IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROW ARD COUNTY, FLORIDA

OFFICE OF THE ATIORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA,

Plaintiff, Case No. 13-CA"014854(12)

vs.

NATIONWIDE POOLS, INC., a Floiida corporation; NATIONWIDE POOLS OF DADE, INC., a Flotida corporation; NATIONWIDE POOLS OF W. PALM BCH, INC., a Florida corporation; NATIONWIDE POOLS, GULF COAST, INC., a Florida corporation, f/k/a STUART POOLS, INC.; KEITH LORING STUART, an individual; LYNN ANTONUCCI STUART, an individual; FELICIA JOSEPHINA MALLIA, an individual, TERRY LYNN EDWARDS, an individual, and THE KINGS HIGHWAY GENERAL CONTRACTING INC., a Florida corporation n/k/a NATIONAL CONSTRUCTION GROUP INC.,

Defendants.

CONSENT FINAL JUDGMENT AND ORDER FOR PERMANENT INJUNCTION AGAINST DEFENDANTS

NATIQNAL CONSTRUCTION QROUP. INC. AND TERRY EDWARDS

The OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL

AFFAlRS, STATE OF FLORIDA ("Plaintiff" or the "Departmenf'), and NATIONAL

CONSTRUCTION GROUP, INC. and TERRY EDWARDS (collectively, the •'Settling

Defendants''), having agreed and stipulated to the entry of this Consent Final Judgment and

Order for Pem1aneut Injunction ("Judgment") and the findings set forth below, and this Court

having reviewed the file and necessary papers, this Court does hereby ORDER and

ADJUDGE:

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Final judgment is hereby entered on the cause of action asserted under the Florida

Deceptive and Unfair Trade Practices Act (Count I) and Florida•s Uniform Fraudulent Transfer

Act (Count II) in favor of the Office of the Attomey General, Department of Legal Affairs, State

of Florida, 1515 N. Flagler Olive, Suite 900, West Palm Beach, FL 33401 and against Defendant

National Construction Group, Inc., whose address is 6574 N. State Road 7 #314, Coconut Creek,

FL 33073, and Defendant Ten)' Edwards ("Edwards"), whose address is 4474 Heathstead Dr.,

Apt. F, Dublin, Ohio 43016, as follows:

I. FINDINGS

I. The Department is an agency of the State of Florida and the enforcing authority

under the Florida Deceptive and Unfair Trade Practices Act ("FDUTPA"), Section 501.201 et

seq., Florida Statutes.

2. The Department initiated an investigation into allegations that Defendants

engaged in acts or practices that were misleading, unfair, deceptive or unconscionable in the

sales, marketing, advertising. and performance of swimming pool construction and remodeling.

3. Defendants, at all times material hereto, solicited consumers within the definitions

of Section 501.203(7), Florida Statutes.

4. Defendants, at all times mate1ial hereto, provided goods or services as defined

within Section 501.203(8), Florida Statutes, within the State of Florida and Broward County.

5. Defendants, at all times material hereto, were engaged in a trade or commerce

within the definition of Section 501.203(8), Florida Statutes.

6. The parties hereby agree and stipulate that this Court has jurisdiction over the

parties and the subject matter of this action pursuant to the provisions of FDUJ'P A, and that

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venue is proper in this Court in that the actions at issue took place in more than one county in the

State of Florida

7. Duling the relevant time peliod, namely fi·om April 2013 through October 2013,

Defendants marketed, advei1ised, sold, and provided services to consumers relating to swimming

pool construction and remodeling.

8. This Cowt detennined that the acts and practices of the Defendants constitute

unfair, deceptive and unconscionable trade practices that were likely to deceive a consumer

acting reasonably under the circumstances.

9. This Court also determined that Defendants' acts and practices are violations of

FDUfPA and Florida's Unifonn Fraudulent Transfer Act

10. On June 24, 2014, this Court entered a Final Default Judgment as to Liability

against Defendant Nationwide Pools and Defendant The Kings Highway General Contracting

Inc., n/k/a National Construction Group Inc. (''National Construction Group'') (collectively, the

"Corporak; Defendants"). In the Final Default Judgment as to Liability, this Court made certain

findings of fact and conclusions of law, which are incorporated herein by reference, and entered

a pennanent injunction against the Corporate Defendants. A copy of the Final Default Judgment

is attached hereto as Exhibit A

11. On February 11, 2015, this Coui1 entered summary judgment as to liability in

favor of Plaintiff and against Defendants Keith Stuart, Lynn Stuart, Felicia Mallia and Terry

