Saturday, March 23, 2013

Raanan Katz Has Elected To Make New Droppings In Copyright Case

In a recently filed Raanan Katz motion to strike affirmative defenses in copyright case, looks like Miami Heat and RK Centers owner, Raanan Katz, somehow is trying to drop his initial claim for damages associated with his alleged copyright infringement.

Here is the extraction from Katz motion: "Notably, Plaintiff (Raanan Katz) does not seek statutory damages in this action; instead it seeks injunctive relief. Therefore, Defendant's second affirmative defense should be stricken..."

 Another good point made by Raanan Katz

"As her seventh "affirmative defense," Defendant alleges that Plaintiff (Raanan Katz) has sustained no loss or damages. [ECF No. 28, p. 5 71. However, "a defense which simply points out a defect or lack of evidence in a plaintiffs case is not an affirmative defense." Morrison, 434 F. Supp. 2d at 1318. Accordingly, this "affirmative defense" should be stricken. Plaintiff (Raanan Katz) now asserts it has elected not to seek statutory damages in this case."

So far Mr. Katz has not filed any notice of withdrawing one of his claims related to the damages, but refused to provide proof of damages under statement: "Notably, Plaintiff (Raanan Katz) does not seek statutory damages in this action; instead it seeks injunctive relief."

This was
"Respectfully submitted,
KLUGER KAPLAN SILVERMAN KATZEN & LEVINE, P.L.
Co-Counsel for Raanan Katz 201 South Biscayne Blvd.,
17th Floor Miarni, Florida 33131
Telephone: 305-379-9000
Facsimile: 305- 379-3428
By: /s Todd A. Levine Alan J. Kluger Florida Bar No. 200379 Email: akluger@ klugerkaplan.com Todd A. Levine Florida Bar No. 899119 Email: tlevine@klugerkaplan.com Jorge R. Delgado Florida Bar No. 084118 Email: jdelgado@klugerkapIan.corn"

Does this Raanan Katz action continue to prove his abusive litigation strategy to enrich himself through his fabricated DAMAGE claims. Don't you need to have damages prior to filing legal actions against someone, Raanan Katz litigation practice proves not. Looks like, you do not need to have damages and cause of actions, just simply fabricate cases in attempt to make threats with monetary demands.

Raanan Katz is clearly claims " I can elect to seek damages from you or not."

He was trying to get money from me and at the same time refused to provide a single proof for it. We all know how it calls..., remember the case with single mother with a special needs Jewish little girl, Mr.Raanan Katz claimed around $250,000.00 of damages in his initial claim, at the end Mr.Katz filed satisfaction of judgement in the amount of $5.00.

How many members of the public has been or might be affected by Raanan Katz demanding and/or obtaining of something through litigation force. I am asking myself question, if I were not that strong, what amount Raanan Katz could get from me personally using his favorite DEFAULT strategy. Raanan Katz keeps harassing my family members making fake claims in state court in attempt to get money to his enrichment.  enrichment. enrichment. enrichment. enrichment.

RAANAN KATZ

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