in the circuit court of the 11th judicial circuit in and...

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IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: MELANIE E. DAMIAN, as Receiver for LAS ESTRELLAS CONDOMINIUM, ASSOCIATION, INC., Plaintiff, v. SERGIO O. SANCHEZ, LUZ GONZALEZ, and ORLANDO CALDERIN, Defendants. ____________________________________/ COMPLAINT Plaintiff, Melanie E. Damian, in her capacity as the Court-appointed Receiver ( “Receiver”) for Las Estrellas Condominium Association, Inc. (“Las Estrellas” or the “Association”), hereby sues Defendants, Sergio O. Sanchez, Luz Gonzalez, and Orlando Calderin (collectively, the “Defendants”), and alleges: INTRODUCTION 1. This lawsuit is brought as part of the Receiver’s continuing efforts to conduct operations of the Association for the benefit of the Association, the unit owners and its creditors, and as a result of the failure of the Defendants to exercise due care, loyalty, and responsibility in their roles as Officers, Directors, and control persons of the Association. 2. The Defendants breached their fiduciary duties of care by causing and/or allowing the Association to become liable for a $766,149.91 debt and by mismanaging and wasting Association funds. Filing # 102751973 E-Filed 02/04/2020 05:37:07 PM

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Page 1: IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND ...lasestrellascondoreceivership.com/Complaint - 2-4-20 FILED.pdf · 3 8. Defendant Sergio O. Sanchez is a citizen and resident

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.:

MELANIE E. DAMIAN, as Receiver for LAS ESTRELLAS CONDOMINIUM, ASSOCIATION, INC., Plaintiff, v. SERGIO O. SANCHEZ, LUZ GONZALEZ, and ORLANDO CALDERIN, Defendants. ____________________________________/

COMPLAINT

Plaintiff, Melanie E. Damian, in her capacity as the Court-appointed Receiver ( “Receiver”)

for Las Estrellas Condominium Association, Inc. (“Las Estrellas” or the “Association”), hereby

sues Defendants, Sergio O. Sanchez, Luz Gonzalez, and Orlando Calderin (collectively, the

“Defendants”), and alleges:

INTRODUCTION

1. This lawsuit is brought as part of the Receiver’s continuing efforts to conduct

operations of the Association for the benefit of the Association, the unit owners and its creditors,

and as a result of the failure of the Defendants to exercise due care, loyalty, and responsibility in

their roles as Officers, Directors, and control persons of the Association.

2. The Defendants breached their fiduciary duties of care by causing and/or allowing

the Association to become liable for a $766,149.91 debt and by mismanaging and wasting

Association funds.

Filing # 102751973 E-Filed 02/04/2020 05:37:07 PM

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3. The Plaintiff, in her capacity as the Receiver for the Association, now seeks to

recover for the benefit of the Association those damages caused by the Defendants’ breaches of

fiduciary duty.

4. The claims stated in this Complaint relate to actions and omissions by the

Defendants, former directors and officers of the Association.

PARTIES, JURISDICTION, AND VENUE

5. On January 7, 2020, the Circuit Court of the Eleventh Judicial Circuit in and for

Miami-Dade County appointed the Receiver in the action styled Joel D. Vega, et al. v. Las Estrellas

Condominium Association, Inc., Case No. 2015-2310 CA 01 (09) (the “Vega Action”) in the Order

attached as Exhibit A. The Court issued an Amended Appointment Order on January 26, 2020,

which is attached as Exhibit B (the “Appointment Order”). In the Appointment Order, the Court

appointed the Receiver and granted her the powers of a receiver over the Condominium in order

to, among other things, “protect and preserve the assets of the Judgment Debtor LAS ESTRELLAS

from waste.” Id.

6. The Receiver has standing to bring these claims pursuant to the Court’s

Appointment Order. See Exhibit B. The Appointment Order specifically empowers the Receiver

to, among other things “[i]nvestigate, institute, prosecute, maintain, defend, intervene, and

otherwise participate in any legal proceedings by, or on behalf of, or against the Association or in

which the Association or its creditors have any interest.” Id. at 5, ¶(9).

The Defendants

7. The Defendants, Sanchez, Gonzalez, and Calderin, are individuals. At all times

material hereto, the Defendants were all officers, members of the Board of Directors, control

persons, and/or employees of Las Estrellas.

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8. Defendant Sergio O. Sanchez is a citizen and resident of Miami-Dade County and

is sui juris. At all times material hereto, Sanchez served as President of the Board of Las Estrellas.

