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Legal, Public Notices IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY STATE OF FLORIDA. JUVENILE DIVISION: 03/TYNAN CASE NO: DP19-15, IN THE INTEREST OF Minor Children: S. J. DOB: 02/21/2007, G. P. DOB: 08/17/2010, J. R. DOB: 04/29/2016. SUMMONS AND NOTICE OF ADVISORY HEARING FOR TERMINATION OF PARENTAL RIGHTS, STATE OF FLORIDA. TO: Sonne Ramirez Joseph Address Unknown: A Petition for Termination of Parental Rights under oath has been filed in this court regarding the above referenced children. You are hereby commanded to appear before Magistrate Craig McCarthy on June 16, 2022 at 10:30 a.m. at the Juvenile Justice Center, 2000 East Michigan Street, Orlando, Florida 32806, for a TERMINATION OF PARENTAL RIGHTS ADVISORY HEARING. You must appear on the date and at the time specified. For this hearing, all parties shall participate via TEAMS. Call in at below number: 407-836-5646 (local) Toll Free: 1-800-3468020 (long distance) Conference Code: 893130# FAILURE TO PERSONALLY APPEAR AT THE TERMINATION OF PARENTAL RIGHTS ADVISORY HEARING CONSTITUTES A CONSTRUCTIVE CONSENT TO THE TPR PETITION OF THE CHILD(REN) AND COULD RESULT IN THE TERMINATION OF PARENTAL RIGHTS TO THE CHILD(REN). “Pursuant to Sections 39.802(4)(d) and 63.082(6)(g), Florida Statutes, you are hereby informed of the availability of private placement with an adoption entity, as defined in Section 63.032(3), Florida Statutes.” WITNESS my hand and seal of this Court at Orlando, Orange County, Florida this 11th day of May, 2022. This summons has been issued at the request of: Sacha C. Dixon, Esq., Florida Bar No.: 1017790, Senior Attorney, Sacha.Dixon@myflfamilies.com CLERK OF COURT By: /s/ Deputy Clerk. (Court Seal) IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA ARTESIAN TITLE, INC., a Florida corporation, CASE NO. 2019-CA-009345-O Plaintiff, vs. CAROLINE VERAGUS and HUSSEIN ELHUSSEINI, Defendants. SECOND AMENDED COMPLAINT Plaintiff, ARTESIAN TITLE, INC. (hereinafter “Artesian”), by and through its undersigned counsel, hereby files this Second Amended Complaint against Defendants, CAROLINE VERAGUS (“Veragus”) and HUSSEIN EL HUSSEINI (“Elhusseini”), and as grounds therefore alleges: Jurisdiction and Venue This Court has jurisdiction pursuant to Florida Statute § 26.012. Additionally, the claims requesting monetary damages all exceed the jurisdictional limit of county courts. Venue is proper because Orange County is where Artesian’s principal office is located pursuant to Florida
Statute § 607.1431 and all other actions in this Amended Complaint occurred in Orange County. Artesian is a corporation formed under the laws of the State of Florida and is situated in Orange County, Florida. Veragus is a non-resident of the State of Florida, but service of process on and personal jurisdiction over her is authorized by Florida Statute § 48.193(1) because the causes of action alleged in this Amended Complaint arose from her commission of a tortious acts within Orange County, Florida. Elhusseini is a natural person domiciled in Orange County, Florida. General Allegations On or about July 13, 2018, Robert Patterson, a closing agent for Artesian, informed Prithi Daswani, owner and president of Artesian, that Artesian’s escrow account was missing several hundred thousand dollars. On or about July 13, 2018, Ms. Daswani discovered, after auditing the escrow account, that Veragus had completed several unauthorized wire transfers from the escrow account. Veragus was employed by Artesian for roughly three years at the time of the unauthorized wires. At the time of the unauthorized wires, Elhusseini was Veragus’ boyfriend and was the recipient of a direct unauthorized wire transfer by Veragus from the Artesian Title escrow account to an account in bis name. On or about July 14, 2018, Artesian removed Veragus’ access to the escrow account and took the steps to terminate Veragus and lock her out of Artesian’s computer systems. For wire transfer approvals in Artesian’s computer system, and