GLOBAL PUBLIC ALERT OF JUSTIN GODUR FRAUD

This
site republishes publicly filed court complaints so that potential investors and victims are aware of ongoing allegations.
THIS IS A GLOBAL PUBLIC ALERT OF
JUSTIN GODUR FRAUD
ALLEGATIONS
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DOWN TO SEE ALL FULLY ACTIVE LAWSUITS AGAINST JUSTIN
GODUR
If
you believe you may have been affected by the alleged fraudulent activity related to Justin Godur, Anna DeFrank, Morris
Jaime
Godur, Blake Leatherman, William Holcomb, or any related or non related companies included below (non inclusive:
Rency,
DEFGOD, Capital Max, Q7..., No Parcel Id, Yes We Build... or others) email your allegation below and you will be

contacted.
If
you have an NDA signed to cover for or mitigate the occurrence of fraud, even if the payments were settled, you could be

complicit
in the fraud itself if not reported.
If
you were hired by, an employee or subcontractor of, or have information on any wrongdoing in relation to any of the

details,
companies, people, or situations herein, contact the email below.
Whether
anonymous or not, for any reason including, but not limited to the items herein, unpaid contracts, bounced checks,
outstanding
payments for services already provided, or other.
[email protected]
Related Cases
AnnaMarieDefrankFraud.com
MorrisJaimeGodurFraud.com

Lawsuit 1 - Old Jamestown vs Godur & Capital Max
Alleged $2.3M financing scam where Justin Godur and Morris Jaime Godur lied about European lenders,
tricked Old Jamestown and Rigsby into wiring millions, defaulted on repayment deals, misused investor
money for personal luxuries, and left $1.9M still unpaid.
Summary of Allegations
• Justin Godur and Morris Jaime Godur misrepresented their ability to secure a $30M European loan, tricking
Old Jamestown and Rigsby into wiring $2.3M for financing that never existed.
• Justin & Morris diverted investor funds and stalled with empty promises, later admitting there was no
legitimate loan agreement or committed lender.
• Justin & Morris defaulted on a June 2024 Repayment Agreement that required $2.3M to be repaid over 23
months, stopping payments after just $400,000.
• Justin & Morris misused investor money for personal purposes, including buying a luxury vehicle and
making unrelated office upgrades.

• Justin & Morris executed a February 2025 Promissory Note obligating $1.114M in repayments but failed to
honor it, leaving $1.9M still unpaid.
• Justin & Morris engaged in securities fraud by using false pretenses to solicit funds under SEC Regulation
D, misrepresenting material facts to induce investment.
• Justin & Morris committed fraud by knowingly lying about institutional financing, intending to induce
Plaintiffs to transfer millions under false promises.
• Justin & Morris breached binding contracts, including the Repayment Agreement and Promissory Note, by
failing to make required payments and diverting funds.
• Justin & Morris continue to raise money through a $100M SEC-registered offering, raising concerns of
using new investor funds to cover old debts in a Ponzi-like scheme.
Lawsuit 2 - Pinnacle vs Godur & DeFrank + Others
Alleged scheme described in court complaints involving theft, forgery, fake contracts, sham invoices, luxury
shopping sprees, and hidden property deals where Justin Godur, Anna DeFrank, and Morris Jaime Godur are
accused of theft of over $2.5 million from investors, forged signatures, falsified documents, and ran a multi-
entity fraud ring leaving lawsuits, broken promises, and financial issues for investors and US Military
Veterans.
Summary of Allegations
• $1 million stolen: Justin forged a consultation agreement, faked a signature, and siphoned $1,000,000
directly from Pinnacle Equity II’s bank account
• $545,765 fake invoices: Justin, Anna, and Leander generated sham construction bills for work never
performed, pocketing the funds through shell companies
• Luxury spending spree: Misappropriated funds were blown on Pennsylvania real estate, a new Chevy
Tahoe, private jets, luxury hotels, and high-end dining
• Forgery and falsification: Multiple forged signatures, fabricated budget approvals, bounced checks, and
fraudulent term sheets were used to cover their tracks
• Fraudulent property deals: Pennsylvania purchases were made with stolen money and leveraged into fresh
loans to conceal and multiply the fraud
• Broken guarantees: Jaime Godur personally guaranteed repayment and indemnification but never honored
his promises, instead signing sham agreements to stall Pinnacle’s recovery
• Civil theft exposure: Their fraud dragged Pinnacle into lawsuits, including a California lender case and a
$4.5M civil theft threat from Butternut Investment Group
• Massive conspiracy: Dozens of shell companies were used in concert to launder money, deceive investors,
and keep the scheme alive
Lawsuit 3 - Shoshana vs Godur & DeFrank + Others
Alleged fraud and theft conspiracy where Justin Godur, Anna DeFrank, and Morris Jaime Godur misled
investors, diverted $1.5M, forged pledges, misused investor funds for luxury living, high end private jets, and
luxury goods, exploited elderly victims, and ran a shell-company scheme to cover their tracks.

Summary of Allegations
• Justin Godur, Anna DeFrank, and Morris Jaime Godur misappropriated $1.5M in investor funds meant for a
Deerfield Beach real estate project, diverting title to insider-controlled entities.
• Forged pledges and filed UCC liens, encumbering assets they had promised were unencumbered, while
hiding money among dozens of shell companies.
• They misused investor contributions to buy personal luxuries including property, vehicles, and travel,
instead of honoring repayment obligations.
• They engaged in conversion by refusing to return funds, permanently depriving investors of their rightful
money.
• They committed fraudulent misrepresentation by lying about ownership, titling, and unencumbered pledges
to induce investment.
• They committed negligent misrepresentation by recklessly ignoring the truth while soliciting funds under
false pretenses.
• They exploited elderly investors, knowingly taking $1.5M from individuals over 65 years old through
deceit and concealment.
• They committed civil theft with felonious intent, refusing to repay, and instead concealing, diverting, and
converting investor funds.
• They conspired together to commit fraud, coordinating lies, forged filings, and sham settlements to stall and
obstruct repayment.
• They aided and abetted conversion and fiduciary breaches, knowingly helping one another to steal funds
and sabotage repayment.
• They engaged in fraudulent transfers, shifting assets and recording insider liens to block investor recovery
and hide misappropriated funds
Old Jamestown vs Justin Godur, Capital Max, Morris Jaime Godur,
Q7Capital Group
Text from actual complaint is below. Formatting, typos, and other mispellings may be seen due to conversion software used.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
OLD JAMESTOWN STORAGE LLC, a
Texas limited liability company; and RIGSBY STORAGE LLC a Texas
limited liability company,
Plaintiffs, v.
CAPITAL MAX GROUP, LLC, a Florida
limited liability company formerly known as Q7CAPITAL GROUP, LLC; JUSTIN
GODUR, an individual; and MORRIS JAIME GODUR, an individual
Defendants.
OLD JAMESTOWN STORAGE LLC, a

Texas limited liability company; and RIGSBY STORAGE LLC a Texas
limited liability company,
Plaintiffs, v.
CAPITAL MAX GROUP, LLC, a Florida
limited liability company formerly known as Q7CAPITAL GROUP, LLC; JUSTIN
GODUR, an individual; and MORRIS JAIME GODUR, an individual
Defendants.
COMPLAINT
Plaintiffs, OLD JAMESTOWN STORAGE LLC (“Old Jamestown”) and RIGSBY STORAGE LLC
(“Rigsby”) (Collectively “Plaintiffs”), by and through their undersigned attorneys, allege as follows against
Defendants, CAPITAL MAX GROUP, LLC, a Florida limited liability company formerly known as
Q7CAPITAL GROUP, LLC (“Defendant” or “Capital Max”), JUSTIN GODUR (“Justin”) and MORRIS
JAIME GODUR (“Morris”) (Collectively “Defendants”):
PARTIES
• Plaintiff OLD JAMESTOWN STORAGE LLC is a limited liability company established in the State of
North Carolina.
• Plaintiff RIGSBY STORAGE LLC is a limited liability company established in the State of Texas.
• Defendant CAPITAL MAX GROUP, LLC is a limited liability company established in the State of Florida
formerly known as Q7CAPITAL GROUP, LLC.
• Defendant JUSTIN GODUR is a natural person residing in the State of Florida and, at all relevant times,
acted as the managing member and authorized representative of Defendant Capital Max.
• Defendant MORRIS JAIME GODUR (“JAMIE GODUR”) is a natural person residing in the State of
Florida.
• Upon information and belief, Justin Godur and Jaime Godur exercised complete dominion and control over
Capital Max, using the entity to perpetrate a fraud and/or for improper personal purposes. Under applicable
Florida law, including the doctrine of piercing the corporate veil, Capital Max operated as the alter ego of
Justin Godur and Jaime Godur, such that Justin Godur and Jaime Godur are personally liable for the acts and
obligations of Capital Max.
JURISDICTION AND VENUE
• This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 because Plaintiffs
assert claims arising under the Securities Exchange Act of 1934, specifically Section 10(b), 15 U.S.C. §
78j(b), and SEC Rule 10b-5, 17 C.F.R. § 240.10b-5.
• This Court also has supplemental jurisdiction over related state law claims pursuant to 28 U.S.C. § 1367, as
those claims arise from a common nucleus of operative facts.
• Venue is proper in this District under 28 U.S.C. § 1391(b) because a substantial part of the events or
omissions giving rise to the claims occurred in this District, including Defendants' solicitation of funds,
execution of relevant agreements, and communications related to the fraudulent scheme.
• Defendant Capital Max maintains its principal office Palm Beach County, and Defendants Justin Godur and
Jaime Godur reside and conduct business in Palm Beach County, thereby subjecting both to personal
jurisdiction in the State of Florida and this Court.
• Personal jurisdiction over Defendants is proper under Florida’s long-arm statute, Fla. Stat. § 48.193,
because Defendants reside in the state, committed tortious acts within the state, transacted business within the
state, and engaged in a course of conduct intended to have effects in Florida and upon a Florida-based
company.
FACTUAL BACKGROUND
• Plaintiff, Old Jamestown Storage, LLC is a company formed to build a self-storage facility in North
Carolina. Old Jamestown, along with its related entity, Rigsby Storage, LLC, raised about $5 million from
investors to fund the acquisition, permitting, and development of two self-storage facilities. Once completed,
the goal was to sell these facilities to CubeSmart, a well- known real estate investment trust.
• In search of construction financing for the project, Plaintiffs were introduced to Jamie Godur and, his son,

Justin Godur. Jaime Godur is a very successful businessman and is well-known in the business community.
His introduction predicated the subsequent meeting(s) that would take place.
• Upon meeting with and throughout the interaction thereafter, Jamie Godur made direct assurances that he
was either the principal or was principally involved in Capital Max. Jaime Godur played a critical role in
finalizing the transactions at issue. Plaintiffs reasonably and detrimentally relied on these representations in
deciding to enter into the agreements. But for Jaime Godur's involvement, these transactions would not have
occurred.
• Both Jamie Godur and Justin Godur promised they could secure institutional financing through a European
fund that would cover 90-95% of the project’s estimated $30 million cost. Both Jamie Godur and Justin
Godur presented themselves as the principles of Capital Max, a lending advisory firm.
• Trusting these claims and after conducting what appeared to be proper due diligence, including a site visit
and face-to-face meetings, Plaintiffs transferred approximately $2.3 million to Defendants. These funds were
meant as a down payment and a lock on the interest rate for the expected loan.
• Although Justin Godur positioned himself as a consultant for an international lending group and that Jamie
Godur would be personally involved in securing the financing, all contracts were signed directly with Capital
Max. It was not until after the funds were transferred by the Plaintiffs that Justin Godur revealed there was no
loan agreement in place, and no legitimate lender had committed to the project.
• Despite this, Justin, on behalf of the Defendants, assured Plaintiffs that he would seek alternative funding
sources while continuing to control the $2.3 million. However, even after multiple follow-ups, Justin failed to
provide any real loan documents or reliable term sheets over several months.
• After months of empty promises and inaction, Plaintiffs ended the agreement with the Defendants and
demanded the return of the funds. Justin Godur, on behalf of the Defendants, refused to return the full
amount, citing vague “expenses,” and instead offered a repayment plan to return the money in installments of
$100,000 per month.
• Subsequently, Capital Max Group LLC entered into a formal Repayment Agreement with Rigsby Storage
LLC and Old Jamestown Storage LLC on June 14, 2024. The
agreement stipulated that Capital Max would repay $2.3 million in installments over 23 months, with
$41,000 allocated to Rigsby Storage LLC and $59,000 to Old Jamestown Storage LLC. A true copy of this
agreement is attached as Exhibit A.
• However, only $400,000 was repaid before the Defendants defaulted on the agreement, halting payments in
or around September 2024. Since then, no additional payments have been made, and there is still $1.9 million
in unpaid funds.
• Although Jaime Godur has attempted to shift responsibility onto his son Justin Godur as solely responsible
for this transaction, it appears that he was the driving force behind these deals.
• During an investigation, Plaintiffs discovered that Justin had used investor funds for personal purposes,
including purchasing a luxury vehicle and making office upgrades unrelated to the Old Jamestown project.
• On February 6, 2025, Capital Max and Old Jamestown Storage, LLC subsequently sentered into a
promissory note. The note required Capital Max to repay Old Jamestown a principal amount of $1,114,000,
plus interest, through monthly payments of $29,141.78 for 53 months at an annual interest rate of 8.75%.
Despite these terms, the debt remains unpaid, and significant arrears have accumulated. A copy of the
promissory note is attached as Exhibit B.
• Throughout this process, Defendants knowingly misrepresented their ability to secure financing and used
false pretenses to persuade Plaintiffs to transfer the funds. Their actions have caused considerable harm to
Plaintiffs, delayed the project’s development, and shaken investor confidence.
• Plaintiffs have also learned that Defendants continue to raise funds through a $100 million SEC-registered
Regulation D offering. There are concerns that he may be using new investor money to repay previous debts.
• Despite efforts to settle this matter through negotiation, Defendants remain in default. Plaintiffs now have
no choice but to seek judicial intervention to recover the misappropriated funds and protect the interests of its
investors.
FIRST CAUSE OF ACTION
Violation of Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5 (Against Defendants
JUSTIN GODUR, MORRIS JAIME GODUR and CAPIT AL MAX)
• The Plaintiffs re-allege and incorporate by reference paragraphs 1-27 as though fully set forth herein.
• Section 10(b) of the Securities Exchange Act of 1934, 15 U.S.C. § 78j(b), and Rule 10b-5 promulgated
thereunder (17 C.F.R. § 240.10b-5), prohibit the use of any manipulative or deceptive device or contrivance

in connection with the purchase or sale of securities.
• Under 15 U.S.C. § 78j(b) and SEC Rule 10b-5 (17 C.F.R. § 240.10b-5),
“manipulative and deceptive devices” refer to fraudulent acts used in connection with the purchase or sale of
securities, including making false statements, omitting material facts, or engaging in deceptive conduct.
These provisions prohibit any scheme intended to mislead investors or distort market integrity. Liability
attaches when a person knowingly or recklessly misrepresents key facts or conceals information that a
reasonable investor would consider important.
• Under the Securities Act of 1933 and the Securities Exchange Act of 1934, “securities” are broadly defined
and include a wide range of financial instruments. According to 15 U.S.C. § 77b(a)(1), the term includes:
"any note, stock, treasury stock, security future, bond, debenture, evidence of indebtedness, certificate of
interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization certificate
or subscription, transferable
share, investment contract, voting-trust certificate, certificate of deposit, for a security, fractional undivided
interest in oil, gas, or other mineral rights..."
• In connection with the offer and sale of securities, Defendants directly and indirectly, by use of means and
instrumentalities of interstate commerce, engaged in a scheme to defraud Plaintiffs by making material
misrepresentations and omissions regarding their ability to procure institutional financing for Plaintiffs’
development project.
• Defendants falsely represented that they had secured or could secure 90–95% institutional financing from a
European-based lender to cover a $30 million development cost. In reliance on these representations,
Plaintiffs wired approximately $2.3 million to Defendants as a down payment and interest rate lock.
• At the time these representations were made, Defendants knew or were reckless in not knowing that no such
lender or financing commitment existed. They concealed material facts regarding the true status of the
financing and failed to disclose that no credible lender had agreed to fund the project.
• Plaintiffs reasonably relied on Defendants’ misrepresentations and omissions when transferring investor
funds.
• Defendants’ fraudulent conduct was made in connection with the sale of securities, as the underlying
transaction involved the use of investor capital raised pursuant to Regulation D, Rule 506(c), and was part of
a larger investment structure tied to a proposed exit sale to CubeSmart, a national REIT.
• As a direct and proximate result of Defendants’ misconduct, Plaintiffs have suffered substantial harm,
including the misappropriation of $2.3 million in investor funds, project delays, reputational harm, and loss
of business opportunities.
• Defendants' actions constitute willful violations of Section 10(b) of the Securities Exchange Act and Rule
10b-5, and demonstrate a pattern of fraudulent conduct that may also involve additional investors.
• Plaintiffs seek all available remedies, including but not limited to rescission, restitution, compensatory
damages, interest, costs, attorneys’ fees, and any further relief the Court deems just and proper.
SECOND CAUSE OF ACTION
Breach of Contract (Against CAPITAL MAX)
• The Plaintiffs re-allege and incorporate by reference paragraphs 1-27 as though fully set forth herein.
• Plaintiffs, Old Jamestown Storage, LLC and Rigsby LLC, entered into a binding written Repayment
Agreement on June 14, 2024, with Defendant Capital Max, whereby Capital Max agreed to repay $2.3
million in monthly installments, with $59,000 allocated to Old Jamestown and $41,000 to Rigsby Storage,
LLC.
• On February 6, 2025, Capital Max Group LLC executed a Promissory Note in favor of Old Jamestown,
obligating it to repay $1,114,000 with monthly payments of $29,141.78 over 53 months at a fixed interest
rate of 8.75%.
• In addition, prior to entering into these formal agreements, Defendants initially represented to Plaintiffs that
they would arrange institutional financing for the development of Plaintiffs’ self-storage facility. Relying on
these representations, Plaintiffs wired an initial $2.3 million as a down payment and interest rate lock for the
forthcoming loan.
• Plaintiffs performed all, or substantially all, of their obligations under the agreements. Specifically,
Plaintiffs wired the initial $2.3 million to Defendants as part of the agreed-upon financing arrangement,
based on Defendants' representations that they would secure
the necessary financing for the Old Jamestown project. Plaintiffs also entered into the Repayment Agreement
and Promissory Note in good faith.

• All conditions precedent to Defendants’ performance under the Repayment Agreement and Promissory Note
either occurred or were waived. Defendants did not fulfill their obligations to secure financing and instead
retained control of the initial $2.3 million wired to them.
• Defendants materially breached the agreements by failing to make the required monthly payments as
agreed. Only $400,000 was repaid under the Repayment Agreement, and payments ceased entirely in or
around September 2024. Defendants also failed to secure financing, as initially promised, and misused the
funds for personal expenses. The Promissory Note likewise remains in default, with significant principal and
interest still outstanding.
• As a direct and proximate result of Defendants’ breach, Plaintiffs have suffered damages of no less than
$1.9 million in unpaid funds, not including accrued interest, attorneys’ fees, and costs.
THIRD CAUSE OF ACTION
Fraud
(Against Defendants JUSTIN GODUR, MORRIS JAIME GODUR and CAPITAL MAX)
• The Plaintiffs re-allege and incorporate by reference the paragraphs 1-27 as though fully set forth herein.
• Defendant Justin Godur and Jaime Godur, acting as the representatives of Capital Max, made multiple false
statements to Plaintiffs. Specifically, Justin and Jaime represented that they could secure institutional
financing through a European-based fund to cover 90-95% of the
$30 million development costs for the Plaintiffs’ project. Defendants further claimed that these funds were
imminent, and Plaintiffs would soon receive the necessary financing.
• At the time these representations were made, Defendants knew that they were false.
In fact, no loan or financing had been arranged, and no credible lender had committed to funding the project.
Defendants failed to disclose this crucial information to Plaintiffs, which was essential to the agreement.
• Defendants made these false representations with the intent to induce Plaintiffs to transfer $2.3 million to
Capital Max Group LLC. The representations were designed to convince Plaintiffs to wire the funds,
believing that the financing was forthcoming and that the project would be completed as planned.
• Plaintiffs, in good faith, relied on Defendants’ false statements and representations when transferring $2.3
million to Capital Max. This reliance was reasonable, especially given the appearances of due diligence
efforts made by Defendants and the assurances they provided regarding securing financing for the project.
• As a direct and proximate result of Defendants’ fraudulent misrepresentations, Plaintiffs have suffered
damages exceeding unpaid $1.9 million, consisting of the funds transferred to Defendants, which were
misused for personal and unrelated business expenses. Furthermore, Plaintiffs have faced delays in the
project and significant harm to its reputation and investor confidence. Despite repeated demands for
repayment, Plaintiffs have yet to recover the funds or see any meaningful progress on the financing.
REQUEST FOR RELIEF
Plaintiffs respectfully request the following relief:
• Award Plaintiffs compensatory damages in the amount of $1.9 million, representing the funds fraudulently
obtained by Defendants, along with any additional damages proven at trial.
• Award Plaintiffs punitive damages to punish Defendants for their fraudulent conduct and to deter future
wrongful behavior.
• Award Plaintiffs reasonable attorneys' fees, court costs, and any other expenses incurred in the prosecution
of this action.
• Award Plaintiffs pre-judgment interest at the legal rate from the date of the fraudulent misrepresentation,
and post-judgment interest until the judgment is satisfied in full.
• Grant such other and further relief as this Court deems just and proper.
May 23, 2025
 
/s/ Senen Garcia
SENEN GARCIA, FBN 58631
Industria Business Lawyers, LLP 701 Brickell Ave., Ste. 1550
Miami, FL 33131
Telephone: (202) 495-1185
Fax: (786) 435-0154
[email protected]

EXHIBIT A
Docusign Envelope ID: 91026658-8421-4989-88C4-7752384065D8
Repayment Agreement
Repayment Agreement
This Repayment Agreement ("Agreement") is made and entered into as of June 14, 2024, by and
between:
Payer:
Capital Max Group LLC
Representative: Justin Godur
Address: 1515 S Federal Hwy Suite 319, Boca Raton, FL, 33432
Payees:
Rigsby Storage LLC
Address: 4524 Sheldon Trail, Fort Worth, TX 76244
Old Jamestown Storage LLC
Address: 4524 Sheldon Trail, Fort Worth, TX 76244
Terms and Conditions:
1. Repayment Amounts:
- Monthly Deposit: $41,000 to Rigsby Storage LLC
- Monthly Deposit: $59,000 to Old Jamestown Storage LLC
2. Payment Details: Capital Max Group LLC agrees to make payments as follows:
Docusign Envelope ID: 91026658-8421-4989-88C4-7752384D85DB
Repayment Agreement
For Rigsby Storage LLC:
- Monthly Deposit: $41,000
- Receiving Bank: JP Morgan Chase Bank
- Bank Address: 4420 Golden Triangle Blvd, Fort Worth, TX 76244
- Account Type: Checking
- Beneficiary Account Name: Rigsby Storage LLC
- Beneficiary Address: 4524 Sheldon Trail, Fort Worth, TX 76244
- Reference: Rigsby Storage
For Old Jamestown Storage LLC:
- Monthly Deposit: $59,000
- Receiving Bank: JP Morgan Chase Bank
- Bank Address: 4420 Golden Triangle Blvd, Fort Worth, TX 76244
- Account Type: Checking
- Beneficiary Account Name: Old Jamestown Storage LLC

- Beneficiary Address: 4524 Sheldon Trail, Fort Worth, TX 76244
- Reference: Old Jamestown Storage
3. Completion of Contract:
This contract shall be considered fulfilled when the total amount paid by Capital Max Group LLC
reaches $2.3 million.
Docusign Envelope ID: 9102665B-8421-49B9-88C4-7752384D65DB
Repayment Agreement
4. Payment Schedule:
Based on the monthly deposits to Rigsby Storage LLC and Old Jamestown Storage LLC, the total
repayment of $2.3 million will be completed over a period of 23 months
5. Non-Disclosure Agreement:
Both parties agree to keep the terms of this Agreement and any related information confidential.
Neither party shall disclose any such information to any third party without the prior written consent
of the other party, except as required by law or as necessary to enforce the terms of this Agreement.
6. Release of Liability:
Upon execution of this Agreement, Capital Max Group LLC and Justin Godur, representative of
Capital Max Group LLC, shall be released from any and all liabilities, claims, and obligations arising
out of or in connection with this Agreement or any other agreements. This release shall be binding
and irrevocable.
7. Governing Law:
This Agreement shall be governed by and construed in accordance with the laws of the state of
Florida.
8. Entire Agreement:
This Agreement constitutes the complete understanding and agreement between the parties
regarding the subject matter herein. Any amendments or modifications to this Agreement must be in
writing and signed by all parties involved.
Docusign Envelope ID: 91026658-8421-4989-88C4-7752384D65DB,
Docusigned by: Repayment Agreement
Justin. Godur
DocySigned by:
Justin Godur
Date: June 14, 2024
Justin Godur Capital Max Group LLC Representative
Wesley Yates Rigsby Storage LLC
Wesley Yates Old Jamestown Storage LLC
Case 9:25-cv-80647-RLR Document 1 Entered on FLSD Docket 05/26/2025 Page 17 of 22

