grisel valdes, and general ) - florida courts

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

THIRD DISTRICT

CASE NO. 3D16-1234 Lower Tribunal Case No.: 2016-003985 CA 01

GRISEL VALDES, and GENERAL ) CLAIMS MANAGEMENT ) CONSULTANTS, P.A., ) )

Defendants/Appellants, ) ) v. ) ) ANGELA SAINZ and OLIVIO O. ) BLANCO, Jr., D.C. in their ) representative capacity for ABEL & ) BUCHHEIM, P.R., INC., ) a Florida corporation, ) )

Plaintiffs/Appellees. ) _____________________________ )

APPELLANT GRISEL VALDES’ EMERGENCY MOTION FOR STAY OF WRIT OF BODILY ATTACHMENT

Appellant GRISEL VALDES respectfully files her Emergency Motion for

Stay Pending Review by the Florida Third District Court of Appeal (“this Court”),

and states as follows in support thereof.

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I.! NATURE OF EMERGENCY

The Honorable Antonio Marin signed a Writ of Bodily Attachment1 on

September 27, 2016, because Appellant Grisel Valdes has not paid $418,162.00 to

Appellees as per the April 27, 2016 Injunction Order that is under review by this

Court. Ms. Valdes has filed evidence with the lower court that she does not have the

present ability to comply with the contempt order or to purge the writ of bodily

attachment. As it stands, she will spend the rest of her life in jail because she has no

way of paying this money.

This Court is reviewing three non-final orders that stem from the lower court’s

decision to enter a temporary injunction order (“the Injunction Order”) in favor of

Appellees. The Injunction Order makes a finding, inter alia, that Appellees are the

majority owners of the corporation at issue. As articulated in Appellants’ initial brief

and reply brief, the order is invalid for numerous reasons ranging from a clerical

error to those of constitutional dimensions. Appellants reasonably believe that they

will succeed in the appeal of the April 27, 2016 Injunction Order.

After considering the arguments below, this Court should invoke its inherent

power to stay the Writ of Bodily Attachment pending this Court’s review of the

Injunction Order and the two related motions.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!1 Attached hereto as Exhibit A.

II.! MEMORANDUM OF LAW

a.! This Court should grant Appellant Grisel Valdes’ emergency motion for stay because she has demonstrated a likelihood of success on the merits and because she will be incarcerated absent a stay.

i.! Appellant will likely succeed in her Pending Appeal of the April 27, 2016 Injunction Order

This Court has the authority to issue a stay for purpose of preserving the status

quo during an appellate proceeding. Perez v. Perez, 769 So. 2d 389 (Fla. 3d DCA

1999). The Court should grant Appellants’ motion for stay on appeal because (1)

Appellant is likely to succeed on the merits, and (2) she will be harmed absent the

entry of a stay. Planned Parenthood of Greater Orlando v. MMB Properties, 148

So. 3d 810, 812 (Fla. 5th DCA 2014); Sunbeam Television Corp. v. Clear Channel

Metroplex, Inc., 117 So. 3d 772 (Fla. 3d DCA 2012).

Without repeating Appellant’s initial brief at length here, her likelihood of

success is reflected by the record and by the arguments contained in her briefs.

Moreover, Appellees even confessed partial error in their answer brief. (See Pg. 29

of Appellees’ Answer Brief). To summarize, the Injunction Order will likely be

reversed and vacated because the trial court abused its discretion and disregarded

Appellants’ constitutional due process rights by not allowing them to introduce or

cross examine evidence at the temporary injunction hearing on April 21, 2016, nor

at Appellants’ motion to dissolve the Injunction Order on May 11, 2016.

In addition to the factual and evidentiary deficiencies, the lower court lacked

jurisdiction when it entered the Injunction Order. The amended complaint (which

has since been replaced by a second amended complaint) failed to state a cause of

action for a shareholder’s derivative suit because it did not include an indispensable

party. The Injunction Order had no legal basis in the amended complaint. Even

though the amended complaint was amended, the injunction order cannot transfer

from one version of the complaint to a subsequent incarnation of the pleading. Thus,

the court was powerless to enter the injunction at the time that it did, and even if it

arguably was enabled to enter it, the injunction should have died with the defunct

amended complaint.

