silva is a resident of North Miami Beach, Florida. In or about 2020, 

Silva purchased a Ferragamo Belt Buckle as part of a belt from a retail store in 

Aventura, Florida, managed by Ferragamo USA through its subsidiaries S-FER 

and/or Sator. Within approximately six months of the purchase, the Belt Buckle 

began showing obvious discoloration and/or tarnishing of the Belt Buckle’s metal.

23. McGriff is a resident of Deerfield Beach, Florida. In or about late 2020, 

McGriff purchased a Ferragamo Belt Buckle as part of a belt from Neiman Marcus’ 

retail store in Doral, Florida. Despite never even wearing the belt, the Belt Buckle 

still began showing obvious discoloration and/or tarnishing of the Belt Buckle’s 

metal.

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C. Facts Common to All Class Members:

24. Unfortunately, Plaintiffs are not uniquely situated. The claims of the 

proposed Class all derive from Defendants’ sale of the defective Ferragamo Belt 

Buckles and deceptive advertising concerning the purported quality of such goods.

25. Defendants engaged in uniform and standardized conduct toward the 

proposed Class. They did not differentiate, in degree of care or candor, in their

actions or inactions, or in the content of their statements or omissions, among 

individual Class members.

26. The relevant, objective facts on these subjects are the same for all Class 

members. 

27. Accordingly, Plaintiffs bring this lawsuit as a class action on their own 

behalf, and on behalf of all other persons similarly situated, as members of the 

proposed Class identified below, pursuant to Federal Rules of Civil Procedure 23(a), 

(b)(3), and/or (c)(4). 

28. This action satisfies the numerosity, commonality, typicality, 

adequacy, predominance, and superiority requirements of these provisions as 

described below.

V. CLASS ACTION ALLEGATIONS (LR 23.1):

29. Pursuant to Federal Rule of Civil Procedure 23 and Local Rule 23.1, 

Plaintiffs bring this class action individually and on behalf of the following proposed 

nationwide class of persons (the “Class”), initially defined as all persons or entities 

in the United States who made retail purchases of one or more Ferragamo Belt 

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Buckles, either alone or as part of a belt, from a physical retail store operated by one 

of the Defendants, where such purchase occurred during the period between four 

years prior to the filing of this action and the date of the final disposition of this 

action, and/or such subclasses as the Court may deem appropriate (the “Class”).

30. The Class does not include Defendants; any affiliate, parent or 

subsidiary of any of the Defendants; any entity in which any of the Defendants has

a controlling interest; any officer, director or employee of any of the Defendants; any 

successor or assign of any of the Defendants; Plaintiffs’ counsel or anyone employed 

by Plaintiffs’ counsel in this action and their immediate families; any judge to whom 

this case is assigned and any member of their immediate family and staff; 

governmental entities; or individuals who have personal injury claims as a result of 

conduct and/or defects alleged herein.

31. Plaintiffs reserve the right to amend or supplement the Class 

descriptions with greater specificity or further division into subclasses or limitation 

to certain issues, after conducting discovery in this matter.

32. Plaintiffs also reserve the right to amend or supplement the definition 

of the Ferragamo Belt Buckles to, e.g., include additional products with similar 

defects, after conducting discovery in this matter.

33. Numerosity of the Class – The members of the Class are so 

numerous that their individual joinder is impracticable. Plaintiffs are informed and 

believe that Defendants sold thousands of the Ferragamo Belt Buckles during the 

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relevant time period. Disposition of the claims in a class action context will provide 

substantial benefits to the parties and the Court.

34. Commonality and Predominance – Common questions of law and 

fact exist as to all members of the Class and predominate over questions affecting 

only individual Class members, as is required by Fed. R. Civ. P. 23(a)(2) and (b)(3). 

