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Filing # 96103478 E-Filed 09/23/2019 10:22:31 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MOBOOKA, LLC., CIRCUIT CIVIL DIVISION
a Florida limited liability company,
Plaintiff, CASE NO.: 2017-CA-004043
v.
JOHN HANCOCK, individually, and
FORSA LLC, a Wyoming limited liability
company,
Defendant.
MOTION FOR SANCTIONS AND FOR ORDER TO SHOW CAUSE
COMES NOW, the Plaintiff, MOBOOKA, LLC. (“Plaintiff”), by and through the
undersigned counsel, moves this court for an order sanctioning FORSA LLC (“Forsa”), for failure
to provide post judgment discovery, and entering an order of contempt against itand states as
follows:
1. On February 7, 2019, Final Judgment was entered against Forsa. A true and correct copy
of said Final Judgment is attached hereto as Exhibit “A.”
2. Pursuant to the Final Judgment, Forsa was obligated to provide a completed Form 1.977(b)
together with all attachments. See Exhibit “A.”
3. However, Forsa failed to provide said attachments and Plaintiff was forced to file a motion
to compel Forsa to do so.
4. The Court entered an Order on August 21, 2019 mandating Forsa provide said post
judgment discovery within 10 days. A true and correct copy of said Order is attached hereto as
Exhibit “B.”
Page 1 of 2
EPGD ATTORNEYS AT LAW, P.A.
777 SW 37th Ave Ste. 510, Miami, Florida 33135 • T: (786) 837-6787 | F: (305) 718-0687 • www.epgdlaw.com
5. The Order further stated that should Forsa fail to provide a complete Form 1.977 with
attachments, it would be sanctioned in the form of attorney’s fees, and an Order to Show Cause
would be entered against it. See Exhibit “B.”
6. Plaintiff and Forsa came to an agreement that the discovery may be provided by September
20, however, the response is still outstanding.
7. Plaintiff therefore asks that this Court sanction Forsa in the form of attorney’s fees for the
drafting of the motion to compel and this Motion, and for the hearings thereof.
8. Additionally, Plaintiffs asks that this Court enter an Order to show Cause as to why the
Form 1.977 was not timely produced.
WHEREFORE Plaintiff respectfully requests this honorable Court sanction Forsa for failure
to provide the post judgment discovery including Form 1.977(b), further compel Forsa to provide
said form, to enter an Order to show Cause, and any further relief the Court deems appropriate.
EPGD ATTORNEYS AT LAW, P.A.
ATTORNEYS FOR PLAINTIFF
777 SW 37th Ave., Ste. 510
Miami, Florida 33135
Tel: (786) 837-6787
Fax: (305) 718-0687
sam@epgdlaw.com
BY: /S/ Samuel J Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was via the by the Florida
Courts e-filing Portal on September 23, 2019.
BY: /S/ Samuel J. Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
Page 2 of 2
EPGD ATTORNEYS AT LAW, P.A.
777 SW 37th Ave Ste. 510, Miami, Florida 33135 • T: (786) 837-6787 | F: (305) 718-0687 • www.epgdlaw.com
Exhibit “A”
Exhibit “B”
Filing # 94548938 E-Filed 08/21/2019 03:28:25 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MOBOOKA, LLC, a Florida limited liability
company, CASE NO. : 2017 -C A-004043
Plaintiff,
JOHN HANCOCK, et. al.,
Defendants.
ORDER GRANTING PLAINTIFF-IN-EXECUTION MOBOOKA'S MOTION TO
THIS CAUSE came before this Court for hearing on August 12,2019 on plaintiff-In-
Execution Mobooka's Motion to Order Defendant Forsa LLC to Complete Fact Information Sheet,
("Motion") and the court, having heard argument of counsel, and being otherwise fully advised in
the premises, finds that, for the reasons stated in open court, it is hereby:
ORDERED A]rtD ADJUDGED that:
1. PlaintiffJn-Execution Mobooka's Motion to Order Defendant Forsa LLC to Complete Fact
Information Sheet, is GRANTED.
2. Defendant FORSA LLC, shall heve ten (10) days from the date of this Order, to fully
complete Form 1 .977(b) and provide Plaintiff with all required aftachments.
3. Should FORSA LLC failto comply with the Final Judgment in this Case and this Order,
the court shall sanction FORSA LLC in the form of attomey's fees and costs, and enter an
Order to Show Cause.
DONE AND ORDERED in Chambers at Orange County, Florida , on lugu",
-40D.
