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IN THE CIRCUIT COURT OF THE ELEVENTH
| JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
CASE NO.: 2017-008051-CA-01, Section 41
| 79 BISCAYNE PLAZA, LLC, a Florida limited liability
| company,
Plaintiff,
v
GROUP NEXUS FIVE, INC. /dba/ WORTH IT, a Florida
corporation,
| Defendant./
| ORDER TO SHOW CAUSE
THIS CAUSE came on to be heard on June 19, 2018, upon Plaintiff's Motion For the
Imposition of Sanctions and/or in the Alternative an Order to Show Cause, and the Court, having
heard the argument of counsel and being otherwise fully advised in the premises, it is hereby
ORDERED AND ADJUDGED:
1. Carlos D. Kochen, as President of Defendant, GROUP NEXUS FIVE, INC. /dba/
WORTH IT, is hereby ordered to answer Plaintiffs Post Judgment Interrogatories and Fact
Information Sheet, within ten (10) days from the date of this Order.
IT IS FURTHER ORDERED AND ADJUDGED that in the event Carlos D. Kochen, as the
President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, fails to respond to
Plaintiff's discovery within such time then it shall appear before the Court on the XD day of
Serene P, 2018, at_ 30 Camy p.m., before the Honorable i
Caryn C. Schwartz, Miami-Dade County Circuit Court, North Dade Justice Center, 15555 Biscayne
Boulevard, Room NDJC 0; iami, Florida 33160, to show cause why this Court should not find
the Defendant in contempt of Court for having failed to comply with this Court's Order to answer
the Post Judgment Interrogatories and Fact Information Sheet. If Carlos D. Kochen, as the
President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, fails to appear on the
above date or fail to comply with this Court's Order to answer the Interrogatories, this Court may
issue a Writ of Bodily Attachment for its failure to comply with Court's Orders and bring Carlos D.
Kochen, as the President of the Defendant before this Court. Carlos D. Kochen, as the President
of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, may purge itself by complying with
x \\cohen-server\DatalWork\Global Realty\Worth It\Order to Show Cause.revised.wpd . |
pv “Prov bed.
No Conformed Ve Riad ev EaveloCase No. 2017-008051-CA-01, Section 41
the Court's Order, and answering the Post Judgment Interrogatories and Fact Information Sheet
before the date of the above hearing. If, in the event Carlos D. Kochen, as the President of the
Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, complies with this Court's Order, or
settles the above-captioned cause with Plaintiff, then in that event Plaintiff shall promptly notify
this Court in order to cancel the above-referenced hearing.
A copy of this Order shall be personally served upon Carlos D. Kochen as the President of
the Defendant by the Office of the Sheriff of Miami-Dade County, Florida, o!
authorized by Florida Law.
DONE AND ORDERED in Miami, Miami-Dade Zounty, i day of
2018.
rocess server
CARYN C. SCHWARTZ, Acting Circuit Court Judge
Copies Furnished to:
Richard S. Cohen, Esq. - rscohen@rscohenesqlaw.com
Jason L. Cohen, Esq. - jcohen@rscohenesqlaw.com
Law Offices of Richard S. Cohen, LLC
811-A North Olive Avenue
West Palm Beach, Florida 33401
SIGNED ANID DATED
IDGE CARYN CANNER SCI
COUNTY COURT JUDGE
GROUP NEXUS FIVE, INC. /dba/ WORTH IT
% Carlos Kochen, President and Director
7401 N.W. 32™ Avenue, Rear
Miami, Florida 33147
\\cohen-server\Data\Work\Global Realty\Worth It\Order to Show Cause.revised.wpd -2-Law Offices of Richard S. Cohen, LLC
811-A North Olive Avenue
West Palm Beach, Florida 33401
ad E-Mail: rscohen@rscohenesalaw.com
Phone: 561-659-0901 Fax: 561-659-0902
July 2, 2018
VIA Certified US Mail: 5 SB
Honorable Caryn Schwartz Ba es 3
North Dade Justice Center Courthouse 33 69
15555 Biscayne Blvd., NDJC 210 zBS we a
Miami, FL 33160 Ske OS
S22 = &
Re: 79 Biscayne Plaza, LLC v. Group Nexus Five, Inc. /dba/ Worth It “24 5 3
Case No.: 2017-008051-CA-01, Section 41 ay a8 eo?
Dear Judge Schwartz, “
In connection with the June 19, 2018 Hearing on the Plaintiffs Motion for Sanctions and/or
Show Cause Order and Your Honor’s memorandum dated June 26, 2018, enclosed please find a
revised proposed Show Cause Order for your Honor’s consideration. Should no further changes
be needed, we request that the show cause hearing date be approximately three months out so we
have sufficient time to receive the executed Order and have our process server serve the Defendant.
Should the proposed Show Cause Order meet with Your Honor’s approval, we kindly ask that
Your Honor execute the same and have your Judicial Assistant send conformed copies to the
Parties via the the enclosed stamped and self-addressed envelopes. Should anything further be
required in this regard, please do not hesitate to have your Judicial Assistant contact our office.
