Filing # 33956334 E-Filed 11/02/2015 03:34:48 PM€¦ · leather. Compared to real leather furniture, bonded leather furniture is of significantly lower quality, lacks durability,

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUITHILLSBOROUGH COUNTY, FLORIDA

CIVIL DIVISION

CLIFF BROWN, individually, and on behalfof all similarly situated persons,

Plaintiff,

vs.

KANE FURNITURE CORPORATION,

Defendant.

CLASS REPRESENTATION

Case No.: 15-CA-006875Division: A

FIRST AMENDED CLASS ACTION COMPLAINTAND DEMAND FOR JURY TRIAL

Plaintiff, Cliff Brown, individually and on behalf of all those similarly situated, sues

Defendant, Kane Furniture Corporation ("Defendant" or "Kane's"), and alleges as follows:

PARTIES, JURISDICTION, AND VENUE

1. This is an action for damages in excess of $15,000.00, exclusive of interest,

attorneys' fees, and costs.

2. This is a class action lawsuit for deceptive and unfair business practices in

violation of Florida's Deceptive and Unfair Trade Practices Act, §§ 501.201 et seq. of the Florida

Statutes ("FDUTPA"), as well as claims for declaratory and injunctive relief, equitable relief,

breach of contract, and breach of express and implied warranties.

3. Plaintiff resides in Hillsborough County, Florida.

4. Defendant is a Florida corporation with 18 retail furniture stores throughout

Florida.

Filing # 33956334 E-Filed 11/02/2015 03:34:48 PM

5. Venue is proper before this Court under Chapter 47 of the Florida Statutes

because, among other things, (a) Defendant has agents or other representatives in Hillsborough

County, Florida, and (b) Plaintiff's causes of action accrued in Hillsborough County, Florida.

GENERAL ALLEGATIONS

6. Defendant sells household furniture products in the retail market to consumers.

7. Among the products that Defendant sells is furniture manufactured by, among

others, Southern Motion, Inc. ("Southern Motion") that is made from aleather-like substance

called "Bonded Leather."

8. Defendant purchases these Bonded Leather furniture items from Southern Motion

and sells them to Defendant's customers.

9. Defendant has sold thousands of pieces of Bonded Leather furniture manufactured

by Southern Motion ("Southern Motion Bonded Leather Furniture") to its customers throughout

Florida.

10. At all material times, Defendant was aware that bonded leather is not leather, but is

a synthetic, man-made, processed leather-like substance that contains only small amounts of

leather. Compared to real leather furniture, bonded leather furniture is of significantly lower

quality, lacks durability, can crack, peel, flake, and deteriorate rapidly, and cannot be easily repaired

or reconditioned. Defendant is aware that the Southern Motion Bonded Leather Furniture that it

sells is not leather, but nonetheless markets and represents to the public and its customers that the

Southern Motion Bonded Leather Furniture is "leather furniture."

11. Plaintiff visited Defendant's retail store located at 6222 North Dale Mabry

Highway, Tampa, Florida (the "Store") to purchase furniture.

12. Plaintiff purchased two items of living room furniture from Defendant, a reclining

sofa and a power console ("Plaintiff's Furniture"). Plaintiffls Furniture was Southern Motion

Bonded Leather Furniture.

13. Defendant marketed and represented to Plaintiff that Plaintiff's Furniture was

"leather furniture."

14. Plaintiff paid a total of $2,239.97 for Plaintiffs Furniture by making a $239.99

deposit and financing the remaining $1,999.98. A complete, accurate, and authentic copy of

Sales Order #0520116XY91 reflecting the purchase and financing of Plaintiff's Furniture (the

"Sales Order") is attached as Exhibit 1.

15. Plaintiffs Furniture and all Southern Motion Bonded Leather Furniture were

covered by a "Lifetime Warranty," described in a brochure provided at the time of the purchase

of Plaintiff's Furniture (the "Brochure"), a complete, accurate, and authentic copy of which is

attached as Exhibit 2. This Lifetime Warranty states as follows:

Lifetime WarrantyKane's Furniture is guaranteed to last a lifetime. Our buyers select the finestquality furniture and ensure that it is built to pass our high quality testing. We'reso confident our furniture will last, we back it with our lifetime warranty atno additional cost. When you purchase from Kane's, you know you're buyingthe best in home furnishings.

Brochure at p. 1 (emphasis supplied). The Brochure further provided as follows regardingleather furniture:

LeatherEach piece of quality leather furniture is made up of many hides, each of whichhas individual characteristics such as lines, stripes, wrinkles, scars or shadingwhich add to the beauty of this nature product.• Leather Protection: Conditions and protects your investment against crackingand discoloration.

