Filing # 108008594 E-Filed 05/27/2020 03:08:14 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,

IN AND FOR ORANGE COUNTY, FLORIDA

ADAM J. SCHERR; MICHAEL

HUTTER; MEAT CASTLE, LLC;
and K5 ENTERTAINMENT, INC.,

Plaintiffs,

v. Case No.: 2020-CA-004758-O

ERIC HOLZER; and MAGIC CITY

PRINTS INC.,

Defendants.
________________________________________/

DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’ COMPLAINT

Defendants, Eric Holzer (“Holzer”) and Magic City Prints Inc. (“Magic City”)

(collectively, “Defendants”), by and through their undersigned counsel, and pursuant to Rule

1.140(b)(6) of the Florida Rules of Civil Procedure, hereby move to dismiss Plaintiffs’, Adam J.

Scherr (“Scherr”), Michael Hutter (“Hutter”), Meat Castle, LLC (“Meat Castle”), and K5

Entertainment, Inc. (“K5”) (collectively, “Plaintiffs”), Complaint, and in support thereof, state:

Introduction

1. At its core, the instant case involves a dispute between three (3) of the four (4)

owners of two different companies, Magic City and K5. Although the Complaint is chock full of

false allegations, such facts, even assuming that they are true, fail to support the claims alleged

against Defendants. The most egregious claim which Plaintiffs’ attempt to gin up against

Defendants is a RICO claim based on conclusory allegations with zero ultimate facts to support

such a claim. It is crystal clear what is going on with this lawsuit; Scherr and Hutter, two

professional wrestlers for World Wrestling Entertainment (the “WWE”), are orchestrating a coup

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to steal Holzer’s interest in Magic City and K5 from him without compensation. In any event, for

the reasons set forth below, Plaintiffs’ Complaint fails to state a claim against Defendants and

should, accordingly, be dismissed, including the breach of contract claim being dismissed with

prejudice.1

Motion to Dismiss Standard

2. “The function of a motion to dismiss a complaint is to raise as a question of law the

sufficiency of the facts alleged to state a cause of action.” Cazares v. Church of Scientology of

Calif., Inc., 444 So. 2d 442, 445 (Fla. 5th DCA 1984) (citing Kest v. Nathanson, 216 So. 2d 233

(Fla. 4th DCA 1968); Pizzi v. Central Bank & Trust Co., 250 So. 2d 895 (Fla. 1971); City of St.

Augustine v. Authentic Old Jail, Inc., 388 So. 2d 1044 (Fla. 5th DCA 1980)). “For the purpose of

passing upon a motion to dismiss, the court must assume all the facts alleged in the complaint to

be true.” Id. “A motion to dismiss must be decided on questions of law only.” Id. “The purpose

of a motion to dismiss is to ascertain if the plaintiff has alleged a good cause of action, and the

court, when faced with a motion to dismiss a complaint for failure to state a cause of action, must

confine itself strictly to the allegations within the four corners of the complaint.” Id.

“[E]xhibits attached to a complaint become part of the complaint and will be considered together

with it”, and they “control over the allegations of the complaint when the two contradict.” Paladin

Properties v. Family Investment Enterprises, 952 So. 2d 560, 563-64 (Fla. 2d DCA 2007).

1
Notably, K5 is listed as a Plaintiff and is alleged to be a Plaintiff. However, K5 brings asserts no
claim against Defendants, and is only mentioned passingly in Counts V and VI brought by Scherr
and Hutter, respectively. Consequently, K5 should be dismissed as a party to this case.
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 Background

A. Allegations concerning Hutter

3. Hutter is a professional wrestler who is publicly known by the stage names “Ethan

Carter, III” and “EC3”. (Compl., ¶ 3).

4. In 2018, Hutter was allegedly approached by his friend, Jedediah “JC” Koszewski,

“to purchase an Epson 5210 ‘Direct to Garment’ printer for use by JC in a fledgling apparel

printing business that JC had started with” Holzer. (Id., ¶ 9). Hutter agreed in September, 2018,

to purchase the printer from an online seller for the price of $4,000.00 as a supposed loan to JC

and Holzer so that they could operate their business under the trade name “Magic City Prints”.

(Id., ¶ 10).

