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Filing # 142558900 E-Filed 01/24/2022 09:47:49 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff
CASE NO: 2019-CA-8558-Cl
Vv.
MFI-MIAMI HOLDINGS, LLC and
STEPHEN J. DIBERT,
Defendants.
/
MFI-MIAMI HOLDINGS, LLC’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE
Defendant, MFI-MIAMI HOLDINGS, LLC., by and through undersigned counsel and
pursuant to F.S. §90.202 — 203, and request the court to take judicial notice of:
Composite Exhibit A - 8 civil cases in Pinellas County that were voluntarily dismissed
consisting of:
Stopa v. Brown - case 20-65-Cl
Stopa v. Beam — case 20-262-Cl
Stopa v. Chane — case 20-261-Cl'
Stopa v. Diaz — case 20-62-Cl
Stopa v. Florida Law Advisers — case 20-63-Cl
Stopa v. Hurt — case 20-198-Cl
Stopa v. Jeeves — case 20-254-Cl
Stopa v. Progressive Divorce — 20-199-Cl
MEMORANDUM OF LAW
COMPULSORY JUDICIAL NOTICE
Fla. Stat. §90.203, sets forth requirements for compulsory judicial notice and provides:
A court shall take notice of any matter in section 90.202 when a party requests it and;
(1) gives each adverse party timely written notice of the request, proof of which is filed with
the court, to enable the adverse party to prepare to meet the request; and (2) furnishes the
court with sufficient information to enable it to take judicial notice of the matter. [Emphasis
added].
Pursuant to §§90.202(6) and 90.203, Florida statutes, MFI—-Miami Holdings, LLC.,
requests that this Court take judicial notice of the judicial records specifically identified herein
and attached hereto. As a result of the instant filing, the opposing party, Mark P. Stopa has
1 This case resolved with a dismissal between the parties, but not before the plaintiff filed an amended complaint seeking
to create conflict between the defendant and his chosen counsel by intentionally adding the attorney of record into the
amended complaint.
***ELECTRONICALLY FILED 01/24/2022 09:47:49 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
received notice of the intent to have the Court rely upon the attached records and to take
judicial notice of same. The attached records are relevant to the proceedings pending before
this court and address issues pending before this court.
DISCRETIONARY JUDICIAL NOTICE
Section 90.202, Fla. Stat. provides for matters that may be judicially noticed by a court.
Subsection (6) of the statute specifically provides that a court may take judicial notice of
records of any court of the State or of any court of record of the United States or of any other
state, territory, or jurisdiction of the United States. Judicial notice may be taken of all judicial
records. See Dufour v. State, 69 So.3d 235 (Fla. 2011); Allstate Ins. Co. v. Grayhound Rent-
A- Car, Inc.,586 So.2d 482, 483 (Fla. 4" DCA 1991) (citing Florida Evidence Code
§90.202(6)). See also Hunt v. State, 613 So.2d 893, 898 n.5 (Fla. 1992)(granting appellant's
motion to judicially notice the record of another case.); Falls v. Nat'l Environ. Prods., 665
So.2d 320 (Fla. 4'" DCA 1995)(explaining that it is proper for a trial court and appellate court
to take judicial notice of the pleadings and briefs of other actions filed that bear a relationship
to the case at bar.)
WHEREFORE, MFI-Miami Holdings, LLC., hereby requests this Honorable Court to
take judicial notice of the attached and referenced judicial records.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
email to markpstopa@gmail.com this 24" day of January 2022.
Samantha Stevins
Samantha Stevins, Esq.
e-mail: stevinslawfirm@gmail.com
2681 Airport Road South, Suite C-104
Naples, Florida 34112
Phone (239) 300-4417
COMPOSITE
EXHIBIT
A
Case Number:20-000262-CI
Filing # 101625104 E-Filed 01/16/2020 02:05:35 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff,
Case No.:
Vv.
DORAN, BEAM & FARRELL, P.A.,
Defendant.
COMPLAINT
Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, DORAN, BEAM & FARRELL,
P.A. (“P.A.”), and alleges:
BACKGROUND
1 P.A. is a Florida corporation. It operates as a law firm, practicing in the area of
personal injury.
2. P.A. uses the website https://pascoinjurylaw.com (“the Website”) as a means of
advertising services to the public and conducting business for profit.
3 P.A. is not a legitimate media source. The Website is not a “news medium” under
Florida law. Rather, P.A. is a for-profit business.
4 STOPA used to be a practicing attorney in Florida, FBN 550507.
5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of
foreclosure defense and consumer protection. During this time, STOPA successfully represented
thousands of Florida consumers, including those in Clearwater, St. Petersburg, New Port Richey,
and the surrounding areas.
6. All conditions precedent have been met, waived, or otherwise satisfied.
***ELECTRONICALLY FILED 01/16/2020 02:05:33 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein
accrued here.
COUNT ONE
8 This is an action for actual damages in excess of $30,000 (exclusive of interest,
attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08.
9. STOPA realleges and incorporates by references paragraphs 1-7 above.
10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation
thereof, e.g. “Attorney Mark Stopa,” for the purpose of advertising P.A. for business purposes
without STOPA’s consent and without any valid license for such use.
11. For example, but without limitation, P.A. has operated a Google Adwords account
through Google, an internet provider, and set up that account in such a manner that anyone who
searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Attorney Mark Stopa”
would be directed to the Website.
12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial
purposes without STOPA’s consent and without a valid license.
13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA
is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and
amounts which would have constituted a reasonable royalty. These actions also constitute a
deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar.
After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has
never practiced in the area of personal injury.
14, STOPA’s actual damages include, but are not limited to, lost business opportunities
resulting from the use of his name on the internet without his consent. Among these damages are
a $15 million business deal which did not close because investors for that deal saw the way
STOPA’s name was being used on the internet.
WHEREFORE STOPA demands the following relief:
A. Trial by Jury
B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name
for any advertising or commercial purposes, either related to the P.A., the Website, or
otherwise
Actual damages, both general and special
Punitive damages
All amounts which would have constituted a reasonable royalty for use of STOPA’s
name and likeness
F All other relief that this Court deems proper and just
This January,
14th day of 2020
Respectfully submitted,
4 D
c/o Segal & Schuh Law Group, P.L.
18167 U.S. Highway 19 North
Suite 100
Clearwater, Florida 33764
Telephone: (727) 667-4808
Email: markpstopa@gmail.com
I#: 2021071810 BK: 21419 PG: 1265, 03/05/2021 at 08:29 AM, RECORDING 3 KEN
BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK:
CLKPR14
CIRCUIT COURT, PINELLAS COUNTY, FLORIDA \
CIRCUIT CIVIL DIVISION ai Cn
A=
aim
20
MASTER ORDER DISMISSAL
ae
CALENDAR NO. 030221 — Section 7
THIS CAUSE, came on upon the Court's own motion, pursuant to Rule of Civil
Procedure 1.420(e), that the cause would be dismissed on MARCH 02, 2021 . The
Court finds that a Notice of Lack of Prosecution was provided, there was no record
activity during the 10 months immediately preceding service of the foregoing notice;
there was no record activity during the 60 days immediately following service of the
foregoing notice; no stay has been issued or approved by the Court; and no party has
shown good cause why the action should remain pending. ACCORDINGLY,
IT IS ORDERED that the cases on the attached listing are dismissed for lack of
prosecution.
DONE AND ORDERED in chambers in Clearwater/St. Petersburg, Pinellas
County, Florida, this Q , day of _ “YW t— , 2021.
