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Home My WebLink AboutCOURT CASE1' Filing # 94662407 E-Filed 08/23/2019 10:31:05 SCANNED cy stLoF%*t1am*1/ THERESA KRUPA, INDIVIDUAIILY, AND AS ASSIGNEE OF CAROL ANN W�LSON, AS TRUSTEE OF THE C.A., HUNTERiTRUST Plaintiff, V. MANTA RAY CONSTRUCTION, INC., a Dissolved Florida Corporation, land STEVEN DRAKE MARSTON, JR., Individually, Defendant. MANTA RAY CONSTRUCTION, INC., a Dissolved Florida Corporation, and STEVEN DRAKE MARSTON, JR., Individually. Third -Party Pl �i ntiff, V. RESISTO, TRI-BUILT and ALLIED BUILDING PRODUCTS, IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT, IN AND FOR ST. LUCIE COUNTY, FLORIDA CASE NO. 2018-CA-001805 DEFENDANTS/THIRD-PARTY PLAINTIFF'S. MANTA RAY CONSTRUCTION INC AND STEVEN I (DRAKE MARSTON, JR., THIRD -PARTY COMPLAINT COMES NOW, the Defendants/Third-Party Plaintiffs, MANTA RAY CONSTRUCTION, i INC. ("Manta Ray"), and STEVEN DRAKE MARSTON, JR. ("Marston"), by and through its -5- undersigned counsel hereby zles this Third -Party Complaint against Resisto, Tri-Built and Allied Building Products Corporatiop ("Allied") and alleges as follows: I. This is an action for da�inages in excess of $15,000, exclusive of interest, attorneys' fees, and costs. I I 2. At all times relevant herein, Manta Ray was a Florida corporation. 3. Additionally, Marston is alresident of San Antonio, Texas. 4. Resisto, is foreign corporation authorized to and doingbusiness to St. Luce County, Florida. 5. Tri-Built is foreign corporatii n authorized to and doing business in St. Lucie County, Florida. 6. Allied is foreign corporation authorized to and doing business in St. Lucie County, Florida. 7. Venue for this action is proper I St. Lucie County, Florida because among other I g things, the property at issue is located in St. Lucie County and the cause of action stated herein accrued in St. Lucie County. I S. All conditions precedent to this action have been performed, have been waived or excused or otherwise have occurred. 9. DefendantslThird-Party Plaintiffs, Manta Ray and Marston, have retained undersigned counsel and agreed to pay undersigned counsel reasonable attorney's fees for its services. 10. The C. A, Hunter Trust, hereinafter "the' owns the property located at 44 Aqua Ra Drive, Jensen Beach, St. Lucie County, Florida) herein after, "the property" or " the residence.' The residence at the property is one-half a duplex. m 11. Plaintiff, THERESA KRUPA, trustee of the C.A., Hunter Trust ("P at the subject property. 12.On December 10, 2018, P performed by Manta Ray and Marston A." 13.On or about February 27, agreement to perform certain scopes the existing roof and replacing the 14.On or about May 3, 2018, the Plaintiff's property. vidually, and as assignee of Carol Ann Wilson, as is the alleged beneficiary of said Trust and resides filed its Supplemental Complaint alleging that the work construction defects. See Attached as "Exhibit 18, Defendants/Third-Party Plaintiffs entered into an work at the residence, more specifically, the removal of with a metal roof. ird-Party Plaintiffs commenced performance on 15. Defendants/Third-Party Plaintiffs ordered and purchased a "high temp" underlayment from Allied to perform its scope of work on the subject property. 16. The underlayment was ultimately delivered and installed on the roof. Shortly after said underlayment was installed a rainstorm passed through in which the underlayment failed allowing for water intrusion into the Plaintiffs residence and allegedly causing damage to the property and its contents. 1 $ 17. Unbeknownst to the Defendants/Third-Party Plaintiffs and later discovered, the underlayment delivered and subsequently installed on the subject property was not the "high temp" underlayment that Defendants./Third-Party Plaintiffs ordered from Allied. 18. Additionally, the failed underlayment that was delivered to and first installed on the Plaintiff's residence is a product manufactured by Resisto and/or Tri-Built. -7- 19. Plaintiff has asserted claims for Breach o£I Contract and Negligence against Manta Ray and Marston for the damages resulting from the failed underlayment. I 20. Defendants/Third-Pa'� y Plaintiffs deny that they are liable to the Plaintiff for any of her alleged claims. Given that Defendants/Third-Party Plaintiffs purchased underlayment from Allied, that Allied ordered and delivered the incorrect underlayment to the property, that the underlayment delivered and ultimately installed was defective, and that the defective underlayment product I ym was a p o manufactured by Resisto and/or Tri-Built, to the extent Defendants/Third-Party Plaintiffs are liable to pay any damages to the Plaintli ff., Defendants/Third-Party Plaintiffs are entitled to recover such damages from the party(ies) who caused such damages. (Against Resisto) 21. Defendants/Third-Party Plaintiffs re -alleges and incorporates by reference the general allegations in paragraphs 1-20 as fully set forth herein. 22. This is an action for common' law indemnity against Resisto. 23. Resisto manufactures for retail sale, to the public at large, underlayment for roofs. 24. Defendants/Third-Party Plaintiffs purchased a "high temp" underlayment, however the underlayment ultimately delivered to and installed on the subject property failed and allowed for water instruction and caused damage to the subject property and its contents. The defective underlayment is a product manufactured�by Resisto. 25. Any liability that Manta flay and/or Marston have to the Plaintiff, or any other party, relating to Resisto's product, more specifically, the defective underlayment installed on the subject property is strictly constructive, technical,, vicarious or derivative, and results from Resisto's negligent acts, breaches of warranties, or ariy other wrongful conduct. I -8 I I I I 26. Manta Ray and Marston are damages. 