EXHIBIT B
Lender may collect a late charge not to exceed an amount equal to five percent (5%) of any
installment which is not paid within ten (10) days of the due date thereof, to cover the extra expense
involved in handling delinquent payments, provided that collection of said late charge shall not be
deemed a waiver by Lender of any of its rights under this Note.
K Default ion:
(a) If Borrower fails to perform any obligation under this Note to pay principal or interest
within fifteen (15) days of the date same is due, it shall constitute an Event of Default and
Lender may, at its option, exercisable in its sole discretion, declare all sums of principal
and interest under this Note to be accelerated and become immediately due and payable
without notice of default, presentment or demand for payment, protest or notice of
nonpayment or dishonor, or other notices or demands of any kind or character.
ra) Phepencip oft Sapitat hereby dittonaliy-end
bi wars 4 —the—p 4
perk f-all-obligations-of the Bi he-Lender under this Note-and
amendments—or-modifieations-thereef, Borrower agrees that this Note survives the
bankruptey of the Borrower and binds administrators, successors and assigns. All
obligations under this agreement continue even if the Borrower becomes insolvent or
bankrupt or is discharged from bankruptcy. Borrower’s obligation is to pay all amounts
owed to the Lender under this Note.
Costs:
In the event that this Note is collected by law or through attorneys at law, or under advice
therefrom (whether such attomeys are cmploees of Lender or an affiliate of Lender or are outside
counsel), Borrower end 1: dary tiabh +
hhereby;-severaliy-end-jointly agree to pay all costs of collection, including attomeys’ fees, including
charges for paralegals, appraisers, experts and consultants working under the direction or supervision of
Lender's; costs for evaluating preserving or disposing of any collateral granted as security for payment of
this Note, or any other charges permitted by applicable law whether or not suit is brought, and whether
incurred in connection with collection, trial, appeal, bankruptcy or other creditors’ proceedings or
otherwise,
iH. Loan Charges:
Nothing herein contained, nor any transaction related thereto, shall be construed, or so operate as
to require Borrower or any person liable for the repayment of same, to pay interest in an amount or at a
rate greater than the maximum allowed by applicable law. Should any interest or other charges paid by
Borrower, or any parties liable for the payment of the loan made pursuant to this Note, result in the
computation or earning of interest in excess of the maximum legal rate of interest permitted under the law
in effect while said interest is being eared, then any and all of such excess shall be and is waived by
Lender, and all such excess shall be automatically credited against and in reduction of the principal
balance, and any portion of the excess that exceeds the principal balance shall be paid by Lender to
Borrower or any parties liable for the payment of the loan made pursuant to this Note so that under no
circumstances shall the Borrower, or any parties liable for the payment of the loan hereunder, be required
to pay interest in excess of the maximum rate allowed by applicable law.
i Iurisdiction:
Page 2
The laws of the State of Texas shall govern the interpretation and enforcement of this Note. In the
event that legal action is instituted to collect any amounts due under, or to enforce any provision of, this

instrument, Borrower person primarity j r
consents to, and by execution hereof submit themselves to, the jurisdiction of the courts of the State of
Texas, and, notwithstanding the place of residence of any of them or the place of execution of this
instrument, such litigation may be brought in or transferred to a court of competent jurisdiction in and for
Tarrant County, Texas.
J Non-Waiver:
The failure at any time of Lender to exercise any of its options or any other rights hereunder shall
not constitute a waiver thereof, nor shall it be a bar to the exercise of any of its options or rights at a later
date. All rights and remedies of Lender shall be cumulative and may be pursued singly, successively, or
together, at the option of Lender.
K. Miscellaneous:
1 ‘TIME IS OF THE ESSENCE OF THIS NOTE.
2, It is agreed that the granting to Borrower or any other party of an extension or extensions
of time for the payment of any sum or sums due under this Note, or for the performance of
any covenant or stipulation thereof or the taking of other or additional security shall not in
any way release or affect the liability of Borrower under this Note.
3. This Note may not be changed orally, but only by an agreement in writing amending
Note, signed by both parties against whom enforcement of any waiver, change,
modification or discharge is sought.
4, All parties to this Note, whether Borrower, principal, surety, or endorser, hereby waive
presentment for payment, demand, notice, protest, notice of protest and notice of
dishonor.
5. Notwithstanding anything herein to the contrary, the obligations of Borrower under this,
Note shall be subject to the limitation that payments of interest shall not be required to
the extent that receipt of any such payment by Lender would be contrary to provisions of
law applicable to Lender limiting the maximum rate of interest which may be charged or
collected by Lender. In the event that any charge, interest, or late charge is above the
maximum rate provided by law, then any excess amount over the lawful rate shall be
applied by Lender to reduce the principal sum of the loan or any other amounts due
Lender hereunder.
6. Borrower acknowledges that Lender shall have no obligation whatsoever to renew,
modify or extend this Note or to refinance the indebtedness under this Note upon the
maturity thereof, except as specifically provided herein
7. Lender shall have the right to accept and apply to the outstanding balance of this Note
and all payments or partial payments received from Borrower after the due date therefor,
whether this Note has been accelerated or not, without waiver of any of Lender’s rights to
continue to enforce the terms of this Note and to seek any and all remedies provided for
Page 3
herein or in any instrument securing the same, including, but not limited to, the right to
foreclose on such security.
8 All amounts received by Lender shall be applied to expenses, late fees, and interest before
principal or in any other order as determined by Lender, in its sole discretion, as permitted
by law.
9, If more than one party executes this Note, all such parties shall be jointly and severally

liable for the payment of this Note.
10, If any clause or provision herein contained operates or would prospectively operate to
invalidate this Note in part, then the invalid part of said clause or provision only shall be
held for naught, as though not contained herein, and the remainder of this Note shall
remain operative and in full force and effect.
11. This Note contains all of the terms, covenants, conditions and understandings between
the parties and no alterations or modifications hereto shall be valid unless made in writing
through a formal Amendment of Note and signed by an authorized representative of each
party. This Note constitutes the entire agreement between the parties with respect to any
amounts claimed due and/or any obligations of any parties of any kind. The parties to this
Note have jointly participated in the drafting and negotiation of this Note. In the event an
ambiguity or question of intent or interpretation arises, this Note shall be construed as if
drafted jointly by the parties, and no presumption or burden of proof will arise favoring
or disfavoring any party by virtue of the authorship of any of the provisions of this Note.
L. Waiver of Jury Trial:
BORROWER AND LENDER HEREBY KNOWINGLY, VOLUNTARILY, AND
INTENTIONALLY WAIVE THE RIGHT EITHER MAY HAVE TO A TRIAL BY JURY IN RESPECT
OF ANY LITIGATION BASED HEREON OR ARISING OUT OF, UNDER OR IN CONNECTION
WITH THIS NOTE AND ANY AGRI ‘T CONTEMPLATED TO BE
MENTS (WHETHER VERBAL OR WRITTEN) OR ACTIONS OF
PROVISION IS A MATERIAL INDUCEMENT FOR LENDER TO EXTEND TO BORROWER THE
LOAN EVIDENCED BY THIS NOTE,
[INTENTIONALLY LEFT BLANK — SIGNATURES ON PAGE TO FOLLOW]
Page 4
Borrower has duly executed this Note effective as of the date set forth hereinabove.
BORROWER:
CAPITAL MAX LLC,
a Florida limited liability company
By: see Scott Godur
JUSTIN GODUR, Member
STATE OF FLORIDA, )
COUNTY OF Palm Beach )
The foregoing instrument was acknowledged before me, by means of [x] physical presence or [
online notarization, this 6th day of February, 2025, by JUSTIN GODUR, as Member of CAPITAL MAX
LLC, a Florida limited liability company on behalf of and as an act of the Company. Who [ ] is personally
NOTARY PUBLIC, STATE OF FLORIDA
Print Name: Eglarine Harrison
My Commission Expires:10/11/2025
NoTBTIZSE TERETAY GAINS UETNG COMMUNTEST ON TECHTSTSGY via Proof.
LENDER:
OLD JAMESTOWN STORAGE LLC,
a Texas limited liability company

, Member
Page 5
Pinnacle vs Justin Scott Godur, Anna Marie DeFrank, Morris Jaime Godur, Rency, Yes
We Build, DEFGOD, Q7Capital Group, Q7 Capital
Text from actual complaint is below. Formatting, typos, and other mispellings may be seen due to conversion software used.
Entity Name: RENCY LLC Jurisdiction: PA Date: 6/18/2025 Receipt Method: Process Server Case Number:
CACE-25-008622 Plaintiff: PINNACLE ONE CAPITAL GROUP, LLC, ET AL. Defendant: JUSTIN
SCOTT GODUR, ET AL. Document Type: Summons
*S154680*
Filing# 225050827 E-Filed 06/11/2025 04:30:49 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY,
FLORIDA
PINNACLE ONE CAPITAL GROUP,LLC; PINNACLE ONE EQUITY FUND I LLC; PINNACLE ONE
EQUITY FUND II LLC; PINNACLE ONE MANAGEMENT II LLC; AND PINNACLE ONE
MANAGEMENTINCOMEFUNDILLC
Plaintiff,
V.
JUSTIN SCOTT GODUR; MORRIS JAIME GODUR; ---; ANNA MARIE DEFRANK;JACK LEANDER;
GSJ CAPITAL, LLC;YES WE BUILD LLC; YES WE BUILD GROUP LLC; DEFGOD LLC; CAPITAL
MAX LLC; CAPITAL MAX GROUP LLC d/b/a Q7CAPITAL GROUP LLC;BUILDING LIGHTHOUSE
LLC; Q7 CAPITAL LLC; RENCY LLC; CUR CAPITAL LLC; NO PARCEL ID LLC;YES WE MANAGE
LLC; ---- MINORITY BUILDERS LLC; WI-IITE BISON HOLDINGS LLC; BLACKSTAR
CONSTRUCTION LLC; and REGAL CONSULTING GROUP INC.
Defendants.
_______________:/
COMPLAINT
Plaintiffs Pinnacle One Capital Group, LLC ("Pinnacle Capital"); Pinnacle One Equity
Fund I LLC ("Pinnacle Equity I"); and Pinnacle One Equity Fund II LLC ("Pinnacle Equity II"
and, collectively with Pinnacle Capital and Pinnacle Equity I, "Pinnacle"); Pinnacle One
Management II LLC ("Pinnacle Management"); and Pinnacle One Management Income Fund I
LLC ("Pinnacle Income I" and, collectively with Pinnacle and Pinnacle Management,
LEVIN!!: KELLOGG LEHMAN SCIINF.IDF,R +GROSSMAN I.LP
100 SE 2nd Street, 36th Floor, Miaini Tower; Miami. Florida 33131 Main: 305.403.8788 Fax: 305.403.8789
"Plaintiff-;") file this Complaint against defendants Justin Scott Godur ("Justin Godur"); Morris Jaime Godur
("Jaime Godur"); --- ("---"); Anna Marie DeFrank ("DeFrank"); .Jack Leander ("Leander"); GSJ Capital LLC
("GS.I"); Yes We Build LCC ("YWB"); Yes We Build Group LLC ("YWB Group"); Defgod LLC
("Defgod"); Capital Max LLC ("Capital Max"); Capital Max Group LLC d/b/a Q7Capital Group LLC
("Capital Max Group"); Building Lighthouse LLC ("Building Lighthouse"); Q7 Capital LLC ("Q7"); Rency
LLC ("Rency"); CUR Capital LLC ("CUR Capital"); No Parcel ID LLC (''No Parcel"); Yes We Manage LLC
("YWM"); ---- Minority Builders LLC ("Minority Builders"); White Bison Holdings LLC ("White Bison");
Blackstar Construction LLC ("Blackstar") and Regal Consulting Group Inc. ("Regal" and, collectively with
the other defendants ("Defendants"). In suppo11 thereof, Plaintiffs alleges:
INTRODUCTION
1. This action involves a coordinated scheme orchestrated and executed by Justin Godur who, with the
assistance ofthe other Defendants named herein, defrauded Pinnacle and its investors of millions of dollars in

investors' funds by using false representations, false promises, and forged and falsified documents to deprive
Pinnacle and its investors of their investment capital.
2. Justin Godur and his limited liability company, GSJ, did so while GSJ and Justin Godur were members of
Pinnacle. Defendants used Justin Godur' s position at Pinnacle to further their scheme.
3. Among other fraudulent transactions he undertook while he was a member of Pinnacle, Justin Godur stoic
$1 million from Pinnacle Equity II, which he obtained authorization to pay himself by fabricating a
Consultation Agreement and forging the signature of one of
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Pinnacle Equity II's other members thereon. He acted in concert with ---, Leander, Defrank and a number of
entities they controlled to falsify invoices totaling approximately $545,765 for purported construction work
performed to develop and renovate an investment property located at 1555 SE 7th Street, Deerfield Beach,
Florida (the "1555 Property") which work was never actually performed. He fabricated budget approvals and
bounced checks, among other documents, in an attempt to delay, confuse, and defraud Pinnacle and its
investors of additional funds.
4. After Justin Godur was caught red-handed by Pinnacle-and both GSJ and Justin Godur were removed as
members of Pinnacle for cause in December of 2024--he did not attempt to deny or defend his actions, and
instead promised to make everything right by repaying Pinnacle and its investors for the damages he caused
them. He executed a written acknowledgement agreement in January of2025 promising to do so.
5. To further induce Pinnacle to refrain from suing him, Justin Godur had his own father-Jaime Godur-vouch
for him and execute a personal guarantee which, among other things, promised to indemnify and hold
Pinnacle harmless for any claims, damages, or lawsuits arising from Justin Godur's actions during Justin
Godur's tenure at Pinnacle.
6. Unbeknownst to Pinnacle, the fraud it had uncovered in December of 2024 was just the tip of the iceberg.
Justin Godur, along with Defrank, continued to use misappropriated investor funds to purchase properties in
Pennsylvania in an attempt to hide these funds from Pinnacle all while Justin and Jaime Godur continued to
represent to Pinnacle that they were making everything right.
7. Justin Godur, Jaime Godur, and a number of entities they controlled continued to falsely represent to
Pinnacle that they would make it whole, and executed documents to that
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effect, all while Justin Godur and Defrank continued with their fraudulent schemes.
8. Ultimately, Justin Godur, GSJ, and Jaime Godur breached their obligations under the acknowledgement
agreement and related personal guarantee.
9. All told, Defendants' scheme has resulted in over $2.5 million of quantifiable
damages to Pinnacle and its investors and has endangered the integrity and reputation of the members of
Pinnacle and the business.
10. Worse, as a direct result ofJustin Godur's actions, Pinnacle Equity I has already been sued by a lender,
Carlyle Capital Fund, Inc. ("Carlyle") in California court through a
lawsuit (the "Carlyle Litigation") which Justin and Jaime Godur promised to indemnify Pinnacle
for and whose defense costs Justin and Jaime Godur promised to fund-neither of which they did.
11. Even worse than that, Pinnacle Equity I was recently threatened by another investor of Justin Godur's,
Butternut Investment Group, LLC with a lawsuit seeking $4.5 million
in damages stemming from an apparently fraudulent joint venture agreement entered into by Justin Godur
which Pinnacle Equity I had nothing to do with.

12. Pinnacle can only be left to guess what other potential claims, lawsuits, or liabilities may arise as a result
of Justin Godur's rampant and pervasive fraud. Likewise,
Pinnacle can only be left to calculate the full extent of the damages it has suffered as a result of Defendants'
fraudulent scheme.
PARTLES, VENUE, AND JURISDICTION
13. Plaintiff Pinnacle Capital is a Florida limited liability company licensed to do business in Florida with its
principal place of business in Boca Raton, Florida.
14. Plaintiff Pinnacle Equity I is a Florida limited liability company licensed to do
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business in Florida with its principal place of business in Boca Ratoh, Florida.
15. Plaintiff Pinnacle Equity II is a Delaware limited liability company licensed to do business in Florida
with its principal place ofbusiness in Boca Raton, Florida.
16. Plaintiff Pinnacle Management is a Florida limited liability company licensed to do business in Florida
with its principal place ofbusiness in Boca Raton, Florida.
17. Plaintiff Pinnacle Income I is a Delaware limited liability company licensed to do business in Florida
with its principal place ofbusiness in Boca Raton, Florida.
18. Defendant Justin Godur is an individual, sui Juris, who, upon information and belief, resides in Boca
Raton, Florida.
19. Defendant Jaime Godur is an individual, sui Juris, who, upon information and belief, resides in Boca
Raton, Florida.
20. Defendant --- is an individual, suiJuris, who, upon information and belief, resides in ---, ---.
21. Defendant Defrank is an individual, suijuris, who, upon information and belief, resides in New Castle
Pennsylvania.
22. Defendant Leander is an individual, suiJuris, who, upon information and belief, resides in Parkland,
Florida.
23. Defendant GSJ is a Florida limited liability company with its principal place of business in Boca Raton,
Florida.
24. Defendant YWB is a Florida limited liability company with its principal place of business in Boca Raton,
Florida.
25. Defendant YWB Group is a Florida limit_ed liability company with its principal place of business in
Boca Raton, Florida.
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I 00 SE 2nd Street, 36th Floor, Miami Tower, Miami, Florida 33131 Main: 305.403.8788 Fax: 305.403.8789
26. Defendant Defgod is a Florida limited liability company with its principal place of business in Boca
Raton, Florida.
27. Defendant Capital Max is a Florida limited liability company with its principal place of business in
Delray Beach, Florida.
28. Defendant Capital Max Group is a Florida limited liability company with its principal place of business in
Delray Beach, Florida.

29. Defendant Building Lighthouse is a Florida limited liability company with its principal place of business
in Jacksonville, Florida.
30. Defendant Q7 is a Florida limited liability company with its principal place of business in Jacksonville,
Florida.
31. Defendant Rency LLC is a Pennsylvania limited liability company with its principal place of business in
Harrisburg, Pennsylvania.
32. Defendant CUR Capital is a Pennsylvania limited liability company with its principal place of business in
Dauphin County, Pennsylvania.
33. Defendant No Parcel is a Pennsylvania limited liability company with its principal place of business in
New Castle, Pennsylvania.
34. Defendant YWM is a Florida limited liability company with its principal place of business in Boca Raton,
Florida.
35. Defendant --- is a --- limited liability company with its principal place of business in ---, ---.
36. Defendant Minority Builders 1s a Florida limited liability company with its principal place of business in
Miami, Florida.
37. Defendant White Bison is a Florida limited liability company with its principal
6 LllVINE Kr,J.LOGG LEHMAN SCHNF:IOER + GROSSMAN LLP 100 SE 2nd Strce!, 36th floor, Miami
Tower, Miami, Florida 33131 Main: 305.403.8788 Fax: 305.403.8789
place of business in Parkland, Florida, and is a citizen of Florida.
38. Defendant Blackstar is a Florida limited liability company with its principal place ofbusiness in Boca
Raton, Florida.
39. Defendant Regal 1s a Florida for-profit corporation with its principal place of business in Boca Raton,
Florida.
40. This Court has personal jurisdiction over this lawsuit because the parties conducted, engaged in, or
carried on a business or business venture in Broward County, Florida and the 1555 Property which fonns a
central part ofthis dispute is located in Broward County, Florida.
41. Pursuant to Fla. Stat. 47.051, venue is proper in this Court because the causes of action at issue arose in
Broward County, Florida and the 1555 Property is located in Broward County, Florida.
42. This Court has jurisdiction over this action because Plaintiffs seek damages in excess of$50,000,
exclusive ofinterest, court costs, and attorneys' fees.
43. This case should be assigned to this Court's complex division pursuant to Administrative Order 2013-I 1-
Civ because the amount in controversy is well over $150,000 and because (a) the case arises, in part, from the
purchase, sale, or lease of an investment real property and (b) the case also concerns the liability and
indemnity obligations of a fonner member of Pinnacle, Justin Godur.
44. The case should also be assigned to this Court's complex division pursuant to Florida Rule of Civil
Procedure 1.201 because it involves complicated legal and case management issues that will require
extensive judicial management. Among other things, this case involves a large number of parties, whom
Plaintiffs anticipate will be separately
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represented. Plaintiffs anticipate this case will require pre-trial management ofa large number of witnesses
and a substantial amount of documentary evidence. Plaintiffs further anticipate that this Court will need to
address numerous pre-trial motions that will be time-consuming to resolve. Finally, Plaintiffs anticipate that

this matter, iftried, will require a substantial amount of time to complete and will involve the management ofa
large number of witnesses, attorneys, and trial exhibits at trial.
45. All conditions precedent to the filing of this action have occurred, have been satisfied, or have otherwise
been waived or excused.
GENERAL ALLEGATIONS
46. Plaintiffs manage and operate private investment funds that specialize in real estate acquisitions,
development, and private placement offerings. Pinnacle Capital is led by a team of experienced professionals
with backgrounds in real estate, finance, and capital markets. Plaintiffs provide accredited investors with
access to curated investment opportunities through private offerings and joint ventures.
47. Justin Godur is the sole member and manager ofGSJ Capital LLC ("GSJ"). GSJ and Justin Godur were
previously members of Pinnacle Capital. For reasons further detailed below, GSJ and Justin Godur were
removed as members of Pinnacle Capital for cause on December 17, 2024.
48. Jaime Godur is Jutin Godur's father and is the sole member and manager ofQ7.
49. --- is a self-professed investor, entrepreneur, branding consultant and business coach. He is the managing
member of ---.
50. Leander is a contractor who, upon information and belief, is a member and/or manager of Minority
Builders, White Bison, Regal and Blackstar.
8 LE\IINI!: KELLOGG L~:HMAN SCHNEIDt:J{ + GROSSMAN l,LrI 00 SE 2nd Street, 36th Floor, Miami
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A. Pinnacle Eguitv I Acquires the 1555 Property on Justin Godur's Recommendation
51. Beginning on or about July of 2024, while GSJ and Justin Godur were still members of Pinnacle Capital,
Justin Godur presented a lucrative business investment opportunity with minimized risk for Pinnacle and its
investors.
52.Specifically, Justin Godur convinced Pinnacle to acquire and develop the 1555 Property with a guaranteed
exit by either --- or the "family Office" as the end buyer.
53. On Justin Godur's recommendation, Pinnacle Equity I purchased the 155 5 Property from its prior
owners, Ronald and Lisa Jakubas, for $1.775 million on or about September I 3, 2024. Jaime Godur and Q7
were, respectively, originally listed as the cooperating broker and sales associate on the transaction. A true
and correct copy of Pinnacle Equity l's deed to the 1555 Property is attached as Exhibit A.
54. Justin Godur recommended that Pinnacle Equity I purchase the 1555 Property so that it could be re-
developed, renovated, and resold for a profit.
55. In order to induce Pinnacle to approve the I 555 Property's purchase and Pinnacle Equity I to go through
with the 1555 Prope,ty's purchase and sale agreement, Justin Godur presented Pinnacle with an executed
purchase and sale agreement executed by --- (the "--- Purchase Agreement"). Derrank was herself involved in
the preparation ofthe --- Purchase Agreement. Under the --- Purchase Agreement, ---, through his limited
liability company, ---, purported to already commit to purchasing the renovated 1555 Property for $6 million
before Pinnacle Equity I had even purchased it.
56. The --- Purchase Agreement gave Pinnacle and its investors a projected return profile on their investment
and was instrumental in Pinnacle's approval of the 1555
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Property's purchase through Pinnacle Equity I.
57. --- doubled down on the --- Purchase Agreement's execution, posting on his social accounts that an end
buyer had committed to purchase the home for $6 million shortly after its purchase by Pinnacle Equity r. ---

also attempted to induce new investors to invest into Pinnacle with the same post.
58. As it has now become clear, --- never intended to perfonn under the --- Purchase Agreement and, instead,
intended to use the 1555 Property's purchase and subsequent development as a vehicle for misappropriating
Pinnacle's capital in concert with Justin Godur.
59. In order to fund the 1555 Property's purchase, Pinnacle Equity I obtained a $] ,331,250 balloon mortgage
(the "Mortgage") from lender Zinc Financial Inc. ("Zinc"). A true and correct copy of the Mortgage is
attached as Exhibit B. The Mortgage was personally guaranteed by ---.
60. --- was instrumental in securing the financing for the 1555 Property's purchase, whose acquisition was
induced by Justin Godur and ---. In fact, in order to induce the original funding lender, Carlyle Fund Inc.
("Carlyle") to extend Pinnacle Equity I the mortgage loan, --- was made a member of Pinnacle Capital
effective May 3, 2024. --- was subsequently removed as a member on September I I, 2024, with an effective
removal date of.June 30, 2024.
61. (n order to memorialize the loan agreement with Carlyle that eventually resulted in the Mortgage with
Zinc, --- and Pinnacle Equity I-at Justin Godur's insistence and instruction-----executed a Letter
ofCommitment (the "Carlyle Contract") in favor ofCarlyle.
62. Justin Godur and --- subsequently allegedly failed to pay Carlyle certain fees due and owing under the
Carlyle Contract. As a result of this alleged failure to pay Carlyle,
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LEVINE K:LLOGG LEIIJ\IAN SCHNEIDER+ GROSSMAN LLP
100 Sc 2nd Street, 36th Floor, Miami Tower, Miami, Florida 33131 Main: 305.403.8788 l'ax: 305.403.8789
Carlyle filed a lawsuit (the "Carlyle Litigation") against Pinnacle Equity I and ---, among others, in the
Superior Court of California on October 17, 2024. In the Carlyle Litigation, Carlyle alleges that Pinnacle
Equity I and --- owe it $166,000 in unpaid fees under the Carlyle Contract.
63. As described in more detail below, Justin Godur expressly agreed to fund the Carlyle Litigation's defense
and to indemnify Pinnacle Equity I for any damages, fees, or liabilities incurred by Pinnacle Equity I.
64. He subsequently breached all ofthese promises.
B. Justin Godur Steals $1 Million from Pinnacle Equity II
65. On or about September 27, 2024, shortly after arranging for the 1555 Property's purchase, Justin Godur
forged the signature of a member of Pinnacle Equity II, Patrick Voltapetti, on a Consultation Agreement for
Commercial Lending Services (the "Capital Max Group Contract") which purported to retain Capital Max
Group to provide consulting services to Pinnacle Equity II in connection with Pinnacle Equity II's obtaining a
commercial real estate loan. A true and correct copy ofthe Capital Max Group Contract is attached as Exhibit
C.
66. Capital Max Group is an entity whose sole member and manager is Justin Godur.
67. Justin Godur used the forged Capital Max Group Contract to authorize the transfer of $1 mi Ilion from
Pinnacle Equity 11, which Justin Godur personally withdrew out of Pinnacle Equity II's bank account on
September 30, 2024.
68. Upon infonnation and belief, these funds were used by Justin Godur for his personal use. In order to
obfuscate his misappropriation of these funds Justin Godur, upon information and belief funneled these funds
through a number ofentities he directly or indirectly controlled, either personally or jointly in concert with
Defrank and ---. These entities
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Tower, Miami, Florida 331 )1 Main: 305.403.8788 l'ax: 305.403,8789
include Defgod, Capital Max, Capital Max (iroup, YWB, YWB Group, YWM, Building Lighthouse, Rency
LLC, CUR Capital, and No Parcel.

