UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO. 06-22128-CV-K1NG/M CALlLEY
( . Q.-. ' FILED by D.C.
0 C ..- -; () 7 2 217
STEVLN M. L.-Aq#MORQ
CLERK t; s Elis'r cT.
s.o.of FC!
-
â.- MIAMI ALBERTO JUSTO RODRIGUEZ LICEA,
FERNANDO ALONSO HERNANDEZ, AND
LUIS ALBERTO CASANOVA TOLEDO,
Plaintiffs/ludgment Creditors,
CURK AO DRYDOCK COMPANY, lNC., A/K/A
CURK AOSE DOKMAATSCHAPPIJ NV, A/K/A
CDM NV ,
Defendant/ludgment Ilebtor.
PLM NTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARNISHM ENT
COM ES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fem ando
Alonso Hernandez, and Luis Alberto Casanova Toledo (ttplaintiffs'), by and thzough their
undersigned counsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 ef. seq.
and move this Court for issuance of a post-judgment writ of gnrnishment conceming the assets of
Defendant/ludgment Debtor Clzracao Drydock Company, lnc., to be served Church of
Scientology Flag Ship Service Organization, Inc.,and as grounds therefore state:
On October 31 , 2008, this Court entered a final Judgment in favor of Plaintiffs
and against Defendant/ludgment Debtor for $80 million plus post-judgment interest at the rate
set by 28 U.S.C. j 1961. DE 1 12.
2. On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00
and interest according to 28 IJ.S.C. j 1961 since October 31, 2008. DE 1 19.
The Final Judgment was not appealed and the time for appeal has passed.
Judgment Debtor has paid none of the judgment; the entire judgment remains
unsatisfied.
Case 1:06-cv-22128-JLK Document 361 Entered on FLSD Docket 10/07/2013 Page 1 of 2
5. As Judgment Debtor is a foreign entity whose assets are primarily located outside
of the United States, Judgment Creditors have been tmable to levy on Judgment Debtor's assets
.
Judgment Debtor is a drydock facility located in Ctlracao.
7. Gam ishee, Charch of Scientology Flag Ship Service Organization, Inc
.,
or its
agent or alter ego is a manager of ships that currently has a ship in repair at the Judgment
Debtor's drydock facility in Cmacao.As such, it owes Judgment Debtor for ship repaixs.
8. Judgment Creditors suggest that garnishee, Chtzrch of Scientology Flag Ship
Service Organization, Inc., is in possession of property belonging to Judgment Debtor, Curacao
Drydock Com pany, lnc.
9. Judgment Creditors seek a writ of gnrnishment pursuant to Fla.Stat. j 77.03.
W H EREFORE, Judëkm ent Creditors request the issuance of a writ of gam isbm ent
against Curacao Drydock Colnpany, Inc.'s property held by garnishee
, Church of Scientology
Flag Ship Service Organization, Inc., in the form attached hereto and to grant any further relief
as is just, fair and equitable.
Dated: October 7, 2013 Respectfully submitted
,
Do CAMPO & THORNTON, P.A.
M iam i Tower
100 Southeast Second Street
Suite 2700
M iam i,FL 33131
Phone: 305-3 -6600
ké-rçj .
Fax: 30 -
<
jjjj. .-' y. .
f Thornton
Florida Bar No. 004820
jt@dandtlamcom
Attorneysfor Plaintp /ludgment
Creditors
Case 1:06-cv-22128-JLK Document 361 Entered on FLSD Docket 10/07/2013 Page 2 of 2
.
a c,oj..e g'+. u ,.j . .
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PAID l P(' '-
e r'- Sljw f
,
/,é//
Steven Mq Lqrlmîluilf.k..k jgxjvso STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO. 06-22128-CV-KlNG/M CAL1LEY
ALBERTO JUSTO RODRIGUEZ LICEA,
FERNANDO ALONSO HETW ANDEZ, AND
LUIS ALBERTO CASANOVA TOLEDO,
Plaintiffs/ludgment Creditors,
VS.
CURK AO DRYDOCK COMPANY, lNC., A/K/A
CURK AOSE DOKMAATSCHAPPIJ NV,A/K/A
CD> V,
Defendant/ludgm ent Debtor.
W RIT OF GARNISHM ENT
THE STATE OF FLORIDA:
To All and Singular the Sheriffs of the State