27. Resisto is wholly at fault for incurred and will incur in the future re subject property. 28. Defendants/Third-Party Plainti Resisto as a matter of law. WHEREFORE, Defendants/Third damages, attorneys' fees, costs, pre j I just and proper. I fault or active negligence in causing the Plaintiffs damages the Defendants/Third-Party Plaintiffs have to Resisto's defective underlayment installed on the are entitled to recover its attorneys' fees and costs from Party Plaintiffs demand judgment against Resisto for ginent interest and for such other relief this Court deerns I(Against Resisto) 29. Defendants/Third-Party Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if frilly set forth herein. 30. After the purchase and installment of the underlayment, the underlayment failed, allowing rain to infiltrate the home of the Ilaintiff. 31. Resisto placed the defective underlayment in the stream of commerce subjecting Resisto to Strict Liability in tort. 32. Resisto's product failed, causing damage to the interior of Plaintiffs residence and contents. 33. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Resisto as a matter of law. -9- i I WHEREFORE, Defendants/Third-Party Plaintiffs demand judgment against Resisto for damages, attorneys' fees, costs, pre judgment interest and for such other relief this Court deems just and proper. COUNT III — NEGLIGENCE (Against Resisto) 34. Defendants/Third-Party', Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fWly set forth herein. 35. Resisto and/or Resisto's agents negligently manufactured and inspected the underlapnent installed at the subject property. 36. After purchasing said underlayment, the Defendants/Third-Parry Plaintiffs installed said underlayment to the Plaintiffs roof. Due to the manufacturer defect the underlayment failed and caused damage to the interior of the Plaintiffs residence and contents. 37. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Resisto as a matter of law. WHEREFORE, Defendants/Third-Party Plaintiffs demand judgment against Resisto for damages, attorneys' fees, costs, pre -judgment interest and for such other relief this Court deems just and proper. I OF IM] (Resisto) 38. Defendants/Third-Party Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully set forth herein. 39. Defendants/Third-Party Plaintiffs ,ordered a "high temp" underlayment from Allied. 40. The incorrect underlayment was � then ordered by Allied from the manufacturer and delivered to the Plaintiff s residence. -10- 41. The underlayment delivered to attaches an implied warranty of fitness for was offered for sale. 42. Third -Party Defendant breached product to be manufactured prior to its hitiff's residence was manufactured by Resisto in which purposes of intended use that the roof underlayment implied warranty of fitness by allowing a defective to Defendants/Third-Party Plaintiffs. 43. Defendants/Third-Party Plaintiffs were unaware that the underlayment would fail and leak. 44. Due to the failure of Resisto's 'roduct, damage was caused to the interior of the Plaintiff s residence and contents. 45. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Resisto as a matter of law. WHEREFORE, Defendants/Third-Party Plaintiffs, Manta Ray Construction, Inc. and Steven Drake Marston JR, demand judgment against the Third -Party Defendant, Resisto for damages, costs and prejudgment interest and demands a trial by jury on all issues so triable. (Against Tri-Built) 46. Defendants/Third-Party Plaintiffs re -alleges and incorporates by reference the general allegations in paragraphs 1-20 ,as fully set forth herein. 47. This is an action for common law indemnity against Tri-Built. 48. Tri-Built manufactures for retail sale, to the public at large, underlayment for roofs. 49. Defendants/Third-Party Plaintiffs purchased a "high temp" underlayment, however the underlayment ultimately delivered to and installed on the subject property failed and allowed for water instruction and caused damage to the subject property and its contents. The defective underlayment is a product manufactured by Tri-Built. - 11 - 50. Any liability that relating to Tri-Built's pr subject property is strictly Built's•negligent acts, Brea 51. Manta Ray and M; damages. 52. Tri-Built is wholly at incurred and will incur in the a Ray and/or Marston have to the Plaintiff, or any other party, more specifically, the defective underlayment installed on the Aructive, technical, vicarious o� derivative, and results from Tri- of warranties, or any other wrongful conduct. r n are without fault or active negligence in causing the Plaintiff's II �Iult for the damages the Defendants/Third-Party Plaintiffs have Lure relating to Tri-Built's defective underlayment installed on the subject property. 53. Defendants/Third-Party Plaintiffs are entitled to recover its AIomeys' fees and costs from Tri-Built as a matter of lativ. 1 WHEREFORE, Defendants/Thil d-Party PIaintiffs demand judgment against Tri-Built for damages, attorneys' fees, costs, prejudgment interest and for such other relief this Court deems just and proper. UOUNT VI- STRICT LIABILITY I(Against Tri-Built) 54. Defendants/Third-Party Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully, set forth herein. 55. After the purchase and instalimentlof the underlayment, the underlayment failed, allowing �I rain to infiltrate the home of the Plaintiff. 56. Tri-Built placed the defective Built to Strict Liability in tort. 57. Tri-Built's product failed, causing contents. 412 - in the stream of commerce subjecting the Tri- to the interior of Plaintiffs residence and 58. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Tri-Built as a matter of law. WHEREFORE, Defendants/Third-Pahy Plaintiffs demand judgment against Tri-Built for damages, attorneys' fees, costs, pre judgment interest and for such other relief this Court deems just and proper. Vy111\Il Y 11-II4z""%JnI'N%-IZ (Against Tri-Built) 59. Defendants/Third-Party Plaintilffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully seti forth herein. 