Blake Hutton Enterprises , A Design Alliance

5224 W. SR 46 #153
Sanford , Florida 32771 CASE NO: 2015-CA-010087-O
(407) 485-0806
Plaintiff in pro se
ORANGE COUNTY NINTH
JUDICIAL CIRCUIT COURT FLORIDA

Blake Hutton )
Individually and )
Blake Hutton dba A Design Alliance )
) FIRST AMENDED COMPLAINT
Plaintiff, ) FOR BREACH OF
) CONTRACT, FORECLOSURE OF
vs. ) MECHANIC'S LIEN, COMMON
) COUNT, UNJUST ENRICHMENT
Phoenicia Development, LLC c/o Tom Harb )
Bella Building Group, LLC c/o Cameron Bradford )
Sawyer Sound Partners, LLC c/o Cameron Bradford )
)
DOES 1 through 10 , inclusive, )
Defendant(s) )
Plaintiff alleges :
INTRODUCTORY ALLEGIATIONS
1. Plaintiff was and is duly licensed by the State of Florida to perform the work
described in this Complaint, with a principal place of business in Seminole County .
2. The real property, hereinafter referred to as “subject property,” subject to this action
is described as follows: 5024 Sawyer Cove Way , Windermere, Florida. 34786. A legal description
was thereof attached as Exhibit “A”
first amended complaint -1-

3. The true names and capacities of Defendants DOES 1 through 10

inclusive are unknown and therefore said Defendant are sued by such fictitious names.
Leave of Court to amend this Complaint to show the true names and capacities will be
made when the same have been ascertained. All of said fictitiously named Defendants are in some
manner responsible incurred herein, and/or have an interest in the subject property, including, but
not limited to, fee simple, option to purchase, lease-option, contract of sale, partnership, joint
venture, leasehold, sub-leasehold, ground lease,
beneficial interest in a Deed of Trust and pursuant to an assignments of lease. Defendants DOES 1
through 10, inclusive, purport to have an interest in the property which is subordinate to Plaintiff's
Mechanic's Lien .
4. At all times herein mentioned, each Defendant was the agent and employee
of the other Defendants and was acting within the course and scope of that agency and
employment in the actions as alleged herein 5.
Defendant, Phoenicia Development , LLC c/oTom Harb were the owners.
6. Defendant , Bella Building Group , LLC c/o Cameron Bradford , (“Defendant
General”) is a licensed general contractor under the laws of the state of Florida .
6a. Defendant, Sawyer Sound Partners , LLC c/o Cameron Bradford , as of
2016 , how title was vested between Phoenicia Development LLC, Bella Building Group, LLC
and Sawyer Sound Partners, LLC.
7. For the venue purposes, it is alleged that the construction services, as well as the
contracts pertaining thereto, and all performance, were accomplished in the above-described
judicial district .
8. In the event any of the defendants are a corporation or limited liability company
(“business entity”) and individual Defendants are also named in the capacity of
shareholders, members , officers, or directors, individual liability is based upon the principles of
corporate or limited liability avoidance , in the interest of justice . Plaintiff alleges on information
and belief, that said individually named Defendants are the alter egos of each business entity by virtue of one
or more of the following: the lack of corporate formalities,
under capitalization, acts and conduct treating the business entity as their own privately controlled entity,
using the business entity for personal purposes, co-mingling business and personal bank accounts and assets,
fraud, not treating the business entity as separate and distinct, defrauding, creditors, and other facts to
determined at the time of trial which indicate, in the interest of justice,- the business entity should be avoided
and personal liability imposed.

FIRST CAUSE OF ACTION

Breach of Contract against
Phoenicia Development LLC c/oTom Harb
Bella Building Group, LLC c/o Cameron Bradford
aka Sawyer Sound Partners ,LLC c/oCameron Bradford
and Does 1 through 10 inclusive

9. Plaintiff hereby incorporates each and every allegation contained in the introductory
Allegations .
10. One or about May 8, 2015 , Plaintiff entered into a contract with the
Defendant General by which Plaintiff agreed to furnish certain labor, services, material, and equipment for a
work of improvement on the subject property, plus those additional sums as would be determined as the price
for extra work, all of which said Defendants agreed to pay.
A copy of that contract/invoice was previously attached hereto as Exhibit “B” and incorporated herein by
reference. Plaintiff has conferred such construction services as required under verbal
contract and the balance owing, including the balance under contract with authorized change orders, with
acknowledgment of credits to date , is the sum of $ 20,871.00 , together with pre -
judgment interest and/or finance charges from and after the due date to be determined by this court.
11. Pursuant to said contract , Plaintiff furnished to the Defendants described in paragraph 5, and
Defendant General , at their special instance and request construction services
to the subject property, which were used and consumed in the work improvement,
now located on the subject real property. The agreed price and reasonable value of those services
actually furnished, including authorized extra work, was and is the sum complaint as described in
the preceding Paragraph.
12. In furnishing the construction services for the work of improvement herein
described, Plaintiff performed all conditions, covenants, and promises on its part to be performed
under the contract.

first amended complaint -3-

 13. The whole of the real property mentioned above is required for the convenient use
and occupation of the work of improvement.
14. Notwithstanding demand having been made on Defendant General, the balance
under the contract is still due and payable and by virtue thereof Defendant General has breached the
contract in the amount herein described. Plaintiff has suffered additional consequential damages,
including, but not limited to, extended overhead, lost profits on other jobs, denial or restriction of
credit through trade lines, increased interest and charges on loans, lines of credit, credit cards, and
other borrowings, lost opportunities to bid other jobs, and other damages according to proof at trial.
The damages in this paragraph are requested against said Defendants, but are not included in the
mechanic's lien or the second cause of action.
15. Plaintiff also requests reasonable attorneys fees and court costs according to proof
WHEREFORE, Plaintiff prays for judgment as herein described.

