Filing # 48379455 E-Filed 11/01/2016 07:47:57 PM

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION

FUTURELAND CORP.,
PLAINTIFF,

DIVISION:

16-CA-10148

-V-

CASE NO.:

KODIAK CAPITAL GROUP LLC,

RESPONDENT/DEFENDANT,
CLEARTRUST, LLC,
A FLORIDA LIMITED LIABILITY CORPORATION,
INDISPENSABLE/ESSENTIAL PARTY,
/
EMERGENCY VERIFIED MOTION FOR IMMEDIATE INJUNCTION
COMES NOW, Plaintiff, FUTURELAND CORP. (Hereafter referred to as
FUTURELAND), pursuant to Chapter 86 et. seq., Florida Statutes and Florida Rule of Civil
Procedure 1.610, by and through the undersigned Attorney, files this Emergency Verified
Motion for Immediate or Temporary Injunction as to shares of stock which are due to be issued
and delivered to the Respondent/Defendant, KODIAK CAPITAL GROUP, LLC (Hereafter
referred so as KODIAK) on or about November 3, 2016. The Plaintiff, on behalf of the
Corporation and all shareholders of the Corporation files such matter as issuance and tendering
of such shares will cause immediate and irreparable harm to the Plaintiff Corporation. The
Plaintiff Corporation necessarily names to the action as indispensable or related party being
CLEARTRUST, LLC, the transfer agent for the Corporation where the issuance of shares is
pending for immediate issuance and would state the following in this matter:

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NATURE OF EMERGENCY AND OVERVIEW

1.

This matter is being filed contemporaneously with a filed complaint as to this

matter. The Defendant KODIAK has rendered and paid NO CONSIDERATION for the shares it
is attempting to obtain by fraud in this case. Without immediate court intervention the irreparable
harm stated herein will occur by or about November 3, 2016. This cause of action for an
emergency immediate injunction is being filed as an Emergency Matter due to the fact that the
attempt by the Defendant KODIAK is attempting and demanding the issuance of common stock
which it will sell on the public market, to be issued immediately (within 2 days of November 1,
2016). The emergency status of this matter is that KODIAK is fraudulently representing that it is
due money from FUTURELAND when in fact absolutely no debt exists. If such shares are
issued and sold on the public market, FUTURELAND and its over one thousand public
shareholders will suffer irreparable harm, which has no remedy at law.
2.

FUTURELAND is a public company under the Security Act of 1934 as stated

herein with in excess of 400 shareholders of record and an estimated 1000 or more shareholders
on the public market throughout the United States, including a large number of shareholders
located in Florida and this jurisdiction. Such action is brought on behalf of the Corporation and
its shareholders to curtail an immediate harm surrounding the release of such shares for
conversion of fraudulent debt to KODIAK in the form of common shares they are seeking to be
issued without restriction. Such issuance will result in immediate harmful effect to the
Corporation and its shareholders which cannot be compensated by money damages. The
damages that will occur is immediate dilution of all other existing shareholders who had actually
paid for their shares by the issuance of shares to KODIAK, which they will sell on the market,
decreasing the value drastically of the FUTURELAND common shares, causing losses to
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shareholders which cannot be compensated since they do not have standing to bring an action in
this matter. FUTURELAND will suffer immediate harm which cannot be compensated by
money damages, since the Corporation, its thousands of shareholders, will lose an immediate
project pending for the acquisition of a business project outside the State of Florida since such
acquisition is unique to the business of FUTURELAND and cannot be remedied through later
money damages. The acquisition is entirely dependent on the stable market price of
FUTURELAND stock on the public market. There would be no compensation to these
shareholders which include persons in nearly all the United States, and hundreds of shareholders
in the State of Florida alone. Such depressed share prices impact the Company in many material
ways, including present financing agreements which depend on the share price stability, which
issuance of such shares shall immediately depress and cause such financing to be breached or be
abandoned as to FUTURELAND.
JURISDICTION
3.

