Raanan Katz, RK Centers and their attorneys Alan Kluger, Todd Levine of Miami based Kluger Kaplan Silverman Katzen Levine law firm prejudiced ALL NEW Defendants in this case. All new Defendants were not served at the time of the hearing and injunction was entered in violation of due process, and Florida Rule of Civil Procedure 1.610.
New Defendants are in immediate need for a law firm eligible to practice in Florida. One of the NEW defendants was served only on November 30, 2012, others were not served as of today (see court dockets case Miami 11 circuit court 13-2011-CA-017842). Here is the extract transcript of the hearing held on November 1, 2012 based on which the order was entered against NEW Defendants.
“Your Honor, for the record, we do not believe that the other Defendant, Dimitri Chevaldine, has been served so he's not a party yet.
THE COURT: Okay. Really, you can bring who ever you wish. If there were testimony or anything and if he's not here, he's not here. There was an amended complaint; correct?
MR. KLUGER: Yes, there was.
THE COURT: And I remember I granted a motion to amend a complaint, but I don't know that I have the amended complaint.
MR. LEVINE: Judge, you did have the amended complaint. We did not bring it with us today because you asked us not to bring anything else. We can send it in later.”
On November 28, 2012 Raanan Katz through his attorneys Alan Kluger and Todd Levine filed a motion to deem the waiver of the services in violation of Florida and US Constitution. See entire motion here. Raanan Katz scheduled hearing on this motion on January 29, 73 West Flagler Street, Miami, FL 33130 Room C400, Judge Leesfield, press and members of the public are welcome.