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Rodriguez Licea et al v. Curacao Drydock Co - Scientology Garnishment Creditor Replies

Rodriguez Licea et al v. Curacao Drydock Co - Scientology Garnishment Creditor Replies

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Published by AnonLover
Rodriguez Licea, et al v. Curacao Drydock Co. in the US District Court of Southern Florida. Docket no. 1:06-cv-22128. See also: https://archive.org/details/gov.uscourts.flsd.125578
Rodriguez Licea, et al v. Curacao Drydock Co. in the US District Court of Southern Florida. Docket no. 1:06-cv-22128. See also: https://archive.org/details/gov.uscourts.flsd.125578

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Published by: AnonLover on Apr 13, 2014
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07/02/2014

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 06-22128-CV-KING/MCALILEY ALBERTO JUSTO RODRIGUEZ LICEA, FERNANDO ALONSO HERNANDEZ, AND LUIS ALBERTO CASANOVA TOLEDO, Plaintiffs/Judgment Creditors, vs. CURAÇAO DRYDOCK COMPANY, INC., A/K/A CURAÇAOSE DOKMAATSCHAPPIJ NV, A/K/A CDMNV, Defendant/Judgment Debtor. _____________________________________/
JUDGMENT CREDITORS’ REPLY TO CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.’S AMENDED ANSWER TO WRIT OF GARNISHMENT.
Judgment Creditors reply to Garnishee Church of Scientology Flag Service Organization, Inc.’s Amended Answer to Writ of Garnishment Served October 31, 2013. Judgment Creditors controvert the answer of the garnishee, Church of Scientology Flag Service Organization, Inc. (“Garnishee”) filed in response to the Writ of Garnishment. Judgment Creditors have good reason to believe and do believe that Garnishee’s Amended Answer (the “Amended Answer”) is incorrect in the following particulars: 1. Contrary to the Amended Answer, Garnishee was indebted to Petitioner/Judgment Debtor, Curacao Drydock Company, a/k/a Curacaose Dokmaatshcappij NV, a/k/a CDMNV (the “Drydock”) as of the time of Garnishee's Answer on October 29, 2013 (the “Answer”), or the Amended Answer on October 31, 2013, or at times since issuance on October 7, 2013 and
Case 1:06-cv-22128-JLK Document 408 Entered on FLSD Docket 11/21/2013 Page 1 of 6
 
 
service of the Writ, or at times between such times and did have or still has monies of the Drydock in its custody, possession or control, and have or may have had other tangible or intangible personal property of the Drydock in its possession or control at the time of the Amended Answer or at times since the service of the Writ. At the time of Garnishee's Amended Answer, Garnishee was aware of persons or entities indebted to the Drydock, who had or may still have property of the Drydock in its custody, possession or control. 2. Specifically, Garnishee and/or its alter ego or agent is the owner or manager of the SMV Freewinds, a vessel that, at the time of the service of the Writ, was undergoing repairs by the Drydock at their facility in Curacao. In its Answer, filed on October 29, 2013, Garnishee states that “it would be logical to assume that Church of Scientology Flag Ship Service Organization, Inc. might be indebted to the Drydock. See Answer at ¶3. On October 31, 2013, Garnishee filed the Amended Answer, removing the reference to Church of Scientology Flag Ship Service Organization.
1
 Despite Garnishee’s knowledge, Garnishee provides no explanation regarding the ownership of the SMV Freewinds, or the monies owed to the Drydock in connection therewith. Similarly, Garnishee provides no explanation in its Answer or Amended Answer regarding the relationship between it and Church of Scientology Flag Ship Service Organization, Inc., nor the relationship between those entities and the SMV Freewinds. Instead, Garnishee simply baldly denies having any property of the Drydock or any knowledge of any person or entity indebted to the Drydock.
See
Amended Answer at ¶¶2-3.
1
 It would be logical to assume that the Garnishee’s alter ego, the Church of Scientology and its related entities, including the Church of Scientology Flag Ship Service Organization, demanded that Garnishee amend its pleading.
Case 1:06-cv-22128-JLK Document 408 Entered on FLSD Docket 11/21/2013 Page 2 of 6
 
 
WHEREFORE, Judgment Creditors request that the issues raised by this Reply and the Answer of Garnishee be tried, as provided by law, and demand judgment against Garnishee in accordance with the findings of the Court against the Judgment Debtors and against Garnishee in order that Judgment Creditors' Final Judgments in the amount of $80,000,000, plus interest and costs may be collected and for such other and further orders and relief as the Court may deem  just and proper; and further request that the Court allow Judgment Creditors a reasonable opportunity to conduct discovery in aid of judgment and execution pursuant to Fed. R. Civ. P. 69(a) into the factual disputes raised in the Answer and this Reply. Respectfully submitted, Dated: Miami, Florida November 21, 2013 GROSSMAN ROTH, P.A. By: /s/ Seth Miles, Esq. Seth Miles, Esq. Stuart Grossman, Esq. 2525 Ponce de Leon Blvd., Suite 1150 Coral Gables, Florida 33134 (305) 442-8666 DO CAMPO & THORNTON, P.A. John Thornton, Esq. Orlando do Campo, Esq. 100 Southeast Second Street, Suite 2700 Miami, Florida 33131 REED SMITH LLP Jordan W. Siev, Esq.* Casey D. Laffey, Esq.* 599 Lexington Avenue New York, New York 10022 *Admitted
Pro Hac Vice  Attorneys for Judgment Creditors
 
Case 1:06-cv-22128-JLK Document 408 Entered on FLSD Docket 11/21/2013 Page 3 of 6

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