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

Similar documents
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA

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

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

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL ACTION

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. Plaintiff, Case No.: (09)

Filing # E-Filed 05/08/ :47:12 PM

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA - CIVIL DIVISION -

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA

HOMEWARD BOUND SERVICES OF NORTH AMERICA MARC ORTH

OFFICE OF THE ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, Plaintiff, v. CASE NO: COMPLAINT

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT ORANGE COUNTY, FLORIDA CIVIL ACTION

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT IN AND FOR POLK COUNTY, FLORIDA CIVIL DIVISION

"~'J;' v" 02li 34r...,;;

Filing # E-Filed 03/07/ :02:15 AM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR ST. JOHNS COUNTY, FLORIDA

COMPLAINT. Plaintiff, OFFICE OF THE ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, ( PLAINTIFF or the ATTORNEY GENERAL ),

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

Filing # E-Filed 07/13/ :52:45 AM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA - CIVIL DIVISION - Plaintiff CASE NO.

IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT, IN AND FOR SARASOTA, MANATEE, DESOTO COUNTY, FLORIDA

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

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO

IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT, IN AND FOR SEMINOLE COUNTY, FLORIDA. Plaintiff, CASE NO. :

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT ORANGE COUNTY, FLORIDA CIVIL ACTION

IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT, IN AND FOR SANTA ROSA COUNTY, FLORIDA. Plaintiffs, CASE NO. :

IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION

IN THE CffiCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND J!'OR BROWARD COUNTY, FI~ORIDA CASE NO.: 1 0~044129(08)

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT ORANGE COUNTY, FLORIDA CIVIL ACTION

IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT FOR POLK COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA COMPLAINT

IN THE CIRCUIT COURT OF THE SIXTH CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA STATE OF FLORIDA CASE NO: CF (B) 02

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

FILED SAN MAteO COUNTY

IN THE CIRCUIT COURT OF ST. LOUIS CITY STATE OF MISSOURI

Case 0:17-cv XXXX Document 1 Entered on FLSD Docket 01/13/2017 Page 1 of 12

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR VOLUSIA COUNTY, FLORIDA. Plaintiff, CASE NO. :

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA -CIVIL DIVISION-

IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR VOLUSIA COUNTY, FLORIDA. Plaintiff, CASE NO. :

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

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA

Office of the Attorney General State of Florida Department of Legal Affairs

Case 0:18-cv DPG Document 1 Entered on FLSD Docket 01/18/2018 Page 1 of 33

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CORRECTED ORDER ON TEMPORARY INJUNCTION

IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT, IN AND FOR SANTA ROSA COUNTY, FLORIDA. Plaintiffs, CASE NO. :

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

~/

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ORIGINAL COMPLAINT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA C O M P L A I N T. COMES NOW, Plaintiff, JUAN ANTONIO CASTRO RIOS, (hereinafter

Filing # E-Filed 04/10/ :26:28 AM

FILED: NEW YORK COUNTY CLERK 11/04/ :40 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/04/2016

STATE OF SOUTH CAROLINA ) ) IN THE COURT OF COMMON PLEAS COUNTY OF CHARLESTON ) NINTH JUDICIAL CIRCUIT

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA - CIVIL DIVISION -

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA SETTLEMENT AGREEMENT

Case 0:12-cv RSR Document 7 Entered on FLSD Docket 12/18/2012 Page 1 of 15

Filing # E-Filed 06/13/ :25:39 PM

SUPERIOR COURT OF CALIFORNIA COUNTY OF YOLO. Plaintiff, Defendant. JEFF W. REISIG, District Attorney of Yolo County, by LARRY BARLLY, Supervising

Case 7:18-cv Document 1 Filed 01/12/18 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

IN THE SUPREME COURT OF THE STATE OF FLORIDA. CASE NO. SC (4th DCA Case No. 4D ) ALBERTO ELIAKIM, Petitioner, vs.

