2014 Miami Garnishment Hearing Transcript — Total Bank v. Navarro — Exhibit 10 to OTO Analytics Complaint

Record facts

Exhibit 10 to OTO Analytics Complaint, Case No. 3:23-cv-01034-GMM · No. 3:23-cv-01034-GMM · Doc. 1-10 · 2014-01-29 · Docket on CourtListener

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 1 of 25

EXHIBIT 10
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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.

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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

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(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

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 5 of 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,

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 6 of 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

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 7 of 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.

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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

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 9 of 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

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 10 of 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

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Case 3:23-cv-01034-GMM Document 1-10 Filed 01/24/23 Page 11 of 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.

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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.

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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

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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.

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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

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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

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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

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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

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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?

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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.

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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

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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.

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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

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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 Document 1-10 Filed 01/24/23 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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