Florida Commission on Ethics P. 0. Drawer 15709, Tallahassee, Florida 32317-5709 Public Office is a Public Trust" COMPLAINT 1. PERSON BRINGING COMPLAINT: Name: Linda Pennin-lan TelephoneNumber!--_ Address: 735 Eighth St, 5. my: Naples Comm Collier 5mg: Florida Zip Code: (34m: 2. PERSON AGAINST WHOM COMPLAINT IS BROUGHT: Use a separate complaint form lor each person you wish to complain against: Name: smj'sud Telephone Number: Address: 735 Eighth SLS. City: County: "In" Zip Code: 340" Naples City Council Member Tltle of office or position held or sought: 3. STATEMENT OF FACTS: Please provide a full explanation of your complaint, describing the facts and the actions oi the person named above and why you believe he or she violated the law. include relevant dates and the names and addresses of persons whom you believe may be witnesses. Please do not submit more than 15 pages, including this form Please do not submit video or audio tapes, CDs. DVDs. flash drives or other electronic media; such material will not be considered part at the complaint and will be returned, 4' OATH STATE OF 14-- COUNTY OF I. the person bringing this complaint. do Sworn to (or affirmed) and subscribed beiore me this swear or affirm that the facts set iorth in day of the foregoing complaint and attachments . thereto are true and correct to the best oi 20 by 3 my knowledge and belief. Public - Slate Ill Flam}: I My Comm. Elpiiu AW 15' loll (Prinl, CE FORM 5o_E,,eme Jammy 9' 2m, Personally Known OR Produced Identification 4 incorporated by relerance in Rule 34-7 moultbi A Type of Identification Produced: 14. (name of person making statement) IGNATURE OF COMPLAI NANT Notary Public) 3. STATEMENT OF FACTS This complaint concerns a city council member whose vote to approve a site plan for a new 7-Eleven service station violated section 112.3143 of the Florida Statutes concerning voting con?icts of interest. A. Parties Sam J. Saad has been a member of the Naples City Council since 2010. He is the principal of the Law of Sam J. Saad, One of the ?rm?s primary practice areas is real estate law.I Pikus Property Management and its owner Matthew Pikus are clients of Saad?s law ?rm. Pikus manages property in the Naples, FL area.2 Saad?s law ?rm handles evictions, contracts, and other legal work related to the prOperties Pikus manages.3 One of Pikus Property Management?s clients is Axonic Capital, LLC.4 Axonic Capital is 'x a a New York based investment advisor, which owns many prOperties in the Naples areas-J Jonathan Shechtman is the portfolio manager for Axonic?s southeast division."l J.- - Axonic Capital manages an investment vehicle called the Axonic Residential Fund I, LP.7 This ?md holds its Naples investment properties through a land trust agreement.8 The Trustee of the trust is Florida Rental Specialists, LLC, and Saad?s law ?rm is the Successor 1 See Saad?s website at (accessed February 27, 2017). 2 See Pikus? website at (accessed February 27, 2017). 3 Exhibit A. 4 See Exhibit B. 5 Id. 6 See Shechtman?s business bio at shechtman-new?york-city-ny (accessed February 27, 2017). 7 See Exhibit c. 3 1d. Trustee.9 Through the trust, Axonic Capital controls a company named 499 Goodlette Road, This company owned a property located at 499 Goodlette-Frank Road North, Naples, FL 34102. A con?ict of interest arose for Saad when Axonic Capital, through a subsidiary, sought permission from the Naples City Council to redevelop this property. B. Voting Con?ict On May 18, 2016, the Naples City Council was asked to approve a site plan for Axonic Capital?s property at 499 Goodlette-F rank Road North. This was Agenda Item 15 for the May 18 Naples City Council meeting.II The petition sought to demolish a vacant gas station and construct a new 24-hour 7-Eleven service station.12 The petition also asked the City Council for a deviation from the