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You can't just file a complaint in court, go "someone somewhere said something illegal but I won't cite it or show any proof, so give me the detailed account of 500 people now"
These social media companies will destroy this in court. The motion to compel will simply lead to iHub filing and killing the case all together. He already admitted on iHub himself it is a witch hunt and that people on the list hadn't mentioned him in 4 years. Jake can't help but ruin his own plan because he is so arragent and petty.
I've watched this type of claims with other CEOs when their shareholders get pissed and express their disappointment after the CEO has destroyed the value.
Why does it not surprise me that the kid sits in chat room as opposed to working to gain shareholder value?
My interest level just climbed here.
Go. Song. Incredible revenues starting to come back and takeoff.
I'm pretty sure these "threats" need to be more specifically identified... And calling a scam a scam or a fraudster a fraudster or reporting scams and fraudsters doesn't count as a threat.
..
.
I presume Jake has screenshots of all these threats because I haven't seen them in any posts.
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=174356748
Incidentally, if you have a guinea pig or similar small pet, Jake won't try and sue you:
https://investorshub.advfn.com/boards/read_msg.aspx?message_id=174355761
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CASE NO. 11-2024-CA-000814-0001-XX
JAKE P. NOCH, and
MUSIC LICENSING INC.
Plaintiffs,
v.
JOHN DOE, et al.
Defendants.
__________________________________/
PLAINTIFFS’ MOTION TO COMPEL DEFENDANT’S COMPLIANCE WITH
SUBPOENA & MOTION FOR SANCTIONS
Plaintiffs, JAKE P. NOCH and MUSIC LICENSING INC. (hereinafter collectively “Mr.
Noch”) by and through their undersigned counsel, submit this Motion to Compel Defendant’s
Compliance with Subpoena to INVESTORSHUB.COM INC. (hereinafter referred to as “iHub”)
to obtain the identity of the Defendants. As such, identities of Defendant are unknow, thus iHub
are required to submit users’ account’s state drivers’ licenses, identification cards, e-mail
addresses, home addresses, phone numbers, and any other relevant information to the user
individuals included on the issued Subpoena. The following in support thereof:
Discovery Requests
1. Mr. Noch received several defamatory and threatening remarks made against them from
multiple user accounts on iHub.
2. Some of these statements were targeted towards Mr. Noch and his family.
Filing # 199895979 E-Filed 06/05/2024 01:11:04 PM
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/05/2024 01:11:04 PM
3. Defendants are hiding behind these iHub accounts and have repeatedly harassed Mr. Noch
by spreading false information and continuing to act threateningly.
4. Due to the non-stopping false and threatening statements, Mr. Noch hired the undersigned
counsel to commence an action to obtain the information of the owners of these accounts.
5. On May 10, 2024, the Plaintiffs issued to the Defendant their Subpoena. (Hereinafter
referred to as “Subpoena”).
6. On May 17th, 2024, Defendants’ Counsel contacted the opposing Plaintiff’s Counsel via
email and U.S. mail to object to Plaintiff's Subpoena, alleging that the users are protected
under their First Amendment. However, the First Amendment does not protect users from
illegal conduct.
WHEREFORE, the Plaintiffs respectfully request this Court to enter an Order to
compel the Defendant to respond to the Plaintiffs’ request to produce, to sanction the
Defendant with any alternative or additional relief the Court deems appropriate under the
circumstances, including attorneys’ fees and cost.
Respectfully submitted,
Transnational Matters, PLLC
BY: /s/ Davy Karkason, Esq.
Davy Karkason, Esq.
Florida Bar No.: 1031867
Attorney for Defendant
2121 Biscayne Blvd., # 1878
Miami, FL 33137
Office: (305) 417-9866
E-mail: dk@transnationalmatters.com
paralegal@transnationalmatters.com
[certificate of service on next page]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of June, 2024, this Motion was
electronically transmitted to the Clerk of Court and all parties of record via the
Florida Courts E-Filing Portal (“FCEP”), and a true and correct copy of the foregoing
has been furnished by electronic mail to all counsel of record.
Respectfully submitted by,
Transnational Matters, PLLC
BY: /s/ Davy Karkason, Esq.
Davy Karkason, Esq.
