Court filing
Exhibit 10 — Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Dkt. 123.10)
Record facts
| Court | U.S. District Court for the District of Puerto Rico |
|---|---|
| Filed | 2024-07-01 |
U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 123-10 · 2024-07-01 · Docket on CourtListener
Summary
Exhibit 10, filed July 1, 2024 as Doc. 123-10 in Oto Analytics, LLC v. Benworth Capital Partners PR LLC, No. 3:23-cv-01034-GMM, in the U.S. District Court for the District of Puerto Rico, is a transcript of a January 29, 2014 hearing in Total Bank v. Bernardo Enrique Navarro, Case No. 12-12858 CA 27, in the Circuit Court of the 11th Judicial Circuit in and for Miami-Dade County, Florida. Before Judge Rosa Rodriguez, counsel for non-party garnishee Benworth Capital Partners, LLC argues its motion for protective order against a corporate representative subpoena, objecting to discovery into Benworth's finances and other employees' pay. Total Bank's counsel responds that Benworth is owned and controlled by the judgment debtor and cites Navarro's deposition testimony that he is paid by one check at year end. The transcript closes with the court allowing 30 days for the deposition.
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Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page1of25 EXHIBIT 10 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 2of 25 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIRCUIT COURT DIVISION CASE NO. 12-12858 CA 27 TOTAL BANK, a Florida corporation, Plaintiff, vs. BERNARDO ENRIQUE NAVARRO, an individual, Defendant. The above-entitled cause came on for hearing before the Honorable Rosa Rodriguez, Judge of the above-styled court, at the Dade County Courthouse, Miami, Florida, on the 29th day of January, 2014, commencing at 11:30 a.m. EDMEE PRATS COURT REPORTING SERVICES EXHIBIT (305) 324-5431 i *C ” Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 3of 25 APPEARANCES On behalf of the Plaintiff: SAPURSTEIN & BLOCH, P.A. 9700 South Dixie Highway Suite 1000 Miami, Florida 33156 BY: BURT SAPURSTEIN, ESQUIRE On behalf of Benworth: LAW OFFICE OF ALEXIS GONZALEZ, P.A. 3162 Commodore Plaza, Suite 3-E Coconut Grove, Florida 33133 BY: LAZARO VAZQUEZ, ESQUIRE EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 4of25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Thereupon, the following proceedings were had:) THE COURT: Total Bank versus Navarro, is anybody here for this? MR. VAZQUEZ: Yes, Your Honor. Lazaro Vazquez on behalf of the Garnishee, Benworth Capital Partners, LLC. MR. SAPURSTEIN: Burt Sapurstein on behalf of Plaintiff, Total Bank. Good morning, Your Honor. MR. VAZQUEZ: We have a court reporter present here today. THE COURT: Great. Please announce your appearances. MR. VAZQUEZ: Lazaro Vazquez on behalf of Garnishee, Non-Party Benworth Capital Partners, LLC. MR. SAPURSTEIN: And Burt Sapurstein on behalf of Total Bank, the Plaintiff. MR. VAZQUEZ: Your Honor, before I begin my argument, just two things. If I may approach with a copy of the motion, I have a hard copy for the court. THE COURT: Great. I have a copy. [It's NON-PARTY Benworth Capital Partners, LLC's EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 5of25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Motion for Protective Order and Objections to Corporate Representative Subpoena... just to make sure that is the same copy. MR. VAZQUEZ: Yes, Your Honor, that is what I just handed to the court. THE COURT: I have it. MR. VAZQUEZ: Your Honor, before I get into the merits of the actual argument, and I just want to make sure that the court is aware that the garnishee's position is, it's not objecting to any discovery being sought in execution of the final judgment against the individual Defendant who is Bernardo Enrique Navarro. Our objections are actually as to particular points raised in the Notice of Deposition Duces Tecum. First of all, Benworth is not a party, it is a garnishee, and as a matter of fact, Benworth isa competitor of Total Bank; Benworth issues loans just like Total Bank issues loans, so they're both in the same industry. I also want to bring up to the court's attention that the court has not ordered Mr. Navarro to file a fact information sheet. I have a copy here of the Final Judgment, EDMBE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 6of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Default Final Judgment, which doesn't say that the individual Defendant is ordered to file a fact information sheet. Now, the issue is that they're seeking the discovery as to the finances of Benworth, the actual corporation and as to the finance of other employees at Benworth, and that's the extent of our objection. If Your Honor goes to Page 2 of our motion, it says that Benworth