Defense 28 06 2018 English ANDRES F. NIÑO - Vs - LUCIA RUGGERI MOON CHARM CATTERY

Andrés Felipe Niño Solano
Ingeniero Industrial
Villavicencio - Colombia, June 26, 2018.
Sirs:
EXECUTIVE BOARD & PROTEST COMMITTEE
THE CAT FANCIER`S ASSOCIATION "C.F.A."
260 East Main Street Alliance, OH 44601
United States Of America
Subject: Appeal of Lucia Ruggeri Vs. Andres Felipe Niño Solano

Reference: Docket Number: 17-027-0714
Respected Members of the BOARD OF DIRECTORS & the COMMITTEE OF PROTEST of CFA,
respectful greeting: in advance I ask that this document be read and be known to the members, of each
and every one of the representatives in the Board of Directors in the next session June 28, 2018:
ANDRES FELIPE NIÑO SOLANO, of legal age, of Colombian nationality, identified civilly as it appears at
the foot of my signature, in my condition of affiliate to CFA under the registration number CFA No. 260339,
being within the normative term, which was communicated to the undersigned on 06/25/2018 through email
(jrandolph@shermanhoward.com), I respond to my defense, with respect to the answer from the
defendant: LUCIA RUGGERI - MOONCHARM CATTERY; "Lucia Ruggeri appeal of CFA Executive Board
of Directors of December 13, 2017 tentative ruling letter Docket No. 17-027-0714 Appeal Statement", in the
following terms:
I. A THE FACTS
In accordance with the official letter and its attachments (Up to Annex 14, I do not know the rest, the 36
attachments were not delivered to me), which contains the appeal letter granted by the CFA to Mrs. LUCIA
RUGGERI in case No. 17 -027-0714, then I allow myself to make the necessary clarifications and
contradictions in my defense:
TO POINT 1.1: IT IS PARTIALLY CERTAIN that a sales contract was signed, since Mrs. Lucia Ruggeri
practically conditioned the purchase and sale which was supported by a contract signed by the buying
party.
This contract was reviewed and adjusted by the undersigned buyer, since the text sent in its original by
Lucia Ruggeri was openly unfair, which only benefited Mooncharm Cattery in the event of any news.
The contract signed and accepted by the undersigned applicant was published on the personal Facebook
page of Mrs. Lucia Ruggeri, who has sent the corresponding translation.
TO ITEM 1.2: IT IS NOT TRUE that the applicant subscriber; ACCEPT in the FIFTH clause of the
aforementioned contract that in case of differences or violation of some of the stipulations derived from said
document, were resolved by the Arbitration Chamber of Caracas - Venezuela, the foregoing for two
reasons: 1) The undersigned applicant, NO he is a Venezuelan citizen, so it is not appropriate to go to a
state service in Venezuela when he does not have the status of a citizen of that country. 2) In the original
text of that contract, the following was agreed: (...) 6. In the case of the violation of this contract by any of
the parties, any legal dispute will be resolved exclusively under the arbitration conducted by the Arbitration
Center of the Chamber of Caracas and / or the Chamber of Commerce of Villavicencio under its rules and
procedures of commercial arbitration, according to agreement between the parties. (...), which allows us to
infer that it was enabled in the negotiation that the Chamber of Commerce of Villavicencio, the city where I
was born and currently living, was also authorized to settle any contractual conflict.
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Dirección de Correspondencia: Calle 4 Sur No. 35 A – 66 Apartamento 201 Bloque A1 Conjunto Cerrado A
Multifamiliares Los Centauros, Villavicencio, Meta (Colombia) Cel. 310 318 4424 – 311 807 2947,
Tel.664 54 07, Email. andresfelipe_ns@hotmail.com
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TO ITEM 1.3: IT IS NOT TRUE that in the light of the commercial norms, only the Chamber of Commerce
and / or arbitration of the City of Caracas would be enabled, as it was previously explained, it was not
logical or feasible for the subscribing plaintiff to accept such imposition at all lights trick of the lady LUCIA
RUGGERI, if you analyze carefully what described by the defendant is UNFAIR to force the counterparty to
accept a contractual clause which can not be asserted because it lacks the legal possibilities to exercise
the rights, this is why that in the contract that I accepted at the time, it was proposed that the Chamber of
Commerce and Arbitration of the city of Villaviencio (Colombia) be also authorized to settle any type of
legal conflict that may arise between the parties.
That is why the defendant does not accept that the contract that is legally signed is the first, the one sent by
the undersigned applicant in order to be more fair and viable for the parties, however it is imperative to
recognize that the CFA in this case because they are properly registered breeders, they can go to the
Protest Committee so that this avoques knowledge of the conflicts between the breeders, and knows and
decides on the violation to the norms and protocols in force of the constitution or any other norm of the
CFA.
So again and again Mrs. LUCIA RUGGERI cleverly tries to suggest that the honorable BOARD OF
DIRECTORS or the PROTEST COMMITTEE of the C.F.A. They are NOT competent to intervene in the
matter that was brought to their knowledge and that was decided by the decision of the Board of Directors
dated December 13, 2017 about the case no. 17-027-0714, and then a second judgment on the decision
dated February 5, 2018 of case No. 17-034-1023 where the CFA acquits the applicant subscriber, for the
counterclaim established by Mrs. RUGGERI against me It is curious that the defendant astutely states that
the CFA has no competence to decide on the matter, but did use the CFA protest procedure; As I
mentioned before, through case No. 17-034-1023 against me, to date I have not received any notification
from the Chamber of Commerce and Arbitration of the city of Caracas.
TO ITEM 1.4: IT IS NOT CERTAIN that the Chamber of Arbitration and Commerce of Caracas has more
post to know the matter than the Committee of Protest of the CFA, it seems disrespectful and unduly that
Mrs. LUCIA RUGGERI affirm that the Chamber of Arbitration and Commerce of Caracas has power to
know about the matter, I reiterate ignoring the modification that was made to the contract of sale where I
am including the chamber of Commerce and Arbitration of the city of Villaviencio, in the case that concerns
us it is FALSE to affirm that the camera of Caracas has power over the contractors because I repeat the
undersigned complainant does not have Venezuelan nationality as if the defendant has Mrs. RUGGERI,
then, it is understood that the parties are affiliated with the CFA the agency that really has power to know
any The conflict that arose between its members is the CFA, since Mr. ANDRES FELIPE NIÑO SOLANO &
Mrs. LUCIA RUGGERI are breeders. two in the CFA.
In this regard, the CFA Constitution reads: ARTICLE XV - DISCIPLINE Section 1 - Competition of the
Chambers:
(...) The Executive Council shall be the sole competent to DISCIPLINE MEMBERS, judges, employees,
ERS breed-, official exhibitors, exhibitors, and all other parties who, by their voluntary participation in CFA
activities subject themselves to its various standards, between They are mentioned in this article, in order
to preserve the integrity of this organization in the fulfillment of its objectives. The disciplinary power can
only be exercised after due notification and the opportunity to be heard is given for the first time. The
disciplinary measures will require the affirmative vote of two thirds (2/3) of the members of the pre-sent
Council. (...)
TO ITEM 1.5: IT IS FULLY TRUE that Mrs. LUCIA RUGGERI failed to comply with her contractual
obligations, but not only that, as the CFA Board of Directors stated in her judgment or ruling of December
13, 2017, which said statement reads: (...) Lucia Ruggeri: guilty of the following violation (s): CFA
Constitution article XV, section 4 (b) - The board has decided that the following disciplinary action will be
imposed: respondent be found guilty and ordered to make restitution to the sum of € 2.832.83 and pay a
fine of $ 500.00 to CFA. both the fine and restitution to be paid within 30 days, or Lucia Ruggeri shall be
suspended from all CFA services until both are paid in full. (...), es decir que se le hallo culpable de violar la
constitución de la CFA la cual nos rige a todos los criadores.
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However, it is contradictory that the complaint states that the CFA is not competent to settle contractual
matters that in the case at hand is process No. 17-027-0714, but if Mrs. RUGGERI has instituted a protest
for the same facts made known by the undersigned, through case No. 17-034-1023, which I reiterate was
not found guilty by the Board of Directors of the CFA or its protest committee.
TO ITEM 1.6: IT IS NOT CERTAIN that the undersigned applicant acknowledged through his writings that
the Venezuelan State could be approached to settle any type of legal conflict against Mrs. LUCIA
RUGGERI, this lacks truth because the undersigned applicant is NOT a citizen Venezuelan, then it is
inappropriate to say that someone can go to a jurisdiction without any novelty when you do not enjoy the
qualities to invoke them or activate the legal mechanisms, if this is so on the other side of the border, it is
also true that the State Colombian would not have jurisdiction to settle a conflict of interest to force Mrs.
LUCIA RUGGERI to be guilty to force her to comply with her contractual or legal obligations, that is why the
only international body that does have the competence to hear this matter is the CFA, also because it deals
with the sale of a cat "PARTI WAI JELLY BELLY" that was born in the Est United States of America, in the
Parti Wai hatchery owned by Mrs. Gloria Bulseman, an American citizen whose hatchery is also registered
with the CFA.
Now, it is of public and international knowledge the economic, social and governmental crisis that has
crossed the country of Venezuela for some years, the Venezuelan state is NOT guarantor even for the
Venezuelan citizens, much less it will be for the foreigners, every day , thousands and thousands of
Venezuelan brothers across the border with Colombia in search of work, health, opportunities, and
especially food, since human beings have died of hunger, the more pets or animals. It is absurd to ignore
this issue, as I mentioned earlier. Venezuela is a dangerous country and it is not so easy for a Colombian
to cross its borders in order to seek "justice".
TO POINT 1.7: I trust that if the Committee of Objection avoco conocimieno and the Board of Directors of
the CFA has decided on the particular in the first instance which was demonstrated through the ruling of
12-13-2017 and then resolving the counterclaim of 03- 02-2018 given by Mrs. Ruggeri, then we are facing
a fact that the CFA, IF has the competence to decide and settle on the issues or conflicts of its members,
affiliates or members, as is the case in particular that concerns us, and will be resolved in the board of
directors for the month of June 2018 for the second and last time.
TO ITEM 1.9: IT IS NOT CERTAIN that the Protest Committee and its board of directors have to refrain
from deciding on a matter that is within their competence as I have argued above.
I repeat is contradictory that Lucia Ruggeri seeks to ignore the authority and supremacy of an entity as
respected and honorable as the CFA, maxime if we do not refer to its governing bodies as is the BOARD
OF DIRECTORS and its protest committee, I allow myself to express that I do recognize your supremacy
because it is a matter more than contractual ethics and respect for the life of animals "cats", as was the
case of Parti Wai Jelly Belly.
It is curious that Mrs. Ruggeri of MoonCharm again and again tries to ignore the authority of the Board of
Directors and its protest committee, but if she has tried to make use of her rights as an affiliate through the
same committee, of course the opinion was not in his favor, he is now launching attacks against the CFA,
as demonstrated in his appeal brief.
TO THE POINT 1.10: IT IS IRRESPETOUS I personally consider to see, as Mrs. Lucia Ruggeri refers to
the decisions and decisions of the CFA, entity to which she freely affiliated and accepted to comply with
some rules and protocols, which now do not only pretends to ignore if not also use qualifiers such as: (...)
the CFA had no power or jurisdiction to hear procedures that were initially presented to their attention, and
even LESS to decide on any claim (...), it seems that the previous The phrase evidenced in your appeal is
crossed and extremely disrespectful and disrespectful, and goes against the wise decisions that the
BOARD OF DIRECTORS and its Protest Committee adopt in the legal and regulatory framework of the
constitution of the CFA.
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The above shows how Mrs. LUCIA RUGGERI, believing that because I try to impose a contract that is
highly damaging to the interests of the buyer, can make fun of justice and as she says the truth is one, and
the truth is that the one that has been commented through each and every one of the accusation and
defense briefs presented by the undersigned plaintiffs against Ruggeri.
TO THE POINT 1.11: Without comment, both the Protest Committee and the Board of Directors have
granted the prudential terms for the defendant to present their defense and their arguments, more so when
the Protest Committee notified the matter of the claim presented by the subscribed, Mrs. Ruggeri never
answered or presented legal recourse within the term, said term expired and the Protest Committee
informed me that there was an error for which it could not be notified, this error can not be attributed to me
as it manifests in its At this moment, the CFA must have updated in its databases all the correspondence
information of its affiliates in order to maintain timely contact with each of them, however despite the fact
that in the first term the Fixed Protest Committee did not answer a second term. where Mrs. Lucia Ruggeri
made use of her legal mechanisms, and to date she has not been denied.
TO POINT 2.1 .: IT IS TRUE that the problem arose, since the subscriber purchased a cat from the Persian
race owned by Mrs. RUGGERI, as she mentioned the papers she received from the Venezuelan
veterinarian saying that the cat had 6 years, when in the records of the CFA it was observed that she was 4
and a half years old at the moment of being sent to Colombia.
With respect to whether he had 04 litters or 05 litters, he DOES NOT CONSISTS ME, since this information
is only known to the defendant, I repeat JELLY BELLY could have had more children that may not have
survived, or had abortions which were not reported when the cat was owned by RUGGERI.
On the other hand, it is important to state that at the time of the sale, that is, when the cat was sent to
Colombia, Mrs. Lucia Ruggeri did NOT have the permission of the PARTI WAI hatchery, to see JellyBelly,
when she inquired with the owner Mrs. GLORIA BULSEMAN, she told me that Lucia Ruggeri never asked
her permission or consulted her to authorize or not the sale of Jelly Belly to a third party, we all know that
when a cat is not born in our cattery it does not appear with our affix for respect to the breeder we must
consult about our intention to sell or transfer it to a third party, maxime when it is sold for reproductive
purposes, remember that breeders are very jealous to give their bloodlines to certain people or countries,
even if not There is a contract of sale, I always repeat for RESPECT, the breeder should be consulted
about the intention of assigning one of our copies.
Now this is more than evident in the advanced age of JELLY BELLY because as she states in her appeal
letter the cat was more than four years, multiple births, and so far as she recognizes only one (01)
Caesarean section.
There is so much talk of ethics and professionalism that Lucia Ruggeri has a hard time recognizing that she
should never have sold a female over 4 years of age, that out of respect for the animal and as she
recognizes herself before being sent to my power, the cat Jelly Belly had a strong health impace, they are
more than enough reasons to have castrated the cat and given her to a home that would take care of her
simply as a companion animal, and never for reproductive purposes, in effect since Ruggeri talks about
that is a woman with ETICA, she should have returned the money written by the undersigned (USD 2,400)
and have NEVER sent to Jelly Belly.
TO POINT 2.2 .: IT IS PARTIALLY TRUE, that the cat was in perfect health, APPARENTLY it was sent
well, that is to say ON LOOKING it did not present signs of enferemdad, which I have manifested again and
again, since since I arrived at the few days of being in my power, the cat, began to present food problems,
which Mrs. RUGGERI intends to see that they were my fault (incopetencia, ignorance etc), it is important to
say that since 2012 I grew up for love of race Persian cats and never had such an unfortunate episode as
was the case of JELLY BELLY which I have told you extensively.
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TO ITEM 2.3: IT IS TRUE that Jelly Belly according to records appears is the mother of some cats that
have achieved titles in the CFA and TICA, but this does not exempt the fact that it is wrong to sell a female
with more than 4 years of age with multiple births and as she states, a single cesarean apparently only one,
since as a report through a university professional here in Colombia, Jelly Belly had more scarring in the
abdomen.
TO POINT 2.4: IT IS PARTIALLY CERTAIN that the 72-hour period was not used to find any novelty or
health symptom apparently visible in the cat, Mrs. Ruggeri does not know that the cat was taken to the vet,
and is more so during The process of nationalization in Colombia at the airport was also inspected by the
veterinarians of the Instituto Colombiano Agropuecuario ICA, entity of the Colombian State, in charge of
carrying out the sanitary controls of the animals that are imported for Colombia.
On the other hand it is clear that it is a great happiness to finally receive Jelly Belly after more than eight
(08) months of waiting, finally the long wait was over and we had our cat which we love very much and was
with us, despite all the health problems.
TO POINT 2.5: IT IS TRUE THAT during the time that JELLY BELLY was under my power and custody the
cat never manifested symptoms of heat, nor reproductive abilities, always behave in a very passive and
calm way as a pet cat, which I generate in my person, the constant complaints to MOONCHARM whenever
Ruggeri always said that it was because of the poor diet that I gave him or lack of veterinary care, which
was false, although it is true I am not a famous or recognized breeder , and clarify I do not pretend to be, I
am not the worst of the ignorant, it is also true that we provide a bad diet, it is also false that we do not
provide an affectionate, adaptable home, nor can we say that we have many specimens for breeding, all
these are only excuses and false arguments from the defendant who tries again and again to cleverly use
any means to safeguard their responsibility.
TO POINT 2.6: IT IS NOT CERTAIN that the undersigned applicant knew that JELLY BELLY had three or
four surgical procedures for cesarean section, if at any time Ruggeri said it he did not remember it, now, I
want us to understand that one, two, three or even four caesarean sections are NOT an impediment for a
female to go into heat, or that this is a valid argument to affirm that JELLY BELLY was an infertile cat, Lucia
Ruggeri if she practiced one or more caesarean sections in order to save the life of the babies and the
mother did well, I think any breeder would do it instead, cousins the mother's life and then that of the
puppies, this is NOT a sin or a mistake, even in the case of human mothers we know that the practice of
the cesarean It is a mechanism that allows the mother to give birth and in no time can generate infertility,
although it is also known that surgical procedures can bring secondary consequences.
With this I want to clarify and distort the thesis of this point presented by Ruggeri, the incorrect fact
committed by the defendant is to hide the information, say it was only a cesarean and recognize only so far
(according to appeal) when in fact they were more practices of these, which was evidenced here in
Colombia, on the other hand in no case is accusing that by; Lucia Ruggeri having authorized the practice of
cesarean section or cesarean sections, I act in an improper way, I reiterate otherwise I do well, which is the
point that generates discomfort, which is NOT due to a female who was subjected to one or more surgical
procedures like these, It is INCORRECT to have sold it for breeding purposes, but apparently Mrs. Ruggeri
applauds and sees this as good, I reiterate, no, it is not correct to have offered and accepted to sell a
female who had such a record, and this if serious lack is set, which shows that the Ruggeri has no ethics or
consideration with their copies.
TO POINT 2.7: IT IS PARTIALLY CERTAIN that all the aspects and characteristics about JELLY BELLY
were known, it can not be said that all the aspects were of my knowledge since it is known that the
breeders only give information that is of interest and that can be supplied , IT IS TRUE that Ruggeri offered
other copies younger than JELLY BELLY, which is also TRUE is that since the month of January 2015, I
personally and several times asked Ruggeri to return the consigned money (USD 2,400), taking into
account account that the cats that were of my interest (JELLY BELLY & RAHCEL) at the time and for the
time of the events, presented clinical singings of deterioration of health as Ruggeri expressed it and I
accept in his writing of appeal.
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TO THE POINTS: 2.8 - 2.8.1 -2.8.2 - 2.8.3 -2.8.4 - 2.8.5 - 2.8.6: IT IS NOT CERTAIN that there is
inrolerance, or falseness in the data provided by the undersigned applicant, said practice of ultrasound was
carried out in the month of December 2015, the Veterinary Medical Center that sent Jelly Belly is ANIMALS
CENTER, owned by Dr. Magnelly Ardila Rey de cedula of Colombian citizenship No. 40,398,295 with valid
professional card as Veterinary Medicine and Zootechnist No. 05323 graduated from the University of the
Llanos, who practiced the ultrasound was Dr. GERMAN LOZANO Veterinarian of the UDCA (University of
Applied and Environmental Sciences of Colombia) with professional card in force as Veterinary Doctor No.
4954, said copy of the opinion of Dr. Lozano, along with the entire file rests in the Veterinary Unit ANIMAL
CENTER, and can be corroborated in the following address: animalcentervillavicencio@hotmail.com,
telephones: 312 478 5642, in the city of Villavicencio Meta, with respect to the formalisms used by Dr.
German Lozano I will not make reference as each professional univeristario is free to use the formats and
texts that you want and in your opinion you consider relevant, in its essence it is the content of the report
that is the background and not the form.
On the other hand as Mrs. Ruggeri in point 2.1 recognized that the Venezuelan veterinarian Jelly Belly
treatment at the time committed a writing error to place the cat was 6 years and not 4 and a half as it was in
reality, and who also like Dr. Lozano, just put the name of Jelly Belly, and not the affix, it is absurd to say
that because this reason the report with signature and seal of a university professional is invalid.
Obviously the female "JELLY" was treated according to what Dr. Magnelly Ardila (referring physician)
ordered, which was satisfactory as the cat exceeded her health impace with great difficulty.
TO POINT 2.9: IT IS NOT CERTAIN, if the report of the ultrasound was provided, a certification from the
medical center ANIMALS CENTER of Villavicencio was also provided, where Dr. DANIEL HERRERA
CARDENAS certified him with a Professional Card No. 28569 (See ANNEX 14 - ANIMALS CENTER
VETERINARY- Official letter dated November 14, 2017), where it is evident that the cat JELLY BELLY is
registered with a medical record under code No. 012840; was certified by this veterinary medical center;
(...) consulting in the past for different health reasons and management issues. I declare that his owner is a
responsible person and cares about the welfare of all his pets (...).
The case of the problem of gengivitis, which was an examination before the National University of
Colombia, added to all the previous clinical pictures, came the recommendation of the veterinarians and
not of the subscribed one to practice the euthanasia to Jelly Belly, which was accepted in your moment I
preferred that the cat rested from so many health losses, and not continue to submit to unnecessary
medical procedures.
TO ITEM 2.10: In this regard I will only limit myself to transcribe what the constitution of the CFA reads as
follows: ARTICLE XV - DISCIPLINE- Section 2 - conduct of the members Subject to the Disciplinary Board:
The Board may reprimand, suspend, expel and / or a fine member of any club in a guilty verdict for: e) any
action or conduct serious and clearly prejudicial to the interests and welfare of the cat or cat breeders
association.
Certainly the constitution of the CFA is categorical in warning those who can be subject to discipline and
also continues to prescribe:
Section 4 - Address of club officers, breeders, exhibitors, show officials and other participants Subject to
Disciplinary Board: The breeder, exhibitor, official show, or other participant in CFA activities may be
harmed, prohibited from exhibiting, provides access to CFA services and facilities, including the registration
of cats, the transfer of property, placement of advertising in CFA publications, and / or a fine if found guilty
of: a) Cruel or inhumane treatment in breeding , maintenance, display, or otherwise deal with felines. & g)
Any action or conduct serious and clearly detrimental to the interests and welfare of the cat or the Cat
Breeders Association.
Then it is understood that the CFA and the autonomy of the Board of Directors can assume or advocate
knowledge in order to discipline any of its members, and the configuration of the lack and the relationship
with the punctual text of the violated constitution will be determined by the CFA and not by the plaintiff.
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TO POINT 2.11: Numeral b) says the intentional misrepresentation in relation to the registration of a litter
OR A CAT. (section 4, Art. 15), it is up to the BOARD OF DIRECTORS to determine the lack and
contextualize it within the normative framework, the cited text demonstrates that not only is the
misrepresentation not only in relation to the documents but also with respect to the cat.
TO ITEM 2.12: IT IS PARTIALLY CERTAIN that the applicant transferred ownership of the cat JELLY
BELLY, however, as mentioned above, she did not have the permission or approval of JELLY BELLY's
breeder, who was actually Mrs. Gloria Bulseman of PARTI WAI PERSIANS. it is cruelty and affects the
welfare interests of the animal as it is in the case at hand, since I repeat JELLY should never have been
sold but on the contrary should have been castrated and delivered to a home to rest and live simply as a
companion animal.
TO POINT 2.13: IT IS NOT CERTAIN that because of my failure as a breeder I want to blame LUCIA
RUGGERI, I do not consider myself a failure, I do not live by exploiting animals, I am an industrial engineer
and I am an industrial engineer of my profession, but above all of the grace of my Lord Jesus Christ, I have
never asked for anything other than the return of the money turned over, or the replacement of another cat:
male or female in conditions acceptable for reproduction and breeding. It is clear that MOONCHARM
CATTERY is guilty of sending a cat under conditions not optimal for reproduction because although it is
sought to argue that the cat JELLY traveled to Colombia in optimal conditions, note that the outcome was
fatal, just like Mrs. LUCIA RUGGERI, accepts that the cat was in recovery and weight gain in order to be
able to finalize the purchase process with the subscriber plaintiff and buyer and be sent in the month of
June 2015.
TO POINT 2.14: DO NOT CONSISTS me that no records have been modified, DO NOT CONSISTS me
that veterinary medical examinations have not been manipulated in Venezuela, DO NOT CONSISTS me
that Mrs. LUCIA RUGGERI has told the whole truth about the health of Jelly Belly.
The truth is that when you inquire about the real social and economic state of Venezuela you can come to
the certainty that none of your institutions are reliable, if this is not for public entities such as private or
private entities, they may lend themselves to acts shameful of corruption.
TO THE POINT 3.1: IT IS CERTAIN in several opportunities consult MOON CHARM CATTERY, about the
availability of Persian puppies or kittens, my dream was to have a copy of Mrs. LUCIA RUGGERI, I
personally admired her a lot and at first she was very kind to me, always answered my concerns, until the
news of JELLY BELLY was presented, once the cat was under my power, and everything changed for the
worse, and it had the fatal outcome that we all now know in social networks, and in the CFA.
TO POINTS 3.2 - 3.3: IT IS CERTAIN what narrated by Mrs. Ruggeri.
TO POINT 3.4 .: PARTIALLY CERTAIN, as Mrs. Ruggeri states at the time maybe I proposed a payment
against delivery, that is to say once the animals (kittens) traveled to Colombia were later payments, this as
she mentioned herself was only one proposal, proposal that was denied by her who required and requires
the payment of their copies before, to be able to make shipments, which seemed understandable at the
time, although risky for the undersigned.
TO POINT 3.5 .: IT IS TRUE that for the time, before or before making the turn (October 2014), I was
extremely interested in the following Cats (03) females and male (01) (still published with photos
supposedly of the current state on his website: http://mooncharmcattery.com/category/persas/hembras-
persas/page/2/):
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http://mooncharmcattery.com/category/retirados/ :
Note that on the website of MOONCHARM CATTERY, the cat PARTI WAI JELLY BELLY is still active as a
breeder.
On the other hand it is important to mention that the cat that was initially bought was PURRINLOT SWEET
RACHEL, with respect to the comments made by the defendant I can only state and aceverar according to
the reports and banking supports, in this case issued by Banco BANCOLOMBIA, entity from which I made
the money transfer to the account indicated by Ruggeri, as it appears on all the receipts contributed by the
undersigned the money was sent on October 22, 2014.
TO POINT 3.6 .: IT IS CERTAIN that Mrs. LUCIA RUGGERI sent signed documents where she recorded
the promise of sale and property documents of the cat PURRINLOT SWEET RACHEL, these documents
were required by the bank BANCOLOMBIA and if they were filed in said entity bank, which can be
corroborated, in this document it can be corroborated that the total price for the sale of PURRINLOT
SWEET RACHEL, was Two thousand five hundred (USD 2,500) that is to say including all paperwork and
shipping costs. As can be confirmed in the document in the document called "certification (promise of
purchase-sale)" dated October 22, 2014, with official logos of MOONCHARM and the CFA, the document
is signed by Lucia Ruggeri and sent from Mrs. Ruggeri's personal email, note that in the text of the second
paragraph of said document it says: (...) in full compliance with the above, I promise to sell the copy in
reference to Mr. ANDRES FELIPE NIÑO SOLANO for a total value of USD 2,500 (price of the cat -
shipping costs), which will be sent before October 31, 2014 by plane ... (...), note that the negotiation with
Lucia Ruggeri where she signs the document that was sent by the same Plaintiff, says that the total price of
PURRINLOT SWEET RACHEL was for a total value of USD 2,500, including shipping costs, and this is
consistent because you can not sell an adult cat at the same price as a puppy, in addition to We are not
talking at the time of the facts of cats with any title or recognition of quality show or exhibition type, if not
simply copies of quality BREEDER, notice that in this document she certifies that the cat PURRINLOT
SWEET RACHEL, would be sent before the October 31, 2014, which was evidently not fulfilled because
neither the cat that was initially bought was sent, nor was it sent within the term that she herself defined as
can be evidenced in said document.
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As the plaintiff herself says in her text and states her text on the letters that were sent to the
BANCOLOMBIA bank, they were appropriate according to RUGERRI.
TO POINT 3.7 .: IT IS CERTAIN Lucia Ruggeri confirmed the receipt of the money sent by the applicant
subscriber, as can be confirmed once signed the documents on the promise of sale signed with the
signature of LUCIA RUGGERI, the money was turned into the bank account provided by the applicant,
however, the following points must be made: 1-) the money was drawn once she finished sending me the
promise of sale so that they were received by the bank in Colombia, 2) as soon as these documents I was
supplied by the defendant proceeded to make the transfer, as you can understand could not send money
before, until I was sure through the document that LUCIA RUGGERI would send the cat PURRINLOT
SWEET RACHEL, which was purchased, 3) with Regarding the money sent the procedure was as follows:
the official currency in Colombia is the peso, and to be able to send the two thousand five hundred dollars
(USD 2,500), it is necessary to Buy each of the dollars according to the exchange rate for the time of the
events, why they came to the account of RUGGERI USD 2,400 and not USD 2,500, according to what the
bank agent told me, due to a tax discount issue or the charge for the commercial transaction, this is why
they came only USD 2,400 and not USD 2,500.
AT POINT 3.8: IT IS NOT CERTAIN that one hundred dollars (USD 100) were missing, it is also true that
another five hundred dollars (USD 500) were missing for the issue of logistics and shipping costs, as
explained in previous points. USD 100, due to a banking issue (representative market rate) and even tax
and collection for the transaction, as the same LUCIA RUGGERI in paragraph 3.6 of his written defense
manifests, the documents sent to the bank BANCOLOMBIA were reviewed and signed by her to full
compliance, and in this document you can corroborate what was negotiated by the undersigned: (...) in full
compliance with the above, I promise to sell the copy in reference to Mr. ANDRES FELIPE NIÑO SOLANO
for a total value of USD 2,500 (price of the cat - shipping costs), which will be sent before October 31, 2014
by plane ... (...), that is to say that with the USD 2,500 was included the issue of logistics and shipment of
the gat SWEET RACHAEL to Colombia, it is not true, it is totally false, that I as a buyer has requested as a
new shipment date the month of December 2014, that is not true, the missing issue of USD 100, was a
subject that we discussed and reached an agreement with RUGGERI, where it was concluded that it was a
subject that the bank discounted by subject of taxes, that is to say that the subscriber should have sent
USD 2,600 and not USD 2,500, in order for the money to come full to RUGGERI, however the situation
was going to be corrected the day of the arrival of the cat to Colombia, that value which should be assumed
by the undersigned which she would be responsible for at the time of the events.
TO POINT 3.10 .: IT IS NOT CERTAIN that the undersigned applicant has requested a change of mind on
the pleasure of first obtaining SWETT RACHEL, as will prove with the flat file downloaded from Messenger
of the social network Facebook, held with LUCIA RUGGERI, the cat It was not sent to Colombia by
decision and information from RUGGERI, who stated that RACHEL was ill with pyometra and that she
could no longer travel, so the undersigned had to select another adult cat of which there had been talk of a
mere interest, however as it can be corroborated the cat that was bought was PURRINLOT RACHEL and
not JELLY BELLY, Jelly was accepted after the refusal of RUGGERI to send to SWEET RACHEL,
according to her she informed me and as it can be corroborated the cat was ill.
Curious is that LUCIA RUGGERI cleverly uses fragments of conversations that I do not know have been
written by me, because it does not send the support of hyperlinks where it can be corroborated that the
original text comes from my authorship.
TO POINT 3.11 .: IT IS CONTRADICTORY as in previous points Mrs. Lucia Ruggeri, falsely states that I
request that RACHEL be sent in the month of December 2014, but in item 3) of numeral 3.11 claim to
inform me that on 20 December 2014, VENEPET closed operations for Christmas holidays. It is
contradictory that Mrs. RUGGERI affirm that I knew or was of my acceptance that the cats were sent once
they recovered their weight, if this is so because I accept the sending of money ?, this question arises, we
talk about ethics one and again but it is not proven that ethics were acted, because LUCIA RUGGERI did
not return the money if it was impossible for her to respond with the promise of purchase initially signed
and sent by her, this had already been filed before the bank, and the documents with the promise of
purchase and sale claimed the defendant to send the cat before October 30, 2014. Each and every
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These narratives are contradictory and lack proof and truthfulness and aims to invalidate them and make
me look like the culprit.
It is laughable to see how systematically LUCIA RUGGERI wants to make me see how the culprit,