Furthermore, the Injunction Order will likely be vacated because it is

inconsistent with the lower court’s oral pronouncements at the injunction hearing on

April 21, 2016. The court probably mistakenly signed a proposed order that was

provided to it by Plaintiffs’ counsel before the April 21 hearing. At the conclusion

of the hearing, the court requested both parties to jointly prepare an order for the

court’s ratification, that was supposed to contain only the court’s oral

pronouncements from the hearing. The parties’ attorneys did work together to draft

an order for the court’s ratification, but the court suddenly executed Plaintiffs’

proposed pre-hearing version of the order which reflects numerous and significant

deviations from the court’s oral pronouncements, including factual findings that

were not made (nor even broached) by the court.

When juxtaposed, the differences between the specific terms of the written

order and the express directives of the oral pronouncements are stark. One critical

difference is that the written order commands Ms. Valdes to “return” $418,162.00

to her company, but leaves out the Court’s key provision that an accounting could

be provided if that money had already been spent on legitimate company obligations

and expenses. Another salient inconsistency is that the Court ordered that no party

be cut off from the company, while the written order provides the exact opposite of

that pronouncement—stating that Grisel Valdes shall stay away from, shall not enter,

or attempt to enter the company’s office; that she refrain from contact with any

company employees, clients, or medical participants; and that she be removed as a

signatory from the company’s bank account. Indeed, the written order and the oral

pronouncements are night and day. Amazingly, Ms. Valdes has tried to disabuse the

lower court from this error on multiple occasions, including multiple emergency

motions, yet the court has not vacated the order. For all of these independent

reasons, Appellant will likely be successful in her appeal of the Injunction Order.

ii.! Appellant will be irreparably harmed by going to jail because she is incapable of purging the lower court’s contempt order.

On September 21, 2016, this Court found that Defendant GRISEL VALDES

has willfully violated the Court’s Contempt Order because she “…has the ability to

comply or substantially comply” with the Injunction Order. The Court stated that

she would remain incarcerated until she complies or makes a good faith showing

that she cannot comply with the court’s order. At the show cause hearing on

September 21, 2016, neither party offered live testimony, nor was Ms. Valdes

present at the hearing. Ms. Valdes’ attorney did make proffers to show that Ms.

Valdes does not have the present ability to further comply with the court’s order.

Also at that hearing, Ms. Valdes produced a true and correct accounting that had

been previously produced to the Appellees, wherein the accounting itemized the

various payments that comprise the use of the $418,162.00 at issue.

In fact, Ms. Valdes does not have the ability to comply with this court’s order

to pay $418,162, nor can she provide passwords and passkeys to access the computer

hardware because she does not know them, nor does she have access to them. Mr.

Piedra is in possession of the hardware because Ms. Valdes turned over the

equipment to him as part of her best efforts to comply with the court’s order. Ms.

Valdes has done everything within her reach and ability to comply with the Court’s

Order as she turned over the required computer equipment and she produced an

accounting of the company’s use of the funds at issue. Ms. Valdes immediately filed

a verified Emergency Motion to Stay Execution of Writ of Bodily Attachment2, which

the lower court denied.

“The key safeguard in civil contempt proceedings is a finding by the trial court

that the contemnor has the ability to purge the contempt.” Parisi v. Broward Cty.,

769 So. 2d 359, 365 (Fla. 2000). Ms. Valdes does not have the ability to purge the

contempt found in this case because she cannot substantially comply with the

required financial payment, nor does she know any of the passwords referenced in

the order. Further, because of the complicated accounts at issue, Ms. Valdes is not

certain as to the exact amount needed to be paid to purge the contempt order (even

assuming arguendo that she could pay it), because the parties have not discussed the

accounts as required per the lower court’s oral pronouncements at the April 21

injunction hearing.

Thus, this Court should stay the execution of the writ of bodily attachment

because it has not been proven that Ms. Valdes has the ability to comply with the

order, but on the contrary, Ms. Valdes has produced irrefutable evidence to support

the fact that she cannot comply. It would be extremely unjust for Ms. Valdes to

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!2 Attached hereto as Exhibit B, please find Grisel Valdes’ verified Motion to Stay Execution of Writ of Bodily Attachment.

serve a life sentence in jail in a civil case. There is no question Ms. Valdes will be

harmed if this Court does not stay the Writ of Bodily Attachment.

III.! CONCLUSION For all of the foregoing independent reasons, Appellant prays for this Court

to stay the Writ of Bodily Attachment until this Court has ruled on the Injunction

Order and on the overarching matters that are on appeal.