Brochure at p. 2 (emphasis supplied).

3

16. The Sales Order provides a disclaimer regarding the "Lifetime Warranty"

described in the Brochure:

Lifetime Warranty Disclaimer: Kane's warranties apply to new Kane's furniture(excluding bedding) and apply only to You. Subject to all the terms containedherein, Kane's will repair a defect in the particular piece of furniture coveredby this warranty. In the event of a defect covered by the terms of this warranty,You should contact the location where the subject piece of furniture waspurchased and give written notification of the defect. In the event that a disputearises regarding this warranty, the terms and provisions of section 14 of the SalesAgreement shall apply. If a covered defect is discovered during the first tenyears that You own the furniture and Kane's is unable to repair the covereddefect, You shall be entitled to an in-store credit, in the amount of theoriginal purchase price of the defective furniture to be used towards newmerchandise.

Sales Order at ¶ 4 (emphasis supplied).

17. Neither the Brochure nor the Sales Order makes any reference to bonded leather.

18. After the purchase of Plaintiffl s Furniture, its Bonded Leather surfaces began to

peel, flake, and otherwise deteriorate in breach of Defendant's express warranty stating that

Plaintiff's Furniture was prepared to prevent against cracking and discoloration. Moreover, this

peeling, flaking, and deterioration constitute a "covered defect" for which Defendant provided an

express warranty pursuant to the Sales Order and the Brochure. See Exh. 1 and Exh. 2.

19. Defendant has sold thousands of pieces of Southern Motion Bonded Leather

Furniture under the same terms provided in the Sales Order and the Brochure and which it

marketed and represented to the public as "leather furniture" that is subject to the same peeling,

flaking, and other deterioration.

20. Plaintiff provided Defendant with notice of the defects with Plaintiff's Furniture.

Consistent with the terms of the express warranty, Plaintiff contacted the Store's manager about

the defects in Plaintiff's Furniture. After repeated efforts to repair Plaintiff's Furniture were

4

unsuccessful, consistent with the terms of the express warranty, Plaintiff sent a demand to

Defendant's corporate office requesting that Defendant honor its express warranty. Defendant

disregarded Plaintiff's demand and did not repair the defect in Plaintiff's Furniture or offer

Plaintiff an in-store credit in the amount of the original purchase price of Plaintiff s Furniture to

be used to purchase new merchandise.

21. As of the date of this complaint, Defendant has refused to comply with its express

warranty.

22. As a result of (a) the peeling, flaking, and other deterioration of Plaintiff's

Furniture and other items of Southern Motion Bonded Leather Furniture sold by Defendant, (b)

Defendant's sale of Plaintiff's Furniture and other items of Southern Motion Bonded Leather

Furniture based on its deceptive and unfair trade practice of selling such items as "leather

furniture," and (c) Defendant's failure to comply with the terms of its express warranty,

Plaintiffls Furniture and other items of Southern Motion Bonded Leather Furniture have no

value.

23. All conditions precedent to the maintenance of this action have either occurred,

including the alternative dispute resolutions provisions provided in the Sales Order as alleged

above, have been performed, or have been waived.

24. Plaintiff has been required to retain the law firms of Clark &Martino, P.A., Bajo

Cuva Cohen Turkel, P.A., and Ricardo A. Roig, P.L. to prosecute this action and is obligated to

pay the firms' fees and costs for their services.

CLASS REPRESENTATION ALLEGATIONS

25. Plaintiff, individually and on behalf of all those similarly situated, makes the

following class representation allegations.

5

26. The proposed Class is defined as follows:

All persons who purchased furniture from Defendant manufactured by SouthernMotion, Inc. and made of Bonded Leather within five (5) years of the filing of thisaction.

27. While the exact number of Class members is unknown to Plaintiff at this time, there

are thousands Florida citizens who have purchased defective Southern Motion Bonded Leather

Furniture from Defendant. The identities of the members of the Class are within knowledge of and

can be ascertained from the records of Defendant.

28. The Class is so numerous that joinder of all of their members is impractical.

29. Plaintiffs claims are typical of the claims of the members of the Class because

Plaintiff, like the Class members, purchased the same defective furniture from Defendant, which

Defendant marketed and represented to the public as "leather furniture." Plaintiff and the members

of the Class were also exposed to Defendant's deceptive and unfair trade practices and its failures to

honor the terms of its express and implied warranties. Similarly, Plaintiff, like all members of the

Class, was damaged by the conduct of Defendant and has no interests antagonistic to those of the

members of the Class.