42-6 Salat
Hon Patricia Ann Muscarella
PINELLAS COUNTY FL OFF. REC. BK 21419 PG 1266
03/02/2021 Cases Scheduled for Dismissal Section 7
DISMISSAL LOP 07 Pinellas County, Florida
Case Number SHIRLEY ANGELO, etal vs. R J REYNOLDS TOBACCO COMPANY, et al
09-011946-Cl
PLAINTIFF(S) LOUIS ANGELO; SHIRLEY ANGELO
DEFENDANT(S) LIGGETT GROUP LLC; LORILLARD TOBACCO COMPANY; PHILIP MORRIS
USA INC; R J REYNOLDS TOBACCO COMPANY; VECTOR GROUP LTD INC
Case Number J ALLEN MILLER Vs. CHASE BANKCARD SERVICES INC
13-001579-Cl
PLAINTIFF(S) J ALLEN MILLER
DEFENDANT(S) CHASE BANKCARD SERVICES INC
Case Number LOUIS TADDIA Vs. NACHMANS NATIVE SEAFOOD INC
15-001123-Cl
PLAINTIFF(S) LOUIS TADDIA
DEFENDANT(S) NACHMANS NATIVE SEAFOOD INC
Case Number LUCIEN PRICE, et al Vs. BIG BROTHERS CAPITAL INC, et al
17-004864-CI
PLAINTIFF(S) ASHLEY PRICE; LUCIEN PRICE
DEFENDANT(S) BIG BROTHERS CAPITAL INC; VITALY CHEPURNOV, INDIVIDUALLY
Case Number JILL FISCHER-PETERS Vs. NADIA ONEAL, DDS
17-004998-Cl
PLAINTIFF(S) JILL FISCHER-PETERS
DEFENDANT(S) NADIA ONEAL, DDS
Case Number MARK ELLIOTT GREEN, et al Vs. JOELLE TONEY, et al
18-003201-Cl
PLAINTIFF(S) JENNIFER LEE GREEN; MARK ELLIOTT GREEN
DEFENDANT(S) DIOP ADONLIN DAOUDA ASSANVO; JOELLE TONEY
Case Number AMICA MUTUAL INSURANCE COMPANY Vs. DUKE ENERGY FLORIDA LLC
18-004451-Cl
PLAINTIFF(S) AMICA MUTUAL INSURANCE COMPANY
DEFENDANT(S) DUKE ENERGY FLORIDA LLC
Case Number NAUSSERA ZADEH Vs. MIKE TWITTY, et al
18-005656-Cl
PLAINTIFF(S) NAUSSERA ZADEH
DEFENDANT(S) CHARLES THOMAS; DIANE GONZALES NELSON; E. LEON BIEGALSKI;
MAURICE GOGARTY; MIKE TWITTY; PAMELA MARY DUBOV
Case Number DANIEL RODRIGUEZ-VAZQUEZ Vs. LARRY DIMMITT CADILLAC INC
19-000306-CI
PLAINTIFF(S) DANIEL RODRIGUEZ-VAZQUEZ
DEFENDANT(S) LARRY DIMMITT CADILLAC INC
Case Number Us BANK NATIONAL ASSOCIATION Vs. RENE LOPEZ, et al
19-001020-CI
PLAINTIFF(S) US BANK NATIONAL ASSOCIATION
DEFENDANT(S) ANY AND ALL UNKNOWN PARTIES; BRIAN MARLOW; FLORIDA HOUSING
FINANCE CORPORATION; RENE LOPEZ; STACIA LOPEZ
PINELLAS COUNTY FL OFF. REC. BK 21419 PG 1267
03/02/2021 Cases Scheduled for Dismissal Section 7
DISMISSAL LOP 07 Pinellas County, Florida
Case Number SUSAN WEBB Vs. WAL-MART STORES EAST LP
19-001204-CI
PLAINTIFF(S) SUSAN WEBB
DEFENDANT(S) WAL-MART STORES EAST LP
Case Number DISCOVER BANK Vs. IAN CHURCH
19-003356-CI
PLAINTIFF(S) DISCOVER BANK
DEFENDANT(S) IAN CHURCH
Case Number OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY Vs. HUGH W
ROBINSON
19-003452-CI OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY
PLAINTIFF(S)
DEFENDANT(S) HUGH W ROBINSON
Case Number EMILY CORPORATION Vs. EMERALD MEDICAL SUPPLY INC, et al
19-004854-Cl
PLAINTIFF(S) EMILY CORPORATION
DEFENDANT(S) EMERALD MEDICAL SUPPLY INC; JONATHAN TANNER
Case Number J LONG REALTY GROUP LLC, et al Vs. ALVIN CASANOVA
19-005030-Cl
PLAINTIFF(S) 4 LONG REALTY GROUP LLC; KSK HOMES INC
DEFENDANT(S) ALVIN CASANOVA
Case Number LOUISE C WIEBE, TRUSTEE Vs. CAGNI CONSTRUCTION COMPANY, et al
19-005938-Cl
PLAINTIFF(S) LOUISE C WIEBE, TRUSTEE
DEFENDANT(S) CAGNI CONSTRUCTION COMPANY; MARK CAGNI
Case Number DIRECT CAPITAL Vs. PRECISION AUTO TINT AND DESIGN CORP, et al
19-008308-Cl
PLAINTIFF(S) DIRECT CAPITAL
DEFENDANT(S) CHRISTOPHER PAINE; PRECISION AUTO TINT AND DESIGN CORP
Case Number ll
Case Number ANGELINA PARKER GREEN Vs. ROOSEVELT BOULEVARD APARTMENTS LLC _|
20-000431-Cl
PLAINTIFF(S) ANGELINA PARKER GREEN
DEFENDANT(S) ROOSEVELT BOULEVARD APARTMENTS LLC
Case Number:20-000065-CI
Filing # 101151288 E-Filed 01/06/2020 11:25:41 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff,
Case No.:
Vv.
BROWN & ASSOCIATES LAW & TITLE, P.A.,
Defendant.
COMPLAINT
Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, BROWN & ASSOCIATES
LAW & TITLE, P.A. (“P.A.”), and alleges:
BACKGROUND
1 P.A. is a Florida professional association. It operates as a law firm, practicing in
the area of foreclosure defense.
2. P.A. uses the website https://www.tampaforeclosurelaw.com (“the Website”) as a
means of advertising services to the public and conducting business for profit. Among these
services is foreclosure defense.
3 P.A. is not a legitimate media source. The Website is not a “news medium” under
Florida law. Rather, P.A. is a for-profit business in the area of foreclosure defense, among others.
4. STOPA used to be a practicing attorney in Florida, FBN 550507.
5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of
foreclosure defense and consumer protection. During this time, STOPA successfully represented
thousands of Florida consumers.
6. All conditions precedent have been met, waived, or otherwise satisfied.
***ELECTRONICALLY FILED 01/06/2020 11:25:39 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein
accrued here.
COUNT ONE
8 This is an action for actual damages in excess of $15,000 (exclusive of interest,
attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08.
9. STOPA realleges and incorporates by references paragraphs 1-7 above.
10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation
thereof, e.g. “Attorney Mark Stopa,” for the purpose of advertising P.A. for business purposes
without STOPA’s consent and without any valid license for such use.
11. For example, but without limitation, P.A. has operated a Google Adwords account
through Google, an internet provider, and set up that account in such a manner that anyone who
searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Attorney Mark Stopa”
would be directed to the Website.
12. In addition, when STOPA ceased practicing law, P.A. obtained possession of his
client list, then solicited many hundreds of Florida consumers by telling them that P.A. would
defend them “in the same way that Mark Stopa did,” or words to that effect. In fact, one of the
agents of P.A. who made these calls previously worked in a similar capacity for STOPA.
13. By acting in such fashion, P.A. has used STOPA’s name for its own commercial
purposes without STOPA’s consent and without a valid license.
14, The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA
is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and
amounts which would have constituted a reasonable royalty.
15. STOPA’s actual damages include, but are not limited to, lost business opportunities
resulting from the use of his name on the internet without his consent. Among these damages are
a $15 million business deal which did not close because investors for that deal saw the way
STOPA’s name was being used on the internet.
WHEREFORE STOPA demands the following relief:
A. Trial by Jury
B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name
for any advertising or commercial purposes, either related to the P.A., the Website, or
otherwise
Actual damages, both general and special
Punitive damages
All amounts which would have constituted a reasonable royalty for use of STOPA’s
name and likeness
F All other relief that this Court deems proper and just
This Sth
January,
day of 2020
Respectfully submitted,
s/ Mark P. Stopa
c/o Segal & Schuh Law Group, P.L.
