RATO’S RESEARCH – To Which It Stands: ” War at Lot 210″

DOCUMENT: THE ENTIRE COW CUT INTO ONE PIECE OF CENTER CUT STEAK

The Plaintiff in the following case does not have a telephone or computor for the upcoming hearing sccheduled for October 7, 2026. What Motion can he file for a delay in the hearing o connect to Case Files and Public Records of Pinellas County Curt >>> CLICK HERE Date Time Hearing Judicial Officer Location 10/07/2026 9:30 AM SMALL CLAIMS PRE-TRIAL SMALL CLAIMS JUDGE, SOUTH ZOOM COURTROOM JULY – DEC WEDNESDAY Events 15 Results Date Event Comments eCertify Docket# Doc Pages 09/30/2026 Party: PACIFICA SEMINOLE MHP, TO QUASH SERVICE OF PROCESS 15 4 09/30/2026 Party: GAINES, SARAN 14 3 09/30/2026 Party: GAINES, SARAN ; PACIFICA SEMINOLE MHP,; GAINES, SARAN ; PACIFICA SEMINOLE MHP, AND DESIGNATION OF E-MAIL ADDRESS 13 2 09/21/2026 ATTACHED FIRE BOMBS AND SHOT GUNS ARTICLE 12 7 09/21/2026 WITH ATTACHMENT 11 2 09/21/2026 Party: WINANS, CHRISTOPHER FOR LEAVE TO AMEND COMPLAINT AND TO TRANSFER TO COUNTY CIVIL DIVISION 10 5 09/21/2026 Party: WINANS, CHRISTOPHER FOR LEAVE TO CREATE A REGISTRY OF COURT WITH ATTACHED PROPOSED ORDER UNSIGNED 9 2 09/15/2026 PROOF OF ACCEPTANCE FOR SARAN 8 1 09/15/2026 BANNER PAGE 7 1 09/15/2026 Party: PACIFCA SEMINOLE MHP, EMAILED AND MAILED TO PLAINTIFF FOR SERVICE 6 7 09/15/2026 Party: GAINES, SARAN VIA CERT MAIL 5 6 09/15/2026 EMAILED AND MAILED 4 2 09/14/2026 3 26 09/14/2026 Party: WINANS, CHRISTOPHER 2 1 09/14/2026 1 1 Other Documents 0 Results (click to view) Document Title: Date: Oct 04, 2026 By: Rato de Advogado Document: THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 The War At Lot #210 – ‘To Which It Stands Intro Presentation: Presentation: PACIFICA SEMINOLE MHP DEFENDANT 1775 HANNCOCK STREET SUITE 200 RA LOU BLOOMBERG FINANCIAL LP SAN DIEGO CA 92110 PATRICK M BOYLAN PATRICK M BOYLAN ATLAS LAW PLLC 1313 N HOWARD AVE TAMPA, FL 33607 813-241-8269 SARAN GAINES DEFENDANT 5015 SEMINOLE BLVD ST. PETERSBURG FL 33708 PATRICK M BOYLAN PATRICK M BOYLAN ATLAS LAW PLLC 1313 N HOWARD AVE TAMPA, FL 33607 813-241-8269 Case Type: SMALL CLAIMS 3 $501 – $2,500 Date Filed: 09/14/2026 Status: OPEN Court: South Judicial Officer: SOUTH SMALL CLAIMS JUDGE UCN: 522026SC011919XXSCSC CHRISTOPHER WINANS PLAINTIFF 5015 SEMINOLE BLVD CHRISTOPHER WINANS 09/14/2026 Transaction Assessment 195.00 09/14/2026 Transaction Assessment 13.87 09/14/2026 Counter Payment | Receipt Number: CV-2026-11780 208.87 Balance Due: 0.00 Name Type Party Address Attorney Lead Attorney Address CHRISTOPHER WINANS PLAINTIFF 5015 SEMINOLE BLVD ST. PETERSBURG FL 33708 , SARAN GAINES DEFENDANT 5015 SEMINOLE BLVD ST. PETERSBURG FL 33708 PATRICK M BOYLAN PATRICK M BOYLAN ATLAS LAW PLLC 1313 N HOWARD AVE TAMPA, FL 33607 813-241-8269 PACIFICA SEMINOLE MHP DEFENDANT 1775 HANNCOCK STREET SUITE 200 RA LOU BLOOMBERG FINANCIAL LP SAN DIEGO CA 92110 PATRICK M BOYLAN PATRICK M BOYLAN ATLAS LAW PLLC 1313 N HOWARD AVE TAMPA, FL 33607 813-241-8269 Case Type: SMALL CLAIMS 3 $501 – $2,500 Date Filed: 09/14/2026 Status: OPEN Court: South Judicial Officer: SOUTH SMALL CLAIMS JUDGE UCN: 522026SC011919XXSCSC Case Type: SMALL CLAIMS 3 $501 – $2,500 Date Filed: 09/14/2026 Status: OPEN Court: South Judicial Officer: SOUTH SMALL CLAIMS JUDGE UCN: 522026SC011919XXSCSC CHRISTOPHER WINANS 09/14/2026 Transaction Assessment 195.00 09/14/2026 Transaction Assessment 13.87 09/14/2026 Counter Payment | Receipt Number: CV-2026-11780 208.87 Balance Due: 0.00 Case Type Case# Filed Style/Description Status Judicial Officer SMALL CLAIMS 3 $501 – $2,500 26-011919-SC 09/14/2026 CHRISTOPHER WINANS Vs. SARAN GAINES, PACIFICA SEMINOLE MHP, CORPORATE HEADQUARTERS OPEN SOUTH SMALL CLAIMS JUDGE Document Title: 1A / Date: Oct 04, 2026 / By: Rato de Advogado / Document: memo on Norm case 3-B LAW THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 A Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands memo on Norm case 3-B LAW MEMO: Date Oct, 2 2026 Written by Plaintiff Case: 26-011919-SC ————————– FACTS: DEFENDANT(S) IN THE CASE HIRED (1) – AN ATTORNEY> ( not sure of his hourly rate) … … . RE: Mr. Tampa Florida Attorney filed a motion to dismiss case 26-011919-SC : Defendant Gaines [ NO statement of CLAIM ] , Quash on Defendant: Pacifica. Seminole MHP { NO LEGAL SERVICE ] Note: Mr. attorney probably had one of his ‘many legal assistants write this Motion To Dismiss’, it most likely touched his desk only briefly, if at all before filing it … question Wednesday: Zoom / phone hearing set for AM… who’s on the phone? The Dismisal basic Fl Law / stated below … LAW RESEARCH (REQUIRED ON ATTORNEY: (BIG Bopper HOWARD Street Tampa Lawyer BOB OF TAMPA, FL) 1.(I) =========================================================================== MOTION TO DISMISS DEFENDANT (#1) S. Gaines statement of claim Rule 1. 140(b) (6) Fla.R.Civ.P / (II) Quash on Defendant (#2) PACIFICA Seminole MHP / NO LEGAL acceptable SERVICE on Pacific, THE TRUE NATURE OF CASE: 26-011919-SC Mr. , [ … … a graduate of Loyola University, CA, USA, (Head of a MULTI-NATIONAL Family owned and run – interwoven LLC throughout the United States, operating dozens , if not hundreds of 55+ communities, … many of these unknown formerly owned properties by Mr. _______ and his relatives and Family are now, high rise Luxury Condominium Building, with a beach view from the top 20 floors of the 50 floor unit building- the building now located where Seniors age 55+ lived only a short time ago] and rule: Rule 7.050 Fla.SmCl.R. =========== failure to state a cause of action upon which relief may be granted/ordered by a Court. Rule1.140 (b)(6),Fla. R. Civ. P ======== Florid small claims requires statement of claim to INFORM THE DEFENDANT of BOTH BASIS and amount of claim ++++++++++++++++ bait and switch allegation Norman v. Ashburn, Square Homeowners’ Ass, Inc, 393 So, 3d 1281, 1288 (Fla. 2d DCA 2024) the root Id at 1289 (quoting Des Rosher & Watkins Towing Co. Third Nat’l Bank, 106 Fla. 466, 143, So. 768, 770 (Fla. 1932) ——– Identify agreement reached**** breach find connection ——— Separate entity, distinct / Coporate Veil law Beltran v. P. Miraglia, M.D., P.A., 125 So. 3d 855, 858 (Fla. 4th DCA 2013) PLEAD SUFFUCUENT FACTS TO PIERCE THE CORPORATE VEIL See, 17315 Collins Ave., LLC v Fortunw Dev. Sales Corp, 34 So. 3d 166 168 (Fla 3d DCA 2010) Agent acting for a disclosed principal is not personally liable for the principals dets. See eg Pelican Auto, Inc v Rutigliano 729 So. 2d 488, 491 (Fla.2d DCA 1999 9citing Philip Schwartz, Inc v Gold Coast Graphics, Inc 623 So. 2d 819 (Fla. 4th DCA 1993 says based on a landlord tenant dispute between Plaintiff and his landlord, the owner of Seminole MHP personal contractual or LEGAL DUTY OWED TO PLAINTIFF , or any independent actionable conduct by Ms. Gaines ======================================================== ———————————— LAW OF SERVICE Under 48.062 1st on the LIMITED LIABILITY COMPANY’s REGISTERED AGENT if registered agent can’t be served, service may be achieved on a member MAY serve ON A MEMBER OF A MEMBER MANAGED LLC: (ii) on a manager of a manager – managed LLC, or (III) IN AN EMPLOYEE Designated by the manager or member in the Manager or member’s absence, See &48.062 Legal ENTITY – REGISTRED AGENT with an office in the State of Florida. PACIFICA Seminole MHPark LLC< HAS A REGISTERED AGENT located in the State of Florida, which registered agent maintains an office that is open for service Register Agent Address: [ a room, with 1 door, no windows, in Tallahassee Florida] ========================= Obligated to serve the office under Rule 1.070 FlaR.Civ.Pro,. Rule 7.070 Fla.SmCl.R and &&48.062 and &48.081 ======================================= Research NOTICE OF FILINGS LAW … E-file Law In The State of Florida / opposition to it / AN EMAIL? digital law work really suffices to fulfill Law in 2026 … how far we’ve progressed, or regressed what if a party to the case can not have access to an email … handicapped , lost access to mobile phone ,,, surely a case in FLORIDA somewhere … … ============== SITE PAPER & FIRE CITE CASE: John Mellencamp v. NYC Name Changing Name B. Boober Bigly LLC, ($) So. 2l 1443. 1444 &Ind.