60. Tri-Built and/or Tri-Built'sI agents negligently manufactured and inspected the underlayment installed at the subject I property. 61. After purchasing said underlayment, the Defendants/Third-Party Plaintiffs installed said I underlayment to the Plaintiffs roof Due to the manufacturer defect, the underlayment failed and caused damage to the interior of the Plaintiffs residence and contents. 62. Defendants/Third-Party P I intiffs are entitled to recover its attorneys' fees and costs from Tri-Built as a matter of law. I WHEREFORE, Defend nts/Third-Party Plaintiffs demand judgment against Resisto for damages, attorneys' fees, costs,lpre judgment interest and for such other relief this Court deems just and proper. COUNT YIII BREACH OF IMPLIED WARRANTY (Against Tri-Built) 63. Defendants/Third-Party Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully set forth herein. 64. Defendants/Third-Party Plaintiffs ordered a "high temp" underlayment from Allied. -13- 65. The incorrect underlayment was then ordered by delivered to the Plaintiff's re'si 66. The underlayment delivered to Plaintiffs residence which attaches an implied warranty of fitness for the underlayment was offered for from the manufacturer and manufactured by Tri-Built in of intended use that the roof 67. Tri-Built breached this'implied warranty of fitness by allowing a defective product to be manufactured prior to its sale to Defendants/Third-Party Plaintiffs', 68. Defendants/Third-Party Plaintiffs were unaware that the underlayment would fail and leak. 69. Due to the failure of Tri-BI ilt's r I p oduct, damage was caused to the interior of the Plaintiffs residence and contents. 70. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Resisto as a matter of law. I WHEREFORE, DefendantslThird-Party Plaintiffs, Manta Ray Construction, Inc. and Steven Drake Marston JR u demandlid ent against i gm g inst the Thud -Party) Defendant, Tri-Built for damages, costs and prejudgment interest and demands a trial by jury on all issues so triable. COUNT IX COMMON LAW INDEMNITY., I(Against Allied) 71. Defendants/Third-Party Plaintiffs re -alleges and incorporates by reference the general allegations in paragraphs 1-20 as fully set forth herein. 72. This is an action for common law indemnity against Allied. 73. Allied is a distributor who sells 'roofing, siding, waterproofing and other construction supplies to residential and commercial building contractors. I -14- 'I I, 'I 74. Defendants/Third-Party Plaintiffs Allied, however the underlayment ul failed and allowed for water instruction 75. Any liability that Manta Ray relating to Allied's error and product it on the subject property, is strictly Allied's negligent acts, breaches of 76. Manta Ray and Marston are damages. and purchased a "high temp" underlayment from delivered to and installed on the subject property caused damage to the subject property and its contents. )r .Marston have to the Plaintiff, or any other party, more specifically the defective underlayment installed ive, technical, vicarious or derivative, and results from ies, or any other wrongful conduct. at fault or active negligence in causing the Plaintiffs 77. Allied is wholly at fault fort the damages the Defendants/Third-Party Plaintiffs have incurred and will incur in the future relating to Allied's error and product installed on the subject property. 78. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Allied as a matter of law. WHEREFORE, Defendan'ts/Third-Party Plaintiffs demand judgment against Allied Building Products, Corporation for damages, attorneys' fees, costs, pre -judgment interest and for such other relief this Court deems just and proper. COUNT X- STRICT LIABILITY (Against Allied) 79. Defendants/Third-Party' Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully set forth herein. 80. After the purchase and installment of the underlayment, the underlayment failed, allowing rain to infiltrate the home of the Plaintiff. -15- 81. Allied erroneously ordered the incorrect underlayment and placed the defective underlayment in the stream of commerce subjecting the Allied to Strict Liability in tort. I 82. Allied s error resulteId in the incorrect, as well as defective, underlayment to be delivered and installed to the subject I-operty, causing damage to the interior of Plaintif fs rff's residence and contents. 83. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Allied as a matter of law. WHEREFORE, Defend) nts/Third-Party Plaintiffs demand judgment against Allied Building Products, Corporation for darnages, attorneys' fees, costs, pre judgment interest and for such other relief this Court deem I just and proper. I x ,na — i�rJvL1�i (Against Allied) 84, Defendants/Third-Party Plaintiffs re -allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully spt forth herein. 85. Allied and/or Allied's agents'negligently ordered and delivered the defective underlayment installed at the subject property. 86. After delivery by Allied of I the incorrect underlayment, the Defendants/Third-Party Plaintiffs installed said underlayment to the Plaintiffs roof. Due to the manufacturer defect, the underlayment failed and caused damag6 to the interior of the Plaintiff's residence and contents. 87. Defendants/Third-Party Plaintiffs are entitled to recover its attorneys' fees and costs from Allied as a matter of law. WHEREFORE, Defendants/Third-Party Plaintiffs demand judgment against Allied Building Products, Corp. for damages, other relief this Court deems just and ' fees, costs, pre judgment interest and for such -16- Allied) 88. Defendants/Third-Party Plaintiffs e-allege and incorporate by reference allegations in paragraphs 1 through 20 as if fully set forth herein. 89. Defendants/Third-Party Plaintiffs) ordered a "high temp" underlayment from Allied. 