Filing # 44656968 E-Filed 08/01/2016 01:02:23 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAM1-DADE COUNTY, FLORIDA
CASE NO.

________

GENESIS DAVILA,
Plaintiff,
v.
TEL-AIR INTERESTS, INC.,
GRANT GRAVITT, JR., and
IMG UNIVERSE, LP,
Defendants.
_________ /

COMPLAINT

Plaintiff, GENESIS DAVILA (Davila or Plaintiff), sues Defendants, TEL-AIR

INTERESTS, INC., a Florida corporation (Tel-Air), GRANT GRAVITT, JR. (Gravitf),
and IMG UNIVERSE, LP, a Delaware limited liability company (IMG) (collectively
Defendants), and states as follows:
OVERVIEW

Plaintiff, Davila competed in and won the popular annual Miss Florida beauty
pageant. After being crowned, Miss Floridas organizers falsely claimed that Plaintiff
violated a "rule", publically stripped her crown and title of Miss Florida and crown, and
designated the runner-up as Miss Florida 2017. Defendants Gravitt and Tel-Air then
embarked on a false, malicious, and defamatory public-smearing campaign, causing
humiliation and embarrassment to the Plaintiff. As demonstrated herein, there was no
basis for Defendants to do so.
1

JURISDICTION AND VENUE

1.

This Court has jurisdiction over each of the Defendants because they each

engage in non-isolated business in Miami-Dade County, because the damages felt and
accrued to the Plaintiff in Miami-Dade County and because the amount sought is greater
than $15,000.00, exclusive of interest, attorneys fees and costs.
2.

This Court has personal jurisdiction over the Defendants because: a)

Defendants committed tortious acts within the State of Florida thereby satisfying the
Florida long-arm statute 48.193 Fla. Stat. (2016); and b) Defendants have committed
intentional torts expressly aimed at smearing the goodwill and reputation of Plaintiff,
Genesis Davila, the effects of which were suffered in this jurisdiction.
3.

Venue is proper in this Court pursuant to 47.011 Fla. Stat. (2016), in that

the cause of action accrued in Miami-Dade County, Florida and the Defendants conduct
business operations in Miami-Dade County, Florida.
PARTIES

4.

Plaintiff, GENESIS DAVILA, is a Florida resident who resides in Miami-Dade

County and who is over the age of 18.

5.

Defendant, TEL-AIR INTERESTS, INC., is believed to be a Florida corporation

engaged in business in Miami-Dade County and Broward County, who is the producer of the
annual Miss Florida beauty pageant, believed to a franchise of the Miss USA and Miss Universe
pageants, owned IMG.
6.

Defendant, GRANT GRAVITT, JR., upon information and belief, is a citizen

and resident of the State of Florida. He is the controlling person of TEL-AIR and serves in the
2

capacity of Executive Director of the Miss Florida USA pageant.

7.

Defendant, IMG UNIVERSE, LP (IMG), is believed to be a limited liability

company incorporated in Delaware, having its principal place of business in New York
City, New York, which upon information and belief, is the owner of the Miss Florida, Miss
USA and Miss Universe beauty pageants.
COMMON ALLEGATIONS

8.

Plaintiff, Davila is a model and beauty-pageant contestant.

9.

Plaintiff began training as a beauty-pageant contestant, expending time, energy,

and money for the competition and to develop her talents as a professional model and
spokesperson.
10.

On or about early 2016, Plaintiff entered and won the Miss Miami Beach beauty

pageant which, in turn, qualified her for entrance to the Miss Florida pageant.
11.

At the time she entered the Miss Florida pageant, the producer of the

pageant, Tel-Air, required her to sign the application/contract, dated May 1, 2016, a
true and correct copy of which is attached hereto as Exhibit A (hereinafter referred to as
the Application).
12.

Plaintiff paid the sum of $1,350.00 to Tel-Air, as an entrance fee to be a

part of and to compete in the Miss Florida pageant.

13.

