IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2021-014716-CA-01

SECTION: CA04

JUDGE: Carlos Guzman

DRO 15R LLC et al

Plaintiff(s)

vs.

AJAR Holdings LLC et al

Defendant(s)

____________________________/

ORDER GRANTING CONSERVATOR’S MOTION FOR ORDER TO SHOW CAUSE

THIS CAUSE, having come before the Court on September 28, 2021, upon the CourtAppointed Conservator, Ramon Abadin’s Supplemental Urgent Motion for Order to Show Cause

Against DRO 15R LLC, RO 15R, LLC, and Raziel Ofer for Violation of Court Order, and the

Court having reviewed the motion and the declaration filed in support, reviewed Mr. Ofer’s

September 22, 2021 affidavit, heard argument of counsel, and being otherwise fully advised in

the premises, the Court finds that:

1. The Conservator’s motion is granted as follows.

The Court relies upon the sworn representation of Mr. Ofer in his September 22,

2021 affidavit that he has “cooperated fully with all requests of Conservator and

provided all information in his possession,” as well as Plaintiffs’ counsel’s

representations at the September 28, 2021 hearing that his clients have provided

all documentation and information in their possession to the Conservator. Such

information consisted of one water bill and a permit number.

2.

DRO 15R LLC, RO 15R, LLC, and Raziel Ofer shall appear for deposition duces

tecum, as noticed by the Conservator on or before October 13, 2021. The

3.

Case No: 2021-014716-CA-01 Page 1 of 3

Filing # 135814054 E-Filed 10/04/2021 10:23:57 AM

COMPOSITE EXHIBIT B

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Conservator and the parties shall agree on a date for the deposition on or before

October 1, 2021, and absent such agreement, the Conservator may notice the

deposition unilaterally upon five days’ notice.

The parties are prohibited from accessing the property located at 1560 and 1568

Drexel Avenue, Miami Beach, Florida without the Conservator’s prior written

permission.

4.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 4th day of

October, 2021.

2021-014716-CA-01 10-04-2021 10:07 AM

Hon. Carlos Guzman

CIRCUIT COURT JUDGE

Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

David J Winker, dwinker@dwrlc.com

David J Winker, davidjwinker@gmail.com

David J Winker, davidjwinker@gmail.com

Jennifer Flores, Jflores@dvllp.com

Lisa Fazzah-Diaz, lfd@dvllp.com

Maurean Mass, mmas@scorpionholdings.net

Melanie Damian, Mdamian@dvllp.com

Nashid Sabir, nashid@bluoceanlaw.com

Nashid Sabir, nashidlaw@gmail.com

Nashid Sabir, brian@bluoceanlaw.com

Raziel Ofer, raz.ofer2@gmail.com

Case No: 2021-014716-CA-01 Page 2 of 3

Case 22-11755-RAM Doc 6-2 Filed 03/08/22 Page 2 of 11
Roniel Rodriguez IV, Ron@RJRfirm.com

Roniel Rodriguez IV, Ron@RJR.Company

Roniel Rodriguez IV, Ron@RJR.Partners

Russell Landy, rlandy@dvllp.com

Russell Landy, mdamian@dvllp.com

Russell Landy, jflores@dvllp.com

Sean Rowley, SRowley@legalservicesmiami.org

Sean Rowley, crodriguez@legalservicesmiami.org

Sean Rowley, pleadings@legalservicesmiami.org

Stuart Kab, srkalb@scorpionholdings.net

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

Physically Served:

Case No: 2021-014716-CA-01 Page 3 of 3

Case 22-11755-RAM Doc 6-2 Filed 03/08/22 Page 3 of 11
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2021-014716-CA-01

SECTION: CA04

JUDGE: Carlos Guzman

DRO 15R LLC et al

Plaintiff(s)

vs.

AJAR Holdings LLC et al

Defendant(s)

____________________________/

ORDER GRANTING CONSERVATOR’S SECOND MOTION FOR ORDER TO SHOW

CAUSE

THIS CAUSE, having come before the Court on November 10, 2021, upon the CourtAppointed Conservator Ramon Abadin’s Second Urgent Motion for Order to Show Cause

Against Plaintiffs, DRO 15R LLC, RO 15R, LLC, and Raziel Ofer, for Violation of Court Order,

and the Court having reviewed the motion, heard argument of counsel, and being otherwise fully

advised in the premises, the Court finds and orders:

1. The Conservator’s motion is granted as follows.

The Court finds that the Plaintiffs failed to comply with the Court’s October 4, 2021

order requiring the Plaintiffs to appear for deposition duces tecum on or before

October 13, 2021.