69. Among other things, Justin Godur and Defrank used the misappropriated funds to purchase multiple
investment properties in Pennsylvania, a new truck, luxury goods, and to finance extravagant travel,
including private jet charters, five-star accommodations, and high-end dining, as further detailed below.
70. When confronted about the "$] million withdrawal by Pinnacle Equity Il's other members, Justin Godur
attempted to obfuscate the reasons for the money's withdrawal and eventually agreed to pay it back
piecemeal only months later.
C. Justin Godur, Leander, and DeFrank Arrange for the Submission of False Invoices to Divert $545,765 in
Funds Earmarked for the 1555 Property's Development
71. After Pinnacle Equity I acquired the 1555 Property, Pinnacle Equity I-at Justin Godur's request and
recommendation-entered into an Independent Contractor Services Agreement with YWB (the "YWB
Contract") on October 29, 2024, pursuant to which YWB agreed to provide demolition, development, and
renovation services with respect to the 1555 Property so that the 1555 Property could be re-developed and re-
sold for a profit. The work at issue was scheduled to commence by November 1, 2024 and to be completed
by May I, 2025. A true and correct copy ofthe YWB Contract is attached as Exhibit D.
72. In order to fund the 1555 Property's renovation, Pinnacle Equity I agreed to a pre.construction cost
estimate of $1,885,000, which the parties agreed they could subsequently modify through change orders as
the project progressed.
73. YWB is a Florida limited liability company that was formed by Justin Godur. At the time the YWB
Contract was executed, its only members were Justin Godur and Defrank.
74. YWB did not itself provide any construction services to Pinnacle 1 Equity and 12
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instead hired a subcontractor, Minority Builders, to provide the services at issue.
75. Leander was, upon information and belief, a managing member of Minority Builders at all material times.
76. On October 28, 2024, YWB submitted an invoice for payment to Pinnacle I Equity which represented
that YWB was owed $523,450 to cover demolition and renovation performed or to be performed with respect
to the 1555 Property through that date. A true and correct copy ofthat invoice is attached as Exhibit E.
77. Pinnacle Equity I subsequently wired $545,765 to YWB cover the payment ofthe invoice, together with
an additional $22,315 in "soft costs" billed by YWB, on October 29, 2024.
78. Justin Godur, in his capacity as a member of YWB, directed Minority Builders and Leander, to generate
an invoice on behalf of Minority Builders reflecting that payment of $523,450 had been received and that the
invoice had been fully satisfied. A copy of that confirmation is attached as Exhibit F.
79. In fact, the work referenced in the invoice was never performed.
80. Instead, a portion of these funds were disbursed by Godur from YWB's account and used for the sole
benefit of Godur, DeFrank and upon information and belief: Leander and Leander's various entities, which
included White Bison, Blackstar, Regal, and Minority Builders. Upon information and belief, a portion of
these funds were also disbursed from YWB's account to YWB Group and YWM, two limited liability
companies jointly managed and controlled by Justin Godur, Defrank, and ---. Upon information and belief, a
portion ofthese funds were also disbursed from YWB's account to Building Lighthouse, a limited liability
company managed and controlled by Justin Godur and ---.
D. Justin Godur and DeFrank Use Misappropriated Funds to Purchase Properties in Pennsylvania and a New
Truck
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81. After misappropriating over $1.5 mill ion in funds from Pinnacle and its investors, Justin Godur and
DeFrank used those funds to purchase seven properties in Lawrence County, Pennsylvania (collectively, the
"Pennsylvania Properties"). They did so through Defgod, a Florida limited liability company whose sole
managing members at all times material to this lawsuit were .Justin Godur and DeFrank. DeFrank was
subsequently removed as a member in March of2025.
82. Specifically, Defgod purchased the following properties m Lawrence County, Pennsylvania between
November 22, 2024 and January 29, 2025:
(a) On November 22, 2024, Dcfgod purchased property located at 126 E. Edison Avenue Newcastle, PA from
prior owners Joyce Deck, Teri Harper, and Mary Jane Davis for $120,000.
(b) On December 3, 2024, Defgod purchased property located at 214 Sunset Drive, Newcastle PA from prior
owners Werner and Maureen Sleich for $225,000.
(c) On December 3, 2024, Defgod also purchased property located at 2104 Pulaski Road, New Castle, PA
from prior owner Barry Brown, as executor for the estate of Robert David Brown for $175,000. Defgod used
the properties located at 126 E. Edison Avenue, 214 Sunset Drive, and 2104 Pulaski Road to secure a
$693,375 open-end mortgage in favor of lender Archwest Punding LLC.
(d) On December 18, 2024, Defgod purchased a set of 5 parcels located at 213, 216, 217, 218, and 231
Cottage Street, New Castle PA from prior owners David Brunton and Stephen Reduga for $120,000. Defgod
then used this property to secure a $140,000 open-end construction mortgage executed in favor of lender
Park Place Finance, LLC ("Park Place").
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(e)
On December 20, 2024, Defgod purchased property located at 512 Elizabeth Ave., Newcastle PA from prior
owners David and Sylvia Black for $120,000. Defgod then used this property to secure a $154,000 open-end
construction mortgage executed in favor of!ender Park Place.
(f)
On December 23, 2024, Defgod purchased property located at 2007 Delaware Ave, Newcastle PA from prior
owner Zacary Schmitt for $120,000. Dcfgod then used this property to secure a $147,000 open-end
construction mortgage executed in favor of lender Park Place.
(g)
On January 23, 2025, Defgod purchased property located at 2504 Ron Drive, New Castle PA from prior
owners Nicholas and Jacqueline Manolis for $660,000. Dcfgod then used that property to secure a $540,000
open-end first mortgage executed in favor of lender Center Street Lending VI II SPE LLC ("Center Street")
and a $33,000 open-end second mortgage in favor ofCenter Street.
83. Additionally, Defgod used a portion ofthe funds Justin Godur stole from Pinnacle and its investors to
purchase a 2025 Chevrolet Tahoe Z71 (the "Truck") on or about December 17, 2024.
84. At the time Defgod purchased the Pennsylvania Properties and the Truck, both Justin Godur and DeFrank
knew the funds used to purchase the Pennsylvania Properties and the Truck had been misappropriated by
Justin Godur from Pinnacle and its investors.
E. Justin Godur is Removed from Pinnacle, Admits His Removal for Cause Was Proper, and Subsequently
Executes and Breaches an Acknowfedgernent of Responsibilities
85. After being served with a copy ofthe Carlyle Litigation's Complaint and learning of Justin Godur's theft
of $1 million frotn Pinnacle Equity II, Pinnacle Capital resolved to

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remove GSJ Capital and Justin Godur as members of Pinnacle Capital and to sever its business relationship
with Justin Godur.
86. On December 17, 2024, Pinnacle Capital executed a Resolution of Removal removing GSJ Capital and
Justin Godur from Pinnacle Capilal for cause.
87. Justin Godur did not dispute his removal or the reasons for his removal.
88. On January 29, 2025, Justin Godur individually and on behalf of GSJ Capital, executed an
Acknowledgement of Receipt and Responsibilities (the "Acknowledgement") recognizing his removal from
Pinnacle Capital for cause. A true and correct copy of that Acknowledgement is attached as Exhibit G.
89. Justin Godur and GSJ subsequently breached a number of their obligations under
. .the Acknowledgement and have failed to cure those breaches despite Pinnacle's written demand
that he do so.
90. Pursuant to section 2.1 of the Acknowledgement, Justin Godur and GSJ agreed to return the $1,000,000
to Pinnacle Equity II on or before December 31, 2025. Justin Godur and GSJ failed to fully comply with this
provision and failed to pay the late fees associated with his late payment.
91. Pursuant to section 2.2 of the Acknowledgement, Justin Godur and GSJ agreed to resolve all outstanding
issues between Pinnacle Capital and ---.
92. Justin Godur and GSJ have failed to do so to date. As further detailed below, --- and --- filed and continue
to maintain a fraudulently recorded UCC financing statement against Plaintiffs, which --- and --- have
refused to release in the face of Plaintiffs' written demands that they do so.
93. Pursuant to section 2.2 of the Acknowledgement and a related January 29, 2025
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Resolution Authorizing Justin Scott Godur to Handle Matters Related to Carlyle Capital Fund, Inc. Lawsuit
(the "Carlyle Resolution"), a copy of which is attached as Exhibit H, Justin Godur and GSJ agreed to handle
all aspects of the Carlyle Litigation on Pinnacle Equity J's behalf, including the retention and funding of
counsel to represent Pinnacle Equity I in the Carlyle Litigation. They further agreed to indemnify Pinnacle
Equity I and each of its members from any liability, damages, or costs, including legal costs, emanating or
arising from the Carlyle Litigation.
94. Justin Godur and GSJ have failed to comply with these obligations. In fact, the attorney Justin Godur
originally retained to represent Pinnacle Equity I in the Carlyle Litigation formally withdrew from the case
on April 15, 2025 due to Justin Godur's failure to pay his attorney's fees. This has exposed Pinnacle to
additional litigation risk and has interfered with Pinnacle Equity l's ability to mount a timely and effective
legal defense to the Carlyle Litigation.
95. Section 2.4 ofthe Acknowledgement requires Justin Godur and GSJ to indemnify Pinnacle Equity I
against any losses or damages suffered because of Defgod's failure to follow through with an agreement to
purchase the 1555 Property from Pinnacle Equity I on February 14, 2025, thereby causing Pinnacle Equity I
to incur additional carrying costs for the 1555 Property. Justin Godur and GSJ have failed to comply with
these obligations.
96. Section 2.5 required Justin Godur and GSJ to refinance the mortgage loan secured by the Mortgage
within fifteen days or else they agreed to be held liable for all ensuing interest payments until the 1555
Property is sold by Pinnacle Equity I. Justin Godur and GS.I have failed to comply with these obligations.

97. Section 2.5 of the Acknowledgement further required Justin Godur and GSJ to reimburse Pinnacle for
$60,960.15 for mortgage payments Pinnacle Equity I made on the
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Mortgage. Justin Godur and GSJ failed to do so, and Pinnacle Equity I has since incurred additional
mortgage payments because of Justin Godur's failure to refinance the Mortgage, all of which Justin Godur
and GSJ are liable for.
98. Section 2.5 also required Justin Godur and GSJ to guarantee $600,000 in investor profits from the sale of
the 1555 Properly. To date Justin Godur has failed to arrange for the purchase and sale of the 1555 Property
despite multiple prior agreements to do so through various entities controlled by Justin and/or Jamie Godur,
all of which have fallen through. He and GSJ have failed to otherwise provide $600,000 in profits to
Pinnacle's investors.
99. Section 2.6 required Justin Godur and GSJ to pay $200,000 in damages to Pinnacle Capital to compensate
it for damages suffered by Pinnacle Capital upon the issuance of a certificate ofoccupancy for the 1555
Property. Justin Godur and GSJ have failed to make this payment to date despite a certificate of occupancy
having issued and Pinnacle having made a written demand for this payment.
100. Section 5.1 of the Acknowledgement provides that Justin Godur and GSJ shall incur a late foe of$200
per day for any late payment owed under the Aeknow ledgernent. Justin Godur and GSJ have not paid any
ofthe late fees owed under the Acknowledgement.
101. Section 5.4 provides that any breaches of the Acknowledgement shall entitle Pinnacle Capital to recover
$ I 00,000 in liquidated damages from Justin Godur and GSJ per breach, in addition to any other remedies
provided for in the Acknowledgement. Justin Godur and GSJ have failed to pay any of the liquidated
damages owed under the Acknowledgement despite Pinnacle's written demand for same.
F. Jamie Godur Guarantees Justin Godur's Obligations Under the Acknowledgement and Subsequently
Breaches His Personal Guarantee
102. On January 30, 2025, Jaime Godur executed a personal guarantee (the
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"Guarantee") pursuant to which he guaranteed the obligations ofJustin Godur and GSJ under the
Acknowledgement. A true and correct copy ofthe Guarantee is attached as Exhibit I.
I 03. Pursuant to section I of the Guarantee, Jaime Godur guaranteed the repayment of $600,000 in profit to
Pinnacle Equity l's investors from the 1555 Property's sale. To date, Jaime Godur has never repaid investors
this $600,000 in profit despite Pinnacle's written demand that he do so.
1
04. Instead, through a series of purchase and sale agreements, Jaime Godur, Q7, and Defgod represented that
they would purchase the 1555 Property from Pinnacle Equity I for up to $2.85 million despite never having
any intention to do so. Jaime Godur, Justin Godur, Q7 and Defgod executed these purchase and sale
agreements knowing they had no intention of performing under them for the sole purpose of delaying
Pinnacle's efforts to recoup investor funds from Justin Godur, all while Justin Godur continued to dissipate
the misappropriated funds he stole from Pinnacle and its investors.
105. Pursuant to section 2 of the Guarantee, Jaime Godur and GSJ guaranteed the payment of $200,000 in
damages to Pinnacle Capital upon the issuance of a certificate of occupancy to the 1555 Property. This
obligation was not continent upon the 1555 Property's sale. Even though a certificate of occupancy has issued
and Pinnacle has made written demand to Jaime Godur for this payment, Jaim~ Godur has failed to pay
Pinnacle Capital the $200,000.

106. Pursuant to section 3 of the Guarantee, Jaime Godur agreed to indemnify Pinnacle and its members from
any claims or lawsuits arising from Justin Godur's actions, including the Carlyle Litigation and Jaime Godur's
dealings with ---. To date, Jaime Godur has failed to comply with these obligations.
l07. Among other things, Jaime Godur has failed to pay for Pinnacle's defense in the
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Carlyle Litigation despite its written demands that he do so. Nor has he taken any action to indemnify,
resolve, or to otherwise hold Pinnacle harmless for Justin Godur's dealings with ---. As further described
below, this has since resulted in --- filing a false UCC Financing Statement against Plaintiffs.
G. --- and --- File False UCC Liens Against Pinnacle, Pinnacle Management, and Pinnacle Income I l 08. On
or around December of 2024, as Justin Godur's fraudulent actions were first
beginning to come to light, --- reached out to Pinnacle to discuss his "exit plan" with respect to the 1555
Property.
I 09. Between December of 2024 and March of 2025, --- attempted to extort a $ I 00,000 "commission" from
Pinnacle, which --- unilaterally decided he was owed for his alleged efforts in securing the mortgage loan
secured by the Mortgage. --- also insisted that the parties enter into an agreement absolving him of any
further obligations with respect to the 1555 Property.
110. --- made these demands despite knowing that he was removed as a member of Pinnacle Capital effective
June 30, 2024-thercby relinquishing any ownership interests, rights, or claims to either Pinnacle Capital or
the 1555 Property-and that neither he nor his company, ---, otherwise had any claim to the $100,000
"commission" he was demanding.
111. Following Pinnacle's refusal to succumb to ---' extortion demands, --- filed a UCC Financing Statement
(the "Financing Statement") on ---'s behalf which purported to encumber the assets of, among other debtor
entities owned or controlled by Justin Godur, the assets of Plaintiffs. The Financing Statement purported to
secure $325,282 in debt, including a $50,000 "loan sponsorship" relating to the 1555 Property, despite the
Plaintiffs having no written agreement with ---. A true and correct copy of the Financing Statement is
attached as Exhibit
20 LEVINE KELLOGG LF,HMAN SCHNEIDf:R + GROSSMAN LU' 100 SE 2nd Street, 36th l'loor,
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J.
I 12. On April 29, 2025, Pinnacle filed a UCC Filing Dispute with the Florida Department ofState to
challenge the filing ofthe fraudulent Financing Statement.
113. To date, --- and --- have refused to withdraw the Financing Statement despite Pinnacle's repeated
demands that they do so and despite knowing that no valid security agreement, lien instrument, agreement, or
other enforceable agreement exists between --- and any ofthe Plaintiffs that could possibly justify --- 's filing
ofthe Financing Statement.
H. Pinnacle Equity I is Threatened to be Sued for Civil Theft Based on Justin Godur's Actions
114. On April 7, 2025, Pinnacle Equity I received a civil theft notice and demand letter from Butternut
Investment Group, LLC and its principals, Shoshana and Benjamin Gibli (the "Butternut Demand"), which
demands $4,500,000 in damages from Defgod, Justin Godur, and Pinnacle Equity I. A true and correct copy
ofthe Butternut Demand is attached as Exhibit K.
115. The Butternut Demand alleges that, on December 26, 2024, Defgod and Butternut entered into a Joint
Venture Agreement (the "Defgod JVA") in connection with the acquisition and development of the 1555
Property pursuant to which Butternut agreed to lend Defgod $1.5 million.
116. Butternut alleges that, pursuant to the Defgod JVA, Defgod agreed that it would purchase the 1555
Property from Pinnacle Equity I, would obtain a loan against the 1555 Property, and would transfer $1.5
million ofthe proceeds to pay back the loan.

117. As a result of Justin Godur's and Defgod's apparent misrepresentations in the Defgod JVA, Butternut has
threatened to sue Pinnacle Equity I for treble damages in the amount of$4.5 million.
I. After Breaching the Acknowledgement, Justin Godur and DeFrank Continue Their
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Scheme ofBuying Pennsylvania Properties
118.
Even after Justin Godur's breach of the Acknowledgement and threats of civil theft from Butternut, Justin
Godur and De Frank continued their scheme of misappropriating and squirreling away investor funds to
purchase properties in Pennsylvania.
119. On April 28, 2025, Justin Godur and DeFrank used No Parcel ID to purchase a property located at 3203
Wallace Drive, New Castle, PA from prior owner Karen Lee Ayers for $130,000. No Parcel ID then used that
property to secure a $204,850 open-end mortgage in favor ofCenter Street, which Defrank executed on No
Parcel ID's behalf.
120. Pinnacle has retained the undersigned law firm to bring this action and has agreed to pay counsel its
reasonable attorneys' fees and costs for its services.
121. All conditions precedent to the filing of this action have occurred, have been performed, or have
otherwise been waived.
COUNT I: BREACH OF ACKNOWLEDGEMENT (against GSJ and Justin Godur)
122. Pinnacle incorporates paragraphs 1 through 121 as iffully set forth herein.
123. This is an action for damages by Pinnacle against Justin Godur and GSJ stemming from their breach
ofthe Acknowledgement.
124. The Acknowledgement is a valid and enforceable contract.
125. Justin Godur and GSJ breached the Acknowledgement by:
(a) Failing to timely refund the entirety of the $1 million referenced in section 2.1 to Pinnacle Equity II on or
before December 31. 2024 or to pay late fees incurred as a result ofJustin Godur's late payment.
(b) Failing to comply with their obligations under section 2.2 by resolving all pending
dealings between himself, --- and Pinnacle Capital, which has resulted in
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---' filing ofthe fraudulent Financing Statement, among other things.
(c) Failing to provide Pinnacle Equity I with a defense in the Carlyle Litigation or to otherwise indemnify or
hold Pinnacle Equity I harmless for liabilities, damages, or costs incurred as a result of the Carlyle Litigation
and Carlyle's claims against Pinnacle Equity I.
(d) Failing to reimburse Pinnacle Equity I $36,625 within 90 days in accordance with section 2.2.
(e) Failing to indemnify Pinnacle Equity f against the losses and damages suffered as a result of Defgod's
failure to purchase the 1555 Property on or before February 14, 2025 or to complete a refinance of the 1555
Property, which has resulted in Pinnacle Equity I having to incur additional carrying costs for the I 555
Property.
(f) Failing to reimburse Pinnacle Equity I for $109,728.27 in mortgage payments made with respect to the
1555 Property.

(g) Failing to pay Pinnacle Equity I $600,000 in damages to cover its lost profits pursuant to section 2.5 ofthe
Acknowledgement.
(h) Failing to pay $200,000 in damages owed to Pinnacle Capital pursuant to section 2.6 ofthe
Acknowledgement.
126. In addition to the above breaches ofthe Acknowledgement, Justin Godur and GSJ owe Pinnacle late fees
of $200 per day for all late payments owed under the Acknowledgement pursuant to section 5.1 thereof.
127. In addition to the above breaches of the Acknowledgement, Justin Godur and GSJ owe Pinnacle
liquidated damages totaling $800,000 for the above-referenced breaches pursuant to section 5.4 of the
Acknowledgement.
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128. Pinnacle has suffered damages as a direct result of Justin Godur's and GS.J's breach of the
Acknowledgement.
WHEREFORE, Pinnacle respectfully requests that this Court award Pinnacle its damages resulting from
Justin Godur's and GSJ's breaches of the Acknowledgement; award Pinnacle its reasonable attorneys' fees
and costs expended in litigating this action; and grant such further reliefas the Court deems j usl and proper.
COUNT II: BREACH OF GUARANTEE (against Jaime Godur)
129. Pinnacle incorporates paragraphs I through 121 as iffully set forth herein.
130. This is an action for damages by Pinnacle against Jaime Godur arising from his breach ofthe Guarantee.
131. The Guarantee is a valid and enforceable contract.
132. Jaime Godur breached the Guarantee by:
(a) Failing to pay $600,000 in profits to Pinnacle Equity I and its investors in accordance with section 2.5
ofthe Acknowledgement.
(b) Failing to pay $200,000 in damages to Pinnacle Capital pursuant to section 2.6 of the Acknowledgement.
(c) Failing to indemnify and hold Pinnacle and its members harmless from claims or
lawsuits arising from Justin Godur's actions, including but not limited to the Carlyle Litigation, ---' claims
against Justin Godur and Pinnacle, and the claims referenced in the Butternut Demand.
133. Pinnacle has suffered damages as a direct result of Jaime Godur's breach of the Guarantee.
WHEREFORE, Pinnacle respectfully requests that this Court award Pinnacle its
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damages resulting from Jaime Godur's breaches of the Guaral)tee; award Pinnacle its reasonable attorneys'
fees and costs expended in litigating this action; and grant such further relief as the Court deems just and
proper.
COUNT III: FRAUD (against Justin Godur, ---, DeFrank, Leander, Minority Builders, and YWB)
I 34. Pinnacle incorporates paragraphs 1 through 121 as iffully set forth herein.
135. This is an action for fraud by Pinnacle Capital and Pinnacle Equity I against Justin Godur, ---, Defrank,
Leander, Minority Builders, and YWB.

136. In order to induce Pinnacle to purchase the 1555 Property, Justin Godur presented Pinnacle with the ---
Purchase Agreement, pursuant to which --- purported to commit to purchasing the renovated 1555 Property
for $6 million before Pinnacle Equity I had even purchased it.
137. The --- Purchase Agreement induced Pinnacle and its investors to agree to Pinnacle Equity I's purchase
ofthe 155 5 Property.
138. --- never had any intention of purchasing the 1555 Property or otherwise performing under the ---
Purchase Agreement.
139. --- was also instrumental in securing the financing for the 1555 Property's purchase, whose acquisition
was negotiated by Justin Godur and ---.
140. Justin Godur, ---, and Defrank thereafter worked with Leander and Minority Builders to arrange for the
submission of false invoices lo Pinnacle Equity I in order to divert $545,765 in funds eannarked for the 1555
Property's development.
141. Specifically, Justin Godur induced Pinnacle Equity I to enter into the YWB Contract with YWB, a
company managed and controlled by Justin Godur and DeFrank.
142. YWB did not itselfprovide any construction services to Pinnacle I Equity.
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143. On October 28, 2024, YWB submitted an invoice for payment which provided that YWB was owed
$523,450 to cover demolition and renovation performed or to be perfonned with respect to the 1555 Property
through that date. YWB also demanded 22,315 in "soft costs" from Pinnacle Equity I. Pinnacle Equity I
wired $545,765 to YWB to cover payment of the invoice and these "soft costs."
144. The work YWB billed for was not actually completed. Instead, a portion of these funds were disbursed
by Godur from YWB's account and used for the for the sole benefit of Godur, DeFrank, and, upon
information and belief, Leander and Leander's various entities, which included White Bison, Blackstar, Regal
and Minority Builders. Upon information and belief, a portion of these funds were disbursed from YWB's
account to YWB Group and YWM, two limited liability companies jointly managed and controlled by Justin
Godur, Defrank, and ---. Upon information and belief. a portion of these funds were disbursed from YWB's
account to Building Lighthouse, a limited liability company managed and controlled by Justin Godur and ---.
145. In order to cover up this fraud, Justin Godur, in his capacity as a member of YWB, directed Minority
Builders and its manager, Leander, to generate an invoice on behalf of Minority Builders reflecting that
payment of $545,765 had been received and that the invoice had been fully satisfied.
146. Justin Godur, ---, Defrank, Leander, Minority Builders, YWB all knew that the work memorialized by
YWB's October 28 invoice had not been performed. They also knew that the "paid" invoice submitted by
Minority Builders was fraudulent and inaccurate. These documents were submitted to Pinnacle in order to
induce Pinnacle Capital and Pinnacle Equity I to pay YWB $545,765 in funds which were subsequently
disbursed to defendants.
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147. In reliance on the named defendants' misrepresentations and omissions, Pinnacle Equity I wired
$545,765 to YWl:3.
148. As a result, Pinnacle Capital and Pinnacle Equity I suffered damages.
WHEREFORE, Pinnacle Capital and Pinnacle Equity I respectfully request that this Court award them their
damages suffered as a result of the fraud perpetrated by Justin Godur, ---, Defrank, Leander, Minority

Builders, and YWB; award Pinnacle Capital and Pinnacle
Equity I their reasonable costs expended in litigating this action; and grant such further relief as the Court
deems just and proper.
COUNT IV: CONSPIRACY TO COMMIT FRAUD (against Justin Godur, ---, DeFrank, Leander, Minority
BuHders, YWB, White Bison, Regal, Blackstar, YWB Group, \'WM, and Building Lighthouse)
149. Pinnacle Capital and Pinnacle Equity I incorporate paragraphs I through 121 as if fully set forth herein.
150. This is an action for civil conspiracy to commit fraud by Pinnacle Capital and Pinnacle Equity I against
Justin Godur, ---, DeFrank, Leander, Minority Builders, YWB, White Bison, Regal, Blackstar, YWB Group,
YWM, and Building Lighthouse.
151. Justin Godur, ---, DeFrank, Leander, Minority Builders, YWB, White Bison, Regal, Blackstar, YWB
Group, YWM, and Building Lighthouse all agreed and combined to engage in a conspiracy to commit fraud
upon Pinnacle.
152. Specifically, they conspired to cause Pinnacle to pay YWB $545,765 for work
that neither YWB nor any ofthe other named defendants actually performed with respect to the 1555
Property.
153. The work YWB billed for was not actually completed. Instead, a portion ofthese
funds were disbursed by Godur from YWB's account and used for the sole benefit of Godur,
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Defrank, and, upon information and belief, Leander and Leander's various entities, which included White
Bison, Blackstar, and Minority Builders. Upon information and belief, a portion of these funds were
disbursed from YWB's account to YWB Group and YWM, two limited liability companies jointly managed
and controlled by Justin Godur, Defrank, and ---. Upon information and belief, a portion of these funds were
disbursed from YWB's account to Building Lighthouse, a limited liability company managed and controlled
by Justin Godur and ---.
154. Justin Godur, ---, Defrank, Leander, Minority Builders, YWB, White Bison, Regal Blackstar, YWB
Group, YWM, and Building Lighthouse engaged in acts to further the conspiracy and each ofthem acquired,
possessed, and maintained a general knowledge of the conspiracy's objective to misappropriate Pinnacle's
funds.
155.
Justin Godur, ---, Defrank, Leander, Minority Builders, YWB, White Bison, Regal, Blackstar, YWB Group,
YWM, and Building Lighthouse engaged in acts to conceal their scheme, including but not limited to
Minority Builders' and Leander's provision of a false invoice reflecting that payment of $545,765 had been
received and applied to work that was never actually perfonned with respect to the 1555 Property.
156. Upon information and belief, and based on, among other documents, text messages received from
Leander and ---, ---, Leander and Defrank coordinated to stop all communication with Pinnacle and to funnel
all future contact through Justin Godur in order to further hide their fraud.
157. As a result of the named defendants' actions, Pinnacle Capital and Pinnacle Equity I have been damaged.
WHEREFORE, Pinnacle Capital and Pinnacle Equity I respectfully request that this
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Court award them their damages suffered as a result of the conspiracy to commit fraud perpetrated by Justin
Godur, ---, Defrank, Leander, Minority Builders, YWB, White Bison, Regal, Blackstar, YWB Group, YWM,

and Building Lighthouse; award Pinnacle Capital and Pinnacle Equity I their reasonable costs expended in
litigating this action; and grant such further relief as the
Court deems just and proper.
COUNT V: FRAUD (against Justin Godur, .Jamie Godur, 07, Capital Max Group, Capital Max, DeFrank,
Dcfgod, and No parcel!)
158. Pinnacle incorporates paragraphs 1 through 121 as if fully set forth herein.
159. This is an action for fraud by Pinnacle against Justin Godur, Jamie Godur, Q7, Capital Max Group,
Capital Max, Defrank, Defgod, and No Parcel.
160. On or about October 30, 2024, Justin Godur forged the signature of Pinnacle Equity II member Patrick
Voltapetti on the Capital Max Group Contract, which contract purported to retain Capital Max Group to
provide consulting services to Pinnacle Equity II.
161. In fact, Capital Max Group provided no such services and Justin Godur used the forged Capital Max
Group Contract to authorize the transfer of $1 million from Pinnacle Equity II to Justin Godur.
162. In fact, Justin Godur went as far as producing a fraudulent Term Sheet in order to justify the
unauthorized transfer. Pinnacle knows this because, without Justin Godur's knowledge, his father, Jaime
Godur, had sent Pinnacle the real term sheet from the lender which was completely different from the one
Justin Godur had produced.
163. Justin Godur and DeFrank then used a portion of these misappropriated funds to purchase the
Pennsylvania Properties, the Truck, luxury goods, extravagant travel, including private jet charters, five-star
accommodations, and high-end dining through Defgod, an entity
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managed and controlled by Justin Godur and DcFrank.
164. At the time Defgod purchased the Pennsylvania Properties and the Truck referenced above, both Justin
Godur and Defrank knew the funds used to purchase the Pennsylvania Properties, the Truck, luxury goods,
extravagant travel, including private jet charters, five-star accommodations, and high-end dining had been
misappropriated by Justin Godur from Pinnacle and its investors.
165. Justin Godur and Defrank also used a portion of these misappropriated funds to purchase the 3205
Property.
166. At the time No Parcel purchased the 3205 Property, both Justin Godur and DeFrank knew the funds used
to purchase 3205 Property had been misappropriated by Justin Godur from Pinnacle and its investors.
167. After Pinnacle began to learn of Justin Godur's fraudulent dealings and removed GSJ and Justin Godur
as members of Pinnacle Capital on December 17, 2024, Jaime Godur assisted Justin Godur, DeFrank, and the
entities they controlled in covering up and masking the extent oftheir fraudulent activities.
168. In order to do so, Jaime Godur executed a number of documents designed to obfuscate Justin Godur's
and DeFrank's actions and to delay Pinnacle's efforts to recoup investor funds from them.
169. Jaime Godur executed a Guarantee of Justin Godur's obligations under the Acknowledgement and
further assured Pinnacle that he would cover Justin Godur's financial obligations under the
Acknowledgement and indemnify Pinnacle and its members and hold them harmless from any claims,
lawsuits or damages arising from .Justin Godur's actions during his tenure at Pinnacle.
30
Lt,;VINE KF.Ll..,OGG LEIII\IIAN SCHNEIDER+ GROSSMAN LLP
100 SE 2nd Street, 36th Floor, Miami Tower, Miami, l'lorida 33131 Main: 305.403.8788 Fax: 305.403.8789

