Case 1:06-cv-22128-JLK Document 390 Entered on FLSD Docket 10/28/2013 Page 1 of 3

UNITED STATES DISTRICT COURT 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. CURACAO DRYDOCK COMPANY, INC., A/K/A CURACAOSE DOKMAATSCHAPPIJ NV, A/K/A CDMNV, Defendant/Judgment Debtor. __________________________________________/ ANSWER OF GARNISHEE COMES NOW, Garnishee, Church of Scientology Flag Ship Service Organization, Inc., (FSSO), by and through undersigned counsel, and hereby files its Answer to Writ of Garnishment [DE 362], served by Plaintiffs/Judgment Creditors, Alberto Justo Rodriguez Licea, Fernando Alonso Hernandez, and Luis Alberto Casanova Toledo (Judgment Creditors), and states: 1. At the time of service of the Writ of Garnishment and at all times subsequent to

such service, up to and including the time of filing this Answer, Garnishee, FSSO, was not and is not indebted to Defendant/Judgment Debtor, Curacao Drydock Company, Inc., a/k/a Curacaose Dokmaatschappij NV, a/k/a CDMNV. 2. At the time of service of the Writ of Garnishment and at all times subsequent to

such service, up to and including the time of filing this Answer, Garnishee, FSSO, does not have in its possession or control any property, tangible or intangible, payable to or otherwise for the

Case 1:06-cv-22128-JLK Document 390 Entered on FLSD Docket 10/28/2013 Page 2 of 3

CASE NO.: 06-22128-CV-KING/MCALILEY Page 2 of 3

benefit of Defendant/Judgment Debtor, Curacao Drydock Company, Inc., a/k/a Curacaose Dokmaatschappij NV, a/k/a CDMNV, nor does it have any reason to expect that it will come into possession or control of any such property. 3. Garnishee, FSSO, operates aboard the Vessel SMV FREEWINDS and was

therefore made aware that the record owner of the SMV FREEWINDS, a Panamanian Corporation, was indebted to and has paid the entire amount they were obligated to pay Defendant/Judgment Debtor, Curacao Drydock Company, Inc., a/k/a Curacaose

Dokmaatschappij NV, a/k/a CDMNV, for recent repairs to the Vessel. Garnishee, FSSO, is not aware of any other person indebted to the Defendant/Judgment Debtor, or who may be in possession or control of any of the property of the Defendant/Judgment Debtor. 4. Having fully answered the Writ of Garnishment [DE 362] served upon Garnishee,

FSSO requests that it be allowed reasonable attorneys fees and costs as provided by applicable law resulting from its participation in this law suit and demands payment of any amounts deposited with the Court for the payment or part payment of Garnishees attorneys fees expended to respond to the writ. WHEREFORE Garnishee, Church of Scientology Flagship Service Organization, Inc., requests that this Honorable Court enter an Order vacating Plaintiffs/Judgment Creditors, Alberto Justo Rodriguez Licea, Fernando Alonso Hernandez, and Luis Alberto Casanova Toledos Writ of Garnishment [DE 362], awarding attorneys fees and costs as referenced above to Church of Scientology Flagship Service Organization, Inc., and for all other relief this Court deems just and proper. Dated: October 28, 2013 Respectfully Submitted, MOORE & COMPANY, P.A. Counsel for Garnishee

Case 1:06-cv-22128-JLK Document 390 Entered on FLSD Docket 10/28/2013 Page 3 of 3

CASE NO.: 06-22128-CV-KING/MCALILEY Page 3 of 3

355 Alhambra Circle, Suite 1100 Coral Gables, FL 33134 Telephone: (786) 221-0600 Facsimile: (786) 221-0601 Email: cnaughton@moore-and-co.com Email: michael@moore-and-co.com s/ Clay M. Naughton ______________________________ Clay M. Naughton FL Bar No. 029302 Michael T. Moore FL Bar No. 207845

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 28, 2013, this document was electronically filed with the Clerk of the Court using CM/ECF and is thereby being served this day on all counsel of record identified on the following service list: John Thornton, Esq. Do Campo & Thornton, P.A. Miami Tower 100 Southeast Second Street, Suite 2700 Miami, FL 33131 Telephone: (305) 358-6600 Facsimile: (305) 358-6601 Email: jt@dandtlaw.com Attorneys for Plaintiffs/Judgment Creditors

s/ Clay M. Naughton _______________________________ Clay M. Naughton

Case 1:06-cv-22128-JLK Document 391 Entered on FLSD Docket 10/29/2013 Page 1 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, v. CURAAO DRYDOCK COMPANY, INC., a/k/a CURAAOSE DOKMAATSCHAPPIJ NV, a/k/a CDMNV, Defendant/Judgment Debtor. ________________________________________/ ANSWER OF GARNISHEE, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC., AND DEMAND FOR GARNISHMENT DEPOSIT Garnishee, Church of Scientology Flag Service Organization, Inc., by and through its undersigned counsel files this answer to the Writ of Garnishment served by Plaintiffs/Judgment Creditors and states: 1. Garnishee is not indebted to Curaao Drydock Company, Inc. a/k/a

