IN THE CIRCUIT COURT OF THE 11rn

JUDICIAL CIRCUIT IN AND FOR

MIAMI-DADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

3 6 6 CA 2 3
Case No: 2 0-2 4
TIMOTHY MICHAEL KINGS,
Plaintiffs, f\\,�J c�ci\
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AARON ROLLINS, fi4RVIY .RUVIN
Defendants. WM. C'IRC!Jrr & coumv �JJRTS
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COMPLAINT FOR DAMAGES

The Plaintiff, TIMOTHY MICHAEL KINGS ("Plaintiff'), proceeding pro se, hereby

brings this Complaint and sues the Defendant, AARON ROLLINS ("Defendant"), for damages

and equitable relief, and alleges as follows:

GENERAL ALLEGATIONS

1. This is an action for damages that exceed Thirty Thousand and 00/100 Dollars

($30,000.00), exclusive of costs, interest and attorneys' fees, and for equitable relief.

2. Venue is proper in Miami-Dade County, Florida because the events giving rise

to this Complaint occurred in Miami-Dade County.

3. Plaintiff is a sui juris individual over the age of eighteen (18) who is a resident

of the St. John's County, living at 141 Pelican Road, St. Augustine, Florida.

4. Defendant is a suijuris individual over the age of eighteen (18) who is a resident

of Miami-Dade County, living at 503 E. Dilido Drive, Miami Beach, Florida.

5. All potential conditions precedent to filing this action have been met by Plaintiff

or have otherwise been waived by the Defendants.

6. On April 2, 2019, Defendant personally called Plaintiff to request that Plaintiff

meet Defendant at Defendant's residence at 503 E. Dilido Drive, Miami Beach, Florida, to

discuss Defendant's desire to employ Plaintiff to go to China to take over management of the
' construction of a $8,670,000 yacht that had been partially completed by the Shipyard in China.

Defendant was referred to Plaintiff by Defendant's Attorney who practices within the maritime

community and knew of Plaintiffs stellar reputation. Plaintiff came to Defendant's home on

April 3, 2020. At the meeting, Defendant maintained to Plaintiff that the manager he had in

China at the time was failing to properly represent Defendant's financial interests and that the

build project was out of control. Defendant noted to Plaintiff that he had been referred to the

Plaintiff based on Plaintiffs unique expertise in yacht construction and, in particular, his past

experience in China with management of high-end, large yacht construction projects in

"Communist" China.

7. During the meeting at Defendant's home, Plaintiff and Defendant entered into

an oral agreement, whereby Defendant would employ Plaintiff to move to China and assume

full management responsibilities of Defendant's yacht construction project.

8. The terms of the agreement between Plaintiff and Defendant were that

Defendant would pay Plaintiff Twelve Thousand Dollars ($12,000.00) each month for the

employment services rendered by Plaintiff and Four Thousand Five Hundred Dollars

(4,500.00) every other month to cover personal, housing and office expenses in China.

Additionally, the Defendant would be responsible for paying for Plaintiffs costs of travelling

to China initially and his final return at the end of the employment.

9. Plaintiff arrived in China on April 9, 2019 to commence his duties at the

Shipyard.

10. On May 28, 2019, Defendant sent the Shipyard an email formally advising the

Shipyard that Plaintiff had full authority to act on behalf of Defendant over all construction

issues and decisions, with full authority as his appointed proxy.

11. Throughout the period of April 2019 to April, 2020, Plaintiff resided in China

and worked each day at the Shipyard representing the Defendant's interests and conducting

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professional and effective hands on management duties related to the construction of the

Defendant's yacht.

12. Throughout the period of April 2019 through April 2020, the parties operated

in accordance with the terms of their agreement. All invoicing was paid on time. The

performance of Plaintiff's duties on behalf of the Defendant were of the highest professional

order. There were no complaints forthcoming from the Defendant about Plaintiffs services.

