IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA GENERAL JURISDICTION

DIVISION CASE NO. 11 20527 CA 21

LTA LOGISTICS, INC. A Florida corporation, and LESTER TRIMINO, ANNETTE TRIMINO, LESTER TRIMINO SR.,
Plaintiff's and Defendant's in the counterclaim,

V.

Enrique Varona,
Defendant and Plaintiff in the counterclaim,

MOTION TO ADMIT RESPONSE TO REQUEST OF ADMISSIONS, STRIKE PLAINTIFF(S) RESPONSE TO REQUEST OF ADMISSIONS, THAT ALL INTERROGATORIES BE ADMITTED, AND FOR DEFAULT SUMMARY JUDGMENT ON THE MERITS

Introduction

Here comes the Defendant, Enrique Varona acting Pro-se, (from hereon, Varona), who is a human being, not a corporation nor statutory person, who believes the U.S. Constitution to be the Supreme law of the land and moves this honorable Court to obey the rule of law in the interest of justice, on account and consideration of the following facts:

1. On December 28, 2011

Varona filed a request of admissions conforming with Fl. R. of

Civ. Procedure 1.370, See; request of Admissions as Exhibit "A". 2. On January 27, 2012 LTA Logistics, Inc., et al, acting through its counsel filed into the Court it's response to request of admissions. See; plaintiff response to request of

admissions as Exhibit "B". 3. Varona moves this Court to (1) admit response to request of admissions, (2) strike response to request of admissions, (3) that all interrogatories be admitted and moves this Court for (4) default summary judgment on the merits on all counts of Complaint and Counterclaim.

Authorities

4. Plaintiff(s) has filed a response to request for admissions in a timely manner, into the Courts record, and has not objected to any interrogatories. 5. Varona states that 16 answers on plaintiffs response to request of admissions are insufficient Because they are false and fraudulent responses in their face. See rule 1.370 which states in part:

"The party who has requested the admissions may move to determine the sufficiency of the answers or objections".

6. Varona moves to strike the plaintiff(s) response to request of admissions. See Rule Florida Rule of Civil Procedure 1.150 (a) which says in part:

"Which requires when ruling on a motion to strike. The rule allows the striking of a pleading when there is evidence of falsity or fraud."

7. Varona moves the Court to admit all the answers on interrogatories of request of admissions, because false and/or fraudulent responses to request of admission does not comply with the requirements of the rule. See Florida Rule of Civil Procedure 1.370 which says in part:

"If the court determines that an answer does not comply with the requirements of this rule, it may order either that the matter is admitted or that an amended answer be served".

8. Varona moves this Court for default summary judgment on the merits. See Florida Rule of Civil Procedure 1.510 (c) which says in part:

"The judgment sought shall be rendered forthwith if the pleadings, depositions, answers to interrogatories, admissions, affidavits, and other materials as would be admissible in evidence on file show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law."

9. Varona has filed an affidavit to support his exhibits and statements of facts.

16 responses on plaintiff(s) response to request of admissions are FALSE therefore, grossly insufficient.

10. LTA Logistics, Inc., et al, has lied on the following interrogatories in their response to request of admissions. All questions are in proper numerical sequence as they appear in the motion of request of admission:

1. is denied, this is FALSE because plaintiff(s) knows that the signature on the contract is a forgery. 2. Is denied, this is FALSE because plaintiff(s) knows he is not a D.O.T Licensed carrier as he was claiming in their advertisement, they do not have a 225 blue trucks fleet as they were claiming in their advertisement, and that those facts of public concern were the nature of the statements made by Varona on the internet. 3. Is denied, this is FALSE and in support see exhibits attached: "C", "D", "E", "F", "G", "H", "I' plaintiff(s) filed numerous fraudulent copyright infringement notices with

Google You Tube, which is a fraud and a violation of Federal Law, Title 17 USC Section 512(f) of the Digital Millennium Copyright Act of 1998. Each violation is a felony which carries a $2,000.00 fine and other penalties. 4. Is denied, this is FALSE plaintiff(s) know they made over 50 such felonious

fraudulent copyright infringement notices, and in support see affidavit. 5. Is denied, this is FALSE and a perjury to the Court. 6. I accept this answer as sufficient. 7. Is denied, this is FALSE, plaintiff(s) have repeatedly failed to disclose who are these customers and will not answer motions to produce requesting such information.