18167 U.S. Highway 19 North
Suite 100
Clearwater, Florida 33764
Telephone: (727) 667-4808
Email: markpstopa@gmail.com
I#: 2021375509 BK: 21811 PG: 1460, 11/18/2021 at 08:56 AM, RECORDING 2 KEN
BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK:
CLKDU17
CIRCUIT COURT, PINELLAS COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
MASTER ORDER DISMISSAL
CALENDAR NO. 110921 - Section 15
THIS CAUSE, came on upon the Court's own motion, pursuant to Rule of Civil
Procedure 1.420(e), that the cause would be dismissed on November 09, 2021. The
Court finds that a Notice of Lack of Prosecution was provided, there was no record
activity during the 10 months immediately preceding service of the foregoing notice;
there was no record activity during the 60 days immediately following service of the
foregoing notice; no stay has been issued or approved by the Court; and no party has
shown good cause why the action should remain pending. ACCORDINGLY,
IT IS ORDERED that the cases on the attached listing are dismissed for lack of
prosecution.
DONE AND ORDERED in chambers in Clearwater/St-Petersburg, Pinellas
oui Florida, this , day of , 2021.
in George M Jirotka
Filed, NOV 17, 2021, 9:55, Ken Burke, Clerk of the Circuit Court and Comptroller, Pinellas County
PINELLAS COUNTY FL OFF. REC. BK 21811 PG 1461
11/09/2021 Cases Scheduled for Dismissal Section 15
DISMISSAL LOP 15 Pinellas County, Florida
Case Number ALANA CAMPOS SOUZA, et al Vs. VEGAS MANAGEMENT LLC
18-008249-CI ALANA CAMPOS SOUZA; BROOKE TAYLOR; JOANNA KRUPA; LINA
PLAINTIFF(S) POSADA; PAOLA CANAS; TIFFANY TOTH GRAY
DEFENDANT(S) VEGAS MANAGEMENT LLC
Case Number JESSICA CASTALDO Vs. WRD LINCOLN SHORES LLC
19-000696-CI
PLAINTIFF(S) JESSICA CASTALDO
DEFENDANT(S) WRD LINCOLN SHORES LLC
Case Number PORTFOLIO RECOVERY ASSOCIATES LLC Vs. SCOTTT SHIELDS
19-004664-CI
PLAINTIFF(S) PORTFOLIO RECOVERY ASSOCIATES LLC
DEFENDANT(S) SCOTT T SHIELDS
Case Number AARON CORLEY Vs. PINELLAS COUNTY JAIL
19-005582-Cl
PLAINTIFF(S) AARON CORLEY
DEFENDANT(S) PINELLAS COUNTY JAIL
|
Case Number RONALD SPEER Vs. TRENT ROAD LLC
20-001741-Cl
PLAINTIFF(S) RONALD SPEER
DEFENDANT(S) TRENT ROAD LLC
Case Number ROBERT PARKS, et al Vs. SOUTHERN OAK INSURANCE COMPANY
20-004500-Cl
PLAINTIFF(S) INMACULADA PARKS; ROBERT PARKS
DEFENDANT(S) SOUTHERN OAK INSURANCE COMPANY,
| Case Number LAURIE HIGDON Vs. TWAIN THORNTON
20-004662-CI
PLAINTIFF(S)LAURIE HIGDON
= DEFENDANT(S) | TWAIN THORNTON
Filed, NOV 17, 2021, 9:55, Ken Burke, Clerk of the Circuit Court and Comptroller, Pinellas County
Filing # 102340126 E-Filed 01/28/2020 12:41:22 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff,
Case No.: 20-261-CI
Vv.
LAW OFFICE OF LAURIE R CHANE, P.A.,
Defendant.
AMENDED COMPLAINT
Plaintiff, MARK P. STOPA (“STOPA”), sues Defendants, LAW OFFICE OF LAURIE R.
CHANE, P.A. (“P.A.”), JASON SAMPSON (“SAMPSON”), and VENERABLE LAW, LLP
(“VENERABLE”), and alleges:
BACKGROUND
1 P.A. is a Florida professional association. It operates as a law firm, practicing in
the area of family law.
2 P.A. uses the website https://chanelaw.com (“the Website”) as a means of
advertising services to the public and conducting business for profit.
3 P.A. is not a legitimate media source. The Website is not a “news medium” under
Florida law. Rather, P.A. is a for-profit business.
4. STOPA used to be a practicing attorney in Florida, FBN 550507.
5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of
foreclosure defense and consumer protection. During this time, STOPA successfully represented
thousands of Florida consumers, including those in Clearwater, St. Petersburg, and the surrounding
areas.
***ELECTRONICALLY FILED 01/28/2020 12:41:22 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
6. All conditions precedent have been met, waived, or otherwise satisfied.
7
Venue lies in Pinellas County, Florida, as the causes of action alleged herein
accrued here.
COUNT ONE
8 This is an action for actual damages against P.A. in excess of $30,000 (exclusive
of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. §
540.08.
9. STOPA realleges and incorporates by references paragraphs 1-7 above.
10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation
thereof, e.g. “Clearwater Lawyer Mark Stopa,” for the purpose of advertising P.A. for business
purposes without STOPA’s consent and without any valid license for such use.
11. For example, but without limitation, P.A. has operated a Google Adwords account
through Google, an internet provider, and set up that account in such a manner that anyone who
searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Clearwater Lawyer
Mark Stopa” would be directed to the Website.
12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial
purposes without STOPA’s consent and without a valid license.
13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA
is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and
amounts which would have constituted a reasonable royalty. These actions also constitute a
deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar.
After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has
never practiced in the area of family law.
14. STOPA’s actual damages include, but are not limited to, lost business opportunities
resulting from the use of his name on the internet without his consent. Among these damages are
a $15 million business deal which did not close because investors for that deal saw the way
STOPA’s name was being used on the internet.
WHEREFORE STOPA demands the following relief:
A. Trial by Jury
B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name
for any advertising or commercial purposes, either related to the P.A., the Website, or
otherwise
Actual damages, both general and special
Punitive damages
All amounts which would have constituted a reasonable royalty for use of STOPA’s
name and likeness
All other relief that this Court deems proper and just
COUNT TWO
15. This is an action for damages against SAMPSON, VENERABLE, and P.A. for
abuse of process in excess of $30,000, exclusive of interest, attorney’s fees, and costs.
16. SAMPSON isa licensed Florida attorney.
17. VENERABLE, an LLP, conducts business as a law firm.
18. SAMPSON is an agent and employee of VENERABLE.
19. All actions taken by SAMPSON, as described herein, were taken within the course
and scope of his employment with VENERABLE.
20. At all times relevant, SAMPSON was an agent of P.A. and acting within the course
and scope of his representation of P.A., rendering P.A. vicariously liable for his actions.
21. On or about January 21, 2020, SAMPSON contacted STOPA in response to his
filing of the original Complaint in this lawsuit (“the Instant Case”) against P.A., indicating that
SAMPSON and VENERABLE would be counsel for P.A.
22. SAMPSON’S first act as counsel was to serve a motion upon STOPA for P.A.
asserting that the Complaint against was frivolous and demanding that STOPA withdraw it (“the
57.105 Motion’).
23. Surprised to see an attorney levy such aggressive, heavy-handed assertions right off
the bat — based on what was obviously a false and incomplete understanding of the facts —STOPA
‘alled SAMPSON via telephone to discuss the Instant Case in an attempt to reach a resolution.
24. During that conversation, SAMPSON criminally extorted STOPA.
25. In particular, SAMPSON apprised STOPA that he had “no idea” the “backlash”
that was going to be unleashed on STOPA as a result of his filing the Instant Case and several
others STOPA had filed like it. When STOPA expressed his incredulity at what SAMPSON meant
by that statement, SAMPSON expressed his view that STOPA’s filing of the Instant Case was
“criminal extortion” and that “the statewide prosecutor does as well.”
26. Viewed in totality, the import of SAMPSON’s statements to STOPA were that he
had spoken to the statewide prosecutor about the Instant Case and that STOPA should be fearful
about what the prosecutor’s office would do to him because of his prosecution of the Instant Case
and others like it. Notably, this conversation took place on the very day that SAMPSON had
served STOPA with the 57.105 Motion and in the very conversation in which SAMPSON was
trying to urge STOPA to voluntarily dismiss the Instant Case.
20 SAMPSON’s filing of the 57.105 Motion and subsequent conversation were an
illegal effort to induce STOPA to dismiss the Instant Case against his client through criminal
misconduct, i.e. extortion.
28. SAMPSON’: actions are an abuse of process by operation of law.
29: As a result of SAMPSON’s abuse of process, STOPA has been damaged. Such
damages include, but are not limited to, emotional distress and special damages in the form of
attorney’s fees STOPA incurred with counsel to discuss his conversation with SAMPSON.
