Filing # 49044462 E-Filed 11/17/2016 03:57:36 PM

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION

HOLLYWALL ENTERTAINMENT, INC.,

PLAINTIFF,

DIVISION: L

-V-

CASE NO.: 16-CA-7958

BLACKRIDGE CAPITAL LLC,

RESPONDENT/DEFENDANT,
CLEARTRUST, LLC,
A FLORIDA LIMITED LIABILITY CORPORATION,
INDISPENSABLE/ESSENTIAL PARTY,
/
MOTION IN OPPOSITITION TO DEFENDANTS MOTION FOR EXTENSION OF
TIME TO FILE RESPONSIVE PLEADING
COMES NOW, Plaintiff, HOLLYWALL ENTERTAINMENT, INC. (Hereafter referred
to as HWAL), pursuant to Complex Business Procedure Rules 5.3 and 5.6, hereby moves for
the Court to deny the motion for extension of time as filed by the Defendant on November 16,
2016. Additional reasons for the denial of such an extension of time are set forth below.
1.

This matter, as the Court is aware, involves contentious litigation and motions by

the Plaintiff Corporation to stop the conversions of claimed debt by the Defendant, Blackbridge
Capital, into shares of common stock of Hollywall at extreme discounts, for a claim of a default
rate where no default rate has been found by the Court to exist.
2.

The Defendant is attempting to delay its response to the properly served

complaint at the same time that it is using such delay to force through further conversions
through the transfer agent on the very same day (November 16, 2016) that they filed for the
extension. This attempt at delay is an obvious attempt to subvert and avoid the legal process as
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they are forcing the issuance of ten million common shares (10,000,000) at the default
conversion rate of $0.0001 per share while the trading value of the stock is $0.005 per share,
which means the Defendant is again using the baseless conversion rate to receive stock at one
fiftieth (1/50th) its market value, thus severely damaging the Company and its thousands of
shareholders on the market. Cleartrust has stated that they must comply and issue such
shares on November 18, 2016. Thus by their motion the Defendant gets the benefit of yet more
share issuances, while delaying even answering the claims made against it.
3.

Without any consultation or attempt to comply with CBP 5.3. the Defendant filed

the motion for extension of time. Counsel for the Plaintiff has checked all emails and messages,
and absolutely no messages or attempts at messages from the Defendant or their counsel were
found to even attempt to confer on the matter of extension of time filed for. What is notable, is
that the Defendant or their counsel does not have the ability to file a responsive pleading in this
matter, but the very same day they submit another conversion notice for the issuance of such a
huge amount of shares at a baseless default rate in order to victimize the Plaintiff Corporaiton
and its shareholders yet again. It seems the Defendant Blackbridge has no issue with seeking to
line its own pockets by another gargantuan issuance of shares, while the same day it will not file
a response to the well formed allegations of the Plaintiff in the amended complaint.
4.

As required by Order of this Court entered on October 13, 2016, the Plaintiff has

filed an amended complaint which set forth fully the jurisdiction of the Court over the
Defendant. Additionally, the Plaintiff caused to be served on the Defendant process of service on
October 27, 2016. Additionally, the Defendant had been in possession of the amended complaint
since such was filed on October 24, 2016 and in the possession of the counsel for the Plaintiff.

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5.

This Court had refused to extend the immediate injunction on this matter, to stop

the absolutely unfounded issuance of more shares, even though the Plaintiff had completely
complied with the October 13, 2016 Order and posted a bond with the Court (which is still in
place) for $29,100.00 and at the same time posted $10,000.00 to the trust account of the attorney
for Blackbridge, which as related at the hearing on October 12, 2016 was to be for the buy out of
the principal and interest of the amount due on the note. As well the Court required the Plaintiff
to show jurisdiction of the Court over the Defendant, which the Plaintiff thoroughly did in the
amended complaint. As such the actions of the Plaintiff have fully complied with all aspects of
the Courts Orders, even though the Court chose not to extend the injunction in this matter.
6.

While counsel for the Plaintiff does not set forth doubt as to the medical issue that

counsel for the Defendant may have, the actions of the Defendant itself, Blackbridge Capital, in
attempting and forcing yet another huge conversion of shares for very little debt, must be
weighed against this request for time. As such the Plaintiff objects to such extension of time for
failure to follow the Complex Business Procedure Rules, and because such an extension when
read in light of the actions of the Defendant itself is being used, or could be interpreted as
subterfuge for the collection of such a vast amount of riches at the expense of the Plaintiff and its
shareholders.
7.

It is noted that even though the named attorney who has appeared in the case is

the one with the medical issue as cited, another attorney who is a recipient of all pleadings is a
full Florida Bar member, and actively receiving all such matters, so that a response to matters
was not inconceivable (Referring to Counsel, Tabitha Taylor, Esq. of Yarnell, PLC).

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MEMORANDUM OF AUTHORITIES
5.3 Certificate of Good Faith Conference. Before filing any motion in a civil case,
the moving party shall confer with counsel for the opposing party in a good faith effort to
resolve the issues raised by the motion and shall file with the motion a statement
certifying that the moving party has conferred with opposing counsel and that counsel
have been unable to agree on the resolution of the motion (the Certificate).
a. The term confer, as used herein, requires an actual, substantive conversation
in person or by telephone in a good faith effort to resolve the motion without
court action and does not envision an exchange of ultimatums by fax or letter.
Counsel must respond promptly to inquiries and communications from
opposing counsel. The Court may sua sponte deny motions that fail to include
an appropriate and complete Certificate under this section.
WHEREFORE the Plaintiff hereby moves for the Court to enter an Order denying the
extension of time sought by the Defendants.
Respectfully submitted,

/s/ Craig A. Huffman

_______________________
Craig A. Huffman, Esquire
Florida Bar No. 116149
Securus Law Group, P.A.
13046 Racetrack Road
Tampa, Florida 33626
Telephone (888) 914-4144
Facsimile (888) 783-4712
E-mail: craig@securuslawgroup.com

CERTIFICATE OF SERVICE
I hereby certify that this filing was served via electronic filing system to all counsel of
record on this 17th day of November, 2016.
/s/ Craig A. Huffman
_______________________
Craig A. Huffman, Esquire
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