Plaintiff complied, in every instance, with all of the terms and conditions

set forth on the Application. She entered the Miss Florida pageant in good faith based
on the express, implied, and overt understanding and agreement that if she won the Miss
Florida pageant, as determined by a panel of independent judges, that she would be
3

crowned Miss Florida and that she would fulfill the responsibilities and receive the
benefits of being Miss Florida. Such benefits would include, but not be limited to, entry
into the Miss USA pageant, and if she was crowned the winner of the Miss USA
pageant, she would be entered into the Miss Universe beauty pageant.
14.

At all times, Plaintiff believed the Defendants would act in good faith and

that the pageant was not rigged, so that a contestant associated with a commercial
sponsor of the pageant would not be declared to be the winner irrespective of the
decisions of the independent judges.
15.

The Miss Florida pageant process began on Wednesday, July 13, 2016,

and at no time were any written rules or regulations (which are referenced in the
Application), ever given to Plaintiff, but rather, certain limited rules and regulations
were announced to all contestants... basically advising the contestants not to use the
services of any outside vendor for purposes of hair or makeup.
16.

The actual Miss Florida pageant occurred on Saturday, July 16, 2016,

which culminated with Plaintiff being voted as and crowned by the panel of
independent judges as Miss Florida.
17.

On Monday, July 18, 2016, Plaintiff was asked to go to the offices of Tel-

Air to sign certain paperwork, relative to her being crowned as Miss Florida.
18.

After being congratulated as to her victory on becoming Miss Florida by

members of Tel-Airs staff, Gravitt, the pageant director, began to scream at her,
asserting that she had lied, was a cheater, and stating that he would take her down.

19.

At the time such statements were made by Gravitt, Plaintiff had no idea

what he was talking about and asked him for clarification. Gravitt stated to Plaintiff that
she had lied about being a U.S. citizen, which is a requirement of the pageant as is
clearly set forth in the Application.
20.

Gravitt insisted that Plaintiff write a letter (which Plaintiff did), stating to

the effect that she was unaware of any accusation or any reason why she was not
properly qualified to serve as Miss Florida. A true and correct copy of the letter is
attached hereto as Exhibit B and herewith referred to as Letter.
21.

Plaintiff, thinking the only issue was her immigration status, as a US

Citizen, then consulted with and hired an immigration lawyer, Mayra Joli, Esq. (Joli),
who advised her that indeed Plaintiff, as a citizen of Puerto Rico (a Commonwealth of
the United States), was in fact a United States citizen, and since she had lived in Miami
for a period of more than 18 months, therefore she was qualified to be Miss Florida
under the terms of the Application.
22.

In furtherance of Plaintiffs thinking that her immigration status was the

only issue concerning her standing as Miss Florida, Plaintiff scheduled an appointment
with Mr. Gravitt and her immigration lawyer, Joli, for Friday, July 22, 2016, at 3pm.
23.

On July 22, 2016, Plaintiffs immigration lawyer, Joli, and an associate

lawyer arrived at the offices of Tel-Air, thinking the meeting was only to discuss
Plaintiffs immigration status. To Ms. Jolis surprise, Tel-Air had arranged a press
conference which she surmised was intended to ambush Plaintiff in front of cameras,

reporters and members of the press, announcing that they had stripped her of the title
and crown of Miss Florida for, at this point, still an unknown reason.
24.

During this meeting, Gravitt stated to Ms. Joli that he came up with a new

reason why Plaintiff was unqualified; that Plaintiff had lied and cheated because they
had a photograph of a vendor in Plaintiffs room helping Plaintiff with her hair and
make-up during the pageant in violation of the rules. Gravitt shared with Ms. Joli the
subject photo. The person in the photo whom Gravitt claimed was Plaintiffs hair and
nail vendor during the pageant, was Maria Reyes (Reyes), a long-time family friend,
who provided no hair or nail services to Plaintiff.
25.

Gravitt stated to Ms. Joli that he insisted on Plaintiff announcing to the

press, that because her mother was sick in a hospital, she was unable to fulfill her
continuing responsibilities as Miss Florida. He threatened that if Plaintiff did not
resign, that he would become very aggressive and would destroy her.
26.

Ms. Joli advised Gravitt that Ms. Reyes was merely a family friend and

there was no basis to claim Plaintiff had violated any announced rule as Plaintiff stated
in Plaintiffs letter.
27.