local code so that the station could exceed the maximum allowable gross floor area for the sale of cold drinks, package foods, tobacco, and similar grocery goods.l3 It further sought conditional approval to construct the station in a general commercial zoning district.14 The City Council took the matter up in a quasi-judicial proceeding.? Saad did not recuse himself.H5 Indeed, he made the motion to approve the resolution and cast the deciding vote to 9 Id. '0 See Florida Division of Corporation?s registration at (accessed February 27, 2017). See Exhibit See Exhibit F. ?6 Id. approve Axonic Capital?s request.? His participation violated the voting con?ict of interest law codi?ed in section 112.3143 of the Florida Statutes. Axonic Capital was an integral party to the petition requesting approval of the site plan from the City Council. Indeed, without approval from the City Council it is likely that Axonic Capital would have lost its lucrative deal to sell its land to 7-Eleven. Saad was well aware of this situation, as his law ?rm was the successor trustee to the trust that controlled the property issue. Further, Axonic Capital?s property manager, Pikus Property Management, was a signi?cant client of Saad?s law ?rm. Accordingly, Saad knew that approval of the site plan would inure to his special private gain. Indeed, a citizen, Emily Thoemke, raised Saad?s con?ict of interest during public comments. Section of the Florida Statutes required Saad to disclose his conflict and prohibited him from voting on the matter. In addition, Saad knew that the proposed site plan would inure to the special private gain of a principal by whom he was retained. Pikus Property Management managed several properties for Axonic Capital?Saad handled the legal work for Pikus related to these properties. Thus, Saad knew that his law ?rm?s client, Pikus Property Management, would bene?t from his vote to approve the site plan. Accordingly, under section 1 Saad should have disclosed his interest in the matter. C. Conclusion For the foregoing reasons, there is ample basis for the Commission on Ethics to investigate if Naples City Council member Sam Saad violated Florida law when he voted to approve Agenda Item 15 at the May 18, 2016, Naples City Council meeting. I7 1d. 'Lajl AXONIC (1 A l? TA l. la AGREEMENT THE 311ansz PROPERTY MANAGEMENT AGREEMENT (the is made effective as of the 31"Day of July, 2015 .by and between Wmifrcd Row, LLC with its principal placeof business at 5290 Golden Gate Pkwy Naples, FL 34116 (hereinafter, and Films Property Management, LLC, a 'Florida limited liability company with its principal place of business at 5296 Golden Gate Pkwy, Naples, FL 34116 (hereinafter, APPOINTMENT AND ACCEPTANCE. AMP 11 appoints Pikus'as exclusive .manager of the property described in Section 2' of this Agreement, and Films accepts the appointment, subject to the ternss and conditions set forth in this Agreement. 2. DESCRIPTION OF THE PROPERTIES. The properties to be managed by Pikes under this Agreement (individually,- a ?Propert? (together, the ?Properties? ?are dmcribed on the attached Schedule A, which shall be maintained and updated by Films and tfansmitted to ARAF II on a regular basis. For purposes of maintaining Schedule A, Piltus shall provide-access to ?lms?s online' property- manegement softwares?uch that ARAF II can gain Teal-time information regarding the properties under management. 3. MARKETING. Pikes will'ca'rry out the marketing activities designed to attract ienants as described herein. 