5. In 2019, Hutter claims that JC again approached him, this time along with Holzer,

asking Hutter to loan them an additional $7,000.00 to purchase more printing equipment to expand

Magic City’s operations. (Id., ¶ 11). Hutter further claims that Holzer pitched the idea of

expanding Magic City’s business and the concept of Hutter, JC, and Holzer forming a corporation

together to expand said business. (Id., ¶ 12).

6. Hutter agreed and purchased additional printing equipment for $7,000.00. (Id., ¶

13). Holzer, thereafter, began to expand Magic City’s business, but no formal contract was drafted

or executed by Hutter, JC, and Holzer to memorialize their alleged agreement. (Id., ¶¶ 13-14).

7. Hutter, JC, and Holzer entered into a lease together for warehouse space in Winter

Garden, Florida to house Magic City’s printing operations. (Id., ¶ 15).

8. On May 10, 2019, Holzer filed the “Articles of Incorporation” for Magic City with

the Florida Division of Corporations. (Id., ¶ 16 and Exh. A). Holzer allegedly listed himself as

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the sole officer of Magic City without a vote or affirmation from either Hutter or JC. (Compl., ¶

17).

B. Allegations concerning Scherr and Meat Castle

9. Scherr is a professional wrestler who is publicly known by the stage name “Braun

Strowman”. (Compl., ¶ 2). Scherr owns and holds the 100% membership interest in Meat Castle.

(Id., ¶ 4).

10. Scherr had developed the moniker “Meat Castle” as one of his wrestling nicknames,

as well as a line of apparel and merchandise under the “Meat Castle” name and founded Meat

Castle for that purpose. (Id., ¶ 19). He further created the website www.meatcastleclothing.com

(the “Website”) in order to offer for sale his “Meat Castle”-branded products. (Id., ¶ 20).

11. Hutter introduced his friend Scherr “to the group” with the promise that Magic City

“could” produce the printed “Meat Castle”-branded apparel and fulfill the orders placed through

the Website. (Id., ¶¶ 18, 21). Therefore, on October 20, 2019, Meat Castle entered into a Joint

Venture Agreement (the “JV Agreement”) with Magic City regarding the production and shipping

of “Meat Castle”-branded merchandise by Magic City. (Id., ¶¶ 22, 23 and Exh. B). Pursuant to

Article VIII of the JV Agreement, payments from Website purchases were to be deposited into a

bank account set up for the joint venture, and pursuant to Article V, Meat Castle was to receive

60% of the net profits from the joint venture, with Magic City to receive the other 40% . (Id., ¶¶

24, 25 and Exh. B).2

12. Subsequent to the JV Agreement, Holzer allegedly “floated” to Scherr the idea that

Scherr invest in Magic City, and thereafter, drafted a “Memorandum” to reflect Scherr would

2
Notably, the joint venture bank account was never established, even though Plaintiffs’ allegations
suggest otherwise.
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acquire an ownership interest in Magic City in exchange for the payment of $15,000.00 to Magic

City. (Compl., ¶¶ 26, 27, and Exh. C). As reflected in Exhibit C, Scherr acquired an 8% interest

in Magic City, while Holzer, Hutter, and JC each held 32%, 32%, and 28%, respectively, and the

officers of Magic City were as follows: (a) Holzer, President; (b) JC, Vice President; (c) Hutter,

Treasurer; and (d) Scherr, Secretary. (Id., Exh. C).

13. On November 19, 2019, Scherr issued a $15,000.00 check, but claims to have

received nothing in return for this payment “that Holzer misrepresented to Scherr as an ‘investment

in Magic City’”. (Id., ¶ 28). Scherr “believe[s]” that “Holzer converted all or a portion of those

funds to his own use and benefit.” (Id.).

14. Scherr further claims that a review of the (non-existent) joint venture bank account

reveals “thousands of dollars of withdrawals by Holzer without Scherr’s prior knowledge or

authorization” as required by the JV Agreement. (Id., ¶ 29).