Florida Bar No.: 1031867
Attorney for Defendant
2121 Biscayne Blvd., # 1878
Miami, FL 331
https://cms.collierclerk.com/CMSWeb/home/pdfframe?k=QuueFLJ+XrKYIVf8NQbfDO1V00RDTUDTfrKoBnX/dEpBydOVPy2Fs0wdGeg0a8z/GlY8nAm8qIMrP5KxQJzGRA==
Yepper !!
Sounds familiar, some striking similarities and resemblance to this CEO with his so called company and other penny stock takeover attempts.
Yeah, he is a pathetic excuse for a human being......
Doesn't Matter ?
I clicked the link. it's crap rap...to you and me...but has had 31m views...
It's music with a pretty short shelf life. Most of the views could have been when it was new 4 years ago. As the years go on they'll be going down. To put it in perspective, this was one of a package of 13 tracks Jake paid $10,000 for, knowing they had only made $1500 in the previous 12 months. This is one of three tracks which made the bulk of that $1500.
He's already paid for two PRs about them which I think cost at least $300 each.
https://auctions.royaltyexchange.com/orderbook/asset-detail/5683/
I clicked the link. it's crap rap...to you and me...but has had 31m views...
Sounds familiar, some striking similarities and resemblance to this CEO with his so called company and other penny stock takeover attempts.
SONG: NO DRIBBLE OR NO DRIVEL LMAO ???
LIL JAKE BOUGHT MORE SHIT LICENSES LOL !!!
Looks like DIRTY JAKE aka THE KID must of gotten a new credit card offer in the mail - and charged a few more worthless "Music licenses" to his VAST portfolio of noise and AI generated crap and Listerine jingle bells....LMAO !!!!!
https://finance.yahoo.com/news/dababy-stunna-4-vegass-no-142900804.html
Friday June 7, 2024
DaBaby and Stunna 4 Vegas's "NO DRIBBLE" Joins Music Licensing, Inc.'s Portfolio
Fiscal Year End 12/31... So, it's quite late, and with no late notice.
..
.
$SONG SCAM : OVER/UNDER ON SUB ONE $BUCK :))
https://www.otcmarkets.com/stock/SONGD/disclosure
Bid $10 / Ask $20 LMFAO !!!!
$15 (current price) / 500,000 = .00003
TRUE SHARE PRICE LOL !!!
Market Cap is 6,000 shares O/S X $15 = $90,000
Momma Regina probably paid more in Annual Property Taxes for the luxury crib where DIRTY LIL JAKEY slums n bums w/ her !!
Vegas Odds Line has this at SUB ONE SHITTY JAKE $BUCK before summer is even over - hell, I'll go out on a limb here and say BEFORE JULY 4th.... this shit heap scam....."tags".... a trip to THE SUB ONE $BUCK DEATH ZONE...... LMAO !!!!
Uh...?????
So where is that Q??
Yepper !!
what if Jake "accidentally" misses the filings, goes to EM again, and he buys all ~6000 shares for next to nothing. I would not put it past him.
"Getting a motion for sanctions for someone who is broke and likely can't keep up with the bills may not be worth it."
what if Jake "accidentally" misses the filings, goes to EM again, and he buys all ~6000 shares for next to nothing. I would not put it past him.
I JUST found that too, defendant is in another state. Stupid they even tried Collier first.
They're moving one of those cases to Federal Court.
https://dockets.justia.com/docket/florida/flmdce/2:2024cv00527/428552
..
.
Nothing else, Stephen is about to rethink this whole thing. Getting a motion for sanctions for someone who is broke and likely can't keep up with the bills may not be worth it.
"abuse of process" is the avenue everyone affected should look into and use against both Noch and his attorneys I would think. This draws the attorneys directly into having to pay damages to defendants they are suing on Mr. Noch's behalf. This seems to be the way to go after the attorneys. IMO sanctions are not sufficient alone. You should all also collect damages from these attorneys. This certainly would include those he was trying to unmask with his SLAPP. I would assume this is causing everyone a great deal of emotional stress they may never recover from. Here:
Abuse of process is a common law tort that involves the misuse of legal process(es) for an ulterior purpose. Abuse of process is one of several actionable offenses aimed at discouraging bad-faith litigation attempts. Indeed, courts hold the authority to sanction parties for bringing frivolous action, and parties also have a right to action under the claim of malicious prosecution.