30. This action poses numerous questions of law and fact that are common to Plaintiff

and the members of the Class, and those common questions predominate over any questions

affecting only individual members of the Class.

31. Plaintiff is committed to the vigorous prosecution of this action and has retained

competent counsel experienced in handling class actions involving, among other things, consumer

rights and deceptive, unfair, and unconscionable trade practices. As a result, Plaintiff is an adequate

representative of the Class and will fairly and adequately protect the interests of the Class.

32. Plaintiff brings this class action under Rule 1.220(b)(2) of the Florida Rules of Civil

Procedure because Defendant has acted or refused to act on grounds generally applicable to all the

members of the Class, thereby making final injunctive relief or declaratory relief concerning the

Class as a whole appropriate.

33. Plaintiff also brings this class action under Rule 1.220(b)(3) of the Florida Rules of

Civil Procedure because a class action is superior to other available methods for the fair and

efficient adjudication of this controversy. Because the amounts of the claims of each individual

member of the Class are small relative to the cost and scope of this litigation, and due to the

financial resources of Defendant, none of the members of the Class could afford to seek legal

redress individually for the misconduct alleged in this case. Absent a class action, that misconduct

would go unremedied. Further, individual litigation would significantly increase the delay and cost

to all parties and would burden the judicial system. There will be no manageability problems with

prosecuting this case as a class action.

COUNTIVIOLATION OF THE DECEPTIVE

AND UNFAIR TRADE PRACTICES ACT —DAMAGES

34. Plaintiff, individually and on behalf of all those similarly situated, re-alleges

Paragraphs 1 through 33, above.

35. This is a cause of action by Plaintiff, individually and on behalf of the Class,

pursuant to Rule 1.220(b)(3) of the Florida Rules of Civil Procedure, for damages under FDUTPA

against Defendant.

36. Under the Florida Deceptive and Unfair Trade Practices Act, unconscionable,

unfair, and deceptive acts or practices in the conduct of trade or commerce are unlawful. §

501.204(1), Fla. Stat. In addition, the violation of any "law, statute, rule, regulation, or ordinance

7

which proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or

practices" constitutes a per se violation of FDUTPA. § 501.203(3)(c), Fla. Stat.

37. In any action by a party that has suffered a loss as a result of a violation of

FDUTPA, such person may bring an action to recover his or her actual damages. § 501.211(2), Fla.

Stat.

38. Section 672.313 of the Florida Statutes provides that a product sold pursuant to an

express warranty must conform to its express terms.

39. Section 672.314 of the Florida Statutes provides that when any product is sold by

a merchant who deals with products of that kind, there is an implied warranty that the product is

"merchantable," i.e., is of fair average quality and is fit for its ordinary purposes.

40. Defendant sold Plaintiff's Furniture and the Southern Motion Bonded Leather

Furniture to Plaintiff and the members of the Class and thereby placed them in the stream of

commerce. Defendant marketed and represented to the public and Plaintiffthat Plaintiff's Furniture

and the Southern Motion Bonded Leather as "leather furniture," even though it knew that they were

made from bonded leather, which is not leather, but is a synthetic, man-made, processed, leather-

like substance that contains only small amounts of leather.

41. By marketing and representing to Plaintiff and the members of the Class that

Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture as "leather furniture,"

which representations were made to Plaintiff and the members of the Class, all of whom are

consumers, in the conduct of commerce or trade, is unfair and deceptive because it is reasonably

likely to mislead consumers to their detriment, offends established public policy, and is immoral,

unethical, oppressive, unscrupulous, and substantially injurious to consumers.

8

42. Plaintiffs Furniture and the Southern Motion Bonded Leather Furniture are

defective, not of fair average quality, and not fit for their ordinary purposes, they do not comply

with the implied warranty of merchantability. Defendant's sale of Plaintiff's Furniture and the

Southern Motion Bonded Leather Furniture in violation of the implied warranty of merchantability

is unfair and deceptive because it is reasonably likely to mislead consumers to their detriment,

offends established public policy, and is immoral, unethical, oppressive, unscrupulous, and

substantially injurious to consumers.