And the U.S. Marshal's Service:
YOU ARE COM M ANDED to stlmmon the garnishee, Chmch of Scientology Flag Ship
Service Organization, lnc., by serving it and/or its registered agent
,
W illiam B. M illiken, at its
registered agent address:212 1 Ponce de Leon Boulevard, Suite 730, M iami
,
FL 33134, to serve
an answer to this writ on JOEN THORNTON, ESQ., Judgment Creditors' attorney, whose
addresses is M iami Tower 100 Southeast Second Skeet Suite 2700 M iami
,
FL 33131, within 20
days after service on the gnrnishee, exclusive of the day of servict, and to file the original with
this court either before service on the attorney or immediately thereafter stating whether the
garnishee is indebted to the defendant, Curacao Drydock Company, Inc
. or its aliases named
above, at the time of service (hf tbe answer OR was indebted at the time of service of the writ
,
OR at any time between such times, AND in what sum and what tangible and intangible
Case 1:06-cv-22128-JLK Document 362 Entered on FLSD Docket 10/07/2013 Page 1 of 2
personal property of the defendant the gnrnishee has in his possession or control at the time of
the answer, OR had at the tirae of service of this writ
,
OR at any tim e between such tim es, AND
whether the garnishee knows of any other person indebted to the defendant
,O R who may be in
possession or control of any of the property of the defendant
. The nmount set in plaintiffs'
motion is $80,000,000.00 plus interest accnzing from October 31
, 2008 at the rate set by 28
U.S.C. j 1961.
W ITNESS STEVEN M . LARIM O RE, as Clerk of the Court
, and the deal of said Court, at
16 t the U
.S. District Courthouse at M inm i, Florida
,
this 1 day of 6c obk f- , 2013.
STEVEN M .LARIM ORE
Clerk of the Court
'-
,
4 tj1 y . f- ,
By:
s Deputy lerk
Case 1:06-cv-22128-JLK Document 362 Entered on FLSD Docket 10/07/2013 Page 2 of 2
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CA SE NO. 06-22128-CV-KlNG/M CAL1LEY
ALBERTO JU STO RODRIGUEZ LICEA ,
FERNANDO ALON SO HERNANDEZ,AND
LUIS A LBERTO CASANOA/A TOLEDO,
Plaintiffs/ludgment Creditors,
FILED by D.C.
021 2 7 2213
STEVEN . M LARIMORE
CLERK tl s Dls-r cT.
s.o.of /LX - Mlkul VS .
CURACAO DRYDOCK COMPANY, INC., A/K/A
CURACAOSE DOKMAATSCHAPPIJ NV, A/K/A
CDM NV,
Defendant/ludgm ent Debtor.
PLAINTIFFS/JUDG M ENT CREDITORS' M O TION FOR A W RIT OF GARNISHM ENT
COM ES NOW Plaintiffs/ludgm ent Creditors, Albel'to Justo Rodriguez Licea, Fernando
Alonso Hernandez, and Luis Alberto Casanova Toledo (tûplaintiffs''), by and through their
undersigned counsel, pursuartt to Fed. R.Civ.P. 62, 64, and 69 and Fla. Stat.jj 77.01 et..$t?t?.
and move this Court for issuance of a post-judgment writ of garnishment concerning the assets of
Defendant/ludgm ent Debtor Curacao Drydock Com pany, lnc., to be served Church of
Scientology Flag Ship Service Organization, lnc., and as grounds therefore state:
On October 3 1, 2008, this Court entered a final Judgm ent in favor of Plaintiffs
and against Defendant/ludgment Debtor for $80 million plus post-judgment interest at the rate
set by 28 U.S.C.j 1961 .DE 1 12.
On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00
and interest according to 28 U.S.C.j 1961 since October 31, 2008. DE 1 19.
The Final Judgm ent w as not appealed and the tim e for appeal has passed.
Judgment Debtor has paid none of the judgment',the entire judgment remains
unsatisfied.
Case 1:06-cv-22128-JLK Document 367 Entered on FLSD Docket 10/07/2013 Page 1 of 2
As Judgment Debtor is a foreign entity whose assets are primarily located outside
