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, 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.

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