43. Defendant failed to honor the terms of its express warranty by failing to repair

Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture after it became aware

that of defects or offer in-store credits for the full purchase price. Consequently, Defendant's

express warranty, which was made to Plaintiff and the members of the Class, all of whom are




44. Further, Defendant's (a) failure to honor the terms of its express warranty by

failing to repair Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture after it

became aware that it was defective or offer an in-store credit for the full purchase price, (b) sale

of defective furniture items that are not merchantable, constitute per se violations of FDUTPA

because the referenced statutes that create the express and implied warranties proscribe unfair

methods of competition, or unfair, deceptive, or unconscionable acts or practices.

45. As a result of (a) the peeling, flaking, and other deterioration of Plaintiff's

Furniture and other items of Southern Motion Bonded Leather Furniture sold by Defendant, (b)

Defendant's sale of Plaintiffs Furniture and other items of Southern Motion Bonded Leather

~]

Furniture based on its representations that it was "leather furniture," and (c) Defendant's sale of

Plaintiff s Furniture and other items of Southern Motion Bonded Leather Furniture in violation

of the implied warranty of merchantability, (d) Defendant's failure to comply with the terms of

its express warranty, Plaintiff's Furniture and other items of Southern Motion Bonded Leather

Furniture have no value.

46. Plaintiff seeks damages, costs, and attorneys' fees pursuant to §§ 501.211(2) and

501.2105 of the Florida Statutes.

COUNT IIDECLARATORY RELIEF



48. This is an action for declaratory relief under Chapter 86 of the Florida Statutes

brought by Plaintiff and the Class against Defendant.

49. Defendant is required to honor the terms of its express warranty and repair

defective furniture or offer an in-store credit for the original purchase price.

50. Defendant, however, disagrees and has routinely failed to comply with its express

warranty.

51. Plaintiff is in doubt concerning his rights under the express warranty and attendant

Florida law, and a justiciable, bona fide, and present controversy exists between Plaintiff, the

members of the Class, and Defendant concerning the proper interpretation of Defendant's

express warranty and any implied warranties, and the parties' attendant rights and obligations

thereunder.

10

52. Plaintiff is entitled to have his uncertainty removed with respect to his rights,

powers, and privileges under the express warranty and any implied warranties and, more

specifically, a determination by this Court that Defendant's failure to replace Plaintiff's Furniture

or offer him in-store credit for the full purchase price violated the terms of any express or implied

warranty.

53. The parties have an actual, present, or adverse and antagonistic interest upon the

existence and effect of the express warranty, and upon whether Defendant property complied

with Florida law.

54. All interest parties and potential adverse interests are before this Court.

55. The relief sought by Plaintiff in this action is not merely to seek legal advice or to

obtain answers to questions propounded out of curiosity.

56. The rights, status, or other equitable or legal relations of the parties are affected by

the terms of Defendant's express warranty.

57. Therefore, under § 86.021 of the Florida Statutes, Plaintiff and the members of the

Class may obtain a declaration of rights, status, or other equitable or legal relations under

Defendant's express warranty.

COUNT IIIVIOLATION OF THE DECEPTIVE

AND UNFAIR TRADE PRACTICES ACT —INJUNCTIVE RELIEF




pursuant to Rule 1.220(b)(2) of the Florida Rules of Civil Procedure, for injunctive relief under

FDUTPA against Defendant.

11

60. Under the Florida Deceptive and Unfair Trade Practices Act, unconscionable,

unfair, and deceptive acts or practices in the conduct of trade or commerce are unlawful. §

501.204(1), Fla. Stat. In addition, the violation of any "law, statute, rule, regulation, or ordinance

which proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or

practices" constitutes a per se violation of FDUTPA. § 501.203(3)(c), Fla. Stat.

61. Anyone aggrieved by a violation of the Florida Deceptive and Unfair Trade

Practices Act may bring an action for injunctive relief. § 501.211(1), Fla. Stat.

62. Section 672.313 of the Florida Statutes provides that a product sold pursuant to an

express warranty must conform to its express terms.

63. Section 672.314 of the Florida Statutes provides that when any product is sold by

a merchant who deals with products of that kind, there is an implied warranty that the product is

"merchantable," i.e., is of fair average quality and is fit for its ordinary purposes.

64. Defendant sold Plaintiff's Furniture and the Southern Motion Bonded Leather

Furniture to Plaintiff and the members of the Class and thereby placed them in the stream of

commerce. Defendant marketed and represented to the public and Plaintiff that Plaintiff s Furniture

and the Southern Motion Bonded Leather as "leather furniture," even though it knew that they were

made from bonded leather, which is not leather, but is a synthetic, man-made, processed, leather-

like substance that contains only small amounts of leather.