4. RENTALS. Films will of?n- for rent: and will rent thelProperiies. Incident thereto; the following provisionswill apply: a. Film: will show the Properties to prospective tenants; Axonlc Capltal LLC 390 Park Avenue, 15?? Floor I New York! New York 10022 (212) 259-0430 DECLARATION OF TRUST THIS TRUST AGREEMENT. dated this l3? day of December 2012. and ts known as the 2349 41' Street SW Land Trust, certi?es that under the Laws and Statutes of the State of Florida. Florida Rental Specialists. LIL. a Delaware limited liability company. whose current mailing address us 3050 Horseshoe Drive N. Suite 154. Naples FL 34104 is about to take ode to real estate. real estate debt instruments. real estate contracts. leases or options as described in the schedule attached hereto and identi?ed as Appendix 1 hereunder; and that when It has taken otle thereto. or to any other qualifying property conveyed to it as Trustee hereunder. will hold It and the proceeds. pro?ts and avails thereof. if any which may come late It: possession by dtrectton of the Bene?ctary or Bene?cianes.or othersin whom the Power of Direction has bren duly vesred b) said Bene?aary or Benc?cianes. who. in combinatiort. have the right of direction incident to not less than a 51% bene?cial interesr herein or by speci?c terms hereof. in Trust. ftir the ulomate use and bene?t of the named persons or entities according to their respective interests as set forth below. When the Trustee has taken title to that Property. or to any other qualifying property conveyed to him as Trustee under this Agreement. it will hold the title. or trust. for the uses and purposes and subject to the terms and conditions as hereinafter set forth. and. It is further the intent of the Trustee to take title to the Property In accordance with the provisions of Section 689.071 . Florida Statutes; and. The Trust created by this instrument shall be known for all purposes as the 2349 41? Street SW Land Trust. NOW. THEREFORE. in constderation of the mutual premises herein ErmtaJl'lCd the parties hereto agree as follows: 1. m. Title to the Property shall be conveyed to the Trustee in accordance with and the rights of the parties shall be governed. to the extentapplicable. by the prowstons of Section 689 071. Florida Statutes. The Trustee agrees to accept the deed to the Property and to cause satd deed to be recordedin the Public Records of Collier County. Florida. and to hold title to the Property for the uses and purposes herein stated The Beneficiaries shall advance to the 'l'mstee all monies required by the Trustee to record said deed including. but nor limited to. all appropriate documentary stamp taxes. The Bene?ciaries may not dedicate or cause any other property to be conveyed to the 'l'rustee under this Trust Agreement unless the Trustee consents thereto in writing. Should other property subsequently be ccmveyed to and held by the Trustee pursuant to this Trust Agreement. the term ?Property? as used herein shall mean and refer to all property. the title to which is held by the Trustee pursuant to this Trust Agreement. This Trust Agreement is Identi?ed as the 2349 41" Street SW Land Trust. 2. W. The names, addresses and of the Initial Bene?ciaries of this Trust. are described in the schedule attached hereto and identi?ed as Exhibit A. The interestof the Bene?ciaries shall consist solely of the following rights respecting the trust property a. Power to direct the Trustee to deal ode to die Property. which power shall include. but is not limited to. directions to the Trustee to execute deeds. leases. mortgages. promissory notes and all other instruments relating to the Property. provided. however, as set forth in paragraphs 12 and 22 of Trust Agreement. the Trustee shall have no individual liability whatsoever nor shall the Trustee be required to furrush any warranties that would tesultin any uidividual liability in regard to the execution of any such instruments. h. Power to manage. possess. use and control the Property. c. Right to receive the comings. avails and proceeds from leases and other uses and from mortgages. sales and other dispositions of the Property. d. all rights and