RK Centers, Raanan Katz: Monkeys From The Space Did Not Sign Lease With Us

In light of Raanan Katz and RK Centers numerous frivolous pleadings filed with multiple courts in Miami Dade this parody comes up.

Ok ….
Raanan Katz, RK Centers v Monkeys from the Space
 

Raanan Katz and RK Centers 2,000,005,555 Amended Complaint
Facts
1.    On or around absolutely sunny, or/ and most clouded day Monkeys from the space flew to Raanan Katz office
2.    Raanan Katz did not invite Monkeys from the space, in fact, they came without Raanan Katz invitation.
3.    It was tons of Monkeys and they all speak the language Raanan Katz could not get, presumably English. Raanan Katz called for Daniel Katz, Daniel Katz called Suzanne Katz, Suzanne Katz called Cato… Monkeys actions were intentional! NO connection with the space was established. Raanan Katz and RK Centers reserved the right to seek punitive damages against Space Monkeys upon proper by Raanan Katz and only Raanan Katz motion and in accordance with RK Centers and Raanan Katz law, opps, Florida Statute 768.72.
4.    Raanan Katz and RK Centers were trying to mitigate damages and called to Kevin Belmont, who upon information and believe has Black Door company and through these doors able to get in connection with the space.
5.    Space Monkeys advised Mr. Belmont that they wanted to have Space’s Pizza at all Raanan Katz current spaces, future non-built spaces, and even premises Raanan Katz and RK Centers did not own.
6.    Space Monkeys also stated they want to sign any lease with Raanan Katz and RK Centers, including “gotcha” automatic lease renewal clause and acceleration clause with 50,000 years of acceleration on all Raanan Katz, RK Centers premises. “We pay cash in advance”, promised Monkeys.
7.    Raanan Katz was ready to jump to the moon, but the ceiling in his office was strong and prevented him from reaching it.
8.    Raanan Katz was trying to calculate profits, but his simple phone was not able to handle such big numbers.
9.    Raanan Katz and RK Centers immediately prepared the LEASE, but Monkeys approached Daniel Katz with many pages printed out from the blog. AAAAAh!!!!!
10.    Monkeys were doing some space research about Raanan Katz to see how he became a successful businessman, and Monkeys were shocked to come across the very NEGATIVE blog about Mr.Raanan Katz that was presumably distributed in galaxy space. Monkeys from the Space told Daniel Katz that they were in great fear (Daniel Katz favorite word) about what they read.
11.    Notwithstanding the fact that Monkeys from the Space loved Raanan Katz, Daniel Katz, Suzanne Katz, Cato, Kevin Belmont, the Monkeys said “NO SOUP FOR YOU” and did not sign the LEASE.
12.    That was not the first time Monkeys from the Space engaged in such misconduct. They repeatedly start coming to Raanan Katz, RK Centers properties, follow them, yes… they have been following all Raanan Katz corporations, Monkeys appeared to be within close proximity from Raanan Katz and Daniel Katz office on several occasions during last 3 seconds to harass Suzanne Katz.
13.    Raanan Katz, RK Centers had to hire an attorney, Todd Levine (305) 379-9000 tlevine@klugerkaplan.com. Todd Levine is  a "lawyer with the creativity of an artist ", who is able to make “four corners” in this complaint.

Dear Court, Raanan Katz, RK Centers, and attorney Todd Levine are in need of default judgment. Default and only Default judgment should be entered!!!

 

RK Centers, Raanan Katz: The Show Must Go On

Following Raanan Katz persistent requests to make his litigation private the Federal Court ordered and I complied by filing 267 pages of Raanan Katz deposition in public court records.

Considering we have only 365 days in a year, publishing only one page a day will take ...WOW...267 days and the same number of articles.

I have to say big thank you to Raanan Katz attorneys for such a great material that every journalist or Raanan Katz biographer could ever dream of. Well done, guys, keep up the good work!!!

For those who cannot wait for another 267 days, you can download Raanan Katz deposition directly from the Court records.

Just have you popcorn ready for the show...

Judge Orders To File Raanan Katz Unsealed Deposition Transcript

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ruled on Raanan Katz Motion for Protective Order in part related to Mr. Katz request to "seal" his deposition transcript in the CASE NO. 12-2221 I-CIV-KING/M CALILEY.

In this case Raanan Katz alleged copyright violation related to his "unflattering" picture.  Judge ordered filing of the transcript with the court records by June 12, 2013, and "under seal" request was denied. This means that new details of the case could be revealed by the end of next week. Here is the extraction from the Court order. 

"Also pending is Plaintiffs (Raanan Katz) Motion for Protective Order, in which he requests, among other things, that the Court enter a protective order requiring that his deposition transcript be filed
under seal. (DE 50, p. 102.)..

I have carefully reviewed Plaintiffs (Raanan Katz) motion for protective order and exhibits, and have considered it in light of Judge King's prior order denying the parties' joint motion for protective order. (DE 23). I find that Plaintiff (Raanan Katz) has not shown good cause for entering a protective order requiring that his transcript be filed under seal. See Fed. R. Civ.P, 26(c)(1) (good cause required for protective order); In re Alexander Grant & Co. Litig.,820 F.2d 352, 355-57 (1 1th Cir. 1987) (although the public has no First Amendment right of access to pretrial discovery materials, the parties must show good cause for a protective order); S.D. Fla. Local Rule 5.4(a) ("Unless otherwise provided by law, Court rule or Court order, proceedings in the United States District Court are public and Court Filings are matters of public record.'').

RK Centers Second Amended Complaint- Legal Extortion

After almost year and a half of initial litigation started Raanan Katz and RK centers file their motion for leave to file verified second amended complaint. This motion was granted. Here is one of many interesting parts of the requested changes. Looks like Raanan Katz just (almost two years after) remembered how many of his companies suffered alleged "damages", considering that no damages were produced by Raanan Katz prior and after filing Second Amended Complaint.

PLAINTIFFS' MOTION FOR LEAVE TO FILE VERIFIED SECOND AMENDED COMPLAINT
Plaintiffs, R.K./FL MANAGEMENT, Inc, RK. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RAANAN KATZ, DANIEL KATZ, RK HALLANDALE 1, LLC, RK HALLANDALB LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, R.K.ASSOCIATES # 2, INC., RK. ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC (collectively, "Plaintiffs"), through their undersigned counsel and pursuant to Fla. R. Civ. P. 1.190(a), hereby file this Motion for Leave to File Verified Second Amended Complaint (the "Proposed Second Amended Complaint"), and state as follows...

6.    Moreover, Plaintiffs RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, R.K.ASSOCIATES # 2, INC., R.K, ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC (the "Additional Plaintiffs") are all affiliated with the Original Plaintiffs, all Plaintiffs operate under the trade name "RK Centers" (f/k/a "RK Associates"), all are the targets of Defendants' tortuous misconduct, and the Additional Plaintiffs are the title owners of the properties upon which Defendants have trespassed (the basis of additional claims set forth in the attached proposed Second Amended Complaint). Thus, Plaintiffs seek to add the Additional Plaintiffs as parties to the Second Amended Complaint. ..."

I've heard that lollipop, because of sugar, helps brain to be active. Is that true???

RK Centers Speak Blonde In Their Pleadings

RK Centers invented new blonde allegations in their amended complaint filed with Miami State Court. Well, the problem is that American taxpayers are paying for RK Centers and Raanan Katz court games and their blond allegations.

Here is the extraction from RK Centers and Raanan Katz amended complaint.