65. By marketing and representing to Plaintiff and the members of the Class that

Plaintiffls Furniture and the Southern Motion Bonded Leather Furniture as "leather furniture,"

which representations were made to Plaintiff and the members of the Class, all of whom are


12



66. Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture are

defective, not of fair average quality, and not fit for their ordinary purposes, they do not comply

with the implied warranty of merchantability. Defendant's sale of Plaintiffl s Furniture and the

Southern Motion Bonded Leather Furniture in violation of the implied warranty of merchantability

is unfair and deceptive because it is reasonably likely to mislead consumers to their detriment,

offends established public policy, and is immoral, unethical, oppressive, unscrupulous, and

substantially injurious to consumers.

67. Defendant failed to honor the terms of its express warranty by failing to repair

Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture after it became aware of

defects or offer in-store credits for the full purchase price. Consequently, Defendant's express

warranty, which was made to Plaintiff and the members of the Class, all of whom are consumers,

in the conduct of commerce or trade, is unfair and deceptive because it is reasonably likely to

mislead consumers to their detriment, offends established public policy, and is immoral,


68. Further, Defendant's (a) failure to honor the terms of its express warranty by

failing to repair Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture after it

became aware that it was defective or offer an in-store credit for the full purchase price, (b) sale

of defective furniture items that are not merchantable, constitute per se violations of FDUTPA

because the referenced statutes that create the express and implied warranties proscribe unfair

methods of competition, or unfair, deceptive, or unconscionable acts or practices.

13

69. Plaintiff seeks an injunction to enjoin future violations of FDUTPA and attorneys'

fees pursuant to §§ 501.211(2) and 501.2105 of the Florida Statutes.

COUNT IVBREACH OF CONTRACT




pursuant to Rule 1.220(b)(3) of the Florida Rules of Civil Procedure, for breach of contract against

Defendant.

72. Pursuant to the Sales Order, Plaintiff and Defendant entered into a contract for the

purchase of Plaintiff's Furniture. The terms of the express warranty that applied to the contract

are contained in the Sales Order the Brochure.

73. The members of the Class entered into identical contracts involving identical

express warranties as in the Sales Order and the Brochure when they purchased the Southern

Motion Bonded Leather Furniture.

74. Defendant breached the terms of its contract with Plaintiff and the members of the

Class by marketing and representing to Plaintiff and the members of the Class that Plaintiff's

Furniture and the Southern Motion Bonded Leather Furniture as "leather furniture," all of which

was defective because the furniture began to peel, flake, and otherwise deteriorate.

75. Defendant breached the terms of its contracts with Plaintiff and the members of

the Class by failing to honor the terms of its express warranty when it failed to repair Plaintiffl s

Furniture and the Southern Motion Bonded Leather Furniture or offer Plaintiff or the members of

the Class in-store credits for the full purchase price for the purchase of replacement furniture.

14

76. By breaching its contracts with Plaintiff and the members of the Class and the

Subclass, Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture have no value,

thereby causing damages to Plaintiff and the members of the Class.

77. Plaintiff and the members of the Class are entitled to attorneys' fees under the

terms of the Sales Order and § 57.105(7) of the Florida Statutes.

COUNT VBREACH OF IMPLIED WARRANTY OF MERCHANTABILITY



79. This is a cause of action by Plaintiff, individually and on behalf of all those

similarly situated, pursuant to Rule 1.220(b)(3) of the Florida Rules of Civil Procedure, for breach

of the implied warranty of merchantability against Defendant.

80. A warranty that a product is merchantable is implied in a contract for its sale if the

seller is a merchant with respect to goods of that kind. A product is merchantable if it is of fair

average quality or is fit for the ordinary purposes for which it is used.

81. Defendant is a merchant with respect to the sale of furniture items such as Plaintiff's

Furniture and the Southern Motion Bonded Leather Furniture.

82. Defendant sold Plaintiffs Furniture and the Southern Motion Bonded Leather

Furniture to Plaintiff and the members of the Class, respectively. Consequently, Plaintiff and the

members of the Class were foreseeable users of Plaintiffs Furniture and the Southern Motion

Bonded Leather Furniture.

