Greenleaf Health v Dechoker LLC court records to date (updated 3/13/18)

April 2, 2018 | Author: Peter M. Heimlich | Category: Independent Contractor, Service Of Process, Complaint, Lawsuit, Employment


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Filing # 64621057 E-Filed 11127/201704:26:15 PMIN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PASCO COUNTY, FLORIDA GREENLEAF HEALTH, INC , 1065 Thomas Jefferson St NW, #450 Washington DC 20007 Plamnff, Case No VS Division DECHOKER LLC, Defendant ----------------------------~/ !!!!!!!l!!! COMPLAINT - == = !!I!!!!!! Plaintiff GREENLEAF HEALTH, INC, sues the Defendant, DECHOKER LLC, and for - iiiiiii iii Its Complaint states as follows == = COUNT I - BREACH OF AGREEMENT 1 This ISan action for damages that exceed $15,000 00, exclusive of Interest, court costs and attorney's fees 2 Plamuff, GREENLEAF HEALTH, INC ,and Defendant, DECHOKER LLC, entered Into :: an Agreement, a copy being attached hereto and made a part hereof - 3 Plamtiff performed all conditions required by the Agreement 4 The Defendant IS In default of the Agreement by faihng to make payment and Plamtiff ISentitled, pursuant to the terms ofthe Agreement, to the sum of$21,175 00, by VIrtue of default, together With Interest thereon 5 Plamtiff ISobhgated to pay ItSattorneys a fee for their services, and pursuant to the terms of the Agreement, Defendant agreed to pay attorney's fees In the event of default WHEREFORE, Plamtiff demands Judgment agamst the Defendant In the sum of $21,17500, together With Interest, court costs and attorney's fees COUNT II - OPEN ACCOUNT 6 Thts IS an action for damages that exceed $15,000 00, exclusive of Interest and court costs Electronically Filed Pasco Case # 2017CA003434CAAXWS 11/27/201704:26:15 PM 7 The Defendant owes the Plamtlff$21,175 00 that IS due with mterest, in accordance With the attached account WHEREFORE, Plamtiff demands Judgment agamst the Defendant in the sum of $21,17500, together wrth mterest and court costs COUNT III - ACCOUNT STATED 8 This IS an action for damages that exceed $15,00000, exclusive ofmterest and court costs 9 Before the mstitution of this action, Plamtiff and Defendant had business transactions between them and agreed to the resultmg balance 10 Plamtiff rendered a statement of It to Defendant, a copy bemg attached, and Defendant did not object to the statement 11 The Defendant owes the Plamnff'Sz l, 175 00 that IS due with mterest, in accordance With the attached account WHEREFORE, n agamst the Defendant in the sum of $21,17500, together with mterest and court costs .,. • BY~~~~r-.-~ ~~-,~~=- __ ( )Ral h cadis, Esquire, FL Bar #351458 (~Gtl S nger, Esquire, FL Bar #282987 ()Am I sky, Esquire, FL Bar #900140 ( )Jona an P empflmg, Esquire, FL Bar #89067 ( )Robert J Lmdeman, Esquire, FL Bar #112608 ( )Stuart H Marcadis, Esquire, FL Bar #121587 5104 South Westshore Blvd, Tampa, FL 33611 813/288-1881, toll free 888/547-1881 Fax 813/288-9678 E-servlce pleadmgs@marcadlslaw com ATTORNEY FOR PLAINTIFF 171016i9291O/JMG TIns IS a commurucanon from a debt collector We are attemptmg to collect a debt Any mformanon you provide may be used for that purpose r/) Greenleaf Health GREENLEAF HEALTH, INC INDEPENDENT CONTRACTOR AGREEMENT This Independent Contractor Agreement (the 'Agreement ) ISentered mto as of )v.-i\ "- fl, 20~ (the 'Effective Date) by and between Greenleaf Health Inc ( Greenleaf) a Delaware corporation (the 'Contractor') and t)l c..\.-.o ~e..r , a _I.-;;__L_:;;.C, _ [corporanon/partnership/etc ] (the Company and together with the Contractor the Parnes ) RECITALS WHEREAS the Company WIshes to engage the Contractor as an independent contractor for the Company for the purpose of completing certain specified tasks on the terms and conditions set forth below and WHEREAS, the Contractor WIshes to provide the Services (as defined m ExhibIt A) m accordance WIththe terms of this Agreement and WHEREAS, each Party IS duly authonzed and capable of entenng into this Agreement NOW THEREFORE m consideration of the above recitals and the mutual promises and benefits contained herem, the Parties hereby agree as follows 1 RESPONSIBILITIES (a) Of the Contractor The Contractor agrees to do each of the following A