APPENDIX A

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

Case No: 20-15954-RAM

ADVERSARY NO. 20-01350-RAM

MELANIE ADAMS, individually and

on behalf of her minor daughter, TAYLOR

ADAMS,

Creditors/Plaintiffs,

v.

PHUONG MIMI NGUYEN,

Debtor/Defendant,

_________________________________________/

PLAINTIFFS’ EXHIBIT LIST

TRIAL DATE: APRIL 28, 2021 at 9:30 a.m.

Exh. # DOCUMENT 

DESCRIPTION

DATE 

IDENTIFIED

DATED 

ADMITTED

WITH OR 

WITHOUT 

OBJECTION

1 Estimate from Kitchens 

By Us to “GC-MimiGreen Paradise” dated 

October 5, 2016 for, 

inter alia, Plaintiffs’ 

kitchen cabinets.

2 Checks written by 

Plaintiff, Melanie 

Adams, made payable 

to Debtor dated 

September 12, 2016, 

October 12, 2016, 

December 17, 2016, 

December 29, 2016, 

BATES STAMP 1 OF 137

Case 20-01350-RAM Doc 27 Filed 04/15/21 Page 1 of 5
APPENDIX A

and December 31, 

2016.

3 New Concept Invoice 

dated December 29, 

2016.

4 Checks written by 

Plaintiff, Melanie 

Adams, made payable 

to New Concept dated 

January 13, 2017 and 

January 15, 2017.

5 Miami-Dade County 

Office of the Property 

Appraiser detailed 

report for Defendant’s 

property located at 

9219 SW 123 Avenue 

Court, Miami, Florida 

33186.

6 Checks written by 

Plaintiff, Melanie 

Adams, to Debtor’s 

subcontractors dated 

September 27, 2016, 

October 12, 2016, 

October 19, 2016, 

January 3, 2017, 

January 13, 2017, 

January 14, 2017, 

February 11, 2017, and 

May 17, 2017.

7 Text messages between 

Plaintiff, Melanie 

Adams, and Debtor.

8 Miami-Dade County epermit record for 

property located at 

14016 SW 132 Avenue, 

Miami, Florida 33186.

BATES STAMP 2 OF 137

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APPENDIX A

9 E-mails between the 

Plaintiff, Melanie 

Adams, and Debtor.

10 Miami-Dade County 

Building 

Department/Department 

of Regulatory and 

Economic Resources 

notice of insurance 

expiration of New 

Concept.

11 Miami-Dade County 

Contractor License 

Information of New 

Concept and Florida 

Department of 

Corporations (SunBiz) 

corporate information 

of New Concept.

12 Debtor’s State of 

Florida certified general 

contractor license 

information.

13 Debtor’s company, 

Green Paradise LLC’s 

insurance policy for 

August 24, 2016 to 

August 24, 2017.

14 Debtor’s company, 

Green Paradise 

Landscaping LLC’s 

insurance policy for 

March 23, 2019 to 

March 23, 2020.

15 E-mails between 

Plaintiff, Melanie 

Adams, and Debtor.

16 Debtor’s deposition 

dated June 4, 2018 in 

BATES STAMP 3 OF 137

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APPENDIX A

the matter of Melanie 

Adams and Taylor 

Adams v. Mimi Nguyen, 

et al., Case No.: 2018-

006210-CA-01 in the 

11th Judicial Circuit 

Court in and for MiamiDade County, Florida. 

17 Debtor’s deposition 

dated February 16, 

2021 in the instant 

action.

18 Florida Department of 

Corporations (SunBiz) 

corporate information 

of Design by 

Mimiyoko, LLC.

19 Florida Department of 

Corporations (SunBiz) 

corporate information 

of Green Paradise 

Landscaping, LLC.

BATES STAMP 4 OF 137

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APPENDIX A

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was 

served on this 15th day of April, 2021, to all parties on the list to receive e-mail 

notice/service for this case, via the Notice of Electronic Filing, and to Ricardo A 

Rodriguez, Esq., FBN: 0496901, Rodriguez Law, P.L., 900 West 49th Street, Suite 

505, Hialeah, FL 33012, Tel: 305-262-8226 / Fax: 305-262-8229, Email: 

ricardo@rdgzlaw.com, Service Email: mail@rdgzlaw.com.

By: /s/ Zachary A. Friedman, Esquire

 FB# 117506

 Friedman and Friedman, P.A.

 Attorneys for Creditors, Melanie and 

Taylor Adams

 2600 Douglas Rd., Ste. 1011

 Coral Gables, FL 33134

 (305) 446-6485 

 (305) 448-7636 fax

zach@friedmantriallawyers.com

john@friedmantriallawyers.com

BATES STAMP 5 OF 137

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