As the President of the Board of Las Estrellas, Sanchez controlled and/or participated in the

policies, operations, and business of Las Estrellas.

9. Defendant Luz Gonzalez is a citizen and resident of Miami-Dade County and is sui

juris. At all times material hereto, Gonzalez served as a member of the Board of Las Estrellas, and,

as such controlled and/or participated or utterly failed to participate in the policies, operations, and

business of Las Estrellas.

10. Defendant Orlando Calderin is a citizen and resident of Miami-Dade County and is

sui juris. At all times material hereto, Calderin served as a member of the Board of Las Estrellas,

and, as such, controlled and/or participated or utterly failed to participate in the policies,

operations, and business of Las Estrellas.

Jurisdiction and Venue

11. This is an action for damages which exceed $30,000.00, exclusive of fees and costs.

12. Venue in this Court is proper because the acts or omissions giving rise to these

claims occurred in Miami-Dade County, Florida.

13. All conditions precedent to this action have been performed or have been excused

or requiring performance of conditions precedent would be futile.

FACTUAL ALLEGATIONS

14. Las Estrellas consists of 220 condominium units over two four-story buildings

located at 606 and 666 W. 81 Street, Hialeah, Florida, was constructed in 1971 and formed as a

condominium in December 2001.

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15. As stated above, at all times material hereto, the Defendants were members of the

Board of Directors of Las Estrellas, were officers, and/or controlled and/or participated in its

policies, operations, and business.

The Vega Action

16. In 2015, Las Estrellas was named as a counter-defendant in the Vega Action by

Counter-Plaintiffs, Joel D. Vega and Camila Belewn Ristano. See Counterclaim attached hereto as

Exhibit C.

17. On February 28, 2017, the Court granted Las Estrellas’s counsel’s motion to

withdraw and ordered Las Estrellas to hire replacement counsel to represent it in the suit and file

an appearance on its behalf within 30 days. See Order attached hereto as Exhibit D.

18. The Defendants failed to hire replacement counsel, and, on August 3, 2017, the

Court sanctioned Las Estrellas for its failure to hire replacement counsel and struck its pleadings.

See August 3, 2017 Order attached hereto as Exhibit E.

19. Thereafter, on December 18, 2018, the Defendants caused Las Estrellas to enter

into a Settlement Agreement in which Las Estrellas would pay Vega and Ristano $700,000 plus

interest. At the time, Defendants knew or should have known that Las Estrellas was incapable of

making any payments pursuant to the Settlement Agreement, the agreed amount of the judgment

was not supported by evidence and a number of defenses were not asserted.

20. Las Estrellas failed to make any payments pursuant to the Settlement Agreement

and, on August 29, 2019, the Court entered a Final Judgment against Las Estrellas and in favor of

Vega and Ristano in the amount of $757,341.18, together with accruing interest. See August 29,

2019 Final Judgment as Exhibit F.

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21. As officers, directors, and/or control persons of Las Estrellas, the Defendants owed

a fiduciary duty to Las Estrellas to, among other things, exercise diligence and care in managing

Las Estrellas in the best interests of Las Estrellas, including defending Las Estrellas in the Vega

Action.

22. In their fiduciary capacities, the Defendants failed to exercise their fiduciary duty

of care by, among other things, recklessly in conscious disregard of the obvious risks (1) allowing

Las Estrellas’s interests to go undefended in the Receivership Action, thereby resulting in Las

Estrellas’ pleadings to be stricken; (2) causing Las Estrellas to enter into a Settlement Agreement

in an amount that was not provable against Las Estrellas, and for which it was incapable of paying;

(3) causing Las Estrellas to fail to make any payments required by the Settlement Agreement,

resulting in entry of the $757,341.18 Final Judgment against Las Estrellas and the Receivership

Order.

23. In addition, the Defendants have recklessly mismanaged the funds of the

Association and in reckless disregard for known and obvious risks failed to prevent waste of the

Association’s assets.

The Defendants’ Breaches of Their Duties Caused Substantial Damages to Las Estrellas

24. At all times material hereto, the Defendants were acting within the course and scope

of their duties as directors, officers, control persons, and/or employees of Las Estrellas.

25. At all times material hereto, the Defendants were authorized to and did act on

account of Las Estrellas and were charged with the responsibility of the business and operations

of Las Estrellas, which included protection of Las Estrellas’s assets from improper or unnecessary

waste or depletion.

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26. The Defendants were vested with the management of the business and affairs of

Las Estrellas; however, rather than manage Las Estrellas in the best interests of the Association

and its members and creditors, the Defendants stood idly by while Las Estrellas’s interests were

unprotected in the Vega Action.