Perform the Services set forth In ExhIbIt A attached hereto and made a part hereof (collectively the Services ) B Devote as much productive ume energy and abrhty to the performance of as duties hereunder as may be necessary to provide the required Services m a timely and productive manner C Perform the Services in a safe good and workmanhke manner by fully tramed slalled competent, and expenenced personnel D Communicate WIth the Company regarding progress the Contractor has made m performing the Services G,.eenlea!Health,lnc Independent COnt1'aCI01'Agreement E Provide services (mcludmg the Services) and end products that are satisfactory and acceptable to the Company F Correct all or any portion of the work or end products found unsuitable Without additional cost or nsk to the Company (b) Of the Company The Company agrees to do each of the following A Engage the Contractor as an independent contractor to perform the Services set forth In Exhtblt A to this Agreement B Provide relevant Information to assist the Contractor With the performance of the Services C Sattsfy all of the Contractor s reasonable requests for assistance m ItS performance of the Services 2 NATURE OF RELATIONSHIP (a) Independent Contractor Status The Contractor agrees to perform the Services hereunder solely as an Independent contractor The Parttes agree that nothing In this Agreement shall be construed as creating a joint venture partnership franchise agency employer/employee, or similar relationship between the Parties or as authonzmg either Party to act as the agent of the other The Contractor IS and Will remam an independent contractor an Its relationship to the Company The Company shall not be responsible for withholdmg taxes With respect to the Contractor S compensatton hereunder The Contractor shall have no claim against the Company hereunder or otherwise for vacation pay sick leave retirement benefits SOCialsecunty worker s compensatton health or disability benefits, unemployment Insurance benefits or employee benefits of any kind Nothing an tlns Agreement shall create any obhgatton between either Party and a third party (b) Indemruficatton of Company by Contractor The Company has entered mto this Agreement In reliance on mformanon provided by the Contractor mcludmg the Contractor's express representatton that It IS an Independent contractor and In comphance With all apphcable laws related to work as an independent contractor If any regulatory body or court of competent junsdicnon finds that the Contractor IS not an Independent contractor andlor IS not m comphance With apphcable laws related to work as an independent contractor based on the Contractor s own actions the Contractor shall assume full responsrbihty and habrhty for all taxes assessments and penalties Imposed against the Contractor andlor the Company resulting from such contrary mterpretanon mcludmg but not lmuted to taxes assessments and penalttes that would have been deducted from the Contractor's earrungs had the Contractor been on the Company's payroll and employed as an employee of the Company Greenlea/Health Inc Independent Contractor Agreement 2 3 CONFIDENTIAL INFORMAnON The Contractor agrees, dunng the Term and thereafter, to hold m stnctest confidence and not to use except for the benefit of the Company, or to disclose to any person, finn or corporation WIthout the pnor wntten authonzanon of the Company any Confidential Information of the Company Confidential Information" means any of the Company's propnetary mformanon techrucal data, trade secrets or know-how mcludmg but not hunted to research product plans products services customer hsts, markets software developments, mvennons, processes, formulas technology, designs drawings engmeenng, hardware configuration mformanon marketing finances or other business mformanon disclosed to the Contractor by the Company, either directly or indirectly The Contractor may use the Confidential Information to the extent necessary for negotianons discussions and consultations With Company personnel or authonzed representatives or for any other purpose the Company may hereafter authorize 10 wnnng 4 REPRESENTA nONS AND WARRANTIES (a) The Parnes each represent and warrant as follows A Each Party has