83. Because Plaintiffls Furniture and the Southern Motion Bonded Leather Furniture

peeled, flaked, and otherwise deteriorated within a short time of its purchase, it is defective and not

15

merchantable because, among other things, it is not of fair average quality, is not fit for its ordinary

purpose for which it is used (i.e., living room fizrriiture), and is not suitable for sale to Florida

CK~3ibY1_fi~I"~il~.~

84. Because of the peeling, flaking, and deterioration of Plaintiff's Furniture and the

Southern Motion Bonded Leather Furniture and Defendant's subsequent failure to replace it or offer

Plaintiff or the members of the Class in-store credits for the original purchase price, Plaintiff's

Furniture and the Southern Motion Bonded Leather Furniture have no value. Therefore,

Defendant's conduct has caused Plaintiff and the members of the Class to incur damages.

COUNT VIUNJUST ENRICHMENT




pursuant to Rule 1.220(b)(3) of the Florida Rules of Civil Procedure, for unjust enrichment against

Defendant.

87. By purchasing Plaintiffls Furniture and the Southern Motion Bonded Leather

Furniture items from Defendant, which marketed and represented to Plaintiff and the members of

the Class that Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture as "leather

furniture" and which later peeled, flaked, and otherwise deteriorated, Plaintiff and the members of

the proposed Class have conferred a significant benefit on Defendant, which Defendant requested

from Plaintiff and the members of the Class.

88. Further, when, upon notice, Defendant failed to comply with the terms of its express

warranty by failing to repair the Plaintiffl s Furniture or the Southern Motion Bonded Leather

16

Furniture or offer an in-store credit for the original purchase price, Plaintiff and the members of the

proposed Class have conferred a significant benefit on Defendant, which Defendant requested from

Plaintiff and the members of the Class.

89. Defendant has knowledge of the benefits that Plaintiff and the members of the

proposed Class have conferred on it in the form of payments for Plaintiffl s Furniture and the

Southern Motion Bonded Leather Furniture, and have accepted the benefits of those payments.

90. Under these circumstances, i.e., (a) Plaintiff and the members of the proposed Class

purchasing Plaintiff's Furniture and the Southern Motion Bonded Leather Furniture from

Defendant, which was marketed and represented to Plaintiff and the members of the Class as

"leather furniture" and which later peeled, flaked, and otherwise deteriorated, (b) Defendant's

breach of its express and implied warranties, it would be inequitable for Defendant to enjoy the

benefits of the amounts that Plaintiff and the members of the Class paid to them.

91. As a direct and proximate result of Defendant's conduct, Plaintiff and the members

of the proposed Class have suffered and will continue to suffer damages, including those described

above.

92. Therefore, Defendant should be required to reimburse to Plaintiff and the members

of the proposed Class any amounts they received from the sale of Plaintiff's Furniture and the

Southern Motion Bonded Leather Furniture.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff, individually and on behalf of all those similarly situated,

requests the following relief:

a. under Count I, a judgment against Defendant for damages, costs, and attorneys' fees

pursuant to § § 501.211(2) and/or 501.2105 of the Florida Statutes;

17

b. under Count II, a judgment against Defendant for damages, costs, and attorneys'

fees to the extent permitted by law;

c. under Count III, a judgment against Defendant for injunctive relief, costs, and

attorneys' fees pursuant to § § 501.211(2) and/or 501.2105 of the Florida Statutes;

d. under Count IV, a judgment against Defendant for damages, costs, and attorneys'

fees under the Sales Contract pursuant to § 57.105(7) of the Florida Statutes;

e. under Count V, a judgment against Defendant for damages, attorneys' fees to the

extent permitted by law, and costs;

f. under Count VI, a judgment against Defendant for damages, attorneys' fees to the

extent permitted by law, and costs;

g. an Order that this action may be maintained as a class action under Rule 1.220(b)(2)

and/or (b)(3) of the Florida Rules of Civil Procedure, appointing Plaintiff and the undersigned

attorneys to represent the Class, and requiring reasonable and adequate notice to be given to

prospective members of the Class following certification; and

h. any additional relief necessary to protect the rights and interests of Plaintiff and the

Class.

DEMAND FOR JURY TRIAL

Plaintiff, individually and on behalf of the Class, demands a trial by jury.

[Attorney's signature appears on the following page.]

18

CERTIFICATE OF SERVICE

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

electronically filed with the Clerk and electronically served using the Florida Courts E-Filing

Portal, upon: Leonard S. Englander, Esq, (email: len land e al.com; [email protected]),,mob

Englander Fischer, 721 First Ave. N., St. Petersburg, o this~day of November 2015.