"...64.    Consistent with their twisted history, on September 3, 2012, Defendants posted an illustration of Mrs. Katz and Daniel Katz on the Blogs. Defendants depicted Mrs. Katz saying "I am staying at a red stop sign for 6 hours... & it's not turning green ... people around are [sic] laughing... and I am getting worried... IS it [sic] SOMETHING WRONG WITH THE SIGN???" Next to this is a depiction of Daniel Katz saying "CALL 911, extension BLONDE."' See September 3, 2012 Blog, a true and correet copy of which is attached hereto as Exhibit "E." (emphasis in original)....Mrs. Katz has blonde hair...",  this was respectfully submitted by RK Centers and Raanan Katz attorney, Mr. Todd Levine.

 This is another part that was respectfully presented by Raanan Katz and RK Centers attorney Todd Levine. My advise do not laugh when attorney Todd Levine testifies about search engine something...

"Todd Levine:Do you know what -- when you do a search on Google, you'll get various results for your search, correct?...
Todd Levine:Search engine optimization is a process by which -- well, you're laughing probably because you know more about this than I do, correct?...
Todd Levine: Is that why you're laughing?...
Todd Levine: Why are you laughing?...
Todd Levine: Why are you laughing at my question when I'm trying to explain search engine optimization to you?..."

RK Centers: What Is The Reason Of Raanan Katz, RK Centers Success

"THE COURT: Yes. Are they fully occupied or are they almost fully occupied (RK Centers)?
MR. KLUGER: Judge, these are very successful centers, the Katz family, it's not only dad who came here from Israel with nothing, his children, his family is in the business. They are very successful. The cases talk about intent to injure in a business way and the fact that people read these poisonous defamatory publications, and as a result they don't want to do business.
THE COURT: Okay.
MR. KLUGER: The fact that they found five other people to do business, doesn't impact at all my ability to get an injunction.
THE COURT: Na speeches yet.
MR. KLUGER: Sorry.
THE COURT: Just down boy."

Raanan Katz: Removal Of Ugly Picture

Here is publicly available and downloadable correspondence where Raanan Katz, RK Centers and Miami Heat owner, making detailed instructions to remove his ugly picture.

RAANAN KATZ

"August 26, 2011
VIA Electronic Mail
Seffi Magriso

RE:    Removal of Ugly Picture   

Dear Seffi:

It was nice speaking to you today and I really appreciate your willingness to help me.
I currently have a problem with an ex-employee who has gotten into some illegal things. Due to his removal, he is contacting online news publications telling them complete lies about me and also sent them an old ugly picture that they found an the Internet, specifically an 'HAARETZ.COM' article.
While no one believes the nonsense written on the blog, the picture is a total insult to me and apparently it was taken by you when, I was under some kind of pressure.
In the seven years that I was involved with Maccabi, you took many pictures of me and have much better ones to be used in the future if necessary.
I am enclosing the following:
1.    Copy of the original article from Haaretz newspaper from February 22, 2011.
2.    Copy of a blog an blogspot.com which is a google company dated May 3, 2011.Please click on the attached link to access the posting
(http://rkassociatesusa.blogspot.com/2O1 1 /07/rk-associates-history-and-somefacts.html). On the top of the page it gives you the option to report copyright abuse, please do so.
3. Copy of the Broward Bulldog article posted online dated this week.
4. Complete contact information for the Broward Bulldog publisher and article author.
All of these articles have the picture with my tongue out like Michael Jordan used to do when he drove to the basket.
It would be greatly appreciated If you could do the following for me:
1.    Contact Haaretz and any other Israel publication that you may have given this picture to and ask them to eliminate it.
2.    Contact Bulldog author and publisher and demand immediate removal from website and to make sure that if they have given the picture to any third party it would be their responsibility to retrieve it immediately.
3.    Contact Google by clicking the Report Abuse link on the blog.
I am also enclosing my business card with all my company information in Boston and Miami (currently I am in my Boston office). I can also be reached on my Boston cell Redacted.
Anything you can do to eliminate this quickly would be greatly appreciated, Keep in touch!
Regards,
Raanan Katz"

Raanan Katz, RK Centers: Give Us The Order Without Service

Today I would like to cover the subject of RK Centers and Raanan Katz interpretation of law related to "Service of process"

RAANAN KATZ

Does Florida Rule of Civil procedure 1.070 "Process" actually work in Miami 11th Court? You can see how, when rich RK Centers and Miami Heat owner Raanan Katz involved in litigation. Miami 11th Court CASE NO.: 11-17842 CA (32). Plaintiffs, RK centers and Raanan Katz, do not even bother to serve numerous defendants in the case, but somehow obtained an order against these defendants violating not only Florida Rules of Civil procedure 1.070 and 1.610, but most importantly the main Law- Constitution.

In other words, these defendants were not the party of the lawsuit, when brave Raanan Katz held his winning order against them.

Here is an extraction from Plaintiffs Motion filed in Miami State Court after Plaintiffs, RK Centers and Raanan Katz, obtained the order.

"PLAINTIFFS' MOTION TO DEEM AS WAIVED THE NECESSITY OF SERVING DEFENDANT WITH ORIGINAL PROCESS

 Plaintiffs, R.K./FL MANAGEMENT, INC., R.K. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RAANAN KATZ, DANIEL KATZ, RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, R.K.ASSOCIATES # 2, INC., R.K. ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC (collectively, "Plaintiffs"), through their undersigned counsel, hereby file this Motion to Deem as Waived the Necessity of Serving Defendant 02  with Original Process...

Defendant  02 chose not to appear at the hearing. John Doe's true identity is currently unknown, so it is also unknown whether he appeared at the hearing or not..."(my comment: is attorney Todd Levine trying to say here that John Doe(s) is/are a ghost (s) who appeared at the hearing, but was/were not visible to Mr. Levine and Mr. Katz.)

"Based upon the facts set forth in the Verified Second Amended Complaint and Plaintiffs' Motion for Preliminary Injunction, immediate and irreparable injury, loss, or damage would result to Plaintiffs before Defendant 02 or John Doe could be heard in Opposition to Plaintiffs' Motion for Preliminary Injunction—especially given Defendant 02's evasion of service of process and the fact the John Doe's identity is currently unknown...

As set forth above, Plaintiffs have been diligently attempting to serve Defendant 02 with process, but they were not required to give further notice because of Defendant 02 avoidance of service, and the fact that he had actual knowledge of the allegations of the Verified Second Amended Complaint and Plaintiffs' Motion for Prelirninary Injunction and the November 1st hearing, but he chose to ignore them. Plaintiffs are unable to serve John Doe until they learn his or her true identity...

Given the foregoing, this Court should amend the Order on Plaintiffs' Motion for Preliminary Injunction to either:

Note that the Order was entered without Notice to Defendant 02 or John Doe because notice was not required given Plaintiffs' attempts to serve Defendant 02 and his apparent avoidance of service of process, the fact that John Doe's actual identity is currently unknown, the immediate and irreparable injury, loss, or damage would result to Plaintiffs before they could be heard in Opposition to Plaintiffs' Motion for Preliminary Injunction, and/or because Defendant 02 and John Doe had actual knowledge of the allegations of the Verified Second Amended Complaint and Plaintiffs' Motion for Preliminary Injunction and the November 1st hearing, but chose to ignore them..." .(my comment:I am curious, how attorney Todd Levine could make this statement, when his law firm did not serve above defendants)

This motion was  "Respectfully submitted, KLUGER, KAPLAN, SILVERMAN, KATZEN & LEVINE, P.L. Attorneys for Plaintiffs Miami Center, Seventeenth Floor 201 S. Biscayne Blvd., Suite 1700 Miami, Florida 33131
Telephone: (305) 379-9000
Facsimile: (305) 379-3428
By:
ALAN J. KLUGER Florida Bar No. 200379 TODD A. LEVINE Florida Bar No. 899119"

Interestingly enough, Plaintiffs appellate attorney, Paul Morris, submitted Confession of error with appeal court in regards to the service. As you probably know, Defendant 02 won the appeal, injunction was reversed, and attorneys fees were granted.
Would you like to be John Doe to get your fees and damages paid???