8. Is denied, this is FALSE since they have failed to prosecute, object to or deny anything on the record. 9. Is denied, this is FALSE. 10.1 accept this answer as sufficient. 1 . Is denied, this is FALSE see exhibits "A" through "J" of counterclaim for evidence. 1 12.1s denied, this is FALSE plaintiff proceed to present the document identified as

Exhibit "D" an exhibit in the counterclaim without objection. 13. Is denied, this is FALSE since all exhibits in counterclaim were not contested by plaintiffs AND ARE ON THE RECORD. 14. I accept this answer as sufficient. 15.1s denied, this is FALSE see exhibit "G" in counterclaim letter from James K. Pedley Paragraph 3 states: "Please note, that three individuals actually witnessed Enrique Varona signing the Agreement..." 16.Is denied, this is FALSE. 17.1s denied, this is FALSE plaintiffs knows I did not sign any agreement is front of plaintiff, his wife or sales manager. 18. Is denied, this is FALSE plaintiff is the source of most of the documents in those exhibits and never contested this fact of law in the counterclaim. 19. Is denied, this is FALSE see supporting evidence in counterclaim. 20.1 accept this answer in part and state is insufficient in part.

11. Of 20 interrogatories on Varona's request of admissions there are 16 responses by plaintiff in their response to request of admissions which are blatant lies. Lies that can easily be proven by calling the U.S. copyright office, by conducting a search on the internet,

by examining the exhibits on the counterclaim, exhibits entered by Varona under an a sworn notarized affidavit into the Court which were never disputed or contested by Plaintiff.

Memorandum of law

12. LTA Logistics, Inc., et al, and its counsel Scott Egelston PA Florida Bar No 883425 have conspired with each other to lie and mislead this court by knowingly filing false, deceptive, fraudulent responses to Varona's Request of admissions in order to prevent the Court form knowing the true facts of the case, obstruct justice and a number of other crimes such a violation of due process (5th amendment). Because no criminal communication between

attorney and client is protected or immune they are both liable. 13. Varona has an expectation of 'Good Faith' on the part of the Plaintiff(s) and their counsel as Agent(s)/employee(s) on behalf of 'companies, corporations, government corporations or officers of the court to answer the inquiries, to give proof, to produce requested documents and evidence. 14. Varona has an expectation that LTA Logistics, Inc., et al, and its counsel Scott Egelston P.A. Florida Bar Number 883425, will act fairly and honestly and in good faith, with clean hands and without intent to cheat, hinder, delay, defraud, lie, coerce, use undue influence, threaten, or violate their 'Oath of Office'. 15. Courts get their jurisdiction from one source and one source only sufficient and truthful pleadings. Without pleadings sufficient to empower the court to act, that court cannot have judicial capacity. Jurisdiction must be proved and on the record. 16. Fraud on the Court is when a lawyer, as an officer of the court, lies to the court about a material fact. In this case lying on this response to request of admissions.

17. Black's Law Dictionary, Sixth Edition id. at 457 defines "Fraud on the Court" as:

"[Fraud on Court] consists of conduct so egregious that it undermines the integrity of the judicial process."

18. LTA Logistics, Inc. etal, has denied the court subject matter jurisdiction for perpetrating a "Fraud committed in the procurement of jurisdiction", for reference see; Fredman

Brothers Furniture v. Dept. of Revenue, 109 III. 2d 202, 486 N.E. 2d 893(1985). 19. Mr. Scott Egleston P.A. counsel for LTA Logistics, Inc., et al, by filling this preposterous and deceitful response to the request of admissions is in violation of his oath of office as

an attorney and officer of the Court- which includes the supremacy clause of the U.S. Constitution- as an ABA certified attorney Florida Bar Number 883425, which provides the following:

"I do solemnly swear: I will support the Constitution of the United States and the Constitution of the State of Florida: I will maintain the respect due to courts of justice and judicial officers: I will not counsel or maintain any suit or proceedings which shall appear to me to be unjust, nor any defense except such as I believe to be honestly debatable under the law of the land; I will employ for the purpose of maintaining the causes confided to me such means only as are consistent with truth and honor, and will never seek to mislead the judge or jury

by any artifice or false statement of fact or law: i win maintain the

confidence and preserve inviolate the secrets of my clients, and will accept no compensation in connection with their business except from them or with their

knowledge and approval; To opposing parties and their counsel. I pledge fairness, integrity, and civility, not only in court, but also in all written and oral communications: i win abstain from an offensive
personality and advance no fact prejudicial to the honor or reputation of a party or witness, unless required by the justice of the cause with which I am charged; I will never reject, from any consideration personal to myself, the cause of the defenseless or oppressed, or delay anyone's cause for lucre or malice. So help me God."

20. Scott Egelston P.A. Florida Bar Number 883425 is an officer of the court and is bound by oath and the Rules of Professional Conduct to be honest and candid with the tribunal. When a lawyer speaks or files documents in court, as an officer of the court, it is presumed he is telling the truth. His word as an officer of the court carries more weight than the words of an unknown pro se litigant and the court is therefore obligated to believe the lawyer over that of someone like me. 21. A lie is a knowing misrepresentation of the truth. Knowingly providing false information in an official proceeding to interfere with that proceeding - even if you're not under oath - is a crime. 22. LTA Logistics, Inc., et al, and its counsel seem to think it's OK to fabricate false evidence and to encourage clients to testify falsely, after all, everybody does it. I think they're used to getting away with it because lawyers allow lawyers to break the rules and judges have shown a high tolerance for dishonesty from lawyers. But just because they may have gotten away with it in the past is no reason to allow them to continue to do so.

Conclusion

The Plaintiff(S) and their counsel in this case seem to be making an argument that lawyers have a right to be dishonest and deceitful. It is as if to make a mockery of the Rules of Professional Conduct. I suppose one has to believe that justice will ultimately prevail. Someone has got to protect and preserve the Integrity of the judicial system. I hope this Court agrees. Defendant, prays for relief from the Court, and moves the Court to strike Plaintiffs response to request of admission, to admit all the interrogatories on Defendants request of admission and that by default enters a ruling of summary judgment on the merits on behalf and favor of Varona and against the Plaintiff(s) claim of tortuous interference with a business advantage and defendants counterclaim, and grant Varona all the relief available u/der\he law.

espepuliy submitted,

Enrique Varona, Pro-se 14823 SW 125 Ct Miami, Florida 33186

CERTIFICATE OF SERVICE

I HEREBY CERTIFY, a true and correct copy of the foregoing was sent by mail to Scott Egelston P.A. Florida Bar Number 883425 at 12000 Biscayne Blvd Suite #220, Miami, Florida 33181 on this day of February 2012.

Enrique Varona, pro-se.

TRUTH AFFIDAVIT
IN THE NATURE OF SUPPLEMENTAL RULES FOR ADMINISTRATIVE AND MARITIME CLAIMS RULEC(6)

PLAIN STATEMENT ABOUT THE FACTS: (1) For resolving a matter it must be expressed, (2) in commerce truth is sovereign, (3) truth is expressed in the affidavit form, (4) an un-rebutted affidavit stands as truth in commerce, (5) an un-rebutted affidavit becomes the judgment in commerce, (6) a truth affidavit, under commercial law, can only be satisfied by a rebuttal about the truth affidavit, by payment, by agreement, by resolution of a jury according to the rules for common law. In commerce everything must be stated in truth, I, Enrique Varona, a human person, a private person, a living soul, a creditor, a claimant and NOT A STATUTORY PERSON upon the land of Miami Dade County, Florida, do hereby solemnly declare, state and say: Statement of facts 1. I am over 18 years of age and competent for my actions. 2. I did not sign a contract dated November 5, 2009. 3. I made internet statements pertaining to facts of public concern. 4. Lester Trimino filed copyright infringement notices with Google You Tube against me. 5. Lester Trimino filed over 50 copyright infringement notices with Google You Tube against me. 6. Lester Trimino has no copyright license in existence that I violated or infringed upon. 7. Exhibits "C", "D", "E", "H" are email notifications of such copyright infringement notices. 8. LTA Logistics, Inc. Does not have exclusive rights to all shippers in the country. 9. All exhibits in this motion are true copies of original documents. 10. All exhibits in this motion are pertinent to this matter. 11.All exhibits presented are true and legitimate evidence. 12.16 of the 20 answers on the response to request of admissions are false. 13.1 will defend against and seek remedy for "deprivation of rights, privileges, or immunities" secured by the constitution of the UNITED STATES of AMERICA and the constitution of the state of Florida against any and all guilty parties.

