HC Trading vs Jonathan Burke

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    IN THE CIRCUIT COURT OF THE6th JUDICIAL CIRCUIT IN AND FORPINELLAS COUNTY, FLORIDA

    H. C. TRADING,oPlaintiff, ..,.- c:>:D-t -x Jc:: (-)c.;VS. I\.D

    lONA T : ~ n ; ~ n ~ U R K E d/b/a QUINTESSENTIAL CONCEPTS f i i ; ; ; : ~ ' i 0 : ~ COMPLA I N / Ff

    alleges:Plaintiff sues Defendant, JONATHAN C. BURKE d/b/a QUINTESSENTIAL CONCEPTS, and

    COUNT I - BAD CHECK

    1. This is an action for damages greater than $15,000.00.2. On May 6,2003, July 1,2003, August 14,2003, and August 21, 2003, Defendant,JONA THAN C. BURKE d/b/a QUINTESSENTIAL CONCEPTS, executed writtenorders for payment of $10,000.00, $10,000.00, $3,300.00, and $3,300.00 commonlycalled checks, copy being attached hereto as Exhibit "A" payable to Plaintiff anddelivered to Plaintiff.3. That Plaintiff did negotiate said check but same was dishonored due to insufficient

    funds.4. That Plaintif f did send the required statutory demand letter pursuant to Florida Statute

    68.065 to the Defendant. A copy of the letter and certified mail receipt are attachedhereto as Composite Exhibit "B".5. Defendant owes Plaintiff $26,600.00 representing the base amount of the checks, plustreble damages in the amount of $79,800.00 pursuant to Statute plus the StatutoryService Charge.6. All conditions precedent to the institution of this action have been performed or have

    occurred.7. Plaintiff is entitled to attorney's fees pursuant to Statute.WHEREFORE, Plaintiff demands Judgment against JONATHAN C. BURKE d/b/aQUINTESSENTIAL CONCEPTS, for $106,400.00 as damages, plus interest, costs, statutory servicecharge and a reasonable attorney's fee.

    COUNT II-GOODS SOLD AND DELIVERED8. This is an action for damages more than $15,000.00.

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    9. Defendant owes Plaintiff $70,355.50 as Damages that are due with interest since June30,2003 for goods sold and delivered by Plaintiff to Defendants (see attached CompositeExhibit "C").

    10. These goods consist of various and diverse merchandise purchased from Plaintiff with avalue reflected above.

    II. All conditions precedent have been performed or waived.12. Plaintiff has agreed to pay its counsel a reasonable tee.WHEREFORE, Plaintiff demands Judgment for $70,355.50 as Damages, plus interest, costsand a reasonable attorney's fee.

    Law Office of Julie E. Yates, P.A.Attorney for Plaintiff5944 Coral Ridge Drive, #208Coral Springs, FL 33076

    ( / eI ho . (9 5 341-1295!"jJi.

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    ,

    EXHIBITJi-

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    I ' '

    .EXHIBITA -

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    .. .

    ....

    EXHIBIT A

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    SEfDER: COMPLETE THIS SECTION Complete items 1, 2, and 3. Also completeitem 4 If Restricted Delivery Is desired. Print your name and a ~ r e . s s on the reverseso that we cat! rEltum t F i ~ card to you. Attach this card to the back of the mailpiece,or on the fronl if space permits.1. ArtIcle Addressed 10:~ < ) ~ U f l Q . c \ b ~ Ou\ ( \ ~ S ~ C \ \ c . c t ' ~

    HYES, enler delivery address below: 0 N

    \D \ ~ D - \ \ ) 0'6 ~ ~ / ' \ r : . . . . ' r J ' { V \ l D Express Mail~ ~ ~ b - . D Retum Receipt for MeDC.O.D.

    2. Article Numberl (Transfer from service label) 7004 0750 0002 5042 6578PS Form 3811, August 2001 Domestic Retum Receipt

    UNITED STATES POSTAL SERVICE 11111/,., -' t, (, '>\ ..

    r -...... _'_..I, ,. ""

    First-Class .MaiL1>oslage"& Fees P.alUSPSPermit No. G-10

    Sender: Please print your n ~ ~ m e . k d d r e s s , and Z I P + ~ _ i n . this box' - - ~ ../ ' -

    JUUE E. YATES, P.A.5944 Coral Ridge Dr. /I 208Coral Springs. Ronda 33076

    i X l ' \ 8 \ 1 ~

    2ACP