Dated: October 11, 2016

Respectfully submitted,

TREMBLY LAW FIRM Attorneys for Defendant/Appellant 9700 South Dixie Highway, Suite 680 Miami, Florida 33156 Telephone: (305) 431-5678 E-Mail: [email protected] Secondary: [email protected]

By: /s/ Fred Viera Fred Viera Florida Bar No. 728535

CERTIFICATE OF SERVICE

I HEREBY CERTIFY, that on October 11, 2016, a true and correct copy of

the foregoing was served via the Court’s E-Filing Portal and via e-mail upon

attorneys for Plaintiffs, Jorge Piedra, Esq. at [email protected] and

[email protected]; and to Mark S. Gallegos, Esq. at

[email protected].

By: /s/Fred Viera_____________

____________________________________________________________________________________________"

Trembly"Law"Firm"–"9700"S."Dixie"Highway,"Suite"680"–"Miami,"Florida"33156"

Ph."(305)"431I5678"I"www.tremblylaw.com""

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Trembly"Law"Firm"–"9700"S."Dixie"Highway,"Suite"680"–"Miami,"Florida"33156"


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_____________________________________________________________________________________________"Trembly"Law"Firm"–"9700"S."Dixie"Highway,"Suite"680"–"Miami,"Florida"33156"


" IN#THE#CIRCUIT#COURT#OF#THE#ELEVENTH#JUDICIAL#CIRCUIT"IN#AND#FOR#DADE#COUNTY,#FLORIDA"

""ANGELA"SAINZ"as"shareholder"of""""""""""""""""""""""""""""""""""""""""""""""""Case"No.:"2016I003985"CA"01"ABEL"&"BUCHHEIM,"P.R.,"INC.,"and""OLIVIO"O."BLANCO,"Jr.,"D.C.,"as"shareholder""of"ABEL"&"BUCHHEIM,"P.R.,"INC.,"a"Florida""Corporation,"and"ABEL"&"BUCHHEIM,"P.R.,"INC.,"a"Florida"Corporation,"" " " " " " " " "" " Plaintiffs,"vs.""GRISEL"VALDES,"individually,"and"GENERAL"CLAIMS"MANAGEMENT"CONSULTANTS,"P.A.,"a"Florida"professional""association,"ABEL"&"BUCHHEIM,"LLC,"a"Florida"limited"liability"company,"and"Mark"S."Gallegos,"an"individual,""" " Defendants."___________________________________________________/""

DEFENDANT#GRISEL#VALDES’#EMERGENCY#MOTION#TO#STAY#EXECUTION#OF#WRIT#OF#BODILY#ATTACHMENT#

#" Defendant" GRISEL"VALDES" by" and" through" undersigned" counsel," hereby" files" this"

Emergency"Motion"to"Stay"Execution"of"Writ"of"Bodily"Attachment"and"as"grounds"states"as"

follows:"

1.! On"September"21,"2016,"this"Court"found"that"Defendant"GRISEL"VALDES"has"

willfully"violated" the"Court’s"Contempt"Order"because"she" “…has" the"ability" to" comply"or"

substantially"comply”"with"the"April"27,"2016"injunction"order"(“the"Court’s"Order”)."

2.! The"Court"ordered"for"the"issuance"of"a"writ"of"bodily"attachment"within"72"

hours"of"the"entry"of"the"order"of"September"21,"2016."

3.! The"Court" stated" that" she"would" remain" incarcerated"until" she" complies"or"

makes"a"good"faith"showing"that"she"cannot"comply"with"the"Court’s"Order.""

Filing # 46810719 E-Filed 09/22/2016 04:11:41 PM



4.! At"the"hearing"on"September"21,"2016,"neither"party"offered"live"testimony,"

nor" was" Ms." Valdes" present" at" the" hearing." " Ms." Valdes’" attorney," Fred" Viera," did" make"

proffers"to"show"that"Ms."Valdes"does"not"have"the"present"ability"to"further"comply"with"

the"Court’s"Order."

5.! At" the" hearing" on" September" 21," 2016," Ms." Valdes" produced" a" true" and"

correct" accounting" that" had" been"previously" produced" to" Plaintiffs’" counsel,"wherein" the"

accounting"itemized"the"various"payments"that"comprise"the"use"of"the"$418,162"at"issue."

6.! Ms."Valdes"does"not,"in"fact,"have"the"ability"to"comply"with"this"Court’s"Order"

to" pay" $418,162" nor" can" she" provide" passwords" and" passkeys" to" access" the" computer"

hardware"because"she"does"not"know"them,"nor"does"she"have"access"to"them." "Mr." Jorge"

Piedra"is"in"possession"of"the"hardware."