of the United States,Judgment Creditors have been unable to levy on Judgm ent Debtor's assets
.
Judgment Debtor is a drydock facility loeated in Curacao
.
Garnishee, Church of Scientology Flag Ship Serviee Organization
, 1nc., or its
agent or alter ego is a manager of ships that currently has a ship in repair at the Judgment
Debtor's drydock facility in Cwuracao.As such
,
it owes Judgment Debtor for ship repairs.
Judgment Creditors suggest that garnishee, Chureh of Seientology Flag Ship
Service Organization,lnc.,is in possession of property belonging to Judgment Debtor
, Curacao
Drydock Company, lne.
Judgment Creditors seek a writ of garnishment pursuant to Fla.
Stat.j 77.03.
W HEREFORE, Judgment Creditors request the issuance of a writ of garnishment
against Curacao Drydoek Company,Ine.'s property held by garnishee
,
Chureh of Seientology
Flag Ship Service Organization, lnc., in the form attached hereto and to grant any further relief
as is just, fair and equitable.
Dated:October l , 2013 Respectfully subm itted
,
Do CAM PO & THORNTON, P.A.
M iam i Tower
100 Southeast Second Street
Suite 2700
M iam i, FL 33131
Phone: 305-358-6600
Fax:305-358-6601
By: - a
ohn Thornton
Florida Bar No. 004820
jt@dandtlaw.com
Attorneysfor Plaintffv/ludgment
Creditors
Case 1:06-cv-22128-JLK Document 367 Entered on FLSD Docket 10/07/2013 Page 2 of 2
%
FEE
l loo.x pxo
.
Iyxlvso svvss Ials-rlucv couR'r '''/f FoR I'I-
IE sou-rldcRx ols-rluc'r oy FLORIDA e c ) V*
*- Clerk CASE NO
. 06-22128-CV-KlNG/M CALlLEY Steven M.tafi r ,
ALBERTO JUSTO RODRIGUEZ LICEA ,
FERN ANDO ALON SO HEFLNANDEZ,AND
LUIS ALBERTO CASANOAJA 'FOLEDO,
Plaintiffs/ludgm ent Creditors,
FILED by & D.c.
02T 2 ? 2213
STEVEN . M LARIMORE
CLERK U s Dls-r cT
.
s.o. of /LZ.- MIXMI CURACAO DRYDOCK COMPANY
,
lNC., A/K/A
CURACAOSE DOKMAATSCHAPPIJ NV, A/K/A
CDM NV,
Defendant/ludgm ent Debtor.
W RIT OF GARNISH M ENT
THE STATE OF FLORIDA :
To All and Singular the Sheriffs of the State
And the U.S.M arshal's Service:
YOU ARE COM M ANDED to sum mon the garnishee,Church of Scientology Flag
Service Organization,Inc., by serving it and/or its registered agent, Robert V.Potter, at its
registered agent address:91 1 Chestnut Street, Clearwater,FL 33756, to serve an answer to this
writ on JOHN THORNTON, ESQ., Judgment Creditors' attorney, whose addresses is Miami
Tower l00 Southeast Second Street Suite 2700 M iam i, FL 33 131,within 20 days afler service on
the garnishee, exclusive of the day of service, and to file the original with this court either before
service on the attorney or imrcediately thereafter stating whether the garnishee is indebted to the
defendant, Curacao Drydock Company, lnc.or its aliases nam ed above, at the time of service of
the answer OR was indebted at the tim e of service of the writ,OR at any tim e between such
times,AND in what sum and what tangible and intangible personal property of the defendant the
Case 1:06-cv-22128-JLK Document 368 Entered on FLSD Docket 10/07/2013 Page 1 of 2
garnishee has in his possession or control at the tim e of the answer, OR had at the tim e of service
of this writ, O R at any tim e between such times,AND whether the garnishee knows of any other
person indebted to the defendant, OR who m ay be in possession or control of any of the property
of the defendant. The amount set in plaintiffs' motion is $80,000,000.00 plus interest accruing
from October 31, 2008 at the rate set by 28 U.S.C.j l 96l .
W ITNESS STEVEN M .LARIM O RE, as Clerk of the Court, and the deal of said Court, at
<
the U.S.District Courthouse at Miami, Florida,this W day of C X , 2013.
STEVEN M . LARIM ORE