pnvileges regarding the Property as if the Bene?ciaries were the legal and equitable owner of the Property Such rights and powers, as well as the interest of the Bene?cranes under the: Trust Agreement. shall FXHIRIT proceeds from rentals or sale. 13. The Trustee shall be under no duty to take any action. to pay any money or to incur any expenses in regard to any legal proceeding involving this Trust Agreement or the Property unless it shall elect. in its absolute discretion. to do so and be fumished with suf?cient funds or be indemni?ed to its satisfaction by the Bene?ciaries If the Trustee is served with process or notice of?egal proceedings or of any other matters concerning this Trust Agreement or the Property. the sole duty of the Trustee shall be to forward the process or notice to the bene?ciary as provided in paragraph 30 hereol.in such case' the Bene?ciary may defend said action in the name ofthe Trustee with counsel reasonably acceptable to the Trustee provided. however. the Trustee may at any time resign as such under this Trust Agreement or personally appear in said proceeding 14. WWI-0W The Trustee may resign at any time by giving ?rst class mail written notice [or current or electronic mail if known) of such intention to resign to the Bene?ciaries and to anyone with the power of direction to the last address made known to the Trustee. a notice of its tntenoon so to do. In the event of such resignations. if the Successor Trustee or Successors that are named in the Declaration of Trust. or if none are named or a Successor or Successors appointed by a maiority of those with the power of direction shall direct the Trustee as to the disposition of the Trusr property by an instrument in writing lodged thereupon with the resigning Trustee. having endorsed thereon the acceptance of such Successor; and thereupon the resigning Trustee shall room the Trust property to such Successor or Successors Trustees. The resignation shall become effective after the Trustee shall have executed any and all documents furnished to the Trustee by the Bene?ciaries and satisfactory to the Trustee for execution. which documents shall be for the purpose of conveying to any successor trustee all existing rights of Trustee under this Trust Agreement and title to the Property provided, however. that in all events said resignation shall become effective no later than seven (7) days after notice of resignation has been delivered to the Bene?ciaries and anyone with power of disccdon. il'applicable. 1f the Trustee is advrsed tn writing by the Bene?ciaries as to who the successor trustee is to be. the Trustee shall prepare. execute. deliver and/ or record any and all documents which are necessary in the absolute discretion of the Trustee to convey or transfer title to the Property to such successor trustee if notice of the successor trustee is not given to the Trustee in writing within thirty (30) days after notice of resignation has been delivered to the Bene?ciaries or if the Bene?ciaries fails to furnish documents satisfactory to the Trustee for execution within twenty (20) days after notice of resignation has been delivered to the Bene?ciaries. the Trusree may convey title to the Property to the Bene?ciaries (and if more than one. then in accordance with the respective interests of the Bene?ciaries as set forth in paragraph 2 of this Trust Agreement. as amended).and the deed of conveyance may be recorded by the Trustee. the resrgnation by the Trustee as provided herein. the Bene?ciaries shall upon such resignation irttalediately pay to the Trustee all payments. advances or expenses made or incurred by the l?rustr-r. in regard to this Trust Agreement or the Property and the Trustee shall continue to have a lien on the Property to secure the payment of such sums as set forth in paragraph 12. which senior lien the