Preview
Filing # 139715185 E-Filed 12/03/2021 05:53:00 PM
IN THE CIRCUIT COURT OF THE 13TH
JUDICIAL CIRCUIT IN AND FOR
HILLSOROUGH COUNTY, FLORIDA
CASE NO.: 2021-CA-008936
In Re: DRB Capital, LLC
NOTICE OF FILING SUPPLEMENTAL INFORMATION
Interested parties, MetLife Tower Resources Group, Inc. ("Met Life Tower") and Metropolitan
Life Insurance Company ("MLIC") (collectively, "MetLife"), through undersigned counsel, hereby
file the attached supplemental information for the Court's consideration in connection with the Petition
for Court Approval (the "Petition") filed by DRB Capital, LLC.
MetLife has been provided information, by Steve H. Saranko, as attorney-in-fact of structured
settlement payee, Michael Jason Saranko, which may be relevant to the Court in connection with its
consideration of the Petition. Specifically, attached hereto as Exhibit A1 isa true and correct copy of
an October 16, 2018 letter from Steve H. Saranko enclosing a Durable Power of Attorney. In addition,
attached hereto as Exhibit B is a true and correct redacted copy of an email submitted by Steve H.
Saranko to MetLife on November 30, 2021.
1
All Exhibits have been redacted to protect confidential information. Unredacted copies of the Exhibitscan be
provided to the Court in camera.
LEGAL\ 55384375 \ 1
12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
MetLife respectfully request that the Court consider this information in connection with its
review of the Petition.
Respectfully submitted,
COZEN O'CONNOR
Southeast Financial Center, Suite 3000
200 South Biscayne Boulevard
Miami, Florida 33131-2352
Telephone: (305) 704-5940
Facsimile: (305) 704-5955
By: /s/ Jason R. Domark
Jason R. Domark
Florida Bar No. 0880191
E-mail: jdomark@cozen.com
2
LEGAL\ 55384375 \ 1
12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via the
Clerk of Court's e-portal system to Andrew J. Decker, IV (Counsel for DRB Capital, LLC); and by
mail to M. S. (payee) this 3rd day of December, 2021.
By: /s/ Jason R. Domark
LEGAL\ 55384375 \ 1
12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
EXHIBIT "A"
12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
(Page 2 of 7 )
oo
(.4
Steve H. Saranko
Post Office Box 517
Seffner, Florida 33583-0517 oo
Telephone: (813) 763-4191 co
October 16, 2018.
To: Metropolitan Structured Settlements
Re: Michael Jason Saranko
Case: 12554DTG
Case ID.: 8298GRP
Dear Sir/Madam,
Attached please find a copy of a Durable Power Of Attorney that l have on my son Michael Jason
Saranko. l have mailed you a certified copy via U. S. Certified Mail. As per rny phone conversation with
-your office, there ibsolutery cio changes tit this payment, including but not limited toale,
-
ls to be
assignment, change of address, direct deposit, or lien, and any changes not heretofore mentioned
without written permission from the grantees of this power of attorney. lf any changes are allowed
then a lawsuit will be filed in Federal Court for Breach Of Contract against Metropolitan Insurance
Company regardless of whether or not this Power Of Attorney is rescinded, revoked, altered, or any
way what so ever canceled.
Yours Truly
Steve H. Saranko
P.O. Box 517
Seffner, FL 33583-0517
Phone: (813) 763-4191
12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
(Page f
7).
3 o
INSTRUMENT#: 2011228300, BK: 20605 PG: 187;r-PGS: 1877 -
1879 07/14/2011 at
03:26:24 PM, DEPUTY CLERK:JMERINO Pat Frank,Clerk of the Circuit Court
•
Hillsborough
•
County 1—•
N.)
