Rodriguez Licea et al v. Curacao Drydock Co - Scientology Garnishment Writs (Oct2013)

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 06-22128-CV-K1NG/M CALlLEY

( . Q.-.'FILED by D.C.

0 C..- -; () 7 2 217

STEVLN M. L.-Aq#MORQCLERK t; s Elis'r cT.s. o. of FC!

-â. - MIAMIALBERTO JUSTO RODRIGUEZ LICEA,

FERNANDO ALONSO HERNANDEZ, AND

LUIS ALBERTO CASANOVA TOLEDO,

Plaintiffs/ludgment Creditors,

CURK AO DRYDOCK COMPANY, lNC., A/K/ACURK AOSE DOKMAATSCHAPPIJ NV, A/K/ACDM NV ,

Defendant/ludgment Ilebtor.

PLM NTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARNISHM ENT

COM ES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fem ando

Alonso Hernandez, and Luis Alberto Casanova Toledo (ttplaintiffs'), by and thzough their

undersigned counsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 ef. seq.

and move this Court for issuance of a post-judgment writ of gnrnishment conceming the assets of

Defendant/ludgment Debtor Clzracao Drydock Company, lnc., to be served Church of

Scientology Flag Ship Service Organization, Inc., and as grounds therefore state:

On October 31 , 2008, this Court entered a final Judgment in favor of Plaintiffs

and against Defendant/ludgment Debtor for $80 million plus post-judgment interest at the rate

set by 28 U.S.C. j 1961. DE 1 12.

2. On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00

and interest according to 28 IJ.S.C. j 1961 since October 31, 2008. DE 1 19.

The Final Judgment was not appealed and the time for appeal has passed.

Judgment Debtor has paid none of the judgment; the entire judgment remains

unsatisfied.

Case 1:06-cv-22128-JLK Document 361 Entered on FLSD Docket 10/07/2013 of 2

5. As Judgment Debtor is a foreign entity whose assets are primarily located outside

of the United States, Judgment Creditors have been tmable to levy on Judgment Debtor's assets.

Judgment Debtor is a drydock facility located in Ctlracao.

7. Gam ishee, Charch of Scientology Flag Ship Service Organization, Inc., or its

agent or alter ego is a manager of ships that currently has a ship in repair at the Judgment

Debtor's drydock facility in Cmacao. As such, it owes Judgment Debtor for ship repaixs.

8. Judgment Creditors suggest that garnishee, Chtzrch of Scientology Flag Ship

Service Organization, Inc., is in possession of property belonging to Judgment Debtor, Curacao

Drydock Com pany, lnc.

9. Judgment Creditors seek a writ of gnrnishment pursuant to Fla. Stat. j 77.03.

W H EREFORE, Judëkm ent Creditors request the issuance of a writ of gam isbm ent

against Curacao Drydock Colnpany, Inc.'s property held by garnishee, Church of Scientology

Flag Ship Service Organization, Inc., in the form attached hereto and to grant any further relief

as is just, fair and equitable.

Dated: October 7, 2013 Respectfully submitted,

Do CAMPO & THORNTON, P.A.

M iam i Tower

100 Southeast Second Street

Suite 2700

M iam i, FL 33131

Phone: 305-3 -6600ké-rçj .Fax: 30 -<

jjjj . .-'y. .

f ThorntonFlorida Bar No. 004820

jt@dandtlamcomAttorneysfor Plaintp /ludgmentCreditors

Case 1:06-cv-22128-JLK Document 361 Entered on FLSD Docket 10/07/2013 of 2

.

a c,oj..e g' +. u ,.j . .<.

PAID l P(' '-

e r'- Sljw f,/,é//

Steven Mq Lqrlmîluilf.k..k jgxjvso STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 06-22128-CV-KlNG/M CAL1LEY

ALBERTO JUSTO RODRIGUEZ LICEA,

FERNANDO ALONSO HETW ANDEZ, AND



VS.

CURK AO DRYDOCK COMPANY, lNC., A/K/A

CURK AOSE DOKMAATSCHAPPIJ NV, A/K/ACD> V,

Defendant/ludgm ent Debtor.