C. Allegations concerning K5

15. At around the time that the joint venture relationship was formed, Scherr, Hutter,

JC, and Holzer decided to start a YouTube channel to provide wrestling fans with more personal

access to Scherr and Hutter. (Id., ¶ 30). To formalize the YouTube arrangement, Scherr, Hutter,

JC, and Holzer formed a Florida corporation called K5. (Id., ¶ 31). Scherr and Hutter claimed to

have invested thousands of dollars for start-up capital for K5 to purchase video and audio

equipment, set design, and the like. (Id., ¶ 32). JC set up the YouTube account for K5. (Id., ¶

33).

16. Thereafter, a number of shows were created, many starring Scherr and Hutter. (Id.,

¶ 34). Plaintiffs claim that, Holzer “seized possession” of the digital footage and content contained

“on the backup computer hard drives that includes digital images and video of Scherr and Hutter”,

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without their knowledge or consent. (Id., ¶ 35). They also claim that Holzer took possession of

“various computers and production hardware and equipment” that were purchased for K5, but has

refused to return them despite demand for same. (Id., ¶¶ 36, 37). Further, they allege that Holzer

has no legal right to possess or utilize such items. (Id., ¶ 37).

17. Upon the above alleged “facts”, Plaintiffs filed their Complaint against Defendants,

alleging the following six (6) claims against them:

a. Count I: Breach of Contract by Scherr against Magic City3

b. Count II: Fraud by Scherr against Holzer

c. Count III: Money Lent by Hutter against Holzer and Magic City

d. Count IV: RICO claim (§ 772.104, Fla. Stat.) by Meat Castle against Holzer

and Magic City.

e. Count V: violation of § 540.008, Fla. Stat., by Scherr against Holzer

f. Count VI: violation of § 540.008, Fla. Stat., by Hutter against Holzer

Analysis

A. Count IV fails to state a RICO claim against Holzer and Magic City.

18. Count IV purports to state a claim under section 772.104, Florida Statutes, which

is the civil remedies portion of the Florida RICO statute. Florida’s RICO statute is patterned after

the federal RICO statute; therefore, when analyzing Florida RICO claims, courts rely on cases

analyzing the federal RICO statute. Fernau v. Enchante Beauty Products, Case No. 18-cv-20866-

Scola/McAliley, 2019 WL 5269427, 2019 U.S. Dist. LEXIS 1600304, *6-*7 (Sept. 27, 2019),

aff’d and adopted by 2019 WL 5268541, 2019 U.S. Dist. LEXIS 179791 (Oct. 17, 2019).

3
Notably, Meat Castle is named in the title of this Count and in the Wherefore Clause, but based
on paragraph 38 of the Complaint, this claim is actually brought by Scherr against Magic City.
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 19. “To state a claim [for civil RICO], a civil plaintiff must plead that a defendant (1)

operated or managed (2) an enterprise (3) through a pattern (4) of racketeering activity that

included at least two racketeering acts.”. Id., at *6 (quoting Ray v. Spirit Airlines, Inc., 836 F.3d

1340, 1348 (11th Cir. 2016)) (internal quotations omitted). “A civil plaintiff must also show (1)

the requisite injury to business or property, and (2) that such injury was by reason of' the

substantive RICO violation.” Id., at *7 (quoting Ray, 836 F.3d at 1348) (internal quotations

omitted).

20. “[A] plaintiff must [further] allege the existence of two distinct entities: (1) a

‘person’; and (2) an enterprise (that engaged in the pattern of criminal activity), that is not the same

‘person’ referred to by a different name.” Id., at *7 (citing Cedric Kushner Productions, Ltd. v.

King, 533 U.S. 158, 161 (2001)). The United States Supreme Court has explained that “liability

depends on showing that the defendants conducted or participated in the conduct of the enterprise’s

affairs, not just their own affairs.” Id. Thus, “a pattern of criminal activity” stemming from

enterprise must be established, see Fla. Stat. §§ 772.103, 772.104 (2019), and a pattern of criminal

activity means “engaging in at least two incidents of criminal activity that have the same or similar

intents, results, accomplices, victims, or methods of commission or that otherwise are interrelated

by distinguishing characteristics and are not isolated incidents”, see Fla. Stat. § 772.102(4) (2019);

Martinez v. Hall, Case No. 6:11-cv-1212-Orl-22DAB, 2011 WL 6182026, 2011 U.S. Dist. LEXIS

143401, *13-*14 (M.D. Fla. Dec. 13, 2011). “Importantly, section 772.102(4) also notes that…the

term ‘pattern of criminal activity’ shall not include two or more incidents of fraudulent conduct

arising out of a single contract or transaction against one or more related persons.” Sineo

International Ltd v. Wade, Case No. 6:12-cv-1884-Orl-DAB, 2013 WL 12153590, 2013 U.S. Dist.