Generally, the elements for abuse of process are: (1) the use of an illegal or improper use of process; (2) an ulterior motive or improper purpose; and in some jurisdictions (3) harm to a litigant. For the purposes of abuse of process, an arbitration proceeding is a judicial proceeding. Abuse of process has been described as misusing a "criminal or civil process against another party for a purpose different than the proceeding's intended purposes" and thereby causing the party damages (e.g., arrest, seizure of property, or economic injury).
A classic case of abuse of process entails an attempt by a plaintiff to coerce the defendant to do some collateral thing which they could not be legally and regularly compelled to do. For example, in a case where a former employer sought to bring criminal charges to its employee to recover stolen money, while knowing that the employee was not responsible for the theft, the court held the employer liable for abuse of process for initiating criminal charges while knowing that the charges were unsupported by probable cause.
In regard to defenses to abuse of process, there is disagreement among jurisdictions on whether good-faith reliance on an attorney's advice in bringing action serves as a complete defense. Still, attorneys who bring the improper process can be held liable to the damaged party as well.
Yes. Stephen B. Gebeloff must looked at Jake's sign-up and contract system and seen it was deceitful, but went ahead and took these cases. If he didn't, and just believed what Jake told him, that should also be reason for sanctions.
LMAO OMG !!!
JAKE P. NOCH -----> JUSTIN COSTELLO
A move for sanctions defiantly applies here. Not only is this case frivolous, I believe it is based on illegal conduct.
.
..
.
Don't do that shajandr. You probably made him cough and he probably almost dropped something made of glass on the ground reading that. Do you want to ruin a perfect day in the Florida sunshine? Important CEO's like him need to concentrate on scheming who to shakedown with the next lawsuit. They don't need to waste their time scrambling to replace items made of glass. Guys like that have their priorities.
BOOM! People getting sued are going for blood. Now making motions for sanctions against Jake's lawyers 😂
See 11-2024-CA-000849
DEFENDANT’S NOTICE OF SERVING MOTION FOR SANCTIONS
PURSUANT TO SECTION 57.105, FLORIDA STATUTES
Defendant, Attitude Dance Center, LLC, by and through the undersigned counsel, and
pursuant to Fla. Stat. § 57.105, hereby gives notice of serving its Motion for Sanctions upon
counsel for Plaintiff, Pro Music Rights, Inc. on June 4, 2024.
SHUMAKER, LOOP & KENDRICK, LLP
JAKE P. NOCH wants a double burger - is put on a payment plan:
JAKE P. NOCH -----> JUSTIN COSTELLO
"it's almost impossible to know where all that money went"
It explains all his actions and why he was pushing so hard to get his first set of shares sold and the urgent push 4 times for an illegal 3a10. It is likely the reason collections stopped, he couldnt pay. Because he is mixing his personal finances and company finances, it's almost impossible to know where all that money went.
But what is clear, he's been broke for a while and thats clearly driven most, of not all, his actions to date. The cc lawsuit notes he stopped paying a while ago and he even had to pay over time a large % of that then just stopped paying.
I have to assume someone who cant pay off that amount has more coming. Really telling... I suspect a ton more 3a10 shares to hit soon and dump the stock back down.
Even worse than I thought. He is finished. Period. What a fool. Jake the Snake. And his poor father (what that man must have gone through, no one can imagine) is not around to bail him out of these situations.
That credit card thing actually does more damage to him than anything. That sticks out like a sore thumb. It'll take decades to build trust again on that alone. Someone even with a very low paying job could have made just a call, and made an arrangement to pay a little over a grand a month back then (closer to $1,500.00 per month now with the interest rates), and had that paid off in two years.
Anything serious in business or work, with really large amounts of cash or dealing in any of the really valuable goodies like weapons, drugs, radioactive material people will pay an arm and a leg for; and either the people you do business with or the government is going to do a lot more investigating than just a routine criminal, drug, credit, and background check. They won't get very far. That will really stick out as untrustworthy and irresponsible; especially for someone of his background for it to get that far.
Secondly, just the sheer amount of litigation will stick out right away. None of the individuals who make things happen are going to want to be involved with him in any manner. Litigation, unless it is really one-sided in your favor, is something anyone, with anything on the ball, avoids.