90. The incorrect underlayment was then ordered by Allied and delivered to the Plaintiff's residence. 91. The underlayment delivered attaches an implied warranty of fitness for the purposes of intended use that the roof underlaymen�t was offered for sale. 92. Allied breached this implied underlayment which resulted in a c installed by Defendants/Third-Party 93. Defendants/Third-Party Pla. underlayment it ordered and that sai 94. Due to the failure of the und< residence and contents. 95. Defendants/Third-Party Resisto as a matter of law. ty of fitness by erroneously ordering the incorrect product to be delivered to Plaintiffs residence and ffs were unaware that the underlayment was not the underlayment would fail and leak. layment, damage was caused to the interior of the Plaintiff- s ffs are entitled to recover its attorneys' fees and costs from WHEREFORE, Defendants/Third-Party Plaintiffs, Manta Ray Construction, Inc. and Steven Drake Marston JR, demand jud I lent against the Third -Party Defendant, Allied Building Products Corporation for damages, costs and prejudgment interest and demands a trial by jury on all issues so triable. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] -17- CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Florida Courts E-Filing Portal and/or email, unless otherwise indicated, to the parties on the attached service list attached, and to all parties who may be listed for service via the E-Filing Portal but of whom the undersigned 11 as not received service information, on jAugust 23, 2019. CHARTWELL LAW Attot-zeys for Defendant 1191 East Newport Center Drive Penthouse Suite H Deerfield Bch, FL 33442 Tel: (754) 227-7995 Fax: (754) 212-4170 Designated emails, per F1a.R.Jud.Admin.2.516 Primary: molmsted@chartwelllaw.com, dortiz@chartwelllaw.com Secondary: jwelch@chartwelllaw.com By: Is/Matthew Olmsted Matthew Olmsted, Esq Florida Bar No.: 36306 Doric Ortiz, Esq Florida Bar No.: 10724 SERVICE LIST I Attorney for Plaintiff I Leif J. Grazi, Esq. Grazi & Gianino, LLP I 217 East Ocean Boulevard Stuart, FL 34994 Lgrazi@gglawyers.com I II I Exhibit "A" Filing # 81870508 E-Filed I2/10/2018 01:11:09 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL DISTRICT IN AND FOR ST. LUCIE COUNTY, FL THERESA KRUPA, individually, and as Assignee of Carol Ann Wilson, as Trustee of the C. A, Hunter Trust, � CASE NO.: 2018-CA-00180 V. MANTA RAY CONSTRUCTON, INC., A Dissolved Florida Corporation, and and STEVEN DRAKE MARSTON, JR., Individually, Defendants. I 1 COMES NOW, the Plaintiff, THERESA KRUPA, individually and as Assignee of Carol Ann Wilson, as Trustee of the C. A, Hunter Trust (hereinafter collectively "KRUPA"). by and through undersigned counsel, Id hereby files this Supplemental Complaint against the Defendants, MANTA RAY CONSTRUCI'ON,1NC., (hereinafter "MANTA RAY") and STEVEN DRAKE MARSTON, JR. Iihereinafter "MARSTON"), and states as follows: 1. This is an action for damages in excess of $15,000.00. 2. The C. A, Hunter Trust,lhereinafter "the Trust," owns the property located at 44 Aqua Ra Drive, Jensen Beach, St. Lucie County, Florida 34957, hereinafter "the property" or "the home." The residence at the property is one-half of a duplex. 3. KRUPA is a beneficiary o the Trust, and pursuant to a Lease Agreement with the Trust, was a tenant at the property on the dates referenced in this action. Krupa v. Manta Ray Construction Case No.: 2018-CA-001805 4. Carol Ann Wilson, as Tr � tee of the C.A. Hunter Trust, assigned all claims of damages related to the Contract betweei the C.A. Hunter Trust and the Defendant, to KRUPA, through an Assignment dated Septemb Ir 24, 2018, herein attached as Exhibit "A." 5. The Defendant MANTA RAY is a dissolved Florida corporation with its last principal place of business in St. Luci (County, Florida. 6. The Defendant MARSTON was the last known Director and Officer of MANTA RAY, which was administratively dissolved by the Department of State on September 22 2017 prior to the execution of the Contract by MARSTON that gives rise to the pending claims, and as a result, MARSTON is personally liable to the Plaintiff for the debts of the corporation, pursuant to Section 607.1421(4), Florida St Itutes. 7. On or about Febru I y 27, 2018, the Defendant MANTA RAY and the Trust entered into a written Contract, a lopy of which is attached to the Assignment (Exhibit A), herein "the Contract." 8. Pursuant to the Contract, MANTA RAY was to remove the existing roof and install a new metal roof at the home located at the property as more particularly described in the Contract. The Contract provided for written warranties. 9. On or about Maly 3, 2018, MANTA RAY commenced performance of the I Contract by sending a crew to the home, who began to install the new roof, 10. At the same time as the receipt of the Proposal, MANTA RAY provided an "Overview of the re -roof process" (attached hereto as Exhibit `B"), which states: "MRCR shall have management known by the contractor and homeowner on -site always." In fact, no i I 2 i i Krupa v. Manta Ray Cor Case No.: 2018-CA-001 management was present at any time during any of the work that was done pursuant to the Contract. 11. Shortly afters removing the existing roof, MANTA RAY's crew installed "peel and stick" underlayment to the plywood on the roof in anticipation of installing the roof as described in the Contract. I 12. After installing he underlayment, the MANTA RAY crew Ieft the property. 