These common questions include, but are not limited to:

a. Whether the Ferragamo Belt Buckles are defectively designed or 

manufactured;

b. Whether such defects constitute a breach of the implied warranties 

inherent in the sale of such products;

c. Whether Defendants are merchants with respect to goods of the kind 

of the Ferragamo Belt Buckles.

d. Whether Defendants made misleading or fraudulent representations 

regarding the quality of the Ferragamo Belt Buckles to consumers;

e. Whether Defendants were unjustly enriched by their sale of the 

Ferragamo Belt Buckles to consumers;

f. Whether Plaintiffs and Class members suffered out-of-pocket losses as 

a result of Defendants’ actions and/or inactions alleged herein;

g. Whether Plaintiffs and Class members are entitled to damages and 

monetary relief and, if so, in what amount; and

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h. Whether a declaration and/or injunction is appropriate to prevent 

Defendants from making future false or misleading representations 

regarding the Ferragamo Belt Buckles.

35. Typicality – The claims of the representative Plaintiffs are typical of 

the claims of each member of the Class, thus satisfying Fed. R. Civ. P. 23(a)(3).

Plaintiffs, like all other members of the Class, sustained damages arising from 

Defendants’ breaches of the implied warranty in the Ferragamo Belt Buckles, from 

Defendants’ misleading or fraudulent statements regarding the quality of the 

Ferragamo Belt Buckles, and from Defendants’ unjust enrichment, as alleged 

herein. The representative Plaintiffs and the members of the Class were and are 

similarly or identically harmed by the same misconduct engaged in by Defendants. 

Plaintiffs’ claims arise from the same practices and course of conduct that give rise 

to the claims of all other members of the Class.

36. Adequacy – The representative Plaintiffs will fairly and adequately 

represent and protect the interests of the Class members and have retained counsel 

who are experienced and competent trial lawyers in complex litigation and class 

action litigation, thus satisfying Fed. R. Civ. P. 23(a)(4). There are no material 

conflicts between the claims of the representative Plaintiffs and the members of the 

Class that would make class certification inappropriate. Counsel for the Class will 

vigorously assert the claims of all Class members.

37. Superiority – This suit may be maintained as a class action under 

Fed. R. Civ. P. 23(b)(3), because a class action is superior to any other available 

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means for the fair and efficient adjudication of this dispute and no unusual 

difficulties are likely to be encountered in the management of this class action. The 

damages suffered by individual Class members are small in comparison to the 

burden and expense of individually litigating each claim. Further, it would be 

virtually impossible for the Class members to individually redress effectively the 

wrongs done to them. Even if Class members themselves could afford such 

individual litigation, the court system could not. In addition, individualized 

litigation increases the delay and expense to all parties and to the court system 

resulting from the legal and factual issues of the case. Individualized litigation also 

presents a potential for inconsistent or contradictory judgments. By contrast, the 

class action device presents far fewer management difficulties; allows the hearing 

of claims which might otherwise go unaddressed because of the relative expense of 

bringing individual lawsuits; and provides the benefits of single adjudication, 

economies of scale, and comprehensive supervision by a single court.

38. Ascertainability: Upon information and belief, the precise number of 

Class members may be ascertained from Defendants’ sales records. Plaintiffs

contemplate the eventual issuance of notice to the proposed Class members setting 

forth the nature of the instant action. Upon information and belief, Class members 

may be notified of this action by recognized, Court-approved notice dissemination 

methods, which may include U.S. mail, electronic mail, Internet postings, social 

media, and published notices, in addition to Defendants’ business records.

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VI. CLAIMS FOR RELIEF:

COUNT ONE

Breach of the Implied Warranty of Merchantability

(Against Defendants Ferragamo USA, S-FER and Sator)

39. Plaintiffs repeat, re-allege, and incorporate by reference the 

allegations contained in paragraphs 1 through 38 as though fully stated herein. 

40. Plaintiffs Fineman and Silva assert this claim on behalf of themselves

and all members of the Class who purchased a Ferragamo Belt Buckle, either alone 

or as part of a belt, from physical retail stores managed by Ferragamo USA through 

its subsidiaries S-FER and/or Sator, whether in Florida or in any other state having 

similar laws regarding the breach of implied warranty.

41. Ferragamo USA, S-FER and Sator are merchants with respect to goods 

of the kind of the Ferragamo Belt Buckles.