WHEREFORE STOPA demands the following relief from SAMPSON, P.A., and
VENERABLE:
A Trial by Jury
B. Actual damages, both general and special
Cc All other relief that this Court deems proper and just
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been furnished via email
to Jason Sampson, Esq., jsampson@venerablelawfirm.com on this
Respectfully submitted,
s/ Mark P. Stopa
c/o Segal & Schuh Law Group, P.L.
18167 U.S. Highway 19 North
Suite 100
Clearwater, Florida 33764
Telephone: (727) 667-4808
Email: markpstopa@gmail.com
Case Number:20-000261-CI
Filing # 101630499 E-Filed 01/16/2020 02:02:44 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff,
Case No.:
Vv.
LAW OFFICE OF LAURIE R CHANE, P.A.,
Defendant.
COMPLAINT
Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, LAW OFFICE OF LAURIE R.
CHANE, P.A. (“P.A.”), and alleges:
BACKGROUND
1 P.A. is a Florida professional association. It operates as a law firm, practicing in
the area of family law.
2. P.A. uses the website https://chanelaw.com (“the Website”) as a means of
advertising services to the public and conducting business for profit.
3 P.A. is not a legitimate media source. The Website is not a “news medium” under
Florida law. Rather, P.A. is a for-profit business.
4 STOPA used to be a practicing attorney in Florida, FBN 550507.
5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of
foreclosure defense and consumer protection. During this time, STOPA successfully represented
thousands of Florida consumers, including those in Clearwater, St. Petersburg, and the surrounding
areas.
6. All conditions precedent have been met, waived, or otherwise satisfied.
***ELECTRONICALLY FILED 01/16/2020 02:02:42 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein
accrued here.
COUNT ONE
8 This is an action for actual damages in excess of $30,000 (exclusive of interest,
attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08.
9. STOPA realleges and incorporates by references paragraphs 1-7 above.
10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation
thereof, e.g. “Clearwater Lawyer Mark Stopa,” for the purpose of advertising P.A. for business
purposes without STOPA’s consent and without any valid license for such use.
11. For example, but without limitation, P.A. has operated a Google Adwords account
through Google, an internet provider, and set up that account in such a manner that anyone who
searched Google with the phrase “Mark Stopa,” and variations thereof, ¢.g. “Clearwater Lawyer
Mark Stopa” would be directed to the Website.
12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial
purposes without STOPA’s consent and without a valid license.
13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA
is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and
amounts which would have constituted a reasonable royalty. These actions also constitute a
deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar.
After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has
never practiced in the area of family law.
14, STOPA’s actual damages include, but are not limited to, lost business opportunities
resulting from the use of his name on the internet without his consent. Among these damages are
a $15 million business deal which did not close because investors for that deal saw the way
STOPA’s name was being used on the internet.
WHEREFORE STOPA demands the following relief:
A. Trial by Jury
B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name
for any advertising or commercial purposes, either related to the P.A., the Website, or
otherwise
Actual damages, both general and special
Punitive damages
All amounts which would have constituted a reasonable royalty for use of STOPA’s
name and likeness
F All other relief that this Court deems proper and just
This January,
14th day of 2020
Respectfully submitted,
s/ Mark P. Stopa
c/o Segal & Schuh Law Group, P.L.
18167 U.S. Highway 19 North
Suite 100
Clearwater, Florida 33764
Telephone: (727) 667-4808
Email: markpstopa@gmail.com
Case Number:20-000062-CI
Filing # 101149182 E-Filed 01/06/2020 11:10:37 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PINELLAS COUNTY, FLORIDA
MARK P. STOPA,
Plaintiff,
Case No.:
Vv.
ROY DIAZ and
SHD LEGAL GROUP, P.A.,
Defendants.
COMPLAINT
Plaintiff, MARK P. STOPA (“STOPA”), sues Defendants, ROY DIAZ (“DIAZ”) and SHD
LEGAL GROUP, P.A. (“P.A.”), and alleges:
BACKGROUND
1 DIAZ is an attorney, licensed to practice law in Florida.
2. P.A. is a Florida professional association through which P.A. is both employed and
conducts business.
3 DIAZ and P.A. use the website https://shdlegalgroup.com (“the Website”) as a
means of advertising services to the public and conducting business for profit. Chief among the
services offered is the prosecution of foreclosure lawsuits on behalf of banks, lenders, and
servicers.
4 P.A. is not a legitimate media source. The Website is not a “news medium” under
Florida law. Rather, P.A. is a for-profit business in the area of foreclosure law. The blog on the
Website is a way for DIAZ and P.A. to attract internet traffic and solicit/procure business.
5 DIAZ created the blog on the Website and maintains control over its contents.
6. STOPA used to be a practicing attorney in Florida, FBN 550507.
1
***ELECTRONICALLY FILED 01/06/2020 11:10:36 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
7. From 2008 through 2018, STOPA’s practice consisted almost exclusively of
foreclosure defense and consumer protection. During this time, STOPA successfully represented
thousands of Florida consumers. As a result, STOPA litigated many hundreds of cases against
DIAZ, P.A., and their clients.
8 All conditions precedent have been met, waived, or otherwise satisfied.
9. Venue lies in Pinellas County, Florida, as the causes of action alleged herein
accrued here.
COUNT ONE
10. This is an action for actual damages in excess of $15,000 (exclusive of interest,
attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08.
11. STOPA realleges and incorporates by references paragraphs 1-9 above.
12. In 2018, DIAZ and P.A. caused to be published an article on the Website (“the
Article”), entitled “Defense Attorney Mark Stopa Faces Potential Disbarment,”
https://shdlegalgroup.com/defense-attorney-mark-stopa-faces-potential-disbarment
13. DIAZ and P.A.’s purpose in publishing the Article was to generate internet traffic
and to advertise and solicit business by use of STOPA’s name.
14. Given the frequency with which he prevailed on behalf of consumers in the
foreclosure arena, banks, lenders, and servicers hated STOPA. These were the entities that DIAZ
and P.A. represented. DIAZ and P.A.’s posting of the Article was their way of telling their clients
“retain us for more cases; we will go after STOPA for you.” It was, quite simply, a way to advertise
and solicit business.
15. The actions of DIAZ and P.A. were made in bad faith and with actual malice.
16. The actions of DIAZ and P.A. constitute violations of Fla. Stat. § 540.08, for which
STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive
telief, and amounts which would have constituted a reasonable royalty.
17. STOPA’s actual damages include, but are not limited to, lost business opportunities
resulting from the publication of the Article on the internet. By way of example, in 2018, STOPA
was prepared to close as an equity partner on a $15 million dollar deal, but the investors backed at
the last minute as a result of the Article and others like it.
WHEREFORE STOPA demands the following relief:
A. Trial by Jury
B. Injunctive relief, including an injunction that prohibits DIAZ and P.A. from publishing
anything bearing the name of MARK STOPA, directly or indirectly, and requiring that
they remove all references to STOPA from the Website
Actual damages, both general and special
Punitive damages
All amounts which would have constituted a reasonable royalty for use of STOPA’s
name and likeness
F All other relief that this Court deems proper and just
ThisDecember,
31st day of 2019
Respectfully submitted,
/s/ Mark P. Stopa
Cees Group, P.L.
18167 U.S. Highway 19 North
Suite 100
Clearwater, Florida 33764
Telephone: (727) 667-4808
Email: markpstopa@gmail.com
3
I#: 2021086354 BK: 21438 PG: 1403, 03/17/2021 at 09:04 AM, RECORDING 2 KEN
BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK:
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IN THE CIRCUIT COURT OF FHE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
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MOTION TO DISMISS CASE
COMES NOW, the Clerk of the Circuit Court, Ken Burke, and moves the court to enter
an order dismissing the above styled cause of action. Pursuant to Florida Statute
28,242 and Florida Rules of Civil Procedure 1.060 allowing transfer of actions and
providing method for same, filing fees have not been received to complete the transfer
per an order signed February 05, 2021 and the action should be dismissed without
prejudice by the court that entered the order of transfer.
WHEREFORE, the Clerk prays for an order dismissing the above styled case.
