Filing 61210013 E-Filed 08/31/2017 03:20:23 PM lN THE (.EOURT OF THE .3 .iTi-l. JUDICIAL CIRCUIT IN AND FOR MIAMLDADE NTY, FLORIDA CASE. JESUS FERNANDEZ. JR. and FERNANDEZ Plaintif?, v. JERRY ALTON HOST EL, 21 Florida Limited Liability Corporation; PALWELL. 111; REBECCA T. and INN. a Florida Limited Liability (forpnraiion; 13 ?303.11 {l ants. COMPLAINT FOR DAMAGES NOW, the Plaintiffs. JESUS FERNANDEZ. JR. {?Jesus In") and .l 1?81? FERNANDEZ (?Jesus Six") (collectively, the ?Plaiuliil?fs??, by and ihrough the undersigned counsel and hereby sue. the Defendants, JERRY GIANCARLO ALTON HOSTEL. a Florida Limited Liability Corporation; PALWELL. REBECICJA T. and COMEBACK INN. a Florida limited Liabiliiy Corporation. (collectively, the ??Deibndanis?) and allege as 1. This Cmnpiaiut suckx damages in excess nf $15,000.00 excluding attorney?s fees and cosis. 2. This is an action to this action. Defendant. JNN, LLC was and is a limited liability company organized and exisiing {Hider the laws of the Suite (run av vw?w-m - 1--'erum1dez v. .F alwell Cmriplaim Page 2. of Florida with its princip for Breach of Contract. Fraud. Fraud in the: lnducemcm, and Unjust Eu ti . 3. This 00:1 has subject matter jurisdictiun uver this action as. it lies in Law and Equity. 4. Plaintiff?s, Jesus Jr. and Jesus Sr. use individuals. sui juris. who reside in Miami- Dadc County. Flurida. 5. Al all times relevant to this action, Defendant. ALTON HOSTEL, LU: {?Altun was and is limitcd liability company organized and existing under the laws of ihe Stale of Florida will} its prinuiml place of business in Miami-Dacia County. Alton Hostel was set up in Fuhmary? of 201.3. and its current managersunembem are GIANCARLO (WANDA (?Granda?) and FALWELL, ill {_?Trcy Falwell?). Alton Hostel is actuali}r a business entity created by JERRY FALWELL, J'r. (?Falwell and REBECCA T. (?5111's. Falwell") with the apparent intent in bene?t offGranLla. 6. At all times relevant ui place of business in Miami-Dude County. 7. Venue is alsu proper in MiamiirDade County, Fluridu as the claims alleged herein accrued in Miami-{Jade County. Florida- (3 ERAL ALLEGATIONS 8.. On or about March of "1012, {Iirunda was working as a pool atmndunt at the Funtainebleau. On 01' about the same time. Falwell Jr. and Mrs. Fab-vol}, were guests at the hotel. Falwell and Mrs. Falwell later developed ?130 a frimully raiutiouship with {'irrundu. As the nIleMIM-mulwmy-u- .. Fernandez v. Falwell Complaint Page 3 relationship evolved between Falwell Jr. And Mr?. Falwell, verbal ohm were made to Chanda to provide him wilh financial assistance. 9. Granda weni to his close friend at the lime, Jesus; Jr., and advised him about line various uffers made by and asked Jesus Jr. for advice and guidance. ii). In the months, as the relaticnship Falwell, Mrs. Falwell and Gmnde ccntinued ic cvelvc, Chanda was ?own around by the Falwells in {heir privatejet in a jci by Liberty College), Falwell Jr. repeated various offers to Granda and indicated that he wanted to help Glenda establish a new career and build a business. l. Falwell 31'. felt! Uranzia to search for a pro?table business idea and promised the: he would purchase. finance andx?or establish this new business for Chanda. 12.. Initially. Granada suggested an. internet investmenl?ln Falwell 112., but Falwell Jr. rejected this idea, and mid (Brande :0 ?nd a diflercnt business that inveived and included a real estate cun?iponent. 13. in light all the {net that had no prior experience. training knowledge in the real estate er business; development field, (iram?la 013120 again sought advice and. guidance lium Jesus .lr. Grumln asked Jesus Jr. To seek the assistance cfhis father. Jesus as Jenna Sr. was very experienced in real estuie ventures. 