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 StipulationCASE 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