Case 0:10-cv KMM Document 1 Entered on FLSD Docket 08/10/2010 Page 1 of 7

Case 5:16-cv Document 1 Filed 09/12/16 Page 1 of 16 Page ID #:1

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE MIDDLE DIVISION

2. Green Tree is without knowledge of the allegations contained in Paragraph 2 of

CASE NO.: DIVISION

MARTIN COUNTY BOARD OF COUNTY COMMISSIONERS

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA

products, in part, by lending his credentials as a doctor of chiropractics research to the active

Case 0:13-cv MGC Document 1 Entered on FLSD Docket 12/05/2013 Page 1 of 8

IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT WILL COUNTY, ILLINOIS ) ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT AT LAW

Case 3:13-cv GPM-PMF Document 5 Filed 02/14/13 Page 1 of 15 Page ID #24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS

PLAINTIFFS OBJECTION TO FRANK AVELLINO S NOTICE OF PRODUCTION TO NON-PARTY UNDER RULE 1.351

AGREEMENT between BROWARD COUNTY and CITY OF FORT LAUDERDALE for PARKING ACCESS IN THE COUNTY PARKING GARAGE

Case 0:18-cv FAM Document 1 Entered on FLSD Docket 03/19/2018 Page 1 of 5

Case 9:16-cv RLR Document 1 Entered on FLSD Docket 04/15/2016 Page 1 of 6

Case No CA000567MB. ~:r~:~~~~~~~galaffairs,

IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR NASSAU COUNTY, FLORIDA CIVIL ACTION. vs. DIVISION: A

Case 2:12-cv Document 1 Filed 12/06/12 Page 1 of 14

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION Case No. ) ) ) ) ) ) ) ) ) ) ) ) )

Case 2:13-cv DSF-MRW Document 14 Filed 12/16/13 Page 1 of 17 Page ID #:150

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

~/

COMPLAINT AND DEMAND FOR JURY TRIAL

NO. 14 The Plaintiff, State of Washington, by and through its attorneys Robert W. Ferguson,

Case 2:06-cv RSM Document 26 Filed 04/17/2006 Page 1 of 10

Case: 1:17-cv Document #: 1 Filed: 03/08/17 Page 1 of 14 PageID #:1

Case 1:08-cv JHR -KMW Document 37 Filed 05/04/09 Page 1 of 13 PageID: 222 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

FILED: NEW YORK COUNTY CLERK 09/08/ :05 PM INDEX NO /2016 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 09/08/2016

Filing # E-Filed 01/09/ :13:29 PM

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS ASSURANCE OF VOLUNTARY COMPLIANCE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION

NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION

Case 8:14-cv CEH-MAP Document 8 Filed 08/27/14 Page 1 of 22 PageID 56

Case 0:14-cv RLR Document 1 Entered on FLSD Docket 07/03/2014 Page 1 of 12

Transcription:

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA, Plaintiff, Case No.: vs. GILDA ANDERSON, individually and as Owner, President and Director of Wizard of Claws, Inc.; JAMES ANDERSON, individually and as Owner of Wizard of Claws, Inc. and WIZARD OF CLAWS, INC.,a Florida corporation and John Does 1-10. Defendants. / COMPLAINT Plaintiff, OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA (hereinafter referred to as "Plaintiff"), sues Defendants GILDA ANDERSON, individually and as Owner and President of Wizard of Claws, Inc.; JAMES ANDERSON individually and as Owner of Wizard of Claws, Inc. and WIZARD OF CLAWS, INC., a Florida for-profit corporation. (hereinafter referred to as Defendants ). JURISDICTION 1. This is an action for restitution, penalties and injunctive relief, brought pursuant to Florida's Deceptive and Unfair Trade Practices Act, Chapter 50l, Part II, Florida Statutes (2001). 2. This Court has jurisdiction pursuant to the provisions of said statute.

3. Plaintiff is an enforcing authority of Florida's Deceptive and Unfair Trade Practices Act as defined in Chapter 50l, Part II, Florida Statutes, and is authorized to seek damages, injunctive and other statutory relief pursuant to this part. 4. The statutory violations alleged herein occurred in or affected more than one judicial circuit in the State of Florida. Venue is proper in the Seventeenth Judicial Circuit as the principal place of business of the Defendants is Broward County, Florida. 5. Plaintiff has conducted an investigation, and the head of the enforcing authority, Attorney General Charles J. Crist, Jr. has determined that an enforcement action serves the public interest. 6. Defendants, at all times material hereto, provided goods or services as defined within Section 501.203(8), Florida Statutes (2001). 7. Defendants, at all times material hereto, solicited consumers within the definitions of Section 501.203(7), Florida Statutes (2001). 8. Defendants, at all times material hereto, were engaged in a trade or commerce within the definition of Section 501.203(8), Florida Statutes (2001). DEFENDANTS 9. Defendant, GILDA ANDERSON, an adult female over the age of twenty one, was at all times material an owner, officer and/or director of Defendant WIZARD OF CLAWS, INC.. Upon information and belief, GILDA ANDERSON is a resident of Broward County, Florida. 10. Defendant, JAMES ANDERSON, an adult male over the age of twenty one, was at all times material an owner of Defendant WIZARD OF CLAWS, INC.. Upon information and belief, -2-

JAMES ANDERSON is a resident of Broward County, Florida. 11. Defendant WIZARD OF CLAWS, INC. is a Florida for-profit corporation, with a principal address of 3134 SW 27 th Street, Fort Lauderdale, FL 33312 and a principal place of business at 9113 Taft St., Pembroke Pines, FL 33024. 12. At all times material, Defendant GILDA ANDERSON knew of and controlled the activities of WIZARD OF CLAWS, INC.. 13. At all times material, Defendant JAMES ANDERSON knew of and controlled the activities of WIZARD OF CLAWS, INC.. COUNT I DECEPTIVE AND UNFAIR TRADE PRACTICES CHAPTER 501, PART II FLORIDA STATUTES 14. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 13 as if fully set forth bellow. 15. Chapter 501.204(1), Florida Statutes, declares that unfair or deceptive acts or practices in the conduct of any trade or commerce are unlawful. 16. Commencing on a date unknown, but at least subsequent to January 1, 2003, Defendants engaged in various deceptive and unfair trade practices, as set out further herein, in violation of Chapter 501, Part II, Florida Statutes (2001). dogs. 17. At all times material, Defendants engaged in the business of the retail sale of 18. In conversations with potential clients and in order to induce consumers to -3-

purchase dogs from Defendant Wizard of Claws, Inc., Defendants would and did make material misrepresentations of fact, to-wit: a) orally represented to consumers the approximate full size weight of dogs which were being purchased when in fact Defendants had no information of the dog s pedigree; b) knowing the dog s pedigree and the approximate final weight, Defendants orally represented a weight inconsistent with that pedigree; c) misrepresented to consumers that they were purchasing American Kennel Club (AKC) registered dogs and thus induced consumers to pay a higher price for the dogs when Defendants in fact knew that the dogs were not registered with the AKC; and d) by material omission or direct misrepresentation, Defendants misrepresented the source from which Defendants obtained subject dogs. 19. Representations relating to the type and size of dogs were material to consumers, in that various apartments and condominiums have restrictions relating to the size of pets. Additionally, the size of pets materially affects the cost of travel and transportation of said pets to the consumer. WHEREFORE, Plaintiff requests this court to enter the following Orders: 1. Grant permanent injunctions against Defendants, their officers, agents, servants, employees, attorneys and those persons in active concert or participation with Defendants who receive actual notice of this injunction, prohibiting such persons from doing the following acts: a. Operating or conducting any business or offering services relating to the sale of -4-

pets to consumers within the state of Florida; b. Violating the provisions of Chapter 501, Part II, Florida Statutes (2001); 2. Award actual damages to all consumers who are shown to have been injured in this action, pursuant to Section 501.206 (1) (c), Florida Statutes (2001); 3. Assess against Defendants herein civil penalties in the amount of Ten Thousand Dollars ( $10,000.00 ) for each act or practice found to be in violation of Chapter 501, Part II, Florida Statutes (2001); 4. Award reasonable attorneys fees pursuant to F.S. 501.2105; 5. Grant temporary relief pursuant to F.S. 501.207; 6. Waive the posting of any bond by Plaintiff in this action; and 7. Grant such other relief as this Honorable Court deems just and proper. Respectfully Submitted CHARLES J. CRIST, JR. Attorney General By: LYNN ETKINS Assistant Attorney General FL Bar No. 642691 Office of the Attorney General Department of Legal Affairs 110 S.E. 6th Street, Ninth Floor Fort Lauderdale, FL 33301 (954) 712-4600 -5-