42. The Ferragamo Belt Buckles sold to Fineman, Silva and the abovedescribed members of the Class violated the implied warranty of merchantability. 

Because of the above-described defect, they are not merchantable and not fit for the 

ordinary purposes for which such goods are used, i.e., as a luxury fashion accessory.

43. As a direct and proximate result of Ferragamo USA’s, S-FER’s and 

Sator’s breaches of the implied warranty, Fineman, Silva and the above-described 

members of the Class received goods whose latent defect substantially impairs their 

value to consumers such as themselves.

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44. Fineman, Silva and the above-described members of the Class were 

unaware of this defect and reasonably could not have discovered it before they 

purchased their Ferragamo Belt Buckles.

45. Fineman, Silva and the above-described members of the Class seek 

damages based on the diminished value of their Ferragamo Belt Buckles as a result 

of this latent and material defect, and all other damages allowable under law.

COUNT TWO

Breach of the Implied Warranty of Merchantability

(Against Defendant SFA)

46. Plaintiffs repeat, re-allege, and incorporate by reference the 

allegations contained in paragraphs 1 through 45 as though fully stated herein. 

47. Plaintiff Malik asserts this claim on behalf of himself and all members 

of the Class who purchased a Ferragamo Belt Buckle, either alone or as part of a 

belt, from SFA’s retail stores, whether in Florida or in any other state having similar 

laws regarding the breach of implied warranty.

48. SFA is a merchant with respect to goods of the kind of the Ferragamo 

Belt Buckles.

49. The Ferragamo Belt Buckles sold to Malik and the above-described 

members of the Class violated SFA’s implied warranty of merchantability. Because 

of the above-described defect, they are not merchantable and not fit for the ordinary 

purposes for which such goods are used, i.e., as a luxury fashion accessory.

50. As a direct and proximate result of SFA’s breach of the implied 

warranty, Malik and the above-described members of the Class received goods 

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whose latent defect substantially impairs their value to consumers such as 

themselves.

51. Malik and the above-described members of the Class were unaware of 

this defect and reasonably could not have discovered it before they purchased their 

Ferragamo Belt Buckles.

52. Malik and the above-described members of the Class seek damages 

based on the diminished value of their Ferragamo Belt Buckles as a result of this 

latent and material defect, and all other damages allowable under law.

COUNT THREE

Breach of the Implied Warranty of Merchantability

(Against Defendant Nieman Marcus)

53. Plaintiffs repeat, re-allege, and incorporate by reference the 

allegations contained in paragraphs 1 through 52 as though fully stated herein. 

54. Plaintiff McGriff asserts this claim on behalf of himself and all 

members of the Class who purchased a Ferragamo Belt Buckle, either alone or as 

part of a belt, from Nieman Marcus’ retail stores, whether in Florida or in any other 

state having similar laws regarding the breach of implied warranty.

55. Nieman Marcus is a merchant with respect to goods of the kind of the 

Ferragamo Belt Buckles.

56. The Ferragamo Belt Buckles sold to McGriff and the above-described 

members of the Class violated Nieman Marcus’ implied warranty of 

merchantability. Because of the above-described defect, they are not merchantable 

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and not fit for the ordinary purposes for which such goods are used, i.e., as a luxury

fashion accessory.

57. As a direct and proximate result of Nieman Marcus’ breach of the 

implied warranty, McGriff and the above-described members of the Class received 

goods whose latent defect substantially impairs their value to consumers such as 

themselves.

58. McGriff and the above-described members of the Class were unaware 

of this defect and reasonably could not have discovered it before they purchased 

their Ferragamo Belt Buckles.

59. McGriff and the above-described members of the Class seek damages 

based on the diminished value of their Ferragamo Belt Buckles as a result of this 

latent and material defect, and all other damages allowable under law.

COUNT FOUR

In the Alternative, Unjust Enrichment

(Against All Defendants)

60. Plaintiffs repeat, re-allege, and incorporate by reference the 

allegations contained in paragraphs 1 through 59 as though fully stated herein. 

Plaintiffs plead this count in the alternative should Plaintiffs’ statutory claims fail 

or be dismissed.