J. Daniel Clark " 1~~T 0106471Matthew A. Crist FB~~35539CLARK & MARTINO, P.A.3407 W. Kennedy BoulevardTampa, FL 33609(813)879-0700(813) 879-5498 (Facsimile)Primary email: dclark(c~clarkmartino.comPrimary email: [email protected] email: rsmith(c~clarkmartino.com

V. Stephen Cohen FBN 948756BAJO CUVA COHEN & TURKEL, P.A.100 N. Tampa Street, Suite 1900Tampa, FL 33602Telephone: (813) 443-2199Facsimile: (813) 443-2193Primary email: [email protected] email: [email protected]

Ricardo A. Roig FBN 639RICARDO A. ROIG, P.L.2803 Safe Harbor Dr.Tampa, FL 33618(813)964-7530(813) 441-6889 (Facsimile)Primary email: [email protected]

Attorneys for Plaintiff

19

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HOMO 838-28P 807-15 S~,NTA FE

STONE (STETS~JN} PWR CNSL L!S 79°

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$89:99

$1,099.99

~~btota( 5'1.~3J9.9f3

delivery $9y,98Sale; Tax $lA~_p(3

Total 52;239 y7

G6positG8N $239.99

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PLEASE REAQ ~lNF3 SIGN MR*SAGER ARPR~7VAL B~ian4e Due $f3.00C HAVE READ ANq AGREE T4 THE TERMS G1P TH1S SALES finance Co: C,E MCSt~IEY Ru#fi: Q2D842CONTpACT RS LISTED ABOVE AtiD ON THE REVERSE

See Diselc~sure Statement Fot L7etailsSlD6. KgNE'S FUR(+NTURE IS Ni7T itE$PONSIBLE F4RCOL(>fi fAST1hiG QR WEARING flUA61TY OF FABRtCS, IF :Financed Amt: $1,999.98THIS IS A SPECIAL ORDER; SEETHE REVERSE SIDE OFT#tE Fin. aroma. Code: 213SALES ORpER FOR SPECIFICTERMS AND CONQf170N5.

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}iF,l'=klfZ~rK 6z. 'I. is.'"r-~fl-1i hitlF_i.:ti;. Ll ~l~}, I:i Fli: il~k'i)f 6(;YEtL. ti{.I.I,EI; 9f3:11..L '~Ol ~~:Ll 11SLE 10121~9~j9pEC 1.1L, t`.I Itr1_~; I, =.LC=:'a,f ~i t'. ..1i 17. U•,~l \G!.~t! :. f, ~<ll.. ~. '1 n1'.l"~i LAPRk.~ (., .l l?lz'L 1P1)~V~HR S~TF ~3F IIiI \Il~R. H1~~DI~7..