Edwards (the "Individual Defendants"), based on their control of and participation in the

Corporate Defendants' acts and practices. A copy of that Order is attached hel'eto as Exhibit B

and incorporated herein by reference. Specifically, this Court found that:

a. '"[A]wareness of fraudulent pl'actices and failure to act within one's authority to control such practices is sufficient to establish liability.' . . . Hen~, each of

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the Individual Defendants is liable for the actions of the Corporate Defendants, as the undisputed facts show that they each: 1) possessed the authority to control and did control the Cot'J'orate Defendants' business operations, 2) directly participated in the subject acts and practices, and 3) failed to act within their authotity to control them." Ex. B, ft 5-6 (citations omitted).

b. "The undisputed evidence shows that each of these Individual Defendants not only had awareness and knowledge of the Corporate Defendants' deceptive acts and practices, but were responsible for them. Thus, there is direct and competent evidence to support a finding of individual liabHity for iajunctive and monetary relief against each of the Individual Defendants." Ex. Bat, 8.

fl.ORDER

A. INJUNCTIVE TERMS

12. ·The J>Ulpose of FDUf PA is to "protect the consuming public and legitimate

business enterprises from those who engage in unfair methods of competition, or

unconscionable, deceptive, or unfair acts or practices in the conduct of any trade or commerce."

Section 501.202(2), FLA. STAT. To that end, "reasonable resb'ictions upon the futw-e activities of

any defendant to impede her or him [sic] from engaging in or establishing the same type of

endeavor" are permitted by the Act, and courts may "order any defendant to divest herself or

himself of any interest in any enterprise." Section 501.207(3), FLA. STAT. Prohibiting business

activities is constitutional when the limitation is rationally related to the State's objective of

preventing deceptive practices. Fraternal Order of Police v. Dept. of State, 392 So. 2d 1296,

1302 (FJa. 1980) (upholding regulations in the Law Enforcen\ent Funds Act even though they

wel'e not "the best possible means to et:adicate the evils perceived" because they were not

"wholly unrelated" to the legislature's pwpose). As such, a permanent injunction is appropriate.

13. The Court hereby ORDERS that Defendant National Construction Group and

Defendant Edwards, individually, CEASE, DESIST and are het'eby BARRED, directly as well

as indirectly through representatives, agents, employees, successors, assigns, independent

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contractors or any other person or entity who acts under, by, through, or on their behalf, from

marketing, advertising, selling, providing, accepting payment for, rendering, engaging i~

assisting with, or otherwise providing pool construction or pool remodeling services to

consumers in the State of Florida.

14. In addition to the permanent injunction previously entered as to the Corporate

Defendants in the Final Default Judgment as to Liability dated June 24, 2014, the Coutt hereby

PERMANENTLY ENJOINS Defendant National Construction Group and Defendant Edwards,

individually, from the following:

a. Engaging in any acts or practices that violate the Florida Deceptive and Unfair

Trade Practices Act, Chapter 50 l, Part II, Florida Statutes;

b. Engaging in any acts and practices that violate Florida's Uniform Fraudulent

Transfer Act, Sections 726.105(1)(a)-(b) and 726J06(1), Floiida Statutes;

c. Marketing, advertising, selling, providing, accepting payment for, rendering,

engaging in, assisting with or otherwise providing pool construction or pool remodeling services

to Fl01ida conswners, in any agent, einployee/employer, manager, ownet", consulting or

contractor capacity whatsoever;

d. Making any false or misleading representations, or false or deceptive statements;

in any communications with consumers.

15. The Court further ORDERS that the Settling Defendants shall hereinafter comply

with Chaptel' 489 of the Florida Statutes} pertaining to Contracting, and Chapter 713, Part I,

known as Florida' Construction Lien Law, in providing any contracting or consouction service

to consumers in the State of Florida. Additionally, the Settling Defendants shall secure a

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payment and performance bond for each contracting or construction job pursuant to which a

conswner makes payments directly to such Defendant.

16. The Settling Defendants shall not destroy, mutilate, conceal, alter, or dispose of

their books, records, contracts, financial records, consumer files and financial infonnation,

regardless of the manner in which it is stored, for a period of three (3) years from the date of this

Judgment.