Having been backed into a comer, Gravitt chose to confront the press that

had gathered in his office, where he made false statements about Plaintiff that he knew
to be untrue; that she lied, cheated, violated the rules and that she was being stripped of
her crown and that the first runner-up have been appointed in Plaintiffs stead as Miss
Florida.

28.

Gravitt then embarked on a calculated, concerted, and malicious public-

smearing campaign to falsely categorize and castigate the Plaintiff as one who cheated,
had violated the pageants rules and who was not qualified to serve as Miss Florida,
even though he knew such statements not to be true, and even though she was
determined by the independent panel of pageant judges to have won the pageant, even
though Plaintiff had denied ever violating the Rules in Plaintiffs letter, and even though
the photograph that Gravitt had from social media does not support Gravitfs
allegations.
29.

As part of this false, slanderous campaign being levied against Plaintiff,

Gravitt initially claimed that Plaintiff violated the rules by having an outside vendor,
who did hair and make-up, visit Plaintiffs room. In this regard, Gravitt first published
to the press another photo taken from Plaintiffs social media (Instagram), depicting
Plaintiff receiving make up from another outside make-up artist, Ilde Goncalves
(Goncalves). In truth, this photograph was taken by Plaintiff at a professional photo
shoot which occurred a week before the Miss Florida pageant, which had a patently
clear and obvious date of July 9, 2016.
30.

As part of and in furtherance to his efforts to publicly slander and

humiliate Plaintiff, Gravitt cropped the aforesaid photograph (removing the date which
identifies when the actual photo was posted on the social media), in order to support his
false allegations.

31.

Gravitt, then-realizing that the cropped Instagram post depicting Plaintiff

and Goncalves which he had put on social media to support his allegations of pageant
violations against Plaintiff pre-dated (by a mere week) the pageant, then changed the
allegations against her (yet again) by claiming that Plaintiff had her hair and make-up
done by Reyes.
32.

In reality, the pageants organizers scheduled a Family and Friends

night, during which pageant contestants were allowed to interact with family and friends
on the night of Friday, July 15, 2016, to help them relax on the eve of the pageant. It
was at this time that Plaintiff met with her mother and her friend, Reyes, in her mothers
room, upon the advice and with express approval of the pageant organizers. Hence, this
photo was taken more than 24 hours before the pageant.
33.

At no time did the pageant organizers tell Plaintiff it was inappropriate or

a violation of any rules for her to go into her mothers room during the Family and
Friends Night, and at no time when she was with her mother and Reyes (nor at any
time) did anyone assist her with her hair, make-up, or otherwise provide any assistance
with respect to her participation as a contestant in the pageant.
34.

Gravitts ever-changing and unsupported reasons for stripping Plaintiff of

her title and crown as Miss Florida, is financially motivated and due to his (and her
mothers) overt prejudice against Puerto Ricans, as he stated to Plaintiff and Ms. Joli.
35.

One of Gravitts

financial sponsors

is a company called PR

Coaches/Pageant Ready (Pageant Ready), which is owned by Jules Meyer.

36.

Pageant Ready serves as a coach to pageant participants. Of the top 15

finishers in the final standings of the Miss Florida pageant, 8 contestants overall and all
of the top 5 finishers (other than Plaintiff), are clients of Pageant Ready.
37.

By stripping Plaintiff of the title of Miss Florida, Gravitt was able to direct

the winner of the pageant to one of the clients of one of his major sponsors.
38.

The commercial value of Davilas name, image, identity, and persona has

been and continues to be materially harmed by Gravitf s actions in the public, smearing
Davila; which brought and continues to bring unfavorable public perception to Davila.
39.

As a natural consequence of Defendants actions, Davila has suffered and

continues to suffer from tremendous emotional distress.

40.

At all times relevant. Plaintiff complied with the rules and regulations of

the pageant that were disclosed to her.

41.

Plaintiff has fulfilled all conditions precedent prior to filing this lawsuit.

42.

Plaintiff has hired the undersigned law firm and has agreed to pay it a

reasonably hourly fee for its services.

