Filing # 48164521 E-Filed 10/27/2016 11:13:12 AM

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,
/
RENEWED EMERGENCY AMENDED MOTION
FOR EXTENSION OF IMMEDIATE INJUNCTION
AND PRESENTATION OF GROUNDS FOR JURISDICTION
OVER DEFENDANT BLACKBRIDGE CAPITAL AND FOR ACCOUNTING AS TO
DEBT PAYOFF HELD BY COUNSEL
COMES NOW, Plaintiff, HOLLYWALL ENTERTAINMENT, INC. (Hereafter referred
to as HWAL), pursuant Chapter 86 et. seq., Florida Statutes and Florida Rule of Civil
Procedure 1.610 and to the Order of the Court entered on October 13, 2014, and in consideration
of the circumstances proving jurisdiction over the Defendant Blackbridge Capital, together with
the attempts by the Defendant Blackbridge to contravene the Orders and actions dictated by the
Court. Blackbridge files this Renewed Emergency Amended Motion for Extension of the
Immdiate Injunction due to the recent and immediate acts of the Defendant to again attempt to
cause the issuance of shares, 1) in contravention of the matters dealt with and ordered by the
Court; 2) for shares to be issued at a default rate which is a low fraction of what it had been
converting with under contract, when no default has been noticed or proven; 3) when such shares
should not be issued since the payoff amount for the principal and interest has been deposited

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with the Defendants attorney as Ordered; and 4) the Plaintiff has now shown extensive and
significant grounds by which this Court has personal jurisdiction over the Defendant
Blackbridge. As grounds for this Emergency Motion the Plaintiff would aver:
1.

The temporary injunction entered by the Court will expire and the shares which

were stopped by the injunction will be issued as being forced by the Defendant Blackbridge and
cause the damages that the Court had entered the injunction to avoid in the first place.
Blackbridge is currently demanding that Cleartrust issue those same shares at an illegally based
conversion price, and Cleartrust has stated that they must comply and issue such shares if
there is no Court action to extend this injunction by October 28, 2016.
2.

This Court had entered an Order on October 13, 2016, for a temporary injunction

being entered for a period of fourteen days. Pursuant to the Order, the Plaintiff has posted a bond
with the Court in the amount of $29,100.00. Such bond will remain in effect upon this injunction
being extended as related by the Bonding Company. In addition, the Plaintiff had deposited with
Counsel for the Defendant Blackbridge, in their IOTA account, the amount of $10,000.00 which
amount was to be sufficient monies to pay for all the remaining debt due and accrued interest
under the remaining portion of the note between the Parties. Such amount was more than
sufficient as agreed to at the hearing held by the Court on October 11, 2016, to cover such
amount of principal due with interest, and was acceptable to Defendants counsel at such
hearing. It should be noted that these matters before the Court and Plaintiffs counsel is now
attempting to gain the court transcript from that hearing which will show the statements,
agreement and reason behind the Courts requirement of that amount being deposited. By far as
shown herein, the bond posted with the Court in the amount of $29,100.00 is more than
sufficient to cover any conceivable damages Blackbridge could ever allege. There was no reason
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to deposit the $10,000.00 with the Defendants attorney but for the pay off of the principal and
interest due.
3.

Significantly, the Court also Ordered that the Plaintiff had fourteen days to

establish jurisdiction over Blackbridge with the Court from the date of the Order. The Plaintiff
has completed an extensive investigation of matters in relation to Blackbridge and found
significant activities within the State of Florida to subject Blackbridge to jurisdiction of the
Court. See Activities Establishing Jurisdiction below.
4.

It is imperative that the injunction entered be extended, and is being sought to be

maintained due to recent actions of Blackbridge who is attempting yet again, to convert the same
debt, which has been covered for both principal and interest by the deposit of monies into their
attorneys trust account. Such actions are yet again threatening the material, irreparable and
imminent harm to Hollywall if such action occurs. Blackbridge is attempting to use a conversion
rate of $0.0001 per share as a default rate when no such default has occurred, nor any found by
the Court. Since this Court now has jurisdiction over Blackbridge the determination of default
will be made in this litigation. In the amended complaint filed by the Plaintiff, the default rate
conversions by Blackbridge are the subject of numerous counts contained therein. (See Amended
Complaint filed October 24, 2016).
5.