is -- excuse me, that they're asking -- examination topic number two, they're asking Benworth to produce a representative regarding the payments made to other employees of the garnishee for the years 2012 to 2013. They're also seeking any person reporting self-employment income through garnishee for the years 2012 through 2013, and they're seeking Benworth produce a representative regarding the financial records of garnishee for the years 2012 through 2013. Our entire position has been, they're obviously entitled to seek discovery of the -- any payments that are going towards Bernardo Enrique Navarro, but everything else EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 7 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 is off limits because otherwise it turns into a fishing expedition. THE COURT: Let me interrupt. MR. VAZQUEZ: Yes, THE COURT: The Defendant is Navarro, as an individual only? MR. VAZQUEZ: Yes, Your Honor. THE COURT: And the judgement is as to Navarro as an individual only? MR. VAZQUEZ: Yes, Your Honor. THE COURT: I just want to make sure. Go ahead. MR. VAZQUEZ: And going forward -- I have a copy of the -- THE COURT: I'm sorry to interrupt you again. You don't have an objection to any of this as it pertains to Mr. Navarro individually, your objection is as to other parties; is that correct? MR. VAZQUEZ: Yes, Your Honor. THE COURT: Okay. So the employees namely are the only other parties that there's an interest in? MR. VAZQUEZ: Yes. THE COURT: Okay. EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 8 of 25 10 Ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. VAZQUEZ: Yes, Your Honor. THE COURT: Okay. MR. VAZQUEZ: And I have here about seven or so employees that are employed by Benworth. THE COURT: Okay. Let me just cut to the chase here -- I'll get back to you. Mr. Sapurstein, that has a certain visceral appeal right away, that if he's the garnishee and if he's an individual. So explain. MR. SAPURSTEIN: Happy to, Your Honor. THE COURT: Okay. MR. SAPURSTEIN: If I may, I'd like to show the court the Florida Department of State, Division of Corporation information on Benworth. THE COURT: Okay. MR. SAPURSTEIN: So that Your Honor can see that the manager of Benworth is Mr. Navarro. I also have the deposition in aid of execution of Mr. Navarro that we took a little over a year ago, Your Honor. This is the original, if I may. And, Your Honor, this is not a situation EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document 123-10 Filed 07/01/24 Page 9of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 where we're dealing with a third party unrelated to our debtor, this is a corporation owned and controlled by our debtor. In the deposition, Your Honor, Page 9, Line 18, I ask Mr. Navarro: "Are you employed, sir?" "Yes." "By whom?" "Benworth Capital Partners." "And what position do you hold?" "President." Well, actually he's the manager, Your Honor. THE COURT: Okay. MR. SAPURSTEIN: And so I said: "Are you paid a salary?" And he said: "No." I said: "How are you paid?" And his answer was, moving to Page 10. "Year end, I get paid at the end of the year." And I said: "Do you get one check?" He said: "Yes." "And did you receive a check in December EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 10 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of '12?" "No." "Why not?" "My accountant hasn't done it yet." "Are you expecting a check in a particular amount?" "T don't know." "You don't know if you're expecting to get paid?" "I don't know when I'm expecting it." "How much is the check going to be?" "IT don't know.” So we go on to Page 12, and I'm asking him how do you explain how much money you're going to get, you're the president? I said: "Are you also the owner of Benworth?" "T'm an owner." "Are you a shareholder?" "Yes." Then he says his percentage of the shares is nine percent and his wife's percentage is 91 percent, Your Honor. So when we start talking about other employees specifically, I want to know about EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 11 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 his wife who he said -- moving to Page 13, Your Honor: "Is your wife employed by Benworth?" "Yes." "What does she do?" "She helps with the office.” "She's an office worker?" "Yes." "And does she receive a salary?" "Yes." "How much does your wife receive?" And he says that he has no idea. THE COURT: Let me ask you, are you seeking only Mr. Navarro and Mrs. Navarro or are there others? MR. SAPURSTEIN: Well, in his deposition he says he has two or three -- THE COURT: I'll tet you respond. MR. SAPURSTEIN: He says he has two or three other employees, Your Honor. I don't care about the other unrelated employees. THE COURT: Okay. So you're interested in the