full power authonty and nght to perform rts obhgations under the Agreement B This Agreement IS a legal Valid, and bmdmg obhganon of each Party enforceable against It m accordance With Its terms (except as may be limited by bankruptcy Insolvency moratonum or Similar laws affectmg creditors' nghts generally and equitable remedies) C Entenng Into tins Agreement Will not Violate the charter or bylaws of either Party or any matenal contract to which that Party IS also a party (b) The Contractor hereby represents and warrants as follows A The Contractor has the sole nght to control and direct the means details, manner and method by which the Services reqwred by this Agreement Will be performed B The Contractor has the nght to perform the Services required by tins Agreement at any place or locanon and at such Urnes as the Contractor shall determme C The Services shall be performed In accordance With standards prevaihng In the Company s industry and shall further be performed in accordance With and shall not Violate any apphcable laws rules or regulanons and the Contractor shall obtain all permits or permissions required to comply With such standards laws rules or regulations D The Services reqwred by this Agreement shall be performed by the Contractor or the Contractor s staff and the Company shall not be reqwred to hire supervise or pay any assistants to help the Contractor perform such services Green/ea/HeaJtJa. Inc Inclependent Contractor Agreement 3 E The Contractor IS responsible for paymg all ordmary and necessary expenses of Its staff F The Contractor IS responsible for provrdmg insurance coverage for Itself and ItS staff (c) The Company hereby represents and warrants as follows A The Company Will make timely payments of amounts eamed by the Contractor under thrs Agreement B The Company shall notify the Contractor of any changes to Its procedures affectmg the Contractor s obhganons under this Agreement at least 30 days pnor to implementmg such changes C The Company shall provide such other assistance to the Contractor as It deems reasonable and appropnate 5 COMPENSATION (a) Terms and CondItions The Company shall pay the Contractor 10 accordance With the terms and conditions under this Agreement (b) Timms of Payment Payments shall be made to the Contractor within (30) days of the Company s receipt of the Contractor s 1OVOlce,supported by reasonable documentation for all Services performed to the Company's sansfacnon ID accordance WIth Exhibit A (c) No Payments 10 CertaIn CIrcumstances Notwithstanding the foregomg, no payment shall be payable to the Contractor under any of the following CIrcumstances A If prohibited under applicable government law regulation or policy B If the Contractor did not directly perform or complete the Services descnbed 10 ExhIbit A, C If the Contractor did not perform the Services to the reasonable sansfacnon of the Company or D If the Services performed occurred after the expiration or termmanon of the Term of this Agreement, unless otherwise agreed 10 wntmg (d) No Other Compensation The compensation set out above shall be the Contractor s sole compensanon under this Agreement (e) Expenses Any expenses mcurred by the Contractor In the performance of this Agreement shall require pre-approval by the Company Greenleaf Health, Inc Independent Contractor Agreement 4 (f) Travel Company agrees to compensate the Contractor for time spent by Consultant(s) 10 travel status at the request of the Company at the rate of 50% of the rate stated 10 ExhIbit A Atr travel at the request of the Company Will be Business Class for destmanons outside the continental United States and Economy Class otherwise Company assumes the nsk of the cost of any penalties due to cancellations as a result of changes 10 schedule made by the Company (g) Taxes The Contractor IS solely responsible for the payment of all income social secunty employment-related or other taxes incurred as a result of the performance of the Services by the Contractor under this Agreement and for all obhganons reports and nmely nonficanons relating to such taxes The Company shall have no obhganon to pay or Withhold any sums for such taxes 6 WORK FOR HIRE The Contractor expressly acknowledges and agrees that any