Filing # 91884266 E-Filed 06/28/2019 06:06:57 PM. IN THE CIRCUIT COURT OF THE 11 CIAL CIRCUIT, IN AND FOR MIAMI DADE COUNTY, FLORIDA. CIVIL DIVISION CASE NO. EMPORIO K, LLC, a Florida limited liability company, GM MANAGEMENT, INC., a Florida corporation, FUNRAZE CONSULTING CORP., a Florida corporation, DC ONE USA, LLC, a Florida limited liability company, HATG HOLDINGS REAL ESTATE, LLC, a Florida limited liability company, PRY UNIT 3805, LLC, a Florida limited liability company, DORALCOL, LLC, a Florida limited liability company, MD HABITAT GROUP CORP., a Florida cotporation, KARIN BERGER, an individual, RENATO D. REIS, an individual, DAL NTAINE, an individual, and PAUL MOYER. an individual. Plaintiffs, v, RELATED GENERAL OF FLORIDA, LLC_ Florida limited liability company d/b/a THE RELATED GROUP, RELATED FLORIDA LLC, a Florida limited liability company dib/a THE RELATED GROUP and PRH PARAISO FOUR, LLC, a Florida limited liability ‘company, Defendants, COMPLAL Plaintiifs, EMPORIO K, LLC, a Florida limited liability company, GM MANAGE T, INC., a Florida corporation, FUNRAZE CONSULTING CORP,, a Florida corporation, DC ONE USA, LLC, 2 Florida limited liability company, HAIG HOLDINGS REAL ESTATE, LLC, a Florida limited liability company, PBV UNIT 3805, LLC, a Florida 1 ve, KAP, SE KATEDN LEE,limited liability company, DORALCOL, LLC, a Florida limited liability company, MD HABITAT GROUP CORP., a Florida corporation, KARIN BERGER. an individual, RENATO D. REIS, an individual, DAIRE FONTAINE, an individual, and PAUL MOYER, an individual (collectively the “Plaintiffs”), sue Defendants, RELATED GENERAL OF FLORIDA, LLC, a Florida limited liability company dib/a THE RELATED GROUP, RELATED FLORIDA LLC, a Florida limited liability company d/b/a THE RI ELATED GROUP (collectively “The Related Group”), and PRH PARAISO FOUR, LLC, a Florida limited liability company (‘PRH Paraiso”), (collectively the “Defendants”, and allege as follows: NATURE OF THE CASE 1 This is an action by Plaintiffs against Defendants arising from Defendants’ breaches relating to sales of units in the Paraiso Bayviews project. Plaintiffs bring claims for (a) damages under Florida’s Deceptive and Unfair Trade Practices Act (Count 1), (b) breach of the Plaintifls’ unit purchase contracts (Count II); (c) damages under Florida’s Condominium Act (Count H1),(4) Fraudulent inducement (Count IV); and (e) Civil Conspiracy (Count V). Defendants provided Plaintiffs with false and misleading promotional advertisement material promoting the sale of a “I bedroom + den” units at the Paraiso Bayviews, a condominium building located at $01 NE 31 Street, Miami, Florida 33137 (“Paraiso 3. The Plaintiffs relied upon Defendants’ false and misleading promotional advertisement materials and entered into their respective Purchase Agreements with PRH Paraiso to purchase a1 bedroom + den” condominium unit, 2 oe, Kay, SERA, RATED BLEEP4, Defendant PRH Paraiso contracted with each Plaintiff to sell and deliver to them a “1 bedroom + den” condominium unit. 5. Defendant PRH Paraiso failed to sell or deliver a “1 bedroom + den” condominium unit to any of the Plaintiffs, 6. Instead, Defendant PRH Paraiso materially breached its purchase agreement with each of the Plaintiffs by a) failing to deliver the contracted for residential unit with a den; b) by delivering a unit with substantially tess interior square footage than the Plaintiffs had contracted for; and c) by failing to notify each Plaintiff that it had materially altered or modified the units prior to Plaintiffs’ closing of their respective condominium unit, The remaining Defendants committed tortious acts in cones nn with Plaintiffs” purchases as alleged below PARTIES, JURISDICTION, AND NUE 7. This is an action for damages in an amount greater than Fifteen Thousand Dollars ($15,000.00), exclusive of interest, costs, and attorneys’ fees 8, Plaintiff, Emporio K, LLC, is a Florida limited liability company with its principal place of business in Miami-Dade County, Florida 9. Plaintiff, GM Management, Inc., is a Florida company with its principal place of business in Miami-Dade County, Florida. 10, Plaintiff, Funraze Consulting Corp., is a Florida corporation with its principal place of business in Miami-Dade County, Florida. 11, Plaintiff, DC One USA, LLC, is a Florida limited liability company with its principal place of business in Miami-Dade County, Florida. 12, Plaintiff, Haig Holdings Real Estate, LLC, is a Florida limited liability company with its principal place of business in Broward County, Florida 3 oe, Kay, SERA, RATED BLEEP