wife? MR. SAPURSTEIN: I'm interested in the wife. EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 10 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 12 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 THE COURT: Okay. MR. SAPURSTEIN: I'm interested in Mr. Navarro. It doesn't sound to me like somebody who says he gets one check at the end of the year, is the manager of the LLC, is the member of the LLC and suddenly say, "I don't know how much money I'm getting,” et cetera et cetera. THE COURT: I didn't know what this business -- I just didn't know the scenario. MR. SAPURSTEIN: No, of course not. THE COURT: I didn't know any of these facts. MR. SAPURSTEIN: He does go on to say that his wife gets paid $70,000 on Page 19 of the, of the deposition. And I would also point out that he was subpoenaed to bring his tax return and he brought only two pages and never brought the schedules including the Kl which would tell us the theoretically how much he earned from Benworth. So there's that issue as well, Your Honor. THE COURT: I understand. MR. SAPURSTEIN: Thank you. EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 13 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 THE COURT: Thank you. Okay. Got the picture somewhat. Let me hear from you again. MR. VAZQUEZ: Just briefly, Your Honor. Again, it's very important to note that Benworth is a direct competitor of Total Bank so there -- if you take a look at their specific request, and I attached a copy of the Notice of Deposition. THE COURT: I have it here. MR. VAZQUEZ: It's not requesting what he's saying he wants here today in court, it's actually very, very ambiguous. THE COURT: Where are you reading? I have Page 1 or -- where -- MR. VAZQUEZ: Exhibit A. THE COURT: Hold on. Number 1 -- you mean you're going to be asking about payments to him or just like, you know, like, when he was employed and how much he's been paid? . MR. VAZQUEZ: I don't have an objection to Number 1, Your Honor. THE COURT: Okay. Number 2 is going to be only other employees, but that's really going to be just EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 14 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 to the wife, correct, Mr. Sapurstein? MR. SAPURSTERIN: Yes, Your Honor. THE COURT: Wife only? MR. SAPURSTEIN: Yes. THE COURT: And then 3, any person reporting self-employment income -- I don't understand that. MR. SAPURSTEIN: Well, Your Honor, again, they didn’t bring their entire tax return, notwithstanding the fact that they were subpoenaed to do so. So, we're not sure whether he pays himself a 1099 and he does self-employment tax, or whether he get a W-2 from Benworth. THE COURT: Okay. MR. SAPURSTEIN: We'd like to see the W-2's of both Mr. Navarro and his spouse so we can determine if they're paid. He claims he gets one check at the end of the year. We'd like to see the payroll, we'd like to see if that's correct. THE COURT: Okay. MR. SAPURSTEIN: And they can redact it as to any other employee, other than Mr. Navarro and his spouse. EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 15 of 25 10 11 12 13 14 15 16 17 18 19 20 2i 22 23 24 25 14 THE COURT: So basically you want the W-2, any payroll records or documentation reflecting payments to Mr. and Mrs., whether they're as employees or 1099's or whatever. MR. SAPURSTEIN: Exactly, Your Honor, that's correct. THE COURT: Okay, I understand. And then financial records of the garnishee for the years 2012 and 2013. MR. VAZQUEZ: That's overly ambiguous, Your Honor. THE COURT: Hold on. MR. VAZQUEZ: That's our issue. MR. SAPURSTEIN: Again, Your Honor, since Mr. Navarro is the member/owner of the company, along with his wife, they appear to own 100 percent of the company, we'd like to see the balance sheet, we'd like to see the assets, we'd like to see what monies are being earned by that company because that bares directly on the ability we believe of Mr. Navarro to pay this judgment. THE COURT: Okay. I understand. Let me hear -- let's start with two. This goes to the wife considering that she EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 16 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 owns 91 percent. MR. VAZQUEZ: Your Honor, just cutting to the chase. The bottom line is what he's requesting is.... he wants the wife's information. The wife has a private financial interest in this information that's separate and apart from her husband. The judgement was entered personally against Bernardo Enrique Navarro, it was not entered against his wife, that's the whole reason why we're objecting today. I feel that the wife's private financial information is off limits as well and I have case law to support that. They haven't shown -- there has to be some kind of good faith predicate to show that there's