RK Centers, Raanan Katz Lost Injunction Appeal

Finally, we have court of appeal decision in 3 DCA in regards to Raanan Katz and RK Centers preliminary injunction for one of the Appellants(case 3D12-3221).

Raanan Katz and RK Centers simply LOST it!!!

Additionally, "upon consideration of the motion for attorneys fees filed by appellant, it is ordered that said motion is granted and remanded to the trial court to fix amount."

Right, it is time to FIX the amount and make Raanan Katz and all his numerous companies/ Plaintiffs  responsible for their court intimidation games in Miami state court. I will publish entire order shortly. 

Big Thank you to Appellants attorneys Kendall Coffey, Jeff Crockett, David Zack.

Attorneys who represented losers are Todd Levine, Alan Kluger of Miami based Kluger, Kaplan, Silverman, Katzen, Levine law firm and appellate attorney Paul Morris.

RAANAN KATZ

Raanan Katz, RK Centers Adding Punitive Damages To The Claim

Raanan Katz, RK Centers are moving for punitive damages! Finally, Raanan Katz and RK Centers openly disclosed the amount they want to make from 10 count complaint. Oh là là ! Only 5 million dollars!?! Quelle catastrophe! Only 5 million dollars!?!

Here is the part of the punitive damages claim recently filed with Miami Court.

"Plaintiffs, R.K./FL MANAGEMENT, INC., R.K. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RAANAN KATZ, DANIEL KATZ, RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, R.K.ASSOCIATES # 2, INC., R.K. ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC, hereby provide notice to this Court that Defendant continues to publish defamatory blogs that support Plaintiffs Motion for Leave to Amend Complaint to Add Claim for Punitive Damages (the "Motion for Punitive Damages"), and state as follows:...


"...b.    Saturday, April 20, 2013: "Raanan Katz: The Picture is Unfair, They Make Fun of Me" (the "April 20 Blog")

RAANAN KATZ AND LISPING ALAN KLUGER

Similarly, the April 20 Blog defames Plaintiffs as liars. In particular, one of the labels attached to the April 20 Blog is the word "pizdabol." According to the online Urban Dictionary, the term "pizdabol" means liar in Russian. See, Urban Dictionary, 'www.urbandictionwy.com/define.php?term=pizdabol.' Additionally, the April 20 Blog contains a threat against Plaintiff Raanan Katz personaLly: "(w)ell, no worries, Raanan, .. .the good one is coming.. and I mean not only picture..." A copy of the April 20 Blog is attached as Exhibit "B."..."

3.    The April 10 Blog and the April 20 Blog are false and defamatory per se because they accuse Plaintiffs of being liars. See Walsh v. Miami Herald Pub. Co., 80 So. 2d 669, 671 (Fla. 1955) (imputations of untruthfulness are considered actionable per se)...

See also Lawnwood Medical Center, Inc. v. Sadow, 43 So. 3d 710, 727 (Fla. 4th DCA 2010) (affirming $5 million dollar punitive damages award for defamation per se even where jury awarded no compensatory or nominal damages)."

This BS was respectfully submitted by Todd Levine (Raanan Katz and RK Centers attorney). Quel imbécile!

Raanan Katz: How To Spell, Don't Ask Me

This Raanan Katz, Miami Heat and RK Centers owner, publicly available deposition speaks for itself. Deposition of Raanan Katz was taken in his alleged copyright  case related to his "ugly picture". Enjoy!!!

RAANAN KATZ

In this part Raanan Katz admits "how much he paid" for allegedly purchased copyright work. Let's not forget that copyright means an intellectual, original works, no matter what Raanan Katz wishes...

"Raanan Katz: Okay. I -- no, again, I you know withdraw -- I offered him again a few dollars, he refuses to -refused to take it.
Attorney: You offered him a few dollars?
Raanan Katz: Yeah, only $500 to be exact, only $500 dollars. He said, "Raanan, I know that I caused you a damage, I apologize 100 times, you know. I'll send it to you -I  send it to you and I'll make sure that an act like this will ever happen again."
Attorney: Okay. Did you give him $500?
Raanan Katz: No, I said no. He refused to take it.
Attorney: Okay. Did you do that offer over the phone?
Raanan Katz: Yes.
Attorney: Did you ever email him an offer in writing?
Raanan Katz: No.
Attorney: Okay. It was only over the phone?
Raanan Katz: Only documents -- all these documents are drawn by Michael Chesal.
Attorney: All the documents are done by Michael Chesal?
Raanan Katz: You know, this only document or this only document was done -- was done by, there is no any other documents.
Attorney: It was prepared by your attorneys.
Raanan Katz: Yes.
Yeah, the guy named Johav Borowski.
Attorney: Johav Borowski?
Raanan Katz: Johav; how to spell, don't ask me.
Attorney: Okay. But he is the -- he doesn't list his name,
It just says Haaretz sports staff, on its article
Raanan Katz: Yeah, yeah.
Attorney: But that's who you believe is the author of the article?
Raanan Katz: Yes, that I believe.
Attorney: Okay. And though he and Mr. Magriso told you that that article was now removed from the Haaretz Newspaper and online edition?
Raanan Katz: Yes.
Attorney: Okay. Yet it's still on their website at least as of August 2nd, 2012 as shown in Exhibit 9?
Raanan Katz: Well, I -- I cannot tell you.
Attorney: Okay.
Raanan Katz: We were disappointed with this.
Attorney: Did you ever send any written demand to the Haaretz magazine to take it down?
Raanan Katz: No.
Attorney: Okay. Do you know how Haaretz ever got the image in the first place?
Raanan Katz: Just as testified before, Mr. Magriso took same picture in Jerusalem while I was falling off -- you I don't remember.
Attorney: Okay. And is it your intent to have a registration in the U.S. for your copyright for your image?
MR. KLUGER: Object to the form.
Raanan Katz: There is no need to do if she stops those -- this baloney what she is doing. As long -- as long when this -- this my case should be over, I don't need to do it -- I don't need to do it. Only reason we try to do it to make sure that -- that your client will stop using this nonsense, okay. And maybe you can or maybe you can put together, understand why should you explain her to stop this nonsense, because it doesn't do any good to anybody whatsoever. You know it, both they know it, she knows it and all my attorneys knows it.
Attorney: Okay. That was not responsive. Let's try the question again.
Raanan Katz: It's very responsive. Okay.
Attorney: Is it your intent to register this image with the U.S. copyright office?
Raanan Katz: I don't know what -- whatever my attorney will -will advise me that's what I'm going to do..."

RAANAN KATZ

I really like this Raanan Katz answer...

"Attorney: Okay. Are you aware that you stopped suing Google as well?
Raanan Katz: I am not that familiar about the dates. So, I cannot tell you exactly when and how. Only I tell you that nobody here is familiar about this atrocity case whatever it is and then -- and then, you know, again everyone tried to find what the right way because nobody understood how far your client will go this kind of nonsense and also this has surprised everybody. As I told you, she should get a life...