B. MQNETARY TERMS

17. FDUTP A authorizes reimbursement to consumers who have been damaged by

deceptive trade pt'actices. §501.207(3), Fla. Stat. It also authorizes recovery of the actual

damages caused by the deceptive practices. §501.207( I )(b ), Fla. Stat. All consumers who paid

money in response to a deceptive trade practice are entitled to their money back, and there is no

need for an individualized inquiry into how each consumer reacted to the practice. F. T. C. v.

Wilcox, 926 F. Supp. 1091, 1105 (S.D. Fla. 1995); F.T.C. v. People's Credit First, No. 8:03-CV-

2353-T, 2005 WL 3468588 (M.D. Fla. Dec. 18, 2005).

18. Judgment is hereby entered against Defendant National Construction Group and

Defendant Edwards, jointly and severally, for consumer restitution in the total amount of Eighty­

Two Thousand Nine Hundred Seventy-Five Dollars and No Cents ($82,975.00) ("Restitution

Amount"), for which let execution issue forthwith. The Restitution Amount shall be paid by

wire transfer, ceitifled funds or cashier's checks, payable to the Department of Legal Affairs

Escrow Fund, c/o Sarah Shullman, Assistant Attorney Generalt Office of the Attorney General,

Consumea.· Protection Division, 1515 North Flagler Drive, Suite 900, West Pahn Beach, Florida

33401.

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19. h1 the event actual restitution for future complainants exceeds the Restitution

Amount, then the Restitution Amount will be distributed pro.-rata to the oomplainants detennined

by the Department to be eligible for restitution. In no event shall any individual consumer

receive more than th~ amount they are actually owed. If any restitution monies remain after the

distribution of the Restitution Amount, the Deprutment will deposit the remaining monies into

the Department of Legal Affairs Revolving Trust Fund and it shall be used to defray the oosts of

restitution distribution and any attorneys' fees and costs incurred in enforcing this Judgment, or

as fees and costs associated with ongoing and future enforcements initiatives pw·suant to Chapter

501, Part IT, Florida Statutes.

20. While restitution serves the pwpose of restoring an injured person to the financial

position held before a defendant t-eceived an unlawful benefit, with a civil penalty "the Jaw

exacts payment by way of punishment for doing some act which is prohibited .. .. " Sun Coast

Intem. Inc. v. Dept. of Business Regulation, 596 So. 2d 1118, 1121 (Fla. 1st DCA 1992) (internal

citations omitted). Anyone who has used a trade practice found to be unlawful under the Act is

liable for a civil penalty of up to $10,000 per violation. §501.2075, Fla. Stat. Each instance in

which a deceptive representation is disseminated constitutes a violation. U.S. v. Reader 's Digest

ks 'n, Inc., 662 F. 2d 955, 966 (3d Cfr. 1981).

21. In this case, more than 8 transactions of unfait· or deceptive conduct occurred in

which the Court found that the Defendants violated FDUTP A. Given the nature of the violation

and the egregiousness of the consumer hann, the appropliate penalty is at least $10,000 per

violation, for a total penalty of Eighty Thousand Dollars and No Cents ($80,000.00).

22. Judgment is hereby entered against Defendant National Construction Group and

Defendant Edwards, jointly and severally, for civil penalties pursuant to Sections 501.2075 and

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501.2077, Florida Statutes, in the amount of $80,000.00 (the "Penalty Amounf'), for which let

execution issue fo11hwith. The Penalty Amount shall be paid by wire transfer, ce11ified funds or

cashier's checks, payable to·the Department of Legal Affairs. The Settling Defendants agree

that the Penalty Amount represents a civil penalty owed to the State of Florida, is not

compensation for actual pecuniary loss, and, therefore is not subject to discharge under the

Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7).

23. Section 501.2105 provides that the prevailing paity may recover fees and costs

from the non-prevailing party. Humane Society qf Broward County v. the Florida Humane

Society, 951 So. 2d 966, %9 (Fla. 4th DCA 2007); Smith v. Bi/gin, 534 So. 2d 852, 854 (Fla. 1st

DCA 1998). The parties stipulate and agree that the Department is entitled to payment of its

attorneys' fees and costs in the amount of$137,773.