SECOND CAUSE OF ACTION

Foreclosure of Mechanic's Lien against
Phoenicia Development, LLC c/o Tom Harb
Bella Building Group,LLC c/o Cameron Bradford
Sawyer Sound Partners, LLC c/o Cameron Bradford
and Does 1 through 10 inclusive
16. Plaintiff hereby incorporates each and every allegation contained in the introductory
allegations and the First Cause of Action.
17. On or about August 26, 2015, Plaintiff duly filed and recorded in the Recorder's
Office of the county where the subject property is situated, its verified Mechanic's ,
a copy of which was previously attached hereto as Exhibit “A”
18. Defendants claim some right, or interest in the subject property which is
subordinate and/or subject to plaintiff's mechanic's lien.
Wherefore, Plaintiff prays for judgment as herein described :
first amended complaint -4-

THIRD CAUSE OF ACTION

Common Count against
Phoenicia Development, LLC c/o Tom Harb
Bella Building Group , LLC c/o Cameron Bradford
Sawyer Sound Partners, LLC c/o Cameron Bradford
and Does 1 through 10 inclusive

19. Plaintiff hereby incorporates each and every allegation contained in the
introductory allegation and the first cause of action.
20. Within the last two years, Plaintiff furnished labor, materials, and equipment to
Defendant General . Such labor, material, and equipment were provided at the special instance and
request of said Defendant, who then and there promised
to Plaintiff the reasonable value of such labor, material, and equipment.
21. The reasonable value of such labor, material, and equipment at the time it was
provided for the subject and to said Defendant, which is now due, owing. And
from Defendants in the amount of $(20,871.00) together with pre-judgment interest
at 10% per annum from and after the due date to be determined by this Court .
22. Plaintiff as request reasonable attorney fee and court cost according to
proof .
WHEREFORE, Plaintiff prays for judgment as herein described.
FOURTH CAUSE OF ACTION
Unjust enrichment – Quasi contract
Phoenicia Development, LLC c/o Tom Harb
Bella Building Group , LLC c/o Cameron Bradford
Sawyer Sound Partners, LLC c/o Cameron Bradford
and does 1 through 10 inclusive
23. Plaintiff hereby incorporates each and every allegation contained in the
introductory allegations and the first and third Causes of Action.
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24. The labor, material, services and equipment conferred upon and in-
into the subject property, including but to, the work performed under the base contract and any
change orders, was at the instance and request of Defendant General , either
personally or through their authorized agent (s) Said Defendants knew of, authorized, and ratified
such or through their authorized (s). Said Defendants knew of, authorized,
and work have benefited from it .
25. The reasonable value of said labor, material , services and equipment was and is the
sum described in paragraph 10.
26. Under the equitable principles of unjust enrichment, a quasi-contract exists for
reimbursement to Plaintiff of said work .
27. Plaintiff also request reasonable atorney fees and court costs according to proof.
WHEREFORE, Plaintiff prays for damages as follows:
On The First Cause of Action

1. For the principal sum described paragraph 10 together with interest and the of
recording the mechanic's lien, to be proven at the time of trial.
2. For reasonable attorneys fees, and court costs according to proof. As
well as such other relief as the Court deems proper.
On The Second Cause of Action.
1. The the rights, claim, ownership, liens, and demands of Defendants, and
each of them, in the above-described real property are subsequent to and subject to
the lien of Plaintiff.
2. Adjudging that the Mechanic's Lien be foreclosed, and that the usual
judgment be made for the forfeiture of the lien to bond according to the law by a
commissioner to be appointed by the Court ; that the proceeds of the sale be applied
in the payment of the amounts claimed by Plaintiff, including principal, interest, and attorney's fees;
that each of the Defendants and all persons claiming under them,
subsequent to the Mechanic's Lien of plaintiff .
3. Adjudging that if there is a deficiency of proceeds to satisfy the amounts
due to Plaintiff, that judgment for the deficiency be entered against Defendants;
4. For reasonable costs, and as well as such other relief as this Court deems.
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5. For reasonable costs, and as well as such other relief as this Court deems
proper.
On the Third Cause of Action
 1. For the principal sum described in Paragraph 10 , together with interest
and attorney's fees to be proven at the time of trial.
2. For reasonable attorney fees and court costs according to proof .

On the Fourth Cause of Action

1. For the principal sum described in Paragraph 9, together with interest and
attorney's fees to be proven at the time of trial.
2. For reasonable attorney fees and court costs according to proof, and such
other relief as this Court deems proper.

DATED; ___________________________________

___________________________________________
Blake Hutton , individually and
dba , A Design Alliance In pro se