Morris Jaime Godur Fraud Allegation Capital Max Rency Defgod Q7

WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for negligent misrepresentation against Defendants, DEFGOD LLC, JUSTIN
GODUR, and MORRIS JAIME GODUR awarding monetary damages of at least $1,500,000.00;
awarding costs, interest, attorney's fees pursuant to contractual agreements; and awarding all such
other and further relief as is just and proper.
COUNT VIE
EXPLOITATION OF AN ELDERLY PERSON
(Giblis v. DEFGOD, Justin Godur, Jaime Godur, and DeFrank)
111. Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 44
and incorporate same by reference as if fully set forth herein.
112. This is an action for exploitation of an elderly person against DEFGOD, Justin
Godur, Jaime Godur, and DeFrank, pursuant to Chapter 825, Florida Statutes.
113. DEFGOD's, Justin Godur’s, Jaime Godur's. and DeFrank’s actions— including,
but not limited to, fraudulent misrepresentations, obfuscation, concealment of assets, and
misappropriation of the Capital Contribution—were intentional and constitute the exploitation of
an elderly person under Chapter 825, Florida Statutes.
114. Section 825.103(1)(a). Florida Statutes defines “exploitation of an elderly person”
as follows:
Knowingly obtaining or using, or endeavoring to obtain or use, an elderly person’s
or disabled adult’s funds, assets, or property with the intent to temporarily or
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NEUMAN LAW, PA
permanently deprive the elderly person or disabled adult of the use, benefit, or
possession of the funds, assets, or property, or to benefit someone other than the
elderly person or disabled adult, by a person who:
Ll Stands in a position of trust and confidence with the elderly
person or disabled adult; or
2. Has a business relationship with the elderly person or
disabled adult
115. In violation of Section 825.103(1)(a), Florida Statutes, DEFGOD, Justin Godur,
Jaime Godur, and DeFrank, as an entity and persons in a business relationship with the elderly
Plaintiffs, knowingly obtained elderly persons’ funds with the intent to temporarily or permanently
deprive them of the use, benefit, and possession of the funds.
116. Section 825.103(2), Florida Statutes establishes a permissive presumption of
exploitation for inter vivos transfers of money or property exceeding $10,000.00 made by a person
aged sixty-five or older to a non-relative whom they have known for fewer than two years.
117, The Giblis are both over the age of sixty-five, transferred $1,500,000.00 to
DEFGOD, and have known Justin Godur, Jaime Godur, and DeFrank, who are non-relatives, for
less than two years.
118, As such, DEFGOD, Justin Godur, Jaime Godur, and DeFrank have violated Section
825.103, Florida Statutes, and the Giblis are entitled to damages thereunder.
WHEREFORE, Plaintiffs, SHOSHANA GIBLI and BENJAMIN GIBLI. respectfully
request judgment for exploitation of elderly persons against Defendants DEFGOD LLC, JUSTIN
GODUR. JAIME GODUR. and ANNAMARIE DEFRANK, awarding compensatory,