COUNT I - BREACH OF CONTRACT (ORAL AND IMPLIED IN FACT)
(Versus All Defendants)

Plaintiff repeats, re-alleges, adopts and incorporates each and every allegation
contained in Paragraphs 1 through 42, as if fully set forth herein, and further alleges:
43.

This is a count for Breach of Contract.

44.

The parties entered into an oral contract and which was implied in fact

(the Contract).
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45.

Pursuant to the Contract, Plaintiff paid the sum of $1,350 as an entry fee,

and in return, if Plaintiff was selected as the winner of Miss Florida, she would be
crowned Miss Florida and would receive all the benefits afforded to Miss Florida,
including a $100,000 package, including among other things, gowns, jewelry and a 3week trip to participate in and compete in the Miss USA pageant and thereafter, if she
won the Miss USA pageant, a chance to participate in

and compete in the Miss

Universe pageant.
46.

By winning the Miss Florida pageant. Plaintiff was in position to receive

public attention, adoration, and the once in a lifetime experience of being Miss
Florida, each day that Plaintiff is denied those benefits she suffers irrevocable harm,
which can only be rectified by this court restoring her as Miss Florida, enjoining
Defendant from allowing the runner up to fulfill Plaintiffs position, and requiring
Defendant to allow Plaintiff to participating in the Miss USA pageant.
WHEREFORE based upon the foregoing. Plaintiff asks this Honorable Court to
find Defendants to be in breach of the Contract, and to award Plaintiff reasonable
compensatory damages and special damages in the form of the reasonable value of the
loss accruing to Plaintiff as a result of the breach, and to enter preliminary and
permanent injunctive relief consistent with paragraph 46 above.
COUNT II - INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Versus Gravitt And Tel-Air)

Plaintiff repeats, re-alleges, adopts and incorporates each and every allegation
contained in Paragraphs 1 through 42, as if fully set forth herein, and further alleges:
10

47.

This is a count for intentional infliction of emotional distress against

Defendants Gravitt and Tel-Air.

48.

Gravitts conduct was intentional and malicious and done with the express

purpose of causing, or was reasonably known by Gravitt to likely cause Davila to

experience humiliation, severe emotional distress, and mental anguish and which was
done with wanton and reckless disregard of the consequences to Davila.
49.

As such, in committing the acts alleged above, Gravitt shamefully and

intentionally inflicted severe emotional distress to Davila.

50.

As a direct and proximate cause of the aforementioned egregious actions,

Davila has suffered and continues to suffer damages to both, her personal and
professional reputation and career, substantial emotional distress and anxiety.
51.

Unless enjoined and restrained by the order of this honorable Court, the

Defendants continued acts will cause the Plaintiff to incur irreparable harm that cannot
be adequately remedied by monetary damages. Thus, Plaintiff is entitled to a temporary
restraining order and preliminary injunctive relief to enjoin the Defendants from
crowning the successor to Plaintiff, de-facto Miss Florida 2017, Linette De Los Santos.
WHEREORE for the reasons set forth herein. Plaintiff asks this Honorable Court
to award her reasonable compensatory and special damages against Defendants, Gravitt
and Tel-Air, as the Court determines to be fair and reasonable, and temporary and
permanent injunctive relief as set forth above.

11

COUNT III: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

Plaintiff repeats, re-alleges, adopts and incorporates each and every allegation
contained in Paragraphs 1 through 42, as if fully set forth herein, and further alleges:
52.

This is a count for negligent intentional infliction of emotional distress.

53.

At all times herein, Gravitt owed a duty to Plaintiff and to all contestants

of the Miss Florida 2017, to treat each of them fairly and reasonably and with dignity.
Furthermore, Gravitt owed a duty to Plaintiff to refrain from publishing false
information about Plaintiff without sufficient proof or justification.
54.

Gravitt acted negligently and unreasonably in stripping Plaintiff of her title

and crown as Miss Florida absent any justifiably supported reason, the subsequent
actions in publicly chastising Plaintiff by accusing her of cheating, violating the rules of
the pageant, and otherwise being unqualified to carry the title and crown of Miss
Florida. By and through such actions, Gravitt has acted beyond all reasonable bounds of
decency, and negligently inflicted emotional distress upon Plaintiff.
55.

