Filing # 74459955 E-Filed 07/03/2018 03:16:27 PM
Filing # 74459955 E-Filed 07/03/2018 03:16:27 PM IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA CASE NO. 2016-CA-000259-M BRUCE A. SCHMITT, Plaintiff, v. DENNIS ZECCA, RALPH LUCIGNANO, JOHN DOE #2 and JOHN DOE #3, Defendants. / AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, Bruce A. Schmitt (“Schmitt”), sues Defendants, Dennis Zecca (“Zecca”), Ralph Lucignano (“Lucignano”), John Doe #2 (“Doe #2”) and John Doe #3 (“Doe #3”), and alleges: JURISDICTION, PARTIES AND VENUE 1. Bruce Schmitt is an individual who resides in Monroe County, Florida. 2. Dennis Zecca is an incarcerated individual currently located in a federal prison in Sumter County, Florida. Prior to Zecca’s incarceration, Zecca was a resident of Monroe County, Florida. 3. Ralph Lucignano is an individual residing in Monroe County, Florida. Lucignano was “John Doe #1” in the original Complaint. 4. Doe #2 and Doe #3 (collectively, the “Does”) are individuals who, upon information and belief, reside in Monroe County, Florida. Information relating to the Does’ existence is contained in audio recordings transcribed by the Federal Bureau of Investigation (“FBI”). CASE NO. 2016-CA-000259-M 5. Zecca has refused to confirm or even discuss Lucignano’s and the Does’ involvement with the facts alleged herein and, as recently as February 2018, Lucignano has denied any such involvement. As a result of Zecca’s and Lucignano’s conspiracy to conceal Lucignano’s and the Does’ identities and involvement with the tortious acts alleged herein, Schmitt was forced to seek this information from federal agencies and through his own investigation.
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