Attorney:Okay. And after number 4 there is a sentence that says, "All of these articles have the picture with my tongue out like Michael Jordan used to do when he drove to the basket."
Raanan Katz: Yes.
Attorney: Right?
Raanan Katz: Yes.
Attorney: Was it terrible that Michael Jordan had his tongue sticking out?
Raanan Katz: Obviously, this was not, but Michael Jordan has tongue sticking out only when he drive to the basket. This was his gesture but not for me I don't stand like a yoyo and had put my tongue out because anybody stand with the tongue out all the time go to, you know, to ame yaya.
Attorney: So it's a signature image tor Michael Jordan one of the most iconic basketball players in the entire world -
Raanan Katz: Uh-huh.
Attorney: But if you stick your tongue out it's a terrible horrible image?
Raanan Katz: Na, no, na, see now you don't -- now you try to trick me. Michael Jordan had his tongue out only sometimes when he drive to the basket, okay. That's a beautiful move, you know, he is not -- I bet he is the second best player because LeBron James is better than him (my comment: at this time I thought he would say his name, but...)-- better than him okay than he was. However, I know - however, it's a different story but Michael did never ever, ever stood in any place with those people and put his tongue out, okay. So you see you are trying to confuse it completely in a -- completely out. I was, I was falling off the steps there and I was
trying to hold myself and that why the tongue out and the photographer made a joke, all right. Your client took the joke and tried to fight me an this. Do you know how much time and money we spend an this? I just hope she paid you and does she pay your legal fee for, you know, tor all these atrocity?
Attorney: My deposition tor you, not your deposition tor me."
Complete details of Raanan Katz case can be downloaded on the federal court website.

Raanan Katz: The Picture Is Unfair, They Make Fun Of Me

Here is Raanan Katz deposition that was taken in his alleged copyright infringement case. To view all publicly available records, please, visit federal court website. For those who do not know Raanan Katz- Raanan Katz is RK Centers and Miami Heat Owner. He also likes suing people...

"DEPOSITION OF RAANAN KATZ

TAKEN ON BEHALF OF THE DEFENDANT

DECEMBER 18, 2012

11:06 a.m. - 4:59 p.m.

Raanan Katz: You know, again -- you know, I believe it took us sorne time to find who did it, took us some time to find, you know, who did it. And only reason I -- I did continue it I've to stop sort of saying, your client Start publishing this, you know, this article in the blogs and I saw everything what she did.

Attorney: Did you -

Raanan Katz: I didn’t have time, I left it alone.

Attorney: So, prior to the beginning publishing of blogs,

articies by my client, did you contact Mr. Seffi Magriso about this -- this photo?

Raanan Katz: Only -- only reason to contact him is because I saw the blog...if he dont have a blog I would've not have -- I would leave it alone, it's a joke...

Attorney: Okay.   The -- so, on that May -- on that May date; that was the first time that you decided that you wanted to go and contact Mr. Magriso?

Raanan Katz: I don't remember. I don't -- I cannot tell you I don't remember.

Attorney: Did you contact Seffi Magriso --

Raanan Katz: No.

Attorney:-- prior to seeing your picture on the defendant's blog? 

  

Raanan Katz: I don't think so.

Attorney: Okay.   So, earlier when you said that you got an email from your friend -

Raanan Katz:Mm-hmm.

Attorney:-- about the Haaretz -

Raanan Katz: Mm-hmm.

Attorney:-- article and you were upset about it -

Raanan Katz: Mm-hmm.

Attorney:-- you didn't contact the -- the photographer until you then later saw it on another publication?

Raanan Katz: No, I -

MR. KLUGER: Objection to -- object to the form. You can answer.

Raanan Katz: I called my friend -- I'm trying to remember. I told my friend to call the reporter not to the photographer.

Attorney: When did you tell your friend to call the reporter?

Raanan Katz: Some time after he sent me this article.

Attorney: After he sent you the article?

Raanan Katz: Yeah, from Haaretz.

Attorney: Was that before you saw the article, the photo, alleged photo in the -- in the blog?

Raanan Katz: I don't remember. She did a marvelous job is putting it nonstop, that's only what I looked like, okay, so.

Attorney: But you're not sure -

Raanan Katz: No -- no, you know, you know, let me answer please, okay. You know, here you see another picture in her one of her blogs. If she really want to be to be punk she could've had this, you know, this picture instead of, you know, this one, okay. So, let's say -- let's don't try to confuse me in some dates but go ahead...

Attorney: So, how -- how did you come to find this photo?

Raanan Katz: Sometimes somebody shows on the -- on the Internet and on the Internet, see I'm pretty popular, you know, in Israel. And it shows there and he sent me this. And I usually had just -- somebody had said me maybe I don't even say it at all. Right now, the only reason I now said, actually I never said it. Only reason it's here because your client decided to put it on you know to put it on it -- on her blogs to get those some ugly situation blogs.

Attorney: Okay. So, this photo here, a minute ago you said -this photo would have been okay to put in the blog article?

Raanan Katz: Yes, yes. Well, it's not to kept blog completely, because the blog is despicable -- make sure you understand what I'm saying, but if you -- if you da something, if you want to -- you can't let your life feel legit whatever it is, she could've put a good picture instead of this ugly pictures that everybody knows that this is certainly does look like me, look me underdressed, okay, that's what I'm saying.

Attorney: So -- so, the difference between this picture that we've been talking about and the other picture is that you believe the picture that's an issue in the case is ugly?

Raanan Katz: That the picture is unfair, they make fun of me.

Attorney: It makes fun of you?

Raanan Katz: And that's exactly what's her intention. To antagonize me, to help me in any way possible and to get me upset. That's exactly what's -- what's her full-- her cause and we can go to it later.

Attorney: Okay. So, if we put -- if she put this photo in an article about you that would be okay?

Raanan Katz: Nothing she do is okay, nothing, not a -- nothing she's doing -- she doing is disgrace to the human race, okay. Make sure you know you geb it; I'll say it in the court of law under -- under oath, okay, completely. But I say -- but at least, if she believe she want to make a point, and not to make a fool out of herself, she should have put picture like this or like this or many other pictures you can find on the -- on the Internet."

Well, no worries, Raanan, ...the good one is coming.. and I mean not only picture...

 

raanan katz

 

Raanan Katz v Google Inc Et Al Case

As Raanan Katz, RK Centers and Miami Heat Owner,  federal copyright case progresses (related to Raanan Katz picture), today I am publishing some new filings that now a part of public records and can be downloaded by members of the public.

So, here is the case #1:12-cv-22211-JLK, Raanan Katz v. Google Inc. et al, case , filed on Tuesday, June 12, 2012.

On March 11, 2013 Raanan Katz filed Motion to Strike the Affirmative Defenses to his Amended Complaint. In other words, Raanan Katz was trying to "elect" his favorite court strategy "Let me get DEFAULT"

On Friday, April 12, Response in Opposition to Plaintiff's (Raanan Katz) Motion to Strike Affirmative Defenses was filed and here are some key points.