24. Judgment is hereby entered against Defendant National Construction Group and

Defendant Edwards, jointly and severally, for attorneys' fees and costs in the amount of One

Hundred Thirty-Seven Thousand Seven Hundred Seventy-Three Dollars and No Cents

($137,773 .00) ("the "Fees Amount.,), for which let execution issue f011hwith. The Fees Amount

shall be payable to the Department of Legal Affairs Revolving Trust Fund, for which let

execution issue forthwith. The Settling Defendants agree that the Fees Amount represents an

amount owed to the State of Florida as the enforcing authority for its fees and costs, is not

compensation fo1· actual pecuniary loss, and, therefore is not subject to discharge under the

Bankruptcy Code pursuant to I 1 U.S.C. § 523(a)(7).

25. Upon ninety-one (91) days following receipt by the Department of the sum of

Forty Thousand Dollars and No Cents ($40,000.00), paid voltmtaiily (i.e. not as a result of

collection efforts by the Department) by or on behalf of Defendant Edwards, for any monies

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owed pw·suant to Section II(B) of this Agreement by Defendant Edwards, jointly 01· severally

with Defendant National Construction Group, the Depm1ment shall stay the unpaid remaining

portion of the money judgment against this Defendant and suspend any collection efforts

pertaining to same.

26. The Department's agreement to the above amounts for restitution, penalties and

fees, and to the partial suspens:ion of collection efforts pw·suant to paragraph 25, is expressly

premised upon the truthfulness, accuracy, and completeness of the Settling Defendants' sworn

financial statements and related documents (collectively, "Financial Representations'')

demonstrating their inability to pay the full judgment amounts. These Financial Representations

include material information upon which the Department relied in negotiating and agreeing to

this Judgment. If, upon motion by the Department, the Court fmds that any of the Settling

Defendants failed to disclose any asset, misstated the value of any asset, or made any other

misstatement or omission in the Financial Representations identified above, then such Settling

Defendant shall be Hable for the full Restitution Amowit ($82,975.00), full Penalty Amount

($80,000.00), and full Fees Amount ($137,773.00), which shall become immediately due and

payable.

C. SURRENDER AND SALE OF ASSETS

27. Effective upon the entry of this Judgment, the Settling Defendants su1Tender to

the Department all control, title, dominion, and interest in the :frozen funds in the Settling

Defendants' TD Bank accounts ending with 9098, 7902 and 6633, pursuant to the Order

Granting Temporary Injunction and Asset Freeze Without Notice (the "Injunction Order") dated

October 14, 2014, which funds shall be credited towm'ds payment of the Restitution Amount.

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28. To effect the surrender of the funds identified in Paragraph 27, the Court directs

that the entity(ies) holding the funds or their successors sltall, immediately upon receiving notice

of this Judgmentt remit the funds to the Deparbnent by certified check(s) or other guaranteed

funds payable to the Department of Legal Affairs, or by wire transfer in· accordance with

directions provided by counsel for the Department. To the extent any identified third party

cannot comply with this Paragraph without the assistance of tlie Settling Defendants, such paity

must, within three (3) business days of receiving this Judgment, notify such Settling Defendants

and counsel for the Department of its inability to comply. Such notification shall specify the

actions by such Defendant(s) that are necessary to comply with this Judgment. The Settling

Defendants shall immediately complete any action necessary to facilitate the identified third

party's ability to timely comply with this Subsection, and the failure of such Settling Defendant

to complete such action within ten (10) days shall be deemed a violation of the Judgment and_

interest at the rate prescribed in the Florida statutes shall immediately begin to accrue.

29. . The Settling Defendants relinquish all dominion, control, and title to the assets

sutTendered or paid to the fullest extent permitted by law. The Settling Defendants shall make no

claim to or demand return of these assets, directly or indirectly, through counsel or otherwise.

30. The Settling Defendants agree not to transfer or convey financial assets of any

type (whether monetary, personal propeiiy, real property or otherwise) to any other third person

or entity as a means to avoid enforcement of this Judgment or payment of any amounts due

hereunder. Any such transfer or conveyance shall be deemed a violation of this Judgment and

subject the applicable Defendant(s) to an additional civil penalty in the amount of $1,000,000,

which shalJ become immediately due and payable upon a finding by this Court that such transfer

occurred.