(Cir) st 1983) ======== ===================== Ok, can’t sue Mr. Owner in San Diego in case 26-011919-SC / but what legal action can be brought to him? ====================================================================================================== ZOOM CALLS: can’ they be eliminated? question: can we NOT legally … force all proceedings to be conducted by a human being, physically present … in front of a judge? ONE WITH A GAVEL! what LAW supports …. —————– Document Title: Norm case 3H SERVER in Leon cnty / DOCUMENT 1B / Date: Oct 04, 2026 / By: Rato de Advogado Document: Norm case 3H SERVER in Leon cnty THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1B Norm case 3H SERVER in Leon cnty Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Norm case 3H SERVER in Leon cnty as a single PDF ================== Because your case is filed in Pinellas County but the registered agent (Paracorp Incorporated) is physically located in Tallahassee (Leon County), you must use a server with jurisdiction in Leon County. You have two primary options: using the official local Sheriff’s office or hiring a private certified process server. [1] Option 1: Leon County Sheriff’s Office (Civil Process Unit) The most straightforward option is to use the local Sheriff’s office. They handle out-of-county legal hand-deliveries regularly. [1] Phone: (850) 606-3450 Office Address: Attn: Civil Division, 3333 W. Pensacola St., Suite 200, Tallahassee, FL 32304 Mailing Address: P.O. Box 727, Tallahassee, FL 32302 Email Contact: lcso_civil_warrants@leonFLSheriff.gov Requirements: You will typically mail them the original summons issued by the Pinellas clerk, a copy of the amended complaint, a copy for their records, and a service fee check (usually around $40.00, though you should call to verify exact out-of-county rates). [1, 2, 3] Option 2: Private Certified Process Servers (Tallahassee Local) If you prefer a private service for faster turnarounds or specialized communication, you can choose from the official Second Judicial Circuit Certified Process Server Directory or agencies certified by the Florida Association of Professional Process Servers (FAPPS): [1, 2] Accurate Serve of Tallahassee Phone: (850) 519-5494 Details: Run by Brennan Fogarty (a member of the Second Circuit Process Server Review Board), this agency specializes heavily in daily courier runs to registered agent offices throughout Tallahassee. [1, 2] KD Process (James Kady) Phone: (850) 545-3452 or (850) 727-4363 Address: 2957 Capital Park Drive, Suite 7, Tallahassee, FL 32399 [1, 2] Nolan Process Servers (Michael Nolan) Phone: (850) 901-0000 or (850) 562-6058 [1] Golden Process Service Phone: (888) 766-7497 Details: Offers specialized same-day delivery specifically targeted at corporate registered agents in Leon County. [1] Pro-Tip: Do not reach out to these servers until after the Pinellas County judge explicitly signs the order granting your Motion for Leave to Amend and the Pinellas Clerk processes your newly issued “Amended Summons.” Once you have that official summons paperwork in hand, you can send it to your chosen server above. AI responses may include mistakes. For legal advice, consult a professional. Learn more Leon County Clerk of Court County Civil & Small Claims call (850) 606-4110. For each defendant listed in the complaint/petition, the plaintiff must provide an original and two copies of… 2nd Judicial Circuit (.gov) Certified Civil Process Servers – 2nd Judicial Circuit Apr 1, 2026 — Certified Civil Process Servers – Second Judicial Circuit. (850) 508-5261 (W); (850) 491-9582 (C). 3/31/2027. Larson, Eric L. 063. Golden Process Service Serving Corporation Service Company (CSC) in Tallahassee Aug 7, 2026 — Its Florida registered office at 1201 Hays Street, Tallahassee, FL 32301 sits in Leon County, minutes. Fort Lauderdale, Miami, Orl… Show all ============= IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA PLAINTIFF NAME(S), Plaintiff, vs. PACIFICA SEMINOLE MHP LLC, Defendant. CASE NO.: 26-011919-SC DIVISION: Small Claims PLAINTIFF’S MOTION FOR LEAVE TO AMEND THE COMPLAINT AND MEMORANDUM IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS Plaintiff, [Your Name], respectfully moves this Court pursuant to Florida Rule of Civil Procedure 1.190(a) and Florida Small Claims Rules for an Order granting leave to amend the initial Statement of Claim. In support, Plaintiff states: Plaintiff filed the initial Statement of Claim in this action on [Date you filed]. Defendant filed a Motion to Dismiss alleging improper service of process, noting that service was delivered directly to the physical business location rather than to Defendant’s designated Florida Registered Agent. Plaintiff recognizes this technical defect and seeks to cure the service issue immediately. Justice requires that the case be decided on its merits rather than a technical service error. Leave to amend “shall be given freely when justice so requires” under Fla. R. Civ. P. 1.190(a). Granting this motion will not prejudice the Defendant, as the case is in its earliest stages, no trial date has been set, and the amendment serves only to properly identify and serve the correct Registered Agent entity. Attached hereto as Exhibit A is the proposed Amended Statement of Claim correctly identifying the Defendant and its Registered Agent for formal service of process. WHEREFORE, Plaintiff respectfully requests this Court enter an Order: Denying Defendant’s Motion to Dismiss; Granting Plaintiff leave to file the attached Amended Statement of Claim; and Allowing Plaintiff an additional 120 days to execute proper service of process upon the Defendant’s Registered Agent: Paracorp Incorporated, 155 Office Plaza Dr, 1st Floor, Tallahassee, FL 32301. Dated: October 1, 2026. Respectfully submitted, [Your Name] [Your Address] [Your Phone Number] [Your Email Address] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal or U.S. Mail to the Defendant or Defendant’s counsel [if they have an attorney] on this 1st day of October, 2026. [Your Signature] ======================================================== == must attach a complete copy of your proposed Amended Statement of Claim directly to the back of your motion === What is the Form to file: Motion for Leave to amend the Complaint in Case: 26-011919-SC, in Small Claims Division of the Pinellas County Court of the 6th Circuit Court, for Plaintiff’s response for motion to dismiss due to: improper serves directly to the corporation: Pacifica Seminole Mobile Home Park and not to the Florida registered agent: The Florida registered agent for Pacifica Seminole MHP LLC (the owner of Seminole Mobile Home Park at 5015 Seminole Blvd.) is Paracorp Incorporated Registered Office Address 155 Office Plaza, 1st Door, Tallahassee, FL 32301 === complaint ========== Motion for Leave to amend the Complaint ============= a Plaintiff’s Response to Defendant’s Motion to Dismiss or an Opposition to the Motion to Dismiss =========== property is owned by Pacifica Seminole MHP LLC (Document Number: L19000250486) =========== The community is an age-restricted (55+) manufactured home park operated by PacShore Communities. [1] Community Office Phone: (727) 242-1242 Alternative Listing / Sales Contact: (941) 345-5583 Official Property Management Portal: You can view availability and community standards on the PacShore Communities Seminole Portal. ================ The Florida registered agent for Pacifica Seminole MHP LLC (the owner of Seminole Mobile Home Park at 5015 Seminole Blvd.) is Paracorp Incorporated Registered Office Address 155 Office Plaza, 1st Door, Tallahassee, FL 32301 Principal Address Mailing Address 1775 Hancock St, step 200, San Diego, CA 92110 ======================================== ================ memo on Norm case 3-B LAW MEMO: Date Oct, 2 2026 Written by Plaintiff Case: 26-011919-SC ========================== Document Title: Ashok Israni Information / DOCUMENT 1C / Document # 1 C / Ashok Israni Information / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 C Ashok Israni Information Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Ashok Israni Chairman & Founding Principal, Pacifica Companies San Diego, CA 92110 Send a Message Phone (619) 296-9000 x104 Mobile (619) 507-0247 Bio As Chairman, Mr. Israni provides strategic leadership across all facets of the organization. Mr. Israni is particularly engaged in acquisitions and ground-up development. Mr. Israni’s background is in electrical engineering, and has a Master’s degree from Loyola Marymount University in Los Angeles, CA. After working in the computer industry for a few years Mr. Israni started a real estate company. The company has since grown to include hundreds of unique assets and operating businesses totaling billions. In addition to leading Pacifica Companies as Chairman, Mr. Israni is an active member of the community. Mr. Israni served on the Board of Directors at City National Corporation for eight years until the bank was acquired by RBC. Mr. Israni is pleased to serve as a member of the Real Estate Advisory Boards at the University of San Diego (USD) and University of California, San Diego (UCSD). Education Loyola University About Pacifica Companies Pacifica Companies is a privately held real estate developer, owner, investor, and investment manager founded in 1978 by Ash Israni. The firm operates as a vertically integrated platform with a diversified portfolio spanning multiple asset classes and geographies. The company pursues an opportunistic investment strategy across senior housing, hospitality, multifamily, retail, office, industrial, and master-planned communities throughout the United States, India, and Mexico. Since entering the Indian market in 2004, Pacifica has expanded its footprint to cities including Ahmedabad, Vadodara, Chennai, Hyderabad, and Bangalore. In the United States, the company maintains operations across multiple asset classes with geographic exposure concentrated in California, Florida, Arizona, Utah, and New York. Through its hotel division, Pacifica Host Hotels, the firm owns and operates over 30 properties under brands including Marriott, Hampton Inn, Doubletree, and Holiday Inn. The senior living division manages approximately 80 to 100 communities nationwide, operating independent living, assisted living, memory care, and skilled nursing facilities. The firm partners with pension funds, institutional banks, investors, and real estate funds for strategic investing ventures Document Title: DOCUMENT 1 D / memo on Norm case 3-B LAW / Document # 1 D / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands / Document # 1 D / Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands / memo on Norm case 3-B LAW / MEMO: /Date Oct, 2 2026 / Written by Plaintiff Case: 26-011919-SC ————————– FACTS: DEFENDANT(S) IN THE CASE HIRED (1) – AN ATTORNEY> ( not sure of his hourly rate) … … . RE: Mr. Tampa Florida Attorney filed a motion to dismiss case 26-011919-SC : Defendant Gaines [ NO statement of CLAIM ] , Quash on Defendant: Pacifica. Seminole MHP { NO LEGAL SERVICE ] Note: Mr. attorney probably had one of his ‘many legal assistants write this Motion To Dismiss’, it most likely touched his desk only briefly, if at all before filing it … question Wednesday: Zoom / phone hearing set for AM… who’s on the phone? The Dismisal basic Fl Law / stated below … LAW RESEARCH (REQUIRED ON ATTORNEY: (BIG Bopper HOWARD Street Tampa Lawyer BOB OF TAMPA, FL) 1.