W RIT OF GARNISHM ENT

THE STATE OF FLORIDA:

To All and Singular the Sheriffs of the State

And the U.S. Marshal's Service:

YOU ARE COM M ANDED to stlmmon the garnishee, Chmch of Scientology Flag Ship

Service Organization, lnc., by serving it and/or its registered agent, W illiam B. M illiken, at its

registered agent address: 212 1 Ponce de Leon Boulevard, Suite 730, M iami, FL 33134, to serve

an answer to this writ on JOEN THORNTON, ESQ., Judgment Creditors' attorney, whose

addresses is M iami Tower 100 Southeast Second Skeet Suite 2700 M iami, FL 33131, within 20

days after service on the gnrnishee, exclusive of the day of servict, and to file the original with

this court either before service on the attorney or immediately thereafter stating whether the

garnishee is indebted to the defendant, Curacao Drydock Company, Inc. or its aliases named

above, at the time of service (hf tbe answer OR was indebted at the time of service of the writ,

OR at any time between such times, AND in what sum and what tangible and intangible

Case 1:06-cv-22128-JLK Document 362 Entered on FLSD Docket 10/07/2013 Page 1 of 2

personal property of the defendant the gnrnishee has in his possession or control at the time of

the answer, OR had at the tirae of service of this writ, OR at any tim e between such tim es, AND

whether the garnishee knows of any other person indebted to the defendant, O R who may be in

possession or control of any of the property of the defendant. The nmount set in plaintiffs'

motion is $80,000,000.00 plus interest accnzing from October 31, 2008 at the rate set by 28

U.S.C. j 1961.

W ITNESS STEVEN M . LARIM O RE, as Clerk of the Court, and the deal of said Court, at

16 tthe U.S. District Courthouse at M inm i, Florida, this 1 day of 6c obk f- , 2013.

STEVEN M .LARIM ORE

Clerk of the Court

'-

,

4tj1 y .f- ,By:

s Deputy lerk



FOR THE SOUTHERN DISTRICT OF FLORIDACA SE NO. 06-22128-CV-KlNG/M CAL1LEY

ALBERTO JU STO RODRIGUEZ LICEA ,

FERNANDO ALON SO HERNANDEZ, AND

LUIS A LBERTO CASANOA/A TOLEDO,


FILED by D.C.

021 2 7 2213

STEVEN .M LARIMORECLERK tl s Dls-r cT.s. o. of /LX - MlkulVS .

CURACAO DRYDOCK COMPANY, INC., A/K/ACURACAOSE DOKMAATSCHAPPIJ NV, A/K/ACDM NV,


PLAINTIFFS/JUDG M ENT CREDITORS' M O TION FOR A W RIT OF GARNISHM ENT

COM ES NOW Plaintiffs/ludgm ent Creditors, Albel'to Justo Rodriguez Licea, Fernando

Alonso Hernandez, and Luis Alberto Casanova Toledo (tûplaintiffs''), by and through their

undersigned counsel, pursuartt to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 et. .$t?t?.

and move this Court for issuance of a post-judgment writ of garnishment concerning the assets of

Defendant/ludgm ent Debtor Curacao Drydock Com pany, lnc., to be served Church of

Scientology Flag Ship Service Organization, lnc., and as grounds therefore state:

On October 3 1 , 2008, this Court entered a final Judgm ent in favor of Plaintiffs


set by 28 U.S.C. j 1961 . DE 1 12.

On October 21 , 2009, the Clerk issued a W rit of Execution for $80,000,000.00

and interest according to 28 U.S.C. j 1961 since October 31, 2008. DE 1 19.

The Final Judgm ent w as not appealed and the tim e for appeal has passed.

Judgment Debtor has paid none of the judgment', the entire judgment remains

unsatisfied.


As Judgment Debtor is a foreign entity whose assets are primarily located outside

of the United States, Judgment Creditors have been unable to levy on Judgm ent Debtor's assets.

Judgment Debtor is a drydock facility loeated in Curacao.

Garnishee, Church of Scientology Flag Ship Serviee Organization, 1nc., or its

agent or alter ego is a manager of ships that currently has a ship in repair at the Judgment

Debtor's drydock facility in Cwuracao. As such, it owes Judgment Debtor for ship repairs.

Judgment Creditors suggest that garnishee, Chureh of Seientology Flag Ship

Service Organization, lnc., is in possession of property belonging to Judgment Debtor, Curacao

Drydock Company, lne.

Judgment Creditors seek a writ of garnishment pursuant to Fla. Stat. j 77.03.

