Case number 1:21-cv-22639
Proeduca Altus, S.A. et al v. Technology Trade Group, Inc. et al > Documents
| Date Field | Doc. No. | Description (Pages) |
|---|---|---|
| Dec 22, 2021 | 41 | Form AO 120/121 (2) Docket Text: FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (cds) |
| Dec 22, 2021 | 40 | Order Dismissing/Closing Case (1) Docket Text: Order Administratively Closing Case upon Notice of Settlement. Signed by Judge Robert N. Scola, Jr on 12/21/2021. See attached document for full details. (cds) |
| Dec 21, 2021 | 39 | Notice of Settlement (2) Docket Text: NOTICE of Settlement Joint Notice of Settlement by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A. (Brafman, David) |
| Dec 15, 2021 | N/A | Order on Motion for Extension of Time (0) Docket Text: PAPERLESS ORDER: granting the Defendants' agreed motion for extension of time. [37]. The Defendants must respond to the Plaintiffs' amended complaint on or before January 7, 2022. Signed by Judge Robert N. Scola, Jr. (ntd) |
| Dec 15, 2021 | 37 | Motion for Extension of Time (4) Docket Text: Unopposed MOTION for Extension of Time to File Answer to Amended Complaint by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Responses due by 12/29/2021 (Adams, Nathan) |
| Dec 1, 2021 | 36 | Order on Motion to Dismiss (11) Docket