USA Investors / Malik Zaman Hamid Zaman, a Pakistani chubster He thinks he can silence me with a very frivolous lawsuit

Looks like your wife Zarina is no longer part of your corrupt company.  I will miss her.  Why did my bud leave your company?  Did she not want to be associated with your scam company anymore?  But it looks your daughter Nida is still hanging around.  

DEFENDANT'S 

 PRO-SE MOTION TO DISMISS THE COMPLAINT

COMES NOW the Defendant respectfully moves this Court, pursuant to Florida Rule of Civil Procedure 1.140(b)(6) files her Motion to Dismiss the Complaint of Plaintiff MALIK HAMID ZAMAN and in support therefore states:

1. In response to the Complaint, Defendant files this Motion to Dismiss based upon Plaintiff’s failure to state a cause of action on all counts.
2. The complaint filed by plaintiff Malik Hamid Zaman (“Plaintiff”) attempts to allege so many ludicrous and mind-numbing counts against Defendant based upon a terminated listing agreement between Defendant and Plaintiff.  The listing agreement was terminated voluntarily by Plaintiff after Plaintiff received an ethics violation notice from the Realtor Association of Palm Beach.  (Exhibit A)  No one had put a gun to the Plaintiff’s head to cancel.  He knew it would not be easy to find me plus he was tired of getting people complaining about him to the Realtor Association.  Plaintiff never had access to the house and spent $0 in marketing of the house except to lock Defendant’s house in MLS listing for 1 month and yet still demanded a “commission”???  Can you believe someone like that exists?  Did he really see “easy money” target?  Based on all of the foregoing, Plaintiff has failed to state a cause of action under Florida law and thus all Counts must be dismissed.
3. The complaint filed by plaintiff Malik Hamid Zaman (“Plaintiff”) attempts to allege so many ludicrous and mind-numbing counts against Defendant based on the truthful online reviews and complaint letters.  Defendant is protected by the First Amendment for statement of facts and opinions written online and letters and emails to everyone in the world. Facts are something that Plaintiff knows nothing about. Just read his ludicrous lawsuit b/c it can really make your head spin.  Based on all of the foregoing, Plaintiff has failed to state a cause of action under Florida law and thus all Counts must be dismissed. 
4. Because Plaintiff is too lazy to find me, Defendant files motion to dismiss based on insufficient service of process. Plaintiff cannot leave documents with tenants when it is not the Defendant’s usual place of abode.  What does it mean when tenant says “she moved out”?  Because Plaintiff has no lawyer experience, Plaintiff likes to make up stuff... oh, wait that is his usual MO.  
5. Defendant files motion to dismiss based on wrong venue. Defendant moved far, far way and does not consider the house her home.  Just because it is in the listing agreement does not mean that she lives there.  Plaintiff already knows that is not her residence because it was told to Plaintiff.  However, property is not in litigation as the contract was cancelled by Plaintiff.  
6. Plaintiff’s lawsuit has no merit and its sole intention was to intimidate Plaintiff and to stop the ethics violation hearing with the RAPB. (Exhibit B).  Plaintiff has filed similar lawsuits against Jack and Jill, Silly Putty (shame on you for making her go thru h*ll), etc.. all who also had filed an ethics violation against Plaintiff with the RAPB and most cases were eventually dismissed or pending.  (Exhibit C)  In addition, pursuant to Fla. Stat. § 501.2105(1), Defendant should be awarded expenses of $20,000 which includes time off from work, being a nervous wreck b/c of possible job loss, flights, car rentals, gas, hotel expenses, phone consultations with attorneys, researching and writing motions, and emotional distress dealing with the maniac and his frivolous claim and looking at his slimey scammer face in court. (GAG)

CONCLUSION

WHEREFORE, Defendant respectfully requests the Court dismiss the Complaint in its entirety with prejudice, and for such other and further relief as the Court deems just and proper and if there’s any justice at all in the world, Plaintiff aka Attorney wannabe should be thrown in prison and the key lost forever.

Respectfully submitted

 ________________________________

 Pro-se Defendant

                                                  CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July ___, 2019, I have mailed a true copy of the foregoing to:

MALIK ZAMAN

4440 PGA Boulevard #600

Palm Beach Gardens, FL 33410

Malik, if you are reading this, I want you to know that my motion to dismiss is waiting.  I wrote it myself.  Not much there in your 150-page poorly written lawsuit full of lies.  By the way, I know lies come so easily out of your mouth as they do in the lawsuit that you wrote.   

If you were smart, you would know better than to mess with someone who told you to cancel the listing agreement TWO days after it was signed esp when you were given no access to the house. Thanks to Derrick for his honest review that I found out about you but you didn't make sense and I should have known better. 

It is too bad that Derrick didn't have the money for a lawyer; heck I could easily have written his defense for him.  His freedom of speech - as long as it is truthful - is protected.  It is also too bad you didn't pay Derrick for all the work he did for you but instead you are trying your best to make his life miserable by appealing your stupidly ridiculous lawsuit against and boy... you even tried to get him arrested like you did with me. 

The police have better things to do than write up your lying complaints.  Instead they should be putting you under lock and key for scammng people.   I'm waiting for you - spend more of your "hard earned" (cough, cough, aka OPM) money to find me so we can put your frivolous lawsuit to rest.  Even your lies can't help you.  

I just realized that you had my house hostage for just a month but darn, it sure seemed longer.  I thought it was 2 months.  And I was on vacation for 2 weeks in that month so it must be because you harrassed me so much that it seemed sooo soooo long.  

I have restarted filing more complaints about you.  I won't stop until you lose your real estate license.  If you cant make an honest living as an real estate agent, then sign up to be a street or park cleaner by picking up doggie doo.  Thats more befitting of you or just get the he* out of the US.  Oh, you are not cut out to be any type of lawyer.  One can easily tell by your lame lawsuits.  California didn't admit you to their bar so no, you are not a lawyer.  I doubt if you even took the bar exam in California.  

PS.  Your family should be ashamed of themselves, your wife (she must be very desperate), your kids (hope they didn't turn out without morals like you), and whatever grandkid you said i had harrassed in your lawsuit.   

Your end as a so-called real estate agent will come to an end, Malik.  Still working on them to revoke your license.  You violated Florida statute 455.227.  Next stop will be the new governor and the attorney general.  We need tougher laws on frivolous cases. 

 You know that you hired 3 lawyers to represent you and all 3 filed a motion to disqualify.  You need to start paying your bills instead of spending an exorbitant amount of time in court and using lawyers just to play mind games with your victims who filed ethics violations against you. 

You also need to start paying your mortgage or I sure hope you don't get another home or an apartment soon.   Maybe it's good if you sleep outside where you belong.    Poor Loandepot.com waiting to be paid. 

So Zaman files something like 150-page lawsuit against me right before the ethics violation hearing. Realtor Association of Palm Beach cancels the hearing because of their policy that there cant be a hearing with a pending lawsuit. RAPB is part of the problem with their money hungry focus.

A week before the hearing, Malik was texting and emailing me every day, pleading (in a very bizarre way) that I drop the charges. I ignore him, of course. So now this man who cant make an honest living by being a real estate agent files a frivolous lawsuit. He claims he will go to California. I sure hope so coz Calif courts will penalize him 3x settlement for filing frivolous lawsuits. We gotta change FLs court system to be like California. I detest bullies!!