"This is a frivolous copyright case, in which the Plaintiff (Raanan Katz) purports to have acquired the copyright to a photograph of the Plaintiff and alleges that the Defendant violated his copyright when she posted the photograph on her blog...

a. Unclean Hands (Affirmative Defense No. 4.)
Plaintiff (Raanan Katz) admitted at deposition that he allegedly acquired the copyright and brought this clam for purposes of causing Defendant to stop blogging about him. This was also admitted in a letter he wrote to the alleged photographer. Plaintiffs (Raanan Katz) not claiming that he lost any economic value of the photograph itself and has alleged no plans, much less the ability, to commercially exploit the photograph. Plaintiff (Raanan Katz) did not contact the alleged photographer to complain about the photograph until after he saw the photo in the blog, even though he had seen the photograph earlier on 'Haaretz.com.' (Ex. A, Katz Depo. at 83:12-16 - 84:1.) As Plaintiff (Raanan Katz) admitted at deposition, the "[o]nly reason we try to do it to make sure that - that [Defendant] will stop using this nonsense." (Ex. A, Katz Depo. at 150:9-15.)  He admitted that the "only reason" he contacted the photographer "is because I saw the blog ... If he don't have a blog, I would've not have —I would leave it alone, it's a joke." (Id. at 78:12-19.) Katz also wrote the alleged photographer that he wanted the assignment of copyright because his attorney is trying to legally eliminate the harassment by very bad Russian people." (Ex. B.) Even after 'Haaretz.com' published the photograph following the filing of this lawsuit, Plaintiff (Raanan Katz) never wrote it to demand that it be taken down. (Ex. A, Katz Depo. at 125:14-2 1.) Thus, the sole purpose of acquiring the copyright and bringing this action is to open another front in his (Raanan Katz) ongoing effort to shut down Defendant's blog...

g.    Misuse (Affirmative Defense No. 1)
Courts have held that copyright misuse can be found where the plaintiff seeks to leverage the copyright to undermine invention and creative expression. See Shloss v. Sweeney, 515 F. Supp. 2d 1068, 1080 (N.D. Cal. 2007). As discussed herein, this action is brought solely to suppress Defendant's blog. Plaintiff (Raanan Katz) admitted that he did not complain about the photo or seek to acquire the copyright until it was posted on Defendant's blog. As admitted in an email, Plaintiff sought to use the copyright to contest the blog, which he complained was published by "these Russians:" "My attorney is trying to legally eliminate the harassment by very bad Russian people and your cooperation will be appreciated. These Russians are posting the picture on their blog every week in order to embarrass me .. ." (Ex. B.) In other correspondence, Plaintiff (Raanan Katz) admitted that the blogs were "news publications." (Ex. C.) This improper leverage to suppress news about business and litigation practices is a proper basis for the misuse affirmative defense.

i.    Failure to Join (Affirmative Defense No. 6.)
This affirmative defense states that "Plaintiff has failed to join parties, including without limitation others claiming ownership of  alleged copyright or copyrights asserted by Plaintiff (Raanan Katz) in this action, which are necessary for a full and complete adjudication of its claims, including, without limitation, as required by Rule 19 of the Federal Rules of Civil Procedure . . ." (D.E. 28 at 5.) Because of questions of Plaintiff's ownership of the copyright, the failure to join the actual owner is fatal to Plaintiff's claim. Plaintiff (Raanan Katz) alleges that he obtained "all right, title and interest, including all rights of copyright" in the subject image by "assignment." (D.E. 10 at 2.) Plaintiff (Raanan Katz) claims to have obtained a written assignment of the copyright from a photographer. However, Plaintiff (Raanan Katz) has been unable to produce an original of the assignment and has not established that the alleged assignor owned the copyright. Plaintiff (Raanan Katz) claims that this photograph was published on the 'Haaretz.com' website, (Ex. C), and it may belong to that organization or another person or entity, other than the alleged assignor. Notably, 'Haaretz.com' continued to publish the photograph even after the alleged assignment. (Ex. A, Katz Depo. at 125:14-21.)

n.    Fraud (Affirmative Defense No. 11.)
The Fraud Affirmative Defense alleges that "Plaintiff knowingly procured the copyright(s) without authorization of the author and has misrepresented Plaintiff's rights." (D.E. 28 at 6.) Plaintiff claims that he acquired the copyright from the photographer, but no original of the assignment has been produced, and it has not been established that the alleged assignor is the actual owner of the copyright.

o.    Standing (Affirmative Defense No. 12.)
This affirmative  defense states "Plaintiff does not own a copyright to the photograph and has no standing to maintain this action.. . ." (D.E. 28 at 6-7.) Plaintiff (Raanan Katz) claims to have obtained the copyright from the photographer. Plaintiff has failed to produce an Original of the assignment agreement. Moreover, Plaintiff (Raanan Katz) failed to investigate whether the assignor was actually the copyright owner, if in fact he was the actual photographer. Notably, the photograph was originally publicized by 'Haaretz.com', but no assignment for 'Haaretz.com' has been produced. Nor has it been disclosed what the arrangement was between 'Haaretz.com' and the photographer regarding ownership of the copyright. Plaintiffs "must meet the statutory standing requirement contained in the Copyright Act of 1976, 17 U.S.C. § 501 (b), which provides that only the legal or beneficial owner of an 'exclusive right' has standing to bring a copyright infringement action in a United States court." Saregama India Ltd. v. Mosley, 635 F.3d 1284, 1290-91 (1 lth Cir. 2011). Plaintiff accordingly lacks standing to bring this claim.
IV.    Conclusion
This action is unambiguously another front in Plaintiffs (Raanan Katz) SLAPP litigation against an admitted news publication. Plaintiff (Raanan Katz) has suffered no harm other than thinking a photograph, in which he is well and appropriately clothed, somehow depicts him as underdressed. In Plaintiff's mind, the photograph is a 'joke." He acquired the copyright solely in an attempt to shut down the blog..."

raanan katz and alan kluger

How Raanan Katz, RK Centers Fabricate Their Pleadings

"он потянул ручки к бизнесу, ручки исчезли,бизнес остался..."

Here is the part of RK Centers and Raanan Katz pleadings based on which my identity was disclosed in Miami  State Court. After RK Centers and Raanan Katz have gotten what they wanted they simply amended the complaint removing the portion below.

"Defendant also published anti-Semitic depictions, including blog posts and cartoons, about Raanan Katz and Danny Katz, which tend to expose Plaintiffs to hatred, contempt, ridicule or obloquy. See copies of the anti-Sernitic blog posts and cartoons attached hereto as Exhibit "B." For instance, Defendant's anti-Semitic cartoon published on November 14, 2011 is comparable to the anti-Semitic cartoons attached hereto as Exhibit "C." Defendant's anti-Semitic publications, including the blog posts and cartoons"...by the way RK Centers and Raanan Katz attorney, Alan Kluger, presented to the court some type of cartoons that have never been published on the blog, intentionally misrepresenting the court in order to get WHAT RAANAN KATZ wants. Wow, what a fabricated liars.

By the way, do you know how Daniel (or they call him Danny) Katz called my husband ... "Russian F..... Jew".  

 

RK Centers, Raanan Katz New Lawsuit In Miami Court

According to Court records, RK Centers and Raanan Katz company, 17070 COLLINS AVE SHOPPING CENTER (LTD), initiated legal action for DAMAGES against former tenants located at 17100 Collins Ave., Sunny Isles Beach, FL 33160 case #2013-9648-CA-01.

RK Centers initiated legal action for DAMAGES on March 15, 2013, service was returned on March 18, 2013 for Defendant 01 and on March 22, 2013 for Defendants 02 and 03.

Now, the sign is posted on the premises by RK Centers that new business is coming. Does it mean RK Centers and Raanan Katz already signed a new lease? How long it takes for RK Centers to sign the lease since legal action for damages been initiated only on March 15?
Today is the due date for Defendant 01 to respond to RK Centers complaint.