The Defendant, as ademantly argued by their counsel at the hearing on October

12, 2016, had not been served with the Complaint. As such the new amended complaint has been
filed with the Court on October 24, 2016, which includes not only the jurisdictional matters
which show significant activities submitting Blackbridge to jurisdiction, but the acts which now
encompass the tortious activity of Blackbridge during the pendency of this litigation during the

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months of August through October 2016. Service of process is in the process of occurring as of
this date on the Defendant. Indeed the Defendant has received all matters through counsel, who
is now part of the filings being made in this cause of action as well, so notice to the Defendant is
well established.
NATURE OF EMERGENCY AND OVERVIEW
6.

This cause of action for extension of the immediate injunction is being filed as an

Emergency Matter as per Rule 5.18 of the Complex Business Litigation Division, since the
Defendant, over whom jurisdiction is now established, and who was a complete participant to the
earlier injunction, is now threatening and demanding that the same conversion of debt from the
involved Note be issued by the transfer agent, Cleartrust, LLC. The Defendant Blackbridge is
demanding that they be issued the amount of 9,000,000 common shares from the very same
conversion the Courts Temporary Injunction entered on October 13, 2014 had prevented from
being issued. The Defendant Blackbridge is ignoring the fact that their attorney received the
money for payment of such debt, with accrued interest, as set forth before the Court at the
hearing on October 11, 2016, as well as the fact that the debt conversion which the Defendant is
now attempting to use is completely covered and paid for in by the agreement of the Defendant,
and the intent of the Parties which resulted in the deposit of the $10,000.00 into the account of
the Defendants counsel. Cleartrust has communicated to all parties that without extension
of such Court Order, they would be forced to process the request on October 28th (Friday)
2016 and the 9,000,000 common shares will be issued to BLACKBRIDGE for sale on the
market to the extreme jeopardy and damage to Hollywall and its hundreds of shareholders.

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A.

PRESENT THREAT TO AGAIN CONVERT DEBT ALREADY PAID FOR

7.

The emergency status of this matter again rears its ugly head through the actions

of Blackbridge is due to the absolute and firm threat by Blackbridge that it is demanding the
issuance of the same shares which were the subject of the temporary injunction entered by the
Court on October 13, 2016. Blackbridge is attempting to use an illegal breach of the agreement
between the parties, to force the issuance of shares as conversion of debt at the rate of $0.0001
per share, for 9,000,000 shares for $900 in debt. This is the very same amount and transaction
this Court stopped before with the injunction, and was the reason that the Court ordered the
deposit of the $10,000.00 into the account of the Defendants attorneys trust account. That
amount was meant specifically for the satisfaction of the debts principal and interest. The
Defendants actions in attempting to convert such debt at such amount, means they are using a
default debt conversion amount where no notice of default has been made to Hollywall, and
where there is no default existing, and where the conversion rate will result in issuance of shares
at one fifty-eighth (1/58th) the current market value of $0.0058 per share. That they are
demanding the issuance which will occur without court intervention, in this extraordinarily large
amount of 9,000,000 shares, will be a value of over $45,000 when the actual amount due and
owing as principal and interest is well less than $10,000.00.
8.

The Court through accounting by the Parties can more than establish that the

amount deposited with the Defendants attorney will be more than sufficient to pay for the
remaining principal and interest due on the debt. Before the last hearing, on conversion
documents the Defendant had agreed that the principal and interest due was less than the
$10,000.00.

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B.

ACTIVITIES OF BLACKBRIDGE ESTABLISHING JURISDICTION

9.

Defendant, through counsel at the hearing held before the Court on October 11,

2016, submitted that the Defendant Blackbridge had no deals or transactions with any Florida
entities. On the contrary, the public record as established through filings with the Securities and
Exchange Commission shows that Blackbridge has significant and ongoing actions with
numerous Florida Corporations or Florida based entities. As well, Blackbridges actions it has
taken in the present case with its interaction with Cleartrust, LLC the Hillsborough County based
tranfer agent, could alone be enough to qualify for jurisdiction under the applicable law.
Other Entity Transactions within Florida or Florida Corporations:
10.

Jurisdiction over Blackbridge exists since it has entered into numerous other

transactions with Florida domesticated or companies located in the State of Florida. The
following actions were found through a search of SEC filings.
a.

On, about or before September 27, 2014,

Pardigm Oil & Gas.

