Filing# 191994680 E-Filed 02/14/2024 09:07:27 PM

IN THE CIRCUIT COURT FOR THE 17th JUDICIAL CIRCUIT

IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-22-007895

VER VER ENTERTAINMENT, LLC,

Plaintiff,

VS.

KISEAN ANDERSON, A/K/A

SEAN KINGSTON"
cir

Defendant.
i

COMPLAINT

VER
Plaintiff, VER ENTERTAINMENT, LLC., ("Ver Ver" or "Plaintiff'),
by and

through undersigned counsel, hereby sues Defendant, Kisean Anderson, a/k/a Sean Kingston.

("Anderson" or "Defendant"),and in support thereof states as follows:

PARTIES, JURISDICTION, AND VENUE

1. This is an action for damages of more than fiftythousand dollars ($50,000.00)

attorneys'fees,and litigation
exclusive o f interest, costs.

2. Plaintiff,Ver Ver is a Florida corporationthat regularlytransacts business in

Broward County, Florida.

3 Defendant, Kisean Anderson, a/k/a Sean Kingston is an individual who resides in

Broward County, Florida.

4. Plaintiff and Defendant entered into a contract for the sale and installation of a 232-

inch television into Defendant's residence in Broward County, Florida. Defendant's breach ofthis

contract and associated conduct, as fullyset forth below, forms the basis of Plaintiff's Complaint.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2024 09:07:25 PM.****
 INTRODUCTION

5. Plaintiff is a nationallyrenowned corporationthat sells and installs high end

television and sound systems.

6. Defendant is a nationallyknown recording artist and uses his stage name "Sean

Kingston" while conductinghis business affairs.

7. On September 23,2023, Defendant contacted Plaintiffvia Instagram and expressed

an interest in one of Plaintiff's premierproducts,a 232-inch Colossal TV, coupled with a robust

sound system.

8 In connection with the purchase of the Colossal TV and sound system, Defendant

made numerous false to Plaintiff.

representations

9- Defendant alleged that he had a current and ongoing working relationshipwith

recordingartist Justin Bieber.

10. To induce Plaintiff to accept a much lower down payment and credit towards the

purchase price, Defendant promised Plaintiff that he would produce promotional videos of

Plaintiff' s corporationwith Mr. Bieber.

11. Defendant had no ongoing working with Mr. Bieber, nor did Defendant and Mr.

Bieber have any intention o f producing promotionalvideos o f Plaintiff's corporation.

12. Defendant made these false statements to induce Plaintiff into installing
a 232-inch

Colossal TV and sound system with as small a down payment as possible.

13. Defendant never had any intention of paying Plaintiff in full for its Colossal TV

and sound system.

14. Shortly thereafter,Plaintiff and Defendant entered into a contractual agreement,

attached hereto as Exhibit A.

2
 15. On November 15, 2023, Defendant wired Plaintiff $30,000.00 to commence

manufacturing ofthe 232-inch Colossal TV.

16. On December 14, 2023, Plaintiff completely performed its contractual obligations

the 232-inch Colossal

by installing TV and sound system at Defendant's residence at 4610 S.W

178th Avenue, Fort Lauderdale, FL 33331.

17. On December 17, 2023, Defendant met Plaintiff at his residence to fullyexplain

how the Colossal TV and sound system worked.

18. Defendant was fullysatisfied with both the functionality

and installation of the

Colossal TV system and signed documentation confirmingthe same. See Exhibit B.

19. As per the Contract, Defendant was obligatedto pay Plaintiff in full upon

installation of the Colossal TV and audio system.

20. Defendant immediately breached the Contract by failingto pay Plaintiff as

contractually
agreed.

21. Defendant then began providing a litanyof excuses as to why payment wasn't

made.

22. On January 15, 2024, Defendant sent Plaintiff a NOVO alert advising that

Plaintiff' s remaining balance was forthcoming.

23. Plaintiff's were false, and no money was ever transferred

representations to

Defendant.

24. On January 29, 2024, Defendant arranged for Plaintiff to come to Defendant's

residence and to pick up a check for the full outstanding

balance of the Contract.