Further, Affiant saith not.

NOTICE TO PRINCIPAL IS NOTICE TO AGENT AND NOTICE TO AGENT IS NOTICE TO PRINCIPAL This document was prepared by Enrique Varona

I declare under penalty of perjury under the laws of the UNITED STATES OF AMERICA and of the state of Florida, that the foregoing is true and correct to the best of my knowledge. Without prejudice, UCC 1-207.

inquewarona 1823 3W 125 Court Miami.VFJorida 33186

NOTICE: Using a notary on this document does not constitute any adhesion, nor does it alter my status in any manner. The purpose for notary is verification and identification only and not for entrance into any foreign jurisdiction, a benefit for the litigants and the Court.

JURAT

STATE OF FLORIDA MIAMI DADE COUNTY

SEAL:

Enrique Varona,

known by me or made known for Me by proper identification and duly 10 day of February 2012.

sworn and subscribed in My presence, this

Notary signatur Notary address: My commission expires on : QQ Inn. 1 o/\\xL

NOTARY PUBLIC-STATE OF FLORIDA

VAiGunoA

Massiel Fuentes i ; Commission # EE024127 %^f/Expires: SEP. 08,2014

BONDED TK3V ATLANTIC BONDING CO., WC.

EXHIBITS
1. Exhibit "A": Motion of Request of Admissions 2. Exhibit's": 3. Exhibit "C": Response to Request of Admissions Letter (email) from GOOGLE YouTube notifying of Copyright violation by

LTA Logistics, Inc. This 1 of 50 such notices. 4. Exhibit "D": Letter (email) from Google YouTube notifying of Copyright violation by

LTA Logistics, Inc. 5. Exhibit "E": Letter (email) informing of deletion of video due to Copyright

infringement notices filed by LTA Logistics, Inc. 6. Exhibit "F": Letter (email) informing of deletion of video due to Copyright Infringement notices filed by LTA logistics, Inc. 7. Exhibit "G": Letter (email) informing of deletion of video due to copyright infringement notices filed by LTA Logistics, Inc. 8. Exhibit "H": Printout of screen (1 of 50) shown of video not available due to a copyright infringement notice by LTA Logistics, Inc. 9. Exhibit "I": Letter of LTA Logistics, Inc counsel to prove a concerted campaign of

harassment and falsehoods with employer and claim of 3 parties witnessing signature signing by Varona of fake contract.

Fw: Re: [#870865165] New YouTube Copyright Complaint Submission - Yahoo! Mail

Page 1 of 1
fl"

;MAIL
Classic

Fw: Re: [#870865165] New YouTube Copyright Complaint Submission

Tuesday, December 13, 2011 2:56 PM From: "Rico Varona" Cc: <ricovarona@rocketmail.com> To: ennquevarona@ymail.com cnp4ad@yahoo.com