LEXIS 203002, *16-*17 (Fla. M.D. Fla. Apr. 1, 2013) (quoting Fla Stat. § 772.102(4)) (emphasis

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added). “Enterprise” is defined to include “any individual, sole proprietorship, partnership,

corporation, business trust, union chartered under the laws of this state, or other legal entity, or

any unchartered union, association, or group of individuals associated in fact although not a legal

entity; and the term includes illicit as well as licit enterprises and governmental, as well as other,

entities.” Fla. Stat. § 772.103(3) (2019).

21. “Additionally, to bring a RICO action in Florida, a plaintiff has to show there has

been some sort of ongoing criminal behavior.” Eagletech Communications, Inc. v. Bryn Mawr

Investment Group, Inc., 79 So. 3d 855, (Fla. 4th DCA 2012) (quoting Ginsberg v. Lennar Fla.

Holdings, 645 So. 2d 490, 501 (Fla. 3d DCA 1994)) (internal quotations omitted). After all, the

purpose of the RICO statute “is to punish, through civil penalties, actions which are ongoing and

criminal in nature.” Id.

22. Here, Meat Castle fails to plead the necessary elements of a Florida RICO claim.

In Count IV, Meat Castle alleges the following: (a) Holzer and Magic City failed to remit the net

profits due Scherr as alleged in Count I (which is the breach of the JV Agreement claim); (b)

“Holzer and/or Magic City rendered unavailable to Meat Castle data, programs, or supporting

documentation residing or existing internal or external to the computer system, computer network

or electronic devices related to the Meat Castle website that are owned exclusively by Plaintiff,

Meat Castle”; and (c) the actions in (a) and (b) constitute a violation by Holzer and/or Magic City

of Chapter 815, Florida Statutes, as described in particular in § 815.04, Florida Statutes”. See

Compl. ¶¶ 61 and 62. The legal deficiencies with these allegations are legion.

23. First, Scherr was not due any profits of “Meat Castle”-branded apparel, so the

alleged failure of Magic City (one of the two parties to the JV Agreement) to remit any profits to

Scherr is of no consequence, and the allegation is specifically negated by the language of the JV

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Agreement itself, thereby rendering such allegation a nullity as the JV Agreement (which is

attached to the Complaint) controls.

24. Second, assuming arguendo that Plaintiff meant to say Meat Castle instead of

Scherr, it would be of no moment as, under Florida law, plaintiffs “should not be permitted to

alchemize their claims for breach of contract into ones for civil RICO.” Signeo International. 2013

U.S. Dist. LEXIS 203002, at *17.

25. Third, regarding the allegation concerning Holzer and/or Magic City rendering

Meat Castle’s electronic data unavailable, there is no factual support for such a conclusory

allegation found anywhere in the Complaint. Florida is a fact-pleading jurisdiction, not a notice

pleading one, and Meat Castle’s conclusory allegations unsupported by ultimate facts falls

mightily short of meeting Florida’s pleading requirements. See Horowtiz v. Laske, 855 So. 2d

169, 172-73 (Fla. 5th DCA 2003) (recognizing that “Florida is a fact-pleading jurisdiction” and

finding that legal conclusions devoid of ultimate fact do not state a claim for relief).

26. Fourth, Meat Castle fails to allege the existence of an “enterprise” pursuant to and

through which Holzer and Magic City engaged in a pattern of criminal activity. Even viewing

Count IV in a light most favorable to Meat Castle, at best, Meat Castle could be considered to have

alleged that either Holzer or Magic City was an enterprise; however, that is not an enterprise that

is distinct from Defendants themselves. Under RICO law, Meat Castle must allege an enterprise

that is separate and distinct from Defendants. Because Meat Castle failed to do that, Count IV is

fatally flawed. See Fernau, 2019 U.S. Dist. LEXIS 160034, at *10-*13 (dismissing RICO claim

where plaintiffs had not “alleged the existence of a RICO enterprise that is distinct from the RICO

defendants”).

