Case Number:19-002748-CI

Filing # 8831 1984 E-Filed 04/22/2019 01 :05z49 PM

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA

MONTEREY CAPITAL, LLC,

a Florida limited liability company
Case No.2
Plaintiff,

v.

SEAN CERUTI and GAVIN BRIDGEFORTH

Defendants.
/

COMPLAINT

Plaintiff, MONTEREY CAPITAL, LLC, by and through his undersigned counsel, sues
Defendants, SEAN CERUTI and GAVIN BRIDGEFORTH (collectively “Defendants”), as
follows:

1. This is an action for damages in excess of $15,000.00, exclusive of pre-judgment

interest, court costs, and attorney’s fees.

2. Plaintiff, MONTEREY CAPITAL, LLC (“DUGGAN”), is a Florida limited

liability company with its principal place of business in Pinellas County, Florida.

3. Defendant, SEAN CERUTI (“CERUTI”), is an individual residing in Pinellas

County, Florida.

4. Defendant, GAVIN BRIDGEFORTH (“BRIDGEFORTH”), is an individual

residing in Pinellas County, Florida.

5. Jurisdiction is proper in Pinellas County, Florida pursuant to § 47.01 1, Florida

Statutes.

6. Venue is proper in Pinellas County, Florida.

7. On or about March 31, 2018, CERUTI and BRIDGEFORTH executed and

delivered a Promissory Note (“Promissory Note”) in favor of DYLAN DUGGAN in the

***ELECTRONICALLY FILED 04/22/2019 01:05:48 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
principal amount 0f $1,3 80,000.00. A copy of the Promissory Note is attached hereto as Exhibit
“A”.

8. Plaintiff is the legal and equitable owner and holder of the Promissory Note by

virtue of an Assignment, attached hereto as Exhibit “B”.

9. Pursuant to the terms of the Promissory Note, Defendants were to pay the

principal balance to Plaintiff in full within 60 days of March 3 1, 2018.

10. To date, Defendants have failed and or refused to pay the balance owed on this

promissory note.

11. All conditions precedent to this action have been performed, waived, excused, or

otherwise discharged.

12. Plaintiff has retained the undersigned counsel to represent its interests in thi's

action and is obligated to pay their reasonable attorney’s fees and costs incurred herein.

COUNT I - BREACH 0F PROMISSORY NOTE

13. Plaintiff hereby realleges and incorporates herein his allegations set for in

paragraphs 1 through 12.

14. This is a cause of action for breach of a Promissory Note against Defendants.

15. Defendants executed a Promissory Note wherein Defendants agreed to pay the

principal balance due on the Promissory Note within 6O days of March 31, 201 8.

16. Plaintiff has fully performed his duties and obligations under the Promissory

Note.

17. Defendants have breached their obligations under the Promissory Note by failing

and/or refusing to pay the Principal balance owed.

18. Plaintiff has declared the full amounts due under the Promissory Note.
 19. Defendants owe Plaintiff the remaining principal amount of $885,000.00, plus

accrued interest, attorney’s fees, and expenses for the filing and prosecution of this action.

WHEREFORE, Plaintiff, MONTEREY CAPITAL, LLC, respectfully requests that this

Court enter a final judgment against Defendants, SEAN CERUTI and GAVIN BRIDGEFORTH,

awarding it principal and interest due under the Promissory Note, reasonable attorney’s fees and

court costs, and any such other, further and supplemental relief as this Court may deem just and

proper under the circumstances.

Dated this fiday of April, 2019.

GOLDBERG LAW GROUP, P.A.

Gl ,
Esq.
FB 1 94 SPN: 02015571
Pamela Konover, Esq.
FBN 125049
Primary E-Mail: glenn@goldberglaw.us
Secondary E-Mail: pamgngldberglawus
2 1 6 Mirror Lake Drive North
St. Petersburg, Florida, 33701
Phone: (727) 898-5200
Fax: (866) 323-6096
Counselfor Plaintiff
MONTEREY CAPITAL, LLC
 Promissory Note

This document is to review the ending of the partnership between Dylan Duggan, Sean Ceruti
and Gavin Bridgeforth involving Affluence Capital Management LLC.

Dylan Duggan entered a partnership agreement with Sean Ceruti and Gavin Bridgeforth. His
responsibility was to provide $1,380,000 for the purpose of achieving profits through various
ventures. In exchange he was entitled to 50% of the profits that were achieved.

Sean Ceruti and Gavin Bridgeforth of Affluence Capital Management have decided to terminate
and return Dylan Duggan the $1,380,000. This money
this partnership shall be paid to Dylan
Duggan within 60 days from ()2 / El /M
If Sean Ceruti and Gavin Bridgeforth fail to pay back the full amount above within the 60 days
they shall owe 1% in interest per month (30 days) on the remaining balance. This shall be paid
on the 1* day of every month that the money is not fully restored.

By signing below both parties have read and understand this Promissory Note.

Dylan Duggan -

Sean Ceruti

/V"

W
Date Gavin Bridgeforth

——J"3 ——13‘
W;
V /\/V
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Date

EiJflJifil ‘>

Exhibit "A"
 ASSIGNMENT 0F A CLAIM FOR DAMAGES

This Assignment of a Claim for Damages (the “Agreement”) ls made and effective this 6‘“ day of
November 201 8,

BETWEEN: Dylan Duggan (the ‘Assignor'), an individual residing at 1740 Gulf Blvd,
Belleair Beach, FL 33786.

AND: Monterey Capital, LLC (the 'Assignee'), a corporation organized and

existing under the laws ofthc Florida with nts head omce located at: 200 Central Avenue, Suite
2000, Saint Petersburg, Florida 33701.

FOR VALUE RECEIVED, the Assignor hereby sells and transfers to the Assignee and its
successors, assigns and personal representatives, any and all claims, demands, and cause or
causes of action of 'any kind whatsoever which the undersigned, has or may have against Sean
Ceruti, Gavin Bridgcforth and Affluence Capital Management jointly and severally, arising fi'om
the following type claim:

A reement/ craters 1i
o' t V tur n a ted 1

A rel cu es
'
n

And the undersiymed may in its own name and for its own benefit prosecute, collect, settle,

compromise and yam releasw on said claim as it in its sole discretion deems advisable.
IN WITNESS WHEREOF, the parties have executed this Assignment on the day and year first
above written.

Signed, sealed and delivered in the presence of:

Assmmpz
Assn; 0R '

Dyla h@(n ~
Glenn behave.)
Monterey Capital, LLC.

Witness:

Witness:

Exhibit "B"