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 And Raanan Katz Companies Droppings

On January 7, 2013, fourteen of Raanan Katz companies filed notice of dropping Count Ten (Stalking) without PREJUDICE in Miami Dade Court . 

Interestingly enough, these Ranan Katz companies already obtained Preliminary Restrain Order (thank you to the most phenomenal Judge Leesfield) against blogger, everyone who is associated with me, John Doe (who can be anyone). This order is subject of appeal at this time. Looks like Raanan Katz and all idiots associated with him like playing self-pleasure games in Miami Dade 11 circuit court. See details of Raanan Katz companies' droppings below.

 

"PLAINTIFFS' NOTICE OF DROPPING CORPORATEPLAINTIEFS FROM COUNT X OF SECOND AMENDED COMPLAINT

Plaintiffs, R.K./FL MANAGEMENT, INC., R.K. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, RK.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, "Corporate Plaintiffs"), through their undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.420(a)(1)  hereby provide notice of the voluntary dismissal without prejudice of only the Corporate Plaintiffs' claims in only Count X (Injunction to Prevent Stalking) of the Second Amended Complaint. This Notice does not affect the claims of Plaintiffs Raanan Katz or Daniel Katz as alleged in connection with Count X of the Second Amended Complaint, nor does this Notice affect any of the Corporate Plaintiffs' claims as alleged in connection with Counts 1 through IX of the Second Amended Complaint.

Respectfully submitted, 

KLUGER, KAPLAN, SILVERMAN, KATZEN & LEVINE, P.L.

Attorneys for P1aintffs

Miami Center, Seventeenth Floor

201 S. Biscayne Blvd., Suite 1700

Miami, Florida 33131

Telephone: (305) 379-9000

By Alan Kluger and Todd Levine"