13. KRUPA became aware of a coming wind and rainstorm, and contacted MANTA RAY, inquiring what needed to be done to protect against water intrusion. A representative of MANTA RAY came by to pick up a check, looked up at the underlayment, and advised KRUPA that the "peel and stick" underlayment was sufficient to stop water intrusion and nothing needed to be done to protect the home. 14, The following day, i wind and rainstorm occurred, and the underlayment failed, allowing rain to saturate the plywo Id and infiltrate the home, destroying the interior of the home, including flooring, cabinets, drywall, and other fixtures, as well as the personal property of KRUPA, the tenant residing in the home. 15. On or about May 14, Io 18, MANTA RAY was notified that the roof leaked during the wind and rainstorm, and the leak caused extensive damage to the interior of the residence. MANTA RAY inspected thl roof and advised KRUPA that the adhesive failed causing the water intrusion. 16, After the roof dried out, underlayment by applying felt paper ANTA RAY attempted to correct the failed fasteners over the top of the failed underlayment. Krupa v. Manta Ray Construction Case No.: 2018-CA-001805 17. On or about July 2, 2018,) MANTA RAY completed the installation of the new roof, and requested payment of the last draw of the payment schedule. 18. Because of concerns abolut the integrity of the roof, and the method employed by MANTA RAY to correct the failed underlayment, the Trust hired Jack Brown & Associates, an independent roofing consultant, to inspect the roof after completion. 19. On or about July 25, 2018, the licensed roofing inspector inspected the roof, and determined that there were sigivficant deficiencies regarding the installation of the new roof, and the method employed by MANTA RAY to correct the failed underlayment. 20. The inspection of thelroof revealed that the method employed by MANTA RAY to correct the failed underlayment �as improper, and did not properly correct the problem. MANTA RAY's method of conecLn amounts to poor workmanship, voids the underlayment manufacturer's warranty, and sho I ens, the life of the roof. To properly correct the failed underlayment, MANTA RAY w I required to remove the failed underlayment, replace waterlogged plywood, and apply new underlayment before installing the metal roof, rather than the material used by MANTA i Y. 21. On July 30, 2018, the Trust caused a Notice of Construction Defects to be sent to MANTA RAY, as required by Chapter 558, Florida Statutes, a copy of which is attached hereto as Exhibit "C," and attached to that Demand/Notice was a copy of the report of Jack Brown & Associates. 22. MANTA RAY failed to return to the property to inspect and/or repair the construction deficiencies after being notified. Krupa v. Manta Ray Construction ' p y Case No.: 2018-CA-001305 I 23. As a result if MANTA RAY disregarding the "558 Notice," and failing to repair the construction deficiencies of the new roof, the Trust will be compelled to hire another roofing contractor to correct the construction deficiencies which will require removing the new roof, making repairs, and installing another new roof 24. In addition to the cost of correcting the construction deficiencies, as well as the failure to provide the warranties pursuant to the Contract, the Trust has suffered damages relating to the damage to the interior of the home, loss of personal property, and Ioss of rent, which have been assigned to KRUPKA, individually, pursuant to Exhibit A. herein. 25. The allegations of paragraphs 1 through 24 are re -alleged as though fully set forth 26. The failure to comply installed was deficient, and 27. The failure to provide the Contract by the Defendant. Building Codes, and the manner in which the roof was a breach of the Defendant's contractual obligation, as required by the Contract constituted a breach of 28. On or about November 17, 2018, there was a rainstorm and as a result, there were four (4) areas within the residence where water infiltrated, the premises, constituting a breach of the contractual obligation of the Defendant to construct a watertight roof that would not leak. 29. The Trustee will incur the II ost of repairing or replacing the roof installed by the Defendant. WHEREFORE, KRUPA, as assignee of the Trust, would demand Judgment for damages, interest, court costs and such other relieflas may be appropriate. 5 i Krupa v. Manta Ray Construction Case No.: 2018-CA-001805 30. . The allegations of set forth herein. 31. The Defendants had a did not enter the residence during the 32. KRUPA notified the previously. 33. Although the took no action to protect the pr were insufficient to protect the 34. The failure by the 1 the rainstorm was a breach of t 35. As a proximate car 1, 3, 5, 6, 13, 14 and 28 are re -alleged as though fully to use care in the construction of the roof so that water of the roof. of the anticipated wind and rainstorm, as alleged were advised of the likelihood of the storm, the Defendants or, in the alternative, any actions taken by the Defendants :y from water intrusion. int to make certain that the premises were protected from duty. of the Defendants' breach of their duty, KRUPA, personally, suffered damages. I 36. In addition to the cost of correcting the construction deficiencies as referenced in Count One above, KRUPA, individually, has suffered damages relating to the a. Loss ofuse of the leased property; b. Costs of vacating the property; C. Loss of personal property; d. Loss of employment hours; and e. Loss,of time in overseeing the repairing of the damage to the interior of the residence. 