BLACKBRIDGE had entered into or conducted a funding, investment or other transaction

directly with a Nevada Corporation, located within the State of Florida. On or before such date,
BLACKBRIDGE had entered into an agreement which resulted in the issuance of shares of
Paradigm Gas & Oil, Inc. which at the time was headquartered at 2701 Gulf Boulevard, Indian
Rocks Beach, Florida 33785. As reflected in a filing with the Securities and Exchange
Commission (SEC) on that date, in a Schedule 13G filing, BLACKBRIDGE revealed that its
transaction with Paradigm Oil Gas had resulted in BLACKBRIDGE being issued 21,978,000
shares. On information and belief, such transaction was a stock purchase, debt purchase or other
transaction, and BLACKBRIDGE took actions within the State of Florida to solicit such a
transaction. As such BLACKBRIDGE transacted business within the State of Florida.
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b.

Bebide Beverage Co.

On, about or before May 14, 2015,

BLACKBRIDGE had entered into or conducted a funding, investment or other transaction

directly with what shows on public SEC filings to be at the time a Florida Corporation, located
within the State of Florida. On or before such date, BLACKBRIDGE had entered into an
agreement which resulted in the issuance of shares of a Company now known as Bebida
Beverage Co. which at the time had a business address located at 1375 Sermon Boulevard,
Casselberry, Florida 32707. As reflected in a filing with the Securities and Exchange
Commission on that date, in a Schedule 13G filing, BLACKBRIDGE revealed that its
transaction with this Company had resulted in BLACKBRIDGE being issued in the amount of
63,244,048 shares. On information and belief, such transaction was a stock purchase, debt
purchase or other transaction, and BLACKBRIDGE took actions within the State of Florida to
solicit such a transaction. As such BLACKBRIDGE transacted business within the State of
Florida.
c.

Western Graphite Corp.

On, about or before May 12, 2015 and on or before

Feburary 12, 2016, BLACKBRIDGE, as shown in public filings with the SEC had entered into
or conducted a funding, investment or other transaction directly with a Nevada Corporation,
located within the State of Florida. On or before such date, BLACKBRIDGE had entered into an
agreement which resulted in the issuance of shares of Western Graphite, Inc. which at the time
had its corporate offices located at 1045 East Washington Street, Monticello, Florida. As
reflected in a filing with the Securities and Exchange Commission (SEC) on that date, in a
Schedule 13G filing, BLACKBRIDGE revealed that some form of transaction had occurred
which caused it to be necessary to file such a filing with the SEC. On May 12, 2015, such SEC
filings showed that BLACKBRIDGE had realized some 12,500,000 common shares of the

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Company. On information and belief, such transaction was a stock purchase, debt purchase or
other transaction, and BLACKBRIDGE took actions within the State of Florida to solicit such a
transaction. As such BLACKBDRIDES transacted business within the State of Florida.
d.

Metrospaces, Inc.

On, about or before March 4, 2015 and on or before

Feburary 12, 2016, BLACKBRIDGE, as shown in public filings with the SEC had entered into
or conducted a funding, investment or other transaction directly with a Florida Corporation,
located within the State of Florida. On or before such date, BLACKBRIDGE had entered into an
agreement which resulted in the issuance of shares of Metrospaces, Inc. which at the time had its
corporate offices located at 888 Brickell Key Drive Unit 1102 Miami, FL 33131. As reflected in
a filing with the Securities and Exchange Commission (SEC) on that date, in a Schedule 13G
filing, BLACKBRIDGE revealed that some form of transaction had occurred which caused it to
be necessary to file such a filing with the SEC. On March 4, 2015, such SEC filings showed that
BLACKBRIDGE had realized some 66,666,667 common shares of the Company. On
information and belief, such transaction was a stock purchase, debt purchase or other transaction,
and BLACKBRIDGE took actions within the State of Florida to solicit such a transaction. As
such BLACKBDRIDES transacted business within the State of Florida.
e.

Bulova Technologies Group, Inc. On about the month of July 2016,

BLACKBRIDGE had solicited and did conduct an aged debt purchase transaction and
conversion with Bulova Technologies Group, Inc., a Florida Corporation, with its corporate
offices located at 1501 Lake Ave SE, Largo, Florida 33771. In such transaction,
BLACKBRIDGE had communicated and solicited to Bulova Technologies Group, Inc. to do
such a transaction by conduct of telephone calls to Bulova, emails, sending documents drafted by

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BLACKBRIDGE, and other numerous actions to conduct the business with Bulova within the
State of Florida. Such matter was established through Bulova to counsel for Plaintiff.
The Present Transaction
f.