Clerk of the Court
By: w, 1
As Deputy Clerk
Case 1:06-cv-22128-JLK Document 368 Entered on FLSD Docket 10/07/2013 Page 2 of 2
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO. 06-22128-CV-K1NG/MCALlLEY
'j (
o c t FILED by
. .
:
0CT 2 2 2213
STEVEN
. M LARIMORE C
LERK t?
. s Dis'r cT
.
s o of F'LA
s MIXMI
ALBERTO JUSTO RODRIGUEZ LICEA,
FERNANDO ALONSO HERNANDEZ, AND
LUIS ALBERTO CASANOVA TOLEDOS
Plaintiffs/ludgment Creditors,
VS.
CURK AO DRYDOCK COMPANY, 1NC., A/K/A
CURK AOSE DOKMAATSCHAPPIJ NV, A/K/A
CDM NV,
Defendant/ludgment Debtor.
PLAINTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARM SHM ENT
COMES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fernando
Alonso Hernandez, and Luis Alberto Casanova Toledo Cûplaintiffs''), by and through their
undersir ed cotmsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 e/.seq.
and move this Court for issuance of a post-judgment writ of garnishment concerning the assets of
Defendant/ludgment Debtor Cm acao Drydock Company, Ine
., to be served on Chtlrch of
Scientology of Florida, lnc., and as grounds therefore state:
1. On October 31, 2008, this Court entered a final Judgment in favor of Plaintiffs
and against Defendant/ludgment Debtor for $80 million plus post-judgment interest at the rate
set by 28 U.S.C.j 1961.DE 112.
On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00
and interest according to 28 U.S.C. j 1961 since October 31, 2008.DE 1 19.
'Ihe Final Judgm ent was not appealed and the time for appeal has passed.
4. Judgment Debtor has paid none of the judgment; the entire judgment remains
unsatisfied.
Case 1:06-cv-22128-JLK Document 378 Entered on FLSD Docket 10/23/2013 Page 1 of 2
5. As Judgment Debtor is a foreign entity whose assets are primarily located outside
of the United States, Judgment Creditors have been unable to levy on Judgment Debtor's assets.
Judgment Debtor is a drydock facility located in Curacao.
Garnishee, The Chtlrch of Scientology International, lnc., or its agent or alter ego 7.
is an owner of a ship that is currently in repair at the Judgment Debtor's drydock facility in
Curacao.As such, it owes Judgment Debtor for ship repairs.
8. Judgment Creditors suggest that gm ishee, The Church of Scientology
International, Inc., is in possession of moperty belonging to Judgment Debtor, Cm acao Drydock
Company, lnc.
9. Judgment Creditors seek a writ of gnrnishment pursllnnt to Fla. Stat. j 77.03.
M EREFOM , Judgment Creditors request the issuance of a writ of garnishment
against Curacao Drydock Company, lnc.'s moperty held by garnishee, The Church of
Scientology Intem ational, Inc., in the form attached hereto and to grant any further relief as is
just, fair and equitable.
Dated:October 21, 2013 Respectfully subm itted,
oo CAMPO & THORNTON, P.A.
M iam i Tower
100 Southeast Second Street
Suite 2700
M inmi, 3) 1
Ph e: 305-3 -6600
z
xax ' 5 60 1
B .V
Jo hornt
'da Bar No. 04820
jt@dandtlamcom
Attorneysfor Plaintp /ludgment
Creditors
Case 1:06-cv-22128-JLK Document 378 Entered on FLSD Docket 10/23/2013 Page 2 of 2
*
A..
.
.
*
F I t l N G F f :
PAID ùk . 1 uxjvso su w s olsrrm c'r COURT
jtvoo y. $ p F R THE SOUTHERN DISTRICT OF FLORIDA '
steven M..uao Fre, clerk p ASE NO.06-22128-CV-KlNG/MCALILEY
ALBERTO JUSTO RODM GUEZ LICEA
,
FERNANDO ALONSO HERNANDEZ
,
AND
LUIS ALBERTO CASANOVA TOLEDO
,
s, FILED by b' D
.C.
1
02T 2 2 2013
STEVEN . M LARIMORE
CLERK U . s DlsT. c'c
s D of /LA - MIAMI
Plaintifs/ludgment Creditors,
VS.
CURK AO DRYDOCK COMPANY, lNC., A/K/A
CURK AOSE DOKM AATSCHAPPIJ NV, A/K/A
CDM NV,
Defendant/ludgment Debtor.