work prepared by the Contractor under this Agreement shall be considered "work for lure' and the exclusive property of the Company unless otherwise specified To the extent such work may not be deemed a work for lure' under applicable law, the Contractor hereby assigns to the Company all of Its nght title, and interest 10 and to such work The Contractor shall execute and dehver to the Company any instruments of transfer and take such other action that the Company may reasonably request, mcludmg, without hmrtanon executing and fihng, at the Company s expense copynght apphcanons, assignments and other documents reqwred for the protection of the Company's nghts to such matenals 7 NO CONFLICT OF INTEREST, OTHER ACTIVITIES The Contractor hereby warrants to the Company that, to the best of Its knowledge It IS not currently obhged under an existmg contract or other duty that conflicts With or IS mconsistent WIth this Agreement Dunng the Term, as defined under the Agreement, the Contractor ISfree to engage m other independent contracnng acnvmes prOVided. however, the Contractor shall not accept work, enter mto contracts or accept obhganons mconsistent or incompanble With the Contractor s obhganons or the scope of Services to be rendered for the Company pursuant to this Agreement 8 lERM.. This Agreement shall become effecnve as of the Effectrve Date and unless otherwise terminated 10 accordance WIth the provisions of Section 9 of this Agreement, Will contmue until the Services have been sattsfactonly completed and the Contractor has been paid 10 full for such Services (the Term ) 9 TERMINA nON This Agreement may be terminated (a) By either Party on provision of 30 days wntten notice to the other Party With or Without cause Greenleaf Health, Inc Independent Contractor Agreement 5 (b) By either party for a matenal breach of any provision of tins Agreement by the other Party lfthe other Party s matenal breach IS not cured wtthm 30 days of receipt of wntten nonce thereof (c) By the Company at any time and without pnor nonce If the Contractor IS convicted of any cnme or offense falls or refuses to comply with the wntten policies or reasonable directrves of the Company or IS gwlty of senous misconduct In connection With performance under this Agreement Following the temunatton oftlus Agreement for any reason, the Company shall promptly pay the Contractor according to the terms of Exhibit A for Services rendered before the effective date of the termmanon The Contractor acknowledges and agrees that no other compensation of any nature or type shall be payable hereunder following the termmatron of this Agreement 10 RETURN OF PROPERTY Wrthm 30 days of the termmanon of this Agreement whether by expiration or otherwise the Contractor agrees to return to the Company all Company products samples, models or other property and all documents retatrung no copies or notes relatmg to the Company s business mcludmg but not hmited to reports abstracts hsts, correspondence, mformanon, computer files computer rusks and all other matenals and all COpies of such matenal obtatned by the Contractor dunng and 10 connection With Its representation of the Company All files records, documents bluepnnts specifications, mformanon letters notes media hsts, ongmal artwork/creative notebooks and similar Items relating to the Company s business whether prepared by the Contractor or otherwise cormng into Its pOSseSSIOn,shall remain the Company s exclusive property 11 INDEMNIFICA nON The Parnes shalltndemrufy and hold harmless each other and Its officers members managers employees, agents, contractors, sublicensees affihates, subsidiaries successors, and assigns from and against any and all damages habihties costs expenses claims, and/or Judgments, mcludmg WIthout hmrtanon, reasonable attorneys' fees and disbursements (collecttvely the 'Claims') that any of them may suffer from or Incur and that anse or result pnmanly from (i) any negligence or Willful misconduct of the either party ansmg from or connected With performance of Its dunes under this Agreement or (u) the either party's breach of any of ItS obhganons agreements or duties under this Agreement 12 A'ITORNEY' S FEES (a) In the event that hngation or other proceechngs anse