14. Jesus Jr. was also privy to information regarding the and. management of hostels located on Miami Beach? Jesus Jr. proposed to Grands: the cimccgit of purchasing and operating a hostel on Miami Beach. Grands: then asked Jesus Jr. to develop 21 real estate thai wnuld satisfy Falwell. J1: requirements. As Jesus 81'. had vast and Fernandez v. Falwell Complaint Page 4 successful experience as a reel estate investor and developer, Gl??ild? wanted to coordinate a business proposal that would secure Falwell. Jr.?s financing. ii. in an ef?irt to secure Jesus Jr, And Jesus development of the business proposal and concept. Granule Offtif?fd to grant Jesus: Jr. and Jesus Sr. ?fty percent of (ji'aiida?s ownership and-"or financial interest in the Hostel business. it was further agreed upon. that Grands; would employ both Jesus Jr. and his girlfriend to run, [haulage and operate the hostel, 16. Relying on the promises and agreements with Uraeda. Jesus Jr. secured his father?s assistance and initiated the arduous; process of identifying and locating a property in Miami Beach which would best suit the new business venture. 17. Through the efforts of Jesus Jr. and Jesus the hostel located at 310 Alton Road was identi?ed. Jesus Jr. and Jesus Sr. their undertook all of the items-Fiery research and secured records For that hostel in order to present the business eoneept to ll?alwell Jr. 18. Grendel, Jesus Jr. And Jesus Sr. Then presented the business eoneept to Falwell, Jr. After presenting all ol'the infeniialiun, Falwell. Jr. agreed to finance the business venture. ll was also agreed that Jesus Jr. and esua Sr. would share ?fty percent nt? Granda?s ownership audior ?nancial interest in the Hostel busiue?ss. Falwell, Jr. Also agreed that Jesus Jr. and his girlfriend would be hired to run. manage and operate the hostel with Grendel. Falwell, Jr. 'l?heii authorized Jesus Jr. and Jesus Sr. To initiate contact with the hostel?s agent in order to visit the property and begin negotiations for the purchase of the. hostel. Fernandez v. Falwell (inmpiaim Page 5 19. As par Falwell, Jr's and Grand-3?s rcpresentationa promises and Jesus Jr. and Jesus Sr, contactcd jeans-rite Faciolincc and Roberto Bruchu, the real carats agents for the hostel foamed at 8 ll) Alton Rrrad, in Miami Florida. 20. As per Falwell, 312?s and Granda?s representations, promises and agreements, Jesus Jr. and Jesus Sr. introduced Falwell. Jr. to Jeanette: Patciolince and Roberto Bracho. {See Exhibit Af?davir ochancuc Facimlince and Exhibit Af?davit of Roberto Braclm}. 2l. Falwell Jr. represented to both Jeanette Faciolincc and Roberto Bruclro that he was looking its purchase a business in order {0 provide a source of li?lCOInt.? for Grandzl. Falwell 31?. also represented to both Jeanette l-?aciolince and Robc?o Bracho mat, Jesus Jr. had pmposed ihc purchase and managen?reni of" the $10 Alum Road pl?upel?tyr?h?stel. Falwell .lr. additionally to both Jeanette Faciolincc and Roberto Brachn that Jesus Jr. would rcce?vc ?fty pcreenl? {150%} ol?Cirandu?s ownership mulfur ?nancial interests in the new business. Falwell {unlit-r to both Jeanette Faciulince and Robe?n Brachn that Jesus r. be employed to assist in the managumcnt and operaiiun ol?ihc hostel. (Sec Exhibit A f?davil of Facioliucc and Exhibit Af?duvil of?RUberto 321143110). 22. Following the OE Falwell. Jr. to Falwell .711 L0 Jeanette Facinlmce and Roberto Bracho, negotiations were initiated which Zed to a for the purchase nf?the Alien Hostel. LLC by way of an inmum:dim?jr= Comeback LLC. Rebecca Falwell was identi?ed as the Mamger of Comeback, LLC. Cmucback, LLC iat?r assigned its contract In Falwell, Jr. and Aimn l-lostel. (See Exhibit Affidavit {Jul Jeanette Fucielince and Exhibit Af?davit of Robcrlo Brachu}. Femnndez v. Falwell Complaint Page ti 23. On or about February of 2013, Falwell Jr. purchased the hes-tel located at fill} Alton Road, Falwell Jt'. purchased the hestel through Alton Hostel and centrally to Falwell?s representations, promises and agreements, he initially identified only 'l?rey Falwell as the sale managing member of Alton Hestel. 