Gravitts conduct was negligent and the proximate cause for Davilas

suffering humiliation, mental anguish, and severe emotional distress, and was done with
wanton and reckless disregard of the effects and consequences to Davila,
56.

Unless enjoined and restrained by order of this Honorable Court, Gravitts

continued acts will cause the Plaintiff to continue to incur irreparable harm that cannot
be adequately remedied by monetary damages. Thus, Davila is entitled to a temporary
and permanent injunctive relief to enjoin the Defendants from continuing their actions.

12

WHEREFORE for the reasons set forth herein, Plaintiff asks this Honorable
Court to award her reasonable compensatory and special damages against Defendants,
Gravitt and Tel-Air as the Court determines to be fair and reasonable.
COUNT IV: DEFAMATION {PER SE)

Plaintiff repeats, re-alleges, adopts and incorporates each and every allegation
contained in Paragraphs 1 through 42, as if fully set forth herein, and further alleges:
57.

This is a count for Defamation Per Se against Defendants Gravitt and Tel-

58.

Davila is a professional beauty pageant model and has and continues to

Air.

enjoy mainstream popularity in her capacity as beauty pageant contestant, spokesperson,

and model. Davila has devoted a substantial amount of time and effort developing her
career, reputation, and brand. Such efforts have created considerable commercial value
in her name, image, identity, and persona.
59.

Gravitts fraudulent and slanderous statements about Davilas alleged

violations of the beauty pageant rules and the ultimate dismissal of her Miss Florida
2017 crown, title, and publicity rights, was for the Defendants advantage in that
I
Davilas name, image, likeness, identity, and persona were used and intended to create
and enhance the Defendants pecuniary gain and profit.
60.

Gravitt acted in order to continue to generate substantial profits derived

from the pageant, to protect and safeguard continuing public interest in their pageant,
and to masquerade the shoddy actions undertaken by the Gravitt and Tel-Air, borne out

13

of hidden financial agendas, all of which led to Plaintiff being stripped of her rightfully
earned crown and title, and the ensuing public smearing campaign against her.
61.

Any reasonable person would deduce from Gravitts false, public

comments, that the Plaintiff is a liar, cheater, and deceitfully gained her right to win the
crown and title of Miss Florida USA 2017, which has destroyed her goodwill and ability
to earn money in her chosen field.
62.

The statements made by Gravitt are completely and utterly false. Davila

did not commit any violations of any of the pageants purported rules.
63.

The Gravitts false and defamatory statements regarding Davila were

fabricated only for the Defendants advantage in that Davilas name, image, likeness,
identity, and persona were used and intended to ultimately create, enhance, and
ultimately protect the Defendants pecuniary gain and profit from their beauty pageant.
64.

As a direct and proximate result of the aforementioned acts by Gravitt,

Davila has suffered and continues to suffer injury, loss, damage, anxiety,
embarrassment, shame, and severe emotional distress.
65.

As a direct and proximate result of the aforementioned acts by Gravitt,

Davila has and continues to face ridicule, embarrassment, damage to her reputation as a
beauty pageant model, and severe harm to her ability to earn future monies in the
profession of her choosing.
WHEREFORE for the reasons set forth herein, Plaintiff, Davila prays for
judgment against Defendants, as follows:

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1.

For an award of general and special damages in an amount in excess of the minimum
jurisdictional limits of this Court ($15,000.00) in accordance with proof at trial
together with interest thereon at the maximum legal rate in an amount in excess of
$15,000,000.00; and

2.

For costs of suit incurred herein.

DEMAND FOR JURY TRIAL

Plaintiff, Davila hereby demands a trial by jury on all issues so triable.

Dated: A ugust 1 ,2016

Respectfully submitted,
WOLFE LAW MIAMI, P.A.