170. Jaime Godur made these representations with no intent to follow through on them, and for the sole
purpose of delaying Pinnacle's attempts to recover its investors' funds while Justin Godur and DeFrank
continued to engage in a series offraudulent transfers in an attempt to hide these funds by, among other
things, pouring them into properties in Pennsylvania which they then leveraged to obtain a number ofopen-
end mortgage loans.
171. Likewise, in order to delay Pinnacle's attempts to recover its investors' funds, Jaime Godur, Justin
Godur, Q7 and Defgod executed purchase and sales contracts for the purchase ofthe !555 Property for up to
$2.85 million despite never having had any intention of perfonning under these contracts. Jaime Godur,
Justin Godur, Q7 and Defgod did so for the sole purpose of delaying Pinnacle's efforts to recoup investor
funds Justin Godur and Defrank continued to engage in a series offraudulent transfers in an attempt to hide
these funds.
172. As a result of the fraudulent actions of Justin Godur, Jamie Godur, Q7, Capital Max Group, Capital
Max, Derrank, Defgod, and No Parcel, Pinnacle has been damaged.
WHEREFORE, Pinnacle respectfully requests that this Court award Pinnacle its damages suffered as a result
of the fraud perpetrated by Justin Godur, Jamie Godur, Q7, Capita! Max Group, Capital Max, Defrank,
Defgod, and No Parcel; award Pinnacle its reasonable costs expended in litigating this action; and grant such
further relief as the Court deems just and proper.
COUNT VI: CONTRACTUAL INDEMNIFICATION (against Justin Godur and GSJ)
l 73. Pinnacle incorporates paragraphs I through 121 as iffully set forth herein.
174. This is an action for contractual indemnification by Pinnacle against Justin Godur and GSJ arising from
the Acknowledgement.
175. Pursuant to section 2.2 and section 31. of the Acknowledgement and the related
31
LlVINF. KELLOGG LEHMA~ SCl!NF.JDER + GROSSMAN LLP I00 SE 2nd Street, 36th floor, Miami
Tower, Miami, l'lorida 33131 Main: 305.403.8788 Fax: 305.403.8789
Carlyle Resolution, Justin Godur and GSJ agreed to (a) resolve all outstanding issues between Pinnacle
Capital and ---; (b) to handle all aspects of the Carlyle Litigation on Pinnacle Equity I's behalf, including the
retention and funding ofcounsel to represent Pinnacle Equity I in the Carlyle Litigation and indemnifying
Pinnacle Equity I and each of its members from any liability, damages, or costs, includi~g legal costs,
emanating or arising from that litigation; and
(c) indemnify and hold Pinnacle and its members harmless from any claims, lawsuits, or costs arising out
ofany actions taken by Justin Godur during his tenure at Pinnacle.
176. Justin Godur and GSJ arc required to indemnify Pinnacle for all liability, damages, expenses, fees, or
costs, including legal fees and costs, emanating or arising from the Carlyle Litigation, .Justin Godur's
dealings with --- and the recording of the Financing Statement, and the Butternut Demand, among other
things.
177. Justin Godur and GSJ have failed and refused to indemnify Pinnacle for these liabilities despite
Pinnacle's written request that they do so.
178. Among other things, Justin Godur and GSJ have failed to pay for Pinnacle's defense in the Carlyle
Litigation, have failed to ensure that the Financing Statement filed by --- and --- is withdrawn, and have taken
no actions to indemnify or hold Pinnacle Equity I harmless with respect to the Butternut Demand.
WHEREFORE, Pinnacle respectfully requests that this Court enter judgment in its favor and against Justin
Godur and GS.I finding that Justin Godur and GS.I have a duty to indemnify Pinnacle for all liability,
damages, expenses, fees, or costs, including legal fees and costs, emanating or arising from the Carlyle
Litigation, Justin Godur's dealings with --- and the recording of the Financing Statement, and the Butternut
Demand; award Pinnacle its reasonable attorneys' fees and costs expended in litigating this action; and grant
such further relief as the

32 LEVINE KELUIGG LEHMAN SCHNF .lrlF,R + GROSSMAN LLP I 00 SF, 2nd Street, 36th floor, Miami
Tower, Miami, Florida 33131 Main: 305.403.8788 Fax: 305.403.8789
Court deems just and proper.
COUNT VII: CONTRACTUAL INDEMNIFICATION (ai:;ainst Jamie Godur)
179. Pinnacle incorporates paragraphs I through 121 as if fully set forth herein.
1
80. This is an action for contractual indemnification by Pinnacle against Jamie Godur arising from the
Guarantee.
181. Pursuant to section 3 ofthe Guarantee, Jamie Godur agreed to indemnify Pinnacle and its members from
all claims, lawsuits, or costs arising from actions or obligations originating during Justin Godur's tenure with
Pinnacle.
I 82. Pursuant to the terms of the Guarantee, Jaime Godur is required to indemnify Pinnacle for all liability,
damages, expenses, fees, or costs, including legal fees and costs, emanating or arising from the Carlyle
Litigation, Justin Godur's dealings with --- and the recording ofthe Financing Statement, and the Butternut
Demand, among other things.
183. Jaime Godur has failed and refused to indemnify Pinnacle for these liabilities despite Pinnacle's written
request that he do so.
184. Among other things, Jaime Godur has failed to pay for Pinnacle's defense in the Carlyle Litigation, has
failed to ensure that the Financing Statement filed by --- and --- is withdrawn, and has taken no actions to
indemnify or hold Pinnacle Equity I harmless with respect to the Butternut Demand.
WHEREFORE, Pinnacle respectfully requests that this Court enter judgment in its favor and against Jamie
Godur finding that Jamie Godur has a duty to indemnify Pinnacle for all liability, damages, expenses, fees, or
costs, including legal fees and costs, emanating or arising from the Carlyle Litigation, Justin Godur's dealings
with --- and the recording of the Financing Statement, and the Butternut Demand; award Pinnacle its
reasonable attorneys' fees
33
LVJNt KELLOGG LEIIMAN SCHNEIDF .R + GROSS.\1/\N LLP I 00 SE 2nd Street, 36th Floor, Miami
Tower, Miami, Florida 3313 I Main: 305.403.8788 Fax: 305.403.8789
and costs expended in litigating this action; and grant such further rel icf as the Court deems just and proper.
COUNT VIII: VIOLATION OF SECTION 817.535 FLORIDA STATUTES (against --- and ---)
185. Plaintiffs incorporate paragraphs 1 through 121 as if fully set forth herein.
186. This is an action by Plaintiffs against --- and --- for violation of section 817.535, Florida Statutes.
187. Pursuant to section 817.535(8)(a), any person adversely affected by an instrument filed in the official
record which contains a materially false, fictitious, or fraudulent statement or representation has a civil cause
of action against the instrument's filer.
188. Section 817 .53 5( I )(b) defines a "filer" as a person who presents the instrument for recording or who
causes the instrument to be recorded.
189. Section 817.525(1)(c)'s definition of an "instrument" includes, among other things, financing statements,
liens, and notices of claims of lien that purport to encumber either real or personal property interests.
190. Upon a finding that a filer filed an instrument with an intent to defraud or harass
. '
an adversely affected party, a court may award actual and punitive damages, subject to the criteria set forth in
768.72, to the party adversely affected, together with a civil penalty of $2,500 for each instrument which
violates the statute.

191. --- executed the Financing Statement on behalf of --- and filed it in the Florida Secured Transaction
Registry on March 10, 2025.
192. --- caused the financing Statement to be filed on March l 0, 2025.
193. The Financing Statement purports to secure a lien held by ---, the secured party, against Plaintiffs,
among other alleged debtors. The secured debt amount purportedly
34 LEVINt: KELLOGG Ll!:H:\fAN SCIIN!cll)F;k + GROSSMAl\ LLP 100 SE 2nd Street, 36th floor,
Miami Tower, Miami, Florida 33131 Main: 305.403.8788 l'ax: 305.403.8789
totals $325,282 and includes, among other things, a $50,000 "Loan Sponsorship" fee relating to the 1555
Property.
194. The Financing Statement contains false information. Plaintiffs do not owe either Mui I ins or --- any
amounts of money relating to the 1555 Property or otherwise.
195. At the time the Financing Statement was tiled, both --- and --- knew that --- had no valid lien, claim of
lien, contract, security agreement, agreement, or any other enforceable agreement with Plaintiff.,; that would
justify ---'s filing of the Financing Statement.
l 96. In fact, the Financing Statement's filing was the culmination of a months-long attempt by --- to extort a
$100,000 "commission" which --- unilaterally decided he was owed in connection with the 1555 Property's
mortgage loan.
197. The Financing Statement was recorded for the purposes of defrauding and harassing Plaintiffs and
ultimately bullying and intimidating them into paying --- his claimed "commission."
198. On April 29, 2025, Plaintiffs filed a UCC Filing Dispute with the Florida Department ofState to
challenge the filing ofthe fraudulent Financing Statement.
199. Despite that filing and Plaintiffs' subsequent written demands, --- and --- have refused to withdraw the
Financing Statement.
200. Pursuant to section 817 .525(8)( c ), Plaintiffs are entitled to recover their reasonable attorneys' fees and
costs for litigating this action.
WHEREFORE, Plaintiffs respectfully request that this Court award them their damages incurred as a result
of ---'s and ---'s violation of section 817.525; award Plaintiffs their reasonable attorneys' fees and costs
expended in litigating this action; and grant such further
35 LEVINE K:U,OGG LEHMAN SCIINF.IDER +GROSSMAN LLP I 00 SE 2nd Street, 36th Ploor, Miami
Tower, MiHlni, Florida 33131 Main: 305.403.8788 Fax: 305.403.8789
relief as the Court deems just and proper.
COUNT IX: FRAUD (against --- and ---)
20 I. Plaintiffs incorporate paragraphs I through 121 as iffully set forth herein.
202. This is an action fo; fraud by Plaintiffs against --- and ---.
203. --- executed the Financing Statement on behalf of --- and filed it in the Florida Secured Transaction
Registry on March I 0, 2025.
204. --- caused the Financing Statement to be filed on March I 0, 2025.
205. At the time the financing Statement was filed, --- and --- knew that it fraudulently claimed that ---
maintained a secured lien against Plaintiffs.
206. While --- and --- claimed that --- maintained a secured debt totaling $325,282 which included a $50,000
"Loan Sponsorship" tee relating to the 1555 Property, Plaintiffs did not owe either --- or --- any amounts of

money relating to the 1555 Property or otherwise.
207. At the time the Financing Statement was filed, both --- and --- knew that --- had no valid lien, claim of
lien, contract, security agreement, agreement, or other enforceable agreement with Plaintiffs that would
justify ---'s filing of the Financing Statement.
208. In fact, the Financing Statement's filing was the culmination of a months-long
attempt by --- to extort a $100,000 "commission" which --- unilaterally decided he was owed with the 1555
Property's mortgage loan.
209. The Financing Statement was recorded with the intent of defrauding Plaintiffa and ultimately inducing
them to pay --- his claimed "commission."
210. On April 29, 2025, Pinnacle filed a UCC Filing Dispute with the Florida
36 LEVINE KELLOGG LF.HMAN SCHNEIDrn + GROSSMAN LLP I00 Sf:; 2nd Street, 36th 1-"loor,
Miami Tower, Miami, l'lorida 33131 Main: 305.403.8788 Fax: 305.403.8789
Department ofState to challenge the filing ofthe fraudulent Financing Statement.
211. Despite that filing and Plaintiffs' subsequent written demands, --- and --- have refused to withdraw the
Financing Statement.
212. As a result of the Financing Statement's recording, Plaintiffs have been damaged.
WHEREFORE, Plaintiffs request that this Court award them their damages suffered as a result of the fraud
perpetrated --- and ---; award Plaintiffs their reasonable costs expended in litigating this action; and grant
such further relief as the Court deems just and proper.
COUNT X: CIVIL THEFT (against Justin Godur, ---, DeFrank, Leander, Minority Builders, and YWB)
213. Pinnacle Equity I incorporates paragraphs 1 through 121 as if fully set forth herein.
214. This is an action for civil theft by Pinnacle Equity I againstJustin Godur, ---, DeFrank, Leander,
Minority Builders, and YWB pursuantto section 772, 11, Florida Statutes.
215. Through the issuance of false invoices and the making of false representations, Justin Godur, ---,
Defrank, Leander, Minority Builders, and YWB caused Pinnacle Equity I to wire YWB $545,765 which
belonged to Pinnacle Equity I with the felonious intent to permanently deprive Pinnacle Equity I of those
funds and to appropriate those funds for the named defendants' own use.
2 I 6. The $545,765 in funds at issue were wired by Pinnacle Equity I to YWB and were subsequently
disbursed by YWB to the remaining named defendants for their own use and benefit.
217.
As a result ofthe named defendants' actions, Pinnacle Equity I has been injured.
218. In an effort to avoid this lawsuit and recoup its loss, Pinnacle Equity I made a 37
LEVINI!: KELLOGG LEHMAN SCIINEIDER + GH.OSSMAN LU' I 00 SE 2nd Street, 36th Floor,
Mia111i Tower, Miami, Florida 33131 -Main: 305.403.8788 -Fax: 305.403.8789
written demand upon each of the named defendants to repay the $545,765 in stolen funds on April 30, 2025.
219. As ofthe filing ofthis lawsuit, the named defendants have refused to pay back the $545,765 at issue.
220. Accordingly, Pinnacle Equity I is entitled to recover treble damages, m the amount of$1,637,295, from
the named defendants.
221. Additionally, Pinnacle Equity I is entitled to recover its reasonable attorneys' fees and costs expended in
litigating this .action pursuant to section 722.11 (1 ), Florida Statutes.
WHEREFORE, Pinnacle Equity I requests that this Court award it treble damages in the amount of
$1,637,295 as a result of the civil theft perpetrated by defendants Justin Godur, ---, DeFrank, Leander,

Minority Builders, and YWB; award Pinnacle Equity I its reasonable attorneys' fees and costs expc~ded in
litigating this action; and grant such further relief as the Court deems just and proper.
COUNT XI: CONVERSION (against Justin Godur, ---, DeFrank, Leander, Minority Builders, and YWB)
222. Pinnacle Equity I incorporates paragraphs 1 through 121 as if fully set forth herein.
223. This is an action for conversion by Pinnacle Equity I against Justin Godur, ---, DeFrank, Leander,
Minority Builders, and YWB.
224. Through the issuance of false invoices and the making of false representations, Justin Godur, ---,
Defrank, Leander, Minority Builders, and YWB caused Pinnacle Equity I to wire YWB $545,765 which
belonged Pinnacle Equity I with the intent to deprive Pinnacle Equity I ofthose funds.
225. The $545,765 in funds at issue were wired by Pinnacle Equity I to YWB and were 38
LF.VINF, KELLOGG LicHMAN SCHNEmER + GROSSMAN LLP 100 SJ-: 2nd S1reet, 36th Floor, Miami
Tower, Mia111i, Florida 33131 -Main: 305.403.8788 Fax: 305.403.8789
subsequently disbursed by YWI3 to the remammg named defendants for their own use and benefit.
226. Through their actions, the named defendants deprived Pinnacle Equity I of its use ofthe funds and
converted those funds for their own use.
227. The named defendants' actions have caused Pinnacle Equity I to suffer damages.
WHEREFORE, Pinnacle Equity I requests that this Court aw~rd it damages in the amount of $545,765
resulting from the conversion of its funds perpetrated by defendants Justin Godur, ---, Defrank, Leander,
Minority Builders, and YWB; award Pinnacle Equity I its reasonable costs expended in litigating this action;
and grant such further relief as the Court deems just and proper.
COUNT XII: ACCOUNTING (against Defendants)
228. Pinnacle incorporates paragraphs 1 through 121 as iffully set forth herein.
229. This is an action for an accounting by Pinnacle against Defendants.
230. As further detailed in Complaint's factual allegations, Justin Godur and GSJ orchestrated a coordinated
scheme with the other named defendants to misappropriate Pinnacle's investor capital and deprive Pinnacle,
its members, and its investors of millions of dollars in funds.
231. Justin Godur used his and GSJ's position as members of Pinnacle to facilitate this scheme.
232. As a result of concentrated efforts by a number ofthe Defendants named herein to obfuscate and hide the
extent of Justin Godur's actions, Pinnacle does not have sufficient information to detennine the full extent of
Justin Godur's fraud or the amounts of Pinnacle's funds that were withdrawn and/or transferred by Justin
Godur and GSJ to the other Defendants
39
LEVINE: KEi,LOGG LEHMAN SUINEJDE:R + GROSSMAN LLP I 00 SE 2nd Street, 36th l'loor, Miami
Tower, Miami, f:lorida 33131 Main: 305.403.8788 fax: 305.403.8789
named herein.
233. An accounting from Defendants of all funds received, transferred, or retained
from Pinnacle from August I, 2024 to date is necessary in order to determine the exact amount
of Pinnacle's and its investors' funds that have been misappropriated by Justin Godur and the
remaining Defendants.
234. Pinnacle has made a written demand for an accounting to Defendants, who have
not complied with its request.

235. Pinnacle has no other adequate remedy at law for obtaining this accounting.
WHEREFORE, Pinnacle requests that this Court compel Defendants to provide an
accounting ofany and all funds received, transferred, or retained from Pinnacle from August 1,
2024 to date; award Pinnacle its reasonable costs expended in litigating this action; and grant
such further relief as the Court deems just and proper.
Dated: June 11, 2025 Respectfully submitted,
LEVINE KELLOGG Lt,;HMAN SCHNEIDER+ GROSSMAN LLP
Counsel for Plaintiff~
I 00 SE 2nd Street, 361h Floor Miami Tower Miami, FL 33131 Telephone (305) 403-8788 Facsimile (305)
403-8789
By: ls/Victor Petresc11
JEffREY C. SCHNEIDER, P.A.
Florida Bar No. 933244
Primary: [email protected]
Secondary: [email protected]
VICTOR PETRESCU, ESQ.
Florida Bar No. 0085268
Primary: [email protected]
Secondary: [email protected]
40 LEVINE KELLOGG LHIMAN SCH~EIDISR + GROSSMAN LLP 100 SE 2nd Street, 36th Floor,
Miami Tower, Miami, florida 33131 Main: 305.403.3788 fax: 305.403.8789
41
LEVli\E KELI.OGG LEHMA'.11 SCIINEIUtR + GROSSMAN LL!'
100 SE 2nd Strcel, 36th floor, Miami Tow~r. Miami, Florida 33131 Main: 305.403.8788 1-ax: 305.403.8789
EXHIBITS CAN BE SEEN WITH THIS LINK HERE FOR BETTER VIEWING VS THE PDF to TEXT TRANSLATION BELOW
See Exhibits
Exhibit A
Instr# 119824909 , Page 1 of 2, Recorded 09/30/2024 at 04:02 PM Broward County Commission Deed Doc Stamps: $12425.00
This Document Prepared By and Return to:
Gary S. Dunay, Esq.
Gary S. Dunay, PA
225 NE Mizner Boulevard, Suite 510
Boca Rston, Florida 33432
Pmel ID Number: 484305090430
'Yarranty Deed_Yh. :.
Th,s Indenture, Made this \ l.; day of ,-t'.'.1, + ,2024 A.O., Between Ronald Jakubas and Lisa Jakubas, his wife of the Cu111y of Palm Beach, State of
Florida, grantors, and PINNACLE ONE EQUITY FUND I LLC, Florida limited liability company whose address is: 1555 SE 7th Street, Deerfield Beach,
FL 33441 of the County of Palm Beach, State ofFlorida, grantee. Witnesseth that the GRANTORS for and in consideration of the sum of TEN DOLLARS
($10) DOLLARS, and other good arid valuable consideration to GRANTORS in hand paid by GRANTEE, the
receipt whereof is herehy acknowledged, have granted, bargained and sold to the said GRANTEE and GRANTEE'S heirs, successor~ and assigns forever,
the following described land, situate, lying and being in the County ofPalm Beach, State ofFlorida to wit:
Lot 5, Block 36, The Cove 2nd Section, according to the map or plat thereof, as recorded in Plat Book 33, Page(s) 27, ofthe Public Records ofBroward
County, Florida
Subject to comprehensive land use plans, zoning, restrictions, prohibitions and other requirements imposed by governmental authority, restrictions and
matters appearing on the plat or otherwise common to the subdivision, public utilities, easements ofrecord, and all other matters ofpublic record, without
reimposing same.
Subject Lo taxes for the year 2024 and all subsequent years which are not yet due and payable.
Together with all the tenements, hereditaments and appurtenances thereto belonging or in any wise appertaining; to have and to hold the same in fee
simple forever.
And the Grantor hereby covenants with Grantee that the Gran.tor is lawfully seized of said land in fee simple, that Grantor has good right and lawful
authority to sell or convey said land, that the Grantor hereby fully warran1s the title to said land and will defend the same against the lawful claims ofall
persons whomsoever.
Instr# 119824909, Page 2 of 2, End of Document
and the grantors do hereby fully warrant the title to said land, and will defend the same against lawful claims ofall persons whomsoever.
In Witness Whereof; the grantors have hereunto set tlicir hands and seals the day and year first above written.
s;gn~,~~~Q;~red mour P'~""'"QJQ[ / tL--
Prbrtfd Name.b~"-e( =Rc....o_n-al_d_J_a_k_u_b~s= ~'--"'-"---.
P.O. Address; ~:J 5 f.lf:;. M/; l,N21; fi\\J-., Address; 13264 Sil er Fo Lane Wi1ncss ;[ >1 Cl 1 !lo~ R.:.:.J-.on, ft-. 3~'a,l Palm Beach Gardens, L,33418
is
Address: 1326 Iver Fox Lane Palm Beach Gardens, FL 33418
State ofFlorida County ofPalm Beach
The foregoing instrument was acknowlcd cd before me by means of[ X] physical presence or [ ] on line notnriza1io11, this ~~ay ofAugust, 4, by Ronald
Jakubas and Lisa Jakubas, who are personally known 10 me or __ who have produced their Florida's driver licenses as
identification. ~ -

Exhibit C
Docusign Envelope ID: A 1C032C 1-3DEA-45O1-842D-14A53C5317EC
Capital Max Group LLC Retainer and Consultation Agreement for Commercial Lending Services
This Agreement is made and entered into this 3!.___day of september2024, by and between:
Consulting Party: Capital Max Group LLC , whose principal address is 1515 s Federal Hwy suite 319, Boca Raton, FL, 33432 ("Consultant"),
and
Client: Pinnacle one Equity Fund II LLC, whose principal address is 1515 s Federal Hwy Suite 318, Boca Raton, FL, 33432 ("Client").
WHEREAS, the Consultant has access to contacts and relationships within the commercial
lending industry; and
WHEREAS, the Client is seeking a commercial real estate loan and would like to utilize the Consultant's services to facilitate an introduction to a suitable
lender.
NOW, THEREFORE, in consideration of the mutual covenants contained herein, it is hereby agreed as follows:
Article 1: Scope of Work
1.1 LoanApplication and Consultation: Consultant will collect all necessary information regarding the Client's commercial real estate loan needs and will
approach suitable lenders to preliminarily determine whether the loan can be approved.
1.2 Due Diligence: Consultant is solely responsible for pre-qualifying lenders and ensuring that they are legitimate and competent to perform the services
required to close a commercial loan.
Article 2: Compensation
2.1 Retainer Fee: Upon entering thisA.greement, Client agrees to pay Consultant a retainer fee of $1,000,000 ("Retainer Fee").
2.2 Refundabl~ ConditionsThe Retainer Fee is refundable at the sole discretion of the
Consultant, under any circumstances.
2.3 Limitation of LiabilityThe Consultant shall not be liable for any damages, losses, or
expenses incurred by the Client if a loan is not secured for any reasonJhe Retainer Fee is refundable at the sole discretion of the Consultant, under any
circumstances.
Docusign Envelope ID: A 1C032C1-3DEA-4501-842D-14A53C5317EC
Article 3: Exclusivity and Non-Circumvention
3.1 Exclusivity: Upon payment of the Retainer Fee, the Client agrees not to seek or accept similar services from another party or directly approach
lenders introduced by the Consultant for a period of 180 days from the date of this Agreement.
Article 4: Limitations and Liabilities
4.1 The Consultant shall not be held liable for any action or omission by any lender to whom the Client is introduced.
4.2 Client acknowledges that a verbal confirmation from a lender does not guarantee the closing or final approval of the loan.
Article 5: Confidentiality
Both parties agree to maintain the confidentiality of all information obtained during the execution of this Agreement.
Article 6: Termination
This Agreement may be terminated by either party with written notice, subject to the refundable conditions outlined in Article 2.2 and 2.3.
Article 7: Governing Law
This Agreement shall be governed by and construed in accordance with the laws of the State of
Florida
Article 8: Amendments
Amendments to this Agreement must be in writing and signed by both parties.
Consultant:
Justin Godur
Name Justin Godur
Date 09/27/2024
Client:
/Ja:eud Vo~
Name /Jat;-~ v~~ Date 09/27/2024
Docusign Envelope ID: A1C032C1-3DEA-4501-842D-14A53C5317EC
By entering into this agreement with Pinnacle One Equity Fund II, LLC, you ("Client") hereby give explicit permission and approval for Capital Max
Group LLC, ("Consultant") to bill using bank wire, for the retainer fee previously mentioned in Article
2.1 of thisi\greement. You acknowledge and agree that this transaction is refundable at the sole discretion of the
Consultant, under any circumstances.
P~v~~,H-;.
cIient Signature: ----~__,,_
---________________
Exhibit D
INDEPENDENT CONTRACTOR SERVICES AGREEMENT (NON-EMPLOYEE COMPENSATION CONTRACT)
This Independent Contractor Services Agreement (the "Agreement") is entered into on this 29th day ofOctober. 2024 by and between Yes We Build LLC
("Contractor") and Pinnacle One Equity Fund I, LLC a limited liability company or S Corp ("Client") for services to be rendered at 1555 SE 7th St
Deerfield Reach 33441.
Contractor ,viii commence work on or befon; November Ist. 2024 and will perfonn the same on a daily basis.
Completion is defined as passing final inspection, completion offinal punch list verified by Client, and final cleaning finished.
This work shall be completed on or before May 1st. 2025
Contractor Initials: ..:.~:....______
Contractor and Client hereby agree to the following:
I. Independent Contractor: Contractor and Client intend this Agreement to be one ur independent contractor and client. Accordingly, Contractor retains
the sole right to control or direct the manner in which the services prescribed herein are to be performed. Subject to the foregoing, Client retains the right
to inspect, to stop work, to prescribe alterations, and generally tu supervise the work lo insure its quality and confonnity with that specified in this
Agreement. Contractor and Client understand that it is the Contractor's sole and complete responsibility to pay all employment taxes, including Federal
and State withholding taxes and Social Security, and to obtain insurance, including worker's compe11saliu11 coverage and public liability insurance and
property damage insurance arising out ofor relating to this Agreement. Contractor waiTants that upon signing orthis Agreement that Contractor has
obtained all stated and necessary insurance and that it shall be kept in full force and effect until the completion ofthe work contracted for herein, and that
the Client shall be named as an additional insured on all ofthe Contractor's insurance policies. The terms ofthis Agreement shall apply to and encompass
all services rendered by any/all sub-contractors pe1forming services on behalfofthe Contractor. To the fullest extent permitted by law, the Contractor
shall indemnify and hold harmless the Client, Client's representatives, agents and employees from all claims, losses, damages und expenses arising out
ofor resulting from the performance ofthe work, including but not limited to any such claim, loss, damage or expense caused in whole or in part by any
negligent act or omission ofthe Contractor, anyone directly employed by them or anyone whose acts they are liable for.
2. Sen-ices Provided: Contractor agrees to perfo1111 the services listed in this contract (as contained in Exhibit "A", attached hereto and made a part
hcrcofhy reforence) on behalfofthe Client.
3. Project Cost Estimate: Pre-construction estimates for construction costs and coordination are approximately: $/ 885,000.00.