24. Jesus Jr. and Jesus Sr. immediately questiened the failure by Falwell Jr. to abide by all ot'liis repeated premises and representations. Falwell Jr. assured both Jesus Jr. and Jesus Sr. that nothing had changed and that they wenld be receiving the promised ?fty percent of Granda?s ownership. Falwell Jr. explained that he would be amending the Articles of Organization for the Alton Hostel to add Glenda and Jesus Jr. 25. "l?hereafter, Falwell Jr. amended the Articles nl? Organization of the Alton Hostel but only added Clrandzt as: at managing member. 26. .lesue Jr. and Jesus Sr. repeatedly demanded that Falwell Jr, and honor their premises and ag?eements. l-lnwevet'. both Falwell Jr. and (Brenda failed. and re?ned to abide by their premises. agreement and contractual obligations. COUNT 1 BREACH OF Heintit'fs rte-allege paragraphs enc {ll through twenty ?ve (26}:15 above: The agreement between Plaintiffs and l?Jet?endente :13 set forth above is a valid and cnl?m'eeahle contract. '28. The Defendants. threugh the etc-lien 0f Defendant, Falwell J33, promised Plaintiff. e'sus Jr., ?fty percent (509-3) el? Grendn?s, :?iwnetship interest in Alton Hostel, LLC, Fernandez v. Falwell Complaint Page. 7 as well (15 positions ofomploymeut for Jesus .lr. and the girlfriend Mic-31.13 Jr. with Alton Hostel, LLC in return for bene?ts Plaintiffs conferred upon Defendants which were essential for the creation of Alton Hostel, 39'. Without the viral local real estate knowledge Plaintiffs offered in addition to the extensive time and cfl?bn Plaintiffs; expended to find the ideal location for Alion Hostel, Defendants would no: have haul access to such an exclusive and lucrative location for their business venmre. 30. Each of the Defendants had knowledge of the bene?ts confcn'ed upon them by Plaintiffs, and knew that Plaintiffs deserved fair paymcz?it for their extensive time, cf?fm?t?, and confen?dl of their real estate- expertise, which was to the. croation of Alton Hostel, LLC. El. Fog" this reason, promised Plaintiffs a signi?cant business opportunity in lhe form of partial ownership of Alton Hostel, LLC and managerial positions for Jesus Jr. and hi3 girlfriend within {he company, which was fair payment for the crucial bene?t Plaintiffs conferred upon the Dcl?endams. 33. Plaintiffs 'easonably relied on Del?endzints? portrayal of this agreement in choosing to licl Detoudams creaic Alton Hostel, LLC. 33. As a result of Plaintiftk' reasonable reliance on the agreement with Defendants, Plaintiffs rightfully expected appropriate payment for Lhe benefit they con?srred upon the mid acted accordingly 1- (n urnr .-u-u-u-u-m-u-m-wM-u-y - u- u-M- -.. Fernandez v. Falwell Complaint Page 3 34. However, as soon as l?iainlif?i pcrihrmed their part uf the agrcemau?r, Defendants brcachcd their part of the agreement. 35. left Plaintiff, Jesus J11, out of ?lm A?iclcs of Organization 01" Alton I-lustcl, as partial owner. and "if Per Employed Jesus Jr. in any managerial positions within the company. 36. When Jesus Jr. contacted Faiwcll Jr. and Chanda. to follm-v up on {his promise, Defendants assure-Li Jesus that in: he added as a partial owner in the AiTiclcs of Organization for Alton Hostel, LLC. 37. To date, Defendants. haw: not amended tha: Altiiflcs of Organization fur Afton I-lusiel. LLC to inciude Jesus Jr. as a partial owner, nor have the Defendants Tui?xu action {0 empioy Jesus: Jr. as a manager and uperatm's of Alton Hosici as promised. 