Case Number: CACE-15-006911 Division: 08
Filing 26410927 E-Filed 04/22/2015 03:29:02 PM

IN THE CIRCUIT COURT OF THE 17TH IUDICIAL
CIRCUIT, IN AND FOR BROWARD COUNTY,

 

FLORIDA
SUPERIOR MOVING STORAGE,
INC., a Florida corporation,
GENERAL CIVIL DIVISION
Plaintiff,
CASE NO.:
V.
SCOTT HOOTON,
Defendant.

COMPLAINT

Plaintiff, SUPERIOR MOVING STORAGE, INC., by and through its undersigned
counsel, sues Defendant, SCOTT HOOTON, and states:

NATURE OF THE ACTION

 

1. This is an action for damages in excess of $15,000 for defamation, and therefore
within the jurisdiction of this Court.
THE PARTIES
2. Plaintiff, SUPERIOR MOVING STORAGE, INC. ("Superior"), is a Florida

corporation organized and existing under the laws of the State of Florida.

 

3. Defendant, Scott Hooton, is an individual residing in Broward County, Florida.
IURISDICTION AND VENUE
4. This Court has personal jurisdiction over the Defendant inasmuch as he is a

resident ofthe State of Florida.
5. Venue is proper in Broward County, Florida as Defendant is a resident of

Broward County, Florida.

FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/22/2015 3:29:02 

6. Superior is a licensed and insured moving company that provides local and long
distance moving services for both residential and commercial businesses. It also offers storage
services in a fully air conditioned and secure storage facility.

7. On or about January 2015, Superior and Hooton executed a Guaranteed/Binding
Estimate [the ?Estimate?) for a residential move.

8. Thereafter, Defendant executed the following documents:

a. An Order for Service (the ?Service Order?);

b. A Uniform Household Goods Bill of Lading and Freight Bill (the ?Bill of
Lading?);

c. A Household Goods Descriptive Inventory [the ?lnventory?);

d. A Superior Additional Terms and Conditions Interstate Moves Contract; and

e. A Superior Long Distance Addendum to Contract [the Addendum?).

9. Pursuant to the Contract, Superior was ready willing and able to pick up the
Defendant?s furniture and other items (collectively, the ?Furniture?), as outlined on the
estimate, however, Defendant Hooton, without cause terminated the contract for the move.

10. Despite the fact that Superior was ready, willing and able to fulfill its contract,
the Defendant has been defaming Superior in online postings. Defendant published the
following false statements about Superior: "They get you on the hook for a low price without
completely understanding the work. Then they apply additional charges until it's unbearable 

11. Each and every one of the above statements is false.

12. Superior has been required to retain the undersigned counsel to represent it in
this action and is obligated to pay said counsel a reasonable fee for services rendered.

13. As a direct and proximate result of the foregoing false statements, Superior has

been damaged.

WHEREFORE, Plaintiff, Superior, respectfully demands judgment in its favor against
Defendant, Hooton, for compensatory damages, special damages including lost profit and
revenue, attorney?s fees pursuant to the Contract, and such additional relief as this Court deems

just and proper.

IURY DEMAND

Plaintiff demands trial by jury of all claims so triable.

MICHAEL B. MANES, RA.
Attorney for Plaintiff

950 S. Pine Island 
Plantation, FL 33324
Telephone: (954) 523-4844
Email: michael@maneslegal.com

By: 
Michael B. Manes
Florida Bar 372684