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???