33. Plaintiff?s huvu tried lime and again to enamel. Defendants to fix the Ariicics of Organization, so {but Jesus Jr. is iisied as :1 puma! owner, as; premised, but 1116 Defendants have wnlinuud in {hair breach ul?uli ul?tl?icir i'epresemutiuus, promises and agreements. 39. Accordingly. Defendants have lit-tiled to deliver mi their promise. broken their with Plaintiffs. and breached their contractual duties. 4-0. Delbudmus? breach of contract caused the: Plaintiffs to suffer signi?cant ccunumic and ?nancial losses, including but not limited to. loss of ownership value in the business, loss of a business uppuriunity their l?e?i csiaic expertise. inscs of the opportunity star? their own lucraiivc business. it! the prime lucaiiun may dis-smarter] fur Alton l"ea?nandez v. Falwell Complaint Page 9 Hostel using their local real estate expertise? and lost p?Sl and future wages pursuant to a reliance on employment by Alton Husicl, LLC. WHEREFORE, Plaintiffs JESUS R. and .llES LE3 FERNANUEZ requesi this l-lnnurablc ("nun {0 enter judgmem in {heir ?wur against Defendants, JERRY FALWELL CHANCARLO ALTGN a Florida Limited Liability Corporation; TREY FALNJELL. Ill; and a Flat-ids: Limited juintly and severally; for all mouetmy Losses, pcrmaaent and ongoing mammary damages, including cansequential damages, and any other relief this flammable Cour: deems jusz and appropriate. COUNT [1 FRAUD Plaintiff?s I?e-etllege paragraphs one through thirty eight [40} as above: 4L Each of {he Defenclanls intentionally and maliciously (.lc??umlcd the Plaintif?: by engaging in, cont?buiing to, and pro?ting the previously stated actions and 43.. Dcf*z1d21nls solicited and maintained a relationship of trust and CO??dcucc with Plainti?'S prior [u and during (1F Alum l-lnstel, LLC For the sale purpose ul? defrauding Plaintiffs out ol?thcir hard wuric and cuveied real estate. expertise. 43. Defendants proceeded to purposefully exploit this with Plaintiffs by inducing Plaintiffs to share their exmnsive of the local real estate- markel will: the Defmldams for each 01' the Defendants? personal pro?t. 1 Fernandez, v. Falwell Complaint Page l0 44. in rolying on Defendants? promise to adequately compensate Plaintiffs for their help in the creation of Afton Hostel, LLC in the form of business opportunities for both future employment in a managerial position and an ownership stake in Alton Hostel, LLC, Plaintiffs shared their real expertise, experience. and hard work with 45. lilciendants? fraudulent promise and misrepresentation than Plaintiffs would receive fair compensation and :1 new business opportunity in retum for Plaintiffs? help and real estate knowledge were intentionally made by .e?sndents with knowledge of their falsity to induce Plaintiffs to give Belinda-mt}; insider information necessary for the creation of Alton Hostel, LLC 46 Without Defendants? exploitation of their relationship with Plaintiffs to make Plaintiffs believe Defendams? fraudulent promise of fair payment Plaintiffs would not have spent their time and effort in helping form Alton Hostel, LLC: nor n-?ould they have given Defenoaul? their insider roal estate knowledge- As a result of fraudulent promise and misrepresentation, which Plaintiffs detrimeutolly rolled on. Plaintiffs have suffered and continue to suffer Signi?cant losses and damages. Plaintiffs chose not to open. up their own hostel or other real estate. venture in reliance of receiving an interest in Alton Hostel. LLC. Plziintii'ils have loot the bene?ts of having worked to obtain expert knoWledge of the local real estate iield by conferring that knowledge onto the Defendants who used this inlfonnation for their own ?nancial gain without repaying Plaintifl?i; for this crucial