(I) =========================================================================== MOTION TO DISMISS DEFENDANT (#1) S. Gaines statement of claim Rule 1. 140(b) (6) Fla.R.Civ.P / (II) Quash on Defendant (#2) PACIFICA Seminole MHP / NO LEGAL acceptable SERVICE on Pacific, THE TRUE NATURE OF CASE: 26-011919-SC Mr. , [ … … a graduate of Loyola University, CA, USA, (Head of a MULTI-NATIONAL Family owned and run – interwoven LLC throughout the United States, operating dozens , if not hundreds of 55+ communities, … many of these unknown formerly owned properties by Mr. _______ and his relatives and Family are now, high rise Luxury Condominium Building, with a beach view from the top 20 floors of the 50 floor unit building- the building now located where Seniors age 55+ lived only a short time ago] and rule: Rule 7.050 Fla.SmCl.R. =========== failure to state a cause of action upon which relief may be granted/ordered by a Court. Rule1.140 (b)(6),Fla. R. Civ. P ======== Florid small claims requires statement of claim to INFORM THE DEFENDANT of BOTH BASIS and amount of claim ++++++++++++++++ bait and switch allegation Norman v. Ashburn, Square Homeowners’ Ass, Inc, 393 So, 3d 1281, 1288 (Fla. 2d DCA 2024) the root Id at 1289 (quoting Des Rosher & Watkins Towing Co. Third Nat’l Bank, 106 Fla. 466, 143, So. 768, 770 (Fla. 1932) ——– Identify agreement reached**** breach find connection ——— Separate entity, distinct / Coporate Veil law Beltran v. P. Miraglia, M.D., P.A., 125 So. 3d 855, 858 (Fla. 4th DCA 2013) PLEAD SUFFUCUENT FACTS TO PIERCE THE CORPORATE VEIL See, 17315 Collins Ave., LLC v Fortunw Dev. Sales Corp, 34 So. 3d 166 168 (Fla 3d DCA 2010) Agent acting for a disclosed principal is not personally liable for the principals dets. See eg Pelican Auto, Inc v Rutigliano 729 So. 2d 488, 491 (Fla.2d DCA 1999 9citing Philip Schwartz, Inc v Gold Coast Graphics, Inc 623 So. 2d 819 (Fla. 4th DCA 1993 says based on a landlord tenant dispute between Plaintiff and his landlord, the owner of Seminole MHP personal contractual or LEGAL DUTY OWED TO PLAINTIFF , or any independent actionable conduct by Ms. Gaines ======================================================== ———————————— LAW OF SERVICE Under 48.062 1st on the LIMITED LIABILITY COMPANY’s REGISTERED AGENT if registered agent can’t be served, service may be achieved on a member MAY serve ON A MEMBER OF A MEMBER MANAGED LLC: (ii) on a manager of a manager – managed LLC, or (III) IN AN EMPLOYEE Designated by the manager or member in the Manager or member’s absence, See &48.062 Legal ENTITY – REGISTRED AGENT with an office in the State of Florida. PACIFICA Seminole MHPark LLC< HAS A REGISTERED AGENT located in the State of Florida, which registered agent maintains an office that is open for service Register Agent Address: [ a room, with 1 door, no windows, in Tallahassee Florida] ========================= Obligated to serve the office under Rule 1.070 FlaR.Civ.Pro,. Rule 7.070 Fla.SmCl.R and &&48.062 and &48.081 ======================================= Research NOTICE OF FILINGS LAW … E-file Law In The State of Florida / opposition to it / AN EMAIL? digital law work really suffices to fulfill Law in 2026 … how far we’ve progressed, or regressed what if a party to the case can not have access to an email … handicapped , lost access to mobile phone ,,, surely a case in FLORIDA somewhere … … ============== SITE PAPER & FIRE CITE CASE: John Mellencamp v. NYC Name Changing Name B. Boober Bigly LLC, ($) So. 2l 1443. 1444 &Ind.(Cir) st 1983) ======== ===================== Ok, can’t sue Mr. Owner in San Diego in case 26-011919-SC / but what legal action can be brought to him? ====================================================================================================== ZOOM CALLS: can’ they be eliminated? question: can we NOT legally … force all proceedings to be conducted by a human being, physically present … in front of a judge? ONE WITH A GAVEL! what LAW supports …. —————– Document Title: OCT 3 , NEW statement of clam DOCUMENT 1 E / Document # 1 E / OCT 3 , NEW statement of clam / Date: Oct 04, 2026 / By: Rato de Advogado / Document: Court Filing / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 E Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands OCT 3 NEW statement of clam . IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CHRISTOPHER L. WINANS, Plaintiff, vs. SARAN GAINES, Individually, and PACIFICA SEMINOLE MHP LLC, Defendants. CASE NO.: 26-011919-SC DIVISION: County Civil Division (Transfer Pending) JUDGE: EDWIN JAGGER PLAINTIFF’S FIRST AMENDED STATEMENT OF CLAIM Plaintiff, Christopher L. Winans, sues Defendants, Saran Gaines, individually, and Pacifica Seminole MHP LLC (doing business as Seminole Mobile Home Park), and alleges: JURISDICTION AND VENUE This is an action for damages, statutory violations, and injunctive relief that exceeds the $8,000 jurisdictional limit of the Small Claims Division due to compounding, active structural and infrastructure damages. Pursuant to Florida Small Claims Rule 7.100(d), this action is subject to immediate transfer to the formal track of the County Court Civil Division. Plaintiff Christopher L. Winans is a resident of Pinellas County, Florida, and owns a mobile home located on Lot #210 within the Seminole Mobile Home Park at 5015 Seminole Blvd, Seminole, FL 33772. Defendant Pacifica Seminole MHP LLC is a Florida limited liability company doing business in Pinellas County, Florida, and is the owner of the park [L19000250486]. Defendant Saran Gaines is a resident of Pinellas County, Florida, and is the physical park manager. She is sued in her individual capacity. The corporate shield doctrine does not protect an individual manager in Florida from being sued for their own active, personal torts, harassment, or bad-faith actions (Vesta Construction and Design, LLC v. Lotspeich & Associates, Inc.). GENERAL ALLEGATIONS: INFRASTRUCTURE DEFECTS Plaintiff’s tenancy is governed by Chapter 723, Florida Statutes (The Florida Mobile Home Act). Under Florida law, the park owner has a non-delegable duty to maintain the park’s common areas and infrastructure in good, safe working order. The Defendant’s property suffers from systemic, severe infrastructure issues, including but not limited to, systemic electrical defects posing immediate hazards, plumbing failures, and structural damages directly impacting Lot #210. These active, compounding infrastructure damages place the true amount in controversy above $8,000, invoking the formal track of the Florida Rules of Civil Procedure pursuant to Florida Small Claims Rule 7.020(b). III. FACTUAL ALLEGATIONS: FABRICATED DELINQUENCY & HARASSMENT On September 23, 2026, Plaintiff filed a motion to securely hold disputed lot rental funds due to these unaddressed infrastructure defects. In retaliation, Defendant Saran Gaines fabricated a fraudulent one-month lot rent non-payment claim regarding Lot #210 for the month of March 2025—a period spanning 17 months prior. Defendant Gaines first informed the Plaintiff of this alleged missing March 2025 rent on July 28, 2026. Defendant Gaines has produced a photocopy of Plaintiff’s March 2025 payment (Check No. 2323), confirming receipt and physical possession of the asset, but claims she cannot produce the actual check in any form because it was “lost” by management. Subsequent to her July 28, 2026 demand, Defendant Gaines accepted Plaintiff’s August 1, 2026 lot rent payment in full. In September 2026, Defendant Gaines acted in overt bad faith by returning Plaintiff’s September 2026 rent check completely uncashed in a deliberate, artificial manipulation of the ledger designed to falsify a pathway for eviction. Since September 23, 2026, Defendant Gaines has engaged in an active campaign of intimidation, which includes sending harassing text messages, physically confronting the Plaintiff unannounced at his home while leveraging her authority as “the park manager,” leveling verbal eviction threats, and standing at the residence taking unauthorized photographs of the inside of the Plaintiff’s private mobile home. COUNT I: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS & INDIVIDUAL CIVIL TORT LIABILITY (Against Defendant Saran Gaines, Individually) Plaintiff re-alleges paragraphs 1 through 15. The corporate shield doctrine does not insulate Defendant Gaines. Her personal actions—fabricating a 17-month-old debt, admitting to losing