IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

IN AND FOR PALM BEACH COUNTY, FLORIDA

CIVIL DIVISION

MALIK HAMID ZAMAN

Plaintiff,

VS. Case Number: 502015CA009809XXXXMB

NO- 1 DERRICK MONTAVIOUS CREW (Alias) Morals Man

NO -2 ADA BERRIOS (Consumer)

Defendants.
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PLAINTIFFS MOTION FOR CONTEMPT AGAINST DEFENDANTS

Plaintiff, Malik Hamid Zaman(Pro se) hereby file this Motion for Contempt against
Defendants, Derrick Montavious crew(Alias) Morals Man and Ada Berrios (Alias) Consumer
(collectively, Defendants) and state as follows:

1- Defendants has failed to abide by the terms and conditions of the final judgment. dated
January 24, 2017, The Plaintiff requests the court to enter an order requiring the violating party to
abide by those terms and conditions of the Final Judgment through enforcement actions by
making sure that Defendants complies with directions of the final Judgment.

2- On May 2, 2016 this Court held a hearing on Plaintiffs Motion for Partial Summary Judgment
against the Defendants and determined that the Plaintiff is entitled to the partial summary
judgment as a matter of law in his favor against the Defendants for the complete retraction and
De-Listing and permanently removing and de-indexing of all these false and defamatory
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 statements and offending web page links as listed here, A true and correct copy of the Summary
Judgment is attached hereto as Exhibit A. {Pages M-9 to M11}and Defendants were ordered
for full retraction and removing of all these false, defamatory, derogatory and reckless inaccurate
statements (allegations) made on the Rip-off website and other social media site
and enjoin them for further publication of such false statements tortuous
Interference, Stalking, Trespass and Defamatory Blogs regarding the Plaintiff and Plaintiffs
business practice, enjoining Defendants, and all others acting by them, through them, with
their, or on their behalf, from directly or indirectly publishing any blogs or any other
written or spoken matter calculated to defame, tortuously interfere with, invade the
privacy of, or otherwise cause harm to Plaintiffs.

See court order rulings about May 2, 2016.

finding that:
For the reasons provided in the supporting Memorandum, Plaintiff contends
that there is no genuine disputed issue as to any material facts for the posting
of these defamatory and false statements on the internet like rip-off reports,
Google, Yahoo and Bing and other social media and the contents of all these
postings were false .
Plaintiff is entitled to the partial summary judgment as a matter of law in his
favor against the Defendants for the complete retraction and De-Listing and
permanently removing and de-indexing of all these false and defamatory
statements and offending web page links as listed here

Order of removing, retracting and De- indexing from the Rip-off

report Web site, "Google" "Yahoo" and "Bing" posted against the
Plaintiff's real name and the Marketing name "Malik Zaman" Zaman
Malik" "Malik Hamid Zaman Sr" "Malik Hamid Zaman" and Plaintiff's
business name American Immigration Dream Realty L.L.C, Plaintiff
contend that there is no genuine disputed issue as to any material fact and
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 that he is entitled to the partial summary judgment as a matter of law on
his claim for summary judgment in his favor to the extent of only
declaring regarding the falsity of these chain of statements comprising of
several links which the Defendants have posted before and after the
filing the Defamation complaint, by fully retraction and removing of
these false, defamatory, derogatory and reckless inaccurate statements
(allegations) made on the Rip-off website and other social media site and
enjoin them for further publication of such false statements regarding the
Plaintiff and Plaintiffs business practice.

Defendants have failed to deny the publishing of these

statements on Rip-off reports and other social media
websites in their pleading as it has been discussed in
details in the motion which were supported by law and
facts. In support of his motion, plaintiffs submitted a
Statement of Undisputed Material Facts, In its
response, defendants have not indicated any
disagreement with those facts or suggested any
other adjudicative facts that support their
position Accordingly. (Defendants were ordered to remove the
following web links,declaring regarding the falsity of these chain of statements
comprising of several links which the Defendants have posted before and after the
filing the Defamation complaint, by fully retraction and removing of these false,
defamatory, derogatory and reckless inaccurate statements (allegations) made on the
Rip-off website and other social media site and enjoin them for further publication of
such false statements regarding the Plaintiff and Plaintiffs business practice.

(a-1) http://www.ripoffreport.com/r/Malik-Hamid-Zaman/internet/Malik-Hamid-Zaman-Malik-
Hamid Zaman-Sr-American-Immigration-Dream-Realty-American-Immig-1244390
(b-2) http://www.ripoffreport.com/r/Malik-Hamid-Zaman-Sr/Palm-Beach-Gardens-Florida-

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 33418/Malik-Hamid-Zaman-Sr-Malik-Zaman-Zaman-Malik-Hamid-Sr-American-Immigration-
Dream-Re-1104325
(c-3) http://www.ripoffreport.com/r/Malik-Hamid-Zaman/Palm-Beach-Gardens-Florida/Malik-
Hamid-Zaman-Unethical-Incompetent-Egotistical-Unprofessional-Extortion-Liar-Pa-1245773
(4d)http://www.malikzaman.properties/contact-us.html
(e-5)https://www.scambook.com/report/view/335290/Malik-Zaman-Complaint-335290-for-
$30,000.00
(f-6) http://www.outscam.com/american-immigration-dream-realty-l-lc-da
(7g)http://www.complaintsboard.com/complaints/malik-zaman-associates-ltd-donrsquot-waste-
money-for-these-fake-forms-c780499.htm

2- On January 24, 2017, a final Judgment was made in this complaint and
following order was made, which has been marked here as an Exhibit (C)
{Pages M15-M17}

A PARTIAL FINAL JUDGMENT BASED UPON THE

MAY2, 2016, ORDER ON PARTIES PARTIAL
SETTLEMENT WAS MADE.
The Court hereby enters partial final judgment in favor of
the Plaintiff, Malik Hamid Zaman, against the Defendants,
Derrick Montavious Crew and Ada Berrios, based upon the May
2, 2016, Order on the Parties Partial Settlement (D.E.#25). 0n
May 2, 2016, a hearing was scheduled and held before the
Court on the Plaintiff's Motion for Partial Summary Judgment
(D.E. #22). During this hearing, the Court received evidence
and testimony from the parties relating to the issues Involved In
this lawsuit. During this hearing, the parties reached a
settlement of all issues claimed by the Plaintiff against the
Defendants except the Parties' claims for money damages

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 remain pending and were separately set for trial. The May 2,
2016, Order on the Parties Partial Settlement speaks for Itself
with regard to the issues and claims settled and withdrawn at the
time, and the Issues that remain pending for determination.

1. Based on the Parties settlement at that time, and the

subsequent order entered by the Court, the Plaintiff is
entitled to partial final judgment against tire Defendants
Including a final judgment that there shall be a complete
retraction and De- Listing and permanently removing and de-
indexing of the false and defamatory statements and offending
web page links listed as:

(a-1) http://www.ripoffreport.com/r/Malik-Hamid-Zaman/internet/Malik-Hamid-Zaman-Malik-
Hamid Zaman-Sr-American-Immigration-Dream-Realty-American-Immig-1244390
(b-2) http://www.ripoffreport.com/r/Malik-Hamid-Zaman-Sr/Palm-Beach-Gardens-Florida-
33418/Malik-Hamid-Zaman-Sr-Malik-Zaman-Zaman-Malik-Hamid-Sr-American-Immigration-
Dream-Re-1104325
(c-3) http://www.ripoffreport.com/r/Malik-Hamid-Zaman/Palm-Beach-Gardens-Florida/Malik-
Hamid-Zaman-Unethical-Incompetent-Egotistical-Unprofessional-Extortion-Liar-Pa-1245773
(4d)http://www.malikzaman.properties/contact-us.html
(e-5)https://www.scambook.com/report/view/335290/Malik-Zaman-Complaint-335290-for-
$30,000.00
(f-6) http://www.outscam.com/american-immigration-dream-realty-l-lc-da
(7g)http://www.complaintsboard.com/complaints/malik-zaman-associates-ltd-donrsquot-
waste-money-for-these-fake-forms-c780499.html
These links and sites above must be removed and retracted and de-Indexed from the Rip -Off Report s
website, Google, "Yahoo", and Bing posted against the Plaintiff, Malik Hamid Zaman, real
name and the marketing name additionally of Malik Zaman, "Zaman Malik", Malik Hamid Zaman
Sr., and Plaintiffs business name American Immigration Dream Realty, LLC, posted or
contributed to, or attached with links, by the Defendants, Derrick Montavious Crew and/or Ada
Berrios.
The Defendants and third parties shall assist In complying with this final
Judgment

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 2. The Defendants are enjoine d from further publication of such false
statements regarding the Plaintiff and Plaintiffs business practice

3- Defendants have contumaciously disregarded this courts clear rulings as pronounced during
May 2, 2016, and January 24, final Judgment hearing and as set forth in the Final Judgment.

4- Defendants have not removed any of their false, defamatory, derogatory and recklessness
inaccurate statements (allegations) made on the Rip-off website, Yahoo,Bing, Web
activism,RepDigger,(posted or contributed to, or attached with links, by the Defendants) and
other social media sites which have been ordered in the Partial Summary Judgment and final
Judgment.

5- ( Malik Hamid Zaman, real name and the marketing name additionally of Malik Zaman,
"Zaman Malik", Malik Hamid Zaman Sr., and Plaintiffs business name American
Immigration Dream Realty, LLC, Malik Zaman and Associates

Defendants conduct shows that they have not taken any

actions in removing or de-indexing for the compliance of the
court order for all theses Negative Links which were posted
by them and were part of the Court order(Final Judgment)
from the Google Search Engine Website is a clear violation of
the Court Order
6- As of August 26, 2017, since eight months have been passed, Defendants have not taken any
steps or any actions or have made any attempt or have shown any progress in permanently
removing or de-indexing all these defamatory and derogatory links which were found in the Yahoo
Website against the Plaintiff's name and Plaintiff's business name, which is a clear violation of the
Final Court Order. Exhibits, marked as G1, G2, G3, G4, G5, G6, G7, G8, have the negative links

Defendants conduct shows that they have not taken any

actions in removing or de-indexing for the compliance of the
court order for all theses Negative Links which were posted
by them and were part of the Court order(Final Judgment)
from the "Yahoo" Search Engine Website is a clear violation
of the Court Order.
7- As of August 26, 2017, since eight months have been passed, Defendants have not taken any
steps or have taken any actions or made any attempt or have shown any progress in permanently
removing or de-indexing all these defamatory and derogatory links which were part of the court
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 order, found in the Yahoo Website against the Plaintiff's name and Plaintiff's business name, which
is a clear violation of the Final Court Order. Exhibits, marked as Y1, Y2, Y3, Y4, Y5, Y6, Y7, Y8,
and Y9 have the negative links.

Defendants conduct shows that they have not taken any

actions in removing or de-indexing for the compliance of the
court order for all theses Negative Links which were posted
by them and were part of the Court order(Final Judgment)
from the "Bing" Search Engine Website is a clear violation of
the Court Order
8- As of August 26, 2017, since eight months have been passed, Defendants have not taken any
steps implied any actions or made any attempt or have shown any progress in permanently
removing or de-indexing all theses defamatory and derogatory links which were found in the Bing
Website against the Plaintiff's name and Plaintiff's business name, which is a clear violation of the
Final Court Order. Exhibits, marked as B1, B2, B3, B4, B5, B6, have the negative links.

9- On July 20, 2016, Defendants posted Plaintiff picture on the Website with a defamatory blog Marked as an Exhibit "P1
Then on July 25, 2016, Defendants posted a blog on the website located at
https://repdigger.com/persons/malik-zaman, MALIK ZAMAN PROFILE This report represents the
search results for the name MALIK ZAMAN, which is not unique. It's not the fact that the results belong
the same person. It's your responsibility to verify a person you search before making your decision.
POSSIBLE NEGATIVE SEARCH RESULTS FOR MALIK ZAMAN Malik Hamid Zaman
Sr Complaint Review Palm' Do not work with Malik Zaman!! He has a blatant disregard to work ethic
and honor. He will scam you out of your money and provide you with ...POST YOUR OWN COMMENT
ABOUT MALIK ZAMAN
10- On July 25, 2016, August 20, 2016, and September15, 2016,Defendants has posted numerous blogs
on the website located at https://webactivism.com/malik-hamid-zaman-investigation-for-fraud-
impersonation-and-perjury-fake-dmca-11556971/bdiykg81/ Malik Hamid Zaman has numerous aliases.
He is a compulsive liar and manipulative. He has hurt innocent victims. He has numerous lawsuits against
him, He intimidates and threatens people. He is a con artist. He defrauds you out of money. He is a
notorious human smuggler/trafficker, The Federal Investigation Agency (FIA) announced the arrest of
notorious human smuggler Malik Hamid Zaman on November 17. Zaman, who ran a travel agency in

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Lahore, was wanted in four cases of human trafficking to Canada and the Middle East
11- Then again on July 25, 2016, Defendants posted a blog on the website located at
https://repdigger.com/persons/malik-zaman, MALIK ZAMAN PROFILE This report represents the
search results for the name MALIK ZAMAN, which is not unique. It's not the fact that the results belong
the same person. It's your responsibility to verify a person you search before making your decision.
POSSIBLE NEGATIVE SEARCH RESULTS FOR MALIK ZAMAN Malik Hamid Zaman
Sr Complaint Review Palm' Do not work with Malik Zaman!! He has a blatant disregard to work ethic
and honor. He will scam you out of your money and provide you with ...POST YOUR OWN COMMENT
ABOUT MALIK ZAMAN
12- True and correct Copies of the Post-Hearing Blogs are attached hereto as Composite Exhibit P1.
P2, P3, P4,and the P5 are The Post-Hearing Blogs are in direct violation of this Courts Partial Summary
Judgment order. Document marked as an Exhibit "P1" Pages(1-9) ,Blogs are also attached hereto as
Composite Exhibit P2 (pages-2), P3, P4,and the P5
13- Like the other blogs that are incorporated into Plaintiffs Complaint and filed as a part of the
Appendix thereto, the Post-Hearing Blogs are false, misleading, and have the tendency to injuries
Plaintiff in their trade or profession and subject Plaintiff to hatred, distrust, ridicule, contempt or
disgrace. Moreover , although Plaintiff is not public figures, the Post-Hearing Blogs were published with
actual malice as they were false when made and Defendants knew that the statements were false at the
time they were published, or Defendants made the statements with reckless disregard for their truth or
falsity, and with reckless disregard for their adverse effect on Plaintiff's reputation and/or their business.
The Post-Hearing Blogs are therefore calculated to defame Plaintiff. In addition, the Post-Hearing Blogs
are calculated by Defendants to tortuously interference with or otherwise harm Plaintiff
14- Accordingly, Defendants should be found in contempt of this Courts ordersCivil contempt proceedings
may be employed to coerce a contemnor into compliance with the court's order and to compensate a
complainant for losses sustained. Popular Bank of Florida v. Banco Popular de Puerto Rico, 180
F.R.D. 461, 465 (S.D. Fla. 1998) (citing Martin v. Guillot, 875 F. 2d 839 (l l th Cir.1989)). Frequently are
useful methods for enforcing judicial orders. Id
15- To find contempt, the court must find that the order violated was clear and unambiguous and that the
party to be charged had notice of the order but did not diligently attempt to comply. Id. (citing in re E.I.
DuPont De Nemours, 99 F.3d 363, 372 (11 th Cir.1996)); see also United States v. Roberts, 858 F.2d
698 (l l th Cir.1988) (civil contempt may be imposed where there has been a violation of a clear and
unambiguous order of which the party to be charged had notice). [A] violation of [an] order need not be
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willful for a party to be found in civil contempt. Popular Baulk of Florida, 180 F.R.D. at 465 (citing
Macomb v. Jacksonville paper Co., 336 U.S. 187 (1949)
16- This Courts rulings during May 2, 2016, hearing and in the Partial Summary Judgment order itself
are clear and unambiguous.
17- Defendants also clearly had notice of the Partial Summary Judgment. Both the Defendants were
physically present in the court during the May 2, 2016 hearing and have personally heard this Courts
rulings and both of the Defendants has signed and received the copies of the court order from the
Presiding Judge of the court, along with the Plaintiff on May 2, 2016, at the conclusion of the hearing.
Defendants have nevertheless chosen to openly violate this Courts rulings. This certainly constitutes a
failure to diligently attempt to comply, which is a ground for a contempt finding. See, e.g., In re E , I.
DuPont De Nemours, 99 F. 3d 363, 372 (l l th Cir.1996). In its Contempt Order, this Court should include
sanctions including but not limited to Plaintiff's litigation expenses, court cost and attorneys fees. [A]n
award of attorney fees to the injured party in a civil contempt case is within the district court's
discretion. Sizzler Family Steal Houses v. Western Sizzlin Steal House, Inc 793 F. 2d 1529, 1534 (11th
Cir. 1986).

WHEREFORE, Plaintiff, MALIK HAMID ZAMAN, respectfully request that this

Court enter an Order finding Defendants, DERRICK MONTAVIOUS CREW (Alias) Morals

Man and ADA BERRIOS (Alias)(Consumer), in contempt of this Court's May 2, 2016 and

January 24, 2017, rulings of the Partial Summary Judgment, and final Partial Judgment

imposing the appropriate sanctions in such instances, and granting such other and further relief

in favor of 'Plaintiff as this Court deems just and proper.

Respectfully submitted,

Malik Hamid Zaman (Pro Se)

6691 South Pine Court, Palm Beach
Gardens FL, 33418
Tel: (561) 729-7624
Fax: (561) 507-5382
Email: mzaman99@hotmail.com
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 Dated August 26, 2017

CERTIFICATE OF SERVICE

I, the undersigned Plaintiff in( Pro Se), certify that a true and
correct copy of Plaintiff's Motion for Contempt was
furnished to the Defendants Derrick Montavious
Crew( Alias) Morals Man and Ada Berrios (Consumer) at
3712 Jackson Blvd, Fort Lauderdale, Florida 33312 and also
foregoing was served via electronic mail delivery at
derrickmcrew@gmail.com

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