On Wed, 12/7/11, Copyright Service <copyright@youtube.com> wrote: From: Copyright Service <copyright@youtube.com> Subject: Re: [#870865165] New YouTube Copyright Complaint Submission To: ricovarona@rocketmail.com Date: Wednesday, December 7, 2011, 3:51 PM Hi there, Thank you for your message. When we're notified that a particular video uploaded to our site infringes another's copyright, we remove the material as the law requires. If you believe a content owner has misidentified your content as infringing, you may file a counter-notification. For more information on how to do this, please visit the Copyright Center page about counter-notifications at: http://www.youtube.com/t/copyright_counter If you don't have the URL of the video in question you can get information about any account penalties within your account at http://www.youtube.com/account#manage/status_copyright or, if you currently cannot access your account, via the form at http://help.youtube.com/support/youtube/bin/request.py?contact_type=accountdisabled Keep in mind that a copyright strike may expire in 6 months, subject to certain conditions, as long as no additional copyright infringement notifications are received during that time. Regards, The YouTube Team

httD://us.mc357.mail.vahoo.com/mc/showMessa0e^.sMid=26&f1d=GoogleYouTiibe<^rllterR

2/R/2012

Fw: Re: [#870865165] New YouTube Copyright Complaint Submission - Yahoo! Mail

Page 1 of 2

MAIL
Classic

an"

Fw: Re: [#870865165] New YouTube Copyright Complaint Submission

Wednesday, February 8, 2012 12:03 PM From: "Rico Varona" <ricovarona@rocketmail.com> To: "enrique varona" <cnp4ad@yahoo.com>

On Tue, 12/13/11, Rico Varona <ricovarona@rocketmail.com> wrote:

From: Rico Varona <ricovarona@rocketmail.com> Subject: Fw: Re: [#870865165] New YouTube Copyright Complaint Submission To: enriquevarona@ymail.com Cc: cnp4ad@yahoo.com Date: Tuesday, December 13, 2011, 11:56 AM

On Wed, 12/7/11, Copyright Service <copyright@youtube.com> wrote: From: Copyright Service <copyright@youtube.com> Subject: Re: [#870865165] New YouTube Copyright Complaint Submission To: ricovarona@rocketmail.com Date: Wednesday, December 7, 2011, 3:51 PM Hi there, Thank you for your message. When we're notified that a particular video uploaded to our site infringes another's copyright, we remove the material as the law requires. If you believe a content owner has misidentified your content as infringing, you may file a counter-notification. For more information on how to do this, please visit the Copyright Center page about counter-notifications at: http://www.youtube.com/t/copyright_counter If you don't have the URL of the video in question you can get information about any account penalties within your account at http://www.youtube.com/account#manage/status_copyright or, if you currently cannot access your account, via the form at http://help.youtube.com/support/voutube/bin/request.pv7contact type=accountdisabled Keep in mind that a copyright strike may expire in 6 months, subject to certain conditions, as long as no additional copyright infringement notifications are received during that time. Regards, The YouTube Team

httD://us.mc357.mail.vahoo.com/mc/showMe'ssaLJe 9 slV1id=l l&tllrerRv=&

? 78/90

Fvv: ricovarona - Video removed - Copyright Infringement - Yahoo! Mail

Page 1 of 2

MAIL
Classic

T
Wednesday, February 3, 2012 12:03 PM

Fw: ricovarona - Video removed - Copyright Infringement

From: "Rico Varona" <ricovarona@rocketmail.com> To: "enrique varona" <cnp4ad@yahoo.com>

On Tue, 12/13/11, Rico Varona <ricovarona@rocketmail.com> wrote:

From: Rico Varona <ricovarona@rocketmail.com> Subject: Fw: ricovarona -Video removed - Copyright Infringement To: "enrique varona" <enriquevarona@ymail.com> Cc: "enrique varona" <cnp4ad@yahoo.com> Date: Tuesday, December 13, 2011, 12:01 PM

On Tue, 12/13/11, YouTube <no_reply@youtube.com> wrote: From: YouTube <no_reply@youtube.com> Subject: ricovarona - Video removed - Copyright Infringement To: "ricovarona" <ricovarona@rocketmail.com> Date: Tuesday, December 13, 2011, 12:01 PM help center | e^maiLoptipj