25. When Plaintiffarrived at Defendant's residence,he was met by Defendant's cousin,

who advised that no one else was at the residence,and that he knew nothing about a check.

3
 26. Plaintiff and Defendant spoke that same day. Defendant apologized and arranged

for Plaintiff to return to Defendant's residence to pick up a check for payment in full.

27. Once again, Plaintiff returned to Defendant's residence, and was met by

Defendant's cousin. Once again,Defendant's cousin had no knowledge as to Plaintiff's alleged

check.

28. Unbeknownst Defendant has a long historyof engaging in fraudulent

to Plaintiff,

conduct.

29. In 2015, judgment was entered against Defendant for obtaining $356,000.00 in

watches without paying for them.

30. In 2016, judgment was again entered against Defendant when he obtained

$301,500.00 in jewelry without paying for it.

31. Again in 2022, Defendant was sued for obtaining two luxury watches worth

$1,054,107.50 and failingto pay for them.

32. Additionally, at all material times that Plaintiff and Defendant were

communicating, Defendant was at that time and will remain on felonyprobation for trafficking

in stolen property.

33. All of Defendant's misrepresentationswere designed to add Defendant to

Plaintiff's list of victims.

COUNTI
DEFENDANT'S BREACH OF CONTRACT

34. Plaintiff offered to sell Defendant a 232-inch Colossal TV and sound system for

the terms contained within the Contract. See Exhibit A.

35. Defendant agreed to Plaintiff's terms and gave Plaintiff$30,000.00as a depositto

commence the project.

4
 36. Plaintiff fullycomplied with its contractual obligations the 232-inch
by installing

Colossal TV and sound system in Defendant's residence. See Exhibit B.

37. Defendant breached the Contract by failingto pay for the Colossal TV and sound

system as agreed.

38. As a direct result ofPlaintiff's contractual breach, Defendant has suffered monetary

damages as set forth above.

COUNT II
FRAUD

39. Defendant made numerous false statements to Plaintiff as stated above.

40. Defendant representedthat he would pay for the Colossal TV and sound system in

full upon installation. Plaintiff had no intention of doing so.

41. Defendant representedthat he would make promotional videos with Mr. Justin

Bieber for Defendant's business when Plaintiff knew full well that he would not and could not do

SO.

42. Defendant representedto Plaintiff that he was transferring

money to Plaintiff via

NOVO, when he knew that he was not.

43. relied upon Defendant's false statements.

Plaintiffjustifiably

44. As a result of relyingon Defendant's false statements, Plaintiff was damages by

agreeingto a discounted pricefor the Colossal TV and audio system and providingthe system in

for
its entirety only $30,000.00.

WHEREFORE, requests that this Honorable Court enter judgment in favor of

Plaintiff,

Plaintiff and againstDefendant for treble damages, reasonable attorneys'fees and litigation
costs;

for statutory interest from the date of breach to the present and continuing;reimbursement for

incurred attorney'sfees;for injunctive such conduct in the future;and such other

reliefprohibiting

5
and further relief as this Court deems proper.

Plaintiff demands a Trial by Jury.

ith
Respectfullysubmitted this 14 day of February, 2024.

/s/ .J. Dennis Card jr.

J.Dennis Card, Jr.,Esq. (FL Bar No: 0487473)
E-mail: dennis@cloorg.com
CONSUMER LAW ORGANIZATION, P.A.
721 US Highway 1, Suite 201
North Palm Beach, Florida 33408
Telephone: (561) 822-3446
Facsimile: (305) 574-0132

Attorneyfor Plaintiff

6
Exhibit "A"

7
 Imfo/explmled ty
PAOFORMA INVOICE
JIHE M??ner
5?owr.' 81wd. Boca Raton
Ftorlda. ?nltcd State

.**:
Tax ld:
Sean Kinsgtol
QUOI' 2823*j- - e&933 - 05
Addre*? P,01 Kt: COLO55AL TV C-232 KONG
Space: LIVING ROOM
..r.*t: 82,
Dltall: 5/rles 150
mmn.InA.DGs
Tel.