THE HONORABLE KEVIN B. WEISS
CIRCUIT COURTJUDGE
Copies fumished to:
All Counsel of Record and Parties
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Filing # 96103478 E-Filed 09/23/2019 10:22:31 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC., CIRCUIT CIVIL DIVISION a Florida limited liability company, Plaintiff, CASE NO.: 2017-CA-004043 v. JOHN HANCOCK, individually, and FORSA LLC, a Wyoming limited liability company, Defendant. MOTION FOR SANCTIONS AND FOR ORDER TO SHOW CAUSE COMES NOW, the Plaintiff, MOBOOKA, LLC. (“Plaintiff”), by and through the undersigned counsel, moves this court for an order sanctioning FORSA LLC (“Forsa”), for failure to provide post judgment discovery, and entering an order of contempt against itand states as follows: 1. On February 7, 2019, Final Judgment was entered against Forsa. A true and correct copy of said Final Judgment is attached hereto as Exhibit “A.” 2. Pursuant to the Final Judgment, Forsa was obligated to provide a completed Form 1.977(b) together with all attachments. See Exhibit “A.” 3. However, Forsa failed to provide said attachments and Plaintiff was forced to file a motion to compel Forsa to do so. 4. The Court entered an Order on August 21, 2019 mandating Forsa provide said post judgment discovery within 10 days. A true and correct copy of said Order is attached hereto as Exhibit “B.” Page 1 of 2 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37th Ave Ste. 510, Miami, Florida 33135 • T: (786) 837-6787 | F: (305) 718-0687 • www.epgdlaw.com 5. The Order further stated that should Forsa fail to provide a complete Form 1.977 with attachments, it would be sanctioned in the form of attorney’s fees, and an Order to Show Cause would be entered against it. See Exhibit “B.” 6. Plaintiff and Forsa came to an agreement that the discovery may be provided by September 20, however, the response is still outstanding. 7. Plaintiff therefore asks that this Court sanction Forsa in the form of attorney’s fees for the drafting of the motion to compel and this Motion, and for the hearings thereof. 8. Additionally, Plaintiffs asks that this Court enter an Order to show Cause as to why the Form 1.977 was not timely produced. WHEREFORE Plaintiff respectfully requests this honorable Court sanction Forsa for failure to provide the post judgment discovery including Form 1.977(b), further compel Forsa to provide said form, to enter an Order to show Cause, and any further relief the Court deems appropriate. EPGD ATTORNEYS AT LAW, P.A. ATTORNEYS FOR PLAINTIFF 777 SW 37th Ave., Ste. 510 Miami, Florida 33135 Tel: (786) 837-6787 Fax: (305) 718-0687 sam@epgdlaw.com BY: /S/ Samuel J Gittle Samuel J. Gittle, Esq. Florida Bar No.: 99778 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was via the by the Florida Courts e-filing Portal on September 23, 2019. BY: /S/ Samuel J. Gittle Samuel J. Gittle, Esq. Florida Bar No.: 99778 Page 2 of 2 EPGD ATTORNEYS AT LAW, P.A. 777 SW 37th Ave Ste. 510, Miami, Florida 33135 • T: (786) 837-6787 | F: (305) 718-0687 • www.epgdlaw.com Exhibit “A” Exhibit “B” Filing # 94548938 E-Filed 08/21/2019 03:28:25 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC, a Florida limited liability company, CASE NO. : 2017 -C A-004043 Plaintiff, JOHN HANCOCK, et. al., Defendants. ORDER GRANTING PLAINTIFF-IN-EXECUTION MOBOOKA'S MOTION TO THIS CAUSE came before this Court for hearing on August 12,2019 on plaintiff-In- Execution Mobooka's Motion to Order Defendant Forsa LLC to Complete Fact Information Sheet, ("Motion") and the court, having heard argument of counsel, and being otherwise fully advised in the premises, finds that, for the reasons stated in open court, it is hereby: ORDERED A]rtD ADJUDGED that: 1. PlaintiffJn-Execution Mobooka's Motion to Order Defendant Forsa LLC to Complete Fact Information Sheet, is GRANTED. 2. Defendant FORSA LLC, shall heve ten (10) days from the date of this Order, to fully complete Form 1 .977(b) and provide Plaintiff with all required aftachments. 3. Should FORSA LLC failto comply with the Final Judgment in this Case and this Order, the court shall sanction FORSA LLC in the form of attomey's fees and costs, and enter an Order to Show Cause. DONE AND ORDERED in Chambers at Orange County, Florida , on lugu", -40D. THE HONORABLE KEVIN B. WEISS CIRCUIT COURTJUDGE Copies fumished to: All Counsel of Record and Parties