Replies to post #10158 on Music Licensing Inc (SONG)

[gulliblebob]

now with the stock at 2 dollars, that's $.000004, its nothing, but what's happening is that they have more stock introduced into the market, its going all the way back done to a penny. At some point, this kid might have some serious problems

[tdbowieknife]

Jake is asking for 6 million a year salary as part of Judgment.

IN THE COUNTY COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
CIVIL ACTION
Jake P Noch Family Office LLC CASE NO. 11-2024-CA-000998-0001-XX
a Florida Limited Liability Company,
Plaintiff,
v.
Baron Capital Enterprise Inc.
a Florida Corporation,
Defendant
______________________________________


PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
Plaintiff, Jake P Noch Family Office LLC, pursuant to Florida Rule of Civil Procedure
1.500(b), hereby respectfully moves this Court for a default judgment against Defendant, Baron
Capital Enterprise Inc., and states:
1. This is a civil action for damages in excess of $50,000, against Defendant.
2. Plaintiff owns more than 250,000,000 shares in BCAP.
3. BCAP is the symbol that Defendant uses to trade on the Over The Counter Market.
4. On May 13, 2024, Plaintiff commenced this suit, asserting bought common shares
over the OTC market from Defendant, and Plaintiff took a position within
Defendant’s company and owned over a substantial amount of common shares as
of today.
5. Defendant was not and is currently not compliant with its annual or quarterly
reporting requirements as a publicly traded company therefore, as a shareholder,
Plaintiff requested in writing to Defendant corporate records of the company.

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WHEREFORE, Plaintiff respectfully requests that this Court enter an Order granting a
default judgment against Defendant Baron Capital Enterprise Inc. in favor of Plaintiff and
granting Plaintiff’s initial requests in the Complaint and such other and further relief as this
Court deems just and proper. Furthermore, Plaintiff requests that this Court:
1. Appoint Plaintiff as Chairman of the Board (COB) and Chief Executive Officer (CEO) of
Baron Capital Enterprise Inc. without the need to hold a formal shareholder vote.
2. Grant Plaintiff custodianship of Baron Capital Enterprise Inc.
3. Remove all existing share classes that Plaintiff deems necessary.
4. Provide Plaintiff with a voting control block as part of this process.
5. Address and resolve any voting rights issues as requested by Plaintiff.
6. Plaintiff’s annual salary as a custodian would be paid as a form of convertible note. The
convertible note shall permit the Custodian Jake P. Noch or his affiliated entities or third
party entities to receive shares until Jake P. Noch is able to realize six million dollars
($6,000,000.00) in cash with any other expenses incurred to realize this amount.
Additionally, Plaintiff will receive 50% of the net profit of all future ventures that Plaintiff
formalizes under the company. The note shall remain valid and in effect until Mr. Noch
realizes six million dollars ($6,000,000.00), and additional shares may be added to the
convertible note as necessary in order for such amount to be received. The entity shall
indemnify Plaintiff due to unknown liabilities that may pre-exist. This salary mechanism
is for the risks undertaken and costs incurred in cleaning up regulatory issues, restructuring
the business, and acquiring or building a new company, ensuring the continued benefit to
shareholders.
7. Conduct the reimbursement, convertible note, and the shares related in this transaction as
a 3(a)(10) exemption of the Securities Act of 1933 and hold a fairness hearing to ensure
compliance with the exemption process.
Additionally, the custodian will take over the Series AA shares, BB shares, and any other control
blocks and will have the discretion to determine the structure of the shares currently in existence.
Furthermore, Plaintiff requests the Court to create a class of shares called Preferred J Class with
the following rights:
1. Each share in the Preferred J Class can vote on all matters.
2. The Preferred J Class is intended to be exclusively held by Jake P. Noch or his affiliated
entities.
3. The Preferred J Class will have 80% voting power across all classes of shares of the
company.

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Explanation of Benefits of 3(a)(10) Exemption:
The 3(a)(10) exemption under the Securities Act of 1933 allows for the issuance of securities in
exchange for bona fide claims without the need for registration under the Act, provided that a
fairness hearing is held and the court approves the transaction. This exemption is beneficial for
the following reasons:
1. Efficiency and Cost-Effectiveness: By utilizing the 3(a)(10) exemption, the transaction
can proceed without the lengthy and costly process of registration with the SEC, saving
time and resources for all parties involved.
2. Protection for All Parties: The requirement of a fair hearing ensures that the interests of
all shareholders and stakeholders are considered and protected, providing a transparent
and equitable process.
3. Regulatory Compliance: The exemption allows the company to comply with securities
laws while addressing the urgent need for restructuring and regulatory clean-up, which
are necessary for the company's survival and future growth.
4. Facilitates Reimbursement and Investment: This process enables Plaintiff to be
reimbursed for the significant risks and costs undertaken in the restructuring and clean-up
process. It also facilitates the necessary investment to acquire or build a new company,
ultimately benefiting the shareholders by restoring the company’s viability and enhancing
its value.

https://cms.collierclerk.com/cmsweb/


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