W HEREFORE, Judgment Creditors request the issuance of a writ of garnishment

against Curacao Drydoek Company, Ine.'s property held by garnishee, Chureh of Seientology

Flag Ship Service Organization, lnc., in the form attached hereto and to grant any further relief

as is just, fair and equitable.

Dated: October l , 2013 Respectfully subm itted,

Do CAM PO & THORNTON, P.A.M iam i Tower


Suite 2700

M iam i, FL 33131

Phone: 305-358-6600

Fax: 305-358-6601

By: - a

ohn Thornton

Florida Bar No. 004820

[email protected] Plaintffv/ludgmentCreditors


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FEE

l loo.xpxo .

Iyxlvso svvss Ials-rlucv couR'r'''/f FoR I'I-IE sou-rldcRx ols-rluc'r oy FLORIDAe c )V**- Clerk CASE NO

. 06-22128-CV-KlNG/M CALlLEYSteven M. tafi r ,

ALBERTO JUSTO RODRIGUEZ LICEA ,

FERN ANDO ALON SO HEFLNANDEZ, AND

LUIS ALBERTO CASANOAJA 'FOLEDO,

Plaintiffs/ludgm ent Creditors,

FILED by & D.c.

02T 2 ? 2213

STEVEN .M LARIMORECLERK U s Dls-r cT.s. o. of /LZ. - MIXMICURACAO DRYDOCK COMPANY

, lNC., A/K/A

CURACAOSE DOKMAATSCHAPPIJ NV, A/K/ACDM NV,


W RIT OF GARNISH M ENT

THE STATE OF FLORIDA :

To All and Singular the Sheriffs of the State

And the U.S. M arshal's Service:

YOU ARE COM M ANDED to sum mon the garnishee, Church of Scientology Flag

Service Organization, Inc., by serving it and/or its registered agent, Robert V. Potter, at its

registered agent address: 91 1 Chestnut Street, Clearwater, FL 33756, to serve an answer to this

writ on JOHN THORNTON, ESQ., Judgment Creditors' attorney, whose addresses is Miami

Tower l00 Southeast Second Street Suite 2700 M iam i, FL 33 131, within 20 days afler service on

the garnishee, exclusive of the day of service, and to file the original with this court either before

service on the attorney or imrcediately thereafter stating whether the garnishee is indebted to the

defendant, Curacao Drydock Company, lnc. or its aliases nam ed above, at the time of service of

the answer OR was indebted at the tim e of service of the writ, OR at any tim e between such

times, AND in what sum and what tangible and intangible personal property of the defendant the


garnishee has in his possession or control at the tim e of the answer, OR had at the tim e of service

of this writ, O R at any tim e between such times, AND whether the garnishee knows of any other

person indebted to the defendant, OR who m ay be in possession or control of any of the property

of the defendant. The amount set in plaintiffs' motion is $80,000,000.00 plus interest accruing

from October 31, 2008 at the rate set by 28 U.S.C. j l 96l .

W ITNESS STEVEN M . LARIM O RE, as Clerk of the Court, and the deal of said Court, at

<the U.S. District Courthouse at Miami, Florida, this W day of C X , 2013.

STEVEN M . LARIM ORE

Clerk of the Court

By: w, 1

As Deputy Clerk



FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 06-22128-CV-K1NG/MCALlLEY

'j( o c tFILED by . .

:

0CT 2 2 2213

STEVEN .M LARIMORECLERK t? .s Dis'r cT

.s o of F'LA s MIXMI



LUIS ALBERTO CASANOVA TOLEDOS


VS.

CURK AO DRYDOCK COMPANY, 1NC., A/K/ACURK AOSE DOKMAATSCHAPPIJ NV, A/K/ACDM NV,

Defendant/ludgment Debtor.

PLAINTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARM SHM ENT

COMES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fernando

Alonso Hernandez, and Luis Alberto Casanova Toledo Cûplaintiffs''), by and through their

undersir ed cotmsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 e/. seq.


Defendant/ludgment Debtor Cm acao Drydock Company, Ine., to be served on Chtlrch of

Scientology of Florida, lnc., and as grounds therefore state:

1. On October 31, 2008, this Court entered a final Judgment in favor of Plaintiffs


set by 28 U.S.C. j 1961. DE 112.

On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00


'Ihe Final Judgm ent was not appealed and the time for appeal has passed.