W RIT OF GARNISHM ENT
TlfE STATE OF FLORJDA:
To A1l and Singular the Sheriffs of the State
And the U.S.M arshal's Service:
YOU ARE COM M ANDED to summon the garnishee
, Church of Scientology of
Florida, lnc., by serving it and/or its registered agent
, Craig Ftlrlin, at its registered agent address:
120 GIM LDA AVEN UE, COM L GABLES
,
FL 33134, to serve an answer to this writ on
JOHN THORNTON, ESQ., Judgment Creditors' attomey, whose addresses is Miami Tower 100
Southeast Second Street Suite 2700 M iami, FL 33131
, within 20 days after service on the
garnishee, exclusive of the day of services and to file the original with this court either before
service on the attorney or immediately thereo er stating whether the garnishee is indebted to the
defendant, Cmacao Drydock Company, Inc. or its aliases named above
,
at the tim e of service of
the answer OR was indebted at the time of service of the writ
, OR at any time between such
times, AND in what sttm and what tangible and intangible personal property of the defendant the
Case 1:06-cv-22128-JLK Document 379 Entered on FLSD Docket 10/23/2013 Page 1 of 2
#
gnrnishee has in his possession or control at the time of the answer
, OR had at the time of service
of this writ, OR at any time between such times, AND whether the gam ishee knows of any other
person indebted to the defendant, OR who may be in possession or control of any of the property
of the defendnnt. The nmount set in plaintiffs' motion is $80,000,000.00 plus interest accruing
9om October 31, 2008 at the rate set by 28 U.S.C.j 1961.
W ITNESS STEVEN M . LARIM ORE, as Clerk of the Court
,
and the deal of said Court, at
the U.S. District Courthouse at Miami, Florida, this 'Zoday of btkyl
.f , 2013.
STEVEN M .LARIM ORE
Clerk of the Court
By:
As De ty Clerk
Case 1:06-cv-22128-JLK Document 379 Entered on FLSD Docket 10/23/2013 Page 2 of 2
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO. 06-22128-CV-K1N G/M CAL1LEY
FILED by t D
.C.
1
0CT 2 2013
STEVEN . M LARIMORE
CLERK t) s oisT cT
.
s o of ;-t.A sysrvll ALBERTO AJSTO RODRIGUEZ LICEA,
FERNANDO ALONSO HERNANDEA AND
LUIS ALBERTO CASAN OVA TOLEDO,
Plaintiffs/ludgment Creditors,
VS.
CURK AO DRYDOCK COMPANY, INC., A/K/A
CURACAOSE DOKMM TSCHAPPIJ NV, AJK/A
CDM NV,
Defendant/ludgment Debtor.
PLM NTIFFS/JUDGM ENT CREDITORS' M OTION FOR A W RIT OF GARNISHM ENT
COMES NOW Plaintiffs/ludgment Creditors, Alberto Justo Rodriguez Licea, Fernando
Alonso Hernandez, and Luis Alberto Casanova Toledo Csplaintiffs''), by and tlzrough their
undersigned counsel, ptlrsuant to Fed. R. Civ. P. 62, 64, and 69 and Fla. Stat. jj 77.01 c/.seq.
and move this Court for issuance of a post-judgment writ of garnishment concerning the assets of
Defendant/ludgment Debtor Curacao Drydock Company, Inc., to be served on The Church of
Scientology lntem ational, Inc., and as grounds therefore state:
1. On October 31, 2008, this Court entered a final Judgment in favor of Plaintiffs
and against Defendant/ludgment Debtor for $80 million plus post-judgment interest at the rate
set by 28 U.S.C.j 1961.DE 112.
On October 21, 2009, the Clerk issued a W rit of Execution for $80,000,000.00
and interest according to 28 U.S.C. j 1961 since October 31, 2008. DE 1 19.
3. The Final Judgment was not appealed and the tim e for appeal has passed.
4. Judgment Debtor has paid none of the judgment; the entire judgment remains
tmsatisfied.
Case 1:06-cv-22128-JLK Document 380 Entered on FLSD Docket 10/23/2013 Page 1 of 2
5. As Judgment Debtor is a foreign entity whose assets are primarily located outside