2.

The Court relies upon the sworn representation of Mr. Ofer in his November 10,

2021 affidavit concerning his health, as well as Plaintiffs’ counsel’s representations

at the November 10, 2021 hearing that his clients are not able to sit for deposition

until December 7, 2021, and that the Plaintiffs have provided all documentation

and information in their possession to the Conservator. Such information

3.

Case No: 2021-014716-CA-01 Page 1 of 3

Filing # 138565865 E-Filed 11/15/2021 09:28:54 PM Case 22-11755-RAM Doc 6-2 Filed 03/08/22 Page 4 of 11
consisted of one water bill and a permit number.

Accordingly, DRO 15R LLC, RO 15R, LLC, and Raziel Ofer shall appear for

deposition duces tecum, as noticed by the Conservator on December 7, 2021. 

4.

DRO 15R LLC and RO 15R, LLC shall produce a designee as required by Florida

Rule of Civil Procedure 1.310(b)(6) for the areas of inquiry noticed by the

Conservator (and produce the duces tecum documents) on December 7, 2021

irrespective of whether that designee is Mr. Ofer, or some other designee. 

5.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 15th day of

November, 2021.

2021-014716-CA-01 11-15-2021 9:20 PM

Hon. Carlos Guzman

CIRCUIT COURT JUDGE

Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

David J Winker, dwinker@dwrlc.com

David J Winker, davidjwinker@gmail.com

David J Winker, davidjwinker@gmail.com

Eric P. Stein, docservice@epslaw.com

Eric P. Stein, eric@epslaw.com

Isaac Raijman, isaac@raijman.com

Jennifer Flores, Jflores@dvllp.com

Lisa Fazzah-Diaz, lfd@dvllp.com

Maurean Mass, mmas@scorpionholdings.net

Case No: 2021-014716-CA-01 Page 2 of 3

Case 22-11755-RAM Doc 6-2 Filed 03/08/22 Page 5 of 11
Milton Raijman, milton@raijman.com

Nashid Sabir, nashid@bluoceanlaw.com

Nashid Sabir, nashidlaw@gmail.com

Nashid Sabir, brian@bluoceanlaw.com

Raziel Ofer, raz.ofer2@gmail.com

Roniel Rodriguez IV, Ron@RJRfirm.com

Roniel Rodriguez IV, Ron@RJR.Company

Roniel Rodriguez IV, Ron@RJR.Partners

Russell Landy, rlandy@dvllp.com

Russell Landy, mdamian@dvllp.com

Russell Landy, jflores@dvllp.com

Sean Rowley, SRowley@legalservicesmiami.org

Sean Rowley, crodriguez@legalservicesmiami.org

Sean Rowley, pleadings@legalservicesmiami.org

Stuart Kab, srkalb@scorpionholdings.net

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

Physically Served:

Case No: 2021-014716-CA-01 Page 3 of 3

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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2021-014716-CA-01

SECTION: CA04

JUDGE: Carlos Guzman

DRO 15R LLC et al

Plaintiff(s)

vs.

AJAR Holdings LLC et al

Defendant(s)

____________________________/

AMENDED ORDER GRANTING CONSERVATOR’S THIRD MOTION FOR ORDER

TO SHOW CAUSE

THIS CAUSE, having come before the Court on December 22, 2021, upon the CourtAppointed Conservator Ramon Abadin’s Emergency Third Motion for Order to Show Cause

Against Plaintiff(s), DRO 15R LLC, RO 15R, LLC, Raziel Ofer, and Robert Mendez for

Violation of Court Orders, and the Court having reviewed the motion, heard argument of

counsel, and being otherwise fully advised in the premises, the Court finds and orders:

1. The Conservator’s motion is granted.

The Court has determined that the Plaintiff(s) failed to comply with the Court’s

October 4, 2021 order requiring the Plaintiff(s) to appear for deposition duces

tecum on or before October 13, 2021, and failed to comply with the Court’s

November 15, 2021, order requiring the Plaintiff(s) to appear for deposition on

December 7, 2021.

2.

Further, the Court has determined that the Conservator presented evidence that

DRO 15R LLC, RO 15R, LLC, Raziel Ofer failed to comply with the Court’s

October 4, 2021, order prohibiting the parties from accessing the Property without

3.

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prior written consent of the Conservator.

DRO 15R LLC and Raziel Ofer, shall appear before this Court on January 25,

2022, at 2:45 pm and show cause why they should not be held in contempt of

court for violation of the Court’s Appointment Order and the Court’s October 4,

2021, and November 15, 2021, orders, by, including but not limited to their refusal

to cooperate with the requests of the Conservator, failure to appear for Court

ordered depositions, address the Conservator’s evidence that Plaintiff(s) collected

funds from tenants after the Appointment Order, and accessing the Property

without prior written approval by the Conservator.

