UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No.: 9:25-cv-80050-AMC
CIRO DESENZANI,
d/b/a POLO UNITED, and
MICHAEL DORIGNAC
Plaintiffs,
v.
WENDY OURIEL, and
WENDY OURIEL RACING, LLC,
a California limited liability Company,
Defendants.
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WENDY OURIEL’S AFFIDAVIT IN SUPPORT OF DEFENDANTS’ MOTION TO
QUASH FOR INSUFFICIENT SERVICE OF PROCESS OR, IN THE ALTERNATIVE,
MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
Defendant, Wendy Ouriel, hereby states the following:
1. I have reached the age of majority, am competent to testify, and make the
following statements based on my personal knowledge.
2. I am domiciled in Florida.
3. I am the Owner of Wendy Ouriel Racing, LLC (“WOR”).
4. I had not received, either individually or as the Owner of WOR, a copy of the
summons and complaint via registered or certified mail.
5. I have not attempted to conceal my whereabouts from Plaintiffs.
6. Based upon information and belief, Michel Dorignac lives in Florida. A copy of
Michel Dorignac’s Mortgage is attached as Exhibit A and a copy of Michel Dorignac’s Warranty
Deed is attached as Exhibit B.
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7. Based upon information and belief, Michel Dorignac operates a business in
Florida named Michel Polo Inc. A copy of Michel Polo Inc.’s Florida Profit Corporation Annual
Report is attached as Exhibit C.
8. Based upon information and belief, Michel Dorignac is employed in Florida.
9. Based upon information and belief, Michel Dorignac maintains a continuous
Florida presence and maintains horses at 4932 Pelham Circle, Wellington, Florida.
10. Based upon information and belief, Ciro Desenzani d/b/a Polo United is a
business operating in Florida, as indicated by the Electric Articles of Organization for Polo
United USA LLC, listing Ciro Desenzani as the person authorized to manage the LLC. A copy of
Polo United USA LLC’s Florida Profit Corporation Annual Report is attached as Exhibit D.
11. Based upon information and belief, Ciro Desenzani is incapacitated. A copy of
court records indicating Ciro Desenzani’s incapacitation is attached as Composite Exhibit E.
Pursuant to 28 U.S.C. § 1746, I affirm that these statements are true and correct to the
best of my knowledge.
________________________________________
WENDY OURIEL