Trustee may evidence by causing to be recorded in the Public Records of Collier County. Florida. a notice of lien specifying the amount of monies owed to it by the Bene?ciaries. The Trustee may thereafter enforce its lien against the Property by appropriate judicial proceeding and. tn said proceeding, the Trustee shall be entitled to recover from the Beneficiaries. and the same shall be a lien on the Property, all its costs and expenses. including attorney's fees, in such proceeding. In the event that the Trustee is an indivtdual and not a corporation. then. upon the death or incompetence or inability of the Trustee. the successor trustee shall be the following Sam Said Ill. PA. whoa current business address is 851 5th Avenue North. Suite 306. Naples. FL 34102. then such other person or entity as designated by a majority of the bene?ciaries Notwithstanding the fort-going. the decision to transfer ride to a different trustee or different order of trustees from that as set forth above shall be determined solely by bene?ciaries or other persons who. in combination. hold the power of direction incident to not less than 51 of the bene?ts-t] interest in this rust. The recording in the public records of Collier County. Florida. of a death certi?cate for any trustee under this Trust Agreement shall be deemed a conveyance of title to the Property to the successor f? EXHIBIT A The following are the inith] Bene?ciaries of tins rust.and such shall be to all of the earnings, avails and of the trust property according to the percentage Interest set forth opposite his name: Wm Axonic Residential Asset: Fund 1. LP 100% Undl vidcd Interest 489 Fifth Avenue. 31" Floor New Yes-k. New York 1001'! FXHIRIT APLES CITY COUNCIL AGENDA MEMORANDUM I. .I I .. . Regular Meeting Date: May 18I 2016 Agenda Section: Prepared By: Erica J. Martin. MPA. AICP. Senior Planner Regular Department: Planning Agenda Item: Legislative Quasi-Judicial 15 SUBJECT: Resolution determining Site Plan with Deviations Petition 16-SPD1 for property owned by 499 Goodlette Road. LLC and located at 499 Goodlette Frank Road North. SUMMARY: City Council is asked to consider a Resolution determining Site Plan with Deviations Petition 16- SPD1 approving a convenience store and gas station with a deviation from Section to exceed the maximum allowable gross ?oor area for the sale of cold drinks. package foods. tobacco and similar grocery goods; determining conditional use approval pursuant to Section 58-593(10) to allow a gasoline service station in a C-2 General Commercial Zoning District. for property owned by 499 Goodlette Road. LLC and located at 499 Goodlette Frank Road North. In that this is a quasi-judicial matter. the swearing in of those giving testimony is required. BACKGROUND: The petitioner wishes to demolish the existing structure and construct a new 7?Eleven gasoline service station comprised of approximately 3.000 square feet of convenience store space and 12 fueling stations beneath a new 3,000 square foot fuel canopy. This property is approximately 0.89 acres. or 38.777 square feet and currently contains a 6,785 square foot one-story multi-unit commercial building. Previously. a gasoline convenience store occupied one of the units and gasoline pumps were located in front of the store. The pumps have since been removed. The combined structures will occupy less than 16% of the total area of the property. The petitioner has received administrative Site Plan approval and preliminary Design Review Board approval for the proposed development. Section 58-593(10) of the Code of Ordinances provides that gasoline service stations require conditional use approval within the CZ. General Commercial district. The proposed gasoline service station is consistent with the Conditional Use criteria set forth in Section 46-34(d) of the Code of Ordinances. Section 