Motion: - TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT Due Date: Complete Date:

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                          Filing # 88264991 E-Filed 04/19/2019 05:27:37 PM

IN THE CIRCUIT COURT OF THE 11™
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
BRIDGE GOLDE, CASE NO. 2019-09262-CA-25
Plaintiff,
VS.

LYUDMILA KOGAN, and
POLLACK, POLLACK & KOGAN, LLC,

Defendants.
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MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT AND
MOTION FOR ORDER REQUIRING PLAINTIFF TO FURNISH SECURITY

COME NOW Defendants, LYUDMILA KOGAN and POLLAC K, POLLACK &
KOGAN, LLC (collectively “Defendants”), pursuant to Florida Statute §68.093, and hereby
move this Court to declare Plaintiff, BRIDGE GOLDE (“Plaintiff”), a vexatious litigant and for
entry of an order prohibiting Plaintiff from filing any further actions pro se, and for entry of an
order requiring Plaintiff to furnish security (post a bond) in the instant action, and as grounds
thereof, state as follows:

FACTUAL BACKGROUND

 

1. Since January 2018, Plaintiff has commenced six (6) related and unsubstantiated
actions, pro se, against Michael Placentra (“Mr. Plac…