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???