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IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUITIN AND FOR MIAMI-DADE COUNTY, FLORIDA

LTA LOGISTICS, INC.,a Florida corporation, andLESTER TRBVflNO

GENERAL JURISDICTION DIVISIONPlaintiff,

CASENO.: 1 1 - 2 0 5 2 7 CA 2 1V.

ENRIQUE JOSE VARONA,

Defendant

VERIFIED COMPLAINT FOR DAMAGES. EMERGENCY PETITION FORTEMPORARY INJUNCTION AND FOR PERMANENT INJUNCTION

Plaintiff, LTA LOGISTICS, INC., and LESTER TRBVflNO files this Verified

Complaint for Damages, Emergency Petition for Temporary Injunction and for

Permanent Injunction, ("Verified Complaint") against Defendant, ENRIQUE JOSE

VARONA, individually and alleges as follows:

PARTIES

1. Plaintiff, LTA LOGISTICS, INC., is a Florida corporation with a principal

place of business at 14331 SW 120th Street Suite 203 Miami Florida 33186.

2. Plaintiff, LESTER TRIMINO is the President of LTA LOGISTICS INC.

3. Defendant, ENRIQUE JOSE VARONA, is an individual who is sui juris

and to the best knowledge and belief works and/or resides in Miami-Dade County,

Florida.

JURISDICTION AND VENUE

4. This is an action seeking temporary and permanent injunctive relief and

damages in excess of Fifteen Thousand Dollars (15,000.00), exclusive of interest, costs,

and attorneys' fees, arising from the Defendant's tortuous and systematic interference

with LTA's existing and potential business relations.

5. Venue is proper in this Court because the causes of action accrued in

Miami Dade County Florida and the Plaintiff and Defendants reside in and/or conduct

business in Miami-Dade County, Florida.

GENERAL ALLEGATIONS

6. LTA Logistics Inc., is a company that specializes in the acquisition and

coordination of all types of transportation throughout the United States and Canada. LTA

Logistics Inc. specializes in the transportation of heavy construction equipment,

hydraulic excavators, wheel loader equipment and all other types of large equipment,

from any point in the United States including Canada.

7. LTA's Logistics Inc. business and services are highly customer specific.

8. The Defendant was previously employed by LTA Logistics in June of 2009.

9. The Defendant was employed by the Plaintiff for approximately eight months.

10. Prior to the defendant's employment, the defendant executed a Nondisclosure and

Non-Solicitation Agreement which prohibited the defendant from soliciting any of the

Plaintiffs customers for a period of two years hi the event that the defendant would be

terminated from his employment with LTA Logistics.

11. The defendant's employment was terminated by the Plaintiff. The defendant

was subsequently employed by a direct competitor of LTA Logistics. The competitpr's

name is Landstar Logistics, Inc. The defendant was subsequently terminated from

employment with Landstar Logistics Inc.

12. Since the defendant's termination from Landstar Logistics, the defendant has

intentionally and systematically made false and misleading statements concerning LTA

Logistics Inc. The defendant has intentionally and systematically made false and

misleading statements about the President of LTA Logistic Inc. The defendant has been

making theses statements not only orally but by posting theses false and misleading

statements on the Web.

12. Beginning in June 2009, VARONA, individually launched a verbal and internet

attack campaign against LTA Logistics Inc. and the President of LTA Logistic Inc.,

Lester Trimino in a blatant effort to disrupt and interfere with LTA Logistic Inc. business

relationships and in a blatant effort to tarnish the reputation of LTA Logistics Inc. and

the President Lester Trimino.

13. The Defendant specifically listed a blog Titled LTA LOGISTICS LIAR LIAR

PANTS ON FIRE. LIES AND DECEPTION FROM LTA LOGISTICS INC AND

ITS VIOLENT OWNER.

14. The Defendant again listed another blog Titled LTA LOGISTICS A TRUE OR

FALSE QUIZ: TRUE OR FALSE YOU DECIDE LTA LOGICSTICS INC AND

ITS VIOLENT OWNER.