1 The Contractor shall use the Contractor's best efforts and make every effort possible to keep costs ofconstruction with stated budget and in an event the
costs surpass estimates, the Contractor will follow the rules ofchange orders, stated in this dOCl1ment.
4. Taxes and Building Permits: The Contractor understands and agrees that he shall be responsible for all taxes, fees and expenses imposed directly or
indirectly for its work, labor, material and services required to fulfil) this contract. The Contractor is responsible for all pcnnits pertaining to the law,
ordinances and regulations where the work is performed.
5. Inspections: The Contractor shall call for all building inspections, meet with the inspecto1s, and ensure that all work contemplated herein passes all
required building inspections, The Contractor shall pay for the entire cost ofany re-work resulting from a failed inspection. Jr the Contractor tails to pay
for any re-work inspection costs, the Client may deduct the reasonable costs against any sums due to the Contractor.
6. Clean-up: Contractor wi11 be responsible for cleaning up thejob on a daily basis, including al I generated construction debris, drink cans, food
wrappers, and/or other trash, If the Client determines in the Client's sole discretion that the Contractor is not cleaning upthe job on a daily basis, the
Client may have tilejob cleaned up on a daily basis and can deduct the reasonable costs against any sums due to the Contractor.
7. Client Approval: Client will approve Contractor services on the following basis: a, The services meet all governing building codes,
b. All required building permit inspections have been completed and passed.
c.
The services have been completed including all punch-out work as agreed.
8. Invoicing and Payments: See the payment schedule as contained in Exhibit "B", attached hereto and made a part hereofby reference.
9. Change orders: The Contractor understands and agrees that no change orders or contract additions may be made unless agreed to
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in writing by the Client and Contractor. This includes but is not limited to alternations, additions, or small changes made in the work
orthe method ofperfonnance. Ifany additional work is performed and not covered in this Agreement, the Contractor proceeds at the
Contractor's own risk and expense and hereby waives any rights to reimbursement or contribution from the Client, in addition to
waiving any other rights that may become available lo thi:: Contractor to he compensated for the additional work.
10. Cancellation: The Client may, without any further obligation or penalty, (i) (;ancel any ofthe services in this contract which have not been completed
by the Contractor within the speci lied time frame and/ or (ii) cancel, at any time, any ofservices in this Agreement which have not yet been started by the
Contractor. !Jpon such cancellation, the Contractor shall only entitled to compensation for the work performed. No compensation will he due for any and
all of(i) the work that has not been started, and (ii) the portion of1.he work that is remaining lo be completed.
11. Penalties: Ifthe Contractor delays completion ofthe work beyond May Ist. 2025 , the Client may reduce the Contractor's fee by the sum of$! SO for
each day the Co11traclor delays completion ufthc work beyond the aforementioned dale. Or, ifthe payment has already heen made, the Contractor shall
reimburse to Client the sum of$] 00 for ea(;h day the Contractor ddays completion ofthe work beyond the aforementioned date. The completion date may
be adjusted for change orders (including price and time changes), if in a signed writing between the Contractor and the Client. Ifthe Contractor
completes the work before
May I st, 2025, the Client will pay a bonus of$50 for eve1y day early the contractor finished ahead ofthe aforementioned date.
Contractor Initials: ,ilfi.
12. Warranty: The Contractor warrants all services for one year alter completion. Ifany item develops a problem within one year of completion, the
Contractor shall repair it within three (3) business days ofbeing notified hy the Client, at no additional expense to the Client. Ifthe Contractor does not
make the requested n:pairs within three (3) business days, the Client may have a third pa11y completethe repairs ,:md the Client may charge the
Contractor for all reasonable costs incum:d to complete the repairs.
13. Waiver: Failure ofthe Client tu insist upon strict compliance ofany ofthe provisions ofthis J\grcemcnt sha!l not constitute a waiver ofany violation, nor
shull any partial puyment outside ofthe "payment scheduli::" be deemed as a waiver ofany ofthe Client's rights to strict compliance with any ofthe tenns
ofthis Agreement.
14. Address: The Contractor herewith provides to Client the true and con-eel residence address, home phone number, and Federal Employer
Identification Number or Social Security Number.
15. Mediation: The Client and Contractor agree that ifany controversy or claim arising out oror relating to this Agreement cannot he settled through
direct dis(;ussions, they shall tittempt to settle the controversy or claim through mediation. The parties shall mutually agree on a qualified mediator
licensed to practice law in Florida or a retired judge, and the mediation shall take place in the City of Boca Raton. Each party shall bear its own costs,
and the mediation fees shal I be shared eqL1ally. The parties agree that the remedy for any claim brought pursuant to this Agreement shall be limited to
actual damages, and in 110 event shall any party he entitled to recover punitive or exemplaiy damages, rescind this Agreement, or seek injunctive or any
other e4uitahle relief.
16. Controlling Law:
a. This Agreement shall be governed and construed in accordance with the internal laws ofthe State ofrlorida applicable to contracts entered into and
fully to be performed therein. To the extent the arbitration provisions ofthis Agreement are not enforced or court proceedings urc otherwise required,
commenced, or maintained, the parties consent and agree to the exclusive jurisdiction and venue oflhe state and federal courts havingjurisdiction in Palm
IJea(;h County, Florid1:1, with respect to any action that any pa11ydesires to commence arising out ofor in connection with this Agreement or any breach
or alleged breach ofany provision ofthis Agreement, and all parties waive any objection as to improper venue or that any state or federal cow1 of Florida
is an inconvmient
forum.
b. Nothing in this Agreement shall be construed lo require the rnmmission ofany act conlmry to law, and in the event ofanyconflict between any provision
ofthis Agreement and any present or future statute, law, ordinan(;e, or regulation, the latter shall prevail. The provision ofthis Agreement atfocted
theri::by shall be modified only to the extent ni::ccssa1y to bring it within legal requirements; such provbion shall be deemed stricken and severed from
this J\grccment, and the remaining terms ofthis Agreementshall continue in full force and effect.
17. Time is ofthe essence lo this Agreement.
18. No Rule ofConstruction Against the Drafter. Any rule ofconstruction to the effect that any ambiguity is to be resolved against the drafting parties shall
not be applied to the interpretation ofthis Agreement.
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19. Entire Agreement: The Agreement constitutes and represents the entire agreement between the Client and the Contractor, and supersedes and
extinguishes all prior agreements, understandings, representations, wan-anties and arrangements ofany nature, whether oral or written, between the
parties relating to the work to be perfom1ed hereunder. The Agreement shal I be binding upon and inure to the benefit ofthe parties and their respective

successors and permitted assigns. The Agreement is not torthe benefit ofany other person, and no other person shall have any right under the Agreement
against either party.
20. Special Stipulations: The following stipulations, ifin conflict with any ofthe preceding, shall control: The Contmctor and any/all sub-contractors
rendering services on hchalfofthe contractor waives his/her right to hold the Client liable for any and all injuries occurring as a result ofservices rendered.
21. Safety Requirements:
21.I Contractor Responsibility for Safety. Contractor shall, at its own expense, be solely responsible for protecting its employees, subcontractors, material
suppliers and all other persons from risk ofdeath, injury or bodily harm arising from or in any wayrelated to the work or the site where it is heing
performed and ensuring full compliance with all government safety and FLORIDA OSHA rules and regulations.
21.2 Safety L.iws and Indemnity Agreement. Contractor shall fully comply with all laws, orders, citations, rules, regulations, standards and statutes
concerning occupational health and safety, accident prevention, safety equipment and practices, including hut to limited to federal and FLORIDA/OSI IA
regulations. Such safety equipment and practices include but arc not limited to:
Wearing harnesses or preventative fall protection
Wearing eye protection
Wearing hard hats
Tools shall not be altered in any way (e.g., no pin guards on saws)
No wires or extension cords shall be left exposed.
Contrnctor shall also immediately pay all fines or penalties assessed upon Contractor or Owner relating to the work
21.3 No Alcohol or Drugs. Contractor shall prohibit and prevent the presence or use ofalcohol or drugs by its employees, permitted subcontractors or
suppliers at a job location or performance ofthe work by any persons under the intluence ofalcohol ordrugs
22. Force Majeure (Acts ofGod): The Contractor shall not be liable for any delays in the completion ofthe project caused by events or conditions beyond
the Contractor's reasonable control, including but not limited to acts ofGod, natural disasters (such as hurricanes,floods, or earthquakes), fire, war,
government regulations, strikes, or other events that could nut have heen anticipated or avoided by the exercise ofreasonable diligence (each, a "Force
Mt1;jcure Event").In the event ofa delay caused hy a Force Majeure l,vent, the Contractor shall promptly notify the Client in writing, detailing the nature
orthe delay, the antidpated duration, and any steps heing taken to mitigate the delay. The completion dale for the project w ilIhe adjustedaccordingly to
account for the duration ofthe Force Majcure Event, and no penalties for delays will apply during this period. Ifa Force Majeurc Event continues for an
extended period (to be defined by the parties, e.g., 30 days or more), the Client and Contractor shall discuss potential solutions, including the possible
le1111ination ofthis i\grccment if mutually agreed upon.
IN WITNESS WHEREOF, all ofthe pa1ties hereto affix their lrnnds and seals.
CH, ot Dato . ________
Contractor: Justin Godur Date: 29.,_,/1'--"0"--'/2=-4,________ _
Social Security or Federal ID#: 595-79-7 445 Address: 1515 S Federal Hwv
EXHIBIT "A" SERVICES PROVIDED EXHll31T "B" PAYMENT SCHEDlJLF.
EXHIBIT "C" INSURANCE AGREEMENT
Cost for services and luhor rendered b: $.________
Total cost for the services contained in this Agreement including labor and materials is:$ I.885.000.00
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DISCLAIMER: This document is for infomiational pt1rposes only and shot1!d not be regarded as legal advice. Pinnacle One Equity Fund 1, LLC does
not provide legal advice and they make no warranty or representation regarding the us~ ofthis document. Pinnacle One Equity Pund 1, LI .C
recommends that students should always receive legal advice from a real estate attorney located in the student's state ofbusiness before using any legally
prepared documents such as this one. Stale real estate laws differ throughout the country and therefore it is necessary lo make sure all legal documents
are compliant with your slate laws. Pinnacle One Equity Fund 1, LLC re-states that this document is for informational purposes only and not to be used
outside ofa learning environment. Pinnacle One Equity Fund I, LLC shall not assume any liability for damages, ofany kind whatsoever, relating to the
use, misuse or reliance ofthis document. By viewing this document, you acknowledge, understand and accept the foregoing.
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Payment Schedule Exhibit "B"
PROJECT ADDRESS: !555 SE 7th St Deerfield Beach 33441
CONTRACTOR: Yes We Build, LLC
CLIENT: Pinnacle One Equity Fund I, LLC
Payment Schedule as follows PAYMENT# DATE AMOUNT($)1st Payment 10/29/2024 $22,315 Soft Costs
Milestones and Benchmarks:
Preliminary Design Work, Electrical Repair, Geotechnical Report. These
Items are not in the construction budget and will be billed separately.
2nd Payment 10/29/2024 $523,450
Milestones and Benchmarks:
Deposit for Materials, Start of Demo 3rd Payment $320,387
Milestones and Benchmarks:
Framing Complete
4th Payment $320,388 Milestones and Benchmarks:
Rough-Ins Complete
5th Payment $320,387Milestones and Benehmarks:
Finishing Work Complete
6th Payment $320,388 Milestones and Benchmarks:
Exterior Work Complete
Contingency (Included in Bid): $80,000TOTAL: $1,885,000 + $22,315 Soft Costs (Billed Sevarately)
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Exhibit "C"
fNDEMNIFICATION, HOLD HARMLESS & INSURANCE AGREEMENT
A. INDEMNIFICATION AND HOLD HARMLESS
To the fullest extend permitted by law, Yes We Build, LLC (Contractor) agrees to defend, indemnify and hold harmless Pinmrcle One Equity Fund I, LLC
(Owner), its/their officers, directors, agents and employees from and against any and all claims, suits, liens, judgments, damages, losses and expenses
including reasonable legal fees and costs arising in whole or in part and in any manner from acts, omissions, breach or default of Contractor, in

connection with performance ofany work by Contractor, its officers, directors, agents, employees and subcontractors.
B. INSURANCE
Contractor hereby agrees that it will obtain and keep in force an insurance policy/policies to cover its liability hereunder and to defend and save harmless
Owner in the minimum amounts of$1,000,000 per occurrence (or another appropriate agreed upon amount) for personal injury, bodily injury and
property damage.
Said Liability policies shall name Owner as additional insured and shall be primary to any other insurance policies.
Contractor will obtain and keep in force Workers Compensation insurance including Employers Liability to the full statutory limits.
Contractor shall furnish to the Owner certificates of insurance evidencing that the aforesaid insurance coverage is in force.
Project Location/Address: 1555 SE 7th StDeerfield Beac/r 33441
Contractor: Yes We Build, LLC
1]u.rt/11 Godut 29/10124
Authorized Signature:_ _i, _ dur ____ Date -----.
J_.,,t Go_ _(o_cr_29,_20_24_14_,~_Eo_r1 __
PINNACLE ONE CAPITAL
Pinnacle One Equity Fund I, LLC
1515 S Federal Hwy, Suite 318, Boca Raton, FL 33432
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Exhibit E
YesWeBuildLLC (954) 400-9837 [email protected]
Invoice
Bill to Pinnacle One Equity Fund I LLC
SERVICE INFO
Contractor fee application 1 ( see attached)
Invoice#
356899-000002
Date issued Oct 28,
2024
PO#
Next payment due
Oct 28, 2024
QTY UNIT UNIT PRICE TAX TOTAL
$523,450.00
Subtotal
Tax
Total (USD)
$523,450.00
$523,450.00 $0
$523,450
APPLICATION AND CERTIFICATE FOR PAYMENT
TOOWNER PROJECT: l555SE71h Dee,field B<>ach Fl 33~41
FROM CONTRACTOR: AACHITECT: Madsen Desi~ MinorityBuilders LI..C Greg Madsen 5500Glasdes RD Ste. 500 6oca Raton FL33431
CONTRACT FOR: 1555SE 7th Reno
CONTRACTOR'S APPLICATION FOR PAYMENT
Exhibit F
Exhibit G
ACKNOWLEDGMENT OF RECEIPT AND RESPONSIBILITIES
This Acknowledgment is made and entered into on this29-day of January, 2025, by Justin Scott Godur ("Acknowledging Party"), representing GSJ
Capital LLC, in connection with the Resolution of Removal adopted by Pinnacle One Capital Group, LLC (the "Company") on December 17, 2024.
WHEREAS:
The Resolution of Removal sets forth obligations, responsibilities, and liabilities of GSJ Capital LLC and its representative, Justin Scott Godur, following
their removal as Member and Manager of the Company. It is essential to document the acknowledgment of receiptand acceptance of the outlined
responsibilities.
NOW, THEREFORE, the undersigned acknowledges, agrees, and covenants as follows:
1. Acknowledgment of Receipt
1.1 The Acknowledging Party confirms receipt of the Resolution of Removal dated December 17, 2024, and all accompanying documents.
1.2 The removal was determined to be for "Cause" as defined under Section 6.7(a) of the Operating Agreement, including but not limited to actions
outlined in the resolution.
2. Obligations and Responsibilities
2.1 Return of Funds
Return $1,000,000 to Pinnacle One Equity Fund II, LLC by December 31, 2024.
Provide proof of payment within five (5) business days of completion.
2.2 Resolution of Pending Issues
Address and resolve all dealings with --- and Pinnacle One Capital Group, LLC, and all affiliated entities, including any side dealings with ---.
Resolve all dealings with Carlyle Capital Fund, Inc., including indemnifying Pinnacle One Equity Fund I, LLC and its members from liabilities, damages,
or costs arising from the pending lawsuit (case number 30-2024-01433895-CU-BC-CJC).
Personally reimburse $36,625 to Pinnacle One Equity Fund I, LLC within 90 days if Carlyle Capital Fund, Inc. does not refund the specified amount.
2.3 Documentation
Initial: JG
~----.
Provide detailed documentation verifying the fulfillment of each obligation listed herein within five (5) business days of completion.
2.4 Withdrawal from Property Purchase
The Acknowledging Party is no longer pursuing the purchase of the property located at 1555 SE 7th St, Deerfield Beach, FL 33441, due to lack of
financial capability. This decision follows the default on the Purchase and Sale Agreement (PSA) signedpersonally on January 15, 2025, by Justin Godur

as Manager of Defgod, LLC, a Florida company, The PSA required escrow to be opened within three (3) days and a $100,000 Earnest Money Deposit
(EMO) to be deposited, neither of which was completed. The closing, originally scheduled tor February 14, 2025, has therefore not occurred.
Indemnify Pinnacle One Equity Fund I, LLC against any losses or damages related to this withdrawn transaction.
2.5 Refinancing Obligations for 1555 SE 7th St, Deerfield Beach, FL 33441
Refinance to occur within fifteen (15) days of the date of this agreement. Justin Scott Godur will be held fully liable for ensuringall interest payments until
the property is exited by Fund I, with related fees paid out-of-pocket and not rolled into the loan against the property.
Reimburse Pinnacle One Equity Fund I, LLC approximately $60,960.15 for all
mortgage payments made to date on the current loan within ten (1 O) days of the refinance.
Personally guarantee $600,000 of profit to Pinnacle One Equity Fund I investors from the eventual sale ofthe property. An addition al personal guarantee
from Morris Jaime Godur will support this obligation.
Failure to meet these obligations will result in legal actions to recover costs and enforce compliance, with all associated expenses borne personally by
Justin.
2.6 Personal Damage Payment
Personally pay $200,000 in damages to Pinnacle One Capital Group, LLC, to compensate for the extended timeline and unreliability attributed to the
Acknowledging Party's actions. This amount will be personally guaranteed by Morris Jaime Godur and is to be paid upon the completion of construction
and issuance of the certificate of occupancy. This payment is not contingent upon the sale of the Deerfield Beach property.
3. Indemnification
3.1 The Acknowledging Party agrees to indemnify and hold harmless Pinnacle One Capital Group, LLC, and its remaining members from any claims,
lawsuits, or costs arising from
Initial: .,.,JG...._______
actions or obligations originating during their tenure. This includes but is not limited to liabilities related to:
Carlyle Capital litigation.
Side dealings with ---.
Relationships or business dealings outside the remaining partners (JD2 Holdings,LLC; VoltCapital LLC; SM Investments LLC).
The indemnification shall include all reasonable attorney fees and defense costs incurred by Pinnacle One Capital Group, LLC in connection with such
claims.
4. Non-Disclosure Agreement (NDA)
4.1 Confidentiality
The Acknowledging Party agrees not to disclose or use any confidential or proprietary information belonging to Pinnacle One Capital Group, LLC, its
Funds, members, clients, or business associates, without prior written consent from the Company. Confidential information includes, but is not limited to,
business strategies, client data, financial details, and operational processes.
4.2 Non-Engagement with Clients and Partners
The Acknowledging Party agrees to notify Pinnacle One Capital Group, LLC in writing before engaging in any business relationship with current or
former clients, partners, or business associates of the Company following the date of this agreement.
Pinnacle One Capital Group, LLC reserves the right to withhold consent for such engagements if it determines that the pro posed relationship may
jeopardize the Company's business, reputation, Cir client relationships.
4.3 Mutual Non-Disparagement
Both the Acknowledging Party and Pinnacle One Capital Group, LLC agree notto make any negative, defamatory, or disparaging statements-publicly or
privately-about each other.
Any breach of this mutual agreement will result in liabilityfor damages, including reputational harm and associated legal fees.
5. Penalties for Breach of Agreement
5.1 The Acknowledging Party agrees to bear full Liability for any breach of this agreement,with the following penalties:
Initial: J..'IG....______
Any late payment shall incur an additional fee of $200 per day untilthe payment is made in full.
Reimbursement oflegal, administrative, and enforcement costs incurred by Pinnacle One Capital Group, LLC to address breaches.
5.2 Acknowledgment of Negligence:
Any breach of this agreement by the Acknowledging Party constitutes a willful act of negligence, and they accept full personal liability for any resulting
harm or losses suffered by Pinnacle One Capital Group, LLC or its members.
5.3 Legal Action and Regulatory Reporting:
The Acknowledging Party acknowledges and accepts that any failure to comply with the terms of this agreement may result in lawsuits initiated by
Pinnacle One Capital Group, LLC or its members to recover damages, enforce compliance, or address negligence.
5.4 Liquidated Damages:
The parties agree that quantifying losses arising from a breach of th is agreement is inherently difficult. Therefore, if the Acknowledging Party breaches
any provision of this agreement, they shall pay Pinnacle One Capital Group, LLC $100,000 as liquidated damages for each breach, in addition to any
other remedies provided herein. The parties intend this amount to be compensation for the breach, not a penalty.
6. Compliance with Local Laws
This Acknowledgment shall be governed by and construed in accordance with the laws of the State of Florida.
7. Severability Clause
If any provision of this agreement is found to be invalid, unenforceable, or unenforceable, the remaining provisions shall remain in full force and effect.
8. Amendments
9. Confidentiality of Agreement
This agreement may only be amended by a written agreement signed by both parties. Unauthorized amendments are nulland void.
Initial: .i.1G=-------4
The Acknowledging Pany agrees that all information in this agreement remains confidential and shall not be disclosed to any third party without prior
written consent from Pinnacle One Capital Group, LLC.
10. Acknowledgment of No Further Claims and Compensation

The Acknowledging Party agrees that they forfeit any future claims, disputes, demands for compensation, or restitution against Pinnacle One Capital
Group, LLC, related to their removal, prior dealings, or any other matter.
11. Continuing Obligations
The obligations, indemnities, and guarantees set forth in this agreement shall survive the termination of any business relationship between the parties and
continue in full force and effect until all obligations are fully satisfied and all potential liabilities have expired under applicable statutes of limitations.
12. Continuity of Obligations
12.1 Estate Responsibility:
In the unfortunate event ofJustin Scott Godur's passing, the obligations and responsibilities outlined in this agreement will be transferred to his estate to
ensure the continued fulfillment of the agreed-upon terms.
12.2 Business Partner Cooperation:
Business partners of Justin Scott Godur in ventures that benefited from Pinnacle One Capital Group, LLC's Funds are expected to cooperate in fulfilling
the obligations set forth in this agreement.
12.3 Notification:
The executor of Justin Scott Godur's estate is kindly requested to inform Pinnacle One Capital Group, LLC within a reasonable timeframe following any
such event.
12.4 Identification of Related Parties:
To maintain transparency, Justin Scott Godur's estate is asked to provide Pinnacle One Capital Group, LLC with information on business partners and
ventures that received benefits from Pinnacle One Capital Group, LLC's Funds.
12.5 Continuation of Protections:
Initial: J..G..,_____
The protections outlined in Section 3 of this agreement will continue to apply to Justin Scott Godur's estate and associated business partners.
12.6 Agreement Enforcement:
Pinnacle One Capital Group, LLC retains the option to take necessary steps to ensure the terms of this agreement are upheld and any outstanding
obligations are fulfilled.
Acknowledgment
Signature ofAcknowledging Party Personally, bearing full personal responsibility:
Juduv~QfM/;
Justin Scott Godur PRODUCED A FL DL
Signature of Acknowledging Party Representing GSJ Capital LLC:
( Justin Godur, Representative GSJ Capital LLC
Printed Name: Sandra E. Davis
Notary Public State of FLORIDA County of DUVAL The foregoing instrument was acknowledged before me this 29THday ofJanuary, 2025, by Justin
Scott Godur, who is personally known to me or who has produced ______as identification.
Notary Signature: 0/,,evQlvte eaalw Seal: Shevonne Cooke
Initial: JG
------This notarial act was an online notarization
Exhibit H
RESOLUTION AUTHORIZING JUSTIN SCOTT GODUR TO HANDLE MATTERS RELATED TO CARLYLE CAPITAL FUND, INC. LAWSUIT
WHEREAS, Carlyle Capital Fund, Inc. ("CARLYLE") has filed a lawsuit against Pinnacle One Equity Fund I LLC ("PINNACLE") and other
defendants (case number 30-2024-01433895-CU.BC-CJC); and
WHEREAS, Justin Scott Godur, despite his removal from Pinnacle One Capital Group, LLC,
remains responsible for resolving all matters related to this lawsuit as per the Acknowledgment
ofReceipt and Responsibilities dated January 29, 2025;
NOW, THEREFORE, BE IT RESOLVED, that Justin Scott Godur is hereby authorized and
directed to:
l. Handle all aspects ofthe lawsuit filed by Carlyle Capital Fund, Inc. against Pinnacle One Equity Fund I LLC and other defendants ( case number 30-
2024-01433 895-CU-BC.CJC).
2. Collaborate with legal counsel representing Pinnacle in this matter.
3. Make decisions regarding case strategy and settlement negotiations with the primary goal ofresolving the dispute and protecting Pinnacle's interests.
However, any final decision, including but not limited to settlement agreements, liability assumptions, or other material actions, must be submitted in
writing and approved by a majority vote ofthe managers of Pinnacle One Capital Group, LLC prior to execution.
4. Provide weekly written updates to Pinnacle One Capital Group, LLC regarding the progress of the case, legal strategy, and any significant
developments.
5. Indemnify Pinnacle One Equity Fund l LLC and its members from any liabilities, damages, or costs arising from this lawsuit, as outlined in the
Acknowledgment of Receipt and Responsibilities.
6. Maintain confidentiality regarding all casewrclated information and communications, ensuring that no proprietary, financial, or internal business
matters of Pinnacle One Capital Group, LLC are disclosed beyond what is necessary for legal representation.
LIMITATION OF AUTHORITY
This authorization is strictly limited to handling the aforementioned lawsuit and does not extend to any other matters or responsibilities. It does not grant
Justin Scott Godur access to Pinnacle One Capital Group, LLC's financial accounts, contractual obligations, corporate governance, or any unrelated
business decisions.
TERMINATION & REVOCATION
This resolution shall remain in effect until the lawsuit is fully resolved or until revoked by Pinnacle One Capital Group, LLC. Revocation must be made
in writing and approved by a majority vote ofthe managers of Pinnacle One Capital Group, LLC. Justin Scott Godur may not assign or delegate his
authority under this resolution to any third party without prior written approval from Pinnacle One Capital Group, LLC.
IN WlTNESS WHEREOF, the undersigned, being the duly authorized representatives of Pinnacle One Capital Group, LLC, hereby certify that the
foregoing resolution was duly adopted on this 30th day ofJanuary, 2025.
Pinnacle One Capital Group, LLC
By: ~,Jesse DiLillo, Manager
Patrick Voltapetti, Manager
Shawn Thomas, Manager
Final Audit Report 2025-02-27
Created: 2025-02-27
By: Status; Transaction ID: Jesse Dillllo [email protected]) Signed CBJCHBCAABAAOYISMPElm_RIIRNq_aFwOZ2Ym3OJV3kz
RESOLUTION AUTHORIZING JUSTIN SCOTT GODUR TO HANDLE MATTERS RELATED TO CARLYLE CAPITAL' FUND
"RESOLUTION AUTHORIZING JUSTIN SCOTT GODUR TOH ANDLE MATTERS RELATED TO CARLYLE CAPITAL FUND" H istory
f:l
Document created by Jesse Dilillo [email protected]) 2025-02-27-8:22:50 PM GMT-IP address: 75.206.126.170
D.Document emailed to Shawn Thomas ([email protected]) for signature 2025-02-27 -8:22:54 PM GMT