Page of 3
Durable Power of Attorney
I, Michael Jason Saranko, as Grantor, hereby execute this DURABLE POWER OF
ATTORNEY, pursuant to Florida Statutes Section 709.08, designating the Grantee, Steve
Howard Saranko, my Father, or, Steven Howard Saranko, my Brother, or Stephanie Jean
Saranko/King, my Sister, as my attorney-in-fact to act as follows: •
A. SCOPE OF AUTHORITY. The Grantee shall have every power to take all actions and
execute and deliver all papers, as if I were personally present, to the full and complete extent that
I am permitted by law to act individually, jointly with others, or as a fiduciary, including without
limitation:
1. Business Financial Matters: The Grantee shall have the followirfg powers:
(a) to grant, bargain, sell, assign, transfer, convey, and lease real property (land and
improvements);.to purchase, buy,_acquire, and lease real property;_to Mortgage or accept a
for the or sale of real property; to grant or accept
mortgage or other financing acquisition
options for all real estate transactions; to accept delivery of deeds (with or without mortgage
assumption clauses); to execute, deliver, or receive all closing papers pertaining to real property;
and to otherwise conduct allother real estate transactions;
(b) to sell, assign, transfer, convey, lease to or from, purchase, buy, and acquire tangible
personal property; and to otherwise conduct all other tangible personal property transactions;
(c) to sell, pledge, assign, transfer, convey, purchase, buy, and acquire stocks, bonds,
securities, and other tangible personal property; to maintain and operate brokerage accounts;
and to otherwise conduct all other intangible peisonal property transactions;
(d) to conduct individually or jointly with others, all banking transactions, including
opening, closing, depositing to and withdrawing from all checking, money market, and other •
accounts; to borrow monies for my use and benefit and for the use and benefit of members of
my family; and to pledge, hypothecate, and mortgage assets as security for the loans;
(e) toconduct business transactions, including the operations of a going business and the
acquisition or sale of businesses;
(f) to conduct insurance transactions, including acquiring, paying the premiums for, filing
claims, instituting and prosecuting lawsuits, compromising and settling claims and lawsuits,
with respect to comprehensive general liability, property, casualty, and life insurance (excluding
any power or other incidents of ownership in life insurance policies insuring the life of the
grantee and owned by me);
(g) to prepare or cause to be prepared and to execute and file tax returns for federal and
state property, income, gift, and estate tax transactions; to represent me before all tax
authorities; to protest, defend, compromise, and settle all tax controveriies for all types of taxes
and for all years prior to and after the execution of this power, including without limitation
federal income, gift, and estate taxes for the five years prior to the execution of this instrument
and 20 years after the execution of this instrument;
(h) to institute, prosecute, defend, compromise, settle, appeal, or terminate any
administrative proceedings, civil claims, litigation,or other proceedings by or against me; and
1
(i) to resign any position which I may hold as an officer or director of a corporation, as a
of a partnership, as a personal representative, trustee, guardian, or other fiduciary or
partner
as a politically elected or appointed officer or other similar position.
2. Personal Financial Matters: The Grantee shall have the following powers:
(a) to contract for and pay all bills and expenses for me and for meinbers of my family;
(b) to receive and answer mail and to cancel or continue credit cards or charge accounts;
(c) to take custody of and preserve in safekeeping my valuable papers, including Wats,
insurance policies, securities,or accounts;
Grantor Initials: tATS. Witness Initials: R. r-
Witness Initials: OH.
5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
112/3/2021
'1.
of 7)
(Page 4
Bk. 20605 Pg 18713 "
-;
•
00
OE
0
Page 2 of 3 •
(d) to deal with trustees of trusts in which I ave an interest and to exercise where oo
appropriate any rights I may possess in such trusts;
(e) to disclaim on my behalf all property rights I may have under applicable law;
(f) toconduct an safe deposit box transactions, including contracting to open boxes and to
terminate contracts for boxes, either in my natne alone or with others, and to have access to all
boxes to which I have access from time to time juring my remaining lifetime;
(g) to conduct trust funding transactions, including transfers of properties (real and
personal) froin me to trustees of trusts (revocable and irrevocable) established by me alone or
with others, even though I may be the trustee or one of the trustees; provided however, the
grantee shall be without power to revoke or amend revocable trusts established by me;
(h) tomake charitable gifts consistent with niy prior known donative intent; and
(i) tomake lifetime gifts of my properties to members of my family, [including the granteed
either outright or in trust; provided, however, that all suck gift transactions shall be consistent
with the prudent estate planning or financial management or with my known or probable intent
with respect to the disposition of my estate; and provided however, that gifts to the grantee or
for the benefit of any person to whom the grantee has an obligation of support shall be limited
to gifts for health, maintenance, support, and education of the donee.