7.! Ms."Valdes"has"done"everything"within"her"reach"and"ability"to"comply"with"

the" Court’s" Order" as" she" has" turned" over" the" required" computer" equipment" and" has"

produced"an"accounting"of"the"company’s"use"of"the"$418,162"at"issue."

8.! “The" key" safeguard" in" civil" contempt" proceedings" is" a" finding" by" the" trial"

court" that" the" contemnor"has" the"ability# to#purge" the" contempt.”" "Parisi&v.&Broward&Cty.,"

769"So."2d"359,"365"(Fla."2000)."

9.! Ms."Valdes"does"not"have"the"ability"to"purge"the"contempt"found"in"this"case"

because"she"cannot"substantially"comply"with"the"required"financial"payment,"nor"does"she"

know"any"of"the"passwords"referenced"in"the"order.""(See&attached&affidavit)."

10.! Further," because" of" the" complicated" accounts" at" issue," Ms." Valdes" is" not"

certain"as"to"the"exact"amount"needed"to"be"paid"to"purge"the"contempt"order,"because"the"

parties"have"not"discussed"the"accounts"as"required"per"the"Court’s"Order."



11.! Thus," the" Court" should" stay" its" execution" of" the"writ" of" bodily" attachment"

because"it"has"not"been"proven"that"Ms."Valdes"has"the"ability"to"comply"with"the"order,"but"

on"the"contrary,"Ms."Valdes"has"produced"irrefutable"evidence"to"support"the"fact"that"she"

cannot"comply."""""""""""""

WHEREFORE," Ms." Valdes" prays" for" the" Court" to" stay" its" execution" of" the" writ" of"

bodily"attachment"because"she"does"not"have"the"ability"to"further"comply"with"the"Court’s"

temporary"injunction"order"as"pronounced"at"the"hearing"on"April"21,"2016."

"

Respectfully"submitted"this"22nd"day"of"September,"2016."

TREMBLY#LAW#FIRM#Attorneys&for&Defendants1&9700"South"Dixie"Highway,"Suite"680""Miami,"Florida"33156"Telephone:"(305)"431I5678"EIMail:"[email protected]"Secondary"EIMail:"[email protected]"""By:"/s/""Fred"Viera" " " ""

"""""""" " " " " " " Fred#Viera#Florida"Bar"No."728535"

"

CERTIFICATE#OF#SERVICE##

I" HEREBY" CERTIFY," that" on" September" 22," 2016," a" true" and" correct" copy" of" the"

foregoing" was" served" via" the" Court’s" EIFiling" Portal" and" via" eImail" upon" attorneys" for"

Plaintiffs,"Jorge"Piedra,"Esq."at"[email protected]"and"[email protected];"and"to"

Mark"S."Gallegos,"Esq."at"[email protected].""

"

" " " " " """"""""""" """"" By:"/s/"Fred"Viera" "

1 Not"including"Mark"Gallegos,"Esq.

IN#THE#CIRCUIT#COURT#OF#THE#ELEVENTH#JUDICIAL#CIRCUIT!IN#AND#FOR#DADE#COUNTY,#FLORIDA!

!!ANGELA!SAINZ!as!shareholder!of!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!Case!No.:!2016:003985!CA!01!ABEL!&!BUCHHEIM,!P.R.,!INC.,!and!!OLIVIO!O.!BLANCO,!Jr.,!D.C.,!as!shareholder!!of!ABEL!&!BUCHHEIM,!P.R.,!INC.,!a!Florida!!Corporation,!and!ABEL!&!BUCHHEIM,!P.R.,!INC.,!a!Florida!Corporation,!! ! ! ! ! ! ! ! !! ! Plaintiffs,!vs.!!GRISEL!VALDES,!individually,!and!GENERAL!CLAIMS!MANAGEMENT!CONSULTANTS,!P.A.,!a!Florida!professional!!association,!ABEL!&!BUCHHEIM,!LLC,!a!Florida!limited!liability!company,!and!Mark!S.!Gallegos,!an!individual,!!! ! Defendants.!___________________________________________________/!!

AFFIDAVIT#OF#GRISEL#VALDES#IN#SUPPORT#OF#EMERGENCY#MOTION#TO#STAY#EXECUTION#OF#WRIT#OF#BODILY#ATTACHMENT#

#! I,!GRISEL!VALDES,!do!hereby!affirm,!under!penalty!of!perjury,!the!following:!