knowledge, Accordingly, Plaintiffs have lost current and potential husmess opportunities in the South Floiida real est-ate market by lending their exportiso rv-MW ?mu- Femandez v. Faiweli Complaint Page 11 the Defendants? company, Alton Husrcl. which was by the {Defendants as a Negative buainess and opportunity for the Plaimii'ff's. 48. l?luintiffs? reiiunce on Defendants' promise was a substantial cause OfPiaintiffs? losscs and damages. em. Each of the Defendants conu'ibutcd to or pro?ted from the lusscs and damages suffered by Piaimiffs as a result of Plaintiffs reasonabic reliance or: .?iisc promise, and, accordingly, Defendants should be required to pay damages, according to proof, in return Plaintiffs as; best as pussible to whute. WHEREFORE, Piaimif??; JESUS FERNANDEZ. JR. and JESUS request this Honorable to judgment in their favor against Defendants, JERRY FALWELL. IR: GIANCARLO GRANDA: ALTON Fluridu Limited Liability Carporation; I'll; REBECCA Ti and COMEBACK INN, a Florida Limited Liabiliiy Corporation, jointly and severally, for permanent and mguing damages, including consequential damages, and my other relief {his Honorable Court deems just axed appropriate. COUNT FRAUD IN THE INDUCE res-allege paragrz?tphs one U) through forty six {49) as above: um Fernandez v. Falwell Cowolainl Page. l2 30. Delhndatnts knowingly made a fraudulent promiae to Plaintifto which Defendants kitew was material to Plaintiffs" decision to provide their real estim: services foz' tho creation of" Alton Hostel, LLC. 51. Not only did Defondaots know that the misrepresentation they made in the fono of a promise of fair payment in return for Plaintiffs sewiceo was? material to Plaintll?l?s? to help Dcfondantsi Defendants rolled on this knowledge to induce l?laintiil'is to oonfor tho bene?t of their services on .Dohnclanto 52. Plaintiffs: would not have provided Belinda-lots with their real estate. services or conferred their local real estate knowledge on Gtanda absent catch of this knowing and intentional false representations of material fact in tl {Jolt?tidonts? promise to give Jesus Jr. partial interest in and employment with Alton Hostel, LLC. 53. Defendants know that the only way they would have access to the coveted local real estate knowledge they needed. to start their new, lucrative venture, Alton Hostel, LLC, was to promise l?lointil?lk that they would be adequately componaotcd in the form Ufa new business opportunity. 54. Plaintiffs roosionably relied on 'l'kfendmits? material misrepreoentations in making the docigsiz'm to provide their coveted real 05mm services and complete much of the necessary log? work for Alton HostoL LLC as a result of l?lointi?s? relatirmship of trust and con?dence with Defendants. 55. Defendants valued the minor increase in otmership shares of Alton I-lostcl, .LLC over their relationship with Plaintiffs: by knowingly making false promises to Plaintiffs knowing Fernandez Falwell Complaint Page 13 that. these false prmnises weuld induce l?luimi??s re sacrifice Their time, effort, and real esiate knowledge to help creme Alien Hoetei, demonstrating that Defendants solicited and initiated the relatii?msltip ell-trust and con?dence with Pia-iiniiffs with the sole intent ufdefrauciing Plaintiff?s from the start. 56:. By reiying on lkfendunts' pl??l?l'llSB To provide fait? and just payment in retain for Pluiniil?i's? conveyance ef their legal real estate knowledge time and effort, and guidance on Creating Alton Hostel, Plaintiffs have suffered losses as a result of not receiving the fair pawn-em promised to them by Delemlunts and agreed upon by bath parties. l3?laintifte? 