The present transaction only occurred due to the actions of BLACKBRIDGE

within the State of Florida when it offered and entered into communications into the State to
purchase the debt involved in this matter from a Florida entity. On or about June 23, 2015,
BLACKBRIDGE did communicate, solicit, and communicate with EMAX Media, Inc. for the
purchase or assignment of debt held by EMAX Media in HWAL. As a result of such actions,
EMAX Media did on or about that time, enter into a debt assignment agreement with
BLACKBRIDGE for the assignment of such debt due and owing from HWAL to EMAX. As
such BLACKBRIDGE took such actions within the State of Florida towards EMAX Media,
which was a Florida Corporation, located at 8902 Fowler Avenue, Lot D, Pensacola, Florida
32534. As such, BLACKBRIDGE did conduct business within the State of Florida.
g.

In the present transaction, BLACKBRIDGE conducted numerous actions within

the State of Florida with Cleartrust, LLC, a Florida Limited Liability Company, (hereafter
referred to as Cleartrust), is a Stock Transfer Agent located at 16540 Pointe Village Drive
Suite 206, Lutz, Florida 33558, who is the SEC registered stock transfer agent for HWAL and is
responsible for all duties of issuance and maintaining necessary stock accounting for HWAL. As
such BLACKBRIDGE during the months of August 2016 through October 2016, through the
time of the entry of the Temporary Order of Injunction on October 13, 2016, by making
telephone calls into the State to Cleartrust, wrote and sent emails and documents into the State to
Cleartrust, made demands of Cleartrust to take actions, and other manner of actions to cause

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Cleartrust to act upon the conversion of debt for issuance of shares of HWAL common stock. As
such BLACKBRIDGE was conducting business within the State of Florida.
LEGAL ARGUMENT
Floridas Long Arm Statute is set forth in Section 48.193, Florida Statutes, which
prescribes the circumstances under which an out of state defendant can be hailed into Florida
court under in personam jurisdiction. It is without doubt that under the legal authorities
applicable, that BLACKBRIDGE has submitted itself to jurisdiction within the State of Florida
and this Court.
A.

SPECIFIC JURISDICTION
Specific Jurisdiction exists over BLACKBRIDGE under Floridas long arm statute. As is

clear, Section 48.193(1), Florida Statutes lists acts under which a defendant may be subject to
jurisdiction in Florida, provided the cause of action arises out of a specifically pleaded act under
the statute. Jurisdiction under this subsection is known as specific jurisdiction. Specific
jurisdiction can arise out of a single, isolated contact with the forum state, if the cause of action
so closely related to the contact as to not offend the notions for fair play and substantial justice.
The following are the notable acts from the subsection for establishing specific jurisdiction in
this matter over Blackbridge:
(a) Operating, conducting, engaging in, or carrying on a business or business venture in
this state or having an office or agency in this state.

As shown above, Blackbridge has actively sought and engaged in activity within and into

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the State of Florida for a number of transactions for its economic gain. The specific acts set forth
above more than show the actions of Blackbridge have continuously conducted and engaged in
conduct of business into and within the State of Florida.
B.

GENERAL JURISDICTION
Subsection (2) of Section 48.193, the long arm statute provides a basis for establishing