Thank you for your time and consideration.
Respectfully Submitted,
—
7
>. Jason en, Esq.
(enclosures as stated)
CC: Worth It
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IN THE CIRCUIT COURT OF THE ELEVENTH | JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2017-008051-CA-01, Section 41 | 79 BISCAYNE PLAZA, LLC, a Florida limited liability | company, Plaintiff, v GROUP NEXUS FIVE, INC. /dba/ WORTH IT, a Florida corporation, | Defendant./ | ORDER TO SHOW CAUSE THIS CAUSE came on to be heard on June 19, 2018, upon Plaintiff's Motion For the Imposition of Sanctions and/or in the Alternative an Order to Show Cause, and the Court, having heard the argument of counsel and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED: 1. Carlos D. Kochen, as President of Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, is hereby ordered to answer Plaintiffs Post Judgment Interrogatories and Fact Information Sheet, within ten (10) days from the date of this Order. IT IS FURTHER ORDERED AND ADJUDGED that in the event Carlos D. Kochen, as the President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, fails to respond to Plaintiff's discovery within such time then it shall appear before the Court on the XD day of Serene P, 2018, at_ 30 Camy p.m., before the Honorable i Caryn C. Schwartz, Miami-Dade County Circuit Court, North Dade Justice Center, 15555 Biscayne Boulevard, Room NDJC 0; iami, Florida 33160, to show cause why this Court should not find the Defendant in contempt of Court for having failed to comply with this Court's Order to answer the Post Judgment Interrogatories and Fact Information Sheet. If Carlos D. Kochen, as the President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, fails to appear on the above date or fail to comply with this Court's Order to answer the Interrogatories, this Court may issue a Writ of Bodily Attachment for its failure to comply with Court's Orders and bring Carlos D. Kochen, as the President of the Defendant before this Court. Carlos D. Kochen, as the President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, may purge itself by complying with x \\cohen-server\DatalWork\Global Realty\Worth It\Order to Show Cause.revised.wpd . | pv “Prov bed. No Conformed Ve Riad ev EaveloCase No. 2017-008051-CA-01, Section 41 the Court's Order, and answering the Post Judgment Interrogatories and Fact Information Sheet before the date of the above hearing. If, in the event Carlos D. Kochen, as the President of the Defendant, GROUP NEXUS FIVE, INC. /dba/ WORTH IT, complies with this Court's Order, or settles the above-captioned cause with Plaintiff, then in that event Plaintiff shall promptly notify this Court in order to cancel the above-referenced hearing. A copy of this Order shall be personally served upon Carlos D. Kochen as the President of the Defendant by the Office of the Sheriff of Miami-Dade County, Florida, o! authorized by Florida Law. DONE AND ORDERED in Miami, Miami-Dade Zounty, i day of 2018. rocess server CARYN C. SCHWARTZ, Acting Circuit Court Judge Copies Furnished to: Richard S. Cohen, Esq. - rscohen@rscohenesqlaw.com Jason L. Cohen, Esq. - jcohen@rscohenesqlaw.com Law Offices of Richard S. Cohen, LLC 811-A North Olive Avenue West Palm Beach, Florida 33401 SIGNED ANID DATED IDGE CARYN CANNER SCI COUNTY COURT JUDGE GROUP NEXUS FIVE, INC. /dba/ WORTH IT % Carlos Kochen, President and Director 7401 N.W. 32™ Avenue, Rear Miami, Florida 33147 \\cohen-server\Data\Work\Global Realty\Worth It\Order to Show Cause.revised.wpd -2-Law Offices of Richard S. Cohen, LLC 811-A North Olive Avenue West Palm Beach, Florida 33401 ad E-Mail: rscohen@rscohenesalaw.com Phone: 561-659-0901 Fax: 561-659-0902 July 2, 2018 VIA Certified US Mail: 5 SB Honorable Caryn Schwartz Ba es 3 North Dade Justice Center Courthouse 33 69 15555 Biscayne Blvd., NDJC 210 zBS we a Miami, FL 33160 Ske OS S22 = & Re: 79 Biscayne Plaza, LLC v. Group Nexus Five, Inc. /dba/ Worth It “24 5 3 Case No.: 2017-008051-CA-01, Section 41 ay a8 eo? Dear Judge Schwartz, “ In connection with the June 19, 2018 Hearing on the Plaintiffs Motion for Sanctions and/or Show Cause Order and Your Honor’s memorandum dated June 26, 2018, enclosed please find a revised proposed Show Cause Order for your Honor’s consideration. Should no further changes be needed, we request that the show cause hearing date be approximately three months out so we have sufficient time to receive the executed Order and have our process server serve the Defendant. Should the proposed Show Cause Order meet with Your Honor’s approval, we kindly ask that Your Honor execute the same and have your Judicial Assistant send conformed copies to the Parties via the the enclosed stamped and self-addressed envelopes. Should anything further be required in this regard, please do not hesitate to have your Judicial Assistant contact our office. Thank you for your time and consideration. Respectfully Submitted, — 7 >. Jason en, Esq. (enclosures as stated) CC: Worth It