3. Personal Health Care Matters: The Grantee shall have the following powers:
(a) to arrange for and consent to medical, therapeutical, and surgical procedures for me,
including the administration of drugs;
(b) to provide for my personal care and comfortable maintenance, through nursing homes,
health care facilities, life care facilities, medical and health care services; to file and prosecute
claims on my behalf for Medicare and health insurance benefits; and to provide for all other
services for my personal care and comfortable maintenance;
(c) to contract for in-house services by employees, nurses, and similar persons and to file the
required tax returns for such employees;
(d) to determine on my behalf and to obtain siipporting medical opinion that I can no longer
live in my residence, thus constituting an abandontnent of my homestead as defined and
provided for under the Florida Constitution and applicable law; and thereafter to exercise the
power under this instrument to dispose of the residence when the residence is no longer my
homestead;
(e) to make appropriate arrangements for my spiritual and religious needs consistent with
my beliefs;
(f) to arrange travel and entertainment for me as the Grantee shall deem appropriate;
(g) to nominate a person to act as guardian or healih care surrogate should one be necessary
not with standing the existence of this power of ittorney; provided, however, that any authority
of a previously designated health care surrogate who has consented to the designation shall not
take precedence over this power of attorney as te• health care matters;
(h) to have access to any and all medical and related information and records concerning
and to disclose such medical and related information to others;
to grant releases to health care professionals or institutions as deemed appropriate or
(i)
necessary by the Grantee;
to direct that life-prolonging procedures be withheld or withdrawn in accordance with
the instructions contained in my Living Will.
B. AUTHORITY TO DELEGATE. The Grantee shall have no authority.to delegate any powers
granted by thisinstrument.
C. RELEASE. I hereby release and discharge the Grantee from any and all claims, losses, or
causes of action which I or anyone claiming through me, including my heirs or devisees, if any,
may have against the Grantee for the the powers contained in this Durable
exersiper_of
1L021
shall or
Grantor Initials:t'''S 5. Witness Initials:DC./ • Witness Initials: 01-)
5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7
(Page 5 of 7)
Bk. 20605 Pg
1879.
•
•
cf.)
C.>
C')
Page 3 of 3
00
Power of Attorney when the same is exercised in good faith and with the intent of providing for
my best interests. oo
D. DURATION. This Durable Power of Attorney shall not be affected by my disability except as
provided by law.
E. EFFECTIVE DATE. This Durable Power of Attorney shall be exercisable on and from the
date of its execution.
EXECUTED in Hillsborough County, Florida, on October 12, 2008.
111.iti.411113.)1041- Isignature,of grantor]
LL1
D
=
6.
Michael Jason Saranko [Typed name] FE '±lco a
Granitor
_....
know to me, and I believe him to be of sound mind. 0
'Wort!ls
0 ,T., Y
_ilk
'signature of witness] l'Zi`i` •i%lk.
Witims lt, g c, •
1_73 _,
1g31 Tu-cd-\ 4ftec...-e-
Or. [address of witness!
CC-rd.-PI r"i• g -S5/0
0 t-i--
° 2
- '%. 1
o
cc En
0 > a- ,A u- (..„,
........---...... of witness]
•
[signature al 0
"-
-
„within, E :3 it ci ': en
!address of witness] '
(3 -±-
0
ZIZC”
Preview
Filing # 139715185 E-Filed 12/03/2021 05:53:00 PM IN THE CIRCUIT COURT OF THE 13TH JUDICIAL CIRCUIT IN AND FOR HILLSOROUGH COUNTY, FLORIDA CASE NO.: 2021-CA-008936 In Re: DRB Capital, LLC NOTICE OF FILING SUPPLEMENTAL INFORMATION Interested parties, MetLife Tower Resources Group, Inc. ("Met Life Tower") and Metropolitan Life Insurance Company ("MLIC") (collectively, "MetLife"), through undersigned counsel, hereby file the attached supplemental information for the Court's consideration in connection with the Petition for Court Approval (the "Petition") filed by DRB Capital, LLC. MetLife has been provided information, by Steve H. Saranko, as attorney-in-fact of structured settlement payee, Michael Jason Saranko, which may be relevant to the Court in connection with its consideration of the Petition. Specifically, attached hereto as Exhibit A1 isa true and correct copy of an October 16, 2018 letter from Steve H. Saranko enclosing a Durable Power of Attorney. In addition, attached hereto as Exhibit B is a true and correct redacted copy of an email submitted by Steve H. Saranko to MetLife on November 30, 2021. 