Counselfor Genesis Davila

Latitude One Building
175 SW 7,h Street, Suite 2410
Miami, Florida 33131
Telephone: 305-384-7370
Facsimile: 305-384-7371
By:

15

s Richard C. Wolfe
RICHARD C. WOLFE
Florida Bar No. 355607

EXHIBIT A

RULES AND REGULATIONS

I hereby apply as an m an in the MISS FLORIDA USA Pageant ("State Pageant"), and 1acknowledge and agree as
follows
1
I will be ai least eighteen (18) and under twenty-seven (27) years of age on January 1 o f the national Miss
USA Pageant
2
1 am not married, have never been married, and have never had a marriage annulled 1 have never given birth
to a child and I am not now pregnant nor am I a parent If any o f these conditions change. 1 will notify my
State Director immediate))', and 1 understand that this may affect my eligibihi)
2
1 have never participated in a previous national MISS USA Pageant
4
1 have not participated and will not participate in any other state pageant preliminary in ihc MISS USA
pageant system tins year
5
1 am o f good health and moral character.
6
1 represent and warrant that I am a female (recognized medically and legally as a female in the United States)
If my gender or sex designated at birth was not female, I represent and warrant that I have fully completed
sex reassignment and 1 have received and can provide legal recognition o f my assigned sex as female by the
U S Federal government or my U.S state of residence. Documents acceptable for such legal recognition
include driver's license or ID card issued by my state o f residence, birth certificate, U S Passport or Social
Security card.
7
1 am a citizen o f the United States I satisfy one o f the following residency and documentation requirements
a.
(1)1 now reside and have resided in my sate as my permanent and pnmary residence for period
o f at least (6) months immediately pnor to the beginning of my Preliminary pageant (although 1
may have attended college o r university elsewhere)
b
! have resided in my state as a full-time student at a college or a university for one entire semester
immediately prior to the beginning o f my state pageant and 1 am continuing to reside in my state
as a full-time student (although) may have spent or be spending the summer m another state.) In
order to establish my compliance with these residency requirements, 1 am attaching copies o f my
current driver license.
8
I agree that if selected to represent my preliminary in the MISS USA Pageant I will participate in the Pageant
and abide by all the rules and regulations governing that pageant
9
Neither I nor any member of my immediate family (i.e. mother, father, sister, or brother) or anyone living in
my household is current!)', or has within the last two (2) years been, employed by or an officer, director or
agent o f any of the following.
a.
You, any company or enterprise you own or control, or o f any company or enterprise under
common ownership or control with you; or
b.
Miss Universe, NBC Universal, Inc^ NBC West, LLC, Telemundo Network Group LLC
("Telemundo"), NBC Pageants, Inc., Mr. Donald J. Trump Pageants, Inc., Trump Hotels &
Casino Resorts Holdings, L.P., The Trump Organization, Ernst & Young, or, any o f the
subsidiaries, affiliates or related companies of the foregoing (including, without limitation, NBC
Studios, Inc., any NBC and/or Telemando owned television stations, CNBC, MSNBC, Bravo,
Trio. S a F i, and USA).
10. I agree that if ) wm or succeed to the state level title or the tide o f MISS USA, then 1 will not particpale in
any pageants during the time that I hold either o f those tides, unless authorized in writing by MISS
UNIVERSE, LP., LX.UP.
11. I hereby release, unconditionally and forever any claim against MISS UNIVERSE L.P., L.L.L.P , its parent
companies and either their respective officers, directors, partners, employees, agents, and assign, which I may
have by virtue o f my participation in my state pageant or by any use o f my name, likeness voice, and or
biography in connection with ray state pageant, including use in promotional and ad advertising materia)
12. I understand and agree that all issues as to eligibility shall be detennmod by MISS UNIVERSE L.P L.L.L.P
and, 1 agree to abide by that determination both as to myself and other applicants

FINAL A PrtlcA
X

UNE:

7)

Signature o f ^pplicant f S

~hlL
Date

Signature o f Parent or Guardian (If applicant is under (2)) twenty-one)