15. The Defendant has continued to post these blogs on the Web with the intent to

damage the business relationship LTA Logistics Inc. has with their customers and with

the intent to damage and tarnish the reputation of LTA Logistics Inc. and the President

Lester Trimino. (See affidavit of Lester Trimino attached hereto as exhibit "A")

16. In an effort to minimize the damage that the defendant is causing the Plaintiff has

been deleting said blogs hi an effort to preserve the Plaintiffs reputation in the industry.

The Plaintiff receives much of its business from advertising on the internet and these

direct assaults are having an adverse impact on the defendant's business.

17. This type of harassing and threatening behavior has systemically persisted

for months and has been carried out by the defendant. ENRIQUE JOSE VARONA.

18. The Defendant's unjustified actions have caused damage to LTA Logistics Inc.

business relationships and has caused damage to the reputation of The President of LTA

Logistics Lester Trimino and the company itself.

19. As a direct and proximate result of the Defendant's reckless, dangerous

and inexcusable behavior, LTA Logistics Inc., has lost sales and other

revenue and will continue to lose future sales and earnings unless this behavior is

stopped.

20. LTA Logistics Inc., has retained the undersigned counsel to represent it in

this action and is obligated to pay a reasonable fee for their services on its behalf, as well

as costs incurred.

22. All conditions precedent to bringing this action have been satisfied,

performed, or waived.

COUNTITEMPORARY AND PERMANENT EVJUNCTIVE RELIEF

23. LTA Logistic Inc re-alleges and incorporates by reference the allegations in

paragraphs 1 through 22 as though fully set forth herein.

24. To date, the owners, employees and agents of LTA Logistics fear

that the continued harassment by the defendant will have a lasting and permanent affect

on the companies business relationships and client base. As a direct result of this

unwarranted and unjustified harassing actions by the defendant the reputation of LTA

Logistics Inc., and the President Lester Trimino are being damaged. See Affidavit of

Lester Trimino attached hereto as Exhibit "A".

25. LTA Logistics Inc. is without an adequate remedy at law and will continue to

suffer irreparable harm if the Defendant is not enjoined, including but not limited to, the

continued and potential loss of sales and goodwill of the corporation.

26. LTA Logistics Inc. and its employees have a clear legal right to the relief

requested, i.e. to operate its business without the unrelenting constant attacks being

thrown at the Plaintiffs.

27. LTA Logistics Inc. has a substantial likelihood of success on the merits.

28. Enjoining ENRIQUE VARONA will prevent LTA LOGISTICS INC., from

losing additional sales, income, and longstanding lucrative business relations and the

entry of an injunction will not disserve or affect the public interest.

WHEREFORE, LTA LOGISTIC INC., a Florida corporation, and Lester Trimino

President of LTA Logistics demands judgment against Defendant, ENRIQUE JOSE

VARONA, for a temporary and permanent injunction declaring the foregoing conduct of

Defendant, ENRIQUE JOSE VARONA to be unlawful, enjoining Defendant, ENRIQUE

JOSE VARONA from continuing to engage in such conduct, including harassing,

approaching, associating, threatening or communicating by any means, with any owner,

employee, or agent of LTA Logistic Inc., and by immediately ceasing any further posting

on the Web as it relates to LTA Logistics Inc. and Lester Trimino as well as its

reasonable attorneys' fees and costs and any such other and further relief as this Court

deems just and proper.

COUNTHTORTUOUS INTERFERENCE WITH BUSINESS RELATIONS

29. LTA Logistics re-alleges and incorporates by reference the allegations in

Paragraphs 1 through 22 as though fully set forth herein.

30. Both a business and contractual relationship exist between LTA Logistics Inc

and numerous companies throughout Miami Dade County and the United States.

31. The Defendant ENRIQUE JOSE VARONA was previously employed by LTA

Logistics and as such had specific knowledge about the clients and business relationships

of the Plaintiff and how the Plaintiff advertised to secure those clients and how they

advertised to secure future clients.