6 Krupa v. Manta Ray Construction Case No.: 2018-CA-001805 I 37. MARTST IN is personally liable to the Plaintiff for the debts of the corporation pursuant to Section 607.1421(4), Florida Statutes. WHEREFORE, KRUPA individually, and as assignee, would request damages against MANTA RAY and MARSTON, together with court costs, and such other relief as may be appropriate. CERTIFICATE OF SERVICE I HEREBY CERTIFY 'that a true and correct copy of the foregoing was furnished by electronic mail to Matthew Olmstead, Esq., Dorie Ortiz, Esq., Chartwell Law, 3275 W. Hillsboro Blvd., Suite 309, Deerfield BeFL 33442, molmsted rLchartwelllaw.com; dortizZebartwelflaw.corn ��one(i-khartsvellfaw.com, this ,e o day of December, 2018. GRAZI & GIANINO, LLP 217 East Ocean Boulevard Post Office Drawer 2846 Stuart, Florida 34995 Tel. (772) 286-0200/Fax (772) 286-4789 By: Z� 5� LE F 3. GkAZI Florida Bar No.: 296041 LaraziQaalawyers.co m Attorneys for Plaintiff Assignor; Carol Ai E. A. Hu Assignee: Theresa I In exchange for the value rece ved,1, Carol Ann Wilson, as Trustee of the E.A. Hunter Trust, owner of the property known as 44 Aqua Ra Drive, Jensen Beach, Florida 34957, hereinafter Assignor, assign to Therelsa Krupa, of 44 Aqua Ra Drive, Jensen Beach, Florida I 34957, as Assignee and assignee's legal representatives and assigns, for her and their use and benefit, any and all sums of moneylnow due or owing to me, and all claims, demands, and cause or causes of action of whatsoever kind and nature, that I have had, now have, or may have against Manta Ray Construction, Inc., and/or Steven D. Marston, of 85 South Las Olas Drive, Jensen Beach, Florida 34957, or any other person or persons, whether jointly or severally, arising out of, or for, any loss, injury or;damage sustained by me in connection with the Proposal/Contract dated February 27, 2018, related to a new roof to be installed at 44 Aqua Ra Drive, Jensen Beach, Florida 34957, a copy of which is attached hereto. This assignment is without recourse, and assignor does not guarantee payment of the claim assigned. Assignor agrees, however, that in the event any payment under the claim is made to assignor, assignor will promptly transmit such payment to assignee. Assignor appoints assignee, assignee's legal representatives and assigns, the attorney of assignor with power to demand and receive satisfaction of the claim assigned, and in the name of assignor; but at assignee's expense, to take whatever legal action may be necessary to enforce the claim. Assignee hereby accepts the assignment. EXHIBIT I' Assi, By; Carol Ann Wilson, as E.A. Hunter Trust Assignor STATE OF FLORIDA COUNTY OF PCiI r of the CW By: �. c� �i • �� Theresa Krupa Assignee .BEFORE ME, the undersigned authority, on this day personally appeared Carol Ann Wilson, as Trustee of the E.A.IHunter Trust, who first being duly sworn, deposes and says that she executed the foregoing instrument and who ��] is personally known to me or f I has produced F- 1,) ►'ypv _S I_I I`ense as identification. WITNESS my hand and official seal on this; day o#' iQ emb�2018. %*�� ti � _ v.0 00TA4 ® tiCfi, •. I a s � NOTAR BLIC .`► My Comm._ dW MY COMMIS SION EXPIRES: ;. No. 64250 t a o �• • T. A� G .•.` ��od STATE OF FLORIDA �1oi; �O F' i0fA`°�� COUNTY O 1LL-j'9n BEFORE ME, the undersigrie+ who first being duly sworn, deposes�a who f I is personally known to rii, t=(a,-=1C�D. Dr'vev I I r c 015.'� WITNESS my hand and offici Y +. M"'.MYCOMMIS, EXPIRES:FflO0W d ThW 81k 341r co,c4 1 c-1 j?,02-S authority, on this day personally appeared Theresa Krupa, d says that she executed the foregoing instrument and or L_Y_j has produced as identification. l seal on thisr"t! day of 2018. 8 GG 064M h6,ml 2 'lGL=1L(lGL=1Li.�'��C•L..I�'�Q.L, - �. NOTARY PUBLIC MY COMMISSION EXPIRES: 11-1.0rd *T February 27, 2018 Carol Ann Wilson 44Aqua Ra Dr Jensen Beach, FL 772-206-1980 Finativel3 ftmail.com CONS y rTION !;Q. Proposal • Tear off existing "single layer" shingle and flat roof system down to substrate. • Remove and replace up to 4 she Ikts worth of rotten plywood if needed. • If additional plywood is needed is shall be billed out at $65.00 per sheet. • Re -nail existing plywood roof deck ck to meet the updated Florida Building code with 8d ringshank nails every 4/6". • Install a layer of Tri Built self : i hering modified high temperature metal underlayment to meet the high velocity wind zone. • Install 26.ga Acrylume 2x2 drip edge to code with 1-1/4" ringshank nails every 6". • Install new Acrylume gooseneck vents and neoprene boots at all plumbing and dryer ventlocations. • Flash in tube skylight as needed for 5V application • Install 2 4ft Acrylume off theiridgevent on the rear plane of the roof. • Install Extreme Metals 5V crimp 26ga. Acrylume metal roof system to code with 1-1/2" woodzac screws every 12" for High Velocity Wind Zone. • At the flat roof on rear of house, install Certainteed 75# base sheet to code with 1-1/4" ringshank nails and 1-1/2" tin -tags. • Install Certainteed "White" modified rubber torch applied to code. • A 4-year workmanship and manufactures warranty will be forwarded upon receipt of.finai payment. • We propose to supply labor and material for: $ 8,500.00 • Terms shall be as stated: 1) 30% upon signing of contract, notice of comrnencement and permit.. �2) 40% due upon tear off and dry -in of roof. 7 5-1 t z(2 low ;3) 30% due upon completion. " If Manta Ray Owner/Agent i L)CcnscO and'nsurcd 85 5 Las Qlas Drjcnsen beach, FL. CCCJ i 30+• O & CE)C1 z59Y9 Phone: (772)-201-83 1 6 manta rayconstruction@gma ii.com I February27 I .Zit$ Carol Ann Wilson 44 Aqua Ra Dr I Jensen Beach, FL 772-206-1980 Manta Ra CONSTRUCTION :i' ..��`t'*;• �;`S"y� ,.'"'.•, yr• .corn • MRCR to follow all OSHA Sa • MRCR shall have manager l • MRCR to procure permit/j�1' with the County of St. Lucie • All roofing and related mate • Driveway to be covered at a Overview of the re -roof process aty practices and regulations as needed. it known by the contractor and homeowner on -site always. specific engineering and pass all required inspections for the re -roof process Wilding Department. ials to be stored on -site at a predetermined area, out of the vjay. areas for protection. • All shrubbery and A/C unit to covered with tarps as needed. • Job to start on a mutually de • MRCR to remove all related date between homeowner and MRCR. debris daily. I • Any work done beyond the scope of this contract will be billed as extra. I I Licensed and Insurecl 85 5 (.