BUDGET -
Description of prodats and service;

COLOSSALTV
SEAN KINGSTON ECITION

7-1 GOLD FRAME SKIN

t!2**2!!L oe. UNIT P=.E , PCS.=..tl ,-#-#ULS

COLOSSAL TV C-232 MODULE 201 57 113 39 USD 1.352.09 G4 USD 86.578.Oe
VIDEO PROCESSOR H2 USD 4.580.00 1 USD 4.580.00
APPLE TV 4K FREE USD 1 USD
COOGLE TV IK FREE USD 1 Usl

--IiZ?:.yl?mE.=?&-1 .?
?- SO!?ND SVSTEM (BASfi - 33-:3*1.j. .?.1(:: -2,-i),2.*1
M,ranti SR8(315 11.2-Channel Network A/V Receiver USD 3.4SG.00 1 USD 3.456.80
SPEAKERS Kllpich SYSTEMS USD 8.450.00 1 USD 8 456.@e

Subwofer 12' R-10*SW U50 898. 00 z USD 1 780.09

11100000086 -LINTIGMfIOI?l,Kl?:A&--AKEOZ GA":.-f.?.E?-7637'

USD 78.Ge u USD 4 992.ee
Mectromechanlcal assembly
Canflguritiee and io-lsflonln: USD 450.- 1 USD 450.00

logistics FREE USD 1 U5D

Mi?i :

COMMERCIAL PRONSAL

Purchase Contract USD 36 060 86

##lo,y Inte,ratlor UED ..021.18
Soclat Iledta Agreement USD 38.513.59

0(MIED FL
Ver Ver Entertal-ent LLC 481 NE MIZNER BLVD. Bm Raton. FL 33432
2090 /OA Blvo. Pdm Deacm Gardens. FL 33405
EIN number: 35-2706228

#/ OF *ERICA CONTACT INFO

M
VER VER ENTERTAIHMENT LLC Tel. +1 386 344,B42i
ACCOUNT MJMBER 117914738 info#exgliled.tv
ROUTING NlmBER 63100277 In?tagram. com/eiplmledfl

FIlm Beach Gardens. ll-2523

Mr. *,n Klnilton

Merit 5.-aryr:
10/25//23 $36.GDO

Re--lnln- A-unt to -e p.d by 5--n Klngiton l. U- 47.-27.1., .hlc. will . p-id o..e the ln-t@U-tlon of the
equigmelt is complete + 50(ial leola adv

SEAN KINGSTON ARIEL MAIEOS

VER VER ENTERTAINMENT LLC

8
 r- \/ In lANI Rn

VERVERENTERTAINMENTLLC
2000 PGA Blvd
Palm Beach Gardens, FL 33408
info@expimled.tv
+1 386 344 8426

RECEIPT ACKNOWLEDGEMENT

The client Sean Kingston, have received the following product from EXPIMLED FL.

Product Details

1-Microled Screen C 232" KONG,

1-PC AV Receiver Marantz SR 8015 11.2
Sound System Dolby Atmos 5.1
5-Klipsch Speakers
2-Novastar VX600 - Colossal TV Box Sending
1-AV Furniture

I affirm that the product has been delivered in perfectcondition, without any apparent
damage, and has been tested and verified,confirming its proper functioning.

I declare, under my responsibility,

that I have no claims, complaints, or dissatisfaction
regarding the condition, insta;lation,0(gperation
of the received product.

Customer's Signature:
1///02-
i=7Lr-
Date: 12 / 17 / 2023

By signing this document, I acknowledge that I have received the product in the
mentioned condition and have no observations or claims to make.
I appreciate the attention and service provided by Expimled FL

9
Exhibit "B"

10
 Anovo
A payment is coming your way

Hi Ver Ver Entertainment LLC,

Eyes Above Water LLC has sent you a payment for $40.000 00 using Novo

-
Funds should
on 01/25/2024
arrive in your BANK OF AMERICA. N A account ending in

Message for you.

Television Setup.

Interested :n joining more than 200.000 small businesses using Novo? Apply
in minutes. and earn a S40 bonus for fund,ng your account.

Experience powerfutly simply business banking with no hidden fees,

invoicing and budgeting tools. and easily connect to all of your business
apps.

Get Started

Please let us know if you have any questions. our team is happy to help.

Cheers.

The Novo Team

Learn more at novo co

11
12