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31. The Settling Defendants shall be permitted to sell the vehicles :frozen by the

Injunction Order, with net proceeds (if any) utilized towards payment of the Restitution Amount,

which vehicles are hereby released by this Judgment for the sole purpose of sale and payment of

any and all sale proceeds to the Depai1ment of Legal Affairs. Defendant Terry Edwards shall be

pe11nitted one vehicle fo1· persona] ownership and/or use. The asset freeze set forth in the

Injunction Order is otherwise hereby lifted and released in its entirety, as to the Settling

Defendants only, effective 35 days from the date of full payment and satisfaction of the amounts

set forth in Paragraphs 18, 22 and 24, which shall be evidenced by a Satisfaction of Judgment

recorded with the Clerk of the Cou1t by the Department. Any financial institution affected by the

htjunction Order is insnucted and authorized to process credits, debits, deposits and payments

and any other regular business activity of the Settling Defendants in the usual manner as of 35

days from the date of recording of the Satisfaction of Judgment.

D. COMPLIANCE MONITORING

32. From the date of the entry of this Judgment by the Court (the ••Effective Date"),

all of the Settling Defendants' records must be retained for a minimum of three (3) years. The

Settling Defendants shall maintain and make available to the Department's representative, upon

any reasonable written request, all books, records and other documents, except privileged

documents, in the format in which they exist, which l'eflect the implementation of the tenns of

this Judgment and compliance with its tenns. Any such records requested by the Department

shall be made available for inspection within ten (10) business days of the Settling Defendants'

receipt of the request. The Settling Defendants shaH honor any request from the Department to

make such records available without legal process.

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33. For a period of three (3) years from the Effective Date, the Settling Defendants

shall notify the Department of the following within ten (10) days of the occurrence of:

a. Any changes in such Defendant's residence, mailing address, and

telephone number;

b. Any changes in such Defendant's employment status (including self~

employment), and any change in such Defendanfs ownership in any business entity.

Such notice shall include the name and address of each business that such Defendant is

affiliated with, employed by, creates or forms, or performs services for; a detailed

description of the nature of the business; and a detailed desCiiption of such Defendant's

duties and responsibilities in connection with the business or employment~

c. Any changes in such Defendant's name or use of any aliases or fictitious

names; and

d. Any transfers of assets, of any type mid amount, to any other Defendant or

third person or entity.

34. The Settling Defendants shall notify the Department of the filing of a bank1uptcy

petition by such Defendant within fifteen (15) days of filing.

35. Within seven (7)days of the Effective Date, the Settling Defendants must:

a. Designate at least one telephone number and email, physical, and postal

address as points of contact, which the Department may use to communicate

with such Defendant;

b. Identify all businesses the Settling Defendant owns, or directly or indirectly

controls, by all of their names, telephone numbers, and physical, postal, email,

and Internet addresses;

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c. Describe the activities of each such business, including the products and

services offered, and the means of advei1ising, marketing, and sales;

d. Describe in detail the Settling Defendanfs cun·ent employment, whether as an

employee, independent contractor, owner, manager, comiultant or partner, and

describe the nature of such employment including each Defendant's title, role,

responsibilities, participation, authority, control, and ownership.

36. For three (3}years from the Effective Date, the Settling Defendants must report

any change in the information required to be submitted under Paragraph 3 7 at least 30 days

before the change or as soon as practicable after learning about the change, whichever is

sooner.

E. FUTURE VIOLATIONS

37. Any failure to comply with the tetms and conditions of this Judgment, except fo1·

the payment provisions contained in Section II(B), is by statute prim.a facie evidence of a

violation of Chapter 501, Part II, Florida Statutes, and will subject the Settling Defendants to any

and alJ civil penalties and sanctions authorized by law, including attorneys• fees and costs. In the

event that a court of competent jurisdiction makes a detennination that a violation of any

provision of this Judgment has occun·ed, except for the payment provisions contained in Section

II(B), then the Settling Defendants who engaged in the violation shall be liable for an additional

$500,000.00 (Five Hundred Thousand Dollars) in civil penalties, as well as any additional

attomeys' fees and costs, and other relief as may be allowed by law.

F. MISCELLANEOUS PROVISIONS

38. The Settling Defendants shall complete under oath Florida Rule of Civil

Procedure Form 1.977 (Fact Information Sheet), including all required attachments, and serve it

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on the Department, within 45 days from the Effective Date, unless the Judgment is satisfied or

post-judgment discovery is stayed.

39. The claims asserted in the instant action will remain outstanding until the

expiration of91 days following the latter of full execution of this Consent Final Judgment and/or

receipt of all payments due hereunder from the Settling Defendants, provided the Settling

Defendants have fully and completely petfonned all obligations owing to date and no voluntary

or involuntary petition for bankruptcy or other declaration of insolvency has been filed. Such

release of the Department's claims shall be without prejudice to any other remaining

investigation(s) that may otherwise exist as to the Settling Defendants or any other entities.