Jurisdiction and venue is appropriate before this Court since this matter involves

conduct by the Defendant KODIAK as it is alleging it is a note holder and party to other
agreements and contractual obligations involved with FUTURELAND, which breaches occurred
within the State of Florida by its actions with the Parties described herein, namely such actions
as to the Plaintiff Corporation as well as Cleartrust, LLC as the transfer agent for
FUTURELAND. KODIAK has embarked previously on courses of business within the State of
Florida for its own economic gain and conducted its actions as described herein within the State
of Florida. KODIAK is a California based entity located at 260 Newport Center Dr, Newport
Beach, CA 92660.
4.

Additionally, KODIAK has participated and acted within the State of Florida on

at least three other prior occasions with Florida domesticated entities or entities located within

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the State of Florida. As to its present actions, KODIAK is attempting to use fraudulent debt
documents for conversion into common shares of FUTURELAND which debt conversion and
issuances are attempting to be completed exclusively in Hillsborough County, Florida by
Cleartrust LLC, the transfer agent of FUTURELAND.
5.

In the present transaction, KODIAK conducted numerous actions within the State

of Florida with Cleartrust, LLC, a Florida Limited Liability Company, (hereafter

referred to as Cleartrust). Cleartrust is a Stock Transfer Agent located at 16540 Pointe Village
Drive Suite 206, Lutz, Hillsborough County, Florida 33558, who is the SEC registered stock
transfer agent for FUTURELAND and is responsible for all duties of issuance and maintaining
necessary stock accounting for FUTURELAND. As such KODIAK has made 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 Cleartrust to
act upon the conversion of fraudulent debt for issuance of shares of FUTURELAND common
stock. As such KODIAK was conducting business within the State of Florida in the present
transaction in addition to its former actions with other entities.
VENUE
6.

Venue for this action is appropriate before the Circuit Court, since the case

involves shares of common stock and agreements with a value over $15,000.
CERTIFICATION OF COUNSEL AS TO NON-NOTICE TO
RESPONDENT/DEFENDANT KODIAK
7.

The Company through the below signed counsel has communicated to the

principal manager, Ryan Hodsen of KODIAK this motion which is being sent
contemporaneously with its filing on November 1, 2016. Along with the accompanying
complaint being filed, such documents with notice and service will be made upon the
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Respondent/Defendant through such email delivery on that date as well as through follow on
available means of including service of process. The undersigned counsel will provide such
copies of all matters to such available corporate contact emails for BLACKRIDGE as available
and cause such attempt at service at their registered address in California.
8.

Since KODIAK has attempted to submit to Cleartrust a notice of conversion

of part of a fraudulent claim of debt by KODIAK this immediate action is necessary due to
Cleatrusts legal obligation to issue such shares within three days after notice of conversion is
delivered. The below signed counsel also certifies that there exists no reasonable expectation of
response by KODIAK CAPITAL GROUP in any timely fashion which would allow for a full
hearing on the matter before the shares being sought will be issued by the transfer agent.
THE INJURY COMPLAINED OF IS IMMINENT AND ONGOING
9.

KODIAK CAPITAL is attempting to be issued shares by committing a fraud by

claims that shares of common stock related to a Convertible Promissory Note entered into by
FUTURELAND, as related to a Equity Purchase Agreement where KODIAK was to actually
purchase the shares of the company, which was completely reliant on a successful registration of
securities with the SEC. What has occurred is that KODIAK neither paid, loaned, invested or in
any other way ever placed money or consideration of any kind with FUTURELAND or on its
behalf in any manner. As set forth herein, KODIAK, when it presented such agreements as set
forth to FUTURELAND, it did so fraudulently, with no intent whatsoever to ever invest or in
any way give any consideration for the agreements that were presented and entered into by
FUTURELAND, which KODIAK used to entice FUTURELAND into such agreements.
KODIAK is attempting to cause a fraud not only on FUTURELAND, its thousands of
shareholders, but the public market in general. KODIAK interwove a supposed power for it to

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order the issuance of shares, in the form of a transfer agent letter to Cleartrust, which letter was
supposed to allow KODIAK to order shares to be issued after the funding or investing had
occurred. KODIAK is now attempting to have shares issued using the transfer agent letter when
they have not made any investment or consideration at all, the necessary and required
registration was refused by the SEC and thus there can be no share issuance when the necessary
consideration never occurred and never can occur.
8.