1135305 and. injuries sustained as a direct result of {heir justi?able reliance (in the Defendant? fraudulent misrepresentation on" material feels in their proffered business opportunity: include but are not limited to, loss of a business oppormniiy with other pelemiel investors. financial hal'd?hlp? and less (if potential ?ztesre employment eppm?iunitles. WHEREFORE, Plaintiffs JESUS FERNANDEZ, JR, and JESUS FERNANDEZ request {his I'lonemble Court {0 enter judgment in their Fax-m against Defendants? JERRY f?ALlr'v?iiLL, GIANCARLO ALTON a Florida Limi?led Liability Corporazion; ?l'Rl'f?Y ill; T. FALWELL and COME-BACK INN, a Fiuridu Limited Liability Corporaiion, jointly and severally, for permanem and ongoing damages, including eensequentiai damages, and any other relief this Henombie Court deems just and appropriate. COUNT IV l} EN RECUMENT Fernandez v. Falwell Complaint Page 14 Petitioners re-ellege paragraphs one through ?fty three m: above: A5 a result of the conduct: described above, Defendants have been unjustty enriched at the expense of the Plaintiffs. 58. Defendants have full knowledge of the benefits; eoeth?red upon them by and the important rote those. bene?ts have played in the creation, success, and pro?tability of Alton lleStcl, .LLC. 59. Defendants not only knowingly retained the betitet?tts conferred by Plaintiffs, but actively solicited and induced the bene?ts f?rom Plaintiffs with tite assuraece of fair payment in return for those bene?ts. (50. It weuld be inequitable for Defendants L0 retain all of the monies, pre?ts, and gains they have obtained 01' will unjustly obtain in the future from Pleintiffs? conferred bene?ts without paying fair value For the bene?ts can l?en?ed upon them by Pleintif?st Accordingly, Defendants. Should be required to pay all memes. pro?ts, and gains, which the}! have obtained at will unjustly obtain in the future at the expense of Plaintiff?s. WHEREFORE Pieimif?; JESUS FERNANDEZ. JR. and JESUS FERNANDEZ lettuce-t this Court It) enter judgment in their fitter against Defendants. EERRY FALWIELL, GIANCARLD ALTON a Florida Limited Liability Corporation: 314153" FALWELL. ill; REBE-CCA T. FALWELL and COMEBACK INN, Hernia Limited Liability Curpm'atinn, junintly and severally. for pemtanent and engeing damages, including consequential damages. and any other reliefthis Ceurt deems jest and appropriate. Fernandez v. Falwc? Cumpiaim Page 15 DEMAND FOR JURY TRIAL- Plainliffs. JESUS FERNANDEZ, JR. and .EESUS FERNANDEZ, (161113136 a tried by jury of all so triabh: as of right by ajury. CERTIFICATE OF (3001) FAITH EREBY that a reamnahie investigatirm of?the events 3&1:ng in the Conzpmint has been mnducled {111d L?nui the investigatim} has given rise- to a faith basis 1?0 believe that gruumis exist for this aciion against each Defendant. DATED THIS 30121 day OI'AuausL 203?. DIAZ LA GROUP Santana Comer 1430 South Dixie Hwy, Suite. 3 13 Coral Gables. FL 33146 Direct Line: (3.05) 777-3501} BY: is? Roiundu A. Diaz ROLANDO A. DMZ PEN: 963.158 mm? . VERIFIED AFFIDAVIT 0F JEANN FACIOLINCE OF FLORIDA COUNTY OF I HEREE 3" SfEttC the foliowing: 1. My name is Jeanne: Facialince and I am a licensed 1123i estate Salespersen in the State of Florida 1 was an agent in the employment of Dorai Isles Risa! ifistate, a Fi?rida Limited Liability Corllpany. 3. Dora} isics Real Estate war; a. rca} estate broker business that was used by Jerry Falweii, Jr. in purchase a $195th {muted at $20 Aim-n Road in Miami "Beach, Ft: 4. i was the agent that, worker! with and was. engaged for the purchase of a imstel r6211 estate. venture. Dara} Isles Reai Estate was introduced tr; .erry' Pam-walle Jr. by 13311:: Fernandez and Jesus Fernanda; Ir. Dorai lakes Rea? Estate hat} wm?ked in the past with Jesus Fur-mama's in other rcai estate and business ventures. 