How Raanan Katz and RK Centers expect tenant to pay rent if 17070 COLLINS AVE SHOPPING CENTER trespass customers from their tenants businesses, holding trespass order against John Doe(s).
I am curious how this claimed "DAMAGES" matter will be resolved...

RAANAN KATZ, RK CENTERS AND MIAMI HEAT OWNER

RK Centers, Raanan Katz Filed Concession Of Error In Appeal Court

This is the latest update in the appeal court in regards to preliminary injunction RK Centers, Raanan Katz, Daniel Katz, R.K./FL MANAGEMENT, INC., a Florida Corporation, R.K. ASSOCIATES VII, INC., a Florida Corporation, 17070 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RAANAN KATZ, an individual, DANIEL KATZ, an individual, RK HALLANDALE 1, LLC, a Florida Limited Liability Company, RK HALLANDALE LIMITED PARTNERSHIP, a Florida Limited Partnership, 18100 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RK 17600-17632 COLLINS, LLC, a Florida Limited Liability Company, R.K. ASSOCIATES # 2, INC., a Florida Corporation, R.K. ASSOCIATES XVIII, LLC, a Florida Limited Liability Company, R K CAUSEWAY PLAZA, LLC, a Florida Limited Liability Company, RK BISCAYNE PLAZA, LLC, an Oklahoma Limited Liability Company, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., a Florida Limited Partnership, RK SANS SOUCI PLAZA, LLC, a Florida Limited Liability Company, and RK SAGE PLAZA, LLC, a Florida Limited Liability Company,  somehow obtained in Miami State Court.

Alan Kluger and Todd Levine of Miami based Kluger, Kaplan, Katzen, Silverman, Levine Law firm helped rich and famous RK Centers and Raanan Katz to obtain unlawful injunction. 

Here is the extraction of the Concession of Error filed IN THE DISTRICT COURT OF APPEAL OF FLORIDA THIRD DISTRICT CASE NO. 3D12-3221 by RK Centers and Raanan Katz.

"CONCESSION OF ERROR
In this appeal, the appellant challenges a preliminary injunction. In one of the grounds raised, the appellant argues that he was not provided with actual notice until after the hearing on the preliminary injunction and after the issuance of the preliminary injunction, and that the injunction did not meet the requirements of Fla. R. Civ. P. 1.610(a)(1)(A) and (B) for dispensing with such notice. See Initial Brief of Appellant at 9-12 (section "A" entitled "The Injunction. Failed to Satisfy Florida Rules of Civil Procediure 1.610"). Upon review of the record, the appellees (RK Centers, Raanan Katz, Daniel Katz) concede that this argument is correct.
Accordingly, based upon this argument alone, the appellees (RK Centers, Raanan Katz, Daniel Katz) concede error and agree to reversal and remand with directions to vacate the preliminary injunction..."

I will not comment on this matter at this time due to the pending decision of the appeal court.

Just remember these names
RK Centers, Raanan Katz, Daniel Katz, R.K./FL MANAGEMENT, INC., a Florida
Corporation, R.K. ASSOCIATES VII, INC., a Florida Corporation, 17070 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RAANAN
KATZ, an individual, DANIEL KATZ, an individual, RK HALLANDALE 1, LLC, a Florida Limited Liability Company, RK HALLANDALE LIMITED PARTNERSHIP,
a Florida Limited Partnership, 18100 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RK 17600-17632 COLLINS, LLC, a Florida
Limited Liability Company, R.K. ASSOCIATES # 2, INC., a Florida Corporation, R.K. ASSOCIATES XVIII, LLC, a Florida Limited Liability Company, R K CAUSEWAY
PLAZA, LLC, a Florida Limited Liability Company, RK BISCAYNE PLAZA, LLC, an Oklahoma Limited Liability Company, CALIFORNIA CLUB MALL SHOPPING
CENTER, LTD., a Florida Limited Partnership, RK SANS SOUCI PLAZA, LLC, a Florida Limited Liability Company, and RK SAGE PLAZA, LLC, a Florida Limited Liability Company.

RAANAN KATZ

RK Centers, Raanan Katz: Another Default Victory In Miami Court

RK Centers, Raanan Katz company, 18100 Collins Avenue Shopping Center, LTD, a Florida limited Partnership, filed legal action for DAMAGES against it’s commercial Tenant in Miami Court Case 2013-1486-CA-01 on January 14, 2013.

The same day the Defendants (the tenant and guarantor) were served with the pleadings (per court records). For some reason the Defendants have not responded to the complaint that gave RK Centers company green light to go straight to default.

What is the most amazing is the amount of the damages claimed and granted per default judgment $504,336.64

Here is the extraction from the order:

“1. 18100 Collins Avenue Shopping Center, LTD., a Florida Limited Partnership, shall recover from Copper Chimney, Inc., a Florida Corporation, the sum of $369.247.86, as principal, that shall bear interest at the statutory rate, and, in addition, 18100 Collins Avenue Shopping Center, LTD, shall recover prejudgment interest in the amount of $2,017.68, for the period of January 14, 2013 through the estimated date of the entry of this judgment, February 25, 2013, totaling $371,265.54, for which let execution issue forthwith.

2. 18100 Collins Avenue Shopping Centers, LTD shall recover from and Jasmine Uberoi, Individually as Guarantor, the sum of $132,347.86, as principal, that shall bear interest at the statutory rate, and, in addition, 18100 Collins Avenue Shopping Center, LTD. shall recover prejudgment interest in the amount of $723.24, for the period of January 14, 2013 through the estimated date of the entry of this judgment, February 25, 2013, totaling $133,071.10, for which let execution issue forthwith.”

On February 7, 2013 RK Centers and Raanan Katz company filed affidavit in support of motion for summary judgment based on which the DEFAULT was granted.

What is the amount of monthly rent the Tenant was responsible for and how many months the rent was not paid to get $504,336.64 in default damages?

I could not find non-default cases where RK Centers, Raanan Katz and his companies were able to prove the amount of damages they claimed in the initial complaint.

RK Centers Company Makes Droppings One After Another

Well, looks like RK Centers has elected to make more droppings (in Miami Dade Court) and I do not know if the aroma has already reached Raanan Katz Boulevard that located in the middle of RK Centers Plaza in Sunny Isles Beach.

According to court records, another voluntary dismissal was recently filed in Miami Court by Raanan Katz company, 17070 Collins Avenue Shopping Center (LTD), case number  13-2012-CA-016490.

RK Centers (17070 Collins Avenue Shopping Center (LTD)), initiated legal action against former tenant for DAMAGES on April 26, 2012, but …. the Defendant filed answer and affirmative defense. Seems like Raanan Katz company was not ready for this turnaround and …RK Centers has elected to go for voluntary dismissal.

Why RK Centers company, 17070 Collins Avenue Shopping Center (LTD), decided not to prove it’s damages claimed in the complaint after former tenant filed answer and affirmative defense. What happened to the alleged "DAMAGES"? 

 

 

According to free online dictionary: "A legal action or proceeding initiated maliciously and without Probable Cause by an individual who is not acting in Good Faith for the purpose of annoying or embarrassing an opponent.

The U.S. legal system permits persons to file civil lawsuits to seek redress for injuries committed by a defendant. However, a legal action that is not likely to lead to any practical result is classified as vexatious litigation. Such litigation is regarded as frivolous and will result in the dismissal of the action by the court. A person who has been subjected to vexatious litigation may sue the plaintiff for Malicious Prosecution, seeking damages for any costs and injuries associated with the original lawsuit."

