Notice of Pendency of Other Action. This is the second time that Raanan Katz, Miami Heat Owner, has sued the blogger. Last summer, Miami news outlets reported that Katz filed a defamation lawsuit against “John Doe” over critical blog posts.

1. Case 1:12-cv-22211-JLK Document 13 Entered on FLSD Docket 08/09/2012 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 1:12-CV-22211-JLK
RAANAN KATZ, an individual,
Plaintiff,
vs.
IRINA CHEVALDINA,
Defendant.
/
NOTICE OF PENDING, REFILED, RELATED OR SIMILAR ACTIONS
Pursuant to Local Rule 3.8, Defendant, IRINA CHEVALDINA, (hereinafter
"CHEVALDINA"), by and through undersigned counsel, submits this Notice of Pending,
Refiled, Related or Similar Actions. Local Rule 3.8 provides in pertinent part that “[i]t shall be
the continuing duty of the attorneys of record … to promptly bring to the attention of the Court
and opposing counsel … the existence of any similar actions or proceedings then pending before
another court or administrative agency.”
The parties in the instant case are involved in concurrent state court litigation and a
removed and then subsequently remanded prior federal court litigation over the same subject
matter.
A. R.K./Fl Management, Inc., R.K. Associates VII, Inc., 17070 Collins Avenue Shopping
Center, Ltd., Raanan Katz, and Daniel Katz v. Irina Chevaldina, Case No.
11-17842-CA32, 11th Judicial Circuit, in and for Dade County, FL (hereinafter "State
Court Action").
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2. Case 1:12-cv-22211-JLK Document 13 Entered on FLSD Docket 08/09/2012 Page 2 of 4
B. The removed and remanded prior federal court case: R.K./Fl Management, Inc. et. al v.
John Doe, 11-22657-Civ-COOKE/TURNOFF (consolidated with John Doe v. R.K./FL
Management, Inc., et.al.,11-22672-GRAHAM/GOODMAN).
The State Court Action was originally removed by JOHN DOE (who was subsequently
identified as CHEVALDINA), because the RK Plaintiff group asserted a violation of the
Lanham Act (the federal trademark act). A second federal action was filed (Case No. 11-22672)
and then consolidated before Judge Cooke as Case No. 11-22657. The consolidated case 22657
related to the identical blog postings at issue in the pending State Court Action.
The present captioned case (Case No. 12-CV-22211) involves the identical blog as in the
State Court Action because the Photograph of KATZ used in the blog allegedly infringes
KATZ’s copyright. Ultimately, the consolidated case before Judge Cooke was remanded back to
state court since R.K./Fl Management, Inc. et. al dropped their federal claim of false advertising
under the Lanham Act.
The parties and subject matter of the cases are all directly connected and nearly identical.
KATZ is the owner and prime mover of all corporate Plaintiffs.
The direct connection between these cases was not entirely clear until Plaintiff filed its
amended complaint (D.E. 10) specifically identifying the location of the alleged violations,
namely the blogs at issue in the prior case before Judge Cooke and the current pending state
court case.
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3. Case 1:12-cv-22211-JLK Document 13 Entered on FLSD Docket 08/09/2012 Page 3 of 4
Therefore, in accordance with CHEVALDINA’s obligation under S.D.F.L. Local Rule
3.8 this notice of Pending, Refiled, Related or Similar Actions is required.
Dated: Aug. 9, 2012 Respectfully submitted,
By: /RobertKain/
Robert C. Kain, Jr. (Fla. Bar No. 266760)
rkain@complexip.com
Darren Spielman (Fla. Bar No. 010868)
Dspielman@complexip.com
Kain & Associates, Attorneys at Law, P.A.
900 Southeast Third Avenue, Suite 205
Ft. Lauderdale, Florida 33316-1153
Telephone: (954) 768-9002
Facsimile: (954) 768-0158
Attorneys for Defendant Chevaldina
Marc J. Randazza (625566)
Randazza Legal Group
6525 West Warm Springs Rd. Ste. 100
Las Vegas, Nevada 89118
Phone: (888) 667-1113
Fax: (305) 437-7662
mjr@randazza.com
Co-counsel for Defendant
CERTIFICATE OF SERVICE
I hereby certify that on _Aug. 9, 2012_________________, I electronically filed the
foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day on all counsel of record or pro se parties identified on the
attached Service List in the manner specified, either via transmission of Notices of Electronic
Filing generated by CM/ECF or in some other authorized manner for those counsel or parties
who are not authorized to receive electronically Notices of Electronic Filing.
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4. Case 1:12-cv-22211-JLK Document 13 Entered on FLSD Docket 08/09/2012 Page 4 of 4
Alan Kluger, Esq.
Todd Levine, Esq.
Lindsay Haber, Esq.
Kluger, Kaplan, et al.
Miami Center, 17th Floor
201 S. Biscayne Blvd., Suite 1700
Miami, FL 33131
305-379-9000
fax 305-379-3428
Michael Chesal, Esq.
Peretz, Chesal & Herrmann, P.L.
201 S. Biscayne Blvd., Suite 1750
Miami, FL 33131
T. 305-341-3000
F. 305-371-6807
/RobertKain/
Robert C. Kain, Jr.
Florida Bar No. 266760
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