C1 Document emailed to Patrick Voltapetti ([email protected]) for signature 2025-02-27 -8:22:54 PM GMT
[~ Document emailed to Jesse Dilillo ([email protected]) for signature 2025-02-27 -8:22:55 PM GMT
f'l Email viewed by Patrick Voltapetti ([email protected]) 2025-02-27 -8:23:04 PM GMT-IP address: 74.125.210.133
fl Email _viewed by Jesse Dilillo ([email protected]) 2025-02-27 -8:23:11 PM GMT-IP address: 74,125,210.133
&,;; Document e-signed by Patrick Vollapetti ([email protected]) Signature Date: 2025-02-27 -8:23:46 PM GMT -Time Source: server-IP
address: 75.206.126.170
&o; Document e-signed by Jesse Dilillo [email protected]) Signature Dale: 2025-02-27 -8:24:08 PM GMT -Time Source: server-IP address:
104.28.94.187
PJ Adobe Acrobat Sign
Exhibit I
.,.taonel Ouarentae
r, MorrisJaime Godur, hereby personally guarantee the following obligations of JustinScott Godur and GSJ Capital LLC es outlined In the
Acknowledgment of Receipt end Responsibilities dated January 2025:
1. Prop~rty er:ofl.t G.uarante.e: Ipersonally guarantee $600,000 of profit to Pinnacle One Equity Fund I, Llc Investors from the eventual sale of the
property located at , 555 SE 7th St, Deerfield Beach, FL 33441 .
2. ~onalDamap Paym1m1: I personally guarantee the payment ot $200,000 in damages to Pinnacle One Capital Group, LLC. This amount is to be paid
upon the completion ofconstruction and issuance of the certificate ofoccupancy for the aforementioned property. Iacknowledge that this payment is not
contingent upon the sale ofthe Deerfield Beach property.
3. lndemnjfjcatjon: I agree to indemnify and hold harmless Pinnacle One Capital Group, LLC, and its remaining members from any claims, Lawsuits, or
costs arising from actions or obligations originating during Justin Scott Godur's tenure, including but not limited to liabilities related to Carlyle Capital
litigation, side dealings with ---, ~nd relationships or business dealings outside the remaining partners.
4. Survivability Clause: Notwithstanding the passing of Morris Jaime Godur, the guarantor, this Personal Guarantee shall survive and remain in full
force and effect. All ob ligations under th is Personal Guarantee shaIt be considered a debt of the guarantor's estate and shall be given priority in
accordance with applicable laws. The executor or administrator of the guarantor's estate shall be responsible for ensuring the fulfillment of these
obligations to the extent permitted by law.
By signing below, I, Morris Jaime Godur, acknowledge that I have read, understood, and agree to be bound by the terms of this personal guarantee.
Signature: Date:
Witness Signature~ Printed Name: ,f;oAdti
Exhibit K
NEUMAN
Low,PA
JOO! W. Yamato Road, Suite 401, Boca Raton, Florida, 33431
Tel: 561.571.4500
Eric J. Neuman, Esq.
E-Mail: [email protected]
April 7, 2025
VIA E-MAIL ([email protected]) & CERTIFIED MAIL.RETURN RECEIPT REQUESTED
DEFGODLLC c/o Justin S. Godur, Authorized Member 1515 S. Federal Hwy, Suite 319 Boca Raton, FL 33432
Justin S. Godur
699 Kingsbridge Street
Boca Raton, FL 33487
Pinnacle One Equity Fund I LLC
c/o Pinnacle One Capital Management LLC, Manager
40 S.E. 5th Street, Suite 503
Boca Raton, FL 33432
Re: Our Clients: Butternut Investment Group, LLC Amount Due: $4,500,000.00
CIVIL THEFTNOTICE & DEMAND FOR TREBLE DAMAGES
Dear Mr. Godur:
Our law finn is litigation counsel to Butternut Investment Group, LLC ("Butternut") and its principals, Shoshana and Benjamin Gibli. Our clients have
consulted with us regarding Butternut's loan to DEFGOD LLC ("DEFGOD" or "Borrower") in the principal swn of $1,500,000.00 (the "Loan").
As you are well aware, on December 26, 2024, DEFGOD and Butternut entered into a Joint Venture Agreement ("NA") in connection with the acquisition
and development of real property located at 1555 SE 7th Street, Deerfield Beach, Florida (the "Property"). In addition, youcontemporaneously executed
a Pledge Agreement personally pledging your membership interest in Yes We Build, LLC ("Yes We Build") as security for the Loan.
j
April 7, 2025 Page 3
It has come to our clients' attention that you have materially breached the foregoing agreements,and have otherwise violated applicable Florida law,
resulting in damages to our clients in the amount of$4,500,000.00.
Notice of Default: Breaches of the JVA and Pledge Agreement
The NA explicitly warrants that DEFGOD, at the time of the JVA's execution, was under contract to purchase the Property and that the Property would
be titled in DEFGOD's name. In direct contravention of these representations, the Property was instead deeded to Pinnacle One Equity Fund I LLC, an
entirely separate entity. These actions undermine the central premise of the JVA and materially breach Article II ofthe same.
Additionally, DEFGOD agreed in Article IU of the JVA that, within forty-five (45) days of acquiring the Property, it would obtain a construction loan
from Archwest Capital and immediately transfer the full amount of the first draw, anticipated to be $1,500,00.00, to Butternut. As of the date ofthis letter,
no such repayment has been made, constituting a material breach of Article III and a "Default," pursuant to Section 2 of the Pledge Agreement.
Under the Pledge Agreement, you further warranted that your personally pledged interest in Yes We Build was unencumbered. Contrary to your
representations, and in breach ofyour obligations, you filed a UCC-1 financing statement on March I 0, 2025, in favor ofa completely unrelated third
party, --- lnvestments, LLC, granting it a lienover Yes We Build. Your fraudulent concealment and unauthorized encumbrance of pledged collateral is a
direct violation of your warranty in Section 5(a) and your covenant in Section S(h) ofthe Pledge Agreement not to assign or encumber tl1e pledged
interest.
Furthennore, Sections I and 3 of the Pledge Agreement required you to file a UCC-1 naming Butternut as secured party. No such filing has been made.
Your failure to provide "further assurances" to effectuate the agreement (see Section IO of same) constitutes yet another material breach ofthe Pledge
Agreement.
Criminal Violations
The pattern of misrepresentations, diversions of funds, failure to honor contractual obligations, and your misuse of an elderly couple's investment exceeds
mere civil wrongdoing, and squarely falls within the scope ofcriminal conduct under Florida Statutes, namely:
Section 825. l 03( I )(a), Florida Statutes: You exploited elderly persons with whom you had a business relationship by knowingly obtaining and misusing
the Loan, intending to permanently deprive them ofthe same.
Section 825.103(2), Florida Statutes: The Giblis, both over the age of65 and having known you for less than two years, made a transfer exceeding $10,000
for which they received no equivalent financial value. This creates a statutory presumption ofexploitation.
Section 812.014, et seq., Florida Statutes: Your intentional and unauthorized use of the Loan for purposes unrelated to the JVA constitutes civil theft.
Pursuant to. Section 772.1 1, Florida St.atutes, our clients are entitled to treble (triple) damages, attorneys' fees, and costs.

April 7, 2025
Page J
In light of the foregoing, and pursuant to Section 772. l I, Florida Statutes, demand is hereby made on behalf ofButternut that you pay treble damages for
the stolen monies in the amount of $425001000.00 within thirty (30) days of receipt ofthis demand.
While we are hopeful that you will remit the amount due to Butternut without resort to legal action, understand that ourclients are fully prepared to
initiate suit, ifnecessary, wherein we will seek not only a judgment against you and/or DEFGOD for all amounts due and owing, but also collection ofall
resulting costs and attorneys' fees incurred by Butternut.
In order to avoid this eventuality, you must remit the amount of $4,500,000.00 by May 7, 2025. Further payment instructions will be provided upon
receipt ofwritten confinnation ofyour intent to pay via e-mail or letter to the undersigned received on or before April 18, 2025.
lfthis is not done, our firm may proceed to commence legal action against you and/or DEFGOD, and any other responsible parties, without any further
notice and take such other steps as we deem necessary to fully protect and vindicate the interests ofour clients. The detennination as to whether such
action will be required rests entirely in your hands.
In addition to the demand made herein, our clients expressly reserve the right to seek foreclosure of your pledged membership interest in Yes We Build,
the imposition ofa constructive trust over the Property and any substitute assets, injunctive relief to prevent any further dissipation ofassets,
compensation for any and all other damages accrued, and any and aJJ attorneys' fees and costs arising out ofthe foregoing.
We trust that you will be guided accordingly by these advisements, which are set forth without
prejudice to the rights and interests of Butternut Investment Group, LLC, Shoshana Gibli, and
Benjamin Gibli.
Very truly yours,
NEUMANLAW,PA
s//~Uof ~
Eric J. Neuman For the Firm
Shoshana Gibli vs Justin Godur, AnnaDefrank, Morris Jaime Godur Civil Theft &
Fraud Lawsuit
Text from actual complaint is below. Formatting, typos, and other mispellings may be seen due to conversion software used.
Filing # 230348468 E-Filed 08/27/2025 01:28:25 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BUTTERNUT INVESTMENT GROUP, CASE NO: CACE-25-006054 (18)
LLC, a Florida limited liability company,
SHOSHANA GIBLI, an individual,
and BENJAMIN GIBLI, an individual,
Plaintiffs,
vs.
DEFGOD LLC, a Florida limited liability
company, JUSTIN GODUR, an
individual, ANNAMARIE DEFRANK.
an individual, MORRIS JAIME GODUR,
and YES WE BUILD LLC, a Florida
limited liability company,
Defendants.
AMENDED COMPLAINT & JURY DEMAND
Plaintiffs, SHOSHANA GIBLI, BENJAMIN GIBLI (together, the “Giblis”), and
BUTTERNUT INVESTMENT GROUP, LLC (“Butternut”) (collectively, “Plaintifis”) by and
through undersigned counsel, hereby sue Defendants, DEFGOD LLC (“DEFGOD”), JUSTIN
GODUR, ANNAMARIE DEFRANK (“DeFrank™), MORRIS JAIME GODUR (“Jaime Godur”), and YES

WE.
BUILD LLC ("YWB”), and in support thereof allege as follows:
PARTIES, JURISDICTION AND VENUE.
1. Butternut isa limited liability company, organized and existing pursuant to the laws
of the State of Florida, with its principal place of business in Palm Beach County, Florida,
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2. Shoshana Gibli is an individual residing in Florida, over the age of majority, and is
sui juris,
3. Benjamin Gibli is an individual residing in Florida, over the age of majority, and is
sui juris,
4, DEFGOD is a limited liability company, organized and existing pursuant to the
laws of the State of Florida, with its principal place of business in Palm Beach County, Florida.
5. Justin Godur is an individual residing in Florida, over the age of majority,
authorized member and manager of DEFGOD, and is sui juris.
6. DeFrank is an individual residing in Florida, authorized member of DEFGOD, over
the age of majority, and is sui juris,
7. Jaime Godur is an individual residing in Florida, over the age of majority, and is
sui juris.
8. YWB isa Florida limited liability company, organized and existing pursuant to the
laws of the State of Florida, with its principal place of business in Palm Beach County, Florida.
9. is an individual, residing in , over the age of majority, and is swi
juris.
10, is a limited liability company, organized and existing pursuant to the
laws of the State of , with its principal place of business in County, ,
11, The Court has personal jurisdiction over all named Defendants in this action
because the Defendants:
a. conducted, engaged in, or carried on a business or business venture in Broward
County, Florida; and/or
b. committed tortious acts within Florida; and/or
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c. breached a contract in Florida by failing to perform acts required by the subject
contracts to be performed in Florida.
12, The Court has subject matter jurisdiction over this action pursuant to Section
26.012(2)(c), Florida Statutes.
13. Pursuant to Chapter 47, Florida Statutes, venue is proper in Broward County,
Florida because the real property, which is the subject of this action, is situated in Broward County,
Florida.

FACTUAL ALLEGATIONS
A. Agreements and Obligations
14, On or about December 26, 2024, DEFGOD and Butternut, an entity owned and
managed by the Giblis, entered into a Joint Venture Agreement (“JVA”) concerning the
acquisition, renovation, and resale of real property (the “Deerfield Project”) located at 1555 SE
7th Street, Deerfield Beach, Florida (the “Property”). A true and correct copy of the JVA is
attached hereto as Exhibit “A”.
15. A legal description of the Property is as follows:
Lot 5, Block 36, The Cove 2" Section, according to the map or plat thereof, as
recorded in Plat Book 33, Page 27, of the Public Records of Broward County,
Florida.
16, Before execution of the VA, Jaime Godur—Justin Godur’s father—personally
communicated assurances regarding the legitimacy and profitability of the Deerfield Project to
Plaintiffs in order to induce their investment.
17. Pursuant to the JVA, Butternut provided DEFGOD with $1,500,000.00 (the
“Capital Contribution”) as an investment to be used by DEFGOD exclusively to fund the
acquisition, renovation, and resale of the Property. Sve Ex. A, pp. 4, 10.
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18. Pursuant to the JVA, Butternut is allocated a seventy-five percent (75%)
distributive interest in the net profits derived from JVA business and holds decisive veto power
over critical operational and financial decisions, including sales, encumbrances, and contractual
agreements related to the Property. See Ex. A, pp. 5-6.
19, In Article Il of the JVA, DEFGOD explicitly warrants that, at the time of the JVA’s
execution, it was under contract to purchase the Property, and that, once purchased, the Property
would be titled in DEFGOD"s name. See Ex. A, p. 4.
20. Additionally, DEFGOD agreed in Article II] of the JVA that, within forty-five days
of acquiring the Property, it would obtain a construction loan from Archwest Capital and
immediately transfer the full amount of the first draw, anticipated to be $1,500,000.00, to
Butternut,
21. Justin Godur, contemporancously with execution of the JVA, executed a separate
Pledge Agreement, personally pledging his membership interest in YWB as security for the Capital
Contribution. In the Pledge Agreement, Justin Godur warranted that his personally pledged interest
in YWB was otherwise unencumbered. A true and correct copy of the Pledge Agreement is
attached hereto as Exhibit “B.”
22. YWB isa Florida limited liability company that was formed by Justin Godur, with
him and DeFrank as its only members.
23. The Pledge Agreement required Justin Godur to, inter alia, file a UCC-I Financing
Statement naming Butternut as a secured party, refrain from any further encumbrance of YWB or
pledging of its assets without Butternut’s consent, and execute any additional documents necessary

to effectuate the secured transaction.
B. Breaches and Misrepresentations
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24. Sections 1 and 3 of the Pledge Agreement required Justin Godur to file a UCC-1
naming Butternut as secured party in the public records of Broward County, Florida. See Ex. B.
No such filing has been made.
25, Contrary to Justin Godur’s misrepresentation that his interest in YWB was
unencumbered in Section 5(a) and in violation of his covenant in Section 5(h) of the Pledge
Agreement not to assign or encumber the pledged interest, a UCC-1 Financing Statement (the
“UCC-1") was filed on March 10, 2025, in favor of third parties, and , granting them
security interests in YWB. A true and correct copy of the UCC-1 Financing Statement is attached
hereto as Exhibit “C.”
26. The UCC-1 lists YWB among the debtors, along with a myriad of affiliated entities,
and purports to encumber “all assets” of the listed debtors. The UCC-I references indebtedness of
$455,000.00 (of which $195,000.00 is stated as paid) and expressly includes an additional
$50,000.00 “Loan Sponsorship for Deerfield Project Loan,” tying the encumbrance to the Property
and transaction at issue.
27. The UCC-1 was recorded after Plaintiffs’ investment (December 26, 2024) and
after Defendants diverted title to the Property away from DEFGOD (September 13, 2024)
Furthermore, the UCC-1 purports to cover YWB. the very collateral that Justin Godur had pledged
to Plaintiffs as unencumbered and to be perfected in Plaintiffs’ favor.
28. The UCC-1 identifies numerous interrelated, insider-controlled entities as debtors,
including: Capital Max Group, LLC; Q7 Capital Group LLC: Equicaps LLC; GSJ Capital LLC:
DEFGOD LLC; DEFGOD Development LLC; Govo LLC; Yes We Build Group LLC; Yes We
Build LLC; Yes We Buy LLC; Yes We Close LLC: Yes We Design LLC; Pinnacle One Capital
Group LLC; Pinnacle One Management II LLC; Pinnacle One Management Income Fund I LLC:
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Pinnacle One Equity Fund I LLC; and Pinnacle One Equity Fund Il LLC. This demonstrates a
concerted effort to sweep assets and proceeds across the Godur-controlled enterprise in a manner
that would hinder, delay, or defraud Plaintiffs’ recovery
29. Moreover, by explicitly referencing the “Deerfield Project Loan,” the UCC-1
confirms that / acted with knowledge of the very project governed by the JVA and
of Plaintiffs” contractual and security rights, and / nevertheless sought to cloud
PlaintiffS’ collateral with an all-assets claim on YWB and other affiliated debtors,
30. Upon information and belief, , DeFrank, and Justin Godur are business
partners who jointly operate and/or exercise control over a convoluted web of numerous affiliated
entities that were created and are operated for the sole purpose of executing and concealing their
schemes, including shielding and transferring asscts from Plaintiffs and others.
31. Upon information and belief, and coordinated with Justin Godur and
DeFrank to place competing liens and encumbrances on YWB and related entities and to re-route
assets, while having knowledge of Butternut’s superior contractual and security interests, thereby
hindering Butternut’s ability to recover its Capital Contribution.

32 The timing (March 10, 2025), breadth (“all assets”), insider nature of the
counterparties, and explicit reference to the Deerfield Project, taken together, are consistent with
an intent to hinder, delay, or defraud Plaintiffs as creditors and to aid and abet the wrongful
retention and diversion of Plaintiffs’ Capital Contribution.
33. At all times material, DeFrank was an authorized member of DEFGOD. Upon
information and belief, DeFrank participated in, approved, or ratified the diversion of title, the
failure to perfect Plaintiffs’ pledge on YWB, and the imposition of competing insider
encumbrances (including the UCC-1), all to the detriment of Plaintiffs’ bargained-for rights.
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34. Upon information and belief, DeFrank and Justin Godur misappropriated the
Capital Contribution to purchase separate investment properties, a new truck, luxury goods, and
to finance a lavish lifestyle, including extravagant travel on private jets, high-end accommodations,
and fine dining,
35. Additionally, in direct contravention of DEFGOD's misrepresentations that the
Property was under contract to be sold to DEFGOD and would be titled in its name, the Property
was instead titled earlier to Pinnacle One Equity Fund 1 LLC (“Pinnacle One Equity”), an entirely
separate entity. A true and correct copy of the Warranty Deed is attached hereto as Exhibit “D.”
36. Upon information and belief, Justin Godur is or was directly affiliated with Pinnacle
One Equity. According to its Articles of Organization, filed on June 3, 2024, Pinnacle One Equity’s
original registered agent was Justin Godur, A tre and correct copy of Pinnacle One Equi
original Articles of Organization is attached hereto as Exhibit “E.”
37. Moreover, Pinnacle One Equity’s original Articles of Organization list an entity
called Pinnacle One Capital Management, LLC (“Pinnacle One Management”) as its authorized
manager. See Ex. D. Pinnacle One Management's original Articles of Organization lists Justin
Godur as its registered agent, A true and correct copy of Pinnacle One Management's original
Articles of Organization is attached hereto as Exhibit “F.”
38. On March 31, 2025, Pinnacle One Equity changed its registered agent to an entity
called Pinnacle One Capital Group, LLC (“Pinnacle One Group”). A true and correct copy of
Pinnacle One Equity’s Sunbiz page is attached hereto as Exhibit “G.”
39, Furthermore, despite DEFGOD’s obligation to obtain a construction loan within
forty-five days of acquiring the property and transfer the full amount of the first draw, which was
anticipated to be $1,500,000.00, to Butternut, no such payment has been made.
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40. Upon information and belief, Jaime and Justin Godur engaged in protracted
settlement proposals, draft agreements, and bogus “attempts” to repay Plaintiffs merely to
obfuscate, delay repayment, and prevent enforcement of Justin Godur and DEFGOD’s obligations
pursuant to the JVA and Pledge Agreement
41. Plaintiffs have retained the law firm of Neuman Law, PA to represent them in this
action and are obligated to pay a reasonable fee thereto.
42, All conditions precedent to bringing this action have been performed, waived, or

otherwise excused,
BREACH OF FIDUCIARY DUTY
(Butternut vy. DEFGOD)
43, Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
44, This is an action for breach of fiduciary duty against DEFGOD.
45. At all times pertinent to this action, DEFGOD was a partner to Butternut, pursuant
to the JVA, See Ex. A.
46. Asa result, DEFGOD owed Butternut the duties of loyalty, good faith, and care.
47. DEFGOD breached its duties by misrepresenting to Butternut that it was under
contract to purchase the Property.
48. DEFGOD breached its duties by failing to title the Property in DEFGOD's name,
despite its express obligation to do so.
49. Generally, DEFGOD breached its fiduciary duties by misappropriating funds that
were invested by Butternut to be expended in achieving the purposes of the JVA, instead using the
Capital Contribution for personal benefit.
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30. As a direct and proximate cause of the foregoing, Butternut has suffered damages
exceeding $1,300,000.00.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for breach of fiduciary duties against Defendant, DEFGOD LLC; awarding
monetary damages of at least $1,500,000.00; awarding costs, interest, and attomeys’ fees pursuant
to contractual agreements; and awarding all such other and further relief as is just and proper.
COUNT
BREACH OF CONTRACT
(Butternut v. DEFGOD)
51. Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 44
and incorporate same by reference as if fully set forth herein.
$2. This is an action for breach of contract against DEFGOD,
53. Butternut and DEFGOD entered into a valid and enforceable contract, the JVA, on
December 26, 2024, See Ex. A.
54. Pursuant to the JVA, DEFGOD represented that, at the time of the JVA’s execution,
it was under contract to purchase the Property and that the Property would be titled in DEFGOD’s
name. See Ex. A, p. 4.
55. In direct contravention of these representations and obligations, the Property was
instead deeded to Pinnacle One Equity See Ex. D.
56. Additionally, DEFGOD agreed in Article III of the JVA that, within forty-five (45)
days of acquiring the Property, it would obtain a construction loan from Archwest Capital and

immediately transfer the full amount of the first draw, anticipated to be $1,.500,000,00, to
Butternut. See Ex. A, p. 4.
57. As of the date of this Amended Complaint, no such repayment has been made.
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UMAN LAW, PA
58. DEFGOD’s failure to acquire and title the Property in DEFGOD’s name and its
failure to acquire and distribute the construction loan are material breaches of its express
obligations under the JVA.
59. As a direct and proximate cause of DEFGOD’s material breaches of the JVA,
Butternut has suffered significant damages.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for breach of contract against Defendant, DEFGOD LLC; awarding monetary
damages of at least $1,500,000.00; awarding costs, interest, and attorneys’ fees pursuant to
contractual agreements; and awarding all such other and further relief as is just and proper.
COUNT IIL
BREACH OF CONTRACT
(Butternut v. Justin Godur)
60. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
61. This is an action for breach of contract against Justin Godur.
62. On December 26, 2024. Butternut and Justin Godur entered into a valid and
enforceable contract, the Pledge Agreement, in which Justin Godur personally pledged his interest
in YWB, See Ex, B.
63. Under the Pledge Agreement, Justin Godur warranted that his interest in YWB was
otherwise unencumbered. See Ex. B, pp. 4-8.
64. The Pledge Agreement required Justin Godur to. inter alia, file a UCC-1 Financing
Statement naming Butternut as a secured party, refrain from any further encumbrance of YWB or
pledging of its assets without Butternut’s consent, and execute any additional documents necessary
to perfect the secured transaction. See Ex. B, pp. 1. 4-9.
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65, Furthermore, Sections | and 3 of the Pledge Agreement required Justin Godur to
file a UCC-1 naming Butternut as secured party. See Ex. B, pp, 1-3.
66. In direct violation of Justin Godur’s warranty that his interest in YWB was
unencumbered in Section 5(a) and his obligation in Section 5(h) of the Pledge Agreement not to
assign or encumber the pledged interest, a UCC-1 Financing Statement was filed on March 10,
2025, in favor of third parties, and , granting them an interest in
YWB. See Ex. C.
67. Moreover, in contravention of his obligation, Justin Godur failed to file a UCC-1
Financing Statement naming Butternut as a secured party.
68. Justin Godur’s failure to file the UCC-1 naming Butternut as a secured party and
instead filing a UCC-1 in favor of unrelated parties are material breaches of his express obligations
under the Pledge Agreement.

69. As a direct and proximate of Justin Godur’s material breaches of the Pledge
Agreement, Butternut has suffered significant damages.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for breach of contract
gainst Defendant, JUSTIN GODUR; awarding monetary
damages of at least $1,500,000.00; awarding costs, interest, and attorneys’ fees pursuant to
contractual agreements; and awarding all such other and further relief as is just and proper.
COUNT IV
CONV! SION
(Butternut v. DEFGOD, Justin Godur, and DeFrank)
70. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
71. This is an action for conversion against DEFGOD, DeFrank, and Justin Godur.
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72, At all times material, Justin Godur and DeFrank were the only members of
DEFGOD.
73. On or about December 26, 2024, Butternut and DEFGOD entered into the JVA.
See Ex. A.
74, Pursuant to the JVA, Butternut provided DEFGOD with the Capital Contribution
for the purchase and improvement of the Property.
75. Thereafter, DEFGOD failed and/or refused to fulfill its obligations under the
agreement, namely, to acquire the Property and title it in DEFGOD’s name.
76. Furthermore, DEFGOD failed and/or refused to fulfill its obligations under the
agreement by securing a construction loan and providing Butternut with the first construction draw
in repayment to Butternut for its capital contribution.
77. Butternut retains the right to ownership and possession of the funds it paid to
DEFGOD.
78. Butternut previously demanded that DEFGOD return its funds, which rightly
belong to it. See Ex. H.
79. Nevertheless, DEFGOD has failed and/or refused to return the funds.
80. Upon information and belief, Justin Godur and DeFrank have misappropriated the
Capital Contribution for their own personal use.
81. DEFGOD, Justin Godur, and DeFrank have wrongfully exercised dominion and
control, and have permanently deprived Butternut, of Butternut’s money.
82. As a direct and proximate cause of DEFGOD's, Justin Godur’s, and DeFrank’s
actions, inconsistent with Butternut’s ownership interest in the Capital Contribution funds,
Butternut has suffered significant damages.
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WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for conversion against Defendants, DEFGOD LLC, JUSTIN GODUR, and
ANNAMARIE DEFRANK; awarding monetary damages of at least $1,500,000.00; awarding
costs, interest, and attorneys’ fees pursuant to contractual agreements; and awarding all such other
and further relief as is just and proper.
COUNT V
UDULE: ISREPRES| “ATION
(Butternut vy, DEFGOD, Justin Godur, and Jaime Godur)
83. Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 44
and incorporate same by reference as if fully set forth herein.
84. This is an action for fraudulent misrepresentation against DEFGOD, Justin Godur,
and Jaime Godur.
85. The JVA explicitly warrants that DEFGOD, at the time of the JVA’s execution,
was under contract to purchase the Property and that the Property would be titled in DEFGOD's
name, See Ex. A, pp. 3-4.
86. In direct contravention of these representations, the Property was instead titled to
Pinnacle One Equity, an entirely separate entity. See Ex. D.
87. DEFGOD misrepresented that it was under contract to purchase the Property at the
time of the JVA’s execution, which is a material fact. See Ex. A, p. 4.
88. DEFGOD misrepresented that it would title the Property under DEFGOD’s name,
for the purposes of the JVA, which is a material fact. See Ex. A, p. 3.
89. | DEFGOD knew these representations were false when it made them.
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90. Justin Godur misrepresented that his pledged membership in YWB was
unencumbered, would be perfected in Butternut’s favor, and would not be subject to any other
encumbrance, which are material facts. See Ex. B. “4 1, 3. 5.
91. Justin Godur knew these misrepresentations were false when he made them.
92. Jaime Godur personally communicated assurances regarding the legitimacy and
profitability of the Deerfield Project, which are material facts.
93. Jaime Godur knew these misrepresentations were false when he made them.
94. | DEFGOD, Justin Godur, and Jaime Godur intended for Butternut to rely on their
representations in inducement for Butternut to provide the Capital Contribution to DEFGOD.
95. Butternut justifiably relied on DEFGOD's, Justin Godur’s, and Jaime Godur's
misrepresentations.
96. As a direct and proximate cause of DEFGOD's, Justin Godur’s, and Jaime Godur’s
fraudulent misrepresentations, Butternut has suffered significant damages.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for fraudulent misrepresentation against Defendants, DEFGOD LLC, JUSTIN
GODUR, and MORRIS JAIME GODUR; awarding monetary damages of at least $1,500.000.00;
awarding costs, interest, and attorneys’ fees pursuant to contractual agreements; and awarding all
such other and further relief as is just and proper.