4. Judgment Debtor has paid none of the judgment; the entire judgment remains

unsatisfied.



of the United States, Judgment Creditors have been unable to levy on Judgment Debtor's assets.

Judgment Debtor is a drydock facility located in Curacao.

Garnishee, The Chtlrch of Scientology International, lnc., or its agent or alter ego7.

is an owner of a ship that is currently in repair at the Judgment Debtor's drydock facility in

Curacao. As such, it owes Judgment Debtor for ship repairs.

8. Judgment Creditors suggest that gm ishee, The Church of Scientology

International, Inc., is in possession of moperty belonging to Judgment Debtor, Cm acao Drydock

Company, lnc.

9. Judgment Creditors seek a writ of gnrnishment pursllnnt to Fla. Stat. j 77.03.

M EREFOM , Judgment Creditors request the issuance of a writ of garnishment

against Curacao Drydock Company, lnc.'s moperty held by garnishee, The Church of

Scientology Intem ational, Inc., in the form attached hereto and to grant any further relief as is

just, fair and equitable.

Dated: October 21, 2013 Respectfully subm itted,

oo CAMPO & THORNTON, P.A.

M iam i Tower


Suite 2700

M inmi, 3) 1

Ph e: 305-3 -6600

zxax ' 5 60 1

B .V

Jo hornt

'da Bar No. 04820



*

A. .

. . *

F I t l N G F f :

PAID ùk . 1 uxjvso su w s olsrrm c'r COURT

jtvoo y. $ p F R THE SOUTHERN DISTRICT OF FLORIDA'steven M.. uao Fre, clerk p ASE NO. 06-22128-CV-KlNG/MCALILEY

ALBERTO JUSTO RODM GUEZ LICEA ,

FERNANDO ALONSO HERNANDEZ,AND


s,FILED by b' D.C.

1

02T 2 2 2013

STEVEN .M LARIMORECLERK U .s DlsT. c'cs D of /LA - MIAMI

Plaintifs/ludgment Creditors,

VS.

CURK AO DRYDOCK COMPANY, lNC., A/K/ACURK AOSE DOKM AATSCHAPPIJ NV, A/K/ACDM NV,



TlfE STATE OF FLORJDA:To A1l and Singular the Sheriffs of the StateAnd the U.S. M arshal's Service:

YOU ARE COM M ANDED to summon the garnishee, Church of Scientology of

Florida, lnc., by serving it and/or its registered agent, Craig Ftlrlin, at its registered agent address:

120 GIM LDA AVEN UE, COM L GABLES, FL 33134, to serve an answer to this writ on

JOHN THORNTON, ESQ., Judgment Creditors' attomey, whose addresses is Miami Tower 100

Southeast Second Street Suite 2700 M iami, FL 33131, within 20 days after service on the

garnishee, exclusive of the day of services and to file the original with this court either before

service on the attorney or immediately thereo er stating whether the garnishee is indebted to the

defendant, Cmacao Drydock Company, Inc. or its aliases named above, at the tim e of service of

the answer OR was indebted at the time of service of the writ, OR at any time between such

times, AND in what sttm and what tangible and intangible personal property of the defendant the


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gnrnishee has in his possession or control at the time of the answer, OR had at the time of service

of this writ, OR at any time between such times, AND whether the gam ishee knows of any other

person indebted to the defendant, OR who may be in possession or control of any of the property

of the defendnnt. The nmount set in plaintiffs' motion is $80,000,000.00 plus interest accruing

9om October 31, 2008 at the rate set by 28 U.S.C. j 1961.

W ITNESS STEVEN M . LARIM ORE, as Clerk of the Court, and the deal of said Court, at

the U.S. District Courthouse at Miami, Florida, this 'Zoday of btkyl.f , 2013.

STEVEN M .LARIM ORE

Clerk of the Court

By:

As De ty Clerk


UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 06-22128-CV-K1N G/M CAL1LEY

FILED by t D.C.1

0CT 2 2013

STEVEN .M LARIMORECLERK t) s oisT cT

.

s o of ;-t.A sysrvllALBERTO AJSTO RODRIGUEZ LICEA,

FERNANDO ALONSO HERNANDEA ANDLUIS ALBERTO CASAN OVA TOLEDO,


VS.