RAANAN KATZ

RK Centers, Raanan Katz, 17070 COLLINS AVE SHOPPING CTR LTD Filed Voluntary Dismissal In Miami Court

Raanan Katz, the owner of 17070 COLLINS AVE SHOPPING CTR LTD, filed a notice of voluntary dismissal against the only defendant in the Miami Dade case 2012-43014-CA-01.

On November 1, 2012 Raanan Katz company, 17070 COLLINS AVE SHOPPING CTR LTD,  initiated legal action for DAMAGES against former tenant.  Raanan Katz company, 17070 COLLINS AVE SHOPPING CTR LTD, intensively was trying to move this case for DEFAULT. 
On December 24, 2012 default WAS NOT ENTERED...and on Feb 8, 2013 Raanan Katz company 17070 COLLINS AVE SHOPPING CTR LTD filed a notice of voluntary dismissal.  

Should we all make donations to "compensate" Raanan Katz for his alleged "DAMAGES"... and offer him additional "compensation" as  "punitive damages" for his frustration in NOT obtaining DEFAULT??? Another legal droppings made by Raanan Katz company -17070 COLLINS AVE SHOPPING CTR LTD.

Appeal Court Ordered Raanan Katz and RK Centers To Respond By Due Date

RK Centers, Raanan Katz and other 14 appellees have been requesting extension of time over and over again. Unfortunately, for Miami Heat and RK Centers owner, Raanan Katz,  he has to respond by April 3, 2013.

Here is part of the 3DCA order:

"Extension granted to file answer brief NFE (NO FURTHER EXTENSION). Appellee's (Raanan Katz, RK Centers and etc) motion for an extension of time to file the answer brief is granted to and including April 3, 2013, with no further extensions allowed. If said brief is not timely filed in accordance with this order, appellee(s) (Raanan Katz, RK Centers and etc.) will be precluded from filing an answer brief and/or presenting oral argument to the court in this cause."

RAANAN KATZ

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

RK Centers Presented The “Expert” Opinion To Miami Court

Well, the question is who is claimed to be the “expert”- Kevin Belmont. According to social webpages, Mr.Belmont is a proud school dropper (just curious, how this squareheaded could even get in) with the claimed experience - "Most likely I can get that done for you".

During the hearing in Miami Dade Court, Kevin Belmont, Boston based Мудило, decided not to show up, instead he sent an “expert” letter to the judge. Considering that Мудило-Belmont works for RK Centers, who is the Plaintiff in the case, RK Centers attorney Alan Kluger and Todd Levine have represented him as an “expert”. Must be hard to be in litigation when a real professionals cannot support Raanan Katz, RK Centers' frivolous statements.

Several web publications made by Mr.Belmont speak for themselves. Just wonder, what was his English “academic achievements” in school and where did he lean the vocabulary, especially the words he used to describe Raanan Katz.

Raanan Katz, RK Centers, 17070 Collins Avenue Shopping Center Obtained Final Judgment For Damages In Miami

"Est-ce dans les mots de république ou de monarchie que réside la solution du grand problème social ?" Maximilien Robespierre

Miami Court granted final judgment for damages to Raanan Katz, RK Centers company 17070 Collins Avenue Shopping Center.

“It is ordered and adjusted that:

1. 17070 Collins Avenue Shopping Center, LTD, a Florida Limited Partnership, shall recover from Iprofix.com.,Inc, a Florida Corporation, the sum of $1,175.00, as principal, that shall bear interest at the statutory rate.
2. This Court retains jurisdiction of this matter to enter any further Orders that may be necessary, including, but not limited to, an award of attorney’s fees and costs for which 17070 Collins Avenue Shopping Center, is entitled.
3. For purpose of recording this final judgment, the address of the Plaintiff, 17070 Collins Avenue Shopping Center, LTD., is as follows:

17070 Collins Avenue Shopping Center, LTD

17100 Collins Avenue

Suite 225

Sunny Isles Beach, FL 33160”

This was revolutionary litigation, former tenant was really fighting not just against 17070 Collins Avenue Shopping Center, but against commercial landlords like Raanan Katz and RK Centers. The former tenant did not have attorney, she was fighting against RK CENTERS pro-se. This could be the result of small loss, but at the end of the road I believe she is the winner.

Moreover, RK Centers made the lease agreement publicly available. The agreement does not have common area maintenance clause.

Keep asking myself … why after several years and “victories” Raanan Katz and RK Centers in-house attorney Gavin Kahn decided to be outside of  RK Centers Miami office. Maybe too tired from bad dreams or nightmares???

 

RAANAN KATZ

 

RK Centers, Raanan Katz In House Attorney Moved Out Of House

What happened to RK Centers and Raanan Katz in-house attorney. I wounder why he is no longer in house. Maybe the grass is greener in Plantation, and the sun is shinning brighter!!! Why Mr.Kahn did not lease from Mr. Katz?
Anybody out there in Plantation want to move in instead???

 

Raanan Katz, RK Centers: Liar, Liar, Pants On Fire?

Wow, Raanan Katz and RK Centers openly admitted and provided proof to the court that I am invited, have consent from the business owners, and contractual relationships with them. Yet, Katz attorney, Todd Levine, Todd Levine, Todd Levine, Todd Levine of Miami based Kluger, Kaplan, Silverman, Katzen, Levine law firm, is trying to get green light for his client to act against the law and constitution. Apparently, Judge Friedman order and Raanan Katz own settlement agreement was not attached to their motion. No wounder why!!! Liar is always a liar!

Hearing on the contempt matter is scheduled on Feb 26, 2013.
Cannot wait to show to the Court that Raanan Katz and Co were and are repeated liars.  Judge Ellen. L. Leesfield, who unfortunately will be off the bench at the time of the hearing, published Basic Of Expert Testimony where she cited Florida Bar Rule 4-3. 4 (b)

"A lawyer shall not: (b) fabricate evidence, counsel or assist a witness to testify falsely, or offer an inducement to a witness, except a lawyer may pay a witness reasonable expenses incurred by the witness in attending or testifying at proceedings; a reasonable, noncontingent fee for professional services of an expert witness; and reasonable compensation to reimburse a witness for the loss of compensation incurred by reason of preparing for, attending, or testifying at proceedings "

Raanan Katz Company Got Another Final Judgement for Damages After Default

According to Miami Dade court records, Raanan Katz, Miami Heat and RK Centers Owner, got Judgement for Damages after default, case 2011-39340-CA-01. 
I could not believe in the amount of damages claimed by Raanan Katz  
company 18100 Collins Avenue Shopping Center, LTD  - $435,591.70.
here is the part of the court records

"It is ordered and adjusted that:

1. 18100 Collins Avenue Shopping Center, LTD., a Florida Limited Partnership, shall recover from Copper Chimney, Inc., a Florida Corporation, the sum of $432,000.00, as principal, that shall bear interest at the statutory rate, and , in addition, 18100 Collins Avenue Shopping Center, LTD shall recover prejudgment interest in the amount of $1,910.80, for the period from November 28, 2011 through December 31, 2011, and $1,680.90, for the period of January 1, 2012 through the estimated date of the entry of this judgment, January 30, 2011, totaling $435,591.70, for which let execution issue forthwith."

This order was in effect  on 02/07/2012. Surprise, surprise, generous Raanan Katz filed motion of dismissal on April 11, 2012 together with stipulation of settlement, and obtained an order to VACATE the judgement.

You think it would be the end of Raanan Katz and RK Centers legal game.
On January 13, 2013 (what a lovely date), Raanan Katz company, 18100 Collins Avenue Shopping Center, LTD., a Florida Limited Partnership, filed another lawsuit against the same tenant claiming damages again, and again, and again... It must be hard to be so pure...