Dated: March 11, 2021 KEN BURKE, CPA a
Clerk of the Circuit Court and Corgpts
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Filing # 142558900 E-Filed 01/24/2022 09:47:49 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff CASE NO: 2019-CA-8558-Cl Vv. MFI-MIAMI HOLDINGS, LLC and STEPHEN J. DIBERT, Defendants. / MFI-MIAMI HOLDINGS, LLC’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE Defendant, MFI-MIAMI HOLDINGS, LLC., by and through undersigned counsel and pursuant to F.S. §90.202 — 203, and request the court to take judicial notice of: Composite Exhibit A - 8 civil cases in Pinellas County that were voluntarily dismissed consisting of: Stopa v. Brown - case 20-65-Cl Stopa v. Beam — case 20-262-Cl Stopa v. Chane — case 20-261-Cl' Stopa v. Diaz — case 20-62-Cl Stopa v. Florida Law Advisers — case 20-63-Cl Stopa v. Hurt — case 20-198-Cl Stopa v. Jeeves — case 20-254-Cl Stopa v. Progressive Divorce — 20-199-Cl MEMORANDUM OF LAW COMPULSORY JUDICIAL NOTICE Fla. Stat. §90.203, sets forth requirements for compulsory judicial notice and provides: A court shall take notice of any matter in section 90.202 when a party requests it and; (1) gives each adverse party timely written notice of the request, proof of which is filed with the court, to enable the adverse party to prepare to meet the request; and (2) furnishes the court with sufficient information to enable it to take judicial notice of the matter. [Emphasis added]. Pursuant to §§90.202(6) and 90.203, Florida statutes, MFI—-Miami Holdings, LLC., requests that this Court take judicial notice of the judicial records specifically identified herein and attached hereto. As a result of the instant filing, the opposing party, Mark P. Stopa has 1 This case resolved with a dismissal between the parties, but not before the plaintiff filed an amended complaint seeking to create conflict between the defendant and his chosen counsel by intentionally adding the attorney of record into the amended complaint. ***ELECTRONICALLY FILED 01/24/2022 09:47:49 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** received notice of the intent to have the Court rely upon the attached records and to take judicial notice of same. The attached records are relevant to the proceedings pending before this court and address issues pending before this court. DISCRETIONARY JUDICIAL NOTICE Section 90.202, Fla. Stat. provides for matters that may be judicially noticed by a court. Subsection (6) of the statute specifically provides that a court may take judicial notice of records of any court of the State or of any court of record of the United States or of any other state, territory, or jurisdiction of the United States. Judicial notice may be taken of all judicial records. See Dufour v. State, 69 So.3d 235 (Fla. 2011); Allstate Ins. Co. v. Grayhound Rent- A- Car, Inc.,586 So.2d 482, 483 (Fla. 4" DCA 1991) (citing Florida Evidence Code §90.202(6)). See also Hunt v. State, 613 So.2d 893, 898 n.5 (Fla. 1992)(granting appellant's motion to judicially notice the record of another case.); Falls v. Nat'l Environ. Prods., 665 So.2d 320 (Fla. 4'" DCA 1995)(explaining that it is proper for a trial court and appellate court to take judicial notice of the pleadings and briefs of other actions filed that bear a relationship to the case at bar.) WHEREFORE, MFI-Miami Holdings, LLC., hereby requests this Honorable Court to take judicial notice of the attached and referenced judicial records. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been served via email to markpstopa@gmail.com this 24" day of January 2022. Samantha Stevins Samantha Stevins, Esq. e-mail: stevinslawfirm@gmail.com 2681 Airport Road South, Suite C-104 Naples, Florida 34112 Phone (239) 300-4417 COMPOSITE EXHIBIT A Case Number:20-000262-CI Filing # 101625104 E-Filed 01/16/2020 02:05:35 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff, Case No.: Vv. DORAN, BEAM & FARRELL, P.A., Defendant. COMPLAINT Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, DORAN, BEAM & FARRELL, P.A. (“P.A.”), and alleges: BACKGROUND 1 P.A. is a Florida corporation. It operates as a law firm, practicing in the area of personal injury. 2. P.A. uses the website https://pascoinjurylaw.com (“the Website”) as a means of advertising services to the public and conducting business for profit. 3 P.A. is not a legitimate media source. The Website is not a “news medium” under Florida law. Rather, P.A. is a for-profit business. 4 STOPA used to be a practicing attorney in Florida, FBN 550507. 5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of foreclosure defense and consumer protection. During this time, STOPA successfully represented thousands of Florida consumers, including those in Clearwater, St. Petersburg, New Port Richey, and the surrounding areas. 6. All conditions precedent have been met, waived, or otherwise satisfied. ***ELECTRONICALLY FILED 01/16/2020 02:05:33 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein accrued here. COUNT ONE 8 This is an action for actual damages in excess of $30,000 (exclusive of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08. 9. STOPA realleges and incorporates by references paragraphs 1-7 above. 10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation thereof, e.g. “Attorney Mark Stopa,” for the purpose of advertising P.A. for business purposes without STOPA’s consent and without any valid license for such use. 11. For example, but without limitation, P.A. has operated a Google Adwords account through Google, an internet provider, and set up that account in such a manner that anyone who searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Attorney Mark Stopa” would be directed to the Website. 12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial purposes without STOPA’s consent and without a valid license. 13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and amounts which would have constituted a reasonable royalty. These actions also constitute a deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar. After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has never practiced in the area of personal injury. 14, STOPA’s actual damages include, but are not limited to, lost business opportunities resulting from the use of his name on the internet without his consent. Among these damages are a $15 million business deal which did not close because investors for that deal saw the way STOPA’s name was being used on the internet. WHEREFORE STOPA demands the following relief: A. Trial by Jury B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name for any advertising or commercial purposes, either related to the P.A., the Website, or otherwise Actual damages, both general and special Punitive damages All amounts which would have constituted a reasonable royalty for use of STOPA’s name and likeness F All other relief that this Court deems proper and just This January, 14th day of 2020 Respectfully submitted, 4 D c/o Segal & Schuh Law Group, P.L. 18167 U.S. Highway 19 North Suite 100 Clearwater, Florida 33764 Telephone: (727) 667-4808 Email: markpstopa@gmail.com I#: 2021071810 BK: 21419 PG: 1265, 03/05/2021 at 08:29 AM, RECORDING 3 KEN BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK: CLKPR14 CIRCUIT COURT, PINELLAS COUNTY, FLORIDA \ CIRCUIT CIVIL DIVISION ai Cn A= aim 20 MASTER ORDER DISMISSAL ae CALENDAR NO. 030221 — Section 7 THIS CAUSE, came on upon the Court's own motion, pursuant to Rule of Civil Procedure 1.420(e), that the cause would be dismissed on MARCH 02, 2021 . The Court finds that a Notice of Lack of Prosecution was provided, there was no record activity during the 10 months immediately preceding service of the foregoing notice; there was no record activity during the 60 days immediately following service of the foregoing notice; no stay has been issued or approved by the Court; and no party has shown good cause why the action should remain pending. ACCORDINGLY, IT IS ORDERED that the cases on the attached listing are dismissed for lack of prosecution. DONE AND ORDERED in chambers in Clearwater/St. Petersburg, Pinellas County, Florida, this Q , day of _ “YW t— , 2021. 