I hereby apply for entry into the MISS FLORIDA USA Pageant, and the opportunity to compete m the state
finals of the MISS FLORIDA USA Pageant
I understand and agree that my acceptance os a state finalist and my continued consideration for the title of
MISS FLORIDA USA is under the sole and complete discretion o f my State Pageant Director
I understand and agree that if selected as the winner, as one of my obligations. 1 wilt go to my host city
during the time required for me to appear in the MISS FLORDA USA Pageant
I agree to abide by all die rules o f the local, state, and, national contest now m effect or as announced
hereafter from time to tune,
I hereby agree that the site, date, time, production, manner and method of judging o f the local, state, and
national contests shall be solely within the discretion o f my State Pageant Director and the decisions o f the judges
shall be final.
I understand and agree that if I urn selected os the winner, nil decision* concerning production, promotion,
photographs, programs, appearances, and all the others aspects of the MISS FLORIDA USA Pageantfs), as well as
throughout my reign, are solely at the discretion of my Stnlc Pageant Director. (Tel-Air Interests, Inc.)
1 agree to permit my likeness, voice recording and name to lie used without charge for all purposes related to
the Pageants without charge in all media now known or may lie known m tltc future.
1 understand that I am free to withdraw from the competition t any tunc, bui under no circumstances will 1
be entitled to a refund or transfer to another contestant any lee. ailin' loll pan. that I or my sponsors have paid.
There wilt be absolutely no exceptions to this policy
1 agree that, if 1 am selected as the winner of my pugcmii, ilmilim one year Tram the day o f the selection my
professional affairs os said winner shall lie under the sote mid cmi|4cii management of my State Pageant Director
and that I will not give any written or verbal endorsement m am mercantile commodity or commercial or
charitable organization without obtaining specific written authority from the State Pageant Director
I agree that I will make no appearances whatsoever unless ollicm! authorization is granted by the state
pageant organization or its ogents. I understand and agree that doing so could result m the loss of my title and
return any and atl prizes awarded.
1 agree that 1will not incur, and am not uuthoriml to incur, any debts on behalf of the MISS FLORIDA USA
Pageant or Tei-Air Interests, Inc.
I voluntarily disclose that prior to the dote of this pogcam, I have not engaged m any activities, which if
disclosed to the public, would bring or tend to bring, myself into disrepute, ridicule, or contempt
1 acknowledge ownership of MISS FLORIDA USA by TEL-AIR INTERESTS, INC., and the validity of the
name MISS FLORIDA USA, and that 1 agree not to jeopardize such property rights in any manner whatsoever
Failure of the winning contestant to comply with any of the terms, provisions, restrictions, or obligations
hereof shall, at the option o f (TEL-AIR INTERSTS, INC.), result m entrants disqualification, loss of me and
return of any and all prizes awarded.
I hereby certify that I have read this official entry form and agree to be bound by all of the rules and
regulations listed. My signature below and your acceptance and agreement indicated by your signature shall
constitute this entry form a binding and agreement and contract between us
I understand that some prizes are awarded by Pageant Sponsors TEL-AIR INTERESTS, INC will extend
reasonable effort to see that Sponsors fulfil their obligations however TcLAir and the Miss Florida USA Pageant
assume no responsibility for the failure of the Sponsors to fulfil their commitment.
By the signature below, applicant and her parents or guardian certify that they have read and understand the
rules and regulations as set forth in paragraphs (1) through (11) and that the applicant meets die requirements and
will comply with the rules and regulations stated. Any untrue statement or failure to comply may result in
applicant's disqualification.
Mail Application, fulMength head to toe photo, Birth Certificate, School Identification and
Registration FcUtarr >
TEL-AIR INTERESTS, IN C
MISS FLORIDA USA HEADQUARTERS
2040 Sherman Street Hollywood, FL 33020
Telephone: 954-924-4949 Fax: 954-924-4980
Email: telair@aol.com
Make Check payable to Tel-Air Interests, Inc.
MISS TEEN USA. MISS USA, and MISS UNIVERSE ore trademarks and service marks o f MISS UNIVERSE, L.P,
LLL.P.