FUTURELAND is a public company under the Security Act of 1934 as stated

herein with in excess of 400 shareholders of record and an estimated 1000 or more shareholders
on the public market throughout the United States, including a large number of shareholders
located in Florida and this jurisdiction. Such action is brought on behalf of the Corporation and
its shareholders to curtail an immediate harm surrounding the release of such shares for
conversion of fraudulent debt to KODIAK in the form of common shares they are seeking to be
issued without restriction. Such issuance will result in immediate harmful effect to the
Corporation and its shareholders which cannot be compensated by money damages. The
damages that will occur is immediate dilution of all other existing shareholders who had actually
paid for their shares by the issuance of shares to KODIAK, which they will sell on the market,
decreasing the value drastically of the FUTURELAND common shares, causing losses to
shareholders which cannot be compensated since they do not have standing to bring an action in
this matter.
9.

FUTURELAND will suffer immediate harm which cannot be compensated by

money damages, since the Corporation, its thousands of shareholders, will lose an immediate
project pending for the acquisition of a business project outside the State of Florida which is
pending, since the issuance will result in the issuance of shares without consideration to
FUTURELAND and such acquisition is unique to the business of FUTURELAND and cannot be
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remedied through later money damages.

10.

Such shares which have no legal basis and have never had any consideration

behind them. There would be no compensation to these shareholders which include persons in
nearly all the United States, and hundreds of shareholders in the State of Florida alone. Such
depressed share prices impact the Company in many material ways, including present financing
agreements which depend on the share price stability, which issuance of such shares shall
immediately depress and cause such financing to be breached or be abandoned.
11.

If all shareholders are harmed by a strong drop in share value due to the sale of

these shares, there is no possible way they could be compensated by money damages at all from
KODIAK, even assuming KODIAK had the ability to pay such damages. Individual shareholders
as well as the Corporation will lose the business since it will shut down some or all Corporate
operations because such sales of such amount of shares on the public market will decrease the
ability of the Corporation to close out pending land and joint venture operations. KODIAKs
fraud will the business shut down many operations, costing jobs, and opportunities that are
unique to the industry, due to the highly regulated nature of the FUTURELANDs business.
12.

This will all occur for the reason that KODIAK completely defrauded the

Company and is now attempting to defraud Cleartrust and the public shareholders to issue the
fraudulently based shares.
NECESSITY OF BOND
13.

No bond is necessary in this matter, but if necessary then the Court must take into

account that KODIAK has not invested, loaned or otherwise paid anything whatsoever to
FUTURELAND or any other party for the shares it is attempting to gain.
14.

As FUTURELAND has moved for rescission of all agreements due to the actions

described below and in the accompanying complaint, no damages to KODIAK may lie at all.

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15.

As well, the Court could Order that the Corporation could set aside such amount

of shares to be issued to KODIAK in the event they prevail in such matter.

16.

Because the phraseology of Rule 1.610 as to waivers of bond, if the Court finds

that a Bond is necessary in this cause of action by the Plaintiff Corporation, then a de minimis
bond would suffice, that the Court would allow Counsel for the Plaintiff Corporation to sign for
as a signature bond with the Clerks Office for posting. Given that the amount of conversion is
not based on any money whatsoever being invested, loaned or otherwise in consideration at all
for such shares, then a bond in the suggested amount of $5,000.00 should suffice.
FACTUAL ALLEGATIONS
17.

KODIAK is attempting to gain shares alleging debt it does not, and never did

hold. FUTURELAND has never received any monies in any fashion from KODIAK, and such
actions by KODIAK are deceptive and fraudulent in its attempts to have shares issued from
Cleartrusts LLC the transfer agent for FUTURELAND.
18.

FUTURELAND Corp. common shares trade on the OTCMarkets exchange under

the same symbol as a reporting company under the Securities Act of 1934. As such with over one
thousand shareholders, the Company is a development stage company with business in the land
development arena for medical, industrial and recreational cannabis and hemp growing projects
in such states where such business is legal, or in industrial in regard to hemp.
18.

