IN THE CIRCUIT COURT FOR
IN THE CIRCUIT COURT FOR
MIAMI-DADE COUNTY, FLORIDA
MC2MM Model Miami, LLC,
f/k/a Karin Models USA, LW
and
MC2 Model Management, LLC,
f/k/a Karin Models of America, LLC,
VS. Plaintiffs,
Defendant.
I GENERAL JURISDICTION DIVISION
CASE NO.:
COMPLAINT
COME NOW the Plaintiffs, by and through the undersigned counsel, and hereby sue
Defendant I.~~ seeking damages and equitable relief (including the
imposition of a constructive trust upon real property in Miami-Dade County, Florida) for
embezzlement, conversion and fraud, and state as follows:
1. This is an action for damages and equitable relief for torts committed by Defendant
in Miami-Dade County, Florida and in other jurisdictions, with an amount in controversy
exceeding $15,000, and is properly within the jurisdiction of this Court.
2. Defendant is residents of Miami-Dade County, and is over the age of eighteen (18)
years and are otherwise suijuris.
GENERAL ALLEGATIONS
3. Plaintiffs are fashion model agencies established under Florida laws and doing
business in Florida, New York as well as other states and regions.
4. At all times relevant hereto, Defendant
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EFTA00725355
5. Prior to=,
6.
7.
S.
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EFTA00725356
I
COUNT 1 - FRAUD
10. Plaintiffs reallege the contents of paragraphs 1 through 9 above as if set forth
herein.
11
Efl 14. There is no adequate remedy wholly at law to remedy the situation, as Defendant
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EFTA00725357
has
WHEREFORE, Plaintiff prays that this Court enter judgment in favor of Plaintiffs
for amounts to be proven at trial or other hearing, and to impose a constructive trust upon
the described real property of Defendant and to award to
Plaintiff attorney's fees and court costs, and any other relief the Court deems just.
COUNT II - CONVERSION
15. Plaintiffs reallege the contents of paragraphs 1 through 9 above as if set forth
herein.
16. At all times material hereto, Plaintiffs were the rightful owners of certain funds that
were the business assets of Plaintiff-companies.
17.
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EFTA00725358
WHEREFORE, Plaintiff prays that this Court enter judgment in favor of Plaintiffs
for amounts to be proven at trial or other hearing, and to impose a constructive trust upon
the described real property of Defendant and to award to
Plaintiff attorney's fees and court costs, and any other relief the Court deems just.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues so triable.
Filed by:
Jonathan N. David, Esq.
Attorney for Plaintiff
Ph:
Fax:
Fla. Bar No. 906816
A constructive trust can be impressed on property where the
property was financed with money directly traceable to embezzled
funds and where there was no consideration for the receipt of
those funds. See In Re Mart, 106 B.R.309 (Bkrtcy.S.D.Fla.
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EFTA00725359
1989) .
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📷 Images in this document (6 detected)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image shows a document with text that is partially obscured by a black rectangle, indicating that certain information is redacted or withheld. The visible text includes a heading that reads "WHEREAS," followed by a paragraph that seems to be discussing legal matters, possibly related to a court case or a legal agreement. The document is titled "JUDGMENT" and includes a signature at the bottom,
[Image 2] The image shows a document that appears to be a court order or a legal document. It contains text and a signature at the bottom. The document is titled "IN THE CIRCUIT COURT OF THE STATE OF FLORIDA" and includes sections such as "Case No." and "Defendant." There are paragraphs with numbered points, which seem to outline the details of the case, including the plaintiff's allegations and the defenda
[Image 3] The image appears to be a document scan, specifically a page of text that seems to be a legal or official document. The text is partially obscured by black rectangles, likely indicating redactions or confidential information. The visible text includes phrases such as "WHEREFORE," "WHEREAS," "WHEREUPON," and "WHEREAS." There are also references to "Plaintiff," "Defendant," "Plaintiff's Complaint,"
[Image 4] The image shows a document with text that has been redacted, leaving blank spaces where the original content should be. The document appears to be a page from a legal or official document, as indicated by the header "COURT OF COMMON PLEAS" and the numbered paragraphs. The visible text includes the title "PLEADINGS" and the number "10," suggesting this is the tenth paragraph in the document. The te
[Image 5] The image shows a document with text that has been redacted, leaving blank spaces where the original content should be. The document appears to be a letter or a report, as indicated by the numbered paragraphs and the formal layout. The visible text includes the title "REPORT" and the number "1" in a bold font, suggesting that this is the first page of a series. The redacted text includes phrases s
[Image 6] The image appears to be a photograph of a document with text. The document is a letter, as indicated by the salutation "Dear" at the beginning. The visible text includes the sender's name, the recipient's name, and a date. The document is addressed to a person named "John," and the date mentioned is "January 15, 2015." The text is in English, and the document is printed on standard letterhead pape