40. The Settling Defendants shall not affect any change in the fonn of doing business

or the organizational identity of any of the existing business entities or create llilY new business

entities as a method of avoiding the terms and conditions set furth in this Judgment.

41. This Judgment is continuing in nature and shall be binding on any and all

successors or assigns of the Settling Defendants.

42. This Judgment is not a waiver of any private rights of any person or release of any

private rights, causes of action. or remedies of any person against the Settling Defendants or any

other person or entity. Notwithstanding any other provision of this Judgment, nothing herein

shall be construed to impair, compromise or affect any right of any government agency other

than the Office of the Attorney General for the State of Florida relating to the operative facts at

issue in this action.

43. Nothing herein shall affect the Settling Defendants' (a) testimonial obligations, or

(b) right to take legal or factual positions in defense of litigation or other legal proceedings to

which the Department is not a party.

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44. If any term of this Judgment is to any extent unenforceable, invalid or illegal,

such te1m shall be excluded to the extent of such invalidity or unenforceability; all other terms

hereof shall remain in full force and effect; and, to the extent pe1mitted and possible, the invalid

or unenforceable tenn shall be deemed replaced by a teim that is valid and enforceable and that

comes closest to expressing the intention of such invalid or unenforceable term.

45. This Court retains jurisdiction of this case to enforce the tenns of this Judgment

and enter any fwther Orders as may be necessary to ensure compliance with this Judgment,

including by contempt proceedings, civil and/or criminal.

46. The parties jointly participated in the negotiation of the terms articulated in this

Judgment, and all parties consulted counsel or had the ability to do so. This Judgment is the

final, complete, and ex.elusive statement of the patties' agreement on the matters contained in

this Judgment, and it supel'sedes all p1·evious negotiations and agreements. Other than any

representation expressly stated in this Judgment, the parties have not made any representations or

wai1·anties to each other, and neither party's decision to enter into this Judgment is based upon

any statements by the other party outside of those in this Judgment.

47. Acceptance of this Judgment by the Department shall be established by the

signature of the Deputy Attorney General.

48. This document is signed in anticipation of this Judgment being submitted to the

Court for approvall without necessity ofhearing1 which is hereby WAIVED by all patties. The

signatures below indicate the patties' consent and agreement to this Judgment.

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TERRY EDWARDS

Agreed to:

STATE OF FLORIDA ) COUNTY OF PALM BEACH )

BEFORE ME, an officer duly authotized to take acknowledgments in the State of Florida, Terry Edwards personally appeared, individually. He acknowledged before me that s/he executed the foregoing instrument for the pw-poses therein stated on the f)<>~' day of Owbv"" 2015.

Subscribed to before me this~ day of PcA oar • 2015.

(print, type, or stamp commissioned Notary Public)

Personally known __ or Produced Identification

Type of Identification Produced:_ .4),~ v '-"S

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)(' (check one)

l~ Sc..~ ·c (_

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NATIONAL CONSTRUCTION GROUP, INC.

Agreed to:

STATE OF iI <WJ»A ot..·o ) COUNTY OF BllQ~ .p;c.'}Je.f.f'

BEFORE ME, an officer duly authorized to take acknowledgments in the State of Flol'ida, Terry Edwards personally appeared as President of National Construction Group, Inc. Ile acknowledged before me that slhe executed the foregoing instrument for the putposes therein stated on the -2!!:___ day of Oc..\.fo-cr , 2015.

Subscribed to before me this~ day of ::J ~b~ '2015.

NO iARY PUBLIC

(print1 type, or stamp conµnissioned Notary Public)

Personally known __ or Produced Identification _X ___ (check one)

Type ofidenti:fication Produced: j),: v '-'"S l-.~~c..<-'!CL

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By~:~~~~~.,.....-----­Smh L Sha•Dnwn Alliltlnt.A ~ Ofllce of& Attol:noy Oemn1 Depldmmt crfLepl Aifain Comam.-Prcmidoa Di'¥ilion lSlSN.Flqlar ~SuitD900 West.PalmS-., PL33'40J

SO ORDBRBD. Approved IDll Bataod i11 Cbembcn in Browmd County, Florida tbi1 _ day of

____ 201S. M\CHAEL L. G~TES C\roui\ Jud09

NQ'I \ & 2.M5 By:

-Circuft-:---o~ .. -urt~J-ud~p-----A TRUE COP'I

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