something going on where it would alert them to the fact that they have to have discovery as to this person. THE COURT: Let me see your case. MR. VAZQUEZ: Yes. THE COURT: Let me see it. And then really four goes hand in hand because that's related to the wife also. In light of Mr. Navarro seeming to be in control of the company but with the wife EDMEER PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 17 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 actually owning the stock, you know, I understand the concern. MR. SAPURSTEIN: Your Honor, also in the deposition, I said: "What does your wife do, she has three children at the time six and under?" He said: "She works from the home." I said: "Well, what does she do? And his answer was: "Well everything, she washes the floor, she types." This is the response I got. THE COURT: At the business? MR. SAPURSTEIN: Yes, notwithstanding the fact that she's allegedly the 91 percent owner of the company. THE COURT: Give those to the bailiff, please. Let me see the cases that you have. So you've given me this Rappaport case, and in this case they were just going after discovery of the wife, there was no company in the middle like we have here. MR. VAZQUEZ: Correct, Your Honor. THE COURT: I'm just glancing at it, so I'm going to rely on you if I've EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 18 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1? misapprehended it. MR. VAZQUEZ: I'm sorry, Your Honor. If I could direct the court to this one particular case out of the Third D.C.A. THE COURT: Yes. MR. VAZQUEZ: It's a law firm -- you have the copy in front of Your Honor. THE COURT: Yes. MR. VAZQUEZ: It's Pyszka Kessler Massey. It's the Law Firm's move for a protective order in a dissolution of marriage proceeding to limit discovery of financial documents by non-equity partner's wife. This is the same scenario, where the wife is a partner in Benworth and she has no stake in this judgment, the judgement is entered against her husband, and now they're trying to backdoor in and reach the wife, but they haven't laid that predicate. THE COURT: Well, they're not really trying to reach the wife, from what I understand, they're trying to reach his interest in this Benworth company and whether any of his interests in that or assets, either assets, interest in the company or EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 19 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 29 18 income is, I guess, being diverted to the wife. It's not a situation, as I see it, where they're just, you know, going to the wife just because she's the wife. MR. SAPURSTEIN: Exactly. MR. VAZQUEZ: And the court has hit on the point. They're trying to see if he's diverting monies to the wife, but they haven't established anything. There has -- he has to lay some kind of predicate. He took the man's deposition, man referring to Navarro, and Navarro, in full candor, said this is my wife's interest, this is what she does for a living. But that's not a showing to the court that it's sufficient to invade the wife's privacy interest as a partner of Benworth. MR. SAPURSTEIN: Your Honor, it takes a lot of temerity to stand before the court, when your client comes to a deposition and says that he's the nine percent owner, his wife's 91, she gets 70,000, he may or may not get a check, yet the documents with Secretary of State reflect that he's the manager of the company, it's his company. What does she do? EDMEE PRATS COURT REPORTING SERVICES (305} 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 20 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 She washes the floor and types. It's clear that this Defendant is attempting to hide income and assets, and I think it's very reasonable to take a look and see the extent to which that is happening. THE COURT: I've heard enough. I'm going to deny the Motion for Protective Order regarding the wife, you know, matters related to her and this company, given that Benworth -- MR. VAZQUEZ: Benworth Capital Partners. THE COURT: --~ is a competitor, if there's some kind of confidentiality agreement that you all want to include or -- you know, certainly I would, you know, be willing because I understand, but I don't know that any proprietary issues, you know, would come up, but you could consider that. But I think that as to the wife's finances, just as to this one company, his interest in this one company, is not inappropriate. MR. VAZQUEZ: Your Honor, if I could just make a record. THE COURT: Sure. EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 21 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 20 MR. VAZQUEZ: We've cited to the 3rd D.C.A.'sS opinion at 602 So.2d 955, Pyszka, Kessler, Massey, Weldon, Catri, Holton, & Douberley