a processed check (Check #2323), intentionally rejecting a lawful tender of current rent to fake an eviction track, and capturing unauthorized photos of the inside of Plaintiff’s private residence—constitute independent, intentional tortious acts of fraud and harassment. This conduct is extreme, outrageous, goes far beyond the bounds of lawful property management, and was executed with the intention to cause severe emotional distress and force the Plaintiff from his home. COUNT II: VIOLATION OF CHAPTER 723, FLA. STAT. (STATUTORY RETALIATION & BREACH OF GOOD FAITH) (Against Defendant Pacifica Seminole MHP LLC) Plaintiff re-alleges paragraphs 1 through 15. Waiver: Under Florida law, Defendant’s acceptance of subsequent August 2026 rent after gaining knowledge of the alleged March 2025 default legally waived and extinguished any right to initiate an eviction action based on that historical period. Defective Notice: Rejscting Plaintiff’s lawful tender of September 2026 rent to manufacture a current default is a bad-faith distortion of the 5-day written demand notice requirement under Section 723.061(1)(a), Florida Statutes. A landlord cannot refuse rent and then claim a tenant failed to pay. Statutory Retaliation: The threat of eviction and the continuous manipulation of the tenant ledger are primarily retaliatory acts punishing the Plaintiff for raising infrastructure complaints, directly violating Section 723.0615, Florida Statutes. Breach of Good Faith: Defendants have violated the overarching obligation of good faith and fair dealing imposed on all mobile home tenancies by Chapter 723, Florida Statutes, and have breached the implied covenant of quiet enjoyment. WHEREFORE, Plaintiff Christopher L. Winans respectfully requests this Court: Enter judgment for damages against Defendants, jointly and severally, in an amount exceeding $8,000 to be proven at trial; Grant Plaintiff leave to deposit ongoing disputed lot rental funds into the Court Registry pursuant to Fla. R. Civ. P. 1.600 and Section 723.063, Florida Statutes; and Issue a temporary and permanent injunction pursuant to Fla. R. Civ. P. 1.610 enjoining the Defendants and their agents from initiating eviction proceedings, entering Lot #210, or continuing to harass or photograph the Plaintiff at his residence. Dated: October 2, 2026. Respectfully submitted, Christopher L. Winans 5015 Seminole Blvd, Lot #210 Seminole, FL 33772 727.947.0067 clw4422@gmail.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal to the Defendant’s attorney of record on this 2nd day of October, 2026. Christopher L. Winans Document Title: version 1 SEE VERSION (E) Document Title: / AMENDED STATEMENT of Claim 2 Oct 2 OCT 2, Original to Doc. E DOCUMENT: [ 1 E (XYZ)] / version 2 Document # 1 E / OCT 3 , NEW statement of clam / Date: Oct 04, 2026 / By: Rato de Advogado / Document: Court Filing / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 E (XYZ) Document Title: / AMENDED STATEMENT of Claim 2 Oct 2 “The corporate shield doctrine does not protect an individual manager in Florida from being sued for their own active, personal torts, harassment, or bad-faith actions.” The compounding actions taken by Manager Saran Gaines and Pacifica Seminole MHP LLC to fabricate a non-payment claim violate multiple procedural mandates, statutory requirements, and common-law doctrines under Florida law. If this case goes before Judge Jagger, you can argue that the management’s actions directly violate the following laws and legal principles: Waiver of Right to Evict by Accepting Rent Under long-standing Florida landlord-tenant and mobile home jurisprudence, a landlord’s acceptance of subsequent rent completely waives their right to evict for a prior known violation or non-payment. By accepting your August 1, 2026 lot rent after notifying you on July 28, 2026 about the alleged March 2025 missing rent, management legally waived and extinguished any right to use March 2025 as a basis for an eviction proceeding. Statutory Failure of 5-Day Written Demand Notice Under Section 723.061(1)(a), Florida Statutes, a park owner can only initiate eviction for non-payment if they deliver a written demand and the default continues for 5 days after delivery. [1] Defective Notice & Itemization: Returning your September 2026 rent check uncashed in an attempt to artificially manufacture a current “non-payment” status is a bad-faith distortion of the statute. A landlord cannot refuse a lawful tender of rent and then claim the tenant failed to pay. Violation of Unlawful Retaliatory Conduct Under Section 723.0615, Florida Statutes, it is strictly unlawful for a mobile home park owner to threaten or bring an action for possession primarily because they are retaliating against a homeowner. [1] Because you raised legitimate disputes and initiated legal proceedings regarding severe infrastructure and property defects, fabricating a stale, 17-month-old “lost check” claim and returning your current checks to force an eviction constitutes statutory retaliation. Violation of the Statutory Duty of Good Faith Under Chapter 723, Florida Statutes (The Florida Mobile Home Act), every rental agreement and duty imposed by the Act enforces an obligation of good faith and fair dealings in its performance and enforcement. [1] Artificially manufacturing a ledger delinquency from nearly a year and a half prior—while possessing a photocopy showing the check was generated (Check #2323)—and then weaponizing it to threaten your tenancy violates this overarching duty of good faith. Common-Law Civil Torts: Intentional Interference and Fraud Fraudulent Misrepresentation / Falsification of Records: Presenting a photocopy of a check, admitting it was lost on their end, and then claiming the tenant “failed to pay” constitutes a fraudulent statement designed to deceive the court and bypass civil protections. Breach of the Covenant of Quiet Enjoyment: A landlord has a common-law contractual duty not to interfere with a tenant’s peaceable possession. Intentionally generating a fake eviction track to force a tenant out breaches this covenant. Would you like help drafting a Formal Motion for Sanctions for Bad-Faith Litigation to file alongside your amended complaint, or would you like me to show you how to weave this timeline into the Factual Allegations section of your Amended Statement of Claim? IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CHRISTOPHER L. WINANS, Plaintiff, vs. SARAN GAINES, Individually, and PACIFICA SEMINOLE MHP LLC , Defendants. CASE NO.: 26-011919-SC DIVISION: Small Claims (Transfer Pending) JUDGE: EDWIN JAGGER PLAINTIFF’S FIRST AMENDED STATEMENT OF CLAIM Plaintiff, Christopher L. Winans, sues Defendants, Saran Gaines, individually, and Pacifica Seminole MHP LLC (doing business as Seminole Mobile Home Park), and alleges: JURISDICTION AND VENUE This is an action for damages and injunctive relief that exceeds the $8,000 jurisdictional limit of the Small Claims Division due to compounding, active structural and infrastructure damages. Jurisdiction is appropriate in the County Court Civil Division. Plaintiff Christopher L. Winans is a resident of Pinellas County, Florida, and owns a mobile home located on Lot #210 within the Seminole Mobile Home Park at 5015 Seminole Blvd, Seminole, FL 33772. Defendant Pacifica Seminole MHP LLC is a Florida limited liability company doing business in Pinellas County, Florida. Defendant Saran Gaines is a resident of Pinellas County, Florida, and is sued in her individual capacity for independent, intentional tortious conduct committed outside the scope of legitimate property management duties. GENERAL ALLEGATIONS: INFRASTRUCTURE DEFECTS Plaintiff’s tenancy is governed by Chapter 723, Florida Statutes (The Florida Mobile Home Act). Under Florida law, the park owner has an non-delegable duty to maintain the park’s common areas and infrastructure in good, safe working order. The Defendant’s property suffers from systemic, severe infrastructure issues, including but not limited to: Systemic electrical defects posing immediate hazards. Plumbing failures and structural damages directly impacting Lot #210. These active, compounding infrastructure damages place the true amount in controversy above $8,000, requiring a transfer to the formal track of the County Court Civil Division. COUNT I: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS & HARASSMENT (Against Defendant Saran Gaines, Individually) Plaintiff re-alleges paragraphs 1 through 8. Since September 23, 2026, Defendant Saran Gaines has engaged in an intentional campaign of extreme harassment and intimidation targeting the Plaintiff. Defendant Gaines has repeatedly sent harassing text messages demanding disputed rent amounts, physically confronted the Plaintiff unannounced at his residence, and leveraged her authority as “park manager” to threaten immediate eviction. Most egregiously, Defendant Gaines has engaged in an unlawful invasion of privacy by standing at the residence, leveling verbal threats, and actively taking unauthorized photographs of the inside of the Plaintiff’s private mobile home. This conduct is outrageous, goes far beyond the bounds of lawful property management, and has caused the Plaintiff severe emotional distress, anxiety, and the loss of quiet enjoyment of his property. COUNT II: BREACH OF COVENANT OF QUIET