IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT. IN AND FOR DUVAL COUNTY. FLORIDA

STATE OF FLORIDA, OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS,

Plaintiff,

v.

BROOK ANTHONY ROQUE, ANTHONY RENE ROQUE, GLENDA CHESTER ROQUE, KASSAUNDRA ANN BUTTRAM, and MICHELLE LEE ECHOLS, d/b/a as Five Star Bulldogs, Grand Bulldogs, Matrix Bulldogs, Brook's Bullies, and Remarkabull,

Defendant.

Case No. : 16-2014-CA-5031

Division: CV-G

CONSENT JUDGMENT AND ORDER

It is hereby ordered, adjudged and decreed, pursuant to and in accordance with the

Stipulation for Entry of Consent Judgment and Order entered into by and between the plaintiff,

State of Florida, Office of the Attorney General, Department of Legal Affairs ("OAG"), and

Defendant KassaundraAnn Buttram, ("Defendant"), as follows:

FINDINGS

A. This Court has jurisdiction over this matter. Venue in the Fourth Judicial Circuit is

proper.

B. The Complaint states a claim upon which relief may be granted against Defendant under

the Florida Deceptive and Unfair Trade Practices Act ("FDUTPA"), Chapter 501, Part II,

Florida Statutes (2013). § 501.207, Fla. Stat. (2013); § 501.2075, Fla. Stat. (2013);

§ 501.2077, Fla. Stat. (2013).

C. Defendant waives the right to appeal or otherwise contest the validity of this Order.

D. Defendant agrees to bear her own costs and attorneys' fees.

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Definitions

For purposes of the Order, the following definitions apply:

E. "Person" means any natural person, an organization or other legal entity, including a

corporation, partnership, sole proprietorship, limited liability company, association,

cooperative or any other group or combination acting as an entity.

F. "Advertisement," or "advertising" means any written, verbal statement, illustration, or

depiction designed to effect a sale or create interest in the purchasing of goods or

services, whether it appears in a book, brochure, newspaper, magazine, pamphlet,

leaflet, circular, mailer, book insert, free standing insert, letter, catalogue, poster, chart,

billboard, public transit card, point of purchase display, packaging, package insert, label,

film, slide, radio, television or cable television, audio program transmitted over a

telephone system, program-length commercial ("infomercial"), the Internet, email,

social media, applications for smartphones, press release, video news release, or in any

other medium.

G. "Defendant's Property'' means any property that the Defendant resides in, owns, rents

or has the ability to control.

H. "Household Pet" means any dog acquired or kept by the Defendant that is not used for

breeding, naturally or artificially, or used to impregnate any other dog naturally or

artificially.

I. The terms "and" and "or" shall be construed conjunctively or disjunctively as necessary,

to make the applicable sentence or phrase inclusive rather than exclusive.

J. The term "including" means "including without limitation."

INJUNCTION

Prohibited Practices

It is further ordered that:

1. As of the date of the execution of this Order, the Defendant is permanently

enjoined to not, either directly or indirectly through any other person, agent,

employee, servant, officer, representative, successor, partner, assigns, sole

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proprietorship, corporation, limited liability company, subsidiary, branch, trust

or other entity:

1.1. Advertise, solicit, breed, import, offer for sale or sell dogs.

1.2. Use third parties, other persons or agents, in order to import, breed, sell,

solicit, offer, or advertise dogs for sale.

1.3. Act as a third party or agent for another person in order to assist other

persons to import, breed, sell, solicit, offer, or advertise dogs for sale.

1.4. House on Defendants' Property any dog other than a Household Pet.

1.5. Advertise, solicit, offer for sale, sell, or allow the use of a Household Pet

for any reproductive purpose.

1.6. Acquire or keep any dog other than a Household Pet.

MONETARY JUDGMENT

Consumer Restitution. Civil Penalty and Attorneys' Fees and Costs

It is further ordered that:

2. Judgment in the amount of $2,400.00 is entered in favor of the OAG against

Defendant for consumer restitution. Defendant is ordered to pay $2,400.00 to

the OAG payable to the Department of Legal Affairs Revolving Trust Fund, for

consumer restitution, pursuant to section 501.207(3), Florida Statutes, and

pursuant to the schedule, terms, and conditions set forth below:

2.1. Defendant is ordered to pay $1,600.00 to the OAG within seven business

days of entry of this Order.

2.2. Defendant agrees to have Vystar Bank transfer $337.29 from two

accounts to the OAG as payment for consumer restitution. Within seven

business days of entry of this Order, Vystar Bank is ordered to transfer to

the OAG by electronic funds transfer from the Defendant's two accounts

with VyStar Bank the following amounts: VyStar Checking Account No.

XXXXXX3024 in the amount of $286.03, and VyStar Savings Account No.

XXXXX7856 in the amount of $51.26. The OAG will provide Vystar Bank

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within two business days with the electronic fund transfer instructions

and a copy of this Order.

2.3. Defendant's restitution amount after payment of Paragraphs 2.1 and

Section 2.2 is $462. 71.

2.4. The Defendant is ordered to pay the remainder of the balance by making

monthly payments on the 5th day of each month beginning on August 5.