according to the defendant I plan a whole plan against him, send USD 2,500 or USD 2,400 for the sole
purpose of harming and hurting him, that is, the intention was not to acquire My part is a cat in reproductive
qualities and really healthy, on the contrary, the defendant wants to show that he wants to confuse her, or
that he tries to trick her into damaging her in his good name, which is absurd, and one can say a lot but the
evidence is proof , the only certain thing is what is written in the document CERTIFICATION - PROMISE
OF PURCHASE signed by Ruggeri, all the text is in Spanish.
It is not true that I have agreed to continue negotiations for the following year (2015), as I mentioned earlier
there was already a document that contained what had been agreed and negotiated, they are documents
with the signature of the defendant, the truth is that the refusal of the return of the money that I had turned
in the month of October of 2014, I had to accept forced to pass the months of November and December of
2014, to see how everything was solved according to me in the month of January of 2015
TO ITEM 3.12 .: See how Mrs. LUCIA RUGGERI manifests and accepts that JELLY BELLY was in
recovery, see how she ACCEPTED and affirms that she informed me that now PARTIWAI JELLY BELLY
could not travel immediately, in item 1 of this text (3.12) , she accepts without mentioning what was the
supposed recovery of JELLY BELLY, that is to say that it can be concluded that the cat if she had episodes
of unfavorable health, although it is true that the females after a delivery may be somewhat weak due to the
issue of childbirth Wear is not so bad, nor does it take months and months to recover. With regard to what
is stated in point 2) of paragraph 3.12, Ruggeri states that the replacement of a new copy would annul the
previous negotiation, it is important to mention that the negotiation and the agreement was always
unilaterally annulled by RUGGERI, because as manifesto was she who failed to fulfill the promise of
purchase and sale document that I had in my possession and had been settled in the bank, she signs in
item 3.) that the money already transferred would be kept as the payment of the new copy (cat) and only to
cover some expenses, it is absurd in the promise of purchase and sale document is signed by the
defendant, she affirmed that the total value of the cat with all the paperwork plus shipping was for a value
of USD 2,500, if we consider that they really entered the bank account of RUGGERI a figure that amounts
to USD 2,400, it is understood that everything was payment, shipping, shipping logistics, exams, permits
etc. Then it is false that Mrs. Ruggeri says that not all expenses were paid, absurd from every point of view.
It is important to clarify that not obviously, given all the denials and inconsistencies affirmed by RUGGERI
at the time of the events, it was not going to send a single dollar, it was neither prudent nor wise to send
money to so many anomalies reported by the plaintiff at the time, Anyone in my place would have done the
same, first I would demand that he fulfill what was promised, and then the payment of the surplus or
missing, that if we analyzed were not representative figures, as the plaintiff alleges, they were only one
hundred dollars, compared to two thousand four hundred dollars sent, I can not be blamed again, since it
was a purely banking issue, the discounts and other charges made by banks, a situation beyond my
control.
TO ITEM 3.13 .: IT IS NOT CERTAIN that Mrs. RUGGERI has informed that the price of the cat that would
replace the initially negotiated one is to say PURRINLOT SWEET RACHEL, was minor, at the end always
the money rotated was in the power of RUGGERI that is to say the USD 2,400, and she used that money,
benefited, and served as she wanted, despite the fact that on several occasions she requested the refund
or the total refund of this to my power, she was so discouraged and did not want to continue with any kind
of negotiation of RUGGERI, you will understand that at this point in history I was at will of what Mrs.
RUGGERI wanted to do and propose, she had no more possibilities than to accept practically obliged
everything that she wanted to determine, even if she did not fulfill what was promised before the bank and
my person.
About the distribution and use of the money that I send (USD 2,400), I do not know the figures or the
values described in this point by the defendant, we must analyze the economic context of Venezuela,
where RUGGERI lives , entiandase and if the Bolivar is investigated the official currency of Venezuela is
strongly devalued, VENEPET as a Venozolana company works with official currency inside Venezuela, it is
obvious that a currency like the Dollar or the Colombian Peso against the Bolivar currency is very superior
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and her transaction quadruples the money sent by the undersigned, however RUGGERI states that she
canceled all the shipping logistics procedures in dollars when in Venezuela it is used the Bolivar.
With regard to the return of the money made by Mr. Fernando Moreno, I do not know how I said, with Mr.
MORENO owner of the D SONNANS CATTERY hatchery, I have not had any commercial link, if
RUGGERI asked him to please me. send money is not my knowledge, until now I find out about this, never
entered such a dollar or peso to my personal account BANCOLOMBIA, savings account, as can be
confirmed with the bank.
It is important to state that until now I have not been allowed to see Annex 23, 22, 21 or 20, and from there
only the annexes provided as evidence by the defendant from Annex 01 to Annex 14, as sent by Mr. John
M. Randolph, on June 25, 2018, through 04 emails: jrandolph@shermanhoward.com.
Clearly up to here I do not understand, I do not understand, the insistence of RUGGERI for trying to involve
the breeders FERNANDO MORENO & JUAN CARLOS ROJAS MUÑOZ (DJUANCE CATS now ZOHO
CATTERY), in this case, situation that I have expressed are totally alien and not they care, it only matters
to the plaintiff and the defendant.
TO POINT 3.14 .: Mrs. LUCIA RUGGERI at this point ACCEPTS and CONFIRMS, that Jelly Belly if she
had health problems, that if she was impaired in her health, at this point and in others she subtly ACCEPT
that cat that I was I was sent to Colombia, had been for months and months in recovery of weight and who
knows what other things, the truth was only known LUCIA RUGGERI, calls my attention or causes curiosity
that if it is stated that she is a person with ethics and professionalism, because it takes so long the recovery
of the cat JELLY BELLY, is absurd and any breeder with or without experience can understand, that no
childbirth can leave so weakened a cat so that its recovery takes months, unless it is have performed a
cesarean or some surgical procedure where the animal has been so weak with the risk of losing their lives,
at this point I love to see how RUGGERI accepts and recognizes for the first time the health episodes of
favorable, then allows us to deduce that Mrs. RUGGERI if she acted without ethics, to send a cat in a clear
deterioration state of health, confirms then the theory that in fact she should abstain from sending a cat so
adult, and with unfavorable health episodes , confirms the theory that the cat JELLY BELLY should have
been castrated after that recovery of health and weight as stated in this point RUGGERI, the photographs
sent by RUGGERI show that the cat if she was sick, it does not look like the photograph in the website of
MOONCHARM CATTERY.
TO POINT 3.15 .: Every breeder knows that there is a process of recovery of the females after a normal
delivery and without any complications, obviously when precautionary measures are taken, that is, during
pregnancy, the pregnant mother should be well fed, so that the puppies do not wear it physically, IT IS NOT
TRUE that after childbirth a cat takes almost a year to recover, if JELLY BELLY had unfavorable health
episodes like the same Mrs. RUGGERI at this point and in the previous manifests, the money for the
payment of it should have been in effect returned in full, I did not care if the transaction deducted 50 or 100
dollars, I did not lose all my money, but despite request this and again RUGGERI he did not want to accept
and everything had to be done according to his criteria and imposition.
TO ITEM 3.16 .: Look how again and again Mrs. LUCIA RUGGERI especially in this item accepts
numerous medical check-ups from January to May, that is almost a semester, the first of 2015, I was never
sent or delivered a document where will verify the actual health status of JELLY BELLY, if on May 06
ended the recovery process of JELLY BELLY because it was sent until June 16, 2015, ie more than a
month, if it is true that RUGGERI failed to comply with the agreed by not paying for it and assuming the
cost of shipping, which was imposed on me, violating again and again what was agreed between the
parties.
TO ITEM 3.17 .: IT IS NOT CERTAIN that the undersigned did not have the money to pay for the flight and
sent JELLY BELLY from Caracas to Bogotá, see how the defendant again and again wants to ignore their
responsibility and breach, remember that in the promise of purchase and sale consists in the document that
the shipping costs plus the costs of the copy were included in the order that you made to the defendant, the
USD 2400 is more than enough money to cover each and every one of the expenses resulting from the
sale, however as I have manifested I had to accept all the impositions manifested by RUGGERI in order to
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finalize the buying and selling process, according to me everything ended with the sending of the cat and
the arrival without any novelty of the cat JELLY BELLY.
TO POINT 3.18: IT IS CERTAIN just as Mrs. RUGGERI was sent to me a contract totally unfair and
injurious to my personal interests, where I practically protected and benefited the SELLING party, LUCIA
RUGGERI, and totally ignored the PURCHASER's rights. Mr. ANDRES FELIPE NIÑO SOLANO, notice
how he states that I reject any type of agreement to the clauses of the contract, it is important to state the
following, no one can accept that a contract be imposed on the following clauses when:
a-) Clause 2º. He says: (...) ... I agree to notify the farm via email to give him the first option to buy the cat
at half the original price agreed here (...) ------ note that in this clause I have to leaving half the agreed price
according to RUGGERI in USD 1975, it is unfair and totally absurd to accept something like that.
b-) Clause 4ª. It says: (...) ... if my trusted veterinarian finds this cat in unfavorable health conditions, I
understand that I can immediately notify the cattery, return the cat under my expenses and receive a full
refund of the price agreed here, I understand that there will be NO REFUNDS after the lapse of 72 hours
mentioned (...) ------------- notice that in case JELLY BELLY had been in an unfavorable state of health I
would have had to send the cat under my personal expenses in money, is unfair since if the cat within 72
hours had shown unfavorable clinical signs, would have had to incur another additional cat to make the
return, it is absurd to accept that after 72 hours no refunds were accepted, as we all know the clinical signs
of congenital diseases have a time to manifest themselves, hidden or not-obvious defects can occur, and
that with a simple inspection or medical check-up they would not have been detected. Once again,
RUGGERI cleverly tries to escape from any kind of responsibility, so as not to have to answer for his
actions.
c-) Clause 5ª. It says: (...) any legal dispute will be resolved exclusively under the arbitration conducted by
the arbitration center of the Caracas Chamber under its rules and procedures of commercial arbitration. (...)
-------- this point is the most absurd of all, you can not force a person to accept the rules and procedures of
arbitration in a city which is not a citizen, and can not legally be access to that jurisdiction, once again
RUGGERI fraudulently wanted to impose an aggressive contract and totally contrary to the interests of the
plaintiff, for which I reiterate this was not accepted.
Clearly this contract that RUGGERI intends to make as valid was not accepted or signed by the
undersigned, the fingerprint that appears is totally illegible, this was not the contract that I sign and accept,
it is more the contract that I accept, the same sued it in his personal Facebook account, and we all could
see it, then I deleted it and put another contract.
TO POINT 3.19 .: FIJENSE as in this numeral or item, RUGGERI affirms: (....), And by law, Venezuela is
subject to an exchange control mechanism, and the use of foreign currency to buy goods and services is
strictly prohibited. . (...) Which is contradictory to the assertion in point No. 3.13, where I affirm that for the
subject of review and payments to Venezuelan company VENEPET, Mrs. RUGGERI used dollars, but in
number 3.19 she states that they can not perform commercial transactions with foreign currencies.
LUCIA RUGGERI is a liar and in this item everything said is false, in Colombia, or from Colombia you can
not buy plane tickets for ANIMALS, the one in charge of confirming he sent was the VENEPET company,
as the same defendant over and over again. He stated, and also as I previously proved, it can be
corroborated in the office of my authorship dated November 14, 2017, ANNEX 5 copy of the payment
receipt for a total value of USD 332.83 and email of VENEPET OPERACIONES:
operacionesvenepet@gmail.com Date June 15, 2015, where I was notified for the first time, that JELLY
BELLY would arrive on Tuesday, June 16, 2015 on flight # CM627 of the airline COPA AIRLINES.
IT IS NOT CERTAIN that Jelly Belly had to wait until June 17, 2015, because the undersigned plaintiff had
no money, there were two situations, one was the issue of nationalization and payment of taxes before the
DIAN Colombian Customs authority, and the ICA zoological-sanitary authority Colombia, these procedures
took almost all of the day June 16, 2015, otherwise I was not informed of the total value to be paid for the
cost established by the airline COPA AIRLINES, a situation that was resolved by the undersigned, and only
until the day After having complied with all the procedures, Jelly Belly was delivered on June 17, 2015.
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TO POINT 4.1 .: IT IS NOT CERTAIN that I do not follow the recommendations that as a breeder LUCIA
RUGGERI gave me, it is FALSE, she affirms that the cat came into a state of deteriorated health according
to her because she always feeds her with fish, or dog food, or food for birds, it is absurd and as I have
stated do not attach the actual evidence where you can corroborate this, it is false that it does not feed well,
it is false that JELLY does not care, it is false that I subjected her to mistreatment, it is false that leave your
luck, until the last day fight to have it well, we always provide you with good food, JELLY always lived in a
family environment with lots of love, in adequate and comfortable locative facilities, I think I have sent
photos of this to the committee of Protest.
It is absurd, I repeat, for a person to invest USD 2,400 to buy an animal for the sole purpose of hurting it,
making it suffer, and then letting it die, it is absurd as LUCIA RUGGERI intends to take responsibility for the
irresponsibility and lack of ethics on their part when selling a cat so adult, that is to say at an advanced age,
with multiple births, and cesarean procedures.
TO THE POINTS 4.2. - 4.3 .: IT IS TRUE, the money sent to Mrs. LUCIA RUGGERI was in dollars and not
in euros.
With regard to the description of the distribution of the money, I am not aware of it and as she stated
previously, she describes that the distribution of the money was in dollars, USD 25 for the guacal or kennel,
USD 220 for the services of VENEPET, and USD 1925 for the value of the cat JELLY BELLY, I repeat I do
not know. Now curious is that the plaintiff subscriber paid for the value of sending and processing with
COPA AIRLINES more than USD300, and she affirms that she paid VENEPET USD 220; that is, the cost
of sending JELLY BELLY almost USD 600 is super expensive.
Now if she at this point reaffirms that she paid USD 220 to the VENEPET company for the cat to be sent to
Bogotá, because she contradictoryly states that the cat JELLY BELLY did not send in May 2015 because
the plaintiff allegedly did not I had money and supposedly had to pay a ticket for an animal, if they see and
analyze the constant contradictions and inconsistencies written by RUGGERI.
TO THE POINTS 4.4. And 4.5 .: ACCORDING to lucia Ruggeri the payment was verified by her until
October 23, 2014, I do not know, I know the report issued by my bank BANCOLOMBIA dated October 22,
2014, affirm that the other communications such as medical reports sent by email and Facebook to LUCIA
RUGGERI personal access information accounts are invalid is absurd, you can not cut a person to
communicate in one way or another when, in the contract of sale and previous documents she enables all
your personal information so that it can be contacted.
TO POINT 5.1 .: RUGGERI is certain of this item, precisely for this reason because of his career at the time
was that I decided to trust my money and buy one of the copies that she offered me, unlike the defendant, I
have never affirmed that her career as a breeder has not obtained achievements and great awards. I have
never underestimated that other breeders have run with the luck that the acquired cats have obtained
important titles, and that they are currently in breeding programs in force, however that was not my story, I
did not run with the same luck, and each case is particular and concrete, and it can not be asserted that the
achievements made in the past can not make mistakes, and that is precisely where LUCIA RUGGERI is
wrong, by not accepting that if he made a mistake and that in my case he acted improperly, his arrogance
and haughtiness does not let her see and during these 3 years they have not allowed her to correct the
error, to repair the demanding subscriber to take care of their claims and therefore to demonstrate that I am
working correctly.
IT IS TRUE that the undersigned applicant is a humble breeder of Persian cats, I have never dreamed of
glory and have international renown, it is not my intention to be famous, if I become so only God knows that
with humility I will receive any congratulations or achievement or title of part of my cats, this makes
RUGGERI more responsible since she had in fact to advise the applicant subscriber well, for the amount of
USD 2,400 currently in the United States there are wonderful cats with great show or exhibition potential, it
was incorrect on behalf of RUGGERI sell for a breeding plan a cat with to an unfavorable clinical history
and with evident health burnout as she herself affirmed in previous points.
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Unlike LUCIA RUGGERI, if you read carefully each point as you write, as it is expressed even arrogantly
before the governing body of the CFA as is the board of directors, you can see the kind of person it is, if
very successful but it is a high-handed woman, that although it is true nowadays the economy of Venezuela
is in decline, when she receives in bank accounts abroad the payments in dollars or euros it can be
corroborated that the change of the currency from dollars to bolivars is a lot of money, it could be said that
she can lead a totally peaceful life because as she says in Venezuela she has no competition from other
breeders of the Persian race, then the market is practically monopolized by her.
TO POINT 5.2 .: IT IS NOT TRUE that LUCIA RUGGERI has acted according to the rules, I always look for
the benefit of the situation, IT IS NOT CERTAIN that Jelly Belly has enjoyed a perfect state of health, now
we come to know that she was in the process of recovery because according to the plaintiff the cat JELLY
was lactating, if it had been correct and with ethics as she states that she acted, she had to make the full
refund of the money for not meeting twice with the cats that were selected, I am accused of inexperience or
ignorance in front of the breeding of Persians ignoring that I am a cat breeder since 2012, also that I have
always loved animals and I admire the creation of God, I respect life and I am aware of my obligations as a
breeder and protector of animals, many times I have saved animals from the street, with my wife we have
donated to animal shelter centers, and support is enough to adopt the abandoned animals.
I am a Industrial Engineer, currently I am 28 years old, and I want to say that I have never profited from the
sale of Persian cats, I have always sought to acquire beautiful and healthy specimens, because I love
raising one day will have the opportunity when I get the American visa to participate in feline exhibitions of
the CFA or TICA, I believe that nobody is born great, everything is achieved with efforts and sacrifices, a lot
of discipline and perseverance, and above all a blind faith in God, Jesus is the one who gives us all things
to he be glory and honor forever and ever.
TO POINT 5.3 .: With regard to the questioning of the few Persian cats that I have acquired in these 06
years of breeding of the Persian race, I must state the following; unlike Lucia Ruggeri who reports on her
page more than 10 breeding females and as many males as reproducers, it is known by all that the lady of
MOON CHARM CATTERY reproduces many Persian cats and sells at large scales ie many offspring of
Persians per year , I can not say that she profited and lives at the expense of reproducing indiscriminately
Persian females and males, however you as an entity for control and genealogical registry will know more
or less on average how many property transfers and litter records RUGGERI performs during one year.
Now I am accused of financial difficulties to support my hatchery, precisely because I know what my
economic capabilities are that I have a small number of cats in my kennel, I repeat I'm not interested in
having lots of Persian cats to reproduce and profit from it, as if Mrs. LUCIA RUGGERI does, currently my
cattery is made up of three cats: a Persian male named KIARA MERLIN, two females: FELINEGOLD
ORIANA and GATAIAN CATS NATASHA, obviously the death and all the loss of money and time of PARTI
WAI JELLY BELLY delayed the advance of my farm a lot I have been affected in all ways psychologically,
socially, and now economically, because it is enough money which I invested in JELLY BELLY only to get
problems now with Mrs. LUCIA RUGGERI.
Recently in the city of Villavicencio Meta, we attended for the first time a feline show of Persian cats in the
month of September 2017: VIVAN LOS GATOS organized by the TICA Club "STAR OLYMPUS CAT
CLUB", I will send some pictures of my participation as an exhibitor , there we are taking the first steps very
satisfied of my baby kittens, which I love with all my soul. I repeat, I do not think we're unsuccessful as
Holyspirit Cattery breeders: because that's what Cattery is now called before the CFA, it was founded in
honor of the Holy Spirit of God. It is clear that by sending a cat without reproductive capabilities and
especially when it had unfavorable health episodes, LUCIA RUGGERI is directly responsible for the delay
and progress of the breeding site.
TO POINT 5.4.: I defended myself from the attacks and false accusations by LUCIA RUGGERI, it was she
who started a campaign of defamation against me and my wife. MOON CHARM you have used the social
networks to tell the story of JELLY BELLY according to its version and way of seeing, I the only thing I have
done is also tell my story and how things went, and since it was made public that is public opinion and the
society that judges who acted incorrectly, obviously while recognizing the authority of the Board of
Directors of the CFA and its wise decisions.
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TO POINT 5.4.1 .: I am very struck by how Mrs. RUGGERI intends to interfere in this matter and conflict
Mr. JUAN CARLOS ROJAS MUÑOZ, owner of ZOHO CATTERY (formerly Djuance Cats), this character
Mr. ROJAS MUÑOZ, as nefarious and unscrupulous as RUGGERI, they have made a whole plan to agree
and lie, get alleged evidence to support LUCIA RUGGERI, as far as I know and as can be confirmed in the
genealogical register, Mr. ROJAS MUÑOZ bought MOONCHARM VERONICA casually daughter of the cat
Parti Wai JELLY BELLY if I ever talk to Mr. JUAN CARLOS ROJAS MUÑOZ that does not matter,
obviously I already listen to some of the audios that were provided to me by Mr. Jhon M. Randolph, and I
do not find any relationship between the audios and the case in particular, who can assure that it is my
voice ?, and also if that was who gave legal authorization to Mr. ROJAS MUÑOZ to reveal some private
audios ?, Where is the legal document where the undersigned applicant authorizes him to use my voice as
evidence in this matter, it would be worthwhile to analyze the legal measures against Mr. ROJAS MUÑOZ
for his incorrect proceeding, I ask the Board to dismiss the audios since they are shown in a sequence,
they are only extracted astutely to affirm that I supposedly offered the cat, curiously it is observed at this
point that Mrs. RUGGERI affirms that Mr. JUAN ROJAS MUÑOZ was going to treat her, that is, I do not
understand such incongruity. Mr. ROJAS MUÑOZ was going to be in charge of a fertility treatment ?.
As far as I understand, LUCIA RUGGERI has promised in exchange for delivering a copy of the deceased
VERONICA, if she receives help in this case, we will see it in the coming days if the ruling goes in favor of
RUGGERI very happy with a new MOON CHARM, in exchange for the help given to testify against me.
Now the audios have no relationship or reports a flat file where you can corroborate the sequence of a
supposed conversation held between Messrs. ROJAS MUÑOZ and NIÑO SOLANO, now I reiterate I have
not given legal and formal authorization for Mr. JUAN CARLOS ROJAS MUÑOZ discloses, publishes, or
distributes audios with my voice, this is illegal in Colombia, and can not be established or accepted as
evidence, in addition to the above because nothing has to do with Mr. ROJAS MUÑOS between the case
of LUCIA RUGGERI and ANDRES FELIPE NIÑO, as the plaintiff herself allegedly claims the audios
provided are a private conversation apparently between ROJAS and SOLANO CHILD.
In any way I am not afraid of what the audios where my voice is presumed, and were selected by Mr.
ROJAS MUÑOZ to make them stand as evidence against me, were sent to Mrs. RUGGERI to be
presented as evidence before the BOARD OF DIRECTORS OF THE CFA.
If the audios are analyzed carefully, according to the test presented by LUCIA RUGGERI, I repeat without
authorization of the subscriber, it is a conversation, it is understood that a conversation is between two or
more people, I repeat it is an invalid test because the audios are not attached of Mr. ROJAS MUÑOZ
where supposedly he answers me supposedly to my improper propositions, I repeat there is no sequence
and can not corroborate which topic or what was being discussed, the audios apparently were extracted
strategically to make it appear that I made some affirmations about the health status of Jelly Belly.
Now if in the case that the undersigned applicant had come to the aid of another breeder to try to practice
some kind of remedy, or treatment to save the life of Jelly Belly, I see nothing strange or incorrect in the
matter, obviously who invests in a medical treatment will incur expenses and therefore expect to receive
something in return, anyway Mrs. RUGGERI intends to see as guilty of everything to the undersigned and
obviously Valera of whatever is not to respond for their wrongful acts.
I reiterate I respectfully request the Board of Directors to dismiss and prevent Mr. ROJAS MUÑOZ from
being involved in this matter, which only matters to RUGERRI and Mr. NIÑO SOLANO.
On the contrary, it would be pertinent for the CFA to inform Mr. JUAN CARLOS ROJAS MUÑOZ that if he
feels injured or violated in his rights as breeder, for any wrongdoing committed by the subscribing plaintiff,
he goes to the protest committee and formally denounces me , this is due process, that each one go and
do what is his responsibility and stop using the case of another breeder as is the case that concerns us to
present alleged evidence and defame, otherwise if Mr. ROJAS MUÑOZ does not present formal complaint
against me in the coming months, is simply an intruder who wants to take advantage of this situation as it is
my knowledge.
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TO THE POINT 5.4.2 .: IT IS NOT TRUE, It lacks veracity since the report of the pathology laboratory of
the National University of Colombia is dated on 01.03.2017 and the Euthanasia report is dated on April 24,
2017, there is more than a month apart and obviously medical treatment, at which time I had time to offer
as Jelly Belly, and if so, it would have been very commendable and noble on behalf of Mr. ROJAS MUÑOZ
to take experimental treatments to heal and try to save the life of JELLY BELLY, but if this was not the
case, all the medical treatments were taken by the applicant subscriber, I never received money loans from
Mr. ROJAS MUÑOZ, I would like to know what is the interest of that man so disastrous in your matter, if
you analyze Mr. ROJAS MUÑOZ insists and persists in being part of this process, having nothing to do with
the matter.
Interestingly, as mentioned by the cat MOON CHARM VERONICA, owned by JUAN CARLOS ROJAS, a
cat who was the daughter of JELLY BELLY, she was also euthanized for a similar clinical picture in her
mouth, like the one presented by her mother JELLY BELLY, you CFA corroborate that Mr. JUAN CARLOS
has not registered litters of that cat and I do not know if she has already reported that she was discharged
from the pedigree.
With regard to the similarity of date in the month of April on the filing of the complaint for the first time
before the CFA of the JELLY BELLY case, I am curious as the plaintiff claims in this item to have known
the notification and content of the claim. which was sent by Mrs. MELISA WATSON, and the defendant did
not answer, then the Protest Committee sent it a second time as I was informed that there was a
notification error which is verified at this point is NOT true and she is say the defendant if he had
knowledge of the matter and did not want to respond delaying the process against him and making fun of
all of us.
The fact that the initial presentation of the application did not have the same calendar date in its document,
does not mean that something was improperly orchestrated or planned against RUGGERI, since I have
always acted head-on and my actions in the CFA have been notified to the defendant in due manner, due
process has been respected, and to exercise their right to defense, it is so true that on June 28, 2018, the
Board of Directors granted the right to double instance and exercise the defense for the second and last
time.
TO THE POINT 5.4.3 .: IT IS NOT CERTAIN that the contract provided by the undersigned applicant, was
adulterated, since the reported contract was uploaded and loaded by the same LUCIA RUGGERI on its
Facebook page, at the time I provided all the hyperlinks and links so that the protest committee will
corroborate the source and verify that the contract that I report was actually published by Mrs. RUGGERI,
then it is false that I adulterate and present a false contract, on the other hand as to the questioning that the
contract provided by the plaintiff does not have the signature of lucia Ruggeri and the other yes, that only
has to do with a personal decision of RUGGERI.
TO POINT 5.4.4 .: THE FIRST person to inform the public opinion about JELLY BELLY, that is to say the
one that concerns us, was the same Mrs. LUCIA RUGGERI, whether we have attacked or not mercilessly
has been in response to the same campaign of defamation initiated by RUGGERI, of which we have
defended ourselves with the truth, as well as until now it is of knowledge of the CFA.
TO THE POINT 5.4.5 .: IT IS NOT TRUE, I do not understand how I can a Colombian who lives hundreds
of kilometers from Caracas, can threaten a whole family, now if the children of LUCIA RUGGERI have
dared to post offensive comments in our against, and we have responded because this is normal,
understand that there is a conflict that has not been resolved and that we are almost approaching the 04
years since consigning the money to RUGGERI, without this being resolved.
It is totally true that LUCIA RUGGERI ceased all communication with the undersigned and never
responded to my emails or requests.
TO POINT 5.4.6 .: I have not received any notification from the CFA, where I am accused of harassment,
the only thing I have done is to insistently go and always request respectfully to the members of the CFA,
to attend to my requests and resolve my concerns.
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I have maintained communication through email, with the ladies Linda Breg and Melissa Watson, in order
to answer the requirements and help with the process established by the undersigned against Lucia
Ruggeri.
Obviously all this could have been resolved long before and without any intervention by the CFA, Chamber
of Commerce, public opinion, if Mrs. Lucia Ruggeri had accepted or proposed a conciliatory agreement by
mutual agreement, as always victimizing herself, pretending to make me see as the culprit of this whole
situation, all for wanting to try to seek justice and a solution to the conflict raised by the plaintiff, who is the
only culprit that we all have entered into this type of wear, the solution could have been solved long ago,
only just enter the social networks of MOON CHARM CATTERY - LUCIA RUGGERI, to see the large
number of baby kittens available for sale, some in an advanced state and old.
From the above, it can be corroborated that Mrs. RUGGERI has as recurrent practice to sell the specimens
of her breeding plan at an advanced age. I will mention only a few examples:
- OCALICOS JAZMIN OF STAROLYMPUS: sold for reproduction with more than 5 years of age.
- OCALICOS CATALINA OF FORTUNESCATS: Sold at a superior age of 04 years of age as can be
confirmed in the web pages of these breeders.
- OCALICOS CHEWBACA OF FORTUNES CATS: Sold also at an advanced age.
- OCALICOS READ MICHELLE OF FORTUNESCATS: sold over 4 years old.
- PURRINLOT DREAMING OF BLUE OF FORTUNESCATS: sold at a very old age.
- Among others.
Now Mrs. LUCIA RUGGERI runs and ran the risk of being intruded to sell and give up cats of such
advanced age, when any breeder with ethics only had castrated them and given them up for adoption, then
they try to make us see everyone as guilty of their irresponsible actions .
On the other hand, if the first and subsequent points to the appeal brief presented by RUGGERI are
carefully observed and analyzed, it can be analyzed that with arrogance it addresses the honorable CFA
BOARD OF DIRECTORS, affirming that said board does not have the competence to settle , neither to
solve, nor to discipline it by its bad acting, which is not true, then who lacks the respect to the members of
the CFA, only RUGGERI as I remain evidenced.
TO THE POINT 5.4.7 .: IT IS NOT TRUE, that it is intended to make a confusion between the presentation
of evidence, especially the one that is attacked and referred to in this item, about the practice of ultrasound,
as the lady says RUGGERI, according to the report on October 06, 2015, according to general veterinary
inspection apparently was well, but after the days the state of health began to deteriorate resulting in the
report issued by Dr. GERMAN LOZANO, to the veterinary treating MAGNELY ARDILA REY, the practice of
this ultrasound lies in the JELLY BELLY clinical file as it was certified by communicating or writing by the
ANIMALS CENTER veterinary unit, with respect to the tests performed in March 2017, only on March 1 of
2017 a take or organic sample in order to determine the state of the masses in the mouth that appeared in
the mouth of Jelly Belly.
The test is authentic, and I have provided all the data so that it can be corroborated, it is not true that the
applicant subscriber has submitted adulterated or manipulated evidence.
TO POINT 5.4.8 .: The ultrasound is authentic, and at the time it was sent to the veterinary center
ANIMALS CENTER they were the ones who gave me a copy of what was sent by Dr. GERMAN LOZANO,
which was provided as proof within this record beforehand.
TO THE POINT 5.5. - 5.6. - 5.7 .: REITER, DO NOT CONSIDER ME the writ of the appeal presented by
Ruggeri close to the undersigned applicant was not accompanied by the attached documents mentioned in
these points, the supports of paragraph 5.5 as mentioned in annex 35, or in section 5.6 annex 36, nor the
annexes to number 5.7, annex 37.
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II. FACTICAL FOUNDATIONS AND EVIDENCE
In careful response to the defense presented by Mrs. LUCIA RUGGERI is necessary to expand the catalog
or file of evidence that are already in the hands of the CFA, and expand the factual foundations of what has
been evidenced up to here:
FIRST: BE FIRST to state that once reviewed the media that LUCIA RUGGERI has presented as
documentary evidence provided in the complaint filed by Mrs. LUCIA RUGGERI of MOONCHARM
CATTERY, in case No. 17-034-1023; present the following anomalies, that is contrary to what Mrs.
RUGGERI said, the only person who has tried to manipulate the truth has been the defendant as I will
prove below:
1-) Analyzing the following documents: Annex 5 (Page c-17, c-18, c-19), Annex 7 (c-23, c-24), Annex 8 (c-
25, c-26) ): "The underline in red is mine"
Note: "the underline in red is mine"
I observe that the statements have obvious similarities, such as:
a-) font size and font.