6. Jerry Faiweii, 31', represented that he was looking to purchase a basins-33 in larder {0 provide 2r of income far (.iiancariu Gmnda. Jerry Falwell, 31'. indicated that Jesus Fernanda; Jr. had pr?opesad the purchase and management 01?11 Hostel. Jr was known If) me and reprcsem'ecl by Jerry; Falweli. Jr, that ha agreed to purchase and ?nance the hostel busintss concept, with {ha agreement rim: Jesus Fernandez, Jr, rmuld receive ?fty percem ra'f a Egan-or ream? A Af?dzmit oflanetic Rahal-to Braclw Page 2 Gianaarl? Granda's ownershi andinr ?nancial interest in the new business. 11 was illSt',? known and represented {hut Giusmm?lo Grasclu and Jesus Fernandez, 3r. be employ 1'0 assist in (he ryianagement and Operation of the. hostel. 7. Pursuant to the. agrees-zen: Wlill Jerry Falwell, Jesus Fernanda: and Jesus Fernandez. Jr. actively sought tn ?nd a in Mimnl Beach. Florida. Jesus Fa'rnzmi'icz and Jesus Fm'nundez, Jr. were the anus that {hand and identified The 8 0 Alma ROME Property and Hostel. Jesus Fernandez, Jr. was alsu the person that secured vzu?iuus ?nancial and business models for the successful operaiigm mi? a. hostel in Miami [36:34:11, Fluvial-a. 'l'l1e 310 Alton Road Property and Hostel were presented to Jerry Falls-veil, Jr. Jesus Farnandez was then ss?md to initiate contain and initial negotiaticms with {he seal estate agemfbroker for the 810 Alton Roar: and Haste}. ll. he. initial negotiati?ns led to a contract for the purchase the Alton Haslel, LLC by way of an intermediary, Comeback, LLC. Reba-20.21 Falwell was identified as the Manager cf Comeback. LLCT. Comeback. later assigted its contract to Falwell, Jr. and Alien Haste! . 9. "l'hrougliom the negatiations and of purchasing the 819 Mien Read Properly and Hostel, it was always by Jerry Falwell, .lr. that since Jesus Fernanda; 51'. introduced the hostel concept, and he was the person then investigated the {inane-i313 and business models for the business venture, that Jesus Fernandez, Jr. was going to be a pariner in the business with Grands. This representation and agl?eazmtni was furi?her cenl?u'med when Ferry Falwell, Jr. requested {hat iesus l??ez'nandcz assist in. The idcn?i?cmion of the idsal property for the hastel. as a means his son, Jesus Fernandez. Jr. 91'5? .M .. -. m?fzda?av'it 01511111211: 12111111110 1311131111 Page 3 10. The 311'} 1111011 Read and [10.11131 wen-1 purchased by #1111111 112151121, F?lm'ida [41111111 {3111111111 (-111111t1m1y. 2'11 {he time 111111 111 310 Alton Road [1111121211151 was 13111011113361, 3133?- .15 F121'11111'11'3c2" 11121111! (313111011110 (3121111111 were 11531111311 111111 1311:} 11011111 he 211211211 11.1:- Mem her/0111111215 1111111 the timing of 1111': sale. 1 1. 1111331111 to 1111: 1111111 111111 swear to 1111-: accuracy 01? the: contents 11115118 .11. Hick-M1. AF SAYETH I17 AU Sig! 311 ihis 2113111 (?113: 111" Selma-11111181. 33916. BEFORE ME. 15112 11111211310111. 21111111111111 this day, persormily appcared 18111111ch Facinl?nce Mm, after 11131111; {.1111}; sworn, dcposes and says that he has 1121111 the above and foregoing 2113111111111 1111:! 111111 he. has sci his 112111113 11111;! 312111 1111211310 113111143 uses and 1111111113123 therein expres 313d. AND SUB SCREBEZ be?arc 1116 {his 20?? claw of September 2016. by Jeannette 113 identi?cation. My {3.111111111535011 expires: 9 ?.mvaac?? ?9.cm 111,": .rE I +2 13113.7? vr_ ?4:13 .uu?u-?u-uunu AFFIDAVIT 0F BRACHO STATE OF FLORIDA OF I HEREBY mat: the following: 1. My name is Roberto Bl??Chi} and am a li cased real estate Salesperson in the State of Flm'ida. 2. I was one cf the Principles and Member Owner of 1.30mi 23163 Rea} a Finrida Limited liability Company: .3. Dm'?l Isle Real Estate, a Florida Limited Ljab?ily Cumpany was a real estate: broker business that was maxed by Jerry Falwell, Jr. in purchase :1 Hoswl lucated at 810 Aims} Read in Miami Beach, FL 4. Jeannette Falcioiince was on of D0133 Isles Raw: Estate and she was agent itssigncd to the: imnsaction, S. Dmal Real Estate was introduced to Jerry F111 sail, Jr. by 165113 Fernandez. and Jesus Fernandez, Ir. Dom] Isles Real Estate 12m} in the past wiih Jesus Fernandez in other real estate and business x-?cmurea. 