Judge Orders To File Raanan Katz Unsealed Deposition Transcript

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ruled on Raanan Katz Motion for Protective Order in part related to Mr. Katz request to "seal" his deposition transcript in the CASE NO. 12-2221 I-CIV-KING/M CALILEY.

In this case Raanan Katz alleged copyright violation related to his "unflattering" picture.  Judge ordered filing of the transcript with the court records by June 12, 2013, and "under seal" request was denied. This means that new details of the case could be revealed by the end of next week. Here is the extraction from the Court order. 

"Also pending is Plaintiffs (Raanan Katz) Motion for Protective Order, in which he requests, among other things, that the Court enter a protective order requiring that his deposition transcript be filed
under seal. (DE 50, p. 102.)..

I have carefully reviewed Plaintiffs (Raanan Katz) motion for protective order and exhibits, and have considered it in light of Judge King's prior order denying the parties' joint motion for protective order. (DE 23). I find that Plaintiff (Raanan Katz) has not shown good cause for entering a protective order requiring that his transcript be filed under seal. See Fed. R. Civ.P, 26(c)(1) (good cause required for protective order); In re Alexander Grant & Co. Litig.,820 F.2d 352, 355-57 (1 1th Cir. 1987) (although the public has no First Amendment right of access to pretrial discovery materials, the parties must show good cause for a protective order); S.D. Fla. Local Rule 5.4(a) ("Unless otherwise provided by law, Court rule or Court order, proceedings in the United States District Court are public and Court Filings are matters of public record.'').

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 Speak Blonde In Their Pleadings

RK Centers invented new blonde allegations in their amended complaint filed with Miami State Court. Well, the problem is that American taxpayers are paying for RK Centers and Raanan Katz court games and their blond allegations.

Here is the extraction from RK Centers and Raanan Katz amended complaint.

"...64.    Consistent with their twisted history, on September 3, 2012, Defendants posted an illustration of Mrs. Katz and Daniel Katz on the Blogs. Defendants depicted Mrs. Katz saying "I am staying at a red stop sign for 6 hours... & it's not turning green ... people around are [sic] laughing... and I am getting worried... IS it [sic] SOMETHING WRONG WITH THE SIGN???" Next to this is a depiction of Daniel Katz saying "CALL 911, extension BLONDE."' See September 3, 2012 Blog, a true and correet copy of which is attached hereto as Exhibit "E." (emphasis in original)....Mrs. Katz has blonde hair...",  this was respectfully submitted by RK Centers and Raanan Katz attorney, Mr. Todd Levine.

 This is another part that was respectfully presented by Raanan Katz and RK Centers attorney Todd Levine. My advise do not laugh when attorney Todd Levine testifies about search engine something...

"Todd Levine:Do you know what -- when you do a search on Google, you'll get various results for your search, correct?...
Todd Levine:Search engine optimization is a process by which -- well, you're laughing probably because you know more about this than I do, correct?...
Todd Levine: Is that why you're laughing?...
Todd Levine: Why are you laughing?...
Todd Levine: Why are you laughing at my question when I'm trying to explain search engine optimization to you?..."

RK Centers: What Is The Reason Of Raanan Katz, RK Centers Success

"THE COURT: Yes. Are they fully occupied or are they almost fully occupied (RK Centers)?
MR. KLUGER: Judge, these are very successful centers, the Katz family, it's not only dad who came here from Israel with nothing, his children, his family is in the business. They are very successful. The cases talk about intent to injure in a business way and the fact that people read these poisonous defamatory publications, and as a result they don't want to do business.
THE COURT: Okay.
MR. KLUGER: The fact that they found five other people to do business, doesn't impact at all my ability to get an injunction.
THE COURT: Na speeches yet.
MR. KLUGER: Sorry.
THE COURT: Just down boy."

Raanan Katz: Removal Of Ugly Picture

Here is publicly available and downloadable correspondence where Raanan Katz, RK Centers and Miami Heat owner, making detailed instructions to remove his ugly picture.

RAANAN KATZ

"August 26, 2011
VIA Electronic Mail
Seffi Magriso

RE:    Removal of Ugly Picture   

Dear Seffi:

It was nice speaking to you today and I really appreciate your willingness to help me.
I currently have a problem with an ex-employee who has gotten into some illegal things. Due to his removal, he is contacting online news publications telling them complete lies about me and also sent them an old ugly picture that they found an the Internet, specifically an 'HAARETZ.COM' article.
While no one believes the nonsense written on the blog, the picture is a total insult to me and apparently it was taken by you when, I was under some kind of pressure.
In the seven years that I was involved with Maccabi, you took many pictures of me and have much better ones to be used in the future if necessary.
I am enclosing the following:
1.    Copy of the original article from Haaretz newspaper from February 22, 2011.
2.    Copy of a blog an blogspot.com which is a google company dated May 3, 2011.Please click on the attached link to access the posting
(http://rkassociatesusa.blogspot.com/2O1 1 /07/rk-associates-history-and-somefacts.html). On the top of the page it gives you the option to report copyright abuse, please do so.
3. Copy of the Broward Bulldog article posted online dated this week.
4. Complete contact information for the Broward Bulldog publisher and article author.
All of these articles have the picture with my tongue out like Michael Jordan used to do when he drove to the basket.
It would be greatly appreciated If you could do the following for me:
1.    Contact Haaretz and any other Israel publication that you may have given this picture to and ask them to eliminate it.
2.    Contact Bulldog author and publisher and demand immediate removal from website and to make sure that if they have given the picture to any third party it would be their responsibility to retrieve it immediately.
3.    Contact Google by clicking the Report Abuse link on the blog.
I am also enclosing my business card with all my company information in Boston and Miami (currently I am in my Boston office). I can also be reached on my Boston cell Redacted.
Anything you can do to eliminate this quickly would be greatly appreciated, Keep in touch!
Regards,
Raanan Katz"

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???

RK Centers, Raanan Katz Lost Injunction Appeal

Finally, we have court of appeal decision in 3 DCA in regards to Raanan Katz and RK Centers preliminary injunction for one of the Appellants(case 3D12-3221).

Raanan Katz and RK Centers simply LOST it!!!

Additionally, "upon consideration of the motion for attorneys fees filed by appellant, it is ordered that said motion is granted and remanded to the trial court to fix amount."

Right, it is time to FIX the amount and make Raanan Katz and all his numerous companies/ Plaintiffs  responsible for their court intimidation games in Miami state court. I will publish entire order shortly. 

Big Thank you to Appellants attorneys Kendall Coffey, Jeff Crockett, David Zack.

Attorneys who represented losers are Todd Levine, Alan Kluger of Miami based Kluger, Kaplan, Silverman, Katzen, Levine law firm and appellate attorney Paul Morris.

RAANAN KATZ