56-124 of the Code allows for the sale of cold drinks. package foods. tobacco and similar grocery goods for ?lling station customers. as accessory and incidental to principal operation. provided that the area devoted to this use shall not exceed 50 percent of the gross ?oor area of the service station. This Section also provides the services permitted by gasoline service stations including the repair and maintenance of vehicles. The proposed 7-Eleven station will operate as a convenience market. focused primarily on the retail sale of gasoline. cold drinks. package foods and other convenience items and will not operate as or include the more intense uses associated with an automobile service station. The Petitioner is requesting a deviation to allow for 100 percent of the station to be devoted to retail sales of food. beverage and other convenience items. This request is EVLIIDIT l"l CITY AGENDA MEMORANDUM Ili'g -- Regular Meeting Date: May 18I 2016 Page Two Agenda Item: 15 BACKGROUND (cont): consistent with the modern standards of gasoline station and convenience store programming and is more compatible with the adjacent residential uses. The Planning Advisory Board heard this item at their April 13. 2016 meeting and voted 3 to 1 to recommend approval of the Site Plan with Deviations request subject to the conditions in the Resolution. File Reference: 16-SPD1 Petitioner: 7-Eleven. Inc. Location: 499 Goodlette-Frank Road North Zoning: 02, General Commercial; CRA District; Corridor Management Overlay District PUBLIC NOTICE: On March 29, 2016 a total of 52 letters were mailed to all property owners located within 500 feet of the subject property. As of the date of this report, staff has received no written responses to the mailing. Staff did receive a telephone call from Mr. Willie Anthony. resident of the adjacent residential neighborhood. Mr. Anthony expressed his objection to this proposed development and his concerns about the 24 hour operation of the service station, the inclusion of 12 gasoline pumps on the site. and the threat to pedestrian safety. Mr. Anthony questions the feasibility of trucks entering/exiting and maneuvering within the site and the potential consequences of having a busy gasoline service station at the entrance to a neighborhood that has only one way in and out. Mr. Anthony stated that he does not believe that this is the proper location for the proposed gasoline service station. Other speakers at the Planning Advisory Board expressed similar concerns. RECOMMENDED ACTION: Approve a Resolution determining Site Plan with Deviations Petition 16-SPD1 approving a convenience store and gas station with a deviation from Section to exceed the maximum allowable gross floor area for the sale of cold drinks, package foods. tobacco and similar grocery goods; determining conditional use approval pursuant to Section 58-593(10) to allow a gasoline service station in a 0-2 General Commercial Zoning District, for property owned by 499 Goodlette Road, LLC and located at 499 Goodlette Frank Road North. subject to the conditions in the Resolution. Reviewed by Department Director Reviewed by Finance Reviewed by City Manager Robin D. Singer NIA A. William Moss City Council Action: WW COLLIER COUNTY CLERK OF COURTS WEBB Case List By Attorney Wand-Smith Naples FL 34112 Cases Filed Between 12/01/2012 and 12/19/2016 Phone?: 2399631635 Attorney: Lupo, David Todd . 