COUNT VI
GLIGENT MISREPRESENTATION
(Against DEFGOD, Justin Godur, and Jaime Godur)
97. Plaintiff’ repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
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98. This is an action for negligent misrepresentation against DEFGOD, Justin Godur,
and Jaime Godur, pleaded in the alternative to Count V.
99. The JVA explicitly warrants that DEFGOD, at the time of the JVA’s execution,
was under contract to purchase the Property and that the Property would be titled in DEFGOD’s
name. See Ex. A, pp. 3-4.
100. In direct contravention of these representations. the Property was instead titled to
Pinnacle One Equity, an entirely separate entity, See Ex. D.
101. DEFGOD misrepresented that it was under contract to purchase the Property at the
time of the JVA’s execution, which is a material fact. See Ex. A., p. 4.
102. DEFGOD misrepresented that it would title the Property under DEFGOD’s name,
for the purposes of the IVA, which is a material fact. See Ex. A., p. 3.
103. DEFGOD was negligent in making th
representations because it knew or should
haye reasonably known that these representations were false when it made them,
104, Justin Godur misrepresented that his pledged membership in YWB_ was
unencumbered, would be perfected in Butternut’s favor. and would not be subject to any other
encumbrance, which are material facts. See Ex. B, §¥ 1, 3,5.
105. Justin Godur was negligent in making these representations because he knew or
should have reasonably known that these representations were false when he made them.
106. Jaime Godur personally communicated assurances regarding the legitimacy and
profitability of the Deerfield Project, which are material facts.
107. Jaime Godur was negligent in making these representations because he knew or
should have reasonably known that these representations were false when he made them.
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108. DEFGOD, Justin Godur, and Jaime Godur intended for Butternut to rely on these
representations in inducement for Butternut to provide DEFGOD with the Capital Contribution.
109. Butternut justifiably relied on the misrepresentations,
110, Asa direct and proximate cause of DEFGOD’s, Justin Godur's, and Jaime Godur's
negligent misrepresentations, Butternut has suffered significant damages.

WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for negligent misrepresentation against Defendants, DEFGOD LLC, JUSTIN
GODUR, and MORRIS JAIME GODUR awarding monetary damages of at least $1,500,000.00;
awarding costs, interest, attorney's fees pursuant to contractual agreements; and awarding all such
other and further relief as is just and proper.
COUNT VIE
EXPLOITATION OF AN ELDERLY PERSON
(Giblis v. DEFGOD, Justin Godur, Jaime Godur, and DeFrank)
111. Plaintiffs repeat and reallege the allegations contained in Paragraphs | through 44
and incorporate same by reference as if fully set forth herein.
112. This is an action for exploitation of an elderly person against DEFGOD, Justin
Godur, Jaime Godur, and DeFrank, pursuant to Chapter 825, Florida Statutes.
113. DEFGOD's, Justin Godur’s, Jaime Godur's. and DeFrank’s actions— including,
but not limited to, fraudulent misrepresentations, obfuscation, concealment of assets, and
misappropriation of the Capital Contribution—were intentional and constitute the exploitation of
an elderly person under Chapter 825, Florida Statutes.
114. Section 825.103(1)(a). Florida Statutes defines “exploitation of an elderly person”
as follows:
Knowingly obtaining or using, or endeavoring to obtain or use, an elderly person’s
or disabled adult’s funds, assets, or property with the intent to temporarily or
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permanently deprive the elderly person or disabled adult of the use, benefit, or
possession of the funds, assets, or property, or to benefit someone other than the
elderly person or disabled adult, by a person who:
Ll Stands in a position of trust and confidence with the elderly
person or disabled adult; or
2. Has a business relationship with the elderly person or
disabled adult
115. In violation of Section 825.103(1)(a), Florida Statutes, DEFGOD, Justin Godur,
Jaime Godur, and DeFrank, as an entity and persons in a business relationship with the elderly
Plaintiffs, knowingly obtained elderly persons’ funds with the intent to temporarily or permanently
deprive them of the use, benefit, and possession of the funds.
116. Section 825.103(2), Florida Statutes establishes a permissive presumption of
exploitation for inter vivos transfers of money or property exceeding $10,000.00 made by a person
aged sixty-five or older to a non-relative whom they have known for fewer than two years.
117, The Giblis are both over the age of sixty-five, transferred $1,500,000.00 to
DEFGOD, and have known Justin Godur, Jaime Godur, and DeFrank, who are non-relatives, for
less than two years.
118, As such, DEFGOD, Justin Godur, Jaime Godur, and DeFrank have violated Section
825.103, Florida Statutes, and the Giblis are entitled to damages thereunder.
WHEREFORE, Plaintiffs, SHOSHANA GIBLI and BENJAMIN GIBLI. respectfully
request judgment for exploitation of elderly persons against Defendants DEFGOD LLC, JUSTIN
GODUR. JAIME GODUR. and ANNAMARIE DEFRANK, awarding compensatory,

consequential, and special, damages pursuant to Sections 415.1111 and 825.103, Florida Statutes;
awarding costs, interest, attorneys’ fees pursuant to Sections 415.1111 and 825.103(1), Florida
Statutes; and awarding all such other and further relief as is just and proper.
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COUNT VIII
CIVIL THEFT
(Butternut v. DEFGOD and Justin Godur)
119, Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
120. This is an action for civil theft against DEFGOD and Justin Godur, pursuant to
Section 772.11, Florida Statutes and predicated upon violations of Section 812.014, Florida
Statutes.
121. On or about December 26, 2024, Butternut provided DEFGOD with the Capital
Contribution to be used solely for the acquisition, renovation, and resale of the Property, pursuant
to the parties’ IVA.
122. Justin Godur, through DEFGOD, knowingly obtained and used, or endeavored to
obtain and use, Butternut’s funds with the felonious intent to either temporarily or permanently
deprive Butternut of its right to the Capital Contribution or a benefit thereftom, and/or to
appropriate the Capital Contribution to their own use or to the use of others, in direct violation of
Section 812.014, Florida Statutes.
123, DEFGOD and Justin Godur’s felonious intent and unlawful taking and use of the
Capital Contribution are evidenced, inter alia, by the following non-exhaustive conduct: (a)
misrepresenting that DEFGOD was under contract to purchase the Property and that title would
be placed in DEFGOD’s name, while instead directing that title be placed in an entirely separate,
affiliated entity’s name; (b) failing to obtain and remit the first construction draw to Butternut, as
expressly required by the JVA; (c) diverting and/or using Butternut’s Capital Contribution for
purposes unrelated to the JVA and exclusively for the benefit of DEFGOD and Justin Godur and/or
third parties; and (d) refusing to return Butternut’s funds upon demand.
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124. On April 7, 2025 and pursuant to Section 772.11, Florida Statutes, Butternut served
written demand upon Defendants DEFGOD and Justin Godur for payment of three times the
amount misappropriated. A true and correct copy of the Demand Letter is attached hereto as
Exhibit “H”.
125. More than thirty days have passed since service of the demand.
126. Defendants have failed and otherwise refused to comply with the April 7, 2025 civil
theft demand letter.
127. Justin Godur’s and DEFGOD's actions constitute independent, intentional torts
separate and distinct from any mere breach of contract and, therefore, evince the requisite felonious
intent under Section 812.014, Florida Statutes.
128, As a direct and proximate cause of DEFGOD’s and Justin Godur’s civil theft,
Butternut has suffered damages of no less than $1,500,000.00.

129. Pursuant to Section 772.11, Florida Statutes, Butternut is entitled to recover treble
damages, as well as its reasonable attorneys’ fees and costs.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests that the Court enter judgment against Defendants, DEFGOD LLC and JUSTIN GODUR,
jointly and severally, awarding treble damages pursuant to Section 772.11, Florida Statutes; pre-
and post-judgment interest; reasonable attorneys’ fees and costs pursuant to Section 772.11; and
such other and further relief as the Court deems just and proper.
COUNT IX
CIVIL CONSPIRACY TO COMMIT FRAUD
(Against Justin Godur, Jaime Godur, DeFrank, , , and YWB)
130. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
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131. This is an action for civil conspiracy to commit fraud against Justin Godur, Jaime
Godur, DeFrank, , , and YWB (the “Conspiracy Defendants”)
132. ‘The Conspiracy Defendants agreed and acted in concert to obtain Plaintiffs’ funds
by misrepresentation and to subsequently hinder, delay, or prevent repayment and enforcement
through unlawful means, including, but not limited to: (a) false statements concerning titling,
repayment via construction draws, and an unencumbered pledge of YW: (6) diversion of the
Property’s title away from DEFGOD; and (c) the UCC-1 encumbrance sweeping “all assets” of
YWB and affiliates and expressly referencing the Deerfield Project.
133. One or more overt acts were committed in furtherance of the conspiracy, including,
but not limited to: (a) the execution of the JVA and Pledge Agreement to induce Plaintif's*
investment; (b) the deed diversion to Pinnacle One Equity and subsequent promise to purchase the
Property from Pinnacle One Equity by ; (c) delay and bad faith “settlement” tactics
employed by Jaime Godur; and (d) the UCC-| filing to ’ and ’s benefit.
134. The Conspiracy Defendants engaged in agreement and with a common plan.
Defendants Justin Godur, DeFrank, Jaime Godur, , , and YWB combined to induce
Plaintiffs" Capital Contribution by misrepresenting titling, repayment, and an unencumbered
pledge, and then to prevent or delay repayment through insider transfers and encumbrances tied to
the Deerfield project.
135. Acts in furtherance of the conspiracy include, but are not limited to: (a) placing title
to the Property with Pinnacle One Equity—which, upon information and belief, was lured into
purchasing the property by a separate scheme involving , DEFGOD, DeFrank, and the
Godurs—rather than DEFGOD; (b) recording of the UCC-1 naming as secured party and
as additional secured party, asserting an “all assets” claim over Y WB and other affiliates
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and expressly referencing the Deerfield Project; and (c) protracted “settlement” overtures that
mirrored tactics used in related matters and were intended to obfuscate and delay enforcement by
Plaintif's.
136. DeFrank, as an authorized member of DEFGOD, participated in or approved the
actions taken on its behalf.

137. Jaime Godur personally reinforced pre-investment assurances and later engaged in
bad faith “settlement” efforts only as a means to obfuscate and delay enforcement of DEFGOD’s
and Justin Godur’s contractual obligations.
138. / recorded the Deerfield Project-linked “all assets” UCC-1 filing
despite knowledge of Plaintiffs’ rights under the JVA and pledge.
139. Upon information and belief, and Justin Godur are business partners who
jointly operate and/or control multiple affiliated entities and work closely together, as reflected by
the UCC-I’s sweeping inclusion of Godur-affiliated debtors and its explicit reference to the
Deerfield Project.
140. Upon information and belief, the Conspiracy Defendants created, controlled, and
operated this constellation of shell entities for the purpose of executing and concealing their
scheme—diverting title, encumbering pledged collateral, and moving assets among insiders to
frustrate Plainti rights.
141. Plaintiffs were significantly damaged as a direct and proximate cause of the
Conspiracy Defendants’ overt acts.
WHEREFORE, Plaintiffs, BENJAMIN GIBLI, SHOSHANA GIBLI, and BUTTERNUT
INVESTMENT GROUP, LLC, respectfully request judgment for civil conspiracy to commit fraud
against Defendants, JUSTIN GODUR, JAIME GODUR, ANNAMARIE DEFRANK,
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, , and YES WE BUILD LLC, awarding
monetary damages of at least $1,500,000.00; awarding pre- and post-judgment interest; awarding
punitive damages; and awarding all such other and further relief as is just and proper.
COUNT x
AIDING AND ABETTING CONVERSION
(Butternut v. Jaime Godur, , , and YWB)
142. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein,
143. This is an action for aiding and abetting conversion against Jaime Godur, ,
, and YWB.
144. A conversion occurred when DEFGOD, Justin Godur, and DeFrank wrongfully
exercised dominion and control over Plaintiffs’ specifically identifiable Capital Contribution by
refusing to title the Property in DEFGOD’s name, failing to remit construction-draw repayment as
promised, and refusing to return the funds upon Plaintif's’ demand, instead misappropriating the
Capital Contribution for their own personal use.
145, / had actual knowledge of the Deerfield Project and Plaintiffs’ pledge
rights, as shown by the UCC-1 explicitly referencing a “Loan Sponsorship for Deerfield Project
Loan” while asserting an insider “all assets” claim over YWB and affiliates.
146. Jaime Godur personally communicated assurances to induce the Capital
Contribution and later engaged in bad faith settlement tactics designed to obfuscate and delay
enforcement of Plaintiffs’ rights. Jaime Godur had actual knowledge of DEFGOD’s, Justin

Godur’s and DeFrank’s plans to misappropriate the Capital Contribution for their personal use.
147. YWB had actual knowledge of Plaintiffs’ rights and of the conversion, including
knowledge that the JVA. required titling of the Property in DEFGOD’s name and prompt
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repayment of Plaintiffs’ Capital Contribution from construction draws, and that Justin Godur
pledged his YWB membership interest as unencumbered collateral to be perfected in Plaintifis’
favor. YWB knew these facts through its managers and controlling members—comprised of Justin
Godur and DeFrank—and from the UCC-1 expressly tied to the Deerfield Project.
148. The above-named Defendants substantially assisted and encouraged the conversion.
by, among other acts: (a) authorizing or facilitating the non-DEFGOD titling of the Property; (b)
procuring/recording the UCC-1 in favor of / asserting an “all assets” lien over YWB
and affiliated entities, expressly tied to the Deerfield Project, thereby impairing Plaintiffs’ pledged
collateral and frustrating return of the funds; and (c) engaging in a coordinated pattem of insider
encumbrances and delay that impeded Plaintiffs’ recovery.
149, Plaintiffs were significantly damaged as a direct and proximate cas of these
Defendants’ actions.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for aiding and abetting conversion against Defendants JAIME GODUR,
, , and YES WE BUILD LLC; awarding
monetary damages of at least $1,500,000.00; awarding punitive damages; awarding pre- and post-
ent interest; and awarding all such other and further relief as is just and proper.
COUNT XI
AIDING ABETTING BREACH OF FIDU Y DUTY
(Butternut v. DeFrank, , , and Jaime Godur)
150, Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein.
151. This is an action for aiding and abetting breach of fiduciary duty against DeFrank,
, , and Jaime Godur.
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152. As managing party and joint venturer with respect to the Deerfield Project,
DEFGOD owed Plaintiffs fiduciary duties of loyalty, good faith, and care, including to act in the
joint venture’s best interests, honor Plaintiffs’ veto/approval rights on major transactions,
safeguard the venture asset (the Property), and effectuate the JVs repayment mechanism.
153. DI
1D breached its fiduciary duties by, among other things: (a) diverting title
to Pinnacle One Equity rather than titling the Property in DEFGOD’s name: (b) failing to obtain
and remit construction draws to repay Plaintiffs; and (c) failing to perfect Plaintiffs" pledge in
YWB while permitting and causing competing insider encumbrances by and ,
154, With knowledge of DEFGOD’s duties and breaches, DeFrank, , , and
Jaime Godur substantially assisted or encouraged those breaches by approving, arranging, or

recording: (a) the non-DEFGOD titling of the Property; (b) the UCC-1 “all as encumbrance
over YWB and affiliated entities that directly conflicted with Plaintiffs’ bargained-for first-priority
pledge and impeded the JVA’s repayment mechanism; (c) misappropriating the Capital
Contribution for personal use; and (d) obfuscating, concealing assets, and intentionally delaying
Butternut from enforcing its contractual rights.
155. Plaintiffs were significantly damaged as a direct and proximate cause of these
Defendants" actions.
WHEREFORE, Plaintiff, BUTTERNUT INVESTMENT GROUP, LLC, respectfully
requests judgment for aiding and abetting breach of fiduciary duties against Defendants
ANNAMARIE DEFRANK, , , and
JAIME GODUR; awarding monetary damages of at least $1,500,000.00; awarding punitive
damages; awarding costs, interest, and attorneys’ fees: and awarding all such other and further
relief as is just and proper,
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COUNT XII
FRAUDULENT TRANSFER
(Butternut y. Justin Godur, DEFGOD, YWB, , and )
156. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 44
and incorporate same by reference as if fully set forth herein,
157. This is an action for fraudulent transfer, pursuant to Section 726.105, Florida
Statutes, against Justin Godur, DEFGOD, YWB, , and .
158. Butternut is a creditor of Defendants by virtue of the JVA and Butternut’s Capital
Contribution, which created contractual rights to prompt repayment from construction draws and
a pledged, first-priority security interest in Justin Godur’s membership interest in YWB.
159. Before and after Butternut became a creditor, Defendants made or caused transfers
and incurred obligations intended to hinder, delay, or defraud Butternut, including: (a) On
September 13, 2024, diverting title to the Property to Pinnacle One Equity rather than titling the
Property in DEFGOD’s name as represented and required by the JVA—upon information and
belief, these actions were part of a scheme involving Justin Godur, DEFGOD, and /,
in which, unbeknownst to Butternut, / promised to then purchase the Property from
Pinnacle One Equity; and (b) On March 10, 2025, recording the UCC-1 in favor of and
naming as an additional secured party, purporting to encumber “all assets” of YWB and a
myriad of interrelated, insider-controlled entities, and explicitly referencing an additional “Loan
Sponsorship for Deerfield Project Loan.”
160. The UCC-1 recites a principal balance of $455,000.00 (with $195,000.00 already
paid), evidencing that insiders received value derived from the encumbrance before Plaintiffs were
repaid or secured as promised, further impairing Plaintiffs” ability to realize on pledged collateral.
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161. Badges of fraud include, without limitation: transfers to insiders; concealment and
misdirection regarding true title; after-the-fact, insider encumbrances over pledged collateral; lack
of reasonably equivalent value to DEFGOD or Butternut; suspect timing after Plaintiffs became
creditors and were due funds for repayment of the Capital Contribution; and the broad inclusion

of multiple affiliated debtors to sweep assets and proceeds beyond Butternut’s reach.
162. Alternatively, the foregoing transfers/obligations were made without receiving
reasonably equivalent value at a time when the above-named Defendants were engaged in
transactions leaving unreasonably small assets or intended to incur, or believed they would incur,
debts beyond their ability to pay as they became due.
163. As a direct and proximate cause of the above-named Defendants’ actions, Butternut
has been significantly damaged.
WHEREFORE, Plaintiff BUTTERNUT INVESTMENT GROUP, LLC respectfully
requests judgment against Defendants JUSTIN GODUR, DEFGOD LLC, YES WE BUILD LLC,
, and , and awarding damages of at least
$1,500,000.00; attaching YWB’s assets and enjoining further disposition thereof: ordering
turnover of all relevant records and a full accounting of YWB?s assets and obligations: appointing
a receiver, as necessary; awarding costs, interest, and attorneys’ fees; and awarding all further
relief deemed just and proper.
JURY DEMAND
Plaintiffs, BUTTERNUT INVESTMENT GROUP, LLC, SHOSHANA GIBLI, and
BENJAMIN GIBLI, demand a trial by jury as to all issues so triable.
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Respecifully submitted,
MAN LAW, PA
Attorneys for Plaintiffs
1001 W. Yamato Road, Suite 401
Boca Raton, Florida 33431
Tel.: (S61) 571-4500
By:/s Fado FY Mouman
Eric J. Neuman, Esq.
Florida Bar No. 0028186
[email protected]
Levi A. Harris
Florida Bar No. 1049037
[email protected]
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EXHIBIT “A”JOINT VENTURE AGREEMENT
BETWEEN
Defgod, LLC, a Florida limited liability company
&

Butternut Investment Group, LLC, a Florida limited liability
company
Page 1 of 10
TABLE OF CONTENTS
ARTICLE I: NAME OF THE JOINT VENTURE
ARTICLE V. BOOKS, RECORDS, TAX RETURNS AND BANK ACCOUNTS
ARTICLE VI. MANAGEMENT OF THE JOINT VENTURE
ARTIC) VII:" COMPETING BUSINESS ACTIVITIES
ARTICLE VIII: DISSOLUTION AND LIQUIDATION
ARTICLE IX: RECORDING
ARTICLE X: NOTICES
ARTICLE XI: MISCELLANEOUS
Page 2 of 10
JOINT VENTURE AGREEMENT
This Joint Venture Agreement (“Agreement”) is hereby entered into as of this 26th December, 2024 (the
“Effective Date”) by and between DEFGOD, LLC, a Florida limited liability
company (“DEFGOD”) and BUTTERNUT INVESTMENT GROUP, LLC, a Florida limited
ability company (‘BUTTERNUT’), a Florida Limited Liability Corporation. Each party hereto
being individually referred to as a “Party” and collectively as the “Parties.”
RECITALS
WHEREAS, DEFGOD and BUTTERNUT desire to enter into a joint venture with each
other in connection with the purchase, rehab and sale of one or more real properties, pursuant to
and in accordance with such terms and conditions as hereinafter set forth in this Agreement (the
“Joint Venture”); and
WHEREAS, the Parties desire to make arrangements and to enter into an agreement, under
which all their respective rights and obligations growing out of their relationship as joint-venturers
shall be fully prescribed and bounded thereby
and
WHEREAS, this Agreement has come about through mutual negotiation of all the terms
and provisions of this Agreement between the Parties and therefore no presumption exists with
regard to any ambiguous term which may exist in this Agreement; and
WHEREAS, the Parties each warrant and represent to the other that they each fully
understand all of the terms, covenants, conditions, provisions and obligations incumbent upon each
of them by virtue of this Agreement to be performed or contemplated by each of them hereunder,
and each believe the same to be fair, just, equitable, reasonable and in his best interest;
NOW THEREFORE, in consideration of ten dollars ($10.00) and other valuable
consideration and mutual covenants and agreements contained herein, the parties agree as follows:
ARTICLE I: NAME OF THE JOINT VENTURE

The Parties consent and agree that all business of the Joint Venture shall be conducted under
(OD or such other entity as the Parties may from time to time utilize.
the name of DE
ARTICLE II: PURPOSES OF THE JOINT VENTURE
The purposes of the Joint Venture are . age and ope
the following property in the State of Florida: 15: . Deerfield Beach, FL 33441 (“Property”)
as well as to incur indebtedness, secured and unsecured; to mortgage, finance, refinance, encumber,
lease, sell, exchange, convey, transfer or otherwise deal with or dispose of Property in accordance
with the Agreement; to enter into and perform contracts and agreements of any kind necessary to,
in connection with or incidental to management of Property; and to carry on any other activities
necessary to, in connection with or incidental to the foregoing (collectively Joint Venture
The Parties specifically consent and agree that Property acquired by the Joint Venture
in the name of DEFGOM. At the time the Parties executed this Joint Venture Agreement,
Page 3 of 10
DEFGOD is under contract to purchase Property. The Patties further agree Property, despite being
titled in the name of DEFGOD, should be deemed to be owned, possessed and operated by both
DEFGOD and BUTTERNUT (or such other entity to be created by the Parties pursuant to Article
I above) and that a Court or arbitrator is fully authorized to, and shall, create and/or effect a
ne by BUTTERNUT (or such other
constructive trust upon the Properties upon the request for §
entity to be created by the Parties pursuant to Article T above).
‘As additional consideration for this Agreement, Justin Godur has transferred ten percent
(10.0%) of his interests in DEBGOD to BUTTERNUT. Upon successful completion of this
Agreement, BUTTERNUT shall immediately transfer its interests in DEFGOD to Justin Godur.
The interests in DEFGOD transferred herein are only intended to provide BUTTERNUT with
protection against the sale of Property without its consent and shall not entitle BUTTERNUT to
any additional assets, distributions profits and/or revenue of DEFGOD.
Other than the Capital Contribution (defined below) by BUTTERNUT, and notwithstanding:
anything set forth to the contrary herEin or any other agreement, BI NUT shall have no
financial obligations for the expenses of either DEFGOD or Property.
ARTICLE III, CAPITAL CONTRIBUTIONS AND LIENS
Concurrently with the execution of this Agreement, the Parties shall contribute for the
effectuation of the Joint Venture Purposes amounts set forth in “Schedule A” opposite each Party's
name (“Capital Contribution”).
The Parties anticipate DEFGOD shall obtain a construction loan in the amount of
$2,285,000.00 from Archwest Capital (“Lender”) for Property at the time of purchase of Property
Ic is further anticipated that Lender will distribute a lump sum construction draw for Property to
DEFGOD of at least $1,500,000,00 within forty-five (45) days of DEFGOD's acquisition of
Property (“Lump Draw”), subject to any delays outside of the control of DEFGOD.
In the event DEFGOD receives Lump Draw, the entirety of Lump Draw shall be
immediately transferred by DEFGOD to BUTTERNUT to repay BUTTERNUT’s Capital
Contribution.
In the event Lump Draw does not occur, then DEFGOD shall transfer the full amount of
any and all construction draws for Property received by DEFGOD from Lender to BUTTERNUT
until such time as BUTTERNUT has been repaid its Capital Contribution in full.