42-6 Salat Hon Patricia Ann Muscarella PINELLAS COUNTY FL OFF. REC. BK 21419 PG 1266 03/02/2021 Cases Scheduled for Dismissal Section 7 DISMISSAL LOP 07 Pinellas County, Florida Case Number SHIRLEY ANGELO, etal vs. R J REYNOLDS TOBACCO COMPANY, et al 09-011946-Cl PLAINTIFF(S) LOUIS ANGELO; SHIRLEY ANGELO DEFENDANT(S) LIGGETT GROUP LLC; LORILLARD TOBACCO COMPANY; PHILIP MORRIS USA INC; R J REYNOLDS TOBACCO COMPANY; VECTOR GROUP LTD INC Case Number J ALLEN MILLER Vs. CHASE BANKCARD SERVICES INC 13-001579-Cl PLAINTIFF(S) J ALLEN MILLER DEFENDANT(S) CHASE BANKCARD SERVICES INC Case Number LOUIS TADDIA Vs. NACHMANS NATIVE SEAFOOD INC 15-001123-Cl PLAINTIFF(S) LOUIS TADDIA DEFENDANT(S) NACHMANS NATIVE SEAFOOD INC Case Number LUCIEN PRICE, et al Vs. BIG BROTHERS CAPITAL INC, et al 17-004864-CI PLAINTIFF(S) ASHLEY PRICE; LUCIEN PRICE DEFENDANT(S) BIG BROTHERS CAPITAL INC; VITALY CHEPURNOV, INDIVIDUALLY Case Number JILL FISCHER-PETERS Vs. NADIA ONEAL, DDS 17-004998-Cl PLAINTIFF(S) JILL FISCHER-PETERS DEFENDANT(S) NADIA ONEAL, DDS Case Number MARK ELLIOTT GREEN, et al Vs. JOELLE TONEY, et al 18-003201-Cl PLAINTIFF(S) JENNIFER LEE GREEN; MARK ELLIOTT GREEN DEFENDANT(S) DIOP ADONLIN DAOUDA ASSANVO; JOELLE TONEY Case Number AMICA MUTUAL INSURANCE COMPANY Vs. DUKE ENERGY FLORIDA LLC 18-004451-Cl PLAINTIFF(S) AMICA MUTUAL INSURANCE COMPANY DEFENDANT(S) DUKE ENERGY FLORIDA LLC Case Number NAUSSERA ZADEH Vs. MIKE TWITTY, et al 18-005656-Cl PLAINTIFF(S) NAUSSERA ZADEH DEFENDANT(S) CHARLES THOMAS; DIANE GONZALES NELSON; E. LEON BIEGALSKI; MAURICE GOGARTY; MIKE TWITTY; PAMELA MARY DUBOV Case Number DANIEL RODRIGUEZ-VAZQUEZ Vs. LARRY DIMMITT CADILLAC INC 19-000306-CI PLAINTIFF(S) DANIEL RODRIGUEZ-VAZQUEZ DEFENDANT(S) LARRY DIMMITT CADILLAC INC Case Number Us BANK NATIONAL ASSOCIATION Vs. RENE LOPEZ, et al 19-001020-CI PLAINTIFF(S) US BANK NATIONAL ASSOCIATION DEFENDANT(S) ANY AND ALL UNKNOWN PARTIES; BRIAN MARLOW; FLORIDA HOUSING FINANCE CORPORATION; RENE LOPEZ; STACIA LOPEZ PINELLAS COUNTY FL OFF. REC. BK 21419 PG 1267 03/02/2021 Cases Scheduled for Dismissal Section 7 DISMISSAL LOP 07 Pinellas County, Florida Case Number SUSAN WEBB Vs. WAL-MART STORES EAST LP 19-001204-CI PLAINTIFF(S) SUSAN WEBB DEFENDANT(S) WAL-MART STORES EAST LP Case Number DISCOVER BANK Vs. IAN CHURCH 19-003356-CI PLAINTIFF(S) DISCOVER BANK DEFENDANT(S) IAN CHURCH Case Number OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY Vs. HUGH W ROBINSON 19-003452-CI OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY PLAINTIFF(S) DEFENDANT(S) HUGH W ROBINSON Case Number EMILY CORPORATION Vs. EMERALD MEDICAL SUPPLY INC, et al 19-004854-Cl PLAINTIFF(S) EMILY CORPORATION DEFENDANT(S) EMERALD MEDICAL SUPPLY INC; JONATHAN TANNER Case Number J LONG REALTY GROUP LLC, et al Vs. ALVIN CASANOVA 19-005030-Cl PLAINTIFF(S) 4 LONG REALTY GROUP LLC; KSK HOMES INC DEFENDANT(S) ALVIN CASANOVA Case Number LOUISE C WIEBE, TRUSTEE Vs. CAGNI CONSTRUCTION COMPANY, et al 19-005938-Cl PLAINTIFF(S) LOUISE C WIEBE, TRUSTEE DEFENDANT(S) CAGNI CONSTRUCTION COMPANY; MARK CAGNI Case Number DIRECT CAPITAL Vs. PRECISION AUTO TINT AND DESIGN CORP, et al 19-008308-Cl PLAINTIFF(S) DIRECT CAPITAL DEFENDANT(S) CHRISTOPHER PAINE; PRECISION AUTO TINT AND DESIGN CORP Case Number ll Case Number ANGELINA PARKER GREEN Vs. ROOSEVELT BOULEVARD APARTMENTS LLC _| 20-000431-Cl PLAINTIFF(S) ANGELINA PARKER GREEN DEFENDANT(S) ROOSEVELT BOULEVARD APARTMENTS LLC Case Number:20-000065-CI Filing # 101151288 E-Filed 01/06/2020 11:25:41 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff, Case No.: Vv. BROWN & ASSOCIATES LAW & TITLE, P.A., Defendant. COMPLAINT Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, BROWN & ASSOCIATES LAW & TITLE, P.A. (“P.A.”), and alleges: BACKGROUND 1 P.A. is a Florida professional association. It operates as a law firm, practicing in the area of foreclosure defense. 2. P.A. uses the website https://www.tampaforeclosurelaw.com (“the Website”) as a means of advertising services to the public and conducting business for profit. Among these services is foreclosure defense. 3 P.A. is not a legitimate media source. The Website is not a “news medium” under Florida law. Rather, P.A. is a for-profit business in the area of foreclosure defense, among others. 4. STOPA used to be a practicing attorney in Florida, FBN 550507. 5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of foreclosure defense and consumer protection. During this time, STOPA successfully represented thousands of Florida consumers. 6. All conditions precedent have been met, waived, or otherwise satisfied. ***ELECTRONICALLY FILED 01/06/2020 11:25:39 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein accrued here. COUNT ONE 8 This is an action for actual damages in excess of $15,000 (exclusive of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08. 9. STOPA realleges and incorporates by references paragraphs 1-7 above. 10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation thereof, e.g. “Attorney Mark Stopa,” for the purpose of advertising P.A. for business purposes without STOPA’s consent and without any valid license for such use. 11. For example, but without limitation, P.A. has operated a Google Adwords account through Google, an internet provider, and set up that account in such a manner that anyone who searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Attorney Mark Stopa” would be directed to the Website. 12. In addition, when STOPA ceased practicing law, P.A. obtained possession of his client list, then solicited many hundreds of Florida consumers by telling them that P.A. would defend them “in the same way that Mark Stopa did,” or words to that effect. In fact, one of the agents of P.A. who made these calls previously worked in a similar capacity for STOPA. 13. By acting in such fashion, P.A. has used STOPA’s name for its own commercial purposes without STOPA’s consent and without a valid license. 14, The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and amounts which would have constituted a reasonable royalty. 15. STOPA’s actual damages include, but are not limited to, lost business opportunities resulting from the use of his name on the internet without his consent. Among these damages are a $15 million business deal which did not close because investors for that deal saw the way STOPA’s name was being used on the internet. WHEREFORE STOPA demands the following relief: A. Trial by Jury B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name for any advertising or commercial purposes, either related to the P.A., the Website, or otherwise Actual damages, both general and special Punitive damages All amounts which would have constituted a reasonable royalty for use of STOPA’s name and likeness F All other relief that this Court deems proper and just This Sth January, day of 2020 Respectfully submitted, s/ Mark P. Stopa c/o Segal & Schuh Law Group, P.L. 18167 U.S. Highway 19 North Suite 100 Clearwater, Florida 33764 Telephone: (727) 667-4808 Email: markpstopa@gmail.com I#: 2021375509 BK: 21811 PG: 1460, 11/18/2021 at 08:56 AM, RECORDING 2 KEN BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK: CLKDU17 CIRCUIT COURT, PINELLAS COUNTY, FLORIDA CIRCUIT CIVIL DIVISION MASTER ORDER DISMISSAL CALENDAR NO. 110921 - Section 15 THIS CAUSE, came on upon the Court's own motion, pursuant to Rule of Civil Procedure 1.420(e), that the cause would be dismissed on November 09, 2021. The Court finds that a Notice of Lack of Prosecution was provided, there was no record activity during the 10 months immediately preceding service of the foregoing notice; there was no record activity during the 60 days immediately following service of the foregoing notice; no stay has been issued or approved by the Court; and no party has shown good cause why the action should remain pending. ACCORDINGLY, IT IS ORDERED that the cases on the attached listing are dismissed for lack of prosecution. DONE AND ORDERED in chambers in Clearwater/St-Petersburg, Pinellas oui Florida, this , day of , 2021. in George M Jirotka Filed, NOV 17, 2021, 9:55, Ken Burke, Clerk of the Circuit Court and Comptroller, Pinellas County PINELLAS COUNTY FL OFF. REC. BK 21811 PG 1461 11/09/2021 Cases Scheduled for Dismissal Section 15 DISMISSAL LOP 15 Pinellas County, Florida Case Number ALANA CAMPOS SOUZA, et al Vs. VEGAS MANAGEMENT LLC 18-008249-CI ALANA CAMPOS SOUZA; BROOKE TAYLOR; JOANNA KRUPA; LINA PLAINTIFF(S) POSADA; PAOLA