5. Jerry Pam-E11, {cpresemed that he was {unkilng to purchase a business? 211 maim- to provide: a; source of incorm: for Giz-mcario Grands-L Jerry Fa?aweli, indicamd that .I?saus Fernandez, 31'. had {.n?aposed the purchase and management of a Haste}. It was Imam-m i0 me: and mpmaented by Jerry 11'. that he agreed to purchase mi {mm-ice the 3:091:31 business . a g: ?5 .. - A?idavi: of Facimiince Roberto Ea'aclw Page. 2 {20:104ch with {he agraerrmm? than Jesus Fernandez, 3r. would receive ?fty percent. ui? Giancarlo Grantla?s ownereihip andfor ?nancial iatereal in the new business. It was ?ier} known. and represented that Giancario Ggrauda and Jesus Fernandez, Jr. wouid be employ in asaiat in the managemeni and opal-alien of the ?3 Fur-sum! {0 the agreement with Jerry Fame?, In, Jesus Femmdez and Jesus chandcz? Jr. actively suughz to ?nd a haste! in Miami Beach, Florida. Jeans Fem-ands: and Jesus Femandcz, Jr. were: the miles that found and identi?ed the Mien Road Pm an and 3r I-Icuste. Jesus; Fernancicz, J5: was also the person that saccumd various ?nancial records and businegs maids [hr the success?? operatian of :1 imsmi in Miami Beach. Fioricla. Thu 31 Alton Ruad Pmperty and Hostel were presented 10 Jerry Faiwe?, Jr. .Iesm Fernanda-z, was ?11m as ?ed to initiate contact and initial nagotiatiuns with the {cal estate agema?bs?okez? for the $10 Aitnn Road Pz'?ptriy and Host?i. S. The negmiaiirms led to a comma fur {ha purchase of the. Alum {-103ch LLC by way of'zm intermediary, Comeback. LLC. Rebecca Falweii wag identi?ed at; the Managar of Car aback, LLC. Comeback, LLC hum aasigned its contract to Fain-2:13, 31: and Altar: Hastel. Tin-{Jughum the negatiailons and process of purchasing the 310 Aimn Road Property and Hogtcl, it was aways by Jim}! Falwell, Jr. that since 383% Fernandez, Jr. introduced the hastci Cancepi, 31nd he; was the person that investigated the. ?nancials and. business modem Fur the business venture, ?1131 Jesus Femam?icz, Jr. was going to bit a partner in the business with Giancm?io (Emma. Thig rcpresmtariun and agreement was Further con?rmed Affidavit nf l??actolinttc Robert? Bracing Page 3 when Ferry li-?a?aweii, Jr. t'eqttusted that Jesus Fernandez assist in the identi?catiau at" aha ideal progeny Pm: the hostel, as 1111113113 Qt?assisting his 303, Jesus: Fernandez, Jr. 19. The EEG Aitmt Road Fromm! and 1-1113th wtre purchased by Aim Hostcz?t, a. Florida Limited Liability Company. At thr: time that the Alum Road pmperty was purchased, Jesus Femaudea Jr. and Giana-aria.) Grandtt were assured that they wettiti be: added as Membcr?hvuers fl?iik.? the. dosing 111? the: sate. 1 1, I affirm to the truth and swat-tr to the. accuracy at contents ofthis Af?davit. AFFIANT SA NAUGHT. Signed this 20th day of Septembar, 3015i. Roberto Bt?ttc ht} EFGRE ME, the untiersigncd authority, this day, pcrsonaily appeared Roberto Bracho who, nits: being; duly sworn, dcpases and says that he has read the abnve and imagining Aft": iavit and that ht: has set his hands and sea! titertzto for the uses and pmrposcs therein cripress'ed. SWORN AND heftwa me this 20th of 2(316t by Hobart?) 3" m, germ-51215.0 ?1 Bl??ch? who is personaliy known tu me [011 has pr?yic . .- "5 I as identi?cation. r. I 2' I a Suita?t-?tmiah . . 0 a 5" My expu'?s: gm" "151,33 vato??u MW 9" 5? Notary Puhiic - State a? o, 3 My Comm Engine Commissian :3 PF 133533 LEW . . 1x- ?my? 11'