No Party (in either personal capacity or as a Party of an entity) shall be liable to the other
Party for the losses, debts, liabilities and obligations of the Joint Venture. Each Party hereto
acknowledges that he is an experienced investor and acknowledges the risks involved in entering into
this Agreement.
ARTICLE IV: ALLOCATIONS AND DISTRIBUTIONS
© Net Profits & Net Losses: As used in this Agreement, the terms "net profits" and
Page 4 0f 10
shall mean the profits or losses of the Joint Venture from the conduct of the Joint
Venture’s business, after all expenses incurred in connection therewith have been paid or provided
for, including, without limitation, all expenses incurred nithant limitation. sequisition costs, rehab costs,
marketing costs, project costs, insurance, legal fees, management costs/fees and other day-to-day
expenses, mortgage related costs and expense: he “Expenses”) and any allowance for
depreciation or amor rion of the cost of the Properties. However in no case shall DEFGOD
charge for their Member's individual time or labor as part of the Expenses. The net profits or net
losses of the Joint Venture shall be determined by the Joint Venture's accountants in accordance
with generally accepted accounting principles applied in determining the income, gains, expenses,
deductions or losses, as the case may be. DEFGOD shall not be required to obtain any prior
consent from BL ote incurring and/or paying the day-to-day expenses of the Joint
Venture. DEFGOD shall, however, be required to obtain prior consent from BUTTERNUT before
selling any property or entering into any contracts or mortgages. All net profits and net losses shall
be allocated in accordance with the Parties’ Distribution Percentage (hereinafter set forth)
© Parties’ Distributions Percentage: As used in this Agreement, the term "Parties’
Distribution Percentage” shall mean the percentages set forth opposite the name of each Party
below:
Party Distribution Percentage
° BUTTERNUT 75.00%
° DEFGOD 25.00%
After the Property is sold the proceeds from the closing shall be distributed according to the
Parties’ Distribution Percentage.
ARTICLE V. BOOKS, RECORDS, TAX RETURNS AND BANK ACCOUNTS
At all times during the continuance of the Joint Venture, DEFGOD shall keep or cause to
be kept accurate records of Joint Venture business in accordance with generally accepted accounting
principles, which may be viewed at any time by BUTTERNUT upon request
DEFGOD shall furnish to BUTTERNUT monthly updates regarding the expenses, net
income and net losses of the Joint Venture. The Parties shall also communicate bi-weekly to apprise
each other of the Joint Ventures business, Each Party shall be responsible for initiating such
communications.
Each Party shall prepare or cause to be prepared his own federal, state and local income tax
returns with the appropriate governmental authorities, All records, books of account, tax and
information returns, and reports and starements, together with executed copies of this Agreement in
connection with the business and dealings of the Joint Venture, shall be open to the inspection and
examination of the Parties or their duly authorized representatives during regular business hours.
ARTICLE VI MANAGEMENT OF THE JOINT VENTURE
Page 5 of 10

By way of this Agreement, DEFGOD is hereby designated as the Managing Party (the
“Managet”) of the Joint Venture. ‘The Manager shall have responsibility for the day-to-day
management of the business and affairs of the Joint Venture and shall devote such time and
attention as the Manager deems necessary to the conduct and management of the business and
affnirs of the Joint Venture.
Except as provided elsewhere in this Agreement, or by non-waivable provisions of
applicable law, the Manager shall possess and enjoy all rights and powers reasonably necessary ot
appropriate for the conduct and management of the business and affairs of the Joint Venture and
hereby is authorized to make all decisions relating to the business and affairs of the Joint Venture
provided such decisions are in the best interests of the Joint Venture. The Manager may make
decisions relating to: the approval, rejection, execution and modification of leases and subleases of,
and options, concessions, licenses and other agreements with respect to, the Property; the retention
and replacement of a managing agent to manage and operate the Property; the demolition of any
building owned or leased by the Joint Venture and the erection of a new building in irs place; the
alteration, improvement, maintenance and repair of any Property owned or leased by the Joint
Venture. However in no case shall the Manager conduct the following activities without the
permission of BUTTERNUT: the acguisition, sale, exchange, transfer, conveyance, assignment,
cacumbrance, mortgage of, or other disposition for cash, other property, or on terms, of all or any
part of, of interest in, the Property.
‘The Manager shall purchase insurance against loss or damage to the Property by fire or
other risks embraced by extended coverage and shall maintain such other hazard and liability
insurance against such risks and in such amounts as the Manager shall deem advisable, but at least
against such risks and in such amounts as customarily is maintained for similar properties in the
vicinity of the Property
‘The parties shall communicate at least bi-weekly to apprise each other on the business of this
Joint Venture, Both parties shall be responsible to each other to initiate such communications.
DEFGOD agrees to hold BUTTERNUT harmless and shall indemnify BUTTERNUT for
any litigation that arises from the ownership/development of the Property and this Joint Venture in
general.
Article VII COMPETING BUSINESS ACTIVITIES
Each Party to this Agreement may eagage in, invest in, participate in, or otherwise enter into,
any other businesses or professions of every nature and description, now or hereafter existing,
individually or with others, including the ownership, operation and management of real estate,
whether or not such businesses or professions compete directly with the Property or the Joint
Venture.
ARTICLE VIII. DISSOLUTION AND LIQUIDATION:
Page 6 of 10
The Joint Venture shall automatically terminate upon the mutually agreed upon sale of the
Property.
Upon the liquidation of the Joint Venture’s assets, the Managing Member shall distribute the
joint Venture’s liquidated assets in the following order:
a ig
© Repayment of all outstanding debts and liabilities owned by the Joint Venture in
connection with the Properties (other than to the Parties to this Agreement); then.
© Repayment of all costs and expenses paid towards the purchase and improvement of the
Property; then

© Repayment of each Party's portion of the Capital Contribution (if not paid repaid prior
pursuant to the terms herein); then
© Balance of the Joint Venture’s liquidated assets shall be disbursed to the Parties in
accordance with the Parties’ Distribution Percentage.
Estimated profit distribution to BUTTERNUT is
719,000.00 based upon a sale price for
Property of $7,650,000.00 minus the costs of purchase, construction, loan interest and closing fees.
ARTICLE IX: RECORDING
BUTTERNUT SHALL HAVE THE RIGHT TO RECORD THIS AGREEMENT
AND/OR A NOTICE OF INTEREST WHICH REFERENCES THIS AGREEMENT IN.
THE OFFICIAL RECORDS OF BROWARD COUNTY, FLORIDA. THE PARTIES
FURTHER AGREE BUTTERNUT MAY ALSO ELECT FOR DEFGOD TO RECORD A
NOTICE IN THE OFFICIAL RECORDS OF BROWARD COUNTY, FLORIDA THAT
BUTTERNUT HAS AN INTEREST IN DEFGOD AND NO SALES OF PROPERTY
SHALL OCCUR WITHOUT BUTTERNUT’S CONSENT.
ARTICLE XI; NOTICES
All notices, demands, requests or other communications which any of the Patties to this
Agreement may desire or be required to give hereunder shall be in writing and shall be deemed to
have been properly given if sent by FedEx or by registered or certified mail, return receipt requested,
with postage prepaid to address of each Party set forth above or via e-mail:
Ifto DEFGOD: c/o Justin Godur
1515S Federal Hw
Boca Raton, FL. 3
[email protected]
e319
¢/o Shoshana Gibli
2600 S. Ocean Blvd., Apt. 12F
Boca Raton, Florida 33432
[email protected]
ARTICLE XI: MISCELLANEOUS.
Page 7 of 10
This Agreement and the rights and liabilities of the Parties hereunder shall be governed by
and determined in accordance with the laws of the State of Florida. Every provision of this
Agreement is intended to be severable. If any provision of this Agreement shall be invalid or
unenforceable, such invalidity or unenforceability shall not affect the other provisions of this
Agreement, which shall remain in full force and effect.
‘The captions in this Agreement are for convenience only and are not to be considered in
construing this Agreement. All pronouns shall be deemed to be the masculine, feminine, neuter,
singular or plural as the identity of the person or persons may require, References to a person or
persons shall include partnerships, corporations, limited liability companies, unincorporated
associations, trusts, estates and other types of entities.
This Agreement, and any amendments hereto may be executed in counterparts all of which
taken together shall constitute one agreement.

‘This Agreement sets forth the entire agreement of the parties hereto with respect to the
subject matter hereof, It is the intention of the Parties that this Agreement shall be the sole source
of agreement of the parties, and this Agreement shall govern even when inconsistent with, or
different from, the provisions of any applicable law or rule, ‘To the extent any provision of this
Agreement is prohibited or otherwise ineffective under the applicable Mlinois Law, such provision
shall be considered to be ineffective to the smallest degrce possible in order to make this Agreement
effective under the Illinois Law.
Subject to the limitations on transferability contained herein, this Agreement shall be binding
upon and inure to the benefit of the parties hereto and to their respective heirs, executors,
administrators, successors and assigns. No provision of this Agreement is intended to he for the
benefit of or enforceable by any third party. Except as expressly provided herein, this Agreement is
for the sole benefit of the Parties and their respective permitted successors and assignees, and shall
not confer directly, indirectly, contingently, or otherwise, any rights or benefits on any person or
party other than the Parties and their permitted successors and assigns.
‘The relationships between the Parties hereto shall be that of joint venturers for the sole and
limited purpose of carrying on the business of the Joint Venture. Except insofar as otherwise
provided for in this Agreement, nothing herein shall be deemed to create an agency, partnership,
understanding or arrangement between the Parties for the carrying on of business outside the scope
of this Agreement, nor shall any Party (except as otherwise stated in this Agreement) have the ability
to act as agent for any other Party.
‘This Agreement may be executed in any number of counterparts and all of such
counterparts taken together shall he deemed to constirute one and the same instrument. Delivery of
an executed counterpart of this Agreement by facsimile, including, without limitation, by facsimile
transmission or by electronic delivery in portable document format ("pdf") or tagged image file
format ("tiff"), shall be equally effective as delivery of a manually executed counterpart thereof. Any
party delivering an executed counterpart of this Agreement by facsimile, pdf or tiff shall also deliver
a manually executed counterpart thereof, but failure ro do so shall not affect the validity,
enforceability or binding effect of this letter of intent. The Parties hereto acknowledge and agree
thar in any legal proceedings between them respecting or in any way relating to this Agreement, each
Page 8 of 10
waives the right to raise any defense based on its execution hereof in counterparts or the delivery of
such executed counterparts by facsimile or electronic delivery, as applicable
Each Parry covenants and agrees that it will at any time and from time to time do, execute,
acknowledge and deliver, or will cause to be done, executed, acknowledged and delivered, all such
farther acts, documents and instruments as may reasonably be required by the parties hereto in
order to carry out and effectuate fully the transactions herein contemplated in accordance with this
Agreement; provided, that no pasty shall be obligated to provide any further assurance that would
materially increase the liabilities or obligations of such party hereunder ox materially reduce the
rights and benefits of such party hereunder,
The prevailing party in any proceeding to enforce this Agreement shall be entitled to an
award of attorneys’ fees against the non-prevailing party
THE PARTIE
AGREEME}
ANY LITIGATION RELATED TO THIS
WAIVE TRIAL BY JURY 1
IN WITNESS WHEREOF, the Parties hereto have executed this Agreement on the date first
above written,

Defgod, LLC, a Florida limited liability company
Justin Godur
Justin Godur, individually
Butternut Investment Group, LLC, a Florida limited
liability company
By: Shoshana Gibli
Its: Manager
Page 9 of 10SCHEDULE A
PARTY CAPITAL CONTRIBUTION
© BUTTERNUT $1,500,000.00
Page 10 of 10
EXHIBIT “B”26th December 2024
AGREEMENT dated effective 26 December 2024 between JUSTIN
GODUR, an individual residing at 699 Kingsbridge St., Boca
Raton, FL 33487 (the "Pledgor") and BUTTERNUT INVESTMENT GROUP,
LLC, a Florida limited liability company, 2600 S. Ocean Blvd.,
Apt 12F, Boca Raton, Florida 33432 (the "Pledgee").
WITNESSETH:
WHEREAS, Pledgee is owed the sum of $1,500,000.00 by the
Pledgor pursuant to a guarantee of the Pledgor of the
obligations of the joint venture agreement dated December 23,
2024 between Pledgee and DEFGOD LLC, a Florida limited liability
company (the "Obligation").
WHEREAS, Pledgor has agreed to pledge all of his right,
title and interest as a member in Yes We Build, LLC, a Florida
limited liability company (the “Company”) as security for the
repayment of all amounts due under the Obligation, inclusive of
interest.
NOW THEREFORE, for good and valuable consideration received
by the parties hereto, the parties hereby agree as follows:
1. Pledge. As security for the payment in full of the
Obligation by Pledgor, the Pledgor hereby pledges and
hypothecates to the Pledgee, and their successors and assigns,
all the issued and outstanding membership interests in the
Company issued in the Pledgor's name together with all proceeds
thereof, (being hereinafter collectively referred to as the"Pledged Interest"), and hereby grants to the Pledqee
a first
lien on, and security interest in, the Pledged Interest and in
all proceeds thereof pursuant to the terms herein. A ucC-1
shall be filed in the County and/or State in which Pledgor
resides and in Broward County, Florida.

2. Default. The term "Default" shall be construed
pursuant to this Pledge Agreement to include any failure by the
Company, after the notice period provided below, to remit any
payment required to be paid to Pledgee pursuant to the
Obligation provided the Company has exercised its right to
redeem the membership interest in the Company owed by Pledgee or
if the Pledgee has exercised a put right to require the Company
to redeem and purchase the Pledgee’s membership interest in the
Company for $5,250,000. Upon the occurrence of a failure by
Company to remit all required and scheduled payments required by
the Obligation, Pledgee shall provide written notice of such
failure to Pledgor setting forth a fifteen (15) day opportunity
to cure the non-payment. Thereafter, the Pledgee shall have all
rights set forth in this Pledge Agreement.
3. ‘Transfer, Distributions, Etc.
(a) Unless notice of non-payment shall have occurred
and be continuing, the Pledgor shall be entitled to exercise
voting and consensual powers, if any, pertaining to the Pledged
Interest, or any part thereof, for all purposes not inconsistentwith the terms of this Agreement or any other
document or
instrument which evidences the Obligations;
(b) In the event of Default:
(i) The Pledgee shall have the right to have the
Pledged Interest registered in his/her name or in the name of a
nominee or nominees for the purpose of enforcing their rights
and remedies with respect to the Obligation;
(ii) all of the Pledgor's rights to both vote the
membership interest and participate in cash flow distributions
shall terminate until such time as the Obligation has been met
and the Pledgee or her nominee or nominees shall have the sole
and exclusive right to exercise all powers of voting and consent
pertaining to the Pledged Interest, or any part thereof, and
shall exercise such powers in such manner as the Pledgee may
elect in her sole discretion including having the power to
remove the Manager of the Company and to cause the sale of the
Company’s real property or cause a financing or refinancing
secured by the Company's real property in order to allow the
company to fulfill the Obligation; and
(iii) all distributions made upon or in respect
of the Pledged Interest, or any part thereof, shall be paid
directly to and shall be retained by the Pledgee, and applied
against the Obligation.4. Application of Proceeds. The proceeds of any sale or
other disposition of all or any part of the Pledged Interest,
and any other cash at any time held by the Pledgee hereunder,
after deducting all costs and expenses incurred by the Pledgee
in connection therewith (including, without limitation, counsel
fees and other legal expenses), shall be applied by the Pledgee
at such time or times as the Pledgee shall elect in its sole
discretion in the following order and manner, unless otherwise
required by operation of law:

(a) to the payment in full of the Obligations in
accordance with this Agreement; and
(b) the remainder, if any, to the Pledgor.
5. Representations, Warranties and Covenants of the
Pledgor. The Pledgor represents and warrants that:
(a) Pledgor is the legal and beneficial owner of, and
has good and marketable title to, the Pledged Interest, that the
Pledged Interest is subject to no pledge, lien, mortgage,
hypothecation, security interest, charge, option or other
encumbrance whatsoever, except the lien and security interest
created by this Agreement;
(b) he or she has full power, authority and legal
right to execute, deliver and perform all its obligations under
this Agreement and to pledge the Pledged Interest hereunder;
(c) this Agreement has been duly executed and
delivered by the Pledgor and constitutes a legal, valid and
binding obligation of the Pledgor enforceable in accordance with
its terms;
(d) no consent, approval or authorization of any
other party and no consent, license, permit, approval or
authorization of, exemption by, notice or report to, oF
registration, filing or declaration with, any governmental
authority, domestic or foreign, is required to be obtained by
the Pledgor in connection with the execution, delivery or
performance of this Agreement;
(e) the making and performance of this Agreement and
the giving of security hereunder do not violate any provision of
any applicable law or regulation or of any order, judgment,
writ, award, decree or regulation of any court, arbitrator or
other governmental authority, domestic or foreign, or of any
mortgage, indenture, lease, contract, or other agreement,
instrument or undertaking to which the Pledgor is a party or
which purports to be binding upon the Pledgor or upon any of the
Pledgor's assets and will not result in the creation or
imposition of any lien, charge or encumbrance on or security
interest in any of the assets of the Pledgor except as
contemplated by this Agreement;if) the pledge, assignment and delivery of such
Pledged Interest intended to be created hereby has been created
as a valid first lien on and a first perfected security interest
in such interests of the Pledged Interest and the proceeds
thereof on the terms herein purported to be granted?
(g) the Pledgor shall warrant, preserve, maintain and
defend the right, title and security interest of the Pledgee in
and to the Pledged Interest and the proceeds thereof and all
right, title and interest represented thereby against the claims
and demands of all persons whomsoever;

(h) the Pledgor shall not assign, transfer, pledge or
otherwise encumber the Pledged Interest in any manner other than
as pledged to the Pledgee under this Agreement; and
(i) the Pledgor shall refrain from the issuance of
any additional membership interests in the Company to himself or
to any other person without the Pledgee’s written consent while
this Pledge Agreement remains in full force and effect, and if
the Obligation has not been fully repaid and satisfied.
6. Pledgor's Obligations Absolute. The obligations of the
pledgor under this Agreement are absolute and unconditional, and
shall not be impaired or affected by:
(a) any extension or indulgence in respect of the
payment of the principal of or any interest on, or any other
amount payable under, the Obligation or any part thereof, or in
6respect of any prepayment of any part of the principal of the
Obligation; or
(b) any renewal, extension, refunding, amendment or
modification of or addition or supplement to or deletion or
departure form any of the terms of the Obligation; or
(c) any compromise, release, consent or other action
or inaction in respect of any of the terms of the Obligation; or
(a) any exercise or non-exercise by the Pledgee of
any right, power or remedy under or in respect of the Obligation
or any waiver of any such right, power or remedy or of any
default in respect of the Obligation or any receipt of any
security or any release, discharge, loss or alteration of or in
ox dealing with any security; or
(e) any bankruptcy, insolvency, reorganization,
arrangement, adjustment, composition, liquidation, winding-up or
dissolution of the Company or the Pledgor: or
(£) any limitation or discharge of the liability of
Pledgor or in the method of payment or terms of payment under
the Obligation which may now or hereafter be imposed by any
statute, regulation or rule of law, or any invalidity or
unenforceability, in whole or in part, of the Obligation; or
(g) any assignment or other transfer of the
Obligation or any interest therein; or(h) any defense, set-off or counterclaim which the
Pledgor may have or assert, other than prior payment; or
(4) any other circumstance, whether similar or
dissimilar to the foregoing; whether or not the Pledgor shall
have had knowledge of any of the foregoing.
7. Financial Statements. N/A.

8. Amendment, Modification and Waiver. The Pledgee shall
not be deemed to have waived any of her rights or remedies
hereunder by any act, delay, omission or otherwise, and none of
the terms or provisions of this Agreement may be waived,
altered, modified or amended except by an instrument in writing
duly executed by the Pledgor and the Pledgee. Any waiver or
consent granted hereunder shall be effective only in the
specific instance and for the purpose for which given. A waiver
by the Pledgee of any right or remedy hereunder on any one
occasion shall not be construed as a bar to any right or remedy
which the Pledgee would otherwise have on any future occasion.
No failure to exercise or any delay in exercising on the part of
the Pledgee, any right, power or privilege hereunder, shall
operate as a waiver thereof; nor shall any single or partial
exercise of any right, power or privilege hereunder preclude any
other or further exercise thereof or the exercise of any other
right, power of privilege.
9. Termination. When the Obligations shall have been paid
in full or otherwise terminated to the complete satisfaction of
the Pledgee, this Agreement shall terminate, and the Pledgee
shall deliver to the Pledgor, without representation or
warranty, against receipt and at the expense of the Pledgor, the
Pledged Interest hereunder.
10. Further Assurances. The Pledgor agrees that at any
time and from time to time upon the written request of the
Pledgee and at the Pledgor's sole expense, the Pledgor will
provide such opinions of counsel and execute and deliver such
further documents and do such further acts and things as the
Pledgee may reasonably request in order to effect the purposes
of this Agreement.
11. Notices. Any notice, request, demand or other
communication permitted or required to be given hereunder shall
be in writing, shall be signed by the party giving it, shall be
delivered personally or sent by certified or registered mail to
the addressee at the address set forth below or to such changed
address as such party may have fixed by notice (any notice of
change of address shall be effective only upon receipt) and,
unless otherwise specifically provided herein, shall be deemed
conclusively to have been given when delivered personally or
mailed at any general or branch office of the United StatesPostal Service in a registered or certified post-paid
envelope,
at their last known addresses, with copies to
To: Justin Godur
699 Kingspriage st.

Boca Raton, FL 33487
With a copy to: Cory Carano, Esq. _
Kelly, Grant & Tanis
370 Camino Gardens Blvd., Suite 30
Boca Raton, FL 33432
To: Shoshana & Benjamin Gibli
2600 S. Ocean Blvd., Apt. 12F
Boca Raton, Florida 33432
12. Severability. In the event that any provision of this
Agreement shall be finally determined to be superseded, invalid,
illegal or otherwise unenforceable pursuant to applicable law by
an authority having jurisdiction, such termination shall not
impair or otherwise affect the validity, legality or
enforceability of the remaining provisions of this Agreement,
which shall be enforced as if the unenforceable provision were
deleted.
13. Expenses. The Pledgor agrees to pay the Pledgee all
expenses (including reasonable expenses for legal services of
every kind) of, or incident to, the enforcement of any of the
provisions of this Agreement, or any actual or attempted sale,
or any exchange, enforcement, compromise or settlement in
respect of any of the Pledged Interest, and for the care of the
Pledged Interest and defending or asserting its rights and
10claims in respect thereof, by litigation or otherwise, including
expenses of insurance.
id. Miscellaneous.
(a) This Agreement and all obligations of the Pledgor
hereunder shall be binding upon the successors and assigns of
the Pledgor, and shall, together with the rights and remedies of
the Pledgee hereunder, inure to the benefit of the Pledgee, and
its successors and assigns.
(b) ‘his Agreement shail be governed by, and be
construed and interpreted in accordance with, the laws of the
State of Florida.
(c) The rights and remedies herein provided are
cumulative and may be exercised singly or concurrently, and are
not exclusive of any rights or remedies provided by law.
PAGE ENDS
lliN WITNESS WHEREOF, the Pledgor and the Pledgee have duly
executed and delivered this Agreement on the 26 day of
December, 2024.
WITNESS: PLEDGOR:
JUSTIN GODUR

PLEDGEE:
BUTTERNUT INVESTMENT GROUP,
By, a Florida limited
liability company
By: Shoshana Gibli
EXHIBIT “H”NEUMAN
Law,PA
TOOT W. Yamato Road, Suite 401, Boca Raton, Florida, 33431
Tel; 561.571.4500
Eric J. Neuman, Esq.
E-Mail: [email protected]
April 7, 2025
VIA E-MAIL ([email protected]) & CERTIFIED MAIL —
RETURN RECEIPT REQUESTED
DEFGOD LLC
c/o Justin Scott Godur, Authorized Member
1515 S. Federal Hwy, Suite 319
Boca Raton, FL 33432
Justin S. Godur
699 Kingsbridge Street
Boca Raton, FL 33487
Pinnacle One Equity Fund 1 LLC
c/o Pinnacle One Capital Management LLC, Manager
40 S.E. 5" Street, Suite 503
Boca Raton, FL 33432
Re: Our Clients: Butternut Investment Group, LLC
Amount Due: $4,500,000,00
CIVIL THEFT NOTICE & DEMAND FOR TREBLE DAMAGES
Dear Mr. Godur:
Our law firm is litigation counsel to Butternut Investment Group, LLC (“Butternut”) and its
principals, Shoshana and Benjamin Gibli. Our clients have consulted with us regarding Butternut’s
loan to DEFGOD LLC (“DEFGOD” or “Borrower”) in the principal sum of $1,500,000.00 (the
“Loan”).
As you are well aware, on December 26. 2024, DEFGOD and Butternut entered into a Joint
Venture Agreement (’JVA") in connection with the acquisition and development of real property
located at 1555 SE 7th Street, Deerfield Beach, Florida (the “Property”). In addition, you
contemporaneously executed a Pledge Agreement personally pledging your membership interest
in Yes We Build, LLC (“Yes We Build”) as security for the Loan.April 7, 2025
Page 3

It has come to our clients’ attention that you have materially breached the foregoing agreements,
and have otherwise violated applicable Florida law, resulting in damages to our clients in the
amount of $4,500,000.00.
Notice of Default: Breaches of the JVA and Pledge Agreement
The JVA explicitly warrants that DEFGOD, at the time of the JVA’s execution, was under contract
to purchase the Property and that the Property would be titled in DEFGOD’s name. In direct
contravention of these representations, the Property was instead deeded to Pinnacle One Equity
Fund I LLC, an entirely separate entity. These actions undermine the central premise of the JVA
and materially breach Article II of the same.
Additionally, DEFGOD agreed in Article III of the JVA that, within forty-five (45) days of
acquiring the Property, it would obtain a construction loan from Archwest Capital and immediately
transfer the full amount of the first draw, anticipated to be $1,500,00.00, to Butternut. As of the
date of this letter, no such repayment has been made, constituting a material breach of Article III
and a “Default,” pursuant to Section 2 of the Pledge Agreement.
Under the Pledge Agreement, you further warranted that your personally pledged interest in Yes
We Build was unencumbered. Contrary to your representations, and in breach of your obligations,
you filed a UCC-1 financing statement on March 10, 2025, in favor of a completely unrelated third
party. , granting it a lien over Yes We Build. Your fraudulent concealment
and unauthorized encumbrance of pledged collateral is a direct violation of your warranty in
Section 5(a) and your covenant in Section 5(h) of the Pledge Agreement not to assign or encumber
the pledged interest.
Furthermore, Sections 1 and 3 of the Pledge Agreement required you to file a UCC-1 naming
Butternut as secured party, No such filing has been made. Your failure to provide “further
assurances” to effectuate the agreement (see Section 10 of same) constitutes yet another material
breach of the Pledge Agreement.
The pattern of misrepresentations, diversions of funds, failure to honor contractual obligations,
and your misuse of an elderly couple’s investment exceeds mere civil wrongdoing, and squarely
falls within the scope of criminal conduct under Florida Statutes, namely:
+ Section 825.103(1){a), Florida Statutes: You exploited elderly persons with whom you had
a business relationship by knowingly obtaining and misusing the Loan, intending to
permanently deprive them of the same.
+ Section 825.103(2), Florida Statutes: The Giblis, both over the age of 65 and having known
you for less than two years, made a transfer exceeding $10,000 for which they received no
equivalent financial value. This creates a statutory presumption of exploitation.
* Section 812.014, er seq., Florida Statutes: Your intentional and unauthorized use of the
Loan for purps unrelated to the JVA constitutes civil theft. Pursuant to Section 772.11,
Florida Statutes, our clients are entitled to treble (triple) damages, attorneys” fees, and
costs.April 7, 2025
Page 3
In light of the foregoing, and pursuant to Section 772.11, Florida Statutes, demand is hereby
made on behalf of Butternut that you pay treble damages for the stolen monies in the amount of
$4,500,000.00 within thirty (30) days of receipt of this demand.
While we are hopeful that you will remit the amount due to Butternut without resort to legal action,
understand that our clients are fully prepared to initiate suit, if necessary, wherein we will seek not
only a judgment against you and/or DEFGOD for all amounts due and owing, but also collection
of all resulting costs and attorneys" fees incurred by Butternut.

In order to avoid this eventuality, you must remit the amount of $4,500,000.00 by May 7, 2025.
Further payment instructions will be provided upon receipt of written confirmation of your intent
to pay via e-mail or letter to the undersigned received on or before April 18, 2025.
If this is not done, our firm may proceed to commence legal action against you and/or DEFGOD,
and any other responsible parties, without any further notice and take such other steps as we deem
necessary to fully protect and vindicate the interests of our clients, The determination as to whether
such action will be required rests entirely in your hands.
In addition to the demand made herein, our clients expressly reserve the right to seek foreclosure
of your pledged membership interest in Yes We Build, the imposition of a constructive trust over
the Property and any substitute assets, injunctive relief to prevent any further dissipation of assets,
compensation for any and all other damages accrued, and any and all attorneys’ fees and costs
arising out of the foregoing.
We trust that you will be guided accordingly by these advisements, which are set forth without
prejudice to the rights and interests of Butternut Investment Group, LLC, Shoshana Gibli, and
Benjamin Gibli.
Very truly yours,
NEUMAN LAW, PA
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GLOBAL PUBLIC ALERT OF JUSTIN GODUR FRAUD

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GLOBAL PUBLIC ALERT OF JUSTIN GODUR FRAUD

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