MOTION TO SCHEDULE MOTION TO AMEND COUNTERCLIAM AND TO NAME AN ADDITIONAL PARTY AS A CO-CONSIPRATOR AND TO AMEND FOR PUNITIVE DAMAGES F/B DFTS PINCUS CAPITAL LLC AND MARK BENUN - TO SCHEDULE MOTION TO AMEND COUNTERCLIAM AND TO NAME AN ADDITIONAL PARTY AS A CO-CONSIPRATOR AND TO AMEND FOR PUNITIVE DAMAGES F/B DFTS PINCUS CAPITAL LLC AND MARK BENUN

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                          Filing # 78740830 E-Filed 10/02/2018 02:39:03 PM

IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
6654 NW 27 AVENUE LLC,
Plaintiff, Case No: 17CA13348 MB AH
Vv.
PINCUS CAPITAL LLC, et. al.,
Defendants.
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MOTION TO SCHEDULE MOTION TO AMEND COUNTERCLAIM AND TO NAME
AN ADDITIONAL PARTY AS A CO-CONSPIRATOR AND TO AMEND FOR
PUNITIVE DAMAGES

 

The Defendants, Pincus Capital LLC and Mark Benun, by and through the undersigned
counsel, hereby files the above named motion and in support thereof states as follows:

. Plaintiff filed the attached motion to amend on 9/25 and the proposed amended

In

counterclaim on 10/2.

2. As set forth in detail in the Motion to Amend, attached hereto as Exhibit A, part of
the reason the amendment is necessary is that the Plaintiff admits to lying and
perpetrating a fraud because the alternative is a dismissal for lack of standing in
accordance with well settled Florida law, again all as detailed in attached
Exhibit A.…