b-) Form of writing,
c-) Line spacing or space between phrase and sentence,
d-) Final greeting,
e-) Position of the firm.
There is obviously a similar way of presenting these evidence provided by Mrs. RUGGERI, the question is
are these free and spontaneous testimonies signed by each of the breeding Or on the contrary are
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manipulated testimonies written by the same person in order to agree in order to lie blatantly in a series of
facts and tests that are not true and that, on the contrary, lack truthfulness and objectivity, which would
allow inferring that seeks to deceive the Committee of Protest and therefore to the BOARD OF
DIRECTORS of the CFA, the testimonies and statements must be an act of mere liberality that leads to the
manifestation of something that is true and that you record to those who testify in favor of a person,
providing evidence to said testimonies.
2-) Annex 02 (17-027R - page R-11): Mrs. Lucia Ruggeri provides an adulterated purchase agreement; by
virtue of modifying the previously defined commercial agreements through conversations through
Facebook accounts.
As evidenced below in accordance with Banco BANCOLOMBIA's support, it is noted that USD 2400 was
recorded, as evidenced by the international trade report, and cash consignment voucher No. 650547089
dated: 2014/10/22:
However, if we compare the Bank's bank reports: BANCOLOMBIA, with the purchase agreement that she
brings, we can prove that she manipulates the figure of the value that I actually pay for the cat "PARTIWAI
JELLY BELLY":
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In the figure described in the alleged contract of sale or price there is a number that describes: USD 1975,
which is false since Lucia Ruggeri was consigned a sum of USD 2400, which can be corroborated in the
Annex page R- 10, which is the description Price: 1975 USD:
As we can see again, Mrs. Lucia Ruggeri, adulterer the evidence and lies blatantly before the protest
committee, in addition to the USD 2400, again related the receipt issued by the Copa Airlines Airline:
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Where it is observed that the day of the arrival of PARTIWAI JELLY BELLY is to say on June 16, 2015 I
cancel an additional value to the one already registered in the month of October 2014 to Mrs. Lucia
Ruggeri, the new value of the shipment was: USD 332.83.
That is to say that if the two values are added the figure amounts to: USD 2,732.83: paid to Lucia Ruggeri
and the Copa Airlines Company. It can be concluded that the contract annexed as evidence to the
complaint against me is false, since it could be corroborated by you that the contract that I signed the same
Lucia Ruggeri published it at the following link: https: // www.
facebook.com/photo.php?fbid=1634865273194274&set=pcb.1634881313192670&type=3&theater, which
RUGGERI deleted from your personal account and can no longer be consulted by submitting a totally false
sales contract to you, the original contract that I signed and accepted is this:
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I still have saved the pdf and Word form, of the purchase agreement that she (RUGERRI) sent me to my
email, and I sent signed on page 01 and end of page 02, with my corrections according to what had been
negotiated .
SECOND: I allow myself to add as a test the chat downloaded from my personal Facebook, I relate the
following hyperlink; https://www.facebook.com/messages/t/100001621033039. As the defendant had
sufficient time to present the defense which is contained in his written appeal to the Board of Directors of
the CFA, as follows:
1-) See page 73 of 100: Lucia Ruggeri confesses that Jelly Belly, Luci Lu, and Rachel are thin due to poor
quality in the food supplied in Venezuela, does not accept the request for refund of money or the shipment
of the cat to Colombia:
ANSWER LUCIA RUGGERI

