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31. LTA LOGISTICS v Enrique Varona (Motion to Recuse Judge)

31. LTA LOGISTICS v Enrique Varona (Motion to Recuse Judge)

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Published by Enrique Varona
We the people have the last word in court, when they the BAR esquires obstruct access to justice then its time for them to go. This is the second time I hope this ends this situation. Not to thnk that the grass is greener on the other side, but everything is on the record.
We the people have the last word in court, when they the BAR esquires obstruct access to justice then its time for them to go. This is the second time I hope this ends this situation. Not to thnk that the grass is greener on the other side, but everything is on the record.

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Categories:Types, Business/Law
Published by: Enrique Varona on Jun 07, 2013
Copyright:Attribution Non-commercial

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08/28/2013

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INTHE COUNTY COURT OF THE ELEVENTH JUDICIALCIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDAGENERAL JURISDICTION DIVISIONCASE NO. 11 20527
CA
21LTA LOGISTICS, INC.LESTER
TRIMINO,
etal,
TH
E
ORDINAL
FILED
ON'-
v
-
Enrique Varona,
Defendant,
MOTION TODISQUALIFYJUDGETHEDEFENDANT,
Enrique Varona, a living human being who is
not
a straw-man or corporate fiction, who is
Sui
Juris
acting
Pro-se
in
this
action, pursuant toFla.R. Jud. Admin.
2.33(d)(l),
hereby
files
the
following
Motion
to
Disqualify
the
Honorable Antonio Arzola
from
presiding over
any
future
motions
filed
in
this case,
and as
grounds
therefore,
states
as
follows:
PRIOR MOTION
TO DISQUALIFY
Florida Rules of Judicial Administration 2.330(c) requires the Defendant
to
inform
that
on
March 4
th
, 2013
the
petitioner
filed a
motion
to
disqualify
this court. The motion was denied by Judge Antonio Arzola.
 
FACTS
1.
Defendant Enrique Varona has been sued by LTA LOGISTICS,INC.
and its
owners
alleging tortious
interference, seeking
an
injunction
against the defendant, and money damages. The Plaintifflawsuit
was
served
on
June
2011.
The
Defendant
has
countersued
the
Plaintiff
for two
counts
of
tortious interference,
fraud,
civil conspiracy.2.
For two
years
the
Defendant
has
been
seeking
relevant
evidence
from
the
Plaintiff which
are
necessary
to
establish
the
facts
of the
caseandneededby theDefendantfor hisdefense.Therequested documentswere
in
full
compliance with
the
Fl
Rules
of
Civil Procedures
and not
objected
to by the
Plaintiff.3. On May 4, 2013 the Plaintiff attorney entered certain documentsinto the record as requested
from
the court order to compel, amongst
them
was thesigned employment
"contract"
betweenthePlaintiffand
Defendant
dated June 9
th
, 2009.4.Onpage 3, section 10, of the contract it required a "mandatory"
and
"exclusive"
choiceof law and
forum
selectioninVirginiaand notFlorida.TheDefendant
filed
amotiontodismissandscheduledahearing on April
11,
2013 to coincide with Plaintiff attorney "motion to
withdraw as
counsel"
seeking
a
court ruling
on his
motion
to
dismiss
for
 
lack
of personal
&
subject matter jurisdiction due to improper choice of
law
andvenue.
5.
In theApril
11,
2013
hearing, Judge
Arzola
refused
toheartheDefendant's motion to dismiss and issued a stay for 30 days so the
plaintiff
could hire new counsel.6.
On May 30,
2013
the
Defendant scheduled
a
hearing
on his
motionto dismiss to coincide with the new counsel, Warren Gammill &Associates on their scheduled hearing on their "motion to amend the
complaint".
However, this
time
the new
attorneys
for the
plaintiffentered a
different
contract that the one entered by the previous attorney
into
therecord,The"new" contractis onedated November5
th
,2009
which is a
fraud.
The
Defendant
at all
times
has
objected
to
thiscontract being entered into the record, has informed the court about this
fraudulent
document
and
objected
to the
filing
of an
amendedcomplaint.
7.
At the May 30,2013hearing Judge Arzola did not allowed the
Defendant to
present
his
motion
to
dismiss
for
wrong choice
of lawand
forum
selection.
The
Defendant pointed
out
that even using
the
fraudulent
contract dated November 5
th
, 2009 which the "new counsel"entered without
an
affidavit
in
support
of the
contract, without
the

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