Filing # 75788083 E-Filed 07/31/2018 05:24:14 PM. IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE NO. PR NEWSWIRE ASSOCIATION LLC, Plaintiff, vs. MIDAM VENTURES LLC, a Florida limited liability company, Defendant. / COMPLAINT Plaintiff, PR NEWSWIRE ASSOCIATION LLC, sues Defendant, MIDAM VENTURES LLC, a Florida limited liability company, and alleges: 1. This action is for damages that exceed $5,000.00 but do not exceed $15,000.00 in amount. 2. Venue is proper in Miami-Dade County, Florida, 3 Defendant, MIDAM VENTURES LLG, is a Florida limited liability company, with its principal place of business in Miami-Dade County, Florida. 4. All conditions precedent have occurred. COUNT! OPEN ACCOUNT 5. Plaintiff realleges and incorporates herein paragraphs 1 through 4 by reference. 6 Plaintiff and Defendant had business transactions between them which involved communication services.CASE NO. 7. Anaccount existed between Plaintiff and Defendant in which the parties had a series of charges, payments, and adjustments. 8. Plaintiff prepared an itemized statement of the account. 9. Defendant owes Plaintiff $13,784.00, plus interest, which became due on ‘September 23, 2017, in accordance with the attached account marked Composite Exhibit "RY Wherefore, Plaintiff demands judgment for damages against Defendant, plus court costs pursuant to Florida Statutes Section 57.041 and prejudgment interest, COUNT II UNJUST ENRICHMENT 10. Plaintiff realleges and incorporates herein paragraphs 1 through 4 by reference. 11. Plaintiff provided communications services to Defendant from March 3, 2017 through August 24, 2017 according to the attached statement marked Composite Exhibit “ 12. Defendant had knowledge before and after of the communication services that Plaintiff provided 13. Defendant benefitted from the services that Plaintiff provided, 14, Plaintiff has incurred costs in providing the communication services and it ‘would be inequitable for the Defendant to benefit from Plaintiffs labor and costs without paying fair value in exchangeCASE NO. Wherefore, Plaintiff demands judgment for damages against Defendant, plus court costs pursuant to Florida Statutes Section 57.041 and prejudgment interest. Poeareo13a Markowitz, Ringel, Trusty & Hartog, P.A. Plaintiff's Attorneys 9130 South Dadeland Boulevard Two Datran Center, Suite 1800 Miami, Florida 33156-7858 Phone: (305) 670-5000 Fax: (305) 670-5011 Primary Email: commlitservice@mrthlaw.com Is Thomas Ringel (Electronically Signed Thomas Ringel Florida Bar No. 220738 Secondary Email: tringel@mrthlaw.com