61. Plaintiffs assert this claim on behalf of themselves and all Class 

members nationwide.

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62. Defendants knew or reasonably should have known of the defect in the 

Ferragamo Belt Buckles but failed to disclose the defect to Plaintiffs and the Class 

either at or before the time of purchase.

63. Plaintiffs and the Class conferred upon Defendants payment for these 

products, which were benefits that were clearly non-gratuitous. They did so without 

knowledge of the defects affecting the products, which rendered them effectively 

useless for their purpose as a luxury fashion accessory.

64. Defendants appreciated, accepted and retained the non-gratuitous 

benefits conferred by Plaintiffs and the Class despite the defects in the Ferragamo 

Belt Buckles. Retaining the non-gratuitous benefits conferred upon Defendants by 

Plaintiffs and the Class under these circumstances is unjust and inequitable, and 

Defendants should pay restitution.

COUNT FIVE

Florida Unfair and Deceptive Trade Practices Act

(Against All Defendants)

65. Plaintiffs repeat, re-allege, and incorporate by reference the 

allegations contained in paragraphs 1 through 64 as though fully stated herein. 

66. Plaintiffs assert this claim on behalf of themselves and all Class 

members who are residents of Florida.

67. The Florida Unfair and Deceptive Trade Practices Act (“FUDTPA”) 

prohibits deceptive acts or practices in the conduct of any business, trade or

commerce or in the furnishing of any service in the state.

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68. Defendants materially misrepresented the quality of the Ferragamo 

Belt Buckles, including by failing to disclose the latent defect which would quickly 

render the products useless as luxury, designer fashion accessories.

69. Defendants’ material misrepresentations and omissions were made in 

the course of their respective businesses.

70. Defendants’ actions and/or inactions directly injured Plaintiffs and the

Class, as described herein.

71. Plaintiffs and the above-described members of the Class seek to recover

all permitted damages and their attorneys’ fees caused by Defendants’ violations of 

the FUDTPA.

VII. PRAYER FOR RELIEF: 

WHEREFORE, Plaintiffs, individually and on behalf of all others similarly 

situated, pray for a judgment against Defendants as follows: 

A. For an order certifying the Class, appointing Plaintiffs as 

Representatives of the Class, and appointing the undersigned law firms as counsel

for the Class; 

B. For compensatory damages to the extent permitted by law in an amount 

to be proven at trial;

C. For an order requiring Defendants to disgorge all profits, benefits, and 

other compensation they obtained from the sale of these defective products, including 

actual damages, and to pay restitution to Plaintiffs and the Class;

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D. For an order declaring, adjudging, and decreeing the conduct of the 

Defendants as alleged herein to be unlawful, unfair and/or deceptive, and enjoining 

any such future conduct;

E. For payment of Plaintiffs’ costs and expenses of suit herein incurred

including reasonable attorneys’ fees as permitted by law; 

F. Both pre-and post-judgment interest on any amounts awarded; and 

G. Such other and further relief as the Court may deem proper. 

VIII. DEMAND FOR JURY TRIAL: 

Plaintiffs and the Class hereby demand trial by jury of all issues triable by 

right. 

Dated: December 15, 2022 Respectfully submitted, 

/s/ Marcus W. Corwin, Esq.

Marcus W. Corwin, Esq. (Bar #764647)

MARCUS W. CORWIN, P.A. d/b/a CORWIN 

LAW

6501 Congress Avenue, Suite 100

Boca Raton, FL 33487

Telephone: 561.482.3636

Facsimile: 561.482.5414

mcorwin@corwinlawfirm.com

Jeffrey C. Schneider, Esq. (Bar #933244)

Victor Petrescu, Esq. (Bar #85268)

LEVINE KELLOGG LEHMAN SCHNEIDER + 

GROSSMAN LLP

100 SE 2nd Street, 36th Floor

Miami, FL 33131

Telephone: 305.403.8788

Facsimile: 305.403.8789

jcs@lklsg.com

vp@lklsg.com

Attorneys for Plaintiffs and the Proposed Class

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