EXHIBIT B

Dear Miss Universe Staff,

A night that was suppose to be a memorable one for me, one that should have
brought me great joy instead has brought me dismay, sadness, confusion and heart
break. Since day one, I felt all eyes were on me as if 1was being scrutinized for just
trying to be me. I admit I may not be the perkiest contestant and can see other
ladies mistaking that as being unfriendly or aloof but don't confuse my indifference
with being antisocial or a Diva. I suffer from chronic depression and anxiety as you
may or may not and have founded an organization raising awareness over
depression so that others don't feel they are alone. To send the message out that we
even with depression are functional and capable members in society. So for me, it's
a challenge to even get out of bed but I battle through it. So I can show others they
can too. They don't have to give in to this illness. So you can imagine my greater
sadness when after winning the crown, I was accused, judged, yelled at for things I
never did or participated in.
Just because one or two ladies decided to start a rumor that wasn't true about me
breaking the rules doesn't mean they are true. In fact, there were a group of girls
who are part of PR coaching team that from the beginning were attacking me, one
being my roommate who happens to belong to that coaching team. I can understand
their frustration since money may come into play for that coaching team and
understand that for them its a business. Next thing I know, the rumor spread like
wild fire and turned into a lynching mob. The worse thing is that I wasn't even given
a chance to voice or admit or deny any of the rumors. Well I am doing that now. I
did not break any rules. I never left the property.
The fact that I was convicted without a fair trial of sorts hurt me in ways I could
never explain to you and has damaged my inner being but as always I am a fighter
and will not allow the envy of others or financial gain of others get the best of me.
Yes I was born in Puerto Rico but I am an American citizen who resides in Florida. I
always believed that the United States was a country where one was innocent until
proven guilty. So far my experience has been the opposite this past weekend's
pageant. I am being condemned as guilty by my peers without having a chance to be
proven innocent I ask you to take a step back and examine the facts. I am a
professional model who knows how to do her own hair and make up. 1dont need
anyone to do it for me. Why would I? I was told that so many have accused me of
having my hair, nails and make up done by professionals. First off, how could I have
left the hotel at any time? I never left the property. With the rigorous pageant
schedule how could I even have had the time or opportunity to get any of it done?
How could all multiple ladies that accuse me of such false ideals be anywhere
around me at the same time to confirm that I had left to get my hair done? Were all
20 ladies there with me when I 'supposedly' went to get my hair done and nails? No
they werent because it did not happen. The facts are the facts. Reasoning is reason.
It comes down to my word against another contestants words and self interest and
the rumors she has spread.

I knew I wasnt liked from day one. I felt it. And again perhaps they misinterpreted
my indifference from depression as a divaish behavior. But I can assure that I am
not. I also was mocked during competition by some of the ladies and over heard
certain ladies question what I was even doing there. That I should be in the Miss
Puerto Rico pageant not in the US system. I consider myself both a proud American
Puerto Rican. I work hard for what I have each day while facing depression and
perhaps they are not at fault for not understanding the difference between seeing
someone with depression and someone who is antisocial. All the more reason why I
need to bring even more attention than ever attention to my cause, so that other
teens, women and society won't scrutinized or judge others if their behavior doesnt
fall into the norm or what society deems it or defines it to be. I am responsible for
my behavior, every day of my life, but I am NOT responsible on how others perceive
my behavior to be.
To have my crown taken away for just here say and hurtful, false rumors would not
only be unfair and unjust to me but to the crown itself and would put in jeopardy
what this organization and country stands for, innocent until proven guilty and
being scrutinized and judged over an illness one may be ignorant or unfamiliar with.
Apparently the ladies and some staff have had their say. I must admit the way it was
brought up to my attention has also been unjustifiable and damaging unforgettable.
But I have learned to not judge others impulsive behaviors and actions as I would
expect for them to not judge mine without having all the facts first.
I was asked to write a letter to explain my behavior. But I am still in turmoil not
truly understanding what I am defending or what I am having to explain? All the
accusations are false and it saddens me to even have to write this letter to you
explaining my point or defending my case, one that does not exist. I understand the
final choice is yours, having to choose one persons word over anothers (and their
team of coaches) as the rumors spread. All I know is that I would make Miss USA
and not because I think highly of myself but because I know I have a strong message
to convey to others, this experience has only validated that! I will take this as a life
lesson, a human lesson, that in this life their is truly only one person you can trust in
this world, yourself.
Kind regards,
Genesis Davila