Before April 8, 2016, KODIAK had represented itself to be a potential investor

into FUTURELAND through a series of documents set forth below. Through the month of
March 2016 and through April 8, 2016, there was the stated and referenced communication by
KODIAK through its manager, Ryan Hodsen and Jim Fitzpatrick to Futureland as represented
herein through email and telephone calls.

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19.

KODIAK had on or about April 8, 2016, prepared and presented three documents

which are at issue in this matter. These three documents included an Equity Purchase Agreement
(EPA) as well as a Convertible Promissory Note (Note) and a Registration Rights
Agreement for shares to be registered with the SEC. The agreements were presented by
KODIAK to FUTURELAND under promises that these agreements would result in necessary
capital to be invested in FUTURELAND for its immediate, short term and long term use for
necessary projects including land purchases, and organic projects for the start-up company to
carry through its business plan.
20.

In the Equity Purchase Agreement, KODIAK made the promise that:

Company shall issue and sell to Investor, from time to time as provided herein, and
investor shall purchase up to One Million Dollars ($1,000,000) of the Company's
Common Stock
(Plaintiffs Exhibit A, page 1).
21.

On information and belief, as a pattern and practice that KODIAK has shown in

numerous agreements with other public issuing companies, they provide such a document, which
seemingly is a promise of investment up to a certain amount by the promise that they will
purchase shares of the common stock of a company. They accompany the EPA with a
Convertible Promissory Note which is by its terms supposed to have been paid for with
consideration. However, KODIAK never provided the consideration for the Notes in similar
company situations. On information and belief no where do they actually provide any purchase
of shares to the companies, nor do they loan or otherwise move money at all to the Companies.
Thus there is never any consideration given for the Notes, which they later allege are debt
documents with this Company and other situated companies.

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22.

In the situation with Plaintiff FUTURELAND, on and about April 8, 2016,

KODIAK made the same promises to FUTURELAND through a serious of telephone calls,
emails and other communications to principals of FUTURELAND, making such actions into the
State of Florida to FUTURELAND at its St. Petersburg, Florida location. KODIAK represented
to the principals of FUTURELAND, being their Chairman and CEO, that KODIAK was binding
itself and agreeing to investment into FUTURELAND up to one million dollars ($1,000,000.00)
through the purchase of common shares of FUTURELAND. The Equity Purchase Agreement,
present at Plaintiffs Exhibit A, shows the promise and enticement that backs up the oral
statements to FUTURELAND that KODIAK would be a large investor based on the EPA. The
operative portion of the EPA includes the Put section which KODIAK held out in the
document and in its representation as being some form of commitment that would empower
FUTURELAND to call or have KODIAK purchase the shares through what is defined as a Put
in the EPA (See filed Complaint Ex. A, Section 1.1 and 2.1).
23.

However, KODIAK by the provision of such EPA agreement also intrinsically

tied matters to two other documents as well, which included a Convertible Promissory Note
(Note) dated the same date of April 8, 2016. Such Note was purported through the
communication made to FUTURELAND to be part and parcel of the investment through the
EPA and completely inseparable from each other. This communication was explained to the
Chairman and the Chief Executive Officer of FUTURELAND, that the Note for its consideration
portion was not just dependent on actual monies being invested into FUTURELAND, but also to
an effective stock registration being accomplished through a Form S-1 filing Registration
Statement with the Securities and Exchange Commission (SEC). The three matters had to
work in conjunction with each other for FUTURELAND to receive monies as an investment (the

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EPA), and thus the debt (the Note) would exist through the S-1 filing being declared effective by
the SEC.
24.

The only way that these agreements would in any way work to cause any debt

FUTURELAND, was if the registration with the SEC for the S-1 Registration Statement with the
SEC to be declared effective by the SEC. KODIAK through its conversations during the time
period on and before April 8, 2016 related and assured both the Chairman and CEO that
obviously no monies would be owed by FUTURELAND unless there was an effective
Registration Statement effected by the SEC, which would place the Company in the position of
using the Put notice in the EPA to make KODIAK purchase shares which were approved
through the registration when it was effective. The Note as it was explained was merely to secure
monies invested through the other agreement, the EPA. The three matters of these documents
worked in conjunction with each other. If one failed they all failed short of KODIAK actually
investing or loaning money to FUTURELAND in separate way. KODIAK has never invested or
loaned money to FUTURELAN in any other manner.
25.

To date, absolutely no monies whatsoever were paid, invested or loaned to

FUTURELAND whatsoever by KODIAK. All representations they are making that the Note
was paid for is fraudulent and false.
26.

For purposes of this Complaint,. The Equity Purchase Agreement is attached as

Exhibit A to accompanying Complaint. The Convertible Promissory Note is attached as Exhibit

B to the accompanying Complaint. As well the Registration Rights Agreement which depended
on the SEC Registration is attached to the accompanying Complaint as Exhibit C.

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27.

KODIAK not only made the representation of this so called commitment through

the EPA, but it also provided the commitment in the Registration Rights Agreement that they
would receive their rights to share issuances through the S-1 registration.
28.

FUTURELAND, pursuant to the Registration Rights Agreement with KODIAK,

filed a Form S-1 with the Securities and Exchange Commission on or about May 23, 2016.
29.

Unknown to FUTURELAND at the time of the filing of the Form S-1with the

SEC, due to the prior history of KODIAK with other Companies, and their course and conduct of
such share purchase agreements, notes and other ruses used, KODIAK on information and belief
become a prime flag for the Securities and Exchange Commission when S-1 filings are made
where they are an intended recipient of shares to be registered for sale.
30.

As communicated by the SEC, based upon in large part the involvement and

listing of KODIAK being involved as a potential funder and a recipient of shares that were to be
registered under the S-1 filing, the SEC responded to FUTURELAND on or about June 15, 2016,
recommending that the S-1 be withdrawn. Specifically, the SEC called attention to the
involvement of KODIAK and stated in the written comments that KODIAKs attempts at being a
debtor under the agreements did not pass inspection by the SEC staff and they would not
recognize such debt and participation.
31.

Pursuant to such communications, and due to the knowledge that the participation

of KODIAK placed the filing in a position that such would not be approved by the SEC, caused
FUTURELAND to withdraw the S-1 filing on or about June 15, 2016 by formal filing with the
SEC. (Such filings are publicly made at www.sec.gov for FUTURELAND, including the S-1
filing and the withdrawal; the communication to FUTURELAND by the SEC is not published
but is available).

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32.

At that time there could not and did not exist any monies which were put into

FUTURELAND by KODIAK for effectiveness of any Note or debt, including the Note they are
attempting to use for conversion for shares from Cleartrust at the present time. Simply put there
existed no consideration at all by KODIAK to FUTURELAND which would entitle KODIAK to
have any rights under the Note, and certainly no issuance of shares for a non-existent debt.
33.

On information and belief, under essentially the same type of agreements,

including an identical Securities Purchase Agreement which was completely unfunded by

KODIAK including with a company called Endenovo Therapeutics and others, the SEC has
stopped other S-1 filings where KODIAK was involved due to their mode of operation of
claiming false debt and attempting to gain ill-gotten shares and dumping them on unsuspecting
market buyers.
34.

On or about November 1, 2016, the time of the demand and communication of

such conversion notice and communications to Cleartrust for issuance of shares for non-existent
debt, KODIAK knew that their representations of debt on the Note were false and fraudulent.
When such communication of the conversion notice was made to Cleartrust for such shares,
KODIAK did so with the intent that Cleartrust will issue such shares to KODIAK on such false
premises. Without Court intervention, Cleartrust will issue the shares involved to KODIAK
causing the irreparable harm to FUTURELAND. For that reason FUTURELAND is filing a
dependent emergency motion for temporary injunction reliant on these same facts.
36.

At all times material, KODIAK, by its actions of communications sent via email,

telephone calls, and the sending of documents, did send such matters containing the false
representations and materials to Cleartrust, into the State of Florida, to which it intended

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Cleartrust to rely upon and to cause the injury to FUTURELAND and its thousands of
shareholders.
At tall times material, KODIAKs actions of communications, demands and

37.

documentation provided to FUTURELAND, which were false as to the debt they claimed due
was with the intent that FUTURELAND would rely on its false representations to cause the
issuance of the common shares which is and will cause the immediate harm to FUTURELAND
and its shareholders due to the issuance and sale of the shares involved.
38.