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 27. Fifth, Meat Castle has failed to allege a “pattern of criminal activity” that is ongoing

in nature and not part of a single transaction (or a series of related transactions). For one thing,

Meat Castle failed to allege the elements of the crime found in section 815.04, which is meant to

address “hacking”. See Garcia v. State, 939 So. 2d 1082, 1084 (Fla. 3d DCA 2006) (recognizing

that section 815.04 “addresses what is colloquially referred to as “hacking.”). Subsection (1) of

this statute provides that “[a] person who willfully, knowingly, and without authorization

introduces a computer contaminant or modifies or renders unavailable data, programs, or

supporting documentation residing or existing internal or external to a computer, computer system,

computer network, or electronic device commits an offense against intellectual property”, which,

per subsection (5)(a), is a third degree felony. Fla. Stat. § 815.04(1), (5)(a) (2019).

28. There are zero ultimate facts alleged in the Complaint to support what data,

programs, or supporting documentation associated with the Website were rendered unavailable as

a result of hacking by Holzer and/or Magic City and when same allegedly occurred. To the

contrary, the allegations in the Complaint and the JV Agreement conclusively establish that Holzer

and/or Magic City did not hack the Website or otherwise access it without authorization, as Magic

City (and Holzer as an owner of Magic City) was required to fill orders placed through the Website.

Moreover, Meat Castle’s conclusory allegations fail to identify two or more predicate acts to

support the requirement of a “pattern of criminal activity” by Defendants that was ongoing or

otherwise establish that any “hacking” activities occurred in a fashion other than in the same

transaction. See Eagletech Communications, Inc., 79 So. 3d at 864 (finding that plaintiff failed to

state a claim for RICO where predicate acts were alleged with conclusory allegations rather than

ultimate facts).

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 29. As a result of the foregoing, Meat Castle failed to allege the elements of a Florida

RICO claim against Defendants, opting instead to track statutory language found in sections

772.104 and 815.04 for some of the allegations in Count IV. As recognized by the Fourth District

in Eagletech, “[a] party does not properly allege a cause of action by alleging in conclusive form,

which tracks the language of the statute, acts which lack factual allegations and merely state bare

legal conclusions.” Consequently, Count IV fails to state a claim and must be dismissed.

B. Counts V and VI fail to state claims against Holzer for violations of section 540.08,
Fla. Stat.

30. Counts V and VI purport to state claims against Holzer for alleged violations of

Section 540.08, Florida Statutes, which is a codification by the legislature of one of the common

law claims for invasion of privacy. Notably, the allegations of Holzer’s conduct in both claims

are the same. The only difference between the claims is that Count V is brought by Scherr and

Count VI is brought by Hutter.

31. Section 540.08, Florida Statutes, provides, in pertinent part, that:

(1) No person shall publish, print, display or otherwise publicly use for
purposes of trade or for any commercial or advertising purpose the
name, portrait, photograph, or other likeness of any natural person without
the express written or oral consent to such use given by: (a) such person….

(2) In the event the consent required in subsection (1) is not obtained, the person
whose name, portrait, photograph, or other likeness is so used, or any
person, firm, or corporation authorized by such person in writing to license
the commercial use of her or his name or likeness, or, if the person whose
likeness is used is deceased, any person, firm, or corporation having the
right to give such consent, as provided hereinabove, may bring an action
to enjoin such unauthorized publication, printing, display or other
public use, and to recover damages for any loss or injury sustained by
reason thereof, including an amount which would have been a reasonable
royalty, and punitive or exemplary damages.
….

(4) The provisions of this section shall not apply to: (a) [t]he publication,
printing, display, or use of the name or likeness of any person in any

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 newspaper, magazine, book, news broadcast or telecast, or other news
medium or publication as part of any bona fide news report or presentation
having a current and legitimate public interest and where such name or
likeness is not used for advertising purposes….

Fla. Stat. § 540.08(1), (2), (4) (2019) (emphasis added). Based on the plain meaning of the statute,

actual use of a name, portrait, photograph, or likeness of another person for a commercial or

advertising purpose is required in order to be entitled to damages or injunctive relief under the

statute. Loft v. Fuller, 408 So. 2d 619, 621 (Fla. 4th DCA 1981) (“Florida Statute 540.08 applies

only to actions in which a person’s name or likeness is used for commercial trade or advertising

purposes.”); Acosta v. Spanish Broad. Sys. of Del., Case No. 15-21837-Civ-Cooke/Torres, 2015

U.S. Dist. LEXIS 186010, *5-*6 (S.D. Fla. Nov. 12, 2015) (“To maintain a cause of action for a

violation of Section 540.08, a plaintiff must allege that his or her name or likeness was used

directly to promote a commercial trade or advertising purpose.”) (emphasis added); see also

Diamond Aircraft Indus., Inc. v. Horowitch, 107 So. 3d 362, 367 (Fla. 2013) (recognizing that

“[i]f statutory language is clear and unambiguous and conveys a clear and definite meaning, there

is no occasion for resorting to the rules of statutory interpretation and construction; the statute must

be given its plain and obvious meaning.”). Thus, a mere threat or belief of a threat is simply not

sufficient to state a claim for relief under the statute.

32. In Counts V and VI, Scherr and Hutter allege that: (a) Holzer “seized possession

of the ‘digital press’ footage and content contained on the backup computer hard drives of Plaintiff,

K5, that includes digital images and video of” Scherr and Hutter without their consent; and (b)

Holzer “has threatened to publish, print, display, or otherwise publicly use for trade or for

commercial or advertising purpose the name, portrait, photograph, or other likeness of” Scherr and

Hutter without their consent. See Compl., ¶¶ 68, 72. These allegations are conclusory and fail to

meet the plain meaning of the statute in question. The footage at issue was allegedly shot by K5

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for use on K5’s YouTube channel, and Holzer is alleged to be an owner of K5. Mere seizing

possession of footage containing the name or likeness of Scherr and Hutter by an owner of the

company that shot the footage does not violate the statute, and neither does allegedly threatening

to use such footage. The statute clearly and unambiguously provides that the footage be actually

used by Holzer for a commercial or advertising purpose, and Scherr and Hutter fail to allege such

actual use. As a result, Counts V and VI fail to state claims for violations of section 540.08 and

must, accordingly, be dismissed.

C. Count I fails to state a claim against Magic City for breach of contract.

33. Count I purports to be breach of contract claim by Scherr against Magic City for an

alleged breach of the JV Agreement. This claim is woefully deficient. Significantly, paragraph

38 states that “[t]his is an action for damages brought by Plaintiff, Scherr, against Defendant,

Magic City, based upon breach of contract”. Scherr, however, is not a party to the JV Agreement,

and no duties or obligations were owed to him personally by Magic City. See Compl., Exh. B.

Because Magic City owed no duties or obligations to him personally, Scherr can never sue Magic

City for breach of the JV Agreement. See White v. Exchange Corp., 167 So. 2d 324, 326 (Fla.

1964) (“It is elementary that a person not a party to nor in privy with a contract does not have the

right to sue for its breach.”) (citing Woodrury v. Tampa Water Works Co., 49 So. 556 (Fla. 1909);

S.A.L. Railroad Co. v. Tampa S. Railroad Co., 121 So. 477 (Fla. 1929)). Consequently, this Court

must dismiss Count I with prejudice.

Conclusion

34. Based on the analysis above, Counts I, IV, V, and VI of the Complaint fail to state

claims against Defendants, requiring that those Counts be dismissed, including Count I with

prejudice.

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 WHEREFORE, Defendants respectfully request that this Court enter an Order: (a)

granting the instant Motion; (b) dismissing Counts I, IV, V, and VI of the Complaint, including

Count I with prejudice; and (c) granting such further relief that this Court deems just and equitable.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via

the Florida Courts E-filing Portal, which will serve a copy of same via email to all counsel of

record on this 27th of May, 2020.

/s/ Brandon W. Banks

Brandon W. Banks, Esq.
Florida Bar No.: 587461
Brain M. Walsh, Esq.
Florida Bar No.: 10968
WALSH BANKS LAW
P.O. Box 2271
Orlando, Florida 32802
Ph: (407) 259-2426; Fx: (407) 391-3626
Email: brandon.banks@walshbanks.com
Email: brian.walsh@walshbanks.com
Secondary Email: service@walshbanks.com

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