27. The Defendants, as directors, officers, and control persons of Las Estrellas, owed

Las Estrellas and its members and creditors a high duty of good faith and due care. Indeed, they

owed a fiduciary duty to Las Estrellas that precluded them from behaving in a manner contrary to

the interests of Las Estrellas or its members and creditors. The Defendants, as a consequence of

their duty, are accountable for any breach of the trust and confidence that was reposed in them by

Las Estrellas.

28. The misconduct by the Defendants was a breach of their duty of good faith and due

care, and of their fiduciary duty to Las Estrellas and its members and creditors.

29. As a result of the Defendants’ breaches of their duties to Las Estrellas and its

members and creditors, Las Estrellas is liable for a $757,341.18 Final Judgment plus interest

attorney’s fees and the costs of the Receivership, plus hundreds of thousands of dollars in

mismanagement and waste.

30. Las Estrellas, and thereby the Receivership Estate, have been damaged significantly

as a direct and proximate result of the misconduct of the Defendants as alleged above. Such

damages include but are not limited to: the monetary judgment entered by the Court in the

Receivership Action and such other and further compensatory and consequential damages as may

be appropriate.

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31. Accordingly, the Receiver brings the instant action in order to collect monies that

were improperly transferred, dissipated, misappropriated, or lost from Las Estrellas as a result of

the Defendants’ breaches of fiduciary duty of good faith and care.

32. All conditions precedent to the bringing of this action have been performed or

satisfied or have occurred.

33. The Plaintiff has retained the undersigned law firm and is obligated to compensate

them their services.

COUNT I Breach of Fiduciary Duty

(All Defendants)

34. Plaintiff hereby re-asserts the allegations set forth in paragraphs 1 through 33,

above, as if fully set forth herein.

35. At all material times hereto, Defendants, Sergio O. Sanchez, Luz Gonzalez, and

Orlando Calderin, were officers, directors, control persons, and/or employees of Las Estrellas.

Specifically, they were the President and members of the Board of Directors of Las Estrellas, and,

in those capacities, owed a fiduciary duty to Las Estrellas and its members and creditors to

discharge their obligations in good faith, with the care that an ordinarily prudent officer, director,

manager, or employee in a like position would exercise, and in a manner reasonably believed to

be in Las Estrellas’s best interests.

36. The Defendants continuously and on an ongoing basis breached their fiduciary

duties to Las Estrellas by, inter alia, recklessly and in conscious disregard of the known obvious

risks:

a. allowing Las Estrellas’s interests to go undefended in the Vega action,

thereby resulting in Las Estrellas’s pleadings being stricken;

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b. causing Las Estrellas to enter into a Settlement Agreement in an amount

that was not provable and which Las Estrellas was incapable of paying;

c. causing Las Estrellas to fail to make any payments required by the

Settlement Agreement, resulting in entry of the $757,341.18 Final Judgment

against Las Estrellas requiring a receiver be appointed and additional costs

and expenses defending collection efforts.

d. permitting mismanagement and waste of association funds and assets.

37. Defendants knew, or it should have been obvious, that there was a risk so great as

to make the harm to the Association probable from the foregoing actions and inactions.

38. These breaches proximately caused damages to Las Estrellas and its members and

creditors.

WHEREFORE, Plaintiff, Melanie E. Damian, as the Receiver for Las Estrellas, hereby

demands judgment against the Defendants, Sergio O. Sanchez, Luz Gonzalez, and Orlando

Calderin, for the total amount of Las Estrellas’s damages resulting from their breaches of their

fiduciary duties to Las Estrellas, plus costs and interest, and attorneys’ fees, if appropriate, and

such further relief as this Court deems to be appropriate and just.

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DEMAND FOR JURY TRIAL

Plaintiff hereby demands a jury trial on all issues and claims so triable.

Respectfully submitted this___ day of February, 2020.

By: /s/ Thomas CulmoTHOMAS CULMO, Esq. Florida Bar No. 775479 Email: [email protected] RUSSELL LANDY, Esq. Florida Bar No. 44417 Email: [email protected] DAMIAN & VALORI LLP Counsel for the Receiver 1000 Brickell Avenue, Suite 1020 Miami, Florida 33131 Telephone: (305) 371-3960 Facsimile: (305) 371-3965

4th

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EXHIBIT A

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EXHIBIT B

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EXHIBIT C

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EXHIBIT D

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EXHIBIT E

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EXHIBIT F

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