ENJOYMENT & INJUNCTIVE RELIEF (Against Defendant Pacifica Seminole MHP LLC) Plaintiff re-alleges paragraphs 1 through 8. Through the actions of its agent, Saran Gaines, Defendant Pacifica Seminole MHP LLC has breached the implied covenant of quiet enjoyment by subjecting the Plaintiff to an unsafe living environment and ongoing intimidation. The Defendant is actively threatening eviction for the non-payment of the very lot rent that is central to this underlying infrastructure litigation. Plaintiff faces immediate, irreparable harm in the form of unlawful eviction and the potential loss of his home if the court does not intervene. Negligence & Failure to Maintain: Plaintiff re-alleges paragraphs 1 through 8 Through the actions of its agent, Saran Gaines, Defendant Pacifica Seminole MHP has violated the law Under Florida Statutes Chapter 723 (The Florida Mobile Home Act), park owners have a statutory duty to maintain the common areas and utility infrastructure they control. If the Defendant Ms. Saran Gaines, knew about the grid surges and failed to repair them or warn residents, she has breached this duty. Fraudulent Concealment / Intentional Nondisclosure: Plaintiff re-alleges paragraphs 1 through 8 Through the actions of its agent, Saran Gaines, Defendant Pacifica Seminole MHP has Intentionally hiding a material fact (the dangerous power surges) that results in economic harm to a tenant allows the Plaintiff to sue a claim for damages, and potentially punitive damages if the concealment was malicious or reckless. Breach of the Rental/Lease Agreement: . 22. Plaintiff re-alleges paragraphs 1 through 8 Mobile home park leases imply that the lot will be provided with safe, functional utility hookups. Systemic grid failures caused by park equipment breach that contract. WHEREFORE, Plaintiff Christopher L. Winans respectfully requests this Court: Enter judgment for damages against Defendants, jointly and severally, in an amount exceeding $8,000 to be proven at trial; Grant Plaintiff leave to deposit all ongoing disputed lot rental funds into the Court Registry; and Issue an injunction enjoining the Defendants and their agents from initiating eviction proceedings or continuing to harass or photograph the Plaintiff at his private residence pending final resolution. Dated: October 1, 2026. Respectfully submitted, Christopher L. Winans 5015 Seminole Blvd, Lot #210 Saint Petersburg, FL 33772 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Amended Statement of Claim, along with the Proposed Order and First Amended Motion for Court Registry, has been furnished via the Florida Courts E-Filing Portal or by US Postal Service to the Defendant’s attorney of record on this 3rd day of October, 2026. Christopher L. Winans Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands OCT 3 NEW statement of clam . IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CHRISTOPHER L. WINANS, Plaintiff, vs. SARAN GAINES, Individually, and PACIFICA SEMINOLE MHP LLC, Defendants. CASE NO.: 26-011919-SC DIVISION: County Civil Division (Transfer Pending) JUDGE: EDWIN JAGGER PLAINTIFF’S FIRST AMENDED STATEMENT OF CLAIM Plaintiff, Christopher L. Winans, sues Defendants, Saran Gaines, individually, and Pacifica Seminole MHP LLC (doing business as Seminole Mobile Home Park), and alleges: JURISDICTION AND VENUE This is an action for damages, statutory violations, and injunctive relief that exceeds the $8,000 jurisdictional limit of the Small Claims Division due to compounding, active structural and infrastructure damages. Pursuant to Florida Small Claims Rule 7.100(d), this action is subject to immediate transfer to the formal track of the County Court Civil Division. Plaintiff Christopher L. Winans is a resident of Pinellas County, Florida, and owns a mobile home located on Lot #210 within the Seminole Mobile Home Park at 5015 Seminole Blvd, Seminole, FL 33772. Defendant Pacifica Seminole MHP LLC is a Florida limited liability company doing business in Pinellas County, Florida, and is the owner of the park [L19000250486]. Defendant Saran Gaines is a resident of Pinellas County, Florida, and is the physical park manager. She is sued in her individual capacity. The corporate shield doctrine does not protect an individual manager in Florida from being sued for their own active, personal torts, harassment, or bad-faith actions (Vesta Construction and Design, LLC v. Lotspeich & Associates, Inc.). GENERAL ALLEGATIONS: INFRASTRUCTURE DEFECTS Plaintiff’s tenancy is governed by Chapter 723, Florida Statutes (The Florida Mobile Home Act). Under Florida law, the park owner has a non-delegable duty to maintain the park’s common areas and infrastructure in good, safe working order. The Defendant’s property suffers from systemic, severe infrastructure issues, including but not limited to, systemic electrical defects posing immediate hazards, plumbing failures, and structural damages directly impacting Lot #210. These active, compounding infrastructure damages place the true amount in controversy above $8,000, invoking the formal track of the Florida Rules of Civil Procedure pursuant to Florida Small Claims Rule 7.020(b). III. FACTUAL ALLEGATIONS: FABRICATED DELINQUENCY & HARASSMENT On September 23, 2026, Plaintiff filed a motion to securely hold disputed lot rental funds due to these unaddressed infrastructure defects. In retaliation, Defendant Saran Gaines fabricated a fraudulent one-month lot rent non-payment claim regarding Lot #210 for the month of March 2025—a period spanning 17 months prior. Defendant Gaines first informed the Plaintiff of this alleged missing March 2025 rent on July 28, 2026. Defendant Gaines has produced a photocopy of Plaintiff’s March 2025 payment (Check No. 2323), confirming receipt and physical possession of the asset, but claims she cannot produce the actual check in any form because it was “lost” by management. Subsequent to her July 28, 2026 demand, Defendant Gaines accepted Plaintiff’s August 1, 2026 lot rent payment in full. In September 2026, Defendant Gaines acted in overt bad faith by returning Plaintiff’s September 2026 rent check completely uncashed in a deliberate, artificial manipulation of the ledger designed to falsify a pathway for eviction. Since September 23, 2026, Defendant Gaines has engaged in an active campaign of intimidation, which includes sending harassing text messages, physically confronting the Plaintiff unannounced at his home while leveraging her authority as “the park manager,” leveling verbal eviction threats, and standing at the residence taking unauthorized photographs of the inside of the Plaintiff’s private mobile home. COUNT I: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS & INDIVIDUAL CIVIL TORT LIABILITY (Against Defendant Saran Gaines, Individually) Plaintiff re-alleges paragraphs 1 through 15. The corporate shield doctrine does not insulate Defendant Gaines. Her personal actions—fabricating a 17-month-old debt, admitting to losing a processed check (Check #2323), intentionally rejecting a lawful tender of current rent to fake an eviction track, and capturing unauthorized photos of the inside of Plaintiff’s private residence—constitute independent, intentional tortious acts of fraud and harassment. This conduct is extreme, outrageous, goes far beyond the bounds of lawful property management, and was executed with the intention to cause severe emotional distress and force the Plaintiff from his home. COUNT II: VIOLATION OF CHAPTER 723, FLA. STAT. (STATUTORY RETALIATION & BREACH OF GOOD FAITH) (Against Defendant Pacifica Seminole MHP LLC) Plaintiff re-alleges paragraphs 1 through 15. Waiver: Under Florida law, Defendant’s acceptance of subsequent August 2026 rent after gaining knowledge of the alleged March 2025 default legally waived and extinguished any right to initiate an eviction action based on that historical period. Defective Notice: Rejscting Plaintiff’s lawful tender of September 2026 rent to manufacture a current default is a bad-faith distortion of the 5-day written demand notice requirement under Section 723.061(1)(a), Florida Statutes. A landlord cannot refuse rent and then claim a tenant failed to pay. Statutory Retaliation: The threat of eviction and the continuous manipulation of the tenant ledger are primarily retaliatory acts punishing the Plaintiff for raising infrastructure complaints, directly violating Section 723.0615, Florida Statutes. Breach of Good Faith: Defendants have violated the overarching obligation of good faith and fair dealing imposed on all mobile home tenancies by Chapter 723, Florida Statutes, and have breached the implied covenant of quiet enjoyment. WHEREFORE, Plaintiff Christopher L. Winans respectfully requests this Court: Enter judgment for damages against Defendants, jointly and severally, in an amount exceeding $8,000 to be proven at trial; Grant Plaintiff leave to deposit ongoing disputed lot rental funds into the Court Registry pursuant to Fla. R. Civ. P. 1.600 and Section 723.063, Florida Statutes; and Issue a temporary and permanent injunction pursuant to Fla. R. Civ. P. 1.610 enjoining the Defendants and their agents from initiating eviction proceedings, entering Lot #210, or continuing to harass or photograph the Plaintiff at his residence. Dated: October 2, 2026. Respectfully submitted, Christopher L. Winans 5015 Seminole Blvd, Lot #210 Seminole, FL 33772 727.947.0067 clw4422@gmail.