of the United States, Judgment Creditors have been unable to levy on Judgment Debtor's assets.
Judgment Debtor is a drydock facility located in Curacao.
Garnishee, The Chttrch of Scientology lnternational, lnc., or its agent or alter ego 7.
is an owner of a ship that is currently in repair at the Judgment Debtor's drydock facility in
Cm acao.A s such,it owes Judgm ent Debtor for ship repairs.
8. Judgment Creditors suggest that gnrnishee, The Chtlrch of Scientology
Intem ational, Inc., is in possession of property belonging to Judgment Debtor, Curacao Drydock
Company, Inc.
9.
W HEREFORE, Judgment Creditors request the issuance of a writ of gnrnishment
against Curacao Drydock Company, Inc.'s property held by gam ishee, The Church of
Judgment Creditors seek a writ of gnrnishment pursdlnnt to Fla.Stat. j 77.03.
Scientology lntemational, lnc., in the form attached hereto and to grant any further relief as is
just, fair and equitable.
Dated: October 21, 2013 Respectfully submitted,
Do CAMPO & THORNTON, P.A.
M iami Tower
100 Southeast Second Street
Suite 27
M i i, FL 33 31
.
one:305-3 8-6600
. 0 - 66
z' ,
.
Jo orntoc
Fl da BarNo. 004820
jt@dandtlamcom
Attorneysfor Plaintp /ludgment
Creditors
Case 1:06-cv-22128-JLK Document 380 Entered on FLSD Docket 10/23/2013 Page 2 of 2
q
' 7
I t l N G F f S F
pAIn . w UNITED STATES Dlsrrltlc'r couR'r
R THE SOUTHERN DISTRICT OF FLORIDA t 9 lppp c4b 1'/
cAsE No.06-22128-cv-Km G/M cALILEY P*
Steveg Mi. Lariozre,Clerq 1
lil6' RTO JUSTO DRJGUEZ LICEA,
FERNANDO ALONSO HERNANDEA AND
LUISALBERTO CASANOVA TOLEDO,
FILED by D.C.
02T 2 2 2 13
STEVEN M LARIMORE
CLERK . tJ s Dis'r c'r
,
s D of F'LA - MlArç1l
Plaintiffs/ludgment Creditors,
VS.
CURACAO DRYDOCK COMPANY,m C.,AXUA
CURACAOSE DOKMAATSCHAPPIJNV,ASUA
CDMNV,
Defendant/ludgment Debtor.
/
W RIT OF GARNISHM ENT
THE STATE OF FLORIDA:
To A1l and Singular the Sheriffs of the Sote
And the U.S. Marshal's Service:
YOU ARE COM M ANDED to summon the ga ishee, The Church of Scientology
lntemational, lnc., by serving it at its address: 120 GIRALDA AVENUE, CORAL GABLES
, FL
33134, to serve an answer to this writ on JOHN THORNTON, ESQ., Judgment Creditors'
attomey, whose addresses is Miami Tower 100 Southemst Second Street Suite 2700 M iami
,
FL
33 131, within 20 days after service on the garnishee, exdusive of the day of service
, and to tlle
the original with this court either before service on the attorney or immediately thereafter stating
whether the garnishee is indebted to the defendant, Curacao Drydock Company
, lnc. or its
aliases named above, at the time of service of the answer OR wms indebted at the time of service
of the writ, OR at any time between such times, AND in what stlm and what tangible and
intnngible personal property of the defendant the garnishee has in his possession or control at the
Case 1:06-cv-22128-JLK Document 381 Entered on FLSD Docket 10/23/2013 Page 1 of 2
#'
time of the answer, OR had at the time of service of this writ
, OR at any time between such
times, AND whether the garnishee knows of any other person indebted to the defendant
,
OR
who may be in possession or control of any of the property of the defendant
. The amotmt set in
plaintifrs' motion is $80,000,000.00 plus interest accruing f'rom October 31
,
2008 at the rate set
by 28 U.S.C.j 1961.
W ITNESS STEVEN M . LARIM ORE, as Clerk of the Court
, and the deal of said Court, at
the U.S. District Courthouse at Miami, Floridw this l2. day of Y.'.S $,?.y'-', 2013.
STEVEN M .LARIM O RE
Clerk of the Court
By:
As De ty Clerk
Case 1:06-cv-22128-JLK Document 381 Entered on FLSD Docket 10/23/2013 Page 2 of 2