13. On May 8, 2020, Plaintiff emailed Defendant his standard "every other"

monthly invoice in the amount of Sixteen Thousand Five Hundred Dollars ($16,500.00), in

accordance with the terms of their agreement. Defendant copied Plaintiff on the same day with

his "approval to pay directive" that he sent to his money managers authorizing payment of the

invoice, also in accordance with their standard practice over the past year.

14. In spite of the Defendant's "approval to pay directive", Plaintiffs May 2020

invoice has never been paid and remains due.

15. On May 9, 2020, the Shipyard had a major fire and the Defendant's yacht

burned to its waterline. The yacht was declared a total loss. This disaster occurred just a few

months before the yacht was due to be completed and delivered to the Defendant.

16. The cause of the fire was determined to be faulty electrical wiring at the

Shipyard.

17. There are no allegations by any person or entity that Plaintiff had any

responsibility related to the fire.

18. During the month of May 2020, Plaintiff continued his professional effort to

represent the interests of the Defendant at the Shipyard, in terms of settling accounts with the

Shipyard and dealing with various insurance claims and investigatory efforts surrounding the

fire event.

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� 19. On May 28, 2020, Defendant sent the Shipyard an email, with a copy to

Plaintiff, wherein the Defendant notified �he Shipyard that the Defendant had terminated his

employment of Plaintiff as his 'yacht build manager'. This termination was wholly without

any cause associated with Plaintiffs duties to represent Defendant. The sole cause of the

termination was the fact that the yacht no longer existed as a result of the fire and therefore

Plaintiffs 'yacht build manager' duties were no longer needed.

20. As of May 28, 2020, China was still on complete lockdown in response to the

virus, thus resulting in it being nearly impossible for Plaintiff to legally leave China. During

the month of June 2020, Plaintiff was involved in trying to get out of China and return to the

United States. And, while he was unable to depart China, he continued daily attendance at the

Shipyard in response to demands that he help deal with insurance and investigatory efforts

surrounding the settlement of accounts and questions about the fire event. This representative

effort in June 2020 with respect to managing issues related to protecting Defendant's interest

after the catastrophic fire was directly to the benefit of the Plaintiff.

21. Throughout June 2020, the exit border into Hong Kong, which was the normal

way Westerners depart China, was still closed tight. Plaintiff was finally able to arrange a

difficult, physically demanding and expensive departure scenario involving first busing into

Shanghai, then moving on to South Korea, then to Vancouver BC and then to Los Angeles.

After this arduous trip out of China, Plaintiff finally arrived back in the United States on June

27, 2020.

22. Plaintiff has sent Defendant an invoice for the month of June 2020 in the

amount of Twelve Thousand Dollars ($12,000.00), which invoice has never been paid and

remains due.

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' 23. Defendant is responsible for covering Plaintiffs cost involved in his departure

from China and return to the United States, which costs total Three Thousand Nine Hundred

Thirty-two Dollars ($3,932.00)

COUNT I - BREACH OF CONTRACT

24. Plaintiff hereby realleges, restates, reasserts and incorporates the allegations

contained in paragraphs one (1) through twenty-three (23) as if set forth at length herein.

Defendant effectively abandoned Plaintiff in China and left Plaintiff to financially fend for

himself within the virus inflicted difficult environment in China, without cause and after

Plaintiff had provided Defendant extremely professional representation for over a year. The

Defendant continues to refuse to pay the within stated sums that are due to Plaintiff. The

Defendant's actions constitute a breach of the oral contract entered into with the Plaintiff, as

described above.

WHEREFORE, the Plaintiff hereby demands judgment for damages in the amount of

Thirty Two Thousand Four Hundred and Thirty-two Dollars ($32,432,00) against the

Defendant, together with post-judgment interest on any money awarded hereunder at the

statutory rate, and costs, as well as such further and additional relief as this Honorable Court

deems just, reasonable, necessary, and/or proper.

Under penalties of perjury, I declare that I have read the foregoing and the facts alleged

therein are true and correct to the best of my knowledge and belief.

Respectfully submitted on this::,' �ay of ----'"=-----'---·

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Plaintift, pro se
141 Pelican Road, St. Augustine, Florida
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