51?s is?! Filed: 02/17/ 2015 Brodie, Lauren CA25 Homestead Residential Foreclosure $250,000 or more Defendant: Kirkpatrick, Catherine Event: 06/15/2015 Cover Letter Disposed Filed: 02/17/2015 Brodie, Lauren CA25 Homestead Residential Foreclosure $250, 000 or more Defendant: Kirkpatrick, Steven Event: 06/15/2015 Cover Letter Disposed Filed: 02/20/2015 Carr, Milie CC04 Evictions Plaintiff: Fairhomes Pearl Properties Uc Successor in Event: 06/22/2015 Return of Service of Writ of Possession Interest To Fairhomes Silver Linings Properties 11-2015-cc-000326-0001-n Disposed Filed: 02/27/ 2015 Crown, Rob CC04 Evictions Plaintiff: Lewis, Franklin Event: 06/22/2015 Correspondence to Court, from Counsel - Hearing Package For Plaintiifs Motion To Dismiss And Motion To Permit Discovery 11-2015-CC-000547-0001-xx Disposed Filed: 04/06/2015 McGarity James CC04 Evictions Plaintiff: Pulkownik, Patricia Event: 05/ 18/2015 Final Judgment on Pulkownik, Charles Recorded 2015-05-19 5123862 11-2015-CC-000626-0001-XX Pending Filed: 04/24/2015 Martin, Janeice CC04 Evictions Plaintiff: Grant, Torn Event: 05/05/2015 Correspondence to Counsel from Clerk Pending Filed: 04/24/ 201.5 Martin, Janeice CCM Evictions Plaintiff: Grant, Toni Event: 05/05/2015 Correspondence to Counsel from Clerk 11-2015-CA-000681-0001-XX Pending Filed: 05/13/2015 Hayes, Hugh 0 Contract and Indebtedness Plaintiff: Holtan, Mathew Event: 09/23/2016 Request for Production 11-2015-CC-000734-0001?i0i Disposed Filed: 05/15/2015 Crown, Rob CC04 Evictions Plkus Pro Mana ement Event: Return of Service of Summons on Andrelie, Abelard, posted 09/02/2015 (?l/guts MM melee, Disposed Filed: 05/21/2015 McGarity Ill, James CC04 Evictions Plaintiff: Fairhomes Silver Linings Properties Event: 07/01/2015 Return of Service of Writ of Possession Printed: Monday, December 19, 2016 12:58 pm Page 7 COLLIER COUNTY CLERK OF COURTS Wm!) Case List By Attorney Naples FL 34112 Cases Filed Between 12 01 2012 and 12 19 2016 I . I I Phoneil: 2399631635 Attorney: Lupo, Davrd Todd mupnmaar?egamnm -. -. - r'T" :1th: ?1 I 1. .1 7? 111.131sz "Rf-11' 151111;;3112. ?31.3- Filed: 05/11/2015 Brown. Michael .I CC04 Plaintiff: Naidof Private Series 1 Lic Event: 06/22/2015 Notice of Voluntary Dismissal Ramirez. Franckiin Hernandez?arcia, Yadira Estrada.Hernandez, Daili 11-2015-CA-001131-0001-XX Reopen Filed: 06/23/2015 Brodie. Lauren CAZB Non-Homestead Foreclosure $250,000 or more Defendant: Queens Park Community Services Event: 06/03/2016 Disburse - Registry Association Inc 11-2015-CC-001047-0001-KX Disposed Filed: 07/ 15/2015 Crown, Rob CC04 Evictions Plaintiff: Hansen, Courtney Event: 11/ 16/2015 Disburse - Registry 11-2015-CA-001594-0001-XX Disposed Filed: 08/ 26/2015 Hayes, Hugh 0 CAB Negligence 1 Construction Defect Defendant: Inc. Martinez Lawn Maintenance Event: 10/21/2016 Final Disposition Form Disposed Filed: 09/24/2015 Carr, Mike CC09 Small Claims =1 $2500 up to $5,000 Plaintiff: Paradise Coast Title And Escrow Ll: Event: 05/02/2016 Order of Dismissal Recorded 201605-03 Instrumentll 5260479 Disposed Filed: 09/28/2015 Shenito, James CA24 Homestead Foreclosure $50,001 - 5249.999 Defendant: Maria I. Ramirez Event: 10/06/2016 Cancelled Foreclosure Sale on 10/13/2016 11:00:00 AM due to BANKRUPTCY Reopen Filed: 10/14/2015 Crown, Rob CC04 Evictions Plaintiff: Ll; angm Management E27: 01/14/2016 Return of Service of Writ of Possession a I 1 ?lm Zia, Disposed Filed: 10/20/2015 Marlin,.laneiceT CCU-4 Evictions Plaintiff: itus Pro Mana eme Event: Notice of Voluntary Dismissal 01 (260 MW 11-2015-CA-001956-0001-xx Pending Filed: 10/23/2015 Shenko, James can Non-Homestead Foreclosure $250,000 or more Defendant: Cheriel, Heather Event: 12/09/2016 Notice of Service of Responses To Request For Production 11-2015-CA-001956-0001-i0t Pending Filed: 10/23/2015 Shenko, James CAZR Non-Homestead Foreclosure $250,000 or more Defendant: Cheriel, Shamid Event: 12/09/2016 Notice of Service of Responses To Request For Production Printed: Monday, December 19, 2016 12:53 pm Page 8 ol Pending Plaintiff: Becker, Ben 11-2015-CA-002126-0001-XX Disposed Plaintiff: Chrome Capital Disposed Plaintiff: Pikus Property Management Uc Pending Defendant: Sa ntuchi, Ismael Pending Plaintiff: Moorman, Mark I Pending Plaintiff: Pikus Property