1 All Exhibits have been redacted to protect confidential information. Unredacted copies of the Exhibitscan be provided to the Court in camera. LEGAL\ 55384375 \ 1 12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 MetLife respectfully request that the Court consider this information in connection with its review of the Petition. Respectfully submitted, COZEN O'CONNOR Southeast Financial Center, Suite 3000 200 South Biscayne Boulevard Miami, Florida 33131-2352 Telephone: (305) 704-5940 Facsimile: (305) 704-5955 By: /s/ Jason R. Domark Jason R. Domark Florida Bar No. 0880191 E-mail: jdomark@cozen.com 2 LEGAL\ 55384375 \ 1 12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via the Clerk of Court's e-portal system to Andrew J. Decker, IV (Counsel for DRB Capital, LLC); and by mail to M. S. (payee) this 3rd day of December, 2021. By: /s/ Jason R. Domark LEGAL\ 55384375 \ 1 12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 EXHIBIT "A" 12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 (Page 2 of 7 ) oo (.4 Steve H. Saranko Post Office Box 517 Seffner, Florida 33583-0517 oo Telephone: (813) 763-4191 co October 16, 2018. To: Metropolitan Structured Settlements Re: Michael Jason Saranko Case: 12554DTG Case ID.: 8298GRP Dear Sir/Madam, Attached please find a copy of a Durable Power Of Attorney that l have on my son Michael Jason Saranko. l have mailed you a certified copy via U. S. Certified Mail. As per rny phone conversation with -your office, there ibsolutery cio changes tit this payment, including but not limited toale, - ls to be assignment, change of address, direct deposit, or lien, and any changes not heretofore mentioned without written permission from the grantees of this power of attorney. lf any changes are allowed then a lawsuit will be filed in Federal Court for Breach Of Contract against Metropolitan Insurance Company regardless of whether or not this Power Of Attorney is rescinded, revoked, altered, or any way what so ever canceled. Yours Truly Steve H. Saranko P.O. Box 517 Seffner, FL 33583-0517 Phone: (813) 763-4191 12/3/2021 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 (Page f 7). 3 o INSTRUMENT#: 2011228300, BK: 20605 PG: 187;r-PGS: 1877 - 1879 07/14/2011 at 03:26:24 PM, DEPUTY CLERK:JMERINO Pat Frank,Clerk of the Circuit Court • Hillsborough • County 1—• N.) Page of 3 Durable Power of Attorney I, Michael Jason Saranko, as Grantor, hereby execute this DURABLE POWER OF ATTORNEY, pursuant to Florida Statutes Section 709.08, designating the Grantee, Steve Howard Saranko, my Father, or, Steven Howard Saranko, my Brother, or Stephanie Jean Saranko/King, my Sister, as my attorney-in-fact to act as follows: • A. SCOPE OF AUTHORITY. The Grantee shall have every power to take all actions and execute and deliver all papers, as if I were personally present, to the full and complete extent that I am permitted by law to act individually, jointly with others, or as a fiduciary, including without limitation: 1. Business Financial Matters: The Grantee shall have the followirfg powers: (a) to grant, bargain, sell, assign, transfer, convey, and lease real property (land and improvements);.to purchase, buy,_acquire, and lease real property;_to Mortgage or accept a for the or sale of real property; to grant or accept mortgage or other financing acquisition options for all real estate transactions; to accept delivery of deeds (with or without mortgage assumption clauses); to execute, deliver, or receive all closing papers pertaining to real property; and to otherwise conduct allother real estate transactions; (b) to sell, assign, transfer, convey, lease to or from, purchase, buy, and acquire tangible personal property; and to otherwise conduct all other tangible personal property transactions; (c) to sell, pledge, assign, transfer, convey, purchase, buy, and acquire stocks, bonds, securities, and other tangible personal property; to maintain and operate brokerage accounts; and to otherwise conduct all other intangible peisonal property transactions; (d) to conduct individually or jointly with others, all banking transactions, including opening, closing, depositing to and withdrawing from all checking, money market, and other • accounts; to borrow monies for my use and benefit and for the use and benefit of members of my family; and to pledge, hypothecate, and mortgage assets as security for the loans; (e) toconduct business transactions, including the operations of a going business and the acquisition or sale of businesses; (f) to conduct insurance transactions, including acquiring, paying the premiums for, filing claims, instituting and prosecuting lawsuits, compromising and settling claims and lawsuits, with respect to comprehensive general liability, property, casualty, and life insurance (excluding any power or other incidents of ownership in life insurance policies insuring the life of the grantee and owned by me); (g) to prepare or cause to be prepared and to execute and file tax returns for federal and state property, income, gift, and estate tax transactions; to represent me before all tax authorities; to protest, defend, compromise, and settle all tax controveriies for all types of taxes and for all years prior to and after the execution of this power, including without limitation federal income, gift, and estate taxes for the five years prior to the execution of this instrument and 20 years after the execution of this instrument; (h) to institute, prosecute, defend, compromise, settle, appeal, or terminate any administrative proceedings, civil claims, litigation,or other proceedings by or against me; and 1 (i) to resign any position which I may hold as an officer or director of a corporation, as a of a partnership, as a personal representative, trustee, guardian, or other fiduciary or partner as a politically elected or appointed officer or other similar position. 