Attorney Andrew Bernhard’s law firm files two new fraud lawsuits

Attorney Andrew Bernhard‘s law firm files two new fraud lawsuits this past month. The fraud-based lawsuits cover both construction fraud and construction defect matters, as well as business disputes and joint venture agreement breaches. See excerpts of the lawsuit pleadings below.


The first, a Miami-Dade lawsuit between a property owner and several construction and contracting entities, alleges fraud, negligence, battery, breach of contract, promissory estoppel, unjust enrichment, civil conspiracy, violation of the Florida Deceptive and Unfair Trade Practices Act (“FDUPTA”), and violation of Florida RICO. As garnered from excerpts of the pleadings:

“[Contractor] and [co-conspirator] conspired to defraud the public and circumvent Florida construction contracting regulations and licensing requirements by spreading one construction contracting license across numerous unsupervised business entities and construction work sites, thereby multiplying the amount of construction jobs they could take in for profit while minimizing the amount of costly expert supervision they employed and paid out per construction job. Under this fraudulent conspiracy, licensed contractor [] and unlicensed businessman [co-conspirator] advertised and offered plumbing and general construction services under a shell game of distinctly owned entities ([entity 1], [entity 2], and others, all doing business as [entity 3]) as though they were one single business jointly owned and operated by a professional and capable plumbing construction expert. . .

“However, there was no proper, legal, or professional affiliation between these people or entities and no licensed contractor supervising all of their construction work. In reality, the incapable and unqualified [co-conspirator] and associates simply performed significantly inferior construction work under the guise of [Contractor]’s unaffiliated [entity 1/entity 2] entity and contractor license, sending kick-backs to [Contractor], who failed to uphold his statutory duty to supervise every aspect of his construction projects for the public’s health, safety, and welfare. Plaintiff [] is a victim of these defendants’ frauds, having transferred payments to the defendants for professional licensed plumbing construction that he never received. . .

“Instead, the defendants caused [Plaintiff]’s property significant damage. When confronted with their fraud, [co-conspirator] physically attacked [Plaintiff]’s owner, while [Contractor] later attempted to siphon more money out of [Plaintiff] before abandoning the construction worksite altogether. These acts multiplied the harm to [Plaintiff], requiring [Plaintiff] to pay new contractors extra to undo the defendants’ property damage. Accordingly, [Plaintiff] seeks treble damages, costs, and attorney’s fees, and any other remedy the Court deems just and proper, for its losses.”


The second, a Miami-Dade lawsuit between a business owner and manager and several former joint venture associates, alleges multiple claims related to fraud and improper business practices. As garnered from excerpts of the pleadings:

“[Defendant 1] is a wealthy and experienced [] businessman who leveraged his power and corporate knowledge to fraudulently induce hopeful [] immigrant [Plaintiff] to invest nearly two years of labor and credit to start up and operate two businesses for [Defendant 1], only to thereafter deny [Plaintiff] his overdue salary and ownership interests, and eject him from the businesses. . .

“[Defendant 1] first contacted [Plaintiff] in 2011 with promises of business ventures, shareholder interests, and decent management compensation. [Defendant] offered $4000/month salaries and company shares if [Plaintiff] would do all of the legwork to start up and manage businesses. [Plaintiff] agreed and diligently performed, successfully launching the first joint venture—import company [Entity 1]. [Plaintiff]’s [Entity 1] launch was so successful that [Defendant 1] determined he could use [Entity 1] to obtain an immigration visa approval, fraudulently inducing [Plaintiff] to transfer all interests in [Entity 1] to [Defendant 1] for that purpose. To bait this inducement and veil the fraud, [Defendant 1] simultaneously suggested collaboration in a second venture—[Entity 2]. Like the [Entity 1] deal, [Defendant 1] offered [Plaintiff] another $4,000 salary and an ownership interest in [Entity 2] if [Plaintiff] would do all of the legwork, from entity creation to business management. In the commotion of starting up [Entity 1], [Plaintiff] agreed to launch [Entity 2]. [Plaintiff] successfully launched [Entity 2], incurring contractual and financial liability in the process. . .

“Once [Defendant 1] obtained his immigration visa and two running businesses, he began to cut off and cut out [Plaintiff] from both ventures, leaving [Plaintiff] with nothing to show but unpaid business bills and a bruised professional reputation. [Defendant 1] has unconscionably taken advantage of [Plaintiff]’s trust and the imbalance of financial and informational power, and up-ended [Plaintiff]’s life through this fraud and deception. Accordingly, [Plaintiff] requests that this Court order [Defendant 1] , these two entities, and their co-owners to compensate him for the unpaid salaries in both businesses, the value of his stolen business ownership interests, the cost to recuperate his financial credit, and the cost of the unpaid business bills, plus interest, attorney’s fees, and court costs.”


If you have a construction defect, fraud, or business dispute, contact attorney Andrew Bernhard at,, or 786-871-3349.


Bernhard Law Firm PLLC
Bernhard Law Firm PLLC


Miami International Attorneys
Miami International Attorneys



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