regarding this engagement and Contractor IS subpoenaed or otherwise requested to testify disclose documents and matenals, or otherwise contnbute to such proceeding, Company agrees to pay for Contractor's reasonable attorney s fees orne and costs, irrespecnve of whether Contractor IS named party to such proceeding Contractor shall have the nght to designate and choose Its own counsel Company will pay the Contractor the Contractor's current hourly rate for the time that the Contractor spends related to such proceeding This section shall survive the termmanon of tins Agreement GreenleafHeal/h Inc Independent Contractor Agreement 6 (b) In the event that hnganon or other proceedings anse regarchng this engagement and Company IS subpoenaed or otherwise requested to testify, chsclose documents and matenals, or otherwise contnbute to such proceeding, Contractor agrees to pay for Company's reasonable attorney's fees time, and costs, irrespective of whether Company IS named party to such proceeding Company shall have the right to designate and choose ItS own counsel This section shall survive the termmanon of this Agreement 13 USE OF TRADEMARKS The Contractor recogruzes the Company's nght, ntle and Interest In and to all service marks trademarks and trade names used by the Company and agrees not to engage 1D any actrvmes or comnut any acts directly or Indirectly, that may contest dispute, or otherwise impair the Company s nght, title and Interest therein nor shall the Contractor cause drrmmshment of value of said trademarks or trade names through any act or representation The Contractor shall not apply for acquire or chum any nght title or interest In or to any such service marks trademarks or trade names or others that may be confusingly similar to any of them, through adverusmg or otherwise Effective as of the termmanon of this Agreement, whether by expiranon or otherwise the Contractor shall cease to use all of the Company s trademarks marks and trade names 14 MODIFICA nON No amendment, change or modification of this Agreement shall be valid unless 10 wnnng and mutually agreed to by both Parties 15 ASSIGNMENT The Company may assign this Agreement freely, 10 whole or 10 part The Contractor may not, WIthout the wntten consent of the Company aseign, subcontract, or delegate Its obhganons under this Agreement exeept that the Contractor may transfer the nght to receive any amounts that may be payable to It for ItS Services under this Agreement, which transfer will be effective only after receipt by the Company of wntten nonce of such assignment or transfer 16 SUCCESSORS AND ASSIGNS All references In this Agreement to the Parnes shall be deemed to Include as apphcable a reference to their respectrve successors and assigns The provisions of this Agreement shall be bindmg on and shall inure to the benefit of the successors and assigns of the Parties 17 FORCE MAJEURE A Party shall be not be considered In breach of or 10 default under this Agreement on account of, and shall not be hable to the other Party for, any delay or failure to perform Its obhganons hereunder by reason of tire earthquake flood, explosion, stnke not war terronsm, or similar event beyond that Party S reasonable control (each a Foree Majeure Event') proVided. however, If a Force Majeure Event occurs, the affected Party shall as soon as practicable (a) notify the other Party of the Force Majeure Event and Its Impact on performance under this Agreement, and Greenleaf Health. Inc Independent Contractor Agreement 7 (b) use reasonable efforts to resolve any 1SSUes resultmg from the Force Majeure Event and perform Its obbgattons hereunder 18 NO IMPLIED WAIVER. The failure of either Party to msrst on stnct performance of any covenant or obhganon under this Agreement. regardless of the length of time for whtch such failure continues shall not be deemed a Waiver of such Party's nght to demand stnct comphance 1D the future No consent or waiver express or imphed, to or of any breach or default in the performance of any obhgatton under this Agreement shall constitute a consent or Waiver to or of any other breach or default In the performance of the same or any other obhganon 19 NOTICE Any notice or other commumcanon provided for herem or grven hereunder to a Party hereto shall be m wntmg and shall be given lD person by overnight couner or by mail (registered or cernfied mall postage prepaid, return-receipt requested) to the respective Parties as follows Ifto the Company D~c...ho \::.