32. The Defendant, ENRIQUE JOSE VARONA has intentionally and unjustifiably

interfered with the existing relationships Plaintiff has with its clients by intentionally and

recklessly launching a verbal and internet attack campaign against LTA Logistics and the

President Lester Trimino.

33. As a result of the above internet attacks by ENRIQUE JOSE VARONA,

LTA Logistics has lost sales and revenue. This will continue unless this behavior is

stopped.

34. Plaintiff reserves the right to seek punitive damages against the Defendant

set forth herein.

WHEREFORE, Plaintiffs, LTA Logistics Inc., a Florida Corporation and Lester

Trimino President of LTA Logistics, demands judgment against Defendant, ENRIQUE

JOSE VARONA, for (1) damages, including lost profits and consequential damages; (2)

prejudgment interest; (3) Plaintiffs reasonable attorneys' fees and costs; and (4) any such

other and further relief as this Court deems just and proper.

fKDate: June/'/ ,2011.

Respectfully submitted,

SCOTT EGLESTON12000 Biscayne BoulevardSuite 220North Miami, Florida 33181Tel: (305) 892-8088

IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUITIN AND FOR MIAMI-DADE COUNTY, FLORIDA

LTA LOGISTICS, INC.,a Florida corporation, andLESTER TRIMINO

GENERAL JURISDICTION DIVISIONPlaintiff,

CASE NO.:

ENRIQUE JOSE VARONA,

Defendant.

AFFIDAVIT OF LESTER TRIMINO

STATE OF FLORIDA )) SS

COUNTY OF MIAMI DADE )

LESTER TRIMINO being duly sworn deposes and says

1. I am over the age of 18

2. I am the President of LTA Logistics Inc., a Florida Corporation.

3. That Enrique Jose Varona was previously employed by LTA Logistics Inc.

4. That prior to the defendant's employment with LTA Logistics Inc., the defendant

executed a Nondisclosure and Non solicitation agreement which prohibited the

defendant from soliciting any of the Plaintiffs customers for a period of two

years in the vent that the defendant would be terminated from his employment

with LTA Logistics.

5. That the defendant was subsequently terminated from his employment with the

Plaintiff.

6. Subsequent to the defendants termination of his employment the defendant has

systematically and intentionally made false and misleading statements concerning

LTA Logistics Inc.

7. Since the defendant's termination of employment the defendant has launched a

verbal and internet attack campaign against LTA Logistics.

8. This attack campaign is having an adverse impact of the business relations and

relationships of LTA Logistics.

9. This internet attack campaign is damaging the reputation of LTA Logistics and

the President of LTA Logistics.

10. The above statements are made under the penalty of perjury.

FURTHER THE AFFIANT SAYETH NAUGHT.

Lester Trimino' U

The foregoing was acknowledged sworn and subscribed before me this day of

June 2011 by Lester Trimino president of LTA Logistics who is personally known to

me or has produced^ A. as identification and who did take an

oath.

My Commission Expires: J ;Notary Public State of

IMMACULADA FERNANDEZ

•\ Notary Public - State of FloridaI My Comm Expires Nov 19,2012

w .:" Commission # DO 839657

''"',-.T, ,V>'' Bonded Througn National Notary Assn.

Fax: (305) 892-9562

Bv:.SCOTT EGLESTONFlorida Bar No.: 883425

VERIFICATION

STATE OF FLORIDA ))

COUNTY OF MIAMI-BADE )

I, Lester Trimino President of LTA Logistics Inc., hereby declare and affirm

that the factual averments contained in the foregoing Verified Complaint are true and

correct to the best of my knowledge, information, and belief.

Dated this day of June / ' 2011.

IMMACULADA FERNANDEZNotary Public -State of Florida

My Comm. Expires Nov 19, 2012Commission # DO 839657

Rnnrt«d Through National Notary ten Notary Public, State of

My commission expires: