In re: 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

Chapter 7 

Case No. 19-19710-SMG 

Louis Tino Fisher, 

Debtor, 

FILfD-USBC, FLS-FTL 

19 NOV 1. ··'11 ~3:37 

~ 

MOTION FOR REHEARING AND CLARIFICATION· 

Debtor LOUIS T. FISHER, PRO SE, respectfully requests this Court to 

rehear and clarify the Creditor Theodore Robert's Motion to Dismiss Case or in the 

Alternative, for Relief from the Automatic Stay (ECF No. 24) (the "Motion") and 

Debtor's Response in Opposition (ECF No.32) (the "Response"). 

"The Rooker-Feldman doctrine, however, 

prohibits a collateral attack on the state court 

judgment in this Court." 

1. The Creditor's oral argument was false, misleading, and impossible. The 

Debtor filed a federal "Automatic Stay" which would make the Creditor's 

argument false. The "Automatic Stay" stops the Debtor and the Creditor from any 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 1 of 8
and/or all attacks in State Court. This is the reason the Creditor requested in his 

motion a request "for Relief from the Automatic Stay" to allow an attack on the 

Debtor in State Court. The Granting of the Creditor's Motion and Dismissal of the 

Debtor's case on October 22, 2019 now allows the advantage of a collateral attack 

to the Creditor. The Debtor well be defending orders from both courts. 

"pursuant to the final judgement of specific 

performance, and that this case is a two-party 

dispute between the Debtor and the movant, 

in which the Debtor is seeking relief from the 

state court judgement." 

2. The Court found that the State case is a two-party and that is not factual. 

The State case is a three-party case with two separate defendants. The State Court 

Case parties are Theodore Roberts v. Louis T. Fisher, Loretta B. Leonard CACE 

19-006197 (9) there are two separate non married induvial with different interest. 

The Debtor sought relief through Bankruptcy to protect his interest. The State Case 

continued against Loretta B. Leonard. The State Court filed separate orders against 

Loretta B. Leonard that stated (Loretta B. Leonard Only Exhibit A). Loretta B. 

Leonard then filed an appeal in her name only in case 4D19-2682 Exhibit B. The 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 2 of 8
Debtor (Louis T. Fisher) was not in Named as an Appellant and is not involved in 

that case. The Creditor argued that the Debtor was involved with Loretta B. 

Leonard's Appeal by doing so the Creditor defrauded the Court. Loretta B. 

Leonard a separate non-married induvial that has the right to defend herself 

separate from Debtor. 

3. The Creditor bolsters that specific performance is the only issue brought 

before the Court. That is a red herring, the Creditor is also additionally seeking 

more than $15,000 in fees cost and expenses that will increase the Debtor debt. 

Moreover the Debtor will incur more than $10,000 in the cost of moving his 

handicap equipment and the contents of his home. 

WHEREFORE, the Debtor moves this Court to rehear the Creditor's motion. 

The Debtor request this Court to clarify whether a third party acting on their own 

behalf and not a party in the bankruptcy has the right to defend themselves 

independent of other named Defendants. 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 3 of 8
I HEREBY CERTIFY that a true and correct copy of the foregoing was served 

by mail this 1st day ofNovember, 2019, on Jason Slatkin, 1 E Broward Blvd Ste. 

609, Suite 410, Plantation, Florida 33301-1872. 

Louis 

:JJe1u!dJ 

T. Fisher 

r, 

( 

~ 

Defendant, 

5440 N.W. Iih Court 

Lauderhill, Florida 33313 

(954) 330-9972 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 4 of 8
DATE:August26,2019 

Fourth District Court of Appeal 

110 South Tamarind Avenue 

West Palm Beach, Florida 33401 

(561) 242-2000 

ACKNOWLEDGMENT OF NEW CASE 

STYLE: LORETT A LEONARD v. THEODORE ROBERTS and 

LOUIS T. FISHER 

The Fourth District Court of Appeal has received the Notice of Appeal reflecting a fi!ing date of A.• '2' ,~t ·:;·;. 

2019 

The county of origin is Srow2rd. 

The lower tribunal case number prmrided is CACi:: 19-006'!97 

Fee Status: Due 

Case Type: Civil Other Fina! 

The Fourth District Court of Appeal's case number must be utilized on all pleadings and correspondence filed 

in this cause. Moreover, ALL PLEADINGS MUST INCLUDE THE ATTORNEY'S FLORIDA BAR NUMBER 

and a physical address. 

ELECTRONIC FILING IS MANDATORY FOR ALL ATTORNEYS 

Incoming filings must be submitted through the Florida Courts E-Filing Portal. 

Outgoing filings will be sent by the Court through eDCA Casemail (https:l/edca.4dca.org). 

Attorneys who have not registered for eDCA will not receive paper documents from the court. 

FILING FEES MAY NOVV BE PAID ELECTRONICALLY THROUGH THE FLORIDA I 

COURTS E-FILING PORTAL - S·EE THE COURT'S WE~SITE FOR INSTRUCTIONS I 

cc: Klauber Goldman, P.A. Loretta Leonard Clerk Broward 

tw 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 5 of 8
Instr# 115958597 , Pag~ 1 of 2, Recorded 07/29/2019 at: 04:38 PM 

Broward County Commission 

.. ... " -

**** FTLED: BROWARD COUNTY, FL Brenda D. Fonnan, CLERK 7/24/2019 4:30:00 PM.**lil* 

IN THE CIRCUIT COURT OF THE l 7TH JUDCIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

THEODORE ROBERTS, 

an individual, 

CASE NO.: CACE-19-006197 (09) 

PlaintifI: 

v. 

LOUIS T. FISHER, an individual, and 

LORETTA B. LEONARD, an individual, 

--------------

Defendants. 

I ~~~~~ SUPPLEMENT AL FINAL JUDGMENT 8V·------

ON ATTORNEY'S FEES AND COST I 

( At>II tf\ljr /.Arll,e.ifJtlf- 8 . L.e0Nl'HZ1:> 11 I\J '-Y) 

The above styled cause having come before this Court on the Plaintiffts) entitlement to 

attorney's fees and costs, it is: 

ORDERED AND ADJUDGED that: 

I. Pursuant to the July I, 2019, Final Judgment, Plaintiffs entitlement to reasonable 

attorney's fees and costs was recognized by this Court. 

2. Upon an evidentiary hearing held on July 24, 2019 the Court finds based upon the 

record evidence, including expert testimony, that Plaintiff is entitled to recover from 

the Defendants' $ ~, 6 q I/. Z 9 as reasonable attorney's fees and costs 

consisting of U-9 ho~rs of attorney time at the detennined reasonable hourly rate 

of S 3 ,it , 00 and, f:lgurs of pa.i:alegal time at the detcnntned Peeseeeele 

hem:ly z:aie of$ 

3. The Court also finds Plaintiff entitled to recover the expert witness fee of 

$ I; 0-0. o-o from Defendants•. 

4. The total attorney's fees and costs award is$ 71 1AJ 9. 7_, 7 . r {~~) 

S. It is further ORDERED AND ADJUDGED that ea sh : f ahcJ)efendantfnwill complete ~ l )' 1 

under oath Form 1.977, FL.R.Civ.P. (Fact Information Sheet), including all required 

attachments, and serve it on the Plaintiffs attorney, within 45 days from the date of 

this Final Judgment. The Court specifically reserves jurisdiction to enforce the terms 

of this Judgment. 

6. Pursuant to Florida law, the total attorney's fees and costs stated in Paragraph 4 above 

sh"11 be applied to and reduce the sales price of the property {$252,000.00). · 

I. ~ I~ ~ vtf ~e.1 De~ U,,vw':. fMfiN.,v~ ' s~s.u h"n,.,_ o-1- &vi/..rrrtr 

-fiitt cruy i.1, ~,, 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 6 of 8
Instr# 115958597 , Page 2 of 2, End of Document 

------------~-----

... 

**** FILED; BROWARD COUNTY. FL Brenda D. Forman, CLERK 7/24/201 ~ 4:30:00 PM.  

CM.E;NO.: CACE-19-006197 (09) 

2019. 

/ 

7. Jurisdiction of this case is retained to enter further orders that are proper. 

FOR WHICH LET EXECUTION NOW ISSUE. 

t,11111-/-,--.o111 

DONE and ORDERED in Oftfttft&ers,. Broward County, 

Copies to: 

l"PJA'\rlll.'LE JEFFREY R. LE 

COURT JUDGE 

of July, 

Mitchell B. Haller, Esq., for PLT, 8751 W. Broward Blvd., Ste 410, Plantatio~ FL 33324 

Louis T. Fisher, Defendant, 5440 N.W. 12 Ct., LauderhiJJ, FL 33313 

Loretta B. Leonard, Defendant, 5440 N.W. 12 CL, Lauderhill, FL 33313 

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 7 of 8
Instr# 115958599, Page 1 of 1, Recorded 07/29/2019 at 04:39 PM 

Broward County Commission 

v0 •• FILED: BROWARD COUNTY. FL Brenda D. Forman, CLERK 7/24/2019 4:30:00 PM.** ** 

IN THE CIRCUIT COURT OF THE / ~ JUDICIAL CIRCUIT, IN AND FOR r,_ ,.A. lhAAill 

COUNTY, FLORIDA (,ryuvvv,, ~ 

THIS CAUSE having come on to be heard on ________ __, Defendant·~ 

and the Court having heard argument of counsel, and being otherwise advised 

in the Premises, it Is hereupon, 

DONE AND ORDERED in Chambers, at ~O;~~~~~~.fi!.~~~~~~r4" 

this ,:l':f dayof,~----~E-=-:----' 

Copies furnished: 

av,,\&()~~ 

DECEI .... n JUL H 20J!! 

8Y.·-------

Case 19-19710-SMG Doc 38 Filed 11/01/19 Page 8 of 8