15. As such, the plaintiff's frivolous complaint is subject to dismissal, with prejudice.
and the Defendant requests that this Court do so.
16. The Defendant has been forced to retain the undersigned attorney to combat the
abuse of the legal process in which the Plaintiff has engaged, and has agreed to pay
him a reasonable fee for his services, and the Plaintiff should be forced to pay said
attorney lees insofar as his conduct has resulted in frivolous litigation.
WHEREFORE, Defendants request this court dismiss the plaintiffs complaint,
for an award of attorncy’s fees and for all other relief to which defendants prove
themselves entitled.
RESPECTFULLY SUBMITTED this 12th day of October, 2017.
CERTIFICATE OF SERVICE [PLAINTIFF NOTE--NEVER REVEIVED AND NO SENT EMAIL COPY ATTACHED]
I HEREBY CERTIFY that 21 tme and correct copy of the foregoing Was furnished
via electronic mail to the Plaintiff, on the above-referenced date.
ABCD LAW FIRM-RICHARD ABC, III, Esq.
Florida Bar No.1
Attorney for Defendants [4]
EXHIBIT - 1
LYNN POLICE DEPARTMENT
Offense I Incident Report
GENERAL OFFENSE INFORMATION Report Type: Cumulative Report
On XX/XX/2017, at approximately 12:40 p.m., I was patrolling the area
of State Road XXX and Highway XX. I observed a 1984 red Mercedes-
Benz passenger car, bearing license plate BACON with an expired
registration decal. After confirming the registration ofthis vehicle was
expired as of 6/9/2017, I conducted a traffic stop at 1317 HOHO Avenue. I
made contact with the driver, who identified himself as Levi via a Commonwealth of Israel ID permit.
I asked Mr. XXXXXX for a valid driver's license, and he pointed
at the ID card he handed me and stated that he had one. I conducted a
computer check and was unable to verify a valid license in any state, or
any other identifiers for Mr. XXXXXXX.
Further investigation also revealed no social security number for Mr.
XXXXXXXXX. Due to the above facts, Mr. XXXXXXXXXXX was placed under
arrest for No Valid DL and secured in double locked cuffs and placed in
t