4.

The Plaintiff(s) are jointly and severally liable for legal fees incurred by the

Conservator to bring his third motion for order to show cause before the Court, in

an amount to be determined at a future hearing.

5.

DRO 15R LLC, RO 15R, LLC, Raziel Ofer, and Robert Mendez shall appear for

deposition duces tecum, on January 5, 2021, and/or January 6, 2021, as shall be

noticed by the Conservator.

6.

DRO 15R LLC and RO 15R, LLC shall produce a designee as required by Florida

Rule of Civil Procedure 1.310(b)(6) for the areas of inquiry noticed by the

Conservator (and produce the duces tecum documents) irrespective of whether

that designee is Mr. Ofer, or some other designee. 

7.

DRO 15R LLC, RO 15R, LLC, Raziel Ofer, and Robert Mendez, and their counsel,

agents, and representatives, are prohibited from contacting any tenants, residents,

workers, or the Conservator’s representatives at the Property until further order of

the Court.[1]

8.

The Court shall hold a further hearing concerning the portion of the Conservator’s

motion concerning whether DRO 15R LLC, RO 15R, LLC, Raziel Ofer, and Robert

Mendez received and/or are required to turn over to the Conservator $2,800, and

any other funds received related to the Property after the date of the Appointment

9.

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Order.

On or before Friday, December 31, 2021, DRO 15R LLC, RO 15R, LLC, Raziel

Ofer, and Robert Mendez shall identify to the Conservator any personal property

believed to be located at the Property which is owned by the Plaintiff(s) or any

third party. This shall be done by an itemized list of all such property containing a

specific and detailed description of the personal property, the full name of the

owner of such personal property (including contact information), and the last

known location of the personal property. Failure to specifically identify any item(s)

shall be deemed to be a waiver of any claim for return of, damages arising from

disposal of, or any other claim whatsoever arising from or relating to such

property. To the extent known to Plaintiff(s), Plaintiff(s) are required to

immediately provide copies of this order and notice of this provision to anyone

claiming interested to any equipment or personal property on site at 1560 and

1568 Drexel Avenue. Any personal property not specifically identified by Friday,

December 31, 2021 may be retained, disposed of, or destroyed consistent with

the Conservator’s powers conferred by the Court.

10.

[1] For the avoidance of doubt, the counsel for the Plaintiff(s) and Mr. Mendez may confer with

the Conservator’s counsel.

DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 30th day of

December, 2021.

2021-014716-CA-01 12-30-2021 11:18 AM

Hon. Carlos Guzman

CIRCUIT COURT JUDGE

Electronically Signed

Case No: 2021-014716-CA-01 Page 3 of 5

Case 22-11755-RAM Doc 6-2 Filed 03/08/22 Page 9 of 11
No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:

David J Winker, dwinker@dwrlc.com

David J Winker, davidjwinker@gmail.com

David J Winker, davidjwinker@gmail.com

Eric P. Stein, docservice@epslaw.com

Eric P. Stein, eric@epslaw.com

Isaac Raijman, isaac@raijman.com

Lisa Fazzah-Diaz, lfd@dvllp.com

Maurean Mass, mmas@scorpionholdings.net

Melanie Damian, mdamian@dvllp.com

Melanie Damian, mdamian@dvllp.com

Melanie Damian, lfd@dvllp.com

Milton Raijman, milton@raijman.com

Nashid Sabir, nashid@bluoceanlaw.com

Nashid Sabir, nashidlaw@gmail.com

Nashid Sabir, brian@bluoceanlaw.com

Raziel Ofer, raz.ofer2@gmail.com

Roniel Rodriguez IV, Ron@RJRfirm.com

Roniel Rodriguez IV, Ron@RJR.Company

Roniel Rodriguez IV, Ron@RJR.Partners

Russell Landy, rlandy@dvllp.com

Russell Landy, mdamian@dvllp.com

Russell Landy, jflores@dvllp.com

Sean Rowley, SRowley@legalservicesmiami.org

Sean Rowley, crodriguez@legalservicesmiami.org

Sean Rowley, pleadings@legalservicesmiami.org

Stuart Kab, srkalb@scorpionholdings.net

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

William Wainright Riley Esq., w.riley@rileyfirm.org

Case No: 2021-014716-CA-01 Page 4 of 5

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Physically Served:

Case No: 2021-014716-CA-01 Page 5 of 5

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