Dear ricovarona:
We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EPISODE III THE EMPEROR HAS NO CLOTHES http://www.youtube.com/watch?v=FklOzssZxac We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EPISODE IV A SECOND FRONT http://www.youtube.com/watch?v=jnC7pmHz1OO We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EPISODE II THE POWER OF TRUTH http://www.youtube.com/watch?v=NGzdJAW7v6k We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EPISODE V STALLING FOR TIME http://www.youtube.com/watch?v=bE4IT6N1ZZQ We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EPISODE I THE EMPIRE STRIKES BACK http://www.youtube.com/watch?v=TcKHwkutYcA

htto://us.mc357 mail vahoo com/mc/showMes.sae?sMid=6&filterBv=& rand=378520208&

2/S/2012

Fw: elmaleficio2 - Video removed - Copyright Infringement - Yahoo! Mail

Page 1 of 2

~YA.HOOf.MAIL
-*Classic

"F
Monday, January 9, 2012 3:17 PM

Fw: elmaleficio2 - Video removed - Copyright Infringement

From: "Henry Rico" <rinkincaya666@yahoo.in> To: cnp4ad@yahoo.com

On Tue, 13/12/11, Henry Rico <rinkincaya666@yahoo.in> wrote:

From: Henry Rico <rinkincaya666@yahoo.in> Subject: Fw: elmaieficio2 - Video removed - Copyright Infringement To: "enrique varona" <enriquevarona@ymail.com> Cc: "enrique varona" <cnp4ad@ahoo.com> Date: Tuesday, 13 December, 2011, 7:47 PM

On Tue, 13/12/11, YouTube <no_reply@youtube.com> wrote: From: YouTube <no_reply@youtube.com> Subject: elmaleficio2 -Video removed - Copyright Infringement To: "elmaleficio2" <rinkincaya666@yahoo.in> Date: Tuesday, 13 December, 2011, 7:47 PM help center I e-mail optioi

Dear elmaleficio2:
We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS EMPIRE'S FISH LOAD http://www.youU] be. com/watch ?v=glUeylGiqak We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS LIAR, LIAR... http://www.yout.ube.com/watch?v=DslkR9QoHiO We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS THE LAW SUIT TRAILER http://www.youtube.com/watch?v=2tvyaympOcA We have disabled the following material as a result of a third-party notification from LTA Logistics claiming that this material is infringing: LTA LOGISTICS RUN, RUN, RUN.... http://www.youtube.com/watch?v=m8XCZRHm5FM Please Note: Repeat incidents of copyright infringement will result in the deletion of your account an all videos uploaded to that account. In order to prevent this from happening, please delete any video: to which you do not own the rights, and refrain from uploading additional videos that infringe on the copyrights of others. For more information about YouTube's copyright policy, please read the

httD://us.mc357.mail.vahoo.com/mc/shovvMessatie 9 sMid=6&fid=GooL'leYouTuhe&filterBv

2/8/2012

Fw: ricovarona - Video removed - Copyright Infringement - Yahoo! Mail

Page

of 2

MAIL
Classic

"G"
Tuesday, December 13, 2011 3:01 PM

Fw: ricovarona -Video removed -Copyright Infringement

From: "Rico Varona" <ricovarona@rocketmail.com> To: "enrique varona" <enriquevarona@ymail.com> Cc: "enrique varona" <cnp4ad@yahoo.com>

On Tue, 12/13/11, YouTube <no_reply@youtube.com> wrote: From: YouTube <no_reply@youtube.com> Subject: ricovarona -Video removed - Copyright Infringement To: "ricovarona" <ricovarona@rocketmail.com> Date: Tuesday, December 13, 2011, 12:01 PM help center I e-mail optioi