2. Personal Financial Matters: The Grantee shall have the following powers: (a) to contract for and pay all bills and expenses for me and for meinbers of my family; (b) to receive and answer mail and to cancel or continue credit cards or charge accounts; (c) to take custody of and preserve in safekeeping my valuable papers, including Wats, insurance policies, securities,or accounts; Grantor Initials: tATS. Witness Initials: R. r- Witness Initials: OH. 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6 112/3/2021 '1. of 7) (Page 4 Bk. 20605 Pg 18713 " -; • 00 OE 0 Page 2 of 3 • (d) to deal with trustees of trusts in which I ave an interest and to exercise where oo appropriate any rights I may possess in such trusts; (e) to disclaim on my behalf all property rights I may have under applicable law; (f) toconduct an safe deposit box transactions, including contracting to open boxes and to terminate contracts for boxes, either in my natne alone or with others, and to have access to all boxes to which I have access from time to time juring my remaining lifetime; (g) to conduct trust funding transactions, including transfers of properties (real and personal) froin me to trustees of trusts (revocable and irrevocable) established by me alone or with others, even though I may be the trustee or one of the trustees; provided however, the grantee shall be without power to revoke or amend revocable trusts established by me; (h) tomake charitable gifts consistent with niy prior known donative intent; and (i) tomake lifetime gifts of my properties to members of my family, [including the granteed either outright or in trust; provided, however, that all suck gift transactions shall be consistent with the prudent estate planning or financial management or with my known or probable intent with respect to the disposition of my estate; and provided however, that gifts to the grantee or for the benefit of any person to whom the grantee has an obligation of support shall be limited to gifts for health, maintenance, support, and education of the donee. 3. Personal Health Care Matters: The Grantee shall have the following powers: (a) to arrange for and consent to medical, therapeutical, and surgical procedures for me, including the administration of drugs; (b) to provide for my personal care and comfortable maintenance, through nursing homes, health care facilities, life care facilities, medical and health care services; to file and prosecute claims on my behalf for Medicare and health insurance benefits; and to provide for all other services for my personal care and comfortable maintenance; (c) to contract for in-house services by employees, nurses, and similar persons and to file the required tax returns for such employees; (d) to determine on my behalf and to obtain siipporting medical opinion that I can no longer live in my residence, thus constituting an abandontnent of my homestead as defined and provided for under the Florida Constitution and applicable law; and thereafter to exercise the power under this instrument to dispose of the residence when the residence is no longer my homestead; (e) to make appropriate arrangements for my spiritual and religious needs consistent with my beliefs; (f) to arrange travel and entertainment for me as the Grantee shall deem appropriate; (g) to nominate a person to act as guardian or healih care surrogate should one be necessary not with standing the existence of this power of ittorney; provided, however, that any authority of a previously designated health care surrogate who has consented to the designation shall not take precedence over this power of attorney as te• health care matters; (h) to have access to any and all medical and related information and records concerning and to disclose such medical and related information to others; to grant releases to health care professionals or institutions as deemed appropriate or (i) necessary by the Grantee; to direct that life-prolonging procedures be withheld or withdrawn in accordance with the instructions contained in my Living Will. B. AUTHORITY TO DELEGATE. The Grantee shall have no authority.to delegate any powers granted by thisinstrument. C. RELEASE. I hereby release and discharge the Grantee from any and all claims, losses, or causes of action which I or anyone claiming through me, including my heirs or devisees, if any, may have against the Grantee for the the powers contained in this Durable exersiper_of 1L021 shall or Grantor Initials:t'''S 5. Witness Initials:DC./ • Witness Initials: 01-) 5:53 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7 (Page 5 of 7) Bk. 20605 Pg 1879. • • cf.) C.> C') Page 3 of 3 00 Power of Attorney when the same is exercised in good faith and with the intent of providing for my best interests. oo D. DURATION. This Durable Power of Attorney shall not be affected by my disability except as provided by law. E. EFFECTIVE DATE. This Durable Power of Attorney shall be exercisable on and from the date of its execution. EXECUTED in Hillsborough County, Florida, on October 12, 2008. 111.iti.411113.)1041- Isignature,of grantor] LL1 D = 6. Michael Jason Saranko [Typed name] FE '±lco a Granitor _.... know to me, and I believe him to be of sound mind. 0 'Wort!ls 0 ,T., Y _ilk 'signature of witness] l'Zi`i` •i%lk. Witims lt, g c, • 1_73 _, 1g31 Tu-cd-\ 4ftec...-e- Or. [address of witness! CC-rd.-PI r"i• g -S5/0 0 t-i-- ° 2 - '%. 1 o cc En 0 > a- ,A u- (..„, ........---...... of witness] • [signature al 0 "- - „within, E :3 it ci ': en !address of witness] ' (3 -±- 0 ZIZC”