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal to the Defendant’s attorney of record on this 2nd day of October, 2026. Christopher L. Winans Document Title: F / Legal Authority to amend 2B . / Document # 1 F / Date: Oct 04, 2026 / By: Rato de Advogado / Document: Legal Authority to amend 2B /// THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 F Legal Authority to amend 2B Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Legal Authority to amend 2B “The corporate shield doctrine does not protect an individual manager in Florida from being sued for their own active, personal torts, harassment, or bad-faith actions.” The compounding actions taken by Manager Saran Gaines and Pacifica Seminole MHP LLC to fabricate a non-payment claim violate multiple procedural mandates, statutory requirements, and common-law doctrines under Florida law. If this case goes before Judge Jagger, you can argue that the management’s actions directly violate the following laws and legal principles: Waiver of Right to Evict by Accepting Rent Under long-standing Florida landlord-tenant and mobile home jurisprudence, a landlord’s acceptance of subsequent rent completely waives their right to evict for a prior known violation or non-payment. By accepting your August 1, 2026 lot rent after notifying you on July 28, 2026 about the alleged March 2025 missing rent, management legally waived and extinguished any right to use March 2025 as a basis for an eviction proceeding. Statutory Failure of 5-Day Written Demand Notice Under Section 723.061(1)(a), Florida Statutes, a park owner can only initiate eviction for non-payment if they deliver a written demand and the default continues for 5 days after delivery. [1] Defective Notice & Itemization: Returning your September 2026 rent check uncashed in an attempt to artificially manufacture a current “non-payment” status is a bad-faith distortion of the statute. A landlord cannot refuse a lawful tender of rent and then claim the tenant failed to pay. Violation of Unlawful Retaliatory Conduct Under Section 723.0615, Florida Statutes, it is strictly unlawful for a mobile home park owner to threaten or bring an action for possession primarily because they are retaliating against a homeowner. [1] Because you raised legitimate disputes and initiated legal proceedings regarding severe infrastructure and property defects, fabricating a stale, 17-month-old “lost check” claim and returning your current checks to force an eviction constitutes statutory retaliation. Violation of the Statutory Duty of Good Faith Under Chapter 723, Florida Statutes (The Florida Mobile Home Act), every rental agreement and duty imposed by the Act enforces an obligation of good faith and fair dealings in its performance and enforcement. [1] Artificially manufacturing a ledger delinquency from nearly a year and a half prior—while possessing a photocopy showing the check was generated (Check #2323)—and then weaponizing it to threaten your tenancy violates this overarching duty of good faith. Common-Law Civil Torts: Intentional Interference and Fraud Fraudulent Misrepresentation / Falsification of Records: Presenting a photocopy of a check, admitting it was lost on their end, and then claiming the tenant “failed to pay” constitutes a fraudulent statement designed to deceive the court and bypass civil protections. Breach of the Covenant of Quiet Enjoyment: A landlord has a common-law contractual duty not to interfere with a tenant’s peaceable possession. Intentionally generating a fake eviction track to force a tenant out breaches this covenant. Would you like help drafting a Formal Motion for Sanctions for Bad-Faith Litigation to file alongside your amended complaint, or would you like me to show you how to weave this timeline into the Factual Allegations section of your Amended Statement of Claim? what law did the Mobile Home Park Manager violate when she fabricated a one month non payment of Lot Rent for Lot #210 for the month of March 2025, informing the Plaintiff of the missing Lot #210 rent for March 2025 in the Month of July, 28th 2026, subsequently accepting August 1 Lot rent then acting in paid faith and returning the September 2026 check uncashed to the defendant, thus falsifying a process for eviction, Manager Gaines, has produced a photo copy of the March 2025 check payment check number 2323, but can not produce the actual check in any form, stating it was lost, DEFENDANT TO BE SERVED: Pacifica Seminole MHP LLC c/o Paracorp Incorporated, Registered Agent 155 Office Plaza Dr, 1st Floor Tallahassee, FL 32301 Legal Authority to amend Your legal authority for these specific motions relies on a combination of Florida court rules and substantive state statutes. Motion for Leave to Amend & Transfer Division Florida Rule of Civil Procedure 1.190(a): This is the core procedural rule governing amendments. It explicitly mandates that “leave of court shall be given freely when justice so requires.” Florida courts heavily favor letting a case be decided on its factual merits rather than procedural errors, provided there is no prejudice to the defendant. [1, 2] Florida Small Claims Rule 7.100(d): This rule dictates what happens when a claim exceeds the monetary bounds of small claims. It states that if a counterclaim or an amendment exceeds the jurisdictional financial limit (which is $8,000 for small claims), the judge must transfer the action to the proper division of the County or Circuit Court. [1] Florida Small Claims Rule 7.020(b): This rule dictates that if a case is transferred out of Small Claims to the formal County Civil track, the Florida Rules of Civil Procedure immediately take over. [1] Motion to Deposit Funds into the Court Registry Florida Rule of Civil Procedure 1.600: This rule provides the direct mechanism for depositing disputed property or money. It states that when a party holds money that is the subject of the lawsuit, they may request leave of court to deposit all or part of that sum with the Clerk of Court, to be held in an interest-bearing registry until the judge determines who owns it. Section 723.063, Florida Statutes (The Florida Mobile Home Act): Under substantive Florida mobile home law, if a park owner brings an eviction action or a tenant defends against rent non-payment based on a material breach of the park’s statutory maintenance duties, the tenant is required by law to pay the disputed rent into the registry of the court to preserve their defense and protect their tenancy from immediate forfeiture. Motion for Injunctive Relief (Stopping Eviction & Harassment) Florida Rule of Civil Procedure 1.610: This is the authority governing injunctions. It grants the court the power to issue temporary and permanent injunctions to prevent “irreparable injury, loss, or damage” before a full trial takes place. Your motion leverages this rule by demonstrating that an unjust eviction would result in the physical loss of your mobile home home Document Title: THE BIG Enchilada / DOCUMENT 1 G Document # 1 G THE BIG Enchilada / Date: Oct 04, 2026 / By: Rato de Advogado / Document: THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands Document # 1 G: THE BIG Enchilada Document Title: / Date: Oct 04, 2026 / By: Rato de Advogado / Document: / THE LAW – BASE FORM A To Which It Stands: ” War at Lot 210 / The War At Lot #210 – ‘To Which It Stands THE BIG Enchilada ….. against dismiss motions EVERYTHING The Florida registered agent for Pacifica Seminole MHP LLC (the owner of Seminole Mobile Home Park at 5015 Seminole Blvd.) is Paracorp Incorporated. Registered Agent Name: Paracorp Incorporated Registered Office Address: 155 Office Plaza Dr, 1st Floor, Tallahassee, FL 32301 Principal Address / Mailing Address: 1775 Hancock St, Ste 200, San Diego, CA 92110 Would you like assistance looking up any additional corporate filings, manager details, or contact information for this property? MyFlorida.com (.gov) pacifica seminole mhp llc – Detail by Entity Name Document Number L19000250486 FEI/EIN Number 84-3337943 Date Filed 10/16/2019 State FL Status ACTIVE 1775 HANCOCK ST STE 200 SAN DI… Integrity Mobile Home Sales Seminole Mobile Home Park 5015 Seminole Boulevard Saint Petersburg, FL 33708. Open in Google Maps →. Integrity Mobile Home Sales … Legal & Trust. Privacy … FloridaParcels.com 5015 seminole blvd – FloridaParcels.com 5015 SEMINOLE BLVD owned by PACIFICA SEMINOLE MHP LLC manager details, or contact information for this property? The management company, corporate officer, and direct contact details for Seminole Mobile Home Park at 5015 Seminole Blvd are detailed below. Management & Operations The community is an age-restricted (55+) manufactured home park operated by PacShore Communities. Community Office Phone: (727) 242-1242 Alternative Listing / Sales Contact: (941) 345-5583 Official Property Management Portal: You can view availability and community standards on the PacShore Communities Seminole Portal. Corporate Manager & Ownership Details According to the Florida Department of State Division of Corporations (Sunbiz), the property is owned by Pacifica Seminole MHP LLC (Document Number: L19000250486). The listed corporate manager and member entities managing this LLC are: Listed Manager: Deepak Israni Managing Member Trusts: Ashok Israni and Lata Israni Family Trust Deepak Israni and Varsha Israni Family Trust Corporate Headquarter Address: 1775 Hancock St, Ste 200, San Diego, CA 92110 Would you like me to help you draft an official inquiry letter to PacShore Communities management, or do you need help searching for public county property appraisal documents for this parcel? PacShore Communities Seminole | PacShore Communities Location: 5015 Seminole Boulevard, Saint Petersburg, FL 33708; Phone: (727) 242-1242. Community Type: 55+ age-restricted manufactu… Integrity Mobile Home Sales Seminole Mobile Home Park Contact our team for current availability, community details, or help scheduling a private tour. Call (941) 345-5583 MyFlorida.com (.gov) pacifica seminole mhp llc – Detail by Entity Name PACIFICA SEMINOLE MHP LLC. Principal Address. 