As such KODIAK did make such communications with knowledge that the

falsely issued shares would be obtained and sold by them on the public market under fraudulent
circumstances.
NECESSITY FOR IMMEDIATE INJUNCTIVE RELIEF

The Plaintiff hereby moves this Honorable Court for an Order of Injunction
against the issuance and conversion of shares by KODIAK.
39.

If the Court does not grant this motion, then KODIAK will sell be issued and sell

such shares upon the open market, causing immediate and irreparable damage to the shareholders
and the Corporation as set forth above.
40.

FUTURELAND seeks an immediate injunction against the issuance of such

shares in the amount called for by KODIAK in the submitted conversion notice due to the
grounds set forth herein, namely that none of the operative agreements did or could occur, and
the fact that KODIAK had provided NO consideration for the debt it is representing.
41.

FUTURELAND is entitled to such injunctive relief due to the immediate and

imminent threat of sales of such securities into the open market, which would result from sales of

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shares which should not be issued in such amounts since no debt at all exists, and all of the
operable agreements have been nullified and breached by action of KODIAK.
41.

The harm to FUTURELAND and all of its shareholders is immediate and on-

going and cannot be remedied with money damages as set forth above. .
42.

FUTURELAND maintains no other adequate remedy at law due to the harm to its

public market and perception of the Corporation with such potential and likely share devaluation
WHEREFORE, Plaintiff respectfully Requests that this Honorable Court enter an
Emergency Immediate Temporary Injunctive Order directed to Cleartrust, LLC as the transfer
agent for the Plaintiff Corporation to stop such share issuance until such matter is decided by the
Court after an appropriate hearing. Further that it is submitted that KODIAK, due to jurisdiction
being presented in this matter, must be restrained from any further attempts at such conversions.
MEMORANDUM OF LAW
Because a temporary injunction, by its nature, is frequently sought and issued under
hurried circumstances, Rule 1.610(b), Florida Rules of Civil Procedure, provides certain due
process requirements which must be followed by the party seeking a temporary injunction
without notice and by the trial court issuing such an injunction. These requirements seek to
assure that "a court ... never issue[s] an ex parte order without notice to defendants and without a
hearing, unless an immediate threat of irreparable harm exists, which forecloses opportunity to
give reasonable notice...." Lieberman v. Marshall, 236 So.2d 120, 125 (Fla.1970).

Rule 1.610 (a)(1) specifies that a temporary injunction without notice may be granted
only if (1) the affidavits or verified pleadings demonstrate that "immediate and irreparable
injury, loss, or damage will result to the movant before the adverse party can be heard in
opposition" and (2) "the movant's attorney certifies in writing any efforts that have been made to
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give notice and the reasons why notice should not be required." Moreover, rule 1.610(a)(2)
provides that "[e]very temporary injunction granted without notice shall be endorsed with the
date and hour of entry and shall . . . define the injury, state findings by the court why the injury
may be irreparable, and give the reasons why the order was granted without notice if notice was
not given."

The threatened injury exists in a continuing and ongoing basis to all shareholders of the
Corporation and to the very existence of the business of FUTURELAND. The amount of proof
that the Plaintiffs has presented is overwhelming as to the actions of the Defendant/Respondent
have no basis for any shares to be issued, as well as the facts that none of the three operable
agreements can function due to the failure of consideration and the acts of KODIAK which made
SEC registration an impossibility.
CONCLUSION AND PRAYER FOR INJUNCTIVE RELIEF
The issuance of shares as requested and demanded by KODIAK CAPITAL GROUP is
premised upon false debt being presented to Cleartrust. As such the Plaintiff Corporation, hereby
prays that the Court issue an immediate injunction against issuance of shares to KODIAK of the
Corporations stock until full determination of such matter is made by the Court. As well the
Plaintiff Corporation prays that this Court find that there is no requirement for the posting of a
bond, or in the alternative that a deminimus bond be required.
Dated this 1st Day of November 2016.

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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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