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.
/

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the Plaintiffs/Judgment Creditors’ Motion for Writ of
Garnishment [DE 378] and the Writ of Garnishment [DE 379] was mailed to: Curacao Drydock
Company, Inc. a/k/a Curacaose Dokmaatschappij, NV a/k/a CDMNV Dokweg 1, Koningsplein, P.O.
Box 3012, Curacao, Netherland Antilles.

Respectfully Submitted,

GROSSMAN ROTH, P.A.
2525 Ponce de Leon Blvd., Suite 1150
Coral Gables, Florida 33134
(305) 442-8666
(305) 285-1668

By: s/ Seth Miles
Seth Miles, Esq.
Florida Bar No. 385530
sem@grossmanroth.com
Case 1:06-cv-22128-JLK Document 387 Entered on FLSD Docket 10/27/2013 Page 1 of 1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

ALBERTO JUSTO RODRIGUEZ LICEA, :
FERNANDO ALONZO HERNANDEZ, and :
LUIS ALBERTO CASANOVA TOLEDO, :
:
Plaintiffs, : Case No. 06-22128-CIV-
: KING/MCALILEY
v. :
:
CURACAO DRYDOCK COMPANY, INC. a/k/a :
CURACAOSE DOKMAATSCHAPPIJ NV a/k/a :
CDMNV, :
:
Defendants, :
---------------------------------------------------------------X
ALBERTO JUSTO RODRIGUEZ LICEA, :
FERNANDO ALONZO HERNANDEZ, and : Case No. 11-22568-CIV-
LUIS ALBERTO CASANOVA TOLEDO, : KING/MCALILEY
:
Plaintiffs, :
v. :
:
ISLAND TERRITORY OF CURACAO, :
THE GOVERNMENT OF THE NETHERLANDS :
ANTILLES and THE KINGDOM OF THE :
NETHERLANDS, :
:
:
Defendants. :
----------------------------------------------------------------X

PLAINTIFFS’ NOTICE OF FILING VERIFIED RETURN OF SERVICE

Plaintiffs/Judgment Creditors, Alberto Justo Rodriguez Licea, Fernando Alonzo
Hernandez and Luis Alberto Casanova Toledo (collectively, “Plaintiffs”), by and through their
undersigned counsel, give notice of filing the verified Return of Service reflecting service of
process on Church of Scientology Flag Ship Service Organization, Inc., perfected on October 7,
2013. The Return is attached as Exhibit A.
Dated: July 7, 2014. GROSSMAN ROTH, P.A.

By: S/ Seth Miles
Seth Miles, Esq.

Case 1:06-cv-22128-JLK Document 462 Entered on FLSD Docket 07/07/2014 Page 1 of 4
2
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 Plaintiffs/Judgment Creditors


Case 1:06-cv-22128-JLK Document 462 Entered on FLSD Docket 07/07/2014 Page 2 of 4
3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served
electronically on July 7, 2014 upon all parties as noted in the service list below.
GROSSMAN ROTH, P.A.

By: S/ Seth Miles
Seth Miles, 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 Plaintiffs/Judgment Creditors


Case 1:06-cv-22128-JLK Document 462 Entered on FLSD Docket 07/07/2014 Page 3 of 4
4
SERVICE LIST

Guy W. Harrison, Esq.
ETCHEVERRY HARRISON LLP
150 South Pine Island Road, Suite 105
Ft. Lauderdale, FL 33324


Case 1:06-cv-22128-JLK Document 462 Entered on FLSD Docket 07/07/2014 Page 4 of 4

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