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Affidavit

Wendy Ouriel, the defendant in a case against Ciro Desenzani and Michael Dorignac, submitted an affidavit asserting that she has not received the summons and complaint and has not concealed her whereabouts. She provides information regarding the residency and business operations of the plaintiffs in Florida, along with evidence of Ciro Desenzani's incapacitation. The affidavit supports her motion to quash for insufficient service of process or to dismiss for lack of subject matter jurisdiction.

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35 views

Affidavit

Wendy Ouriel, the defendant in a case against Ciro Desenzani and Michael Dorignac, submitted an affidavit asserting that she has not received the summons and complaint and has not concealed her whereabouts. She provides information regarding the residency and business operations of the plaintiffs in Florida, along with evidence of Ciro Desenzani's incapacitation. The affidavit supports her motion to quash for insufficient service of process or to dismiss for lack of subject matter jurisdiction.

Uploaded by

wendy
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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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.
___________________________________/

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.

1
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

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