13/01/2015 6:28 01/13/2015 6:28
Lucia: Lucia:
Disculpa no estaba en el face Sorry it was not in the face
Fijate para el dinero tendrias que esperar xque ahora no lo twngo. Las Look for the money you would have to wait because now I do not have it.
gatas lucilu y jelly rstan muy flacas . Ya me llwgo el alimento hace dos The cats lucilu and jelly are very thin. I already got the food two days ago.
dias. Con ese van a aharrar peso rapido. Bsmis a esperar una zemana u With that they will grab fast weight. let's wait a week or a half to see if the
media para ver si ya esta lusta jwlly belly para enviarla. Mi agente llega el jelly belly is ready to send it. My agent arrives on the 15th
15 Here with the food problem we have been wrong. I finally got the 400 kg
Aqui con el problema dek alimento hemos estado nal. Por fin me llegaron of royal canine
los 400 kg de royal canine I have other white cat that is very robust and has the gene of blue eyes
Tengo otras gataa blanca que esta muy robusta y tieneel gen de ojos and disparate
azules y dispares She is strong and ready to be pregnant. That will go into heat in fled now
Esta fuerte y lista para ser prenada. Esa va a entrar en celo ensehuida
ahora
2-) See pages 75 and 76 of 100: Lucia Ruggeri confesses that the cats are of bad weight due to the poor
quality of the concentrate supplied:
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20/01/2015 10:51 01/20/2015 10:51
Lucia: Lucia:
La gata no va a estar repuesta para enviarla este mes. Ellas se vieron The cat will not be ready to send it this month. They were affected by the
afectafas x el alimento de poca calidad quw se conseguia aqui. Tienen poor quality food that was obtained here. They have few weeks with the
pocas semamas con la royal canine. Jack si esta fuerte y puede partir royal canine. Jack is strong and can leave whenever you want. Complete
cuando quieras. Completa la diferencia y te lo mando este mes the difference and I send it to you this month
Y vamos a darkw 1 mes mas a jelky belky And let's give 1 more month to jelly belly
RESPONSE FELIPE NIÑO SOLANO
20/01/2015 01/20/2015
Felipe: Felipe:
lucy como te comente por el momento no tengo mas dinero..para lucy as I comment for the moment I have no more money ... to send you
enviarte y fuera de eso el dolar suber cada dia hoy esta a $2500 pesos and out of that the dollar go up every day today is $ 2500 Colombian
colombianos....cuando compre el dolar para enviartelo para lo de Raquel pesos .... when I buy the dollar to send you for what I cost Raquel 1900
me costo 1900 osea mira la diferencia por cada dolar tengo q pagar 2500 bone looks at difference for each dollar I have to pay 2500 pesos ...
pesos... Felipe:
Felipe: the food is not inconvenient because I have royal canin and vitamins that
lo de alimentacion no es incoveniente por q yo tengo royal canin y I give to my cats ... I do not know what to do but I can not wait any longer
vitaminas q les doy a mis gatos... yo no se q hacer pero la verdad no Felipe:
puedo esperar mas I need the money or I need a cat ... already at the end of February at the
Felipe: beginning but something must happen ..
o necesito el dinero o necesito una gata... ya a finales de febrero a Felipe:
comienzos pero debe suceder algo.. I send you the money in November December January and we enter
Felipe: February 4 months ...
Te envie el dinero en noviembre diciembre enero y entramos a febrero 4
meses...
Continued page 76: Lucia makes another proposal, requests the sending of more money and confesses
that she supplied her cats with low quality concentrate and also that she did not provide them with meat:
REQUIREMENT OF LUCIA RUGGERI