CURK AO DRYDOCK COMPANY, INC., A/K/ACURACAOSE DOKMM TSCHAPPIJ NV, AJK/ACDM NV,


PLM NTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARNISHM ENT

COMES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fernando

Alonso Hernandez, and Luis Alberto Casanova Toledo Csplaintiffs''), by and tlzrough their

undersigned counsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 c/. seq.


Defendant/ludgment Debtor Curacao Drydock Company, Inc., to be served on The Church of

Scientology lntem ational, Inc., and as grounds therefore state:

1. On October 31, 2008, this Court entered a final Judgment in favor of Plaintiffs


set by 28 U.S.C. j 1961. DE 112.

On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00


3. The Final Judgment was not appealed and the tim e for appeal has passed.

4. Judgment Debtor has paid none of the judgment; the entire judgment remains

tmsatisfied.



of the United States, Judgment Creditors have been unable to levy on Judgment Debtor's assets.

Judgment Debtor is a drydock facility located in Curacao.

Garnishee, The Chttrch of Scientology lnternational, lnc., or its agent or alter ego7.

is an owner of a ship that is currently in repair at the Judgment Debtor's drydock facility in

Cm acao. A s such, it owes Judgm ent Debtor for ship repairs.

8. Judgment Creditors suggest that gnrnishee, The Chtlrch of Scientology

Intem ational, Inc., is in possession of property belonging to Judgment Debtor, Curacao Drydock

Company, Inc.

9.

W HEREFORE, Judgment Creditors request the issuance of a writ of gnrnishment

against Curacao Drydock Company, Inc.'s property held by gam ishee, The Church of

Judgment Creditors seek a writ of gnrnishment pursdlnnt to Fla. Stat. j 77.03.

Scientology lntemational, lnc., in the form attached hereto and to grant any further relief as is

just, fair and equitable.

Dated: October 21, 2013 Respectfully submitted,

Do CAMPO & THORNTON, P.A.

M iami Tower


Suite 27

M i i, FL 33 31 .

one: 305-3 8-6600

. 0 - 66z' ,.

Jo orntocFl da BarNo. 004820



q ' 7

I t l N G F f SF

pAIn . w UNITED STATES Dlsrrltlc'r couR'r

R THE SOUTHERN DISTRICT OF FLORIDAt 9 lppp c4b 1'/ cAsE No. 06-22128-cv-Km G/M cALILEYP*

Steveg Mi. Lariozre, Clerq 1lil6'RTO JUSTO DRJGUEZ LICEA,

FERNANDO ALONSO HERNANDEA ANDLUISALBERTO CASANOVA TOLEDO,

FILED by D.C.

02T 2 2 2 13

STEVEN M LARIMORECLERK .tJ s Dis'r c'r,s D of F'LA - MlArç1l


VS.

CURACAO DRYDOCK COMPANY,m C.,AXUA

CURACAOSE DOKMAATSCHAPPIJNV,ASUACDMNV,


/


THE STATE OF FLORIDA:

To A1l and Singular the Sheriffs of the SoteAnd the U.S. Marshal's Service:

YOU ARE COM M ANDED to summon the ga ishee, The Church of Scientology

lntemational, lnc., by serving it at its address: 120 GIRALDA AVENUE, CORAL GABLES, FL

33134, to serve an answer to this writ on JOHN THORNTON, ESQ., Judgment Creditors'

attomey, whose addresses is Miami Tower 100 Southemst Second Street Suite 2700 M iami, FL

33 131, within 20 days after service on the garnishee, exdusive of the day of service, and to tlle

the original with this court either before service on the attorney or immediately thereafter stating

whether the garnishee is indebted to the defendant, Curacao Drydock Company, lnc. or its

aliases named above, at the time of service of the answer OR wms indebted at the time of service

of the writ, OR at any time between such times, AND in what stlm and what tangible and

intnngible personal property of the defendant the garnishee has in his possession or control at the


#'

time of the answer, OR had at the time of service of this writ, OR at any time between such

times, AND whether the garnishee knows of any other person indebted to the defendant, OR

who may be in possession or control of any of the property of the defendant. The amotmt set in

plaintifrs' motion is $80,000,000.00 plus interest accruing f'rom October 31, 2008 at the rate set

by 28 U.S.C. j 1961.

W ITNESS STEVEN M . LARIM ORE, as Clerk of the Court, and the deal of said Court, at

the U.S. District Courthouse at Miami, Floridw this l2. day of Y.'.S $,?.y'-', 2013.

