The 20-page Motion to Dismiss Complaint for Damages and Injunctive Relief, filed September 20, 2013 Miami-Dade Circuit Court , calls the original complaint "a spiteful, publicity-driven lawsuit with no legal merit" and "an attempt to stifle competition in contravention of clear Florida law and nothing more than an attempt to bully a small business owner through an over-pled compilation of misbegotten allegations."
The motion also gives the Miami restaurant scene a new word -- "Kunkeled" or "to Kunkel", which, according to the legal document means,
"To Kunkel" is acquiring a hire - liar - fire cache in the Miami restaurant business, as that appears to be 50 Eggs' pattern with its executive chefs: to hire them, accuse them of lying, and then fire them (or cause them to quit)."
See also: Khong's Chee Bee Headed to Oishi Thai
The motion also raises questions about 50 Eggs CEO John Kunkel's knowledge of Thai food -- and karma in general, and includes a picture of the 50 Eggs leader dining at Oishi Thai, presumably before Khong River House opened.
"One would also think that someone who "fell in love with Thailand," "stayed there for three years," "experienced the tastes and flavors of Thailand by sharing meals around tables in rural homes," and had a "life-altering" experience - as 50 Eggs claims Mr. Kunkel did beginning when he was eighteen, would understand that just because he ate food in Thailand some twenty or so years ago does not give him a quasi-monopoly
on the service of Thai food in Miami. One would also think that living in Thailand and
sharing food in family homes - much as he did in Chef Bee's restaurant in the picture above - would have taught him about karma. Again, apparently not."