v. Mullin. It's our position that, "Disclosure of information delineating the partners' financial situation unnecessarily violates their privacy rights." And we're relaying on this opinion. And here the order would violate the privacy rights of the wife. The next opinion that we're relying on would be Bradstreet v. Taraschi, it's at 529 So.2d 809. "In a dissolution of marriage action, a third party's financial records may discoverable if an issue arises as to improper financial dealings between the third parties and one of the spouses. However, it is improper to require a third party to disclose financial records which are not relevant to any economic issues in the action. Trial courts must perform a delicate balancing act, an inquiry which is too limited may prevent a spouse from obtaining evidence necessary to show the misconduct alleged, while an overwrought inquiry becomes EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 22 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21 an unfettered fishing expedition." And that's our position here. If the court would allow us to have maybe an evidentiary hearing, we also have case law that says that the showing must be made at an evidentiary hearing as far as demonstrating the need to take a third party deposition and invade their private finances; I don't know if the court would be amenable to that. THE COURT: Well, I've already had a hearing and I've ruled so I'm not sure what you're asking. Now you want an evidentiary hearing? I'm not sure where that fits into this picture. MR. VAZQUEZ: In other words, it’s our position that the case law mandates that the party requesting the discovery has to request an evidentiary hearing and prove to the court and make detailed findings of fact as to whether or not there is something -- some deceit or something devious going on as far as moving the finances between the wife and husband, and it's our position that they have not shown that. BEDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 23 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 22 THE COURT: Well, that's a different issue because I've ruled and you're making that argument after I've given a ruling, so I think you've waived that, as far as I'm concerned. MR. SAPURSTEIN: Your Honor -- THE COURT: So that's my ruling. MR. SAPURSTEIN: Your Honor, from a timing standpoint, how long for them to produce and to appear at a deposition? It's been several months because they requested a special hearing. THE COURT: I don't know. I mean, was it because you wanted to wait for this? MR. VAZQUEZ: Yes, Your Honor. THE COURT: Okay, so -- MR. VAZQUEZ: We'll cooperate. We'll prepare a proposed agreed order -- proposed order based on the court's ruling. THE COURT: I don't know. Within what? A couple of weeks, a week, ten days? I mean, I don't know if you're going to take it up. MR. VAZQUEZ: Twenty days. MR. SAPURSTEIN: Twenty days is fine with me, Your Honor, if they'll produce EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 24 of 25 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 295 23 within 20 days. And how long to appear for a deposition, Your Honor, a corporate representative, to appear for a deposition? Thirty days, an agreed time within 30 days? MR. VAZQUEZ: I don't know whether my client is available or not, but 30 days is -- THE COURT: That sounds more than reasonable. I'll tell you what, let's make it 30 days and if there's some extreme hardship or some problem that -- Mr. Sapurstein is reasonable as far as I know -- no, you've always been pretty reasonable, so I can't imagine that if there's is some legitimate scheduling issue that you wouldn't be able to work it out, but, you know, I'm here in case you can't. MR. SAPURSTEIN: Thank you, Your Honor. THE COURT: Thank you. Nice to see you all. Have a nice day. (Thereupon, at 12:00 the hearing was concluded for the day.) EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431 Case 3:23-cv-01034-GMM Document123-10 Filed 07/01/24 Page 25 of 25 24 CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI~DADE ) I, JOANNE CAUDILL, Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that I reported in shorthand the proceedings in the above-styled cause before the Honorable Rosa Rodriguez at the time and place herein set forth and that the foregoing transcript constitutes a true and complete record thereof. I further certify that I am not an attorney or counsel to any of the parties, nor financially interested in said cause. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official seal this 29th day of January, 2014. JOANNE CAUDILL, COURT REPORTER NOTARY PUBLIC, STATE OF FLORIDA My Commission Expires: EDMEE PRATS COURT REPORTING SERVICES (305) 324-5431
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