Management 11-2016-CC-000384-0001-XX COLLIER COUNTY CLERK OF COURTS Case List By Attorney Cases Filed Between 12/01/2012 and 12/19/2016 Attorney: Lupo, David Todd 1' ?pr I- 1 P1. Filed: 11/17/2015 Carr, Mike Event: 211m Lupu, uavru IWH Donn $9.5m Law Of?ce Of Sam .1 Seed Pa 2670 Airport Road South Naples FL 34112 Phone-ll: 2399631635 Dlupo@Saadlegal.Com 3.1-: n. A Evictions Event: 10/10/2016 Motion For Finalludgment - Damages - Denied Without Prejudice Filed: 11/24/2015 Hayes, Hugh 0 CA45 Other Circuit Civil Writ of Repievin Event: 08/04/2016 Cancelled Hearing on 9/4/2016 1:30:00 PM due to per Judge's calendar Filed: 01/14/2016 McGarity Ill, James Evictions Event: - Correspondence to Plaintiff, from Clerk Filed: 01/20/2016 Provost, Michaell CC04 Evictions Event: 10/09/2016 Notice of Appearance by Hurchalia, James Joseph for Angela Charles Filed: 02/04/2016 Hayes, Hugh CAZQ Other Real Property Action $0 - $50,000 Event: 03/02/2016 Notice of Default Not Entered Filed: 02/09/2016 Brown, Michael C695- - Evictions Correspondence to Plaintiff, from Clerk Pending Filed: 03/10/2016 Martin, Janeice 1? C02 County Civil Plaintiff: Springwood Condominium Association of Event: 10/ 17/2016 Answer by Merrie Killian Naples Inc Pending Filed: 03/10/2016 Hayes, Hugh CA29 Other Real Property Action 50 - $50,000 Plaintiff: Moorman, Mark! Event: 07/29/2016 Affidavit of Publication for De Cardenas, Xavier Cardenas, Mateo A, published 07/08/2016 11-2016-CA-000467-00011XX Pending Filed: 03/10/2016 Shenko, James Contract and indebtedness Plaintiff: Sam 1 Seed Pa Event: 07/25/2016 Notice of Default Entered to Foreclosure Solutions Uc Disposed Filed: 04/04/2016 Crown, Rob CCO4 Evictions Plaintiff: Lolly, Beth Event: 05/05/2016 Return of Service of Writ of Possession Printed: Monday, December 19, 2016 12:53 pm Page 9 ol Vanadium/WEE a-L?s Filed. 08/23/2016 COLLIER COUNTY CLERK OF COURTS Case List By Attorney Cases Filed Between 12/01/2012 and 12/19/2016 Attorney: Lupo, David Todd Lupo, David Todd Bare: 181640 Law Of?ce Of Sam Saad Pa 2670 Airport Road South Naples Fl. 34112 Phoneii: 2399631635 Dlupo@Saadlegal.Com Shenlro, James CAPS Homestead Residential Foreclosure $250 000 or more Defendant: Gray, Carolyn Event: 12/08/2016 Home Equity Addendum 11-2016-CA-001683-0001-XX Pending Filed: 09/20/2016 Shenlio, James CA06 Condominium Plaintiff: Springwood Condominium Association Of Event: 10/14/2016 Answer by Shane Shadls Naples Inc 11-2016-CA-001736-000bxx Pending Filed: 09/28/2016 Shenko. James Contract and Indebtedness Defendant: Smith, Errol JR Event: 12/07/2016 Order Granting Continuance - Date to be Determined Pending Filed: 09/28/2016 Shenko. James Contract and Indebtedness Defendant: Tri Pillar Contractors Uc Event: 12/07/2016 Order Granting Continuance - Date to be Determined Disposed Filed:09/ 28/2016 Provost, MichaelJ CC04 Evictions Plaintiff: Pikus Property Management Event: 12/02/2016 Return of Service of Writ of Possession Disposed Filed: 10/06/2016 Provost, MichaelJ C009 Small Claims 3? $2500 up to $5,000 Defendant: Scudeletti Alabba, Tina Event: 11/23/2016 Case Transferred] Do Not Docket in This Case Pending Filed: 10/10/2016 McGarity James CC04 Evictions Defendant: Capalbo, Matteo Event; 11/22/2016 Notice of Filing 11-2016-66?001529-0001-l0t Disposed Filed: 10/ 14/2016 Martin, Janeice Evictions Plaintiff: Pikus Property Management Us Event: 1mg, Cover Letter 11-2016-CC-001696-0001-XX Pending Filed: 11/14/2016 Brown, MiChael CC02 County Civil Plaintiff: The Shores At Berkshire takes Master Event: 11/28/2016 Return of Service of Summons on Wells Fargo Bank Na,. served 11/22/2016 Homeowners Association Inc Pending Filed: 11/22/2016 Brown, Michael .I CC02 County Civil Defendant: Scudelettl Alabha, Tina Event: 11/22/2016 Fees Paid or Waived for in Collier Transfer Printed: Monday, December 19, 2016 12:58 pm Page