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!
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