general jurisdiction:
A defendant who is engaged in substantial and not isolated activity within this state,
whether such activity is wholly interstate, intrastate, or otherwise, is subject to the
jurisdiction of the courts of this state whether or not the claim arises from that activity.
The defendant must also have minimum contacts with Florida which have been set forth by the
facts of the Five other entities that Blackbridge has acted for its own financial benefit when it
actively and continuously engaged in business within the State of Florida.
Minimum Contacts of Blackbridge to Florida
When determining whether a Florida court has jurisdiction over a defendant, the court
looks to see if the complaint alleges sufficient jurisdictional facts to bring the action within the
ambit of the long arm statute; if it does, then the court must decide whether there are sufficient
minimum contacts to satisfy the due process requirements. See Venetian Salami Co. v.
Parthenais, 554 So. 2d 499, 502 (Fla. 1989). The test for determining minimum contacts looks to
whether the defendant purposefully made contacts in the state and whether the defendant should
reasonably anticipate being haled into court in the state. See Burger King Corp. v. Rudzewicz,
471 U.S. 462 (1985).
A corporation having minimum contacts in a Florida can be seen as having a continuous
and systematic business contact with the state of Florida. A company that has consistently
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sought financial gain or strategic advantage from activities directed at residents of Florida will
have minimum contacts to establish general jurisdiction. Consistent actions of a companys
authorized agent or company-controlled subsidiary to further the companys goals within in the
state are usually sufficient to create minimum contacts with the state. In previous cases, out of
state corporations have established minimum contacts through the sale of products that targeted
at Floridians, without anyone from the company ever entering Florida. See e.g. Murante v.
Pedro Land, Inc. 761 F. Supp. 786, 790 (S.D. Fla. 1991)(Pedro Land Inc., a.k.a. South of the
Border never entered Florida, but their fireworks sales on I-95 were targeted at Floridians).
While the forseeability of a companys product being used in Florida is not alone determinative
of sufficient minimum contacts, a company that knows a significant number of its products are
being shipped to Florida will be found to have minimum contacts. Louis Winer Co., Inc. v. San
Francisco Mercantile Co., Inc., 501 So. 2d 171, 173 (Fla. 4th DCA 1987).
In this situation as shown above, Blackbridge has continuously conducted business within
the State of Florida for its own financial gain, by the entry into similar transactions with a
number of domiciled Florida corporations, or companies located in the State. As well
Blackbridges current conduct in this State shows that specific jurisdiction exists, as well as
potentially satisfying general jurisdiction as a matter of law.
CERTIFICATION OF COUNSEL AS TO NOTICE
TO RESPONDENT/DEFENDANT BLACKBRIDGE
The Respondent/Defendant BLACKBRIDGE is currently represented by Counsel in
this action, and such will receive the filing of this Renewed Emergency Motion for Extension of
the Temporary Injunction.

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THE INJURY COMPLAINED AND PREVIOUSLY ENJOINED IS AGAIN

IMMINENT AND ONGOING
The temporary injunction entered by the Court will expire and the shares which were
stopped by the injunction will be issued as being forced by the Defendant Blackbridge and cause
the damages that the Court had entered the injunction to avoid in the first place. Blackbridge is
currently demanding that Cleartrust issue those same shares at an illegally based conversion
price, and Cleartrust has stated that they must comply if there is no Court action on this
injunction by October 28, 2016. Such issuance is based on a completely false default rate which
has been shown in the amended complaint and herein to be unsupported and must not be allowed
to occur. The Plaintiff Company and its shareholders will again suffer the same harm threatened
before, when in fact the Defendant has been paid for the principal and interest through the
deposit to their counsel, as well as a bond is fully in place to cover any claimed to losses, and
the Plaintiff has shown jurisdiction over the Defendant. Again the imminence of harm is within a
day of occurring if such shares are issued and then sold by Defendant on the public market, since
they were issued based upon fraudulent or at least misrepresented circumstances will be an
abomination on the true market of the stock, and will dilute the price inordinately and falsely
against the actual market value of the shares which should be reflected.
NECESSITY OF BOND
Due to the prior Order the Plaintiff had posted a $29,100 bond with the Court, which the
Court found sufficient, and such bond can be maintained with the Court.
CONCLUSION AND PRAYER FOR INJUNCTIVE RELIEF
The issuance of shares as requested and demanded by BLACKBRIDGE CAPITAL
which had been subject to the immediate injunction entered by the Court on October 13, 2016
should be extended for the pendency of this cause of action. The current pending issuance of
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shares being threatened is based on an illegal represented default rate. The Courts Order for the
Plaintiff to show that the Court had jurisdiction over the Defendant has been satisfied by the
extensive showing herein as well as the amended complaint. Any and all further issuances should
be subject to an extended injunction to stop any further issuances of shares to the Defendant.
Such injunction should be immediately entered by extension of the injunctive order stopping any
and all such stock issuances of Hollywall shares, their deposit or sale while this matter is
pending or until a full hearing on a permanent injunction is conducted as part of the related
litigation filed by the Plaintiff Company. The current bond set forth should be adequate for
purposes of extension of this injunction. In addition a full accounting can be made to show that
the amount of money currently held by the Defendants counsel is adequate to cover the payoff
of all pending principal and interest on such debt the Defendant claims is still owed.

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

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CERTIFICATE OF SERVICE
I hereby certify that this filing was served via electronic filing system to all counsel of
record on this 27th day of October, 2016.

/s/ Craig A. Huffman

_______________________
Craig A. Huffman, Esquire

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