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.
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.
Amended Answer at ¶¶2-3.
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