UNITED STATES BANKRUPTCY COURT 

 SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 19-18401-BKC-CLC 

Chapter 7 Adv. Proc. No. 21-01207 

QUALITY TILE & MARBLE DISTRIBUTORS, LLC, 

Debtor 

JACQUELINE CALDERIN, CH. 7 TRUSTEE 

Plaintiff 

vs. 

PEARL CAPITAL BUSINESS FUNDING, LLC, 

Defendant 

_______________________________________/ 

GARNISHEE, BANKUNITED, N.A.’S ANSWER 

TO WRIT OF GARNISHMENT 

BANKUNITED, N.A., Garnishee in the above-styled cause, by and through its undersigned 

counsel, files this Answer of Garnishee and states: 

1. At the time of service of said Writ (plus sufficient time not to exceed one business 

day for Garnishee to act expeditiously on the Writ) and at the time of this Answer, and in between 

said times, excluding any “protected amount” as defined in Title 31, Subtitle B, Chapter II, 

Subchapter A, Part 212, Code of Federal Regulations, if any, the Garnishee’s records reflect the 

following account(s) which may be subject to this Writ of Garnishment: 

Account Number(s) Name(s) on Account 

xxxxxx0353 Pearl Capital Business Funding LLC 

Syndication 

525 Washington Blvd. 3FL 

Jersey City, NJ 07310 

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Chapter 7 Adv. Proc. No. 21-01207 

2. Pursuant to provisions of Section 77.06(2), 77.06(3), and 77.19, and subject to Court 

determination of the proper disposition of proceeds of the above account, set aside the following 

sum(s): 

Account Number(s) Amount Set Aside 

xxxxxxx0353 $24,735.58 (Double Amount) 

 3. Garnishee did not have in its hands, possession or control, any goods, chattels, or 

effects of Defendant(s) at the time of service of the Writ of Garnishment or at the time of this 

Answer, or at any time between such dates, and does not know of any other person(s) indebted to 

Defendant(s) or who may have any of the effects of Defendant(s) in his/her hands. 

4. Having filed the Answer of Garnishee in this case, Garnishee hereby demands from 

Plaintiff the payment of the $100.00 statutory garnishment fee for the part payment of its attorney’s 

fees, in accordance with Florida Statute 77.28, to be made payable to Garnishee’s attorney and 

mailed to the address set forth below. 

DEMAND FOR GARNISHMENT FEE 

Garnishee demands payment from Plaintiff to BankUnited, N.A. in the amount of $100.00 

as provided by F.S. Section 77.28, for service of its attorney in and about the preparation of this 

Answer. 

DESIGNATION OF EMAIL ADDRESS 

Pursuant to Rule 2.516 of the Florida Rules of Judicial Administration and Florida Rule of 

Civil Procedure 1.080 Counsel for Garnishee hereby designates the following primary email address 

for service of court documents: Primary email address: gary.carman@gray-robinson.com, 

anemrow@bankunited.com, Secondary email address: mb-legaldemands@bankunited.com. 

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Chapter 7 Adv. Proc. No. 21-01207

Dated: May 21, 2024 Respectfully submitted, 

/s/ Gary M. Carman 

Gary M. Carman, Esq. 

Florida Bar No. 179409 

Gary.carman@gray-robinson.com

GRAY|ROBINSON 

333 SE Second Avenue, Suite 3200 

Miami, Florida 33131 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on May 21, 2024, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF and a true and correct copy of the foregoing was served 

either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other 

authorized manner upon Maurice Bailey, Assignee of Judgment Creditor, 03089697@bellsouth.net, 

2095 Hwy 211 NW Suite 2-f-146 Braselton, Georgia 30517.

By: /s/ Gary M. Carman 

Gary M. Carman 

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