He's finished from anything worthwhile until well into middle age, and that is if he turned things around immediately, which he is no signs of. He has put himself into a hole that will take at least two decades, again if he straightened out immediately, to build out of. This "CEO" isn't even as valuable a member of society as a teenager who is clean and doing something, anything, constructive. Jake is his own worst enemy and hasn't figured out even that much yet. Honestly, I don't think the kid could manage to figure out how to put his hand through a wet paper bag.
Red flags are us.
$SONG: Bid $13 / Ask $28 SCAM LMAO !!!
NOTHING spells OTC SHIT TICKER than a spread wider than the Grand Canyon and near $ZERO volume and/or one shit trade dropping it 50% as just happened minutes ago LMAO !!!
https://www.otcmarkets.com/stock/SONGD/disclosure
15.00
-15.00
-50.00%
13.05 / 28.00 (1 x 1)
.000015 pre-split, is this the shareholder value promised?
$SONG: FILE FTC FEDERAL COMPLAINT ASAP !!!
Another response to Jakes extortion scam. Same defense, same attorney as Trey....
Attitude Dance Center response
https://drive.google.com/file/d/1JqKhic1AkvTXgy918dzcxh4-8LX0hh3M/view
He's broke. He needs to dump shares to raise capital to pay bills and continue to push out lies to investors to sell more shares. He'a selling shares through an illegal 3a10.
I see nothing from the social media companies. I am referring to the collections cases which are... not going great for ole Jakey poo.
Did twitter, ihub, and any other social media source give him the information the subpoenas requested? Are you referring to his cases collecting royalties?
.000015 pre-split, is this the shareholder value promised?
I am watching all the lawsuits. Two defaulted judgements for people who couldn't afford a lawyer, three people have responded and ripped him a new one, one asked for more time. He's toast. There will be no collections...
In this tweet from May 11th Jake claims people are harassing and threatening both his counsel and the opposing counsels in his "collection campaign".
Music Licensing, Inc. (OTC: $SONG) intends to provide an update on the collection campaign after receiving the first batch of subpoenas back from Twitter. The reason for the lack of updates is cyberstalker(s) emailing our legal counsel, the opposing counsel, the judge, and random…
— Pro Music Rights (@ProMusicRights) May 11, 2024
Another response to Jakes extortion scam. Same defense, same attorney as Trey....
Attitude Dance Center response
https://drive.google.com/file/d/1JqKhic1AkvTXgy918dzcxh4-8LX0hh3M/view
..
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TA still not allowed to update share structure...
https://www.otcmarkets.com/stock/SONGD/security
..
Buyer Beware
Pump and dump
.
Jake is of coures full of it. He dosn't make the list anywhere in the world.
United States
AFM & SAG-AFTRA Intellectual Property Rights Distribution Fund
Artists Rights Society of New York (ARS)
American Society of Composers, Authors and Publishers (ASCAP)
BMI, the Broadcast Music Inc.
Christian Copyright Licensing International
Christian Video Licensing International
Copyright Clearance Center (CCC)
Motion Picture Licensing Corporation (MPLC)
SESAC, a US-based performance rights association
SoundExchange, a performance rights association
VAGA, a visual artists collecting society
ACEMLA, Asociacion de Compositores y Editores de Musica Latinoamericana, formerly SPACEM, a P.R.O. in Puerto Rico
Wow. It's great to finally meet one of Jake's last shareholders here. Do you know the 8 or 9 other ones?
You think SONG makes money? How does it make money?
Jake spent $79,500 on royalty stakes in Listerine which earn around $2500 a year, so he might make some money from them in 31 years.
https://auctions.royaltyexchange.com/orderbook/asset-detail/5538
Jake spent $35,000 on royalty stakes in some old album tracks which should currently bring in about $3000 a year.
https://auctions.royaltyexchange.com/orderbook/asset-detail/5694
Jake spent $160,000 on these which made $21,000 last year:
https://auctions.royaltyexchange.com/orderbook/asset-detail/5405
Jake spent $10,000 on these even though they made just $1,500 last year.
https://auctions.royaltyexchange.com/orderbook/asset-detail/5683/
What is great about the last one is that if you click on the "Rights" tab there's information on all the US PROs, which for some strange reason doesn't mention Pro Music Rights even though Jake says it is the third biggest.
Per the court system in Collier County, SONG is bleeding money so bad Jake can't pay his credit cards
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