Curaaose Dokmaatschappij NV a/k/a CDMNV, at the time of this Answer. Garnishee was also not indebted to Curaao Drydock Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV at the time of service of the Writ or at any time between the time of service and the time of this Answer. 2. Garnishee has no tangible or intangible personal property of Curaao

Drydock Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV in its possession or control at the time of this Answer. Garnishee also had no tangible or intangible personal property of Curaao Drydock Company, Inc. a/k/a Curaaose

Case 1:06-cv-22128-JLK Document 391 Entered on FLSD Docket 10/29/2013 Page 2 of 2

Dokmaatschappij NV a/k/a CDMNV in its possession or control at the time at the time of service of the Writ or at any time between the time of service and the time of this Answer. 3. Garnishee knows of no other person indebted to Curaao Drydock

Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV, or who may have any of the property of Curaao Drydock Company, Inc. a/k/a Curaaose

Dokmaatschappij NV a/k/a CDMNV in his or her possession or control except that the Motion for Writ of Garnishment states that a ship belonging to Church of Scientology Flag Ship Service Organization, Inc., is currently in repair at the Judgment Debtors drydock facility. Accordingly, it would be logical to assume that Church of Scientology Flag Ship Service Organization, Inc. might be indebted to the Judgment Debtor.
4.

Garnishee has retained the undersigned law firm to file this answer and

requests that it be awarded the $100.00 statutory attorneys fee deposit provided for under Fla. Stat. 77.28, payable to the undersigned. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 29, 2013, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to the following: John Thornton, Esq., Do Campo & Thornton, P.A., attorneys for Plaintiffs/Judgment Creditors. /s/ Michael C. Markham Michael C. Markham FBN 768560 E-Mail:mikem@jpfirm.com Johnson, Pope, Bokor, Ruppel & Burns, LLP 911 Chestnut Street Clearwater, Florida 33757 Telephone: (727) 461-1818 Facsimile: (727) 462-0365 Counsel for CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.
1584205

Case 1:06-cv-22128-JLK Document 393 Entered on FLSD Docket 10/31/2013 Page 1 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, v. CURAAO DRYDOCK COMPANY, INC., a/k/a CURAAOSE DOKMAATSCHAPPIJ NV, a/k/a CDMNV, Defendant/Judgment Debtor. ________________________________________/ AMENDED ANSWER OF GARNISHEE, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC., AND DEMAND FOR GARNISHMENT DEPOSIT Garnishee, Church of Scientology Flag Service Organization, Inc., by and through its undersigned counsel files this amended answer to the Writ of Garnishment served by Plaintiffs/Judgment Creditors and states: 1. Garnishee is not indebted to Curaao Drydock Company, Inc. a/k/a

Curaaose Dokmaatschappij NV a/k/a CDMNV, at the time of this Answer. Garnishee was also not indebted to Curaao Drydock Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV at the time of service of the Writ or at any time between the time of service and the time of this Answer. 2. Garnishee has no tangible or intangible personal property of Curaao

Drydock Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV in its possession or control at the time of this Answer. Garnishee also had no tangible or intangible personal property of Curaao Drydock Company, Inc. a/k/a Curaaose

Case 1:06-cv-22128-JLK Document 393 Entered on FLSD Docket 10/31/2013 Page 2 of 2

Dokmaatschappij NV a/k/a CDMNV in its possession or control at the time at the time of service of the Writ or at any time between the time of service and the time of this Answer. 3. Garnishee knows of no other person indebted to Curaao Drydock

Company, Inc. a/k/a Curaaose Dokmaatschappij NV a/k/a CDMNV, or who may have any of the property of Curaao Drydock Company, Inc. a/k/a Curaaose

Dokmaatschappij NV a/k/a CDMNV in his or her possession or control.

4.

Garnishee has retained the undersigned law firm to file this answer and

requests that it be awarded the $100.00 statutory attorneys fee deposit provided for under Fla. Stat. 77.28, payable to the undersigned. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 31, 2013, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to the following: John Thornton, Esq., Do Campo & Thornton, P.A., attorneys for Plaintiffs/Judgment Creditors. /s/ Michael C. Markham Michael C. Markham FBN 768560 E-Mail:mikem@jpfirm.com Johnson, Pope, Bokor, Ruppel & Burns, LLP 911 Chestnut Street Clearwater, Florida 33757 Telephone: (727) 461-1818 Facsimile: (727) 462-0365 Counsel for CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.
1584205