STEVEN M .LARIM O RE

Clerk of the Court

By:

As De ty Clerk



FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 06-22128-CV-KING/MCALILEY




Plaintiffs/Judgment Creditors,

vs.

CURAÇAO DRYDOCK COMPANY, INC.,

A/K/A CURAÇAOSE DOKMAATSCHAPPIJ NV,

A/K/A CDMNV,

Defendant/Judgment Debtor.

/

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the Plaintiffs/Judgment Creditors’ Motion for Writ of

Garnishment [DE 378] and the Writ of Garnishment [DE 379] was mailed to: Curacao Drydock

Company, Inc. a/k/a Curacaose Dokmaatschappij, NV a/k/a CDMNV Dokweg 1, Koningsplein, P.O.

Box 3012, Curacao, Netherland Antilles.

Respectfully Submitted,

GROSSMAN ROTH, P.A.

2525 Ponce de Leon Blvd., Suite 1150

Coral Gables, Florida 33134

(305) 442-8666

(305) 285-1668

By: s/ Seth Miles

Seth Miles, Esq. Florida Bar No. 385530

[email protected]


UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION ALBERTO JUSTO RODRIGUEZ LICEA, : FERNANDO ALONZO HERNANDEZ, and : LUIS ALBERTO CASANOVA TOLEDO, : : Plaintiffs, : Case No. 06-22128-CIV- : KING/MCALILEY v. : : CURACAO DRYDOCK COMPANY, INC. a/k/a : CURACAOSE DOKMAATSCHAPPIJ NV a/k/a : CDMNV, : : Defendants, : ---------------------------------------------------------------X ALBERTO JUSTO RODRIGUEZ LICEA, : FERNANDO ALONZO HERNANDEZ, and : Case No. 11-22568-CIV- LUIS ALBERTO CASANOVA TOLEDO, : KING/MCALILEY : Plaintiffs, : v. : : ISLAND TERRITORY OF CURACAO, : THE GOVERNMENT OF THE NETHERLANDS : ANTILLES and THE KINGDOM OF THE : NETHERLANDS, : : : Defendants. : ----------------------------------------------------------------X

PLAINTIFFS’ NOTICE OF FILING VERIFIED RETURN OF SERVICE

Plaintiffs/Judgment Creditors, Alberto Justo Rodriguez Licea, Fernando Alonzo

Hernandez and Luis Alberto Casanova Toledo (collectively, “Plaintiffs”), by and through their

undersigned counsel, give notice of filing the verified Return of Service reflecting service of

process on Church of Scientology Flag Ship Service Organization, Inc., perfected on October 7,

2013. The Return is attached as Exhibit A.

Dated: July 7, 2014. GROSSMAN ROTH, P.A.

By: S/ Seth Miles

Seth Miles, Esq.


2



(305) 442-8666

DO CAMPO & THORNTON, P.A. John Thornton, Esq. Orlando do Campo, Esq.

100 Southeast Second Street, Suite 2700

Miami, Florida 33131

REED SMITH LLP

Jordan W. Siev, Esq.*

Casey D. Laffey, Esq.*

599 Lexington Avenue

New York, New York 10022

*Admitted Pro Hac Vice Attorneys for Plaintiffs/Judgment Creditors


3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served

electronically on July 7, 2014 upon all parties as noted in the service list below.

GROSSMAN ROTH, P.A.

By: S/ Seth Miles

Seth Miles, Esq.



(305) 442-8666

DO CAMPO & THORNTON, P.A. John Thornton, Esq. Orlando do Campo, Esq.

100 Southeast Second Street, Suite 2700

Miami, Florida 33131

REED SMITH LLP

Jordan W. Siev, Esq.*

Casey D. Laffey, Esq.*

599 Lexington Avenue

New York, New York 10022

*Admitted Pro Hac Vice

Attorneys for Plaintiffs/Judgment Creditors


4

SERVICE LIST Guy W. Harrison, Esq. ETCHEVERRY HARRISON LLP

150 South Pine Island Road, Suite 105

Ft. Lauderdale, FL 33324


Rodriguez Licea et al v. Curacao Drydock Co - Scientology Garnishment Writs (Oct2013)

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Transcript of Rodriguez Licea et al v. Curacao Drydock Co - Scientology Garnishment Writs (Oct2013)