CANAS; TIFFANY TOTH GRAY DEFENDANT(S) VEGAS MANAGEMENT LLC Case Number JESSICA CASTALDO Vs. WRD LINCOLN SHORES LLC 19-000696-CI PLAINTIFF(S) JESSICA CASTALDO DEFENDANT(S) WRD LINCOLN SHORES LLC Case Number PORTFOLIO RECOVERY ASSOCIATES LLC Vs. SCOTTT SHIELDS 19-004664-CI PLAINTIFF(S) PORTFOLIO RECOVERY ASSOCIATES LLC DEFENDANT(S) SCOTT T SHIELDS Case Number AARON CORLEY Vs. PINELLAS COUNTY JAIL 19-005582-Cl PLAINTIFF(S) AARON CORLEY DEFENDANT(S) PINELLAS COUNTY JAIL | Case Number RONALD SPEER Vs. TRENT ROAD LLC 20-001741-Cl PLAINTIFF(S) RONALD SPEER DEFENDANT(S) TRENT ROAD LLC Case Number ROBERT PARKS, et al Vs. SOUTHERN OAK INSURANCE COMPANY 20-004500-Cl PLAINTIFF(S) INMACULADA PARKS; ROBERT PARKS DEFENDANT(S) SOUTHERN OAK INSURANCE COMPANY, | Case Number LAURIE HIGDON Vs. TWAIN THORNTON 20-004662-CI PLAINTIFF(S)LAURIE HIGDON = DEFENDANT(S) | TWAIN THORNTON Filed, NOV 17, 2021, 9:55, Ken Burke, Clerk of the Circuit Court and Comptroller, Pinellas County Filing # 102340126 E-Filed 01/28/2020 12:41:22 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff, Case No.: 20-261-CI Vv. LAW OFFICE OF LAURIE R CHANE, P.A., Defendant. AMENDED COMPLAINT Plaintiff, MARK P. STOPA (“STOPA”), sues Defendants, LAW OFFICE OF LAURIE R. CHANE, P.A. (“P.A.”), JASON SAMPSON (“SAMPSON”), and VENERABLE LAW, LLP (“VENERABLE”), and alleges: BACKGROUND 1 P.A. is a Florida professional association. It operates as a law firm, practicing in the area of family law. 2 P.A. uses the website https://chanelaw.com (“the Website”) as a means of advertising services to the public and conducting business for profit. 3 P.A. is not a legitimate media source. The Website is not a “news medium” under Florida law. Rather, P.A. is a for-profit business. 4. STOPA used to be a practicing attorney in Florida, FBN 550507. 5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of foreclosure defense and consumer protection. During this time, STOPA successfully represented thousands of Florida consumers, including those in Clearwater, St. Petersburg, and the surrounding areas. ***ELECTRONICALLY FILED 01/28/2020 12:41:22 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 6. All conditions precedent have been met, waived, or otherwise satisfied. 7 Venue lies in Pinellas County, Florida, as the causes of action alleged herein accrued here. COUNT ONE 8 This is an action for actual damages against P.A. in excess of $30,000 (exclusive of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08. 9. STOPA realleges and incorporates by references paragraphs 1-7 above. 10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation thereof, e.g. “Clearwater Lawyer Mark Stopa,” for the purpose of advertising P.A. for business purposes without STOPA’s consent and without any valid license for such use. 11. For example, but without limitation, P.A. has operated a Google Adwords account through Google, an internet provider, and set up that account in such a manner that anyone who searched Google with the phrase “Mark Stopa,” and variations thereof, e.g. “Clearwater Lawyer Mark Stopa” would be directed to the Website. 12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial purposes without STOPA’s consent and without a valid license. 13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and amounts which would have constituted a reasonable royalty. These actions also constitute a deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar. After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has never practiced in the area of family law. 14. STOPA’s actual damages include, but are not limited to, lost business opportunities resulting from the use of his name on the internet without his consent. Among these damages are a $15 million business deal which did not close because investors for that deal saw the way STOPA’s name was being used on the internet. WHEREFORE STOPA demands the following relief: A. Trial by Jury B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name for any advertising or commercial purposes, either related to the P.A., the Website, or otherwise Actual damages, both general and special Punitive damages All amounts which would have constituted a reasonable royalty for use of STOPA’s name and likeness All other relief that this Court deems proper and just COUNT TWO 15. This is an action for damages against SAMPSON, VENERABLE, and P.A. for abuse of process in excess of $30,000, exclusive of interest, attorney’s fees, and costs. 16. SAMPSON isa licensed Florida attorney. 17. VENERABLE, an LLP, conducts business as a law firm. 18. SAMPSON is an agent and employee of VENERABLE. 19. All actions taken by SAMPSON, as described herein, were taken within the course and scope of his employment with VENERABLE. 20. At all times relevant, SAMPSON was an agent of P.A. and acting within the course and scope of his representation of P.A., rendering P.A. vicariously liable for his actions. 21. On or about January 21, 2020, SAMPSON contacted STOPA in response to his filing of the original Complaint in this lawsuit (“the Instant Case”) against P.A., indicating that SAMPSON and VENERABLE would be counsel for P.A. 22. SAMPSON’S first act as counsel was to serve a motion upon STOPA for P.A. asserting that the Complaint against was frivolous and demanding that STOPA withdraw it (“the 57.105 Motion’). 23. Surprised to see an attorney levy such aggressive, heavy-handed assertions right off the bat — based on what was obviously a false and incomplete understanding of the facts —STOPA ‘alled SAMPSON via telephone to discuss the Instant Case in an attempt to reach a resolution. 24. During that conversation, SAMPSON criminally extorted STOPA. 25. In particular, SAMPSON apprised STOPA that he had “no idea” the “backlash” that was going to be unleashed on STOPA as a result of his filing the Instant Case and several others STOPA had filed like it. When STOPA expressed his incredulity at what SAMPSON meant by that statement, SAMPSON expressed his view that STOPA’s filing of the Instant Case was “criminal extortion” and that “the statewide prosecutor does as well.” 26. Viewed in totality, the import of SAMPSON’s statements to STOPA were that he had spoken to the statewide prosecutor about the Instant Case and that STOPA should be fearful about what the prosecutor’s office would do to him because of his prosecution of the Instant Case and others like it. Notably, this conversation took place on the very day that SAMPSON had served STOPA with the 57.105 Motion and in the very conversation in which SAMPSON was trying to urge STOPA to voluntarily dismiss the Instant Case. 20 SAMPSON’s filing of the 57.105 Motion and subsequent conversation were an illegal effort to induce STOPA to dismiss the Instant Case against his client through criminal misconduct, i.e. extortion. 28. SAMPSON’: actions are an abuse of process by operation of law. 29: As a result of SAMPSON’s abuse of process, STOPA has been damaged. Such damages include, but are not limited to, emotional distress and special damages in the form of attorney’s fees STOPA incurred with counsel to discuss his conversation with SAMPSON. WHEREFORE STOPA demands the following relief from SAMPSON, P.A., and VENERABLE: A Trial by Jury B. Actual damages, both general and special Cc All other relief that this Court deems proper and just CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been furnished via email to Jason Sampson, Esq., jsampson@venerablelawfirm.com on this Respectfully submitted, s/ Mark P. Stopa c/o Segal & Schuh Law Group, P.L. 18167 U.S. Highway 19 North Suite 100 Clearwater, Florida 33764 Telephone: (727) 667-4808 Email: markpstopa@gmail.com Case Number:20-000261-CI Filing # 101630499 E-Filed 01/16/2020 02:02:44 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff, Case No.: Vv. LAW OFFICE OF LAURIE R CHANE, P.A., Defendant. COMPLAINT Plaintiff, MARK P. STOPA (“STOPA”), sues Defendant, LAW OFFICE OF LAURIE R. CHANE, P.A. (“P.A.”), and alleges: BACKGROUND 1 P.A. is a Florida professional association. It operates as a law firm, practicing in the area of family law. 2. P.A. uses the website https://chanelaw.com (“the Website”) as a means of advertising services to the public and conducting business for profit. 