-as Alas pr,,Jeneen 5each, FL CCC 133o't90 b C%C 125999 Irhone (772) 20I-831 G GRAZI & GIANING, LLP Attorneys at Law A Partnership of Attorneys Including Professional Association Via Certified Mail Return Receipt I Tracking #7016 3560 0000 5593 2880 & Regular U.S. Mail July 30, 2018 Manta Ray Construction, Inc. Attention: Steven D. Marston 85 S. Las Olas Drive Jensen Beach, FL 34957 Re: E.A. Hunter Trust and Theresa Krupa 44 Aqua Ra Drive I Jensen Beach, FL 34957 217 E. Ocean Boulevard Post Office Drawer 2846 Stuart, Florida 34995-2846 Telephone; (772) 286-0200 Facsimile: (772) 286 4789 Leif J. Grazi, Igrazi(agglawyers.com PeterT. Gianino 1.2,4.4 pgiantno ongglawyers.com Maxine A. Noel mnoel9oglawvers.com Ryan S. 0 razi rgrazOgg lawyers, com 1. Certified by the Florida Supreme Courtin Family Mediation. 2. Cerliried by the Florida Supreme Court in "Ma4on. 3. Cerlifed by the Florida Supreme Court in Ci ttlediation. 4. CertlRsd by the Florida Supreme CourtIn Appelate MedtaGon. NOTICE OF CONSTRUCTION DEFECTS AND OPPORTUNITY TO REPAIR Dear Mr. Marston: Your proposal dated February 27i 20181 with Carol Ann Wilson, as Trustee of the C.A. Hunter Trust, a copy of which is attached, was accepted by my client. The contract called for the installation of a new roof at the above referenced home. Your workers went to the residence; removed the existing shingles tolthe substrate (plywood), and installed Resisto felt on the roof. I am uncertain if the Resisto felt is the same as what was required under the terms of.the contract. Nevertheless, after installing the underlayment, your crew departed from the property. The tenant, Theresa Krupa, inquire'a out the need for a tarp to be placed over the underlayment, but was told that it was self adhesive and would keep out any rain. As you are painfully- aware, the underlayment was not self -adhering, and when a storm came through the area, the underlayment lifted up, causing the plywood substrate to get drenched with water that went through the plywood, and destroyed much of the interior of the home. Ultimately, more than one (1) month later, the plywood dried and your crew then installed the new roof on the residence. However, they did not replace any of the wood that had been saturated with water, which is probably warped, nor did they remove the defective underlayment. Instead, the roof was installed over the damaged wood and the deficient underlayment. After installation, an inspection of the completed roof was performed by Jack Brown & Associates, and a copy of their report is enclosed for your convenience, showing defects in the installation of the roof. This Notice is being sent to you pursuant to the requirements of Section 558, Florida Statutes. Pursuant to §558.004, Florida Statutes, Notice is provided of the defects related to the roof installed at the residence, and demand is hereby made for your return to the property to repair the defective work. FEXHIBIT t July 30, 2018 Page 2 You should recognize the vacating the home for ov damaged items, and the interior of the residence i for the repair of the damp review or repair the roof, notice. You might want decision to you. Please be advised that § rights, but also imposes for inspection at a reaso fail to return to the prop recover the damages sui construction and the dar that might otherwise be my clients, the owner and the tenant, have incurred the costs related to one (1) month, removing the kitchen cabinets, countertops, and other rchase of a new kitchen. The actual cost to correct the damage to the not yet known to us, but we are in the process of acquiring proposals e. In the event that you disregard this Notice, or make no efforts to it pay for the cost of the repairs, suit will be filed with no further place your insurance carrier on notice of this claim, but I leave that .004, Florida Statutes, provides you, as the contractor, with certain nin time constraints. We will make the property available le time within thirty (30) days of your receipt of this letter. If you and/or to respond to this Notice, there will be a lawsuit filed to �d. in that event, you will be held accountable for the defects in -s related to the repairs, together with all other contractual remedies This correspondence will als year warranty for both labor for my client entering into tb remaining balance, but was E allegedly because the home i you at the time you included Should you have retained point out a breach of your contract, which provides for a four (4) A materials. That warranty was an important part of the reason contract. At the conclusion of your work, my client paid the vised that there would be no warranty from any manufacturer, is too close to the ocean, a fact that should have been obvious to iat provision in the contract. Thank you for your anticipated Sincerely, qLfJ razi L3G/dm cc: Clients , please send them a copy of this Notice. response in writing. Lr7 ------------ Mo E—. add too at epiwpware) m uajptt&�jCapo .3 13ACWM W. a✓rr lilac aon et cq mV4 ma pc 11. ic I c cr o &,vy S_ Postmark C3 E❑3 Hare r' "-EIG -a mTo Postage anti - s -13 sent o ha AVII M. a,. pf- -:5 Back I Print 201 SCA001803 - KRUPA, THERESA TR vs. MANTA RAY CONSTRUCTION INC Judge: BRONIS, BARBARA W Case Type: BREACH OF CONTRACT Status: OPEN Case Number: 2018CA001805 Uniform Case Number: 562018CA001805 HC Clerk File Date: 9/27/2018 Status Date: 9/27/2018 SAO Case Number: Total Fees Due: 0.00 Agency: Agency Report #: 7 Custody Location: PARTIES TYPE PLAINTIFF PARTY NAME KRUPA, THERESA TR ATTORNEY I a GRAZI, LEIF JAY (Main Attorney) ; DEFENDANT MANTA RAY CONSTRUCTION INC !� OLMSTED, MATTHEW RYON (Main Attorney) DEFENDANT MARSTON, STEVEN DRAKE JR I OLMSTED, MATTHEW RYON (Main Attorney) DEFENDANT TRI-BUILT MATERIALS GROUP LLC I DEFENDANT RESISTO DEFENDANT ALLIED BUILDING PRODUCTS CORP EVENTS I DATE EVENT JUDGE LOCATION RESULT INo.Events on Case CASE HISTORY 1 CASE NUMBER CHARGE DESCRIPTION CASE STATUS DISPOSITION OUTSTANDING AMOUNT (NEXT EVENT (ALERTS I No Additional Cases FEES I COUNT CODE DESCRIPTION SS�SSMENT PAID AIVED BALANCE PAYMENT PLAN/JUDGMENT DUE DATE OTHER CIVIL FILING Other Civil Filing $400.00 $400.00 $0.00 . $0.00 ' SUMMCIRE SUMMONS CIR CIV 20! 