Dear ricovarona:
We have disabled the following material as a result of a third-party notification from LTA Logistics claiming tha this material is infringing: LTA LOGISTICS EPISODE III THE EMPEROR HAS NO CLOTHES http://www.youtube.com/watch ?v=FklOzssZxac We have disabled the following material as a result of a third-party notification from LTA Logistics claiming tha this material is infringing: LTA LOGISTICS EPISODE IV A SECOND FRONT http://www.youtube.com/watch?v=jnC7pmHz1OO We have disabled the following material as a result of a third-party notification from LTA Logistics claiming tha this material is infringing: LTA LOGISTICS EPISODE II THE POWER OF TRUTH http://www.youtube.com/watch?v=NGzdJAW7v6k We have disabled the following material as a result of a third-party notification from LTA Logistics claiming tha this material is infringing: LTA LOGISTICS EPISODE V STALLING FOR TIME http://www.youtube.com/watch?v=bE4IT6N1ZZQ We have disabled the following material as a result of a third-party notification from LTA Logistics claiming tha this material is infringing: LTA LOGISTICS EPISODE I THE EMPIRE STRIKES BACK http://www.yout.ube.com/watch?v=TcKHwkutYcA Please Note: Repeat incidents of copyright infringement will result in the deletion of your account and all videos uploaded to that account. In order to prevent this from happening, please delete any videos to which you do not own the rights, and refrain from uploading additional videos that infringe on the copyrights of other: For more information about YouTube's copyright policy, please read the Copyright Tips guide. If one of your postings has been misidentified as infringing, you may submit a counter-notification. Information about this process is in our Help Center. Please note that under Section 512(f) of the Copyright Act, any person who knowingly materially misrepresen that material was disabled due to mistake or misidentification may be liable for damages. Sincerely, The YouTube Team

YouTube - Broadcast Yourself.

Page 1 of 1

Options (>

Unsaved Playhst Browse | Movies | Upload

Create Account

Sign In

"H"

Help Terms

About

Press & Blogs Safety

Copyright Report a bug Safety: Off *

Creators & Partners Try something new!

Advertising

Developers

New Privacy

English "

Worldwide ^

httn://\vww voutuhe com/watch 9 v=NGzdTAW7v6k

2/8/2012

J AMES K. PEDL E Y
A T T O R N E Y S AT LAW SUITE 301 7 2 7 N O R T H E A S T THIRD A V E N U E

ONT L A U D K K D A I . K . Fi.oKtuiA :s:s:iO4

TELEPHONE OS4) S 2 3 - 2 2 O S

I) HE ED Iff Eljj] .".;L '>3 2'ViO nil

July 26, 2010

James B Gattoni, President Landstar Transportation Logistics, Inc 13410 Sutton Park Drive South Jacksonville, FL 32224 Enrique Verona Landstar Transportation Logistics, Inc 1 3410 Sutton Park Drive South Jacksonville, FL 32224 RE: Enrique Verona and his Non-Compete and Non-Solicitation Agreement with LTA Logistics, Inc Dear Mr. Gattoni and Mr. Verona: Please be advised that I have been retained by LTA Logistics, Inc to contact with you with this written correspondence. This matter is directed to your employee/independent contractor. Enrique Verona and his violation of the Non-Disclosure and Non-Solicitation Agreement. Attached hereto as Exhibit A is a letter dated July 22, 2010 from Lester Trimino, President of LTA Logistics, Inc. and sets forth the factual basis for the breach of the agreement by Mr. Enrique Verona. My client made this information available to Amy at Landstar Transportation Logistics. Inc. A copy of LTA Logistics. Inc's Non-Disclosure and Non-Solicitation Agreement dated November 5, 2009 is attached hereto as Exhibit B. Please note, that three individuals actually witnessed Enrique Verona signing the agreement. Present at the time it was signed was; Annette Trimino, Vice-President of LTA Logistics. Inc: Lester Trimino. President; and Todd Osipiak, the Sales Manager. It is immediately requested that Enrique Verona cease and desist the violation of this agreement as set forth in the letter of Lester Trimino, President of LTA Logistics, Inc. A written response explaining the position of Landstar Transportation Logistics, Inc and Enrique Verona's position with regard to these allegations is demanded at this time. The allegations as set forth in the letter, if true set forth a basis for tortious interference of this agreement by Landstar Transportation Logistics. Inc and would set forth the basis for damages against the company in favor of LTA Logistics. Inc. The goal and purpose of this letter is to

otect the integrity of this agreement and the rights of LTA Logistics, Inc. If this matter is gnored, a lawsuit will be filed. Please, govern yourself accordingly.

Very truly v

gistics, Inc