20/01/2015 01/20/2015
Lucia: Lucia:
Pero de rachel te faltaron 500 del envio recuerda. Yo no voy s mandarte But from rachel you were missing 500 of the shipment remember. I'm not
gatos con problemas sino gatos fuertes. Yo como te explique no tengo el going to send cats with problems but strong cats. As I explained, I do not
dinero ahora x wl tema de la separacion e inverti todo en una inicial para have the money now because of the issue of separation and I invested
salir de aqui. Mandame lo restante que era gastos de envio y yo te everything in an initial to get out of here. Send me the rest that was
mando a jack y los 500 adicionales de jack me los das apenas puedas. shipping costs and I send you Jack and the additional 500 of Jack you
La jelly belly necesita un mes aqui para reponerse y la otra tambien. Los give me as soon as you can.
que tenia en el piso de abajo les duro mas el royal canine soko The jelly belly needs a month here to recover and the other also. Those
estuvieron 1 mes sin el. Las otras mas de 4 meses comiendo las who had on the floor below, they were hard, but the royal canine were
pirquerias de aqui y ni la carne sabes bien que no hay aqui only 1 month without him. The other more than 4 months eating the crap
here and neither the meat you know well that there is not here
RESPONSE ANDRES FELIPE NIÑO SOLANO
20/01/2015 01/20/2015
Felipe: Felipe:
no lucy....entonces yo espero un mes mas pues...lo de jack me espero not lucy .... then I wait a month more then ... what about jack I hope
tantico, no quiero quedarte mal quiero cumplirte siempre... yo espero a tantico, I do not want to stay wrong I always want to fulfill ... I wait to see if
ver si te puedo mandar mas dinero...para las otras gatas I can send you more money ... for the other cats
3-) See page 73 of 100: Lucia Ruggeri confesses that Jelly Belly, Luci Lu, and Rachel are thin because of
poor quality in the food supplied in Venezuela, they do not accept the request for refund of the money or
the shipment of the cat to Colombia:

13/01/2015 6:28 01/13/2015 6:28
Lucia: Lucia:
Disculpa no estaba en el face Sorry it was not in the face
Fijate para el dinero tendrias que esperar xque ahora no lo twngo. Las Look for the money you would have to wait because now I do not have it.
gatas lucilu y jelly rstan muy flacas . Ya me llwgo el alimento hace dos The cats lucilu and jelly are very thin. I already got the food two days ago.
dias. Con ese van a aharrar peso rapido. Bsmis a esperar una zemana u With that they will grab fast weight. let's wait a week or a half to see if the
media para ver si ya esta lusta jwlly belly para enviarla. Mi agente llega el jelly belly is ready to send it. My agent arrives on the 15th
15 Here with the food problem we have been wrong. I finally got the 400 kg
Aqui con el problema dek alimento hemos estado nal. Por fin me llegaron of royal canine
los 400 kg de royal canine I have other white cat that is very robust and has the gene of blue eyes
Tengo otras gataa blanca que esta muy robusta y tieneel gen de ojos and disparate
azules y dispares She is strong and ready to be pregnant. That will go into heat in fled now
Esta fuerte y lista para ser prenada. Esa va a entrar en celo ensehuida
ahora
4-) return request money, and application for sending the cat JELLY BELLY: (Page 77 of 100)
REQUIREMENT OF FELIPE NIÑO SOLANO:

04/02/2015 20:12 02/04/2015 20:12
Felipe: Felipe:
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Hola lucia como Hello, Lucia

Estas.. como va todo These .. how's everything going
Necesito saber para este mes cuando programaste el envio como te dije I need to know for this month when you sent the package as I told you, I
necesito por favor q envíe s la gata ya o q en su defecto me devuelvas el need you to please send the cat to me or, failing that, you will return the
dinero me informas por favor gracias money you inform me please
Este mes es perefecti estot de vacaciones del trabajo hasta el This month is the month of work holidays until the 2nd of March
02de.marzo
07/02/2015 0:14 2/7/2015 0:14
Felipe Felipe
hola lucia como estass no has dado respuesta a mi mensaje pasa algo? hello lucia how are you, have you not answered my message something
ya hoy es 6 de febrero y este mes solo tiene 28 dias....lucia si ud ve q happens? today is February 6 and this month only has 28 days .... lucia if
definitivamente no se puede le pido q por favor me devuelva todo mi you see that you definitely can not ask her to please return all my money
dinero completo ya no puedo esperar mas and I can not wait anymore
ANSWER LUCIA RUGGERI:
07/02/2015 7:15 2/7/2015 7:15
LUCIA: LUCIA:
Buenos dias. Como esras?. En primer lugar tu sabes que soy una Good morning. How are you ?. First of all you know that I am a serious
personq seria y respobsable. Puedes preguntarle a cualquier persona en and respectable person. You can ask any person in the world and I will
el mundo y no voy a quedar mal contigo ni con nadie. Twngo una not look bad with you or anyone. I have an international reputation and I
reputacion internacional y no aconstumbro no entregar los gatos. Jelly do not usually give up cats. Jelly belly is recovering and I repeat just this
belly se esta recuperando y te repito spenas eeste bien para viajar la well to travel the shipment. I think there are still several weeks left. She
envio. Pienso que aun le faltsn varias semsnas. Ella va a viajar apenas will travel as soon as she is in conditions. Cats are not things they are
se encuentre en condiciones. Los gatos no son cosas son seres vivos. living beings. I tell you that money at the moment I do not have it because
Te comente que el dinero en estos momentos no lo tengo porque estoy I am with the expenses of preparation to the other site. If you do not want
con los gastos de preparacion al otro sitio. Si bo quieres la gata pues the cat because I just have it I'll refund it. I have never stayed with other
apenas lo tenga te lo reintegro. No me he quedado nunca con dinero people's money and less will do with yours. I am an honest and
ajeno y menos li hare con el tuyo. Soy uns persona honesta y responsible person.
responsable. Sorry I did not answer you. Yesterday I got a moment to download some
Dosculpa no haberte respondido.pues ayer me meti un momento a bsjar photos and the internet has been very intermittent I could not even finish
unas fotos y el imyernet ha estado muy intermitente ni siquiera pude writing my name and etc. And in the telegon I rarely have internet
terminar dd escribir nombre y etc. Y en el telegono pocss veces tengo
internet
5-) See page 80 of 100: Money back is reques:

07/02/2015 12:44 2/7/2015 12:44
Felipe Felipe
y eso de q te operan no me digas eso imaginate....y ahora con quien voy And that's what you do not tell me that imagine ... and now who I'm going
hablar si tu entas a postoperatorio seria...mejor q me entregaras el dinero to talk to if your postoperative symptoms would be ... better that you'll
antes del viernes de tu operacion...y asi ud se recupere tranquila y yo tb give me the money before Friday of your operation ... and so you recover
aca soluciono mis cosas quiet and I tb here I solve my things
07/02/2015 2/7/2015
Lucia: Lucia:
Recuerda lo que te dije el dinero ahora no lo tengo sino desde cuando te Remember what I told you the money now I do not have it until when I
lo hubiera dado. Tranquilo no me voy a morir. El domi go noche yaxestoy gave it to you. I'm not going to die. Sunday night I am already at home
en casa y con reposo una semana en casa and resting for a week at home
6-) See pages 82 and 83: Mr. Andrés Felipe Niño demands the sending of the cat immediately, or the
return of the money:

19/03/2015 19:46 3/19/2015 7:46 PM
Felipe: Felipe:
LUCIA LA VERDAD YA ME CANSE DE SUS EVACIVAS...OTRA VEZ LUCIA THE TRUTH ALREADY TAKES ME AWAY FROM THEIR
RECIBI UNA LLAMADA DE UNA PERSONA CON LA Q UD HABLA EVACIVES ... AGAIN I RECEIVED A CALL FROM A PERSON WITH
DONDE AFIRMA Q L GATA ESTA MUERTA... UD POR Q NO ME THE ONE YOU SPEAK WHERE IT AFFIRMS Q L GATA IS DEAD ...
ENVIA FOTOS O VIDEOS AL RESPECTO...?? PORQ UD NO TIENE LA WHY DO YOU NOT SEND ME PHOTOS OR VIDEOS REGARDING ...
DELICADESA DE COMUNICARSE CONMIGO Y DE INFORMARME LA ?? PORQ YOU DO NOT HAVE THE DELICATE TO COMMUNICATE
SITUACION... WITH ME AND TO INFORM ME THE SITUATION ...
LUCIA NECESITO Q ME ENVIA LA GATA YA NO LE PUEDO DAR MAS LUCIA I NEED TO SEND ME THE GATA AND I CAN NOT GIVE YOU
ESPERA SI UD NO ME ENVIA A JELLY YO VOY A PROCEDER .... LA MORE WAITING IF YOU DO NOT SEND ME JELLY AND I WILL
GATA A ESTAS ALTURAS YA DEBE ESTAR RECUPERADO DE SU PROCEED .... YOU WILL GET IT AT THESE HEIGHTS AND YOU
PESO Y DE LO DEMAS.... Felipe: SHOULD BE RECOVERED OF YOUR WEIGHT AND OF THE DEMAS
NECESITO Q ME INFORME INMEDIATAMENTE CUANDO VA A .... Felipe :
HACER EL ENVIO O LA DEVOLUCION COMPLETA DEL DINERO...NO I NEED TO REPORT ME IMMEDIATELY WHEN YOU ARE GOING TO
ACEPTO MAS EXCUSAS NI INCOVENIENTES NI LIMITANTES...YO MAKE THE SHIPPING OR THE COMPLETE MONEY BACK ... I DO
TAMBIEN TENGO PROBLEMAS Y NECESITO LA PLATA O ESA NOT ACCEPT MORE EXCUSES OR INCIDENTARY OR LIMITING ... I
GATA....RECUERDE Q UD FIRMO UNA PROMESA DE VENTA...Y SE ALSO HAVE PROBLEMS AND I NEED SILVER OR THAT GATA ...
COMPROMETIO A ENVIARLA EN UN TIEMPO Y YA EL TIEMPO ESTA REMEMBER Q YOU SIGN A PROMISE OF SALE ... AND IT WAS
MAS Q PASADO... COMMITTED TO SEND IT IN A TIME AND IN TIME IS MORE Q LAST ...
Felipe : Felipe:
QUEDO ATENTO..... STAY TUNED.....
Felipe: Felipe:
NO SE CON QUIEN HABLA UD EN COLOMBIA PERO EL CASO ES Q I DO NOT KNOW WHO YOU SPEAK IN COLOMBIA BUT THE CASE IS
ACA A UD LA DETESTAN TODOS LOS CRIADEROS.....HASTA EL Q ACA TO YOU ALL THE CRIADEROS DETEST ... UNTIL THE BOY OF
MUCHACHO DE SWEET STAR EL DE ROB...NO HABLA BIEN DE SWEET STAR THE DE ROB ... DOES NOT SPEAK GOOD OF YOU ...
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Vigencia 26-10-2017
UD....TENGA CUIDADO EL CASO ES Q A MI SOLO ME IMPORTA MI BE CAREFUL THE CASE IS QA MY ONLY MATTERS MY MONEY OR
DINERO O LA GATA...NECESITO URGENTEMETE UNA GATA THE GATA ... I NEED URGENTEMETE AN ADULT CATTLE EVERY
ADULTA TODA VEZ Q TENGO UN MACHO Q LA ESTA ESPERANDO TIME Q I HAVE A MACHO Q THIS IS EXPECTING Felipe:
Felipe: AND THE MALE I HAVE STRESSED ... FOR Q THIS ONLY ... PLEASE
Y EL MACHO LO TENGO ESTRESADO...POR Q ESTA SOLO...POR COMMUNICATE WITH ME I DO NOT ACCEPT MORE EXCUSES ALL
FAVOR COMUNICQUESE CONMIGO NO ACEPTO MAS EXCUSAS THIS ALREADY SEEMS A LACK OF RESPECT AND CONSIDERATION
TODO ESTO YA ME PARECE UN FALTA DE RESPETO Y DE I NEED PROOFS OF THE EXISTENCE OF THE EXEMPLARY ....
CONSIDERACION NCESITO Q COMMUNICATES ME WHEN TO MAKE THE DELIVERY ...
NECESITO PRUEBAS DE LA EXISTENCIA DEL EJEMPLAR.... AND IF THERE EXISTS AGAIN THROUGH A THOUSAND TIME A
NCESITO Q ME COMUNIQUE CUANDO VA HACER EL ENVIO...Y SI LIMITANT..I EXAY THE RETURN AS SOON AS POSSIBLE OF MONEY
EXISTE NUEVAMENTE POR MILESIMA VEZ ALGUNA .... OK
LIMITANTE..EXIJO LA DEVOLUCION LO MAS PRONTO POSIBLE DEL
DINERO....OK
19/03/2015 22:33 03/19/2015 10:33 PM
Lucia: Lucia:
Mañana le escribo Tomorrow I am writing
7-) See pages 84 and 85: Lucia Ruggeri confesses that RACHEL was not sent because she had pyometra,
and that Jelly Belly was not in good health to travel, Lucia Ruggeri wanted Mr. CHILD SOLANO to send
more money than agreed:

20/03/2015 23:43 03/20/2015 23:43
Lucia: Lucia:
Sr Felip Mr Felip
Sr Felipe ahora estoy viendo los mensajes. Hoy se me olvido el telefono Mr. Felipe, I am now seeing the messages. Today I forgot the phone at
en la casa. home.
Lucia: Lucia:
Me parece una falta de respeto. Yo antes de olvidar mi teléfono le pedí I think is disrespecfull. Before I forgot my phone I asked for a place to call
un local para llamar o viber or Uber
Y le dije que mañana le llamaría. Yo no soy ninguna ladrona y no permito And I told him that tomorrow I would call him. I am not a thief and I do not
que me ofenda así. allow myself to be offended like that.
Yo hice negocio con usted y este problema lo resuelvo con usted. Ud I did business with you and this problem I solve with you. You well know
bien sabe que Rachel no se envió por que le dio Pyometra y la otra gata that Rachel was not sent because she gave Pyometra and the other cat
no estaba en condiciones físicas para cambiar hogar was not in physical condition to change home
No sé qué les habrá pasado a uds con otras personas que le han I do not know what happened to you with other people who bought you
comprado gatos. Yo no he dejado nunca de entregar un animal. Además cats. I have never stopped delivering an animal. Also, I remind you that
le recuerdo que fueron 2400 no 2500 y faltaban los 600 para completar there were 2400, not 2500, and the 600 were missing to complete
todo con el envió y ud me dijo que no los tenía. everything with the shipment and you told me that you did not have them.
Mañana le llamo x teléfono. De verdad que es una falta de respeto de ud Tomorrow I call him x phone. It really is a lack of respect for you towards
hacia mi persona me
Ud se sabe que le dije que Jack estaba en condiciones de mandárselo You know that I told him that Jack was in a position to send him
inmediatamente y no lo quiso y de hecho tenía sus fotos porque los que immediately and he did not want it and in fact he had his photos because
me lo compraron se las mandaron a quitar those who bought it sent them to remove
Yo no estoy todo el tiempo con el teléfono en la mano y el internet está I'm not always with the phone in my hand and the internet is very bad at
muy malo en casa y no he entrado x el computador sino en contadas home and I have not entered the computer but on rare occasions
oportunidades
ANSWER FELIPE NIÑO SOLANO:
22/03/2015 18:12 3/22/2015 6:12 PM
Felipe: Felipe:
mi numero local es 6613362 el numero celular viber 320 949 4052 yo my local number is 6613362 viber cell number 320 949 4052 I prefer that
prefiero q hablemos personalmente...lucia por favor.... yo tengo familia en we speak personally ... lucia please .... I have family in Caracas and more
caracas y mas o menos ya los informe de la situacion...y estan a la or less and report the situation ... and are waiting of my instructions. also
espera de mis instruccciones. ademas q mi esposa tiene la nacionalidad q my wife has the nationality venezolona for having family there tb and
venezolona por tener familia haya tb y vivir en valencia. se equivoca al live in valencia. is wrong to say that I or we are inventing things, no,
decir q yo o nostros nos estamos inventando cosas no señora yo soy un ma'am, I am a man and I do not use old and crazy gossip that is theirs ...
varon y yo no me pongo con chismes de viejas y locas eso es de ellos..... for me to send the money that you are asking me would be USD 600 true
para yo enviar el dinero q ud me esta pidiendo serian USD 600 cierto?? ?? but here in Colombia would be $ 1,580,000.oo at this time I prefer not
pero aca en colombia serian $1.580.000.oo en este momento prefiero no to send more money .... given the circumstances .... and also as I have
enviar mas dinero....dada las circunstancias.... y ademas q como le he told lucia I have 10,000 financial problems .... and at the moment is
contado lucia tengo 10.000 problemas financieros....y en estos impossible what you ask me ... I know it is something that you do not care
momentos es imposible lo q ud me pide... yo se q es algo q ud no le or feel compassion .... or want to help someone noo. but it is better that
interesa o sienta compasión....o quiera ayudar a alguien noo. pero bueno we speak again the situation by phone my local number is 6613362 viber
es mejor q nuevamente hablemos la situacion por telefono mi numero cell number 320 949 4052 look for the test of a button .... talk to Jesus the
local es 6613362 el numero celular viber 320 949 4052 mire para la owner of Robb is angry with you I do not lie. ..and the calls I have the call
prueba de un boton....hable con Jesus el dueño de Robb el esta enojado record
coin ud yo no miento...y las llamadas tengo el registro de llamada
8-) See page 100 of 100: Lucia informs that the JELLY BELLY cat would be sent at the end of May or at
the beginning of June 2015:

19/05/2015 18:47 05/19/2015 6:47 PM
Lucia: Lucia:
Hola Andres. LLamame. para cuadrar lo de Jelly. te mande el correo el Hello Andres. Giving me a call. to square Jelly's. I sent the mail the
Pág. 25 de 27
Vigencia 26-10-2017
contrato. Ya la gata la vio el veterinario y emitio el certificado de salud. El contract. The cat was already seen by the veterinarian and issued the
gestor dice que para finales de este mes o primera semana de Junio. Por health certificate. The manager says that by the end of this month or the
favor llama para cuadrar todo. O escribeme por este medio. El pasaje a first week of June. Please call to square everything. Or write me by this
Bogota lo pagas al llegar a Bogota. directaemnte a la linea aerea. means. The passage to Bogota you pay when you arrive in Bogota.
Directly to the airline.
The above texts are transcribed from the chat held with LUCIA RUGGERI, to see more information check
the attached file: chat Facebook lucia Ruggeri ANNEX 1: Conversation FACEBOOK Lucia Ruggeri. It
contains 100 pages of text in Spanish.
9-) Attached proof of another affected breeder Mr. Jesús Rafael Abadía, breeder of Persian cats of
Venezuelan nationality and owner of SWEET STAR CATTERY: where he told me at the time of the events
that Mrs. LUCIA RUGGERI borrowed 7 kilos of concentrate Royal Canon, and never returned the food,
apparently this would not make a person with ethics, here it can be corroborated as in the texts transcribed
above that Mrs. RUGGERI had serious difficulties to feed her cats with quality concentrate, which it can be
evidenced in ANNEX 2: Conversation Facebook Jesús Rafael Abadia, contains two (02) pages.
CONVERSATION BETWEEN
ANDRES FELIPE NIÑO SOLANO & JESUS RAFAEL ABADIA
Jesus: Jesus:
uy hermano no puede ser Huy brother can not be
Como no le va dar la cara q pena de verdad As it is not going to give him the face that really hurts
21/03/2015 10:57 03/21/2015 10:57
Felipe: Felipe:
My God, I do not know what's going to happen
Dios mio no se q va a pasar
she does not say anything
ella no dice nada here in Colombia they are calling me to tell me that the cat is dead
aca en colombia estan q mme llaman a decirme q la gatr esta mueryta and she does not face
y ella no da la cara
Jesus:
Jesus: Well shame but the best thing is to be clear and tell you the truth and lIsto
Bueno que pena pero lo mejor que hay es ser claro y te diga la verdad y Ready to return the silver
losto
Listo q devuelva la plata Felipe:
my wife is angry
Felipe:
mi esposa esta enojada Jesus:
Sure, and you're right, brother
Jesus: I feel sad and it's not me
Claro y estas en toda razón hermani I would help you but I really did not treat her for 2 years
A mi me da pena y no soy yo Since you lend 7kilos of royal food canin
And then the crazy one went and so I left it like that, I declined to ask him
Yo te ayudaría pero de verdad no la trato desde hace 2 años
for the favor that would return my food
Desde q le preste 7kilos de comida royal canin
Y pues igual se hacia la loca y pues lo deje así me ladille de pedirle el 3/22/2015 6:22 PM
favor q me regresara mi comida
Felipe:
22/03/2015 18:22 jesus ... a question you can do me the favor of finding out how much is
worth in bolivaress the shipment of a cat to Bogota from Caracas
Felipe: Jesus:
It's very clear they are like $ 500
jesus...una pregunta tu me puedes el hacer el favor de averiguarme
cuanto vale en bolivaress el envio de una gata a bogota desde caracas
Jesus:
Es clarísimo son como 500$
THIRD: With regard to the interference of Mr. JUAN CARLOS ROJAS MUÑOZ of ZOHO CATTERY, with
respect to the case in particular, I request the gentlemen of the honorable Board of Directors of the C.F.A.
review the complaint that was sent to the Committee of Protest of the CFA by Mr. JAIRO RODRIGUEZ
FERREIRA, Mr. ROJAS MUÑOZ owner of ZOHO CATTERY, breached the contracts signed with STAR
OLYMPUS CATTERY owned by CARLOS AUGUSTO CARDENAS AND HANER DE ARMAS LONDOÑO,
and not satisfied with this I deceive Mr. JAIRO RODRIGUEZ FERRERIA of the city of Bucaramanga -
Colombia, to whom he promised the delivery of certificates and records of (02) cats, and also sent sick cats
to which he never had to sell as a baby- reproduction by express prohibition of the contracts agreed with
STAR OLYMPUS, Mr. ROJAS MUÑOZ has taken a position similar to that of Mrs. LUCIA RUGERRI, is
reluctant to respond for their actions and deliver the corresponding compensation for damages caused to
the Mr. JAIRO RODRIGUEZ FERREIRA.
Pág. 26 de 27
Vigencia 26-10-2017
Mr. CARLOS A. CARDENAS of STAROLYMPUS CATTERY-CAT CLUB, gave me a test in the Spanish
language where he informed Mr. JAIRO RODRIGUEZ FERREIRA, as Mr. JUAN CARLOS ROJAS MUÑOZ
failed to comply with contracts and in his good faith defaced Mr. RODRIGUEZ, selling cats without
permission from STAR OLYMPUS, and also not suitable for breeding and breeding.
Attached copy in pdf as ANNEX 3: of the complaint filed by Mr. JAIRO RODRIGUEZ FERREIRA, the text in
English, who gave me a proof and authorized me to send it through the undersigned applicant, in order that
the entity , be careful about the very nefarious scope of Mr. ROJAS MUÑOZ.
III. TO THE PRTENSIONS
I respectfully request the Board of Directors of the C.F.A. deny the pretensions of Mrs. Lucia Ruggeri, and
consequently confirm the ruling dated December 13, 2017 of first instance in each and every one of its
parts.
Since it is clear that we can reach the certainty that in each and every one of the cases, as I have proved, it
was Mrs. Lucia Ruggeri, who has been unethical and has disregarded her moral and commercial
obligations with respect to the undersigned. applicant.
Even though Mrs. Lucia Ruggeri had 06 months to present a very good appeal, she had enough time to
collect evidence, she is arrogant in front of the Board of Directors, and she constantly tries to go to other
breeders to defame me and attack my good name.
IV. PROOFS AND ANNEXES
ANNEX 1: Conversation Facebook Lucia Ruggeri. 100 pages
ANNEX 2: Conversation Facebook Jesús Rafael Abadia. 02 pages
ANNEX 3: Complaint of Mr. Jairo Rodríguez Ferreira. 48 Pages
APPENDIX 4: Promise Purchase Purrinlot Sweet Rachel.
ANNEX 5: Euthanasia copy, National University exam, Animal Center Veterinary Certification.
Cordially,
,
Att,
C.C. No. 1.121.863.536 de Villavicencio

TP No. 25228-256958 CND del COPNIA
Pág. 27 de 27
Vigencia 26-10-2017

Defense 28 06 2018 English ANDRES F. NIÑO - Vs - LUCIA RUGGERI MOON CHARM CATTERY

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Andrés Felipe Niño Solano

Villavicencio - Colombia, June 26, 2018.

Subject: Appeal of Lucia Ruggeri Vs. Andres Felipe Niño Solano

TO POINTS 3.2 - 3.3: IT IS CERTAIN what narrated by Mrs. Ruggeri.

II. FACTICAL FOUNDATIONS AND EVIDENCE

Note: "the underline in red is mine"

I observe that the statements have obvious similarities, such as:

a-) font size and font.

Note: "the underline in red is mine"

Note: "the underline in red is mine"

Note: "the underline in red is mine"

Note: "the underline in red is mine"

ANSWER LUCIA RUGGERI

ANSWER LUCIA RUGGERI

REQUIREMENT OF LUCIA RUGGERI

ANSWER LUCIA RUGGERI

REQUIREMENT OF FELIPE NIÑO SOLANO:

Hola lucia como Hello, Lucia

5-) See page 80 of 100: Money back is reques:

REQUIREMENT OF FELIPE NIÑO SOLANO:

REQUIREMENT OF FELIPE NIÑO SOLANO:

ANSWER LUCIA RUGGERI

ANSWER LUCIA RUGGERI

21/03/2015 10:57 03/21/2015 10:57

III. TO THE PRTENSIONS

IV. PROOFS AND ANNEXES

ANNEX 1: Conversation Facebook Lucia Ruggeri. 100 pages

ANNEX 2: Conversation Facebook Jesús Rafael Abadia. 02 pages

ANNEX 3: Complaint of Mr. Jairo Rodríguez Ferreira. 48 Pages

APPENDIX 4: Promise Purchase Purrinlot Sweet Rachel.

C.C. No. 1.121.863.536 de Villavicencio

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