1775 HANCOCK ST STE 200. SAN DIEGO, CA 92110. Address PARACORP INCORPORATED. ASHOK I… What is a response to a motion to dismiss a small claims case called A response to a motion to dismiss is most commonly called a Plaintiff’s Response to Defendant’s Motion to Dismiss or an Opposition to the Motion to Dismiss. Because small claims court rules are designed to be less formal, the exact formatting requirements can vary slightly depending on your specific county. However, the document generally serves the same purpose across jurisdictions: 📄 Standard Filing Titles Plaintiff’s Response to Defendant’s Motion to Dismiss Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion to Dismiss (Used if you are providing a detailed legal argument or referencing case law) Opposition to Motion to Dismiss 💡 Alternative Strategy: Motion for Leave to Amend If the defendant’s motion points out a legitimate, easy-to-fix technical flaw in your lawsuit (such as a factual typo, an attached document issue, or naming the wrong entity), a common alternative strategy is to file a Motion for Leave to Amend the Complaint. Instead of arguing against the dismissal, this asks the judge for permission to file a corrected version of your lawsuit. If you are currently drafting a response, let me know: What grounds or reasons did the defendant give for wanting to dismiss the case? (e.g., wrong court, past the statute of limitations, incorrect entity named) Which county or state is this small claims case filed in? I can give you more specific details on standard deadlines or how to format your response argument. AI responses may include mistakes. For legal advice, consult a professional. Learn more Northern District of California (.gov) RESPONDING TO A MOTION TO DISMISS THE COMPLAINT HOW TO COMPLETE THE OPPOSITION TO MOTION TO DISMISS TEMPLATE. 1. Read the Pro Se Handbook – Chapter 11, “What is a Plunkett Cooney, PC Resolving Litigation Through Motions to Dismiss and Motions … Motions to Dismiss A “motion to dismiss” is typically filed in response to a complaint and is made in lieu of filing an “answer.” … WomensLaw.org Before the Trial: How do I respond to a motion to dismiss made by the other party? | WomensLaw.org Common grounds include insufficient facts for the cause of action, lack of jurisdiction, paperwork defects, expired statute of lim… Show all What is the Form to file: Motion for Leave to amend the Complaint in Case: 26-011919-SC, in Small Claims Division of the Pinellas County Court of the 6th Circuit Court, for Plaintiff’s response for motion to dismiss due to: improper serves directly to the corporation: Pacifica Seminole Mobile Home Park and not to the Florida registered agent: The Florida registered agent for Pacifica Seminole MHP LLC (the owner of Seminole Mobile Home Park at 5015 Seminole Blvd.) is Paracorp Incorporated Registered Office Address 155 Office Plaza, 1st Door, Tallahassee, FL 32301 There is no official numbered or pre-printed form provided by the Pinellas County Clerk or the Florida Courts specifically titled “Motion for Leave to Amend a Complaint”. In Florida Small Claims Court, when you need to fix a procedural issue like serving the wrong entity or office, you must draft your own customized, written motion from scratch and file it into your case via the Florida Courts E-Filing Portal. Under Florida Small Claims Rule 7.070 and Florida Rule of Civil Procedure 1.190(a), the court allows amendments freely, but you must attach a complete copy of your proposed Amended Statement of Claim directly to the back of your motion. The template below can be used to format and draft the motion yourself. IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA PLAINTIFF NAME(S), Plaintiff, vs. PACIFICA SEMINOLE MHP LLC, Defendant. CASE NO.: 26-011919-SC DIVISION: Small Claims PLAINTIFF’S MOTION FOR LEAVE TO AMEND THE COMPLAINT AND MEMORANDUM IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS Plaintiff, [Your Name], respectfully moves this Court pursuant to Florida Rule of Civil Procedure 1.190(a) and Florida Small Claims Rules for an Order granting leave to amend the initial Statement of Claim. In support, Plaintiff states: Plaintiff filed the initial Statement of Claim in this action on [Date you filed]. Defendant filed a Motion to Dismiss alleging improper service of process, noting that service was delivered directly to the physical business location rather than to Defendant’s designated Florida Registered Agent. Plaintiff recognizes this technical defect and seeks to cure the service issue immediately. Justice requires that the case be decided on its merits rather than a technical service error. Leave to amend “shall be given freely when justice so requires” under Fla. R. Civ. P. 1.190(a). Granting this motion will not prejudice the Defendant, as the case is in its earliest stages, no trial date has been set, and the amendment serves only to properly identify and serve the correct Registered Agent entity. Attached hereto as Exhibit A is the proposed Amended Statement of Claim correctly identifying the Defendant and its Registered Agent for formal service of process. WHEREFORE, Plaintiff respectfully requests this Court enter an Order: Denying Defendant’s Motion to Dismiss; Granting Plaintiff leave to file the attached Amended Statement of Claim; and Allowing Plaintiff an additional 120 days to execute proper service of process upon the Defendant’s Registered Agent: Paracorp Incorporated, 155 Office Plaza Dr, 1st Floor, Tallahassee, FL 32301. Dated: October 1, 2026. Respectfully submitted, [Your Name] [Your Address] [Your Phone Number] [Your Email Address] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal or U.S. Mail to the Defendant or Defendant’s counsel [if they have an attorney] on this 1st day of October, 2026. [Your Signature] ⚠%EF%B8%8F Crucial Next Steps for Pinellas County: Prepare “Exhibit A”: Take your original Statement of Claim, update any text indicating how they are to be served, write “AMENDED” at the very top of the document title, and attach it behind this motion. File via the Portal: Log into the Florida Courts E-Filing Portal using your case number 26-011919-SC. Upload this document as a single PDF. Issue a New Summons: Once the judge signs an order granting your motion, you must ask the Pinellas County Clerk to issue a new Amended Summons addressed directly to Paracorp Incorporated in Tallahassee so a process server can serve them correctly. Do you already have the contact info for a certified process server in Leon County (Tallahassee) to handle the delivery once the judge grants your motion, or do you need help finding one? AI responses may include mistakes. For legal advice, consult a professional. Learn more Pinellas County Clerk of the Circuit Court (.gov) Forms Page Post Judgment Forms and Miscellaneous Motion for Modification of Injunction for Protection (F.L. Form 12.980(j)) non-child support… Sixth Judicial Circuit Small Claims Administrative Orders Small Claims. Administrative Order Number. Subject. 2026-002. Assignment of Circuit Civil, Family Law, County Civil, and Small Cla… The Florida Bar Florida Small Claims Rules Jul 1, 2026 — effected within a specified time or must dismiss the action without prejudice or drop that party. If the movant requests additiona… Show all contact info for a certified process server in Leon County (Tallahassee) to handle the delivery once the judge grants your motion, Because your case is filed in Pinellas County but the registered agent (Paracorp Incorporated) is physically located in Tallahassee (Leon County), you must use a server with jurisdiction in Leon County. You have two primary options: using the official local Sheriff’s office or hiring a private certified process server. Option 1: Leon County Sheriff’s Office (Civil Process Unit) The most straightforward option is to use the local Sheriff’s office. They handle out-of-county legal hand-deliveries regularly. Phone: (850) 606-3450 Office Address: Attn: Civil Division, 3333 W. Pensacola St., Suite 200, Tallahassee, FL 32304 Mailing Address: P.O. Box 727, Tallahassee, FL 32302 Email Contact: lcso_civil_warrants@leonFLSheriff.gov Requirements: You will typically mail them the original summons issued by the Pinellas clerk, a copy of the amended complaint, a copy for their records, and a service fee check (usually around $40.00, though you should call to verify exact out-of-county rates). Option 2: Private Certified Process Servers (Tallahassee Local) If you prefer a private service for faster turnarounds or specialized