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y. `', :A'>~~[ .1" (?[ ~~'_~=,l.t". ~1`, ti ~t:.1"°.1 ;itili_li L D ~.AL~Gi 7Ci pll~RtL' ~'~D1~1. ['~~.'Cit~.<, 1"~ ~ 1R .'liKiP ".l? i[','.Lrl [`~t:',

~~~~ 13i tìL c„_,-[ ~~i[c ~, t~~t cr_~ i ~.~ ~~o_u~ . I a~ :i~,: _~ in rho: cr[1.:cE1on ~aP~au ndc'rtcdi~~;;~ d~:c° an.3 ar~_i,: • h a~~~~~~;'~~~. 1ou <<,_ ..: ~:c, ~,n i ._ , :~ai,l~ a;tomc~. -l~zi~i~~ ~E'-~ 1~ z ~_r, ~,=p~'11:3zit prt~ce~ ' , ,~<;) ;u7~ a-.curt costs, ,ill inci~I~tctln~;ss st, colltict~~hc:rLi~n,J: z~ s1i.11 be;n i~ rr..t ;t, 1~ _r ~ ~t i;;t,~ ., (,; .~'- e l',~

1',~. t ~ ,~r~,i ~ l ~~ . 1~~.. in<«~ rc,cc~. v a t~~tal r~fiiu[i~f anu muni~,~ farfiizui~hn- ~~. nnly ifynu cancel tn~ sale skithtn '4 1,. r P";. c~~:,;~_ '~ ~°.~n cirir~,:~~ua E,u,J ~,:, «,. 1 ill crxiit y~o~ar char ~~ acs w~_~n[. t#Il oth,~r rcfu~fds wril.l b~ made bs cl~ecs`c and n:ailt-~ from the C,nrp~T,.:c 11 ad~~a.,-ttr~_ 1' r,; ~ilu~.<< n

❑iin~ _r-.r_ ,* !') L~n'~~m; d.tys farr~i~u,~i },roc 7~~y. (~rCie~s e~tnvo~ b:- cancct[ed ;ter moruhaneii~e: h.~rs bet~t~ dcliw~a~r~~ uZc,~~t1 ~ ~ndit,cn Ir ~ ~~e d~~ nat ~arc~}t},~ ,~~'c ~-itnir 'r~ l~~~i~ c n"punkit:s~. only `?(S ~ o1'~lic ptirchp.~c~Pricc kill be rciii~idcd,

r.;. ~i,~ ., ~.r va~r ~, ta~rc;,at.~ F~~^ i v ~tiwr + s ~. :..~ ~- ~ ..J _~'a~..~ z 2: ~.,~t~ iiF2 y~'Rv1e~t-. <<1 I ~,'.S-iS~ "~ - ~ t ,_, .,:,~ ~ ~.F ~.q i ~ ., ,,_~ ~ Z' :'~, l ~~ ~ ;-i`-~ ~~;~.....C~. F ?~SISaT HE P1~Iti1.I: CF- ~~"' ', . tiT ~i ~~I 1 Cry..'. 0,;.~ n:~.; .. ~ ..`.,I;.. ~ ~i ,1.>[t L` L1 ~ .. ~ ; l 0.'~. ~ t ; ,.. ,...

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~ ? ~ ~ `.uu arc ne~tlaume at tiie Qrigiiaal tim4 c~1`dcli~:ery, trc rcdc;ivcry 7s su~i~cetto c, r,~fl~li~ czy chir~c.

T ~. 1+~ ~Ycrtt~i~.~uxrc k7t,u crti„~r~~zcav~.. RE:~~~~:~z~~;n ~ir;acii ~~uts~ i~ st s.~rr. i tri 2li° o er-s-r~c~.rr~ crt~+zzcr~, .~r~r~n nr c~ri~.axc:€~~5.

7 =~-• AE aui~ tints air t~7e p~arohese~ pric~l~, u~ ~natham~tticaI estrn5 i'tr pp~rtpi hn~T 5`;'~ur purc~asc pace may be cnrre~Yed_

~ ~. I~,~~r~'~'ariExn.xT'i+~; i~ s~~~. ~,: x~;~«t.~ i n~; ritocr ~ By purchasing furrtihiri ~tiit7~ Iti~~i~ ~'ou a_ree to cnlplo~r t1,~ fol;oc irta i~~~diod t~f rc~ol~~ing any3i ;~..lt~ r .~;-'ii ar swa zrom t;r relates to our sale ~ ;~grccmcnt ~vitl~.~'ttu. 1. Mots ~~ ill first attcntri to resul : ~ .ulv ~isput~ wits the m ln~.,~r v` t}a~ ~hc~t r ~c~in «ii ~r~...~. u~z rr,_sd~ ye~urptirelt~~. It t!i~s does not r~stut in a n.c~ltitaon, then Z. You ~~~all wlztc io ~~ur C`~~z~ai~h, Dispuie Rc:;o~utior. man ~r at -i)u ~~~" :~~.r~.c I~'~ortl~.~Pi,~ ~~,as ['ar<. Plc~rit~a, ~37~1..3riv: CDR l~]anager. If this person is unatr'-e to resr~lvc ~,ar di,pute ~l~itJiu~ (3(11 dii}s afar }ou fir:~t s~~an withltim or har, tticn:~ ~ ,u ,~iaY Acct to ~~. rice h:ni orh~rw~iYlt a tivr!tten dernariit f"c~rfne~latic!n. 'rl~is nptici: ~~vill be sen_ to Dane, 570E 7pa, .~cenu~ ~r~rtk, Pinellas Par4c Florida.

i. ,a rr~ t:x : uii~ e Q13ices. ~rlediati~~n ,,<ill b~ ~~~n~'~ucte.d ctuou~l~ t}~i; C'iti~cn Di,~~u~~ Scttlemei~t Protein ~u~~l a~~y apFii~a6l~: ~ra~ isi;7n~ ~t the I~l~ri~aR~ l~:> of C ~ v 1 Frog cuur~. ilia Yfed tttic~n r~il1 ta1.e piaec; in the County cohere ~ ou pt~rchascd your ti~rn~tur. 'The oast of l414di~~ir_ i~, i~ an , will t~~: ;h red ecl~i;ill;~bti K~ane's ~ru~9 Yin.

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Filing # 33956334 E-Filed 11/02/2015 03:34:48 PM€¦ · leather. Compared to real leather furniture, bonded leather furniture is of significantly lower quality, lacks durability,