00 $20.00 $0.00 $0.00 CIV CROSS CLAIM CIV CROSS CLAIM $395.00 $395.00 $0.00 $0.00 SUMMCIRE SUMMONS CIR CIV $30.00 $30.00 $0.00 $0.00 RECEIPTS I DATE RECEIPT # PPLIED AMOUNT 9/17/2019 2019000076543 I $30.00 8/26/2019 2019000070454 $395.00 9/28/2018 2018000073876 I $420.00 CASE DOCKETS I SEQ#IMAGE DIN DATE ENTRY 82 3 82, 10/25/2019 RETURN OF SERVICE ON SUMMONS SERVED ( V ) 81 ❑ 3 81 10/3/2019 RETURN OF SERVICE ON SUMMONS SERVED (V ) 80 79 9/16/2019 "RECIPIENTS: MATTHEW OLMSTED - SUBJECT: SERVICE OF COURT DOCUMENT - 2018CA001805, KRUPA, THERESA TR VS. MANTA RAY CONSTRUCTION INC - ATTACHMENT COUNT: 1 - EMAIL DOCKET DESCRIPTIONS: SUM[-9/16/2019" 79 6 78 9/16/2019 SUMMONS ISSUED ( V ) I 78 80 9/16/2019 PAYMENT $30.00 RECEIPT #21019000076543 RECEIVED FOR FILING NUMBER 95692711 VIA FILINGPAYMENTS20190916235959.TXT. 77 Request 1 77 9/13/2019 CORRESPONDENCE - PMT FOR R SUMMONSES (V) 76 76 9/13/2019 "RECIPIENTS: - SUBJECT SERVICE OF COURT DOCUMENT - 2018CA001805, KRUPA, THERESA TR VS. MANTA RAY CONSTRUCTION INC - ATTACHMENT COUNT. 1 - EMAIL DOCKET DESCRIPTIONS: RETP-9/13/2019" 75 1 75 9/13/2019 RETURN PLEADING FORM -REQUESTING PAYMENT FOR THE THREE SUMMONSES FILED 74 2 74 9/13/2019' SUMMONS TO BE ISSUED BY CLERK (V) 73 2 73 9/13/2019 SUMMONS TO BE ISSUED BY CLERK (V) 72 ❑ 2 72 9/13/2019 SUMMONS TO BE ISSUED BY CLERK (V) 71 29 70 8/23/2019 THIRD PARTY COMPLAINT (V) 70 69 8/23/2019 "RECIPIENTS: OLMSTED, MATTHEW RYON - SUBJECT: SERVICE OF COURT DOCUMENT - 2018CA001805, KRUPA, THERESA TR VS. MANTA RAY CONSTRUCTION INC - ATTACHMENT COUNT. 1 - EMAIL DOCKET DESCRIPTIONS: RETP-8/23/2019" 69 ❑ 1 68 8/23/2019 RETURN PLEADING FORM - FILING FEE DUE 68 71 8/23/2019 PAYMENT $395.00 RECEIPT #2019000070454 RECEIVED FOR FILING NUMBER 94662407 VIA FILINGPAYMENTS20190823235959.TXT. 67 1 67 8/22/2019 ORDER GRANTING LEAVE TO FILE 3RD PARTY COMPLAINT ( V ) 66 1 66 8/20/2019 NOTICE OF CANCEL DEPOSITION (V) 65 34 65 8/13/2019 MOTION FOR LEAVE TO FILE 3RD PARTY COMPLAINT ( V ) 64 3 64 8/8/2019 MOTION FOR EXTENSION OF TIME ( V ) 63 ❑ 3 63 8/6/2019 NOTICE OF TAKING DEPOSITION ( V ) 62 ❑ 2 62 7/30/2019 NOTICE OF CANCELLATION OF DEPOSITION ( V ) SEQ#IMAGE DIN DATE ENTRY 61 7 61 7/30/2019 MOTION FOR PROTECTIVE ORDER W REGARD TO DEPOSITION (V ) 60 4 60 7/19/2019 NOTICE OF TAKING DEPOSITION - AMENDED (V ) 59 ❑ 4 59 7/18/2019 NOTICE OF TAKING DEPOSITION (V) 58 PI 2 58 7/18/2019 NOTICE OF UNAVAILABILITY (V) 57 ❑ 7 57 7/9/2019 REQUEST TO PRODUCE ( V ) 56 3 56 6/19/2019 NOTICE OF TAKING DEPOSITION ( V ) I 55 3 55 6/6/2019 NOTICE OF TAKING DEPOSITION (V ) 54 ❑ 3 54 5/16/2019 RESPONSE TO REQUEST TO PRODUCE ( V ) 53 Request 53 5/16/2019 NOTICE OF FILING RESPONSE ( V ) 52 1 52 4/26/2019 ORDER COMPELLING BEIEll RESPONSES (V ) 51 1 51 4/26/2019 COURT NOTES I 50 ❑ 6 50 4/25/2019 NOTICE OF FILING AFFIDAVIT OF SUMMONS RETURNED SERVED (V ) 49 p Request 49 4/25/2019 NOTICE OF FILING AFFIDAVIT OF SUMMONS RETURNED SERVED (V) 48 2 48 4/19/2019 RESPONSE TO REQUEST TO, PRODUCE ( V ) 47 1 47 4/19/2019 NOTICE OF SERVING ANSWER TO INTERR (V ) 46 PI 6 46 4/19/2019 RESPONSE TO REQUEST FOR ADMISSIONS (V ) 45 2 45 4/3/2019 NOTICE OF HEARING - RE -NOTICE ( V ) 44 1 44 3/22/2019 ORDER TO EXTEND TIME (V) 43 2 43 3/20/2019 MOTION FOR ENLARGEMENT/,EXTENSION OF TIME (V) 42 Request 42 3/12/2019 NOTICE OF FILING PROPOSAL711 SETTLEMENT (V ) 41 2 41 3/12/2019 NOTICE OF FILING PROPOSAL FOR SETTLEMENT '(V ) 40 1 40 2/28/2019 NOTICE OF CANCELLATION OF DEPOSITION (V) 39 2 39 2/28/2019 NOTICE OF HEARING (V ) I 38 38 2/27/2019 CIRCUIT JUDGE BRONIS, BARBARA W: ASSIGNED 37 ❑ 20 37 2/25/2019 MOTION FOR PROTECTIVE ORDER(V) 6 ❑ 11 36 2/25/2019 MOTION TO COMPEL (V) I 5 1 35 2/22/2019 NOTICE OF TAKING DEPOSITIONS V j 34 ❑ 3 34 2/22/2019 NOTICE OF TAKING DEPOSITION V) 33 6 33 2/19/2019 REQUEST FOR ADMISSIONS ( V) I 32 7 32 2/19/2019 REQUEST TO PRODUCE ( V) I 31 2 31 2/19/2019 NOTICE OF SERVING INTERROGATORIES (V ) 30 ❑ 3 30 2/15/2019 RESPONSE TO REQUEST TO PRODUCE ( V ) 29 ❑ 1 29 1 /30/2019 NOTICE OF SERVING PROPOSAL FOR SETTLEMENT - AMENDED (V ) 28 1 28 1 /28/2019 NOTICE OF SERVING PROPOSAL FORISETTLEMENT - AMENDED (V) 27 ❑ 1 27 1 /28/2019 NOTICE OF SERVING PROPOSAL FOR SETTLEMENT 26 2 26 1/22/2019 NOTICE OF SERVING ANSWERS TO INTERROGATORIES ( V ) 25 2 25 1 /15/2019 REPLY TO AFFIRMATIVE DEFENSES ( VI) 24 1 24 1 /8/2019 NOTICE OF UNAVAILABILITY ( V ) I 23 23 1 /2/2019 CIRCUIT JUDGE MIRMAN, LAWRENCE: ASSIGNED 22 9 22 12/28/2018 ANSWER, AFFIRMATIVE DEFENSES, ANDIDEMAND FOR JURY TRIAL (V) 21 3 21 12/19/2018 REQUEST TO PRODUCE ( V ) 20 ❑ 1 20 12/19/2018 NOTICE SERVING INTERROGATORIES (WI) 19 14 19 12/10/2018 COMPLAINT ( V ) 18 9 18 12/7/2018 MOTION TO AMEND COMPLAINT (V ) 17 8 17 11 /29/2018 ANSWER/DEFENSE/DEMAND FOR JURY (V ) 16 16 11/13/2018 DEFENDANT ATTORNEY: OLMSTED, MATTHEW RYON ASSIGNED 15 3 15 11 /12/2018 MOTION FOR EXTENSION OF TIME ( V) 14 2 14 11 /912018 NOTICE OF UNAVAILABILITY (V ) , 13 3 13 11 /9/2018 NOTICE OF APPEARANCE (V) I 12 11 9/27/2018 "RECIPIENTS: GRAZI, LEIF JAY - SUBJECT: SERVICE OF COURT DOCUMENT - 2018CA001805, KRUPA, THERESA TR VS. MANTA RAY CONSTRUCTION INC - ATTACHMENT COUNT: 1 - EMAIL DOCKET DESCRIPTIONS: SUMI-9/27/2018" 11 5 10 9/27/2018 SUMMONS ISSUED (V) 10 9 9/27/2018 CIRCUIT JUDGE BELANGER, ROBERT E: ASSIGNED 9 2 9/27/2018 PLAINTIFF ATTORNEY: GRAZI, LEIF JAY ASSIGNED 8 1 9/27/2018 CASE FILED 09/27/2018 CASE NUMBER 2018C'A001805 7 12 9/27/2018 PAYMENT $420.00 RECEIPT #2018000073876 RECEIVED FOR FILING NUMBER 78471880 VIA FILINGPAYMENTS20180927235959.TXT. 6 3 8 9/26/2018, SUMMONS TO BE ISSUED BY CLERK (V) I 5 2 7 9/26/2018 SUMMONS TO BE ISSUED BY CLERK (V) I 4 1 6 9/26/2018 DESIGNATION OF EMAIL ADDRESS ( V) 3 12 5 9/26/2018 COMPLAINT ( V ) I DATE IENTRY I I D 2 3 9/26/2018 CIVIL COVER SHEET ( V )