2015. The amount for August 2015 will be $200 and the amount for

September 2015 will be $262.71.

3. Judgment in the amount of $10,000.00 is entered in favor of the OAG against

Defendant for attorneys' fees and court costs. Provided however, the OAG agrees

to partially suspend the judgment to the amount of $2,000 provided the

following:

3.1. Defendant is ordered to pay $2,000.00 to the OAG payable to the

Department of Legal Affairs Revolving Trust Fund, for attorneys' fees and

costs, pursuant to sections 501.2101(1), and 16.53, Florida Statutes, in

monthly installments. The Defendant is ordered to pay monthly

payments on the 5th day of each month beginning on October 5. 2015.

The amount for October 2015 through July 2016 will be $200 per month.

Defendant will not be penalized for making payments early or in excess

of the amount ordered.

3.2. Defendant makes payment of $2,400.00 for consumer restitution, in

accordance with the schedule and all terms and conditions set forth in

paragraphs 2.1 through 2.4 above.

3.3. Defendant adheres to the injunctive provisions in paragraphs 1.1

through 1.6 of this Order.

3.4. If, upon motion by the OAG, the Court finds Defendant failed to comply

with any of the provisions in paragraphs 3.1 through 3.3, then the Court

shall reinstate the judgment against Defendant, in the full amount of

$10,000.00, less any payment previously made pursuant to paragraph

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3.1, plus interest computed from the date of entry of this Order, which

amount shall become immediately due and payable by the Defendant.

4. Judgment in the amount of $6,000.00 is entered in favor of the OAG against

Defendant, as civil penalty, pursuant to section 501.2075, Florida Statutes.

Provided however, the OAG agrees to suspend the judgment of civil penalty in its

entirety provided the following:

4.1. Defendant makes payment of $2,400.00 for consumer restitution, in

accordance with the schedule and all terms and conditions set forth in

paragraphs 2.1 through 2.4 above.

4.2. Defendant makes payment of $2,000.00 for attorneys' fees and costs, in

accordance with the schedule and all terms and conditions set forth in

paragraph 3.1 through 3.3 above.

4.3. Defendant adheres to the injunctive provisions in paragraphs 1.1

through 1.6 of this Order.

4.4. If, upon motion by the OAG, the Court finds Defendant failed to comply

with any of the provisions in paragraphs 4.1through4.3, then the Court

shall reinstate the judgment against Defendant, in the amount of

$6,000.00, plus interest computed from the date of entry of this Order,

which amount shall become immediately due and payable by the

Defendant.

5. Defendant relinquishes dominion and all legal and equitable right, title, and

interest in all assets transferred to the OAG pursuant to this Order and may not

seek the return of any assets.

ADDITIONAL TERMS

Compliance Reporting

It is further ordered that:

6. Defendant shall submit to the OAG, for the two (2) years after the execution of

this Order, if applicable, signed and sworn to under penalty of perjury:

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6.1. Any changes in Defendant's residence, mailing addresses, and telephone

numbers, within thirty (30) days of the date of such change; and

6.2. Any changes in Defendant's employment status (including self­

employment), and any change in Defendant's ownership in any business

entity, within thirty (30) days of such change. Such notice shall include

the name and address of each business that Defendant is affiliated with,

employed by, creates or forms, or performs services for; a detailed

description of the nature of the business; and a detailed description of

Defendant's duties and responsibilities in connection with the business

or employment; and

6.3. Any changes in Defendant's name or use of any aliases or fictitious

names, within thirty (30) days of such change.

6.4. The Defendant must send the notices in paragraphs 6-8 via first class

mail and electronic mail to:

Office of the Attorney General Consumer Protection Division Attention: Jacek Stramski PL-01, The Capitol Tallahassee, FL 32399 jacek.stramski@myfloridalegal.com

Dismissal of Civil Action

7. The OAG will file with the Clerk of Court a Notice of Dismissal with Prejudice

dismissing the pending Civil Action against Defendant Kassaundra Ann Buttram

within thirty (3 0) days of the last monthly payment.

Effective Date and Scope of Judgment

8. This judgment shall be binding and effective upon entry by the Court, and the

clerk is ordered to enter the Judgment immediately upon filing.

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Denial of Liability

9. Defendant has not admitted any of the allegations set forth in the Complaint, and

entry of this Order is not an admission of any such allegations of wrongdoing or

violation of law. Nonetheless, Defendant stipulates and agrees to entry of this

Order in order to settle and resolve this dispute.

No Authorization of Conduct

10. Neither Defendant nor anyone acting at Defendant's direction will state or imply

or cause to be stated or implied that the OAG or any state agency or officer has

approved, sanctioned, or authorized any practice, act or conduct of the

Defendant.

No Responsibility for Other Defendants

11. It is understood and agreed between the Parties that the stipulation and

agreement to entry of this Order is not conditioned on the settlement of any

other Defendant(s) to this action, specifically Brook Anthony Roque, and/or

Michelle Lee Echols, (collectively referred to as the "Other Defendants"). In the

event any or all of the Other Defendants fail to reach a settlement with the OAG,

or violate the terms of any settlement reached with the OAG in the Civil Action,

the OAG expressly agrees not to take any action against Defendants or to seek

collection from Defendants of any sums owed by the Other Defendants,

individually or jointly.

