Filing # 81307240 E-Filed 11/28/2018 03:17:13 PM.
IN THE COUNTY COURT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. 18-007827 CC 26
PR NEWSWIRE ASSOCIATION LLC,
Plaintiff,
vs.
MIDAM VENTURES LLC, a Florida
limited liability company,
Defendant,
i]
PLAINTIFF'S MOTION TO ENFORCE TERMS OF SETTLEMENT STIPULATION
AND FOR ENTRY OF FINAL JUDGMENT
Plaintiff, PR NEWSWIRE ASSOCIATION LLC, requests the Court to enforce the
terms of the parties Settlement Stipulation and to enter a final judgment for Plaintiff against
Defendant, MIDAM VENTURES LLC, a Florida limited liability company, and states:
1. OnOctober31, 2018, the parties entered into a Settlement Stipulation, which
is attached as Exhibit "A"
2. On November 1, 2018, the Court entered an Order Adopting Settlement
Stipulation and Continuance Pending Payments
3. Defendant defaulted under the Settlement Stipulation by failing to make the
payment due on November 15, 2018.
4. The Settlement Stipulation entitles Plaintiff to the entry of a final judgment
without notice or further hearing.
5. To date, Defendant has failed to cure the default.
7. Defendant made no payments pursuant to the Settlement StipulationCASE NO. 18-007827 CC 26
8. In support of this motion, Plaintiff attaches:
a. Plaintiff's Affidavit of Interest and Costs.
b. Plaintiff's Attorney's Fees Affidavit
ec
Affidavit of Independent Counsel in Support of Award of Attorney's
Wherefore, Plaintiff requests the Court to enforce the terms of the parties’
Settlement Stipulation and to enter a final judgment against Defendant for the principal
sum of $13,784.00, prejudgment interest in the sum of $1,035.10, court costs in the sum
of $392.50, and reasonable attorney's fees in the sum of $3,440.00, making a total of
$18,651.60.
Markowitz, Ringel, Trusty & Hartog, P.A.
Plaintiffs Attorneys
9130 South Dadeland Boulevard
Two Datran Center, Suite 1800
Miami, Florida 33156-7858
Phone: (305) 670-5000
Fax: (305) 670-5011
Primary Email: commlitservice@mrthlaw.com
Js/ Thomas Ringel (Electronically Signed)
Thomas Ringel
Florida Bar No. 220736
Secondary Email: tringel@mrthiaw.com
CERTIFICATE OF SERVICE
| certify that | emailed via Florida Courts E-Filing Portal a copy of this motion on
November 28, 2018, to Justin Rundle, Esq. Florida Bar No. 0108257, Email Address:
JR@rundlelawfirm.com
/s/ Thomas Ringel (Electronically Signed!
Thomas Ringel
Florida Bar No. 220736
2‘ling # 80153465 E-Filed 10/31/2018 03:53:56 PM.
IN THE COUNTY COURT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA,
CIVIL DIVISION
CASE NO. 18-007827 CC 26
PR NEWSWIRE ASSOCIATION LLG,
Plaintiff,
vs,
MIDAM VENTURES LLO, a Florida
fimited tiablity company,
Defendant.
‘SETTLEMENT STIPULATION
Plaintif, PRNEWSWIRE ASSOCIATION LLC, and Defendant, MIDAMVENTURES
LLC, @ Florida limited liabilty company, in orderto settle this case, agree:
4. Defendant wil pay Plaintiff $8,000.00,
2. Defendant will pay the total as foliows:
Date Payment
November 15, 2018 $1,750,00
oormnmmnnnnnn ns Dat 15, 2018 78000"
January 15,2019 1,759,00
February 15, 2019 4,780.00
March 15, 2019 2/000,00
Total: $9,000.00
3, If Defendant makes all payments Ina timely fashion, Plaintif agrees that no
judgment shall be entered against Defendant, that additional costs, interest, and attorney's.
EXHIBIT
is
PF
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