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

Raanan Katz, RK Centers Adding Punitive Damages To The Claim

Raanan Katz, RK Centers are moving for punitive damages! Finally, Raanan Katz and RK Centers openly disclosed the amount they want to make from 10 count complaint. Oh là là ! Only 5 million dollars!?! Quelle catastrophe! Only 5 million dollars!?!

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!

Raanan Katz: How To Spell, Don't Ask Me

This Raanan Katz, Miami Heat and RK Centers owner, publicly available deposition speaks for itself. Deposition of Raanan Katz was taken in his alleged copyright  case related to his "ugly picture". Enjoy!!!

RAANAN KATZ

In this part Raanan Katz admits "how much he paid" for allegedly purchased copyright work. Let's not forget that copyright means an intellectual, original works, no matter what Raanan Katz wishes...

"Raanan Katz: Okay. I -- no, again, I you know withdraw -- I offered him again a few dollars, he refuses to -refused to take it.
Attorney: You offered him a few dollars?
Raanan Katz: Yeah, only $500 to be exact, only $500 dollars. He said, "Raanan, I know that I caused you a damage, I apologize 100 times, you know. I'll send it to you -I  send it to you and I'll make sure that an act like this will ever happen again."
Attorney: Okay. Did you give him $500?
Raanan Katz: No, I said no. He refused to take it.
Attorney: Okay. Did you do that offer over the phone?
Raanan Katz: Yes.
Attorney: Did you ever email him an offer in writing?
Raanan Katz: No.
Attorney: Okay. It was only over the phone?
Raanan Katz: Only documents -- all these documents are drawn by Michael Chesal.
Attorney: All the documents are done by Michael Chesal?
Raanan Katz: You know, this only document or this only document was done -- was done by, there is no any other documents.
Attorney: It was prepared by your attorneys.
Raanan Katz: Yes.
Yeah, the guy named Johav Borowski.
Attorney: Johav Borowski?
Raanan Katz: Johav; how to spell, don't ask me.
Attorney: Okay. But he is the -- he doesn't list his name,
It just says Haaretz sports staff, on its article
Raanan Katz: Yeah, yeah.
Attorney: But that's who you believe is the author of the article?
Raanan Katz: Yes, that I believe.
Attorney: Okay. And though he and Mr. Magriso told you that that article was now removed from the Haaretz Newspaper and online edition?
Raanan Katz: Yes.
Attorney: Okay. Yet it's still on their website at least as of August 2nd, 2012 as shown in Exhibit 9?
Raanan Katz: Well, I -- I cannot tell you.
Attorney: Okay.
Raanan Katz: We were disappointed with this.
Attorney: Did you ever send any written demand to the Haaretz magazine to take it down?
Raanan Katz: No.
Attorney: Okay. Do you know how Haaretz ever got the image in the first place?
Raanan Katz: Just as testified before, Mr. Magriso took same picture in Jerusalem while I was falling off -- you I don't remember.
Attorney: Okay. And is it your intent to have a registration in the U.S. for your copyright for your image?
MR. KLUGER: Object to the form.
Raanan Katz: There is no need to do if she stops those -- this baloney what she is doing. As long -- as long when this -- this my case should be over, I don't need to do it -- I don't need to do it. Only reason we try to do it to make sure that -- that your client will stop using this nonsense, okay. And maybe you can or maybe you can put together, understand why should you explain her to stop this nonsense, because it doesn't do any good to anybody whatsoever. You know it, both they know it, she knows it and all my attorneys knows it.
Attorney: Okay. That was not responsive. Let's try the question again.
Raanan Katz: It's very responsive. Okay.
Attorney: Is it your intent to register this image with the U.S. copyright office?
Raanan Katz: I don't know what -- whatever my attorney will -will advise me that's what I'm going to do..."

RAANAN KATZ

I really like this Raanan Katz answer...

"Attorney: Okay. Are you aware that you stopped suing Google as well?
Raanan Katz: I am not that familiar about the dates. So, I cannot tell you exactly when and how. Only I tell you that nobody here is familiar about this atrocity case whatever it is and then -- and then, you know, again everyone tried to find what the right way because nobody understood how far your client will go this kind of nonsense and also this has surprised everybody. As I told you, she should get a life...

Attorney:Okay. And after number 4 there is a sentence that says, "All of these articles have the picture with my tongue out like Michael Jordan used to do when he drove to the basket."
Raanan Katz: Yes.
Attorney: Right?
Raanan Katz: Yes.
Attorney: Was it terrible that Michael Jordan had his tongue sticking out?
Raanan Katz: Obviously, this was not, but Michael Jordan has tongue sticking out only when he drive to the basket. This was his gesture but not for me I don't stand like a yoyo and had put my tongue out because anybody stand with the tongue out all the time go to, you know, to ame yaya.
Attorney: So it's a signature image tor Michael Jordan one of the most iconic basketball players in the entire world -
Raanan Katz: Uh-huh.
Attorney: But if you stick your tongue out it's a terrible horrible image?
Raanan Katz: Na, no, na, see now you don't -- now you try to trick me. Michael Jordan had his tongue out only sometimes when he drive to the basket, okay. That's a beautiful move, you know, he is not -- I bet he is the second best player because LeBron James is better than him (my comment: at this time I thought he would say his name, but...)-- better than him okay than he was. However, I know - however, it's a different story but Michael did never ever, ever stood in any place with those people and put his tongue out, okay. So you see you are trying to confuse it completely in a -- completely out. I was, I was falling off the steps there and I was
trying to hold myself and that why the tongue out and the photographer made a joke, all right. Your client took the joke and tried to fight me an this. Do you know how much time and money we spend an this? I just hope she paid you and does she pay your legal fee for, you know, tor all these atrocity?
Attorney: My deposition tor you, not your deposition tor me."
Complete details of Raanan Katz case can be downloaded on the federal court website.