IN THE CIRCUIT COURT OF THE

6th JUDICIAL CIRCUIT IN AND FOR

PINELLAS COUNTY, FLORIDA

H. C. TRADING,
o
Plaintiff, ..,.- c:>
:D-t -x J
c:: (-)
c.;
VS.
I
\.D

lONA T:~n;~n~URKE d/b/a QUINTESSENTIAL CONCEPTS fii;;;:~' ~ i0:~

COMPLAIN/ Ff ~ ~
Plaintiff sues Defendant, JONATHAN C. BURKE d/b/a QUINTESSENTIAL CONCEPTS, and
alleges:

COUNT I - BAD CHECK

1. This is an action for damages greater than $15,000.00.

2. On May 6,2003, July 1,2003, August 14,2003, and August 21, 2003, Defendant,
JONA THAN C. BURKE d/b/a QUINTESSENTIAL CONCEPTS, executed written
orders for payment of $10,000.00, $10,000.00, $3,300.00, and $3,300.00 commonly
called checks, copy being attached hereto as Exhibit "A" payable to Plaintiff and
delivered to Plaintiff.

3. That Plaintiff did negotiate said check but same was dishonored due to insufficient
funds.

4. That Plaintiff did send the required statutory demand letter pursuant to Florida Statute
§68.065 to the Defendant. A copy of the letter and certified mail receipt are attached
hereto as Composite Exhibit "B".

5. Defendant owes Plaintiff $26,600.00 representing the base amount of the checks, plus
treble damages in the amount of $79,800.00 pursuant to Statute plus the Statutory
Service Charge.

6. All conditions precedent to the institution of this action have been performed or have
occurred.

7. Plaintiff is entitled to attorney's fees pursuant to Statute.

WHEREFORE, Plaintiff demands Judgment against JONATHAN C. BURKE d/b/a

QUINTESSENTIAL CONCEPTS, for $106,400.00 as damages, plus interest, costs, statutory service
charge and a reasonable attorney's fee.

COUNT II-GOODS SOLD AND DELIVERED

8. This is an action for damages more than $15,000.00.

 9. Defendant owes Plaintiff $70,355.50 as Damages that are due with interest since June
30,2003 for goods sold and delivered by Plaintiff to Defendants (see attached Composite
Exhibit "C").

10. These goods consist of various and diverse merchandise purchased from Plaintiff with a
value reflected above.

II. All conditions precedent have been performed or waived.

12. Plaintiff has agreed to pay its counsel a reasonable tee.

WHEREFORE, Plaintiff demands Judgment for $70,355.50 as Damages, plus interest, costs
and a reasonable attorney's fee.

Law Office of Julie E. Yates, P.A.

Attorney for Plaintiff
5944 Coral Ridge Drive, #208
Coral Springs, FL 33076
( / e I ho . (9 5 341-1295

"jJi.
!
,

EXHIBITJi-
 I ' '

.EXHIBIT A-
 .. .

....

EXHIBIT A
 SEfDER: COMPLETE THIS SECTION

• Complete items 1, 2, and 3. Also complete

item 4 If Restricted Delivery Is desired.
• Print your name and a~re.ss on the reverse
so that we cat! rEltum tFi~ card to you.
• Attach this card to the back of the mailpiece,
or on the fronl if space permits.
1. ArtIcle Addressed 10:
HYES, enler delivery address below: 0 No
~<) ~UflQ. c\b~
Ou\ (\~S~C\\ c.ct'~
\D \ ~ ~D-\\) 0'6 ~~/'\r:....'rJ'{V\l
D Express Mail

~~~b-. D Retum Receipt for Merchandise

DC.O.D.

2. Article Number
l (Transfer from service label)
7004 0750 0002 5042 6578
PS Form 3811, August 2001 Domestic Retum Receipt 2ACPRI·03·Z·0ge

UNITED STATES POSTAL SERVICE

r
~-'>\ 11111 .~I
/,., -' t, (,
-...... _
First-Class .MaiL
1>oslage"& Fees P.al
USPS
Permit No. G-10
'_..I, ,. ""

• Sender: Please print your n~~me.kddress, and ZIP+~_in. this box ~

'--~ ../ ' -

JUUE E. YATES, P.A.

5944 Coral Ridge Dr. /I 208
Coral Springs. Ronda 33076

iXl'\8\1~