-e-v- LL c, If to the Contractor GreenleafHea1th, Inc 2900 K Street. NW Suite 100 Washington 0 C 20007 Attn Patnck Ronan, President 20 GOVERNING LAW ThIS Agreement shall be governed by the laws of the state of Delaware In the event that lrnganon results from or anses out of this Agreement or the performance thereof, the Parnes agree to reimburse the prevailing Party's reasonable attorneys fees, court costs and all other expenses, whether or not taxable by the court as costs m addmon to any other rehef to which the prevailmg Party may be entitled Greenleof Health Inc Independent Contractor Agreement 8 11 COUNTERPARTSIELECTRONIC SIGNATURES This Agreement may be executed in one or more counterparts each of which shall be deemed an onginal but all of which shall constmrte one and the same mstrument For purposes of tins Agreement, use of a facsmule e-mail or other electronic medium shall have the same force and effect as an ongmal signature 11 SEVERABILITY Whenever possible each provrsion of this Agreement will be Interpreted in such manner as to be effective and vahd under apphcable law but If any provision of thrs Agreement IS held to be Invalid Illegal or unenforceable 10 any respect under any applicable law or rule In any junsdiction, such mvalidity rllegahty, or unenforceabthty WIll not affect any other provision or any other junsdicnon but thtS Agreement WIll be reformed, construed, and enforced 10 such junsdictron as If such mvahd Illegal or unenforceable provisions had never been contained herem 23 ENTIRE AGREEMENT TIns Agreement, conSbtutes the final complete and exclusive statement of the agreement of the Parties WIthrespect to the subject matter hereof, and supersedes any and all other pnor and contemporaneous agreements and understandings both wntten and oral between the Parties 24 HEADINGS Headings used 10 this Agreement are provided for convemence only and shall not be used to construe meanmg or intent Greenleaf Health, Inc Independent Contractor Agreement 9 IN WITNESS WHEREOF, the Parties have executed tins Agreement as of the date first above wntten COMPANY [COMPANY NAME] Name A\ c;.. ~ (_ "- «: v e, .r CONTRACTOR Greenleaf Health Inc By Name Patrick Ronan Prest dent Greenleaf Health; Inc Independent Contractor Agreement 10 "Exhlbut A" Fees The Company shall pay the Contractor the Contractor> s current hourly rate for consulting services relating to the Company s Food and Drug Adrmmstranon regulatory Issues The Contractor s current hourly rate IS $600 00 per hour/per consultant Contractor reserves the nght to Increase Its hourly rate on an annual basts Contractor will promptly notify the Company of any changes 10 the Contractor s hourly rate Greenleaf Health Inc Independent Contractor Agreement 11 Greenleaf Health. Inc. 1055 Thomas Jefferson St NW Suite 450 Washington DC 20007 US accountlng@greenleafhealthllc com Statement TO STATEMENT NO 1026 Dechoker LLC DATE 08/25/2017 TOTAL DUE $2117500 ENCLOSED 0713112016 Invoice #DECH0716 Due 08130/2016 23 rts 00 1577500 0813112016 lnvoice #DECH0816 Due 0913012016 5 400 00 5 400 00 000 000 000 000 21 17500 $21,17500 DIVIDER DIVIDER IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PASCO COUNTY, FLORIDA GREENLEAF HEALTH, INC , Plaintiff, C~eNo 2017CA003434CAAXWS VS DIVISion DECHOKER LLC, .. ~ Defendant ":j ~~ _______________________________ 1 :;) () ~ J) i'l :~ ~\ :_::j ()- :::; ..,~ .~ ,~r ... -, ~f ~ c::J (~..I m SUMMONS ::/ 11:>.:::_ ,-., () 0 ~- ~. ('""")0." ~ ~ .. " :) '"", I c 0 Z ...,.., THE STATE OF FLORIDA ,;,-..~._ ::; ga » .' -J -I ._(JJ ;v To each Shenff of the State ?; :! t. ., ~ .. ~~ -. = 0 r YOU ARE HEREBY COMMANDED to serve this Swnmons and co~y ~the c2npl~n5 or Pennon In the acnon on Defendant ..... I ? .