3 P.A. is not a legitimate media source. The Website is not a “news medium” under Florida law. Rather, P.A. is a for-profit business. 4 STOPA used to be a practicing attorney in Florida, FBN 550507. 5 From 2008 through 2018, STOPA’s practice consisted almost exclusively of foreclosure defense and consumer protection. During this time, STOPA successfully represented thousands of Florida consumers, including those in Clearwater, St. Petersburg, and the surrounding areas. 6. All conditions precedent have been met, waived, or otherwise satisfied. ***ELECTRONICALLY FILED 01/16/2020 02:02:42 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 7. Venue lies in Pinellas County, Florida, as the causes of action alleged herein accrued here. COUNT ONE 8 This is an action for actual damages in excess of $30,000 (exclusive of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08. 9. STOPA realleges and incorporates by references paragraphs 1-7 above. 10. On numerous occasions, P.A. has used the name “Mark Stopa,” or some variation thereof, e.g. “Clearwater Lawyer Mark Stopa,” for the purpose of advertising P.A. for business purposes without STOPA’s consent and without any valid license for such use. 11. For example, but without limitation, P.A. has operated a Google Adwords account through Google, an internet provider, and set up that account in such a manner that anyone who searched Google with the phrase “Mark Stopa,” and variations thereof, ¢.g. “Clearwater Lawyer Mark Stopa” would be directed to the Website. 12. By acting in such fashion, P.A. has used STOPA’s name for its own commercial purposes without STOPA’s consent and without a valid license. 13. The actions of P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive relief, and amounts which would have constituted a reasonable royalty. These actions also constitute a deceptive and inherently misleading advertisement, as prohibited by Rule 4-7.13, R.Reg.Fla.Bar. After all, STOPA is not a practicing attorney, has never worked for P.A. in any capacity, and has never practiced in the area of family law. 14, STOPA’s actual damages include, but are not limited to, lost business opportunities resulting from the use of his name on the internet without his consent. Among these damages are a $15 million business deal which did not close because investors for that deal saw the way STOPA’s name was being used on the internet. WHEREFORE STOPA demands the following relief: A. Trial by Jury B. Injunctive relief, including an injunction that prohibits P.A. from using STOPA’s name for any advertising or commercial purposes, either related to the P.A., the Website, or otherwise Actual damages, both general and special Punitive damages All amounts which would have constituted a reasonable royalty for use of STOPA’s name and likeness F All other relief that this Court deems proper and just This January, 14th day of 2020 Respectfully submitted, s/ Mark P. Stopa c/o Segal & Schuh Law Group, P.L. 18167 U.S. Highway 19 North Suite 100 Clearwater, Florida 33764 Telephone: (727) 667-4808 Email: markpstopa@gmail.com Case Number:20-000062-CI Filing # 101149182 E-Filed 01/06/2020 11:10:37 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA MARK P. STOPA, Plaintiff, Case No.: Vv. ROY DIAZ and SHD LEGAL GROUP, P.A., Defendants. COMPLAINT Plaintiff, MARK P. STOPA (“STOPA”), sues Defendants, ROY DIAZ (“DIAZ”) and SHD LEGAL GROUP, P.A. (“P.A.”), and alleges: BACKGROUND 1 DIAZ is an attorney, licensed to practice law in Florida. 2. P.A. is a Florida professional association through which P.A. is both employed and conducts business. 3 DIAZ and P.A. use the website https://shdlegalgroup.com (“the Website”) as a means of advertising services to the public and conducting business for profit. Chief among the services offered is the prosecution of foreclosure lawsuits on behalf of banks, lenders, and servicers. 4 P.A. is not a legitimate media source. The Website is not a “news medium” under Florida law. Rather, P.A. is a for-profit business in the area of foreclosure law. The blog on the Website is a way for DIAZ and P.A. to attract internet traffic and solicit/procure business. 5 DIAZ created the blog on the Website and maintains control over its contents. 6. STOPA used to be a practicing attorney in Florida, FBN 550507. 1 ***ELECTRONICALLY FILED 01/06/2020 11:10:36 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 7. From 2008 through 2018, STOPA’s practice consisted almost exclusively of foreclosure defense and consumer protection. During this time, STOPA successfully represented thousands of Florida consumers. As a result, STOPA litigated many hundreds of cases against DIAZ, P.A., and their clients. 8 All conditions precedent have been met, waived, or otherwise satisfied. 9. Venue lies in Pinellas County, Florida, as the causes of action alleged herein accrued here. COUNT ONE 10. This is an action for actual damages in excess of $15,000 (exclusive of interest, attorney’s fees, and costs), punitive damages, and injunctive relief under Fla. Stat. § 540.08. 11. STOPA realleges and incorporates by references paragraphs 1-9 above. 12. In 2018, DIAZ and P.A. caused to be published an article on the Website (“the Article”), entitled “Defense Attorney Mark Stopa Faces Potential Disbarment,” https://shdlegalgroup.com/defense-attorney-mark-stopa-faces-potential-disbarment 13. DIAZ and P.A.’s purpose in publishing the Article was to generate internet traffic and to advertise and solicit business by use of STOPA’s name. 14. Given the frequency with which he prevailed on behalf of consumers in the foreclosure arena, banks, lenders, and servicers hated STOPA. These were the entities that DIAZ and P.A. represented. DIAZ and P.A.’s posting of the Article was their way of telling their clients “retain us for more cases; we will go after STOPA for you.” It was, quite simply, a way to advertise and solicit business. 15. The actions of DIAZ and P.A. were made in bad faith and with actual malice. 16. The actions of DIAZ and P.A. constitute violations of Fla. Stat. § 540.08, for which STOPA is entitled to actual damages, punitive damages (as prescribed by the statute), injunctive telief, and amounts which would have constituted a reasonable royalty. 17. STOPA’s actual damages include, but are not limited to, lost business opportunities resulting from the publication of the Article on the internet. By way of example, in 2018, STOPA was prepared to close as an equity partner on a $15 million dollar deal, but the investors backed at the last minute as a result of the Article and others like it. WHEREFORE STOPA demands the following relief: A. Trial by Jury B. Injunctive relief, including an injunction that prohibits DIAZ and P.A. from publishing anything bearing the name of MARK STOPA, directly or indirectly, and requiring that they remove all references to STOPA from the Website Actual damages, both general and special Punitive damages All amounts which would have constituted a reasonable royalty for use of STOPA’s name and likeness F All other relief that this Court deems proper and just ThisDecember, 31st day of 2019 Respectfully submitted, /s/ Mark P. Stopa Cees Group, P.L. 18167 U.S. Highway 19 North Suite 100 Clearwater, Florida 33764 Telephone: (727) 667-4808 Email: markpstopa@gmail.com 3 I#: 2021086354 BK: 21438 PG: 1403, 03/17/2021 at 09:04 AM, RECORDING 2 KEN BURKE, CLERK OF COURT AND COMPTROLLER PINELLAS COUNTY, FL BY DEPUTY CLERK: CLK102189 RA IN THE CIRCUIT COURT OF FHE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA UCN: 522020CA000062XXCICI REF: 20-000062-Cl 5 Roe \ 3 Ra MARK P STOPA zor Vs. ae om ‘ ROY DIAZ, et al im a MOTION TO DISMISS CASE COMES NOW, the Clerk of the Circuit Court, Ken Burke, and moves the court to enter an order dismissing the above styled cause of action. Pursuant to Florida Statute 28,242 and Florida Rules of Civil Procedure 1.060 allowing transfer of actions and providing method for same, filing fees have not been received to complete the transfer per an order signed February 05, 2021 and the action should be dismissed without prejudice by the court that entered the order of transfer. WHEREFORE, the Clerk prays for an order dismissing the above styled case. Dated: March 11, 2021 KEN BURKE, CPA a Clerk of the Circuit Court and Corgpts 1 A SS = \ ers Bon = =e By; /s/ Max Tani