communication, you can choose from the official Second Judicial Circuit Certified Process Server Directory or agencies certified by the Florida Association of Professional Process Servers (FAPPS): Accurate Serve of Tallahassee Phone: (850) 519-5494 Details: Run by Brennan Fogarty (a member of the Second Circuit Process Server Review Board), this agency specializes heavily in daily courier runs to registered agent offices throughout Tallahassee. KD Process (James Kady) Phone: (850) 545-3452 or (850) 727-4363 Address: 2957 Capital Park Drive, Suite 7, Tallahassee, FL 32399 Nolan Process Servers (Michael Nolan) Phone: (850) 901-0000 or (850) 562-6058 Golden Process Service Phone: (888) 766-7497 Details: Offers specialized same-day delivery specifically targeted at corporate registered agents in Leon County. Pro-Tip: Do not reach out to these servers until after the Pinellas County judge explicitly signs the order granting your Motion for Leave to Amend and the Pinellas Clerk processes your newly issued “Amended Summons.” Once you have that official summons paperwork in hand, you can send it to your chosen server above. AI responses may include mistakes. For legal advice, consult a professional. Learn more Leon County Clerk of Court County Civil & Small Claims call (850) 606-4110. For each defendant listed in the complaint/petition, the plaintiff must provide an original and two copies of… 2nd Judicial Circuit (.gov) Certified Civil Process Servers – 2nd Judicial Circuit Apr 1, 2026 — Certified Civil Process Servers – Second Judicial Circuit. (850) 508-5261 (W); (850) 491-9582 (C). 3/31/2027. Larson, Eric L. 063. Golden Process Service Serving Corporation Service Company (CSC) in Tallahassee Aug 7, 2026 — Its Florida registered office at 1201 Hays Street, Tallahassee, FL 32301 sits in Leon County, minutes. Fort Lauderdale, Miami, Orl… Show all In case: 26-011919-SC in Small claims division What is the Form respnse to file: Motion for Leave to amend the Complaint in Case: 26-011919-SC, in Small Claims Division of the Pinellas County Court of the 6th Circuit Court, for Plaintiff’s response for motion to dismiss the property manager Saran Gaines as a defendant in the case. Although she has been threatening the Plaintiff regularly, acted in bad faith and threaten eviction unjustly. There is no official pre-printed form provided by the court to oppose the dismissal of an individual defendant; you must file a customized, written Plaintiff’s Response in Opposition to Defendant’s Motion to Dismiss or an Amended Statement of Claim that explicitly details her individual liability. Under Florida law, corporate employees and property managers can be held individually liable if they personally commit an intentional tort (such as civil harassment, civil theft, or intentional infliction of emotional distress) or act in bad faith outside the scope of standard corporate protections, even if they are acting on behalf of an LLC. The template below can be customized to respond to the motion to dismiss Saran Gaines from Case No. 26-011919-SC. IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA [YOUR NAME], Plaintiff, vs. PACIFICA SEMINOLE MHP LLC, and SARAN GAINES, individually, Defendants. CASE NO.: 26-011919-SC DIVISION: Small Claims PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT SARAN GAINES’ MOTION TO DISMISS Plaintiff, [Your Name], respectfully files this Response in Opposition to Defendant Saran Gaines’ Motion to Dismiss, and requests this Court deny the motion to dismiss her as a party to this action. In support, Plaintiff states: Defendant Saran Gaines moves to dismiss the claims against her individually under the assumption that she is protected as a mere agent or employee of Pacifica Seminole MHP LLC. Under established Florida law, an officer, agent, or employee of a corporation or LLC who commits or participates in an intentional tort or acts in bad faith is individually liable to the injured third party, regardless of whether they acted in a corporate capacity (Vesta Construction and Design, LLC v. Lotspeich & Associates, Inc.). Corporate status does not shield an individual from their own tortious acts or bad-faith conduct. Plaintiff’s claims against Defendant Gaines are based on her direct, personal, and intentional actions, which include: Engaging in regular, ongoing harassment and hostile threats against the Plaintiff. Actively acting in bad faith to disrupt the Plaintiff’s peaceful tenancy. Intentionally threatening the Plaintiff with unjust and unlawful evictions to cause distress and leverage compliance. These targeted, intentional actions go beyond the scope of ordinary, lawful property management duties and constitute independent individual misconduct. Dismissing Defendant Gaines at this early stage would severely prejudice the Plaintiff, as she is the central tortfeasor responsible for the face-to-face bad-faith conduct alleged in this dispute. WHEREFORE, Plaintiff respectfully requests this Court enter an Order DENYING Defendant Saran Gaines’ Motion to Dismiss, requiring her to file an Answer to the Statement of Claim within ten (10) days, or alternatively, granting Plaintiff leave to file an Amended Statement of Claim to further articulate these individual tort claims. Dated: October 1, 2026. Respectfully submitted, [Your Name] [Your Address] [Your Phone Number] [Your Email Address] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal to the Defendant’s attorney of record on this 1st day of October, 2026. [Your Signature] 💡 Procedural Tip for Your Hearing When you attend the motion hearing before the Pinellas County judge, the defense attorney will likely argue the “corporate shield doctrine.” Your counter-argument should clearly state: “The corporate shield doctrine does not protect an individual manager in Florida from being sued for their own active, personal torts, harassment, or bad-faith actions.” If you want to strengthen this filing, let me know: Has she sent these threats to you in writing (text/email) or were they strictly verbal? Did she try to issue any official eviction notices (like a 3-day or 7-day notice), or were they just verbal threats? I can help you weave those specific facts into the argument to ensure the judge keeps her in the case. AI responses may include mistakes. For legal advice, consult a professional. Learn more I want to file an amended statement of claim in case: 26-011919-SC with the following information: IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CHRISTOPHER L. WINANS, Plaintiff, v. SARAN GAINES, PACIFICA SEMINOLE MHP, CORPORATE HEADQUARTERS, Defendant. CASE NO.: 26-011919-SC DIVISION: SMALL CLAIMS JUDGE: EDWIN JAGGER ORDER GRANTING LEAVE TO FILE FIRST AMENDED COMPLAINT AND TRANSFERRING ACTION TO THE COUNTY COURT CIVIL DIVISION THIS CAUSE came before the Court upon Plaintiff Christopher L. Winans’ First Amended Motion for Leave to Amend Complaint and to Transfer Venue to the County Court Civil Division. The Court, having reviewed the motion, the records in this file, and noting that the active, compounding damages regarding the infrastructure issues (including systemic electrical, plumbing, and structural damage) place the true amount in controversy above the $8,000 small claims limit, finds that a transfer is appropriate to ensure proper assignment. It is therefore: ORDERED AND ADJUDGED as follows: Plaintiff’s First Amended Motion for Leave to File an Amended Complaint and Transfer Venue is GRANTED. The Plaintiff is deemed to have leave of Court to file the First Amended Complaint. The First Amended Complaint attached to Plaintiff’s motion is hereby deemed filed as of the date of this Order. The Clerk of the Circuit Court and Comptroller for Pinellas County is DIRECTED to immediately transfer and reassign this action from the Small Claims Division to the County Court Civil Division. The Clerk shall update the judicial docket, modify the division track, and issue a standard County Civil case number suffix, if necessary, while preserving the core historical record of this case file. This matter shall remain assigned to County Court Judge Edwin Jagger, who shall proceed to hear the case under the formal track of the Florida Rules of Civil Procedure rather than the Small Claims Rules. To the extent required by the Clerk, the Plaintiff shall pay any operational transfer or civil reopen fees within twenty (20) days of the date of this Order, failing which this transfer order may be subject to review. DONE AND ORDERED in Chambers at Pinellas County, Florida on this _____ day of ______________, 2026. By: ______________________________ COUNTY COURT JUDGE EDWIN JAGGER Conformed copies furnished to: Christopher L. Winans, Plaintiff SARAN GAINES, PACIFICA SEMINOLE MHP, CORPORATE HEADQUARTS, DefendantIN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA SMALL CLAIMS DIVISION CASE NO: 26-011919-SC CHRISTOPHER L. WINANS, Plaintiff, v. SARAN GAINES, PACIFICA MHP CORPORATE HEADQUARTERS, Defendant. CASE NO.: 26-011919-SC DIVISION: SMALL CLAIMS JUDGE: EDWIN JAGGER PLAINTIFF’S FIRST AMENDED MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE COURT REGISTRY AND FOR INJUNCTIVE RELIEF The Plaintiff, Christopher L. Winans, files this First Amended Motion for Leave to Deposit Funds into the Court Registry, and in support thereof states: On September 23, 2026, P