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.
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