Relief from Asset Freeze

It is further ordered that within ten business days of this Order,

12. The freeze on the Defendant's assets entered on or about July 21, 2014 under the

Order Granting Temporary Injunction with Asset Freeze without Notice shall be

dissolved.

13. The OAG will provide notice of this Order to any Third Party Asset Holder

advising the asset holder that the Temporary Injunction no longer applies to

Defendant or her assets.

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14. Kassaundra Ann Buttram is hereby relieved from any and all obligations under

the Order Granting Temporary Injunction with Asset Freeze without Notice

entered on or about July 21, 2014.

15. Any and all Third Party Asset Holders of Kassaundra Ann Buttram, including but

not limited to Vystar Bank, are hereby relieved of any duties as Third Party Asset

Holders set forth in the July 21, 2014 Order Granting Temporary Injunction With

Asset Freeze Without Notice, as to any and all accounts held by Kassaundra Ann

Buttram.

No Limitation of Remedies

16. The remedies provided herein do not limit any other remedies that Defendant's

customers may have under law.

Waiver of Exemption to Garnishment

17. Defendant shall be liable to the OAG for reasonable attorney fees and costs in

any garnishment proceeding, initiated to collect monies due under this Consent

Judgment, in which assets owed to Defendant are garnished.

18. Defendant agrees to sign the waiver of exemption to garnishment, attached to

this Order as Attachment A.

Retention of Jurisdiction

19. It is further ordered that this Court retains jurisdiction of this matter for

purposes of construction, modification, and enforcement of this Order.

ORDER ENTERED So ordered this __ day of ____ _, 2015:

JUL 0 2 2015

Isl LAWRENCE P. HADDOCK

Circuit Judge

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Approved as to Form and Content:

State of Florida. Office of the Attorney General. Department of Legal Affairs

Pamela Jo Bondi

;a;:algvA_ Laura Boeckman, Florida Bar 527750 Bureau Chief - North Region State of Florida, Office of the Attorney General, Department of Legal Affairs 1300 Riverplace Blvd., Suite 405 Jacksonville, FL 32256 Phone Number: (904) 348-2720 Facsimile: (904) 858-6918 Laura.Boeckman@MyFloridaLegal.com

,2015

Defendant

~!JOO i HJ£!k0 kTuun *,u Kassaundra Ann Buttram

Dated: ©.ru. l \ . 2015

~41177211 Casey Woolsey Attorney for Defendant Kassaundra Ann Buttram Tassoe & Dreicer, LLC

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1833 Atlantic Blvd. Jacksonville, FL 32207 Phone Number: (904) 396-3344 Facsimile: (904) 396-3349

Dated :c:Ju;tt,_,_/---l7~ _ __,. 201 S

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ATIACHMENT A

WAIVER OF GARNISHMENT EXEMPTION PURSUANT TO SECTION 222.11, FLORIDA STATUTES

This waiver applies to any garnishment proceeding initiated to collect monies due under the attached Consent Judgment entered into by Kassaundra Ann Buttram, and the State of Florida, Office of the Attorney General.

IF YOU, KASSAUNDRA ANN BUTIRAM, PROVIDE MORE THAN ONE-HALF OF THE SUPPORT FOR A CHILD OR OTHER DEPENDENT, ALL OR PART OF YOUR INCOME IS EXEMPT FROM GARNISHMENT UNDER FLORIDA LAW. YOU CAN WAIVE THIS PROTECTION ONLY BY SIGNING THIS DOCUMENT. BY SIGNING BELOW, YOU AGREE TO WAIVE THE PROTECTION FROM GARNISHMENT.

~ J.. )/l o0 fke-t, i p~ "ll..t\O, 11 I 1...()) 5 Buttram Date

I have fully explained this document to Kassaundra Ann Buttram

[ nsel f Kassaundra Ann Buttram / if none, Counsel for OAG]

STATE OF FJo~/a(q_, COUNTY OF ht-< vaJ

lt/11/ l ff Date

Kassaundra Ann

BEFORE ME, an officer duly authorized to take acknowledgments in the State of F/or1dfi:.; personally appeared li£!$6ti.-l.Lhe~rtt. ~allf]and acknowledged before me th~ he/she executed the foregoing instrument for the purposes therein stated, on this fl!!!._ day of

...... Jutll . 2015.

-~ Sworn to and subscribed before me this JL day ofJbi n~ 2015.

1 1 ~()""'~\~~8(0 TINA WJLKIN.$0N J//d//)t/Jl11: ~/1 •• ' * MY COMMISSION# EE 176072 ~ . av/' ( * EXPIRES: March 6, 2016

NOTARY PUBLIC '1';;,,.~0f,lo'f>'"" eondedThNBudgelNotaiySerricu

(Print, type or stamp commissioned name of Notary Public) Personally known_ or Produced Identification __ (check one) Type of Identification Produced:

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