It's time for the second default, the order is on it's way. Just curious, what will be the amount this time.

RAANAN KATZ............................................DANIEL KATZ

Raanan Katz Claims He Has A Right To Sue People

Raanan Katz, Miami Heat and RK Centers owner, likes filing lawsuits. Today I'd like to publish Raanan Katz peace of  you know what called by Raanan "Assignment of Copyright". Based on this peace of something Raanan feels free to sue people and companies for alleged copyright.

To remind you, back in June, 2012, Raanan Katz filed lawsuit against Google and Blogger for  alleged copyright violation of his FACE.

Prior to that, Google denied Raanan Katz DMCA complaint. If you wounder why, you need to see what Raanan submitted to Google as his copyright ownership rights. By the way, as of today Raanan has not attached this peace of something to any of his federal case pleadings, simply stating that he has exclusive ownership rights to the image. This statement in his complaint gives Raanan Katz right to sue people. Yes, Katz dropped his claim against Google.

Due to ongoing discovery and Raanan Katz deposition in the court I will not reveal more details at this time.

However, more details will be available to the public including Raanan Katz video deposition.

By the way,  Federal Judge denied Raanan Katz attempt to make discovery private  "...the Court's long-standing principle and practice of maintaining Court proceedings and documents public...'The Federal Judiciary has zealously protected the right of all citizens to free, open and public trials'...The proceedings held in federal and state courts are open to public observation by any interested party. Pursuant to Local Rule 5.4 for the Southern District of Florida, absent some extraordinary need for secrecy, the judicial acts performed should be open to public scrutiny."

Raanan Katz, RK Centers Claim RK Plazas Have Limited Public Access

Do businesses, leasing from RK TOWN CENTERS, know that Raanan Katz, his son Daniel Katz, and their "SHOPPING PLAZAS" prevent customers from entering businesses, including Bank of America, TD Bank, CVS Pharmacy, Walgreens, Publics, UPS and etc, at Raanan Katz and RK Centers own discression. At this time Raanan Katz, Daniel Katz claim in the court that RK SHOPPING PLAZAS and TOWN CENTERS have limited public access. I am not even mentioning that this Raanan Katz, Daniel Katz claim violates prior court order entered in 2009 and settlement agreement.

Well, subpoenas submitted to the businesses, such as Bank of America. TD Bank, CVS Pharmacy, Walgreens, Publics, UPS and others, will clear up whether the businesses are aware of Raanan Katz and RK Centers activities of harassing customers  of their tenants (I am not only talking about myself, my family and anyone associated with me, but also John Doe, who is practically might be any customer entering the businesses leasing from Raanan Katz and CO).
Logical question, what type of money could compensate damages caused by Raanan Katz actions. I am not even talking that Raanan Katz and his claimed to be SHOPPING CENTERS interfere into the business relationship between tenants and their customers. But who cares about people, businesses, matters of public interest and constitutionally protected freedom of speech, when Raanan business with his common area and automatic lease renewal is the first priority. What type of compensation will be available to the customers and businesses once appeal reversed JUDGE Leesfield unconstitutional, unlawful at the best order???
In the meantime, Katz and his attorneys, Alan Kluger and Todd Levine of Miami based Kluger, Kaplan, Silverman, Katzen, Levine law firm, can celebrate the VICTORY. But..Not for a long time.

 Raanan Katz and Daniel Katz bring the following argument to the appeal court in the motion for extension of time. By the way, Katzes like taking extensions only in federal and appeal courts, in Judge Leesfield court their motions are emergency and go first priority (probably by accident).

"As his grounds for conditioning consent to this extension upon a stay of the injunction, counsel for the appellant claimed that the injunction prevents the appellant (mine clarification:blogger, all associated, as well as any member of the public) from entering the appellees' properties, thereby preventing the appellant from conducting activities such as banking or grocery shopping, and that the injunction also result in a denial of the appellant's freedom of speech.
However, the appellees (mine:Raanan Katz, Daniel Katz, RK Centers) have no monopoly upon all bank branches, grocery stores, or any other commercial establishments. The appellant is free to frequent any such establishments in South Florida or elsewhere as long as they are not managed by the appellees. Thus, at worst, the injunction poses to the appellant, as the trial court characterized it, a "potential inconvenience" until the matter is tried on the merits. The appellants inconvenience is far outweighed by the irreparable harm and danger to the appellees."
What type of danger Raanan Katz is talking about?

This was filed by LAW OFFICES OF PAUL Morris, P.A. 9350 South Dixie Highway, Suite 1450 Miami, FL 33156
(305) 670-1441 Florida Bar No. 193769 together with well known Miami law firm  of Kluger, Kaplan, Silverman, Katzen and Levine.

Raanan Katz message seems very clear: "pay rent and whatever I ask you to pay, but you are not allowed to do the business..." Censorship and business destruction should not be allowed on Raanan Katz request in Miami, as Miami is still part of the United States of America. What type of freedom we have in Miami if we have to fight for basic things?
In the meantime, I can just enjoy watching meaning of freedom outside of Miami.

RK Centers: Default Was Not Granted To 17070 Collins Avenue Shopping Center

Raanan Katz company, 17070 Collins Avenue Shopping Center, was trying to get default judgement against former tenant in Miami Dade court case # 13-2012-CA-043014.

Lol!!! According to court records default was not entered on Dec 24, 2012.

Another case is moving to compel discovery 13-2009-CA-082675, sounds good to me, considering Mr.Katz and his companies do not like producing documents! 

In both cases RK Centers, Raanan Katz companies represented by RK Centers in house attorney Gavin Kahn, florida bar #976581

17100 COLLINS AVE, STE 225, SUNNY ISLES BCH, FL 33160 Phone:(305) 949-4110

 

 

RK Centers And Raanan Katz Companies Droppings

On January 7, 2013, fourteen of Raanan Katz companies filed notice of dropping Count Ten (Stalking) without PREJUDICE in Miami Dade Court . 

Interestingly enough, these Ranan Katz companies already obtained Preliminary Restrain Order (thank you to the most phenomenal Judge Leesfield) against blogger, everyone who is associated with me, John Doe (who can be anyone). This order is subject of appeal at this time. Looks like Raanan Katz and all idiots associated with him like playing self-pleasure games in Miami Dade 11 circuit court. See details of Raanan Katz companies' droppings below.

 

"PLAINTIFFS' NOTICE OF DROPPING CORPORATEPLAINTIEFS FROM COUNT X OF SECOND AMENDED COMPLAINT

Plaintiffs, R.K./FL MANAGEMENT, INC., R.K. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, RK.ASSOCIATES # 2, INC., R.K. ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC (collectively, "Corporate Plaintiffs"), through their undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.420(a)(1)  hereby provide notice of the voluntary dismissal without prejudice of only the Corporate Plaintiffs' claims in only Count X (Injunction to Prevent Stalking) of the Second Amended Complaint. This Notice does not affect the claims of Plaintiffs Raanan Katz or Daniel Katz as alleged in connection with Count X of the Second Amended Complaint, nor does this Notice affect any of the Corporate Plaintiffs' claims as alleged in connection with Counts 1 through IX of the Second Amended Complaint.

Respectfully submitted, 

KLUGER, KAPLAN, SILVERMAN, KATZEN & LEVINE, P.L.

Attorneys for P1aintffs

Miami Center, Seventeenth Floor

201 S. Biscayne Blvd., Suite 1700

Miami, Florida 33131

Telephone: (305) 379-9000

By Alan Kluger and Todd Levine"