1.! My! name! is! GRISEL! VALDES! (“Affiant”),! and! I! am! over! the! age! of! 18! and!

otherwise! sui$ juris.! ! The! facts! set! forth! in! this! Affidavit! are! based! on! my! personal!

knowledge.!!

2.! I!do!not!own!any!assets,!other!than!my!home.!

3.! I!do!not!have!access!to!any!credit!that!would!enable!me!to!borrow!funds!in!

order!to!pay!$418,162.!

4.! I!am!not!the!beneficiary!of!any!trust.!

5.! I!am!not!a!named!beneficiary!of!any!life!insurance!policy.!

6.! For!the!last!five!months,!I!have!been!supported!by!my!son.!

7.! For! the! last! five!months,! I! have! actively! sought,! but! have! not! been! able! to!

secure,! full:time!employment,! at! least!partly! resulting! from! this! frivolous! lawsuit! against!

of 3

me! and! because! Angela! Sainz! and! Olivio! Blanco! have! tarnished! my! reputation! in! the!

professional!community!in!my!field.!

8.! ABEL!&!BUCHHEIM,!LLC,!of!which!I!am!the!sole!member!and!manager,!owns!

only!one!asset,!a!bank!account!at!Citibank,!N.A.,!which!has!a!current!balance!of!$4,963.07.!!

(See$ attached$ bank$ statement)! This!money! is! earmarked! to! be! paid! on!behalf! of!ABEL!&!

BUCHHEIM!P.R.,!INC.!for!legitimate!company!obligations.!

9.! The! accounting! of! the! disbursements! provided! to! the! Court! during! the!

hearing!on!September!21,!2016,!regarding!the!transactions!related!to!the!$418,120,!is!true!

and!accurate.!!

10.! I!never!stole!any!money!from!ABEL!&!BUCHHEIM!P.R.,!INC.!

11.! Angela!Sainz!stole!at!least!$100,000!from!ABEL!&!BUCHHEIM!P.R.,!INC.!!

12.! Any!money!that!I!personally!received!from!ABEL!&!BUCHHEIM!P.R.,!INC.!was!

received!as!a!result!of!ABEL!&!BUCHHEIM!P.R.,!INC.’s!direction!to!pay!legitimate!expenses.!!

13.! I!do!not!have!a!personal!bank!account! in!my!individual!name!because!I!use!

the!bank!account!of!General!Claims!&!Management!Services,!PA,!from!TD!Bank,!which!holds!

approximately!$101.21!as!of!September!19,!2019.!(See$attached$bank$statement)!

14.! I!do!not!possess!any!physical!cash.!

15.! My! only! significant! asset! is! the! equity! in! my! home,! which! is! illiquid,! and!

which!I!have!been!trying!to!sell,!but!have!not!found!a!buyer.! !Even!if! I!were!successful! in!

selling! the! property,! it! is! encumbered! by! a!mortgage! that!would! command! a! significant!

amount!of! the!sales!proceeds!at!closing.! !Even!assuming! that! the!home!could!sell! for! fair!

market!value,!I!would!still!not!have!anywhere!near!enough!to!pay!$418,162.!

16.! I!do!not!have!direct!or!indirect!access!to!any!family!or!friends!that!could!lend!

or!grant!the!necessary!funds!or!assets!in!order!to!pay!$418,162.!

17.! I!am!not!expecting!to!inherit!any!money!from!anyone’s!estate.!

18.! If!I!am!incarcerated!under!the!condition!that!I!pay!$418,162,!I!will!spend!the!

rest! of!my! life! in! jail! because! I! have!no!way!of! earning!money! to!pay! this! amount!while!

incarcerated,!nor!do!I!expect!anyone!to!pay!this!money!on!my!behalf.!

19.! I!neither!possess,!nor!know!of,!nor!have!access! to,!any!of! the!passwords!or!

passkeys! related! to! the! computer!hardware! that! I! turned!over! to! Jorge!Piedra’s! office! in!

compliance!with!this!Court’s!injunction!order.!

20. I hereby, in good faith, declare to this Court that I do not have the ability tofurther comply with this Court's order to pay $418,L62, nor can I provide passwords andpasskeys to access the computer hardware because I do not know them, nor do I haveaccess to them.

FURTHER AFFIANT SAYETH NAUGHT.

Dated September 22, 20L6

STATE OF FLORIDA

COUNTY OF MIAMI-DADE

Sworn to or affirmed and signed before me on thir&L*yof Septem ber, ZA16,byGRISEL vALDEs who is

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