~~. DE CHOKER LLC, Serve Alan Carver, RA OR any officer or director at 10433 Garda Drive Truuty FL 34655 Each Defendant IS hereby required to serve wntten defenses to said Complaint or Pennon on Plaintiff's attorney, whose name and address IS MARCADIS SINGER, P A 5104 South Westshore Blvd Tampa, Flonda 33611 Withm twenty (20) days after service of this Summons on Defendant, exclusive of the day of service, and to file the ongmal of the defenses With the Clerk at Pasco County Courthouse, 7530 LIttle Road, New Port RIchey, Flonda 34654, either before service on Plaintiff's attorney or Immediately thereafter If Defendant falls to do so, a default Will be entered against Defendant for the relief demanded in the Complaint or Petitron 2017 WITNESS my hand and seal of tlus Court on the -'7-+--- day of Pece ~ ;;?tJ( ) PAULA S O'NEIL Clerk of the Court By isl Cynthia lFerdoo-Gaeda Deputy Clerk 17I016l929l0fJMG This IS a commurucauon from a debt collector We are anempung to collect a debt Any information you provide may be used for that purpose Issued/Ret'd Process Server SUMMONS PERSONAL SERVICE ON AN INDIVIDUAL IMPORTANT A lawsuit has been filed agamst you You have TWENTY (20) calendar days after this Summons IS served on you to file a written response to the attached Complaint m this Court A phone call will not protect you your wntten response includmg the above case number and named parties must be filed If you want the Court to hear your case If you do not file your response on time you may lose the case and your wages money and property may thereafter be taken Without further warnmg from the Court There are other legal requirements You may want to call an attorney right away If you do not know an attorney you may call an attorney referral service or a legal aid office (listed In the phone book) If you choose to file a wntten response yourself at the same time you file your wntten response to the Court you must also mall or take a carbon copy or photocopy of your wntten response to the' Plamtiff/Plamuff's Attorney named below IMPORT ANTE Usted ha sido demandado legalmente Tiene veinte (20) dias contados a partir del recibo de esta nouficacion para contestar la demanda adjunta por escnto y presentarla ante este tnbunal Una Hamada teleforuca no 10 protegera Sl usted desea que el tnbunal considere su defensa debe presentar su respuesta por escnto mcluyendo el numero del caso y los nombres de las partes interesadas en dicho caso SI usted no contesta la demanda a uernpo pudiese perder el caso y podna ser despojado de sus mgresos y propiendades 0 pnvado de sus dercchos sm previo aviso del tribunal Existen otros requisitos legales Silo dcsea pucde usted consul tar a un abogado immediatamente SI no conoce a un abogado pucde lIamar a una de las oficmas de asistencia legal que aparecen en la guia telefornca SI desea responder a la demanda por su cuenta al rrusmo tiernpo en que presenta su respucsta ante el trrbunal debera usted enviar por correo 0 entregar una copra de su respuesta a la persona dcnorrunada abajo como "Plainuff/Plamuff's Attorney (Demandate 0 Abogado del Demanadante) Il\1PORTANT Des poursunes judicianes ont ete entrepnses contre vous Vous avez (20) jours consecuufs a partir de la date de I assignauon de cette cuauon pour deposer une reponse ecnte ala plamre ci-jomte aupres de cc Tribunal Un simple coup de telephone est msuffisant pour vous proteger vous etes oblige de deposer votre reponse escnte avec mention du nurnero de dossier CI dessus et du nom des parties nommees ICI Sl vous souhanez que Ie Tribunal cntende votre cause SI vous ne deposez pas votre reponse ecnte dans Ie relai requis vous nsquez de perdre la cause ams: que votre salaire votre argent et vos biens peuvent etre SaISIS par la suite sans aucun preavis ulterieur du Tribunal II y a d autres obhgauons jundiques el vous pouvez requenr les services immediats dun avocat SI vous ne connaissez pas d'avocat vous poumez telephoner a un service de reference d avocats ou a un bureau d assistance jundique (figurant a.l'annuaire de telephones) SI VOllS choisissez de deposer vous memo une reponse ecrue II vous faudra egalement en me me temps que ceue forrnahte faire parvernr ou expedier une copie au carbone ou une photocopie de votre reponse ecnte au "Plamuff/Plamtiff's Attorney (Plaignant ou a son avocat) nomme CI dessous MARCADIS SINGER P A 5104 South Westshore Blvd Tampa Flonda 33611 (813)288 1881 Telecopier (813)2889678
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