pursuant to its closing procedures, there is a two-person authorization required. Artesian discovered the second person who approved all the transfers with Veragus was Sherwin Davis, who was not in the office on the days the wire transfers were approved. Several of Artesian employees stated they saw Veragus enter Ms. Davis’ office on the days the wire transfers were approved and Mr. Davis was out of the office. Mr. Rick Nayar, husband of Ms. Daswani and co-owner of Artesian, contacted Veragus who had called out sick at the time the wire transfers were discovered to question her regarding the missing money. Veragus claimed to Mr. Nayar that Elhusseini had been doing a real estate transaction through Artesian and that he had wired funds into Artesian’s escrow account to complete the transaction. Veragus further claimed that she transferred the money back into Elhusseini ‘s account and that he intended to wire the funds back into Artesian’s escrow account by July 18, 2018. On or about July 19, 2018, Veragus and Elhusseini, wired back $110,000 of the missing funds to the escrow account. Mr. Nayar commenced lengthy text message exchanges with both Veragus and Elhusseini regarding the rest of the missing funds. In these exchanges, both Defendants claimed that Elhusseini’ s TD Ameritrade business account had been frozen, therefore he could not wire the funds back to Artesian’s escrow account. Richard Patrick Todd, Jacob H. Rubin, Francisco Balaguer, Nicholas A. Doby- Hammond, and Lazaro Ayala (collectively the “Third Parties”), are known associates ofElhusseini. Indeed, Elhusseini confirmed by communication to Mr. Nayar that he has control over all of the funds transferred out of Artesian’s escrow account by Veragus via unauthorized wire. In total, Veragus generated and fraudulently authorized nine (9) wire transfers from Artesian’s escrow account as follows: May 3, 2018 to Richard Patrick Todd in the amount of$57,075.21 May 8, 2018 to Richard Patrick Todd in the amount of $47,692.37 May 23, 2018 to Jacob H. Rubin in the amount of $45,232.42 May 30, 2018 to
Lazaro Ayala in the amount of $87,455.55 June 8, 2018 to Francisco Balaguer in the amount of $34,112.00 June 15, 2018 to Francisco Balaguer in the amount of $40,000.00 June 21, 2018 to Nicholas A. Doby-Hammond in the amount of$114,437.29 June 29, 2018 to Nicholas A. Doby-Hammond in the amount of $32,814.19 July 6, 2018 to Hussein Elhusseini in the amount of $114,995.00 Since $110,000 of this embezzled money has been returned, the total amount stolen and lost from Artesian at this point is approximately $463,744.03 (the “Damages”). Since the amounts comprising the Damages were ultimately owed to other persons, as they were only being held in escrow by Artesian, Artesian has had to pay the Damages through other means. COUNT I-Conversion Against Veragus Artesian restates and re-alleges paragraph nos. 1 through 21. At all times, Artesian was the lawful owner of the funds in the escrow account. Veragus never had permission or authorization from Artesian to make the wire transfers to Defendants. Veragus fraudulently input authorization of another Artesian employee to make fraudulent wire transfers. Veragus therefore abused her employment with Artesian to deprive Artesian of the Damages and wire them to her fellow Defendant, Elhusseini, and the Third Parties, and upon information and belief, to her own control by way of Elhusseini and the Third Parties. Veragus knowingly transferred and received funds that did not rightfully belong to her and continues to hold the Damages in her personal accounts, or by proxy in the accounts of Elhusseini and the Third Parties. Thus, Veragus acted with the intent to permanently deprive Artesian of the funds. Veragus’ actions in wiring the funds without authorization were inconsistent with Artesian’s ownership interest in the funds and amounted to the wrongful deprivation of Artesian’s property. Further, Artesian has demanded the funds be returned and Veragus has refused. Therefore, Veragus’ actions amount to a conversion and are a civil theft, as well. Veragus owes the Damages to Artesian. WHEREFORE, Artesian respectfully requests that this Court find that Veragus has committed a conversion and award Artesian a fmal judgment in the amount of the Damages, Artesian’s reasonable attorney fees and costs, as well as such other relief as this Court deems just and proper. COUNT II - Conversion Against Elhusseini Artesian restates and re-alleges paragraph nos. 1 through 21. At all times, Artesian was the lawful owner of the funds in the escrow account. Elhusseini received an unauthorized wire transfer, consisting of monies in the possession of and owing to Artesian, on or around July 6, 2018 from Veragus. The amount of the wire transfer that Elhusseini received was $114,995.00. Elhusseini returned $110,000.00 of this amount, failing to return $4,995.00. Elhusseini confirmed his possession of the other amounts sent by Veragus’ unauthorized wire transfers but has failed to return those monies as well. Elhusseini knows that he has no right to possession of the amounts consisting of the Damages. Thus, Elhusseini acted with the intent to permanently deprive Artesian of the funds. Elhusseini’ s actions in wiring the funds without authorization were inconsistent with Artesian’s ownershlp interest in the funds. Artesian has demanded the funds be returned and Elhusseini has refused. Therefore, Elhusseini’s actions amount to a conversion. Elhusseini owes the Damages to Artesian. WHEREFORE, Artesian respectfully requests that thls Court fmd that Elhusseini has committed
a conversion and award Artesian a final judgment in the amount of the Damages, Artesian’s reasonable attorney fees and costs, as well as such other relief as thls Court deems just and proper. COUNT ill - Conspiracy to Commit Conversion against Veragus and Elhusseini Artesian restates and re-alleges paragraph nos. 1 through 21, 23 through 32, and 34 through 44. Defendants, Veragus and Elhusseini, entered into an agreement with each other to illegally transfer Artesian funds into their own personal accounts by and through Veragus. In other words, Defendants agreed to commit the conversions alleged in Counts I and II of thls Complaint. Defendant Elhusseini, acted overtly in pursuance of the conspiracy, by knowingly providing account numbers to Veragus for her to illegally transfer Artesian’s funds with the intent to receive Artesian’s illegally transferred funds. Without this communication and cooperation between the Defendants, Veragus would not have known the account numbers in which to transfers the funds too. Veragus agreed to use her access, power, and control given to her as employee of Artesian to wire the funds out of Artesian’s control and into the accounts that Elhusseini identified. Elhusseini agreed with Veragus to use the identified accounts as a mode of transfer to receive and take the funds taken out of Artesian’s control. Elhusseini and Veragus agreed to wrongfully transfer the funds to the Third Parties. After the conversion occurred, Artesian Title demanded the return of the funds from both Veragus and Elhusseini. Both Defendants, Veragus and Elhusseini, agreed to not return the funds taken to Artesian despite the demand from Artesian to do so. Artesian never authorized the transfer of funds out of the escrow account, thus amounting to an unlawful taking of Artesian’s property. As a result of this criminal and civil conspiracy, Artesian has suffered the Damages. WHEREFORE, Artesian respectfully requests that this Court find that each Defendant committed a conspiracy to commit conversion in the amount of the Damages and issue a final judgment that awards the Damages to Artesian along with reasonable fees, costs, and any other relief that this Court deems just and proper. COUNT IV -Breach of Fiduciary Duty against Veragus Artesian restates and re-alleges paragraph nos. 1 through 21. At all relevant times, Veragus was acting in her role as a closing and escrow agent of Artesian. In her role, Veragus was entrusted by Artesian with access to the escrow account to facilitate her work as a closing and escrow agent. Therefore, Veragus was acting in the capacity of a fiduciary. Veragus was also under a duty as an employee to act in good faith and to avoid acting contrary to the interests of her employer, Artesian. Veragus breached her fiduciary duties when she fraudulently input authorization of another Artesian employee to make the illegal wire transfers to Elhusseini and the Third Parties. Veragus breached her duty of good faith to Artesian and violated her position of trust by engaging in the above unauthorized transfers. Veragus breached her fiduciary duties by acting m her own self-interest by transferring the escrow funds to Elhusseini and the Third Parties for her own personal benefit. Veragus breached her fiduciary duties by conspiring with Elhusseini and the Third Parties to illegally transfer Artesian’s funds into their own personal accounts. As a direct result of Veragus’ conduct, Artesian has been deprived of its rightful ownership of the escrow funds and has suffered the above Damages. WHEREFORE, Artesian respectfully requests that this Court find
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that Veragus committed a breach of fiduciary duty resulting in the amount of Damages and issue a fmal judgment that awards the Damages to Artesian along with reasonable fees, costs, and any other relief that this Court deems just and proper. COUNT V - Conspiracy to Commit Breach of Fiduciary Duty against Veragus and Elhusseini Artesian restates and re-alleges paragraph nos. 1 through 21, and 57 through 65. Elhusseini had actual knowledge of Veragus’ actions outlined in Count IV constituting a breach of fiduciary duty. Veragus acted in furtherance of the conspiracy by agreeing to fraudulently input another employee’s password to gain access to the funds and by agreeing to transfer the funds to Elhusseini. Elhusseini substantially assisted Veragus in the commission of the breach of fiduciary duty by communicating with Veragus about the transfer of the escrow funds, providing the account numbers to transfer the funds to, and wrongfully retaining the escrow funds. Therefore, Veragus and Elhusseini, acted in furtherance of the breach of fiduciary duty. As a direct result of these actions, Artesian has suffered the above Damages as it bas been deprived of the escrow funds. WHEREFORE, Artesian respectfully requests that this Court find that each Defendant committed a conspiracy to commit breach of fiduciary duty in the amount of the Damages and issue a final judgment that awards the Damages to Artesian along with reasonable fees, costs, and any other relief that this Court deems just and proper. DEMAND FOR JURY TRIAL Pursuant to Rule 1.430, Fla. R. Civ. P., Artesian demands trial by jury for all factual issues identified in the complaint that are so triable. DATED this 3rd day of December, 2021. Respectfully submitted, /s/ Christian W. Waugh CHRISTIANW. WAUGH,B.C.S. Florida Bar No. 71093 Board Certified Real Estate Attorney MARY A. NORBERG Florida Bar No. 1032028 WAUGH GRANT, PLLC 201 E. Pine Street, Ste. 315 Orlando, FL 32801 Telephone: 321-800-6008 Fax: 844-206-0245 Email: cwaugb@ waughgrant.com Email: mnorberg@ waughgrant.com Email: rwood@ waughgrant.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 3, 2021, a true and correct copy of the foregoing was furnished via the Florida E-filing Portal to all parties who have elected to receive email service. By: /s/ Christian W. Waugh CHRISTIANW. WAUGH Florida Bar No. 71093 MARY A. NORBERG Florida Bar No. 1032028
NOTICE OF PUBLIC SALE: ADAM AYED ENTERPRISES LLC gives Notice of Foreclosure of Lien and intent to sell these vehicles on 6/3/2022, 09:00 am at 9712 RECYCLE CENTER RD ORLANDO, FL 32824- 8146, pursuant to subsection 713.78 of the Florida Statutes. ADAM AYED ENTERPRISES LLC reserves the right to accept or reject any and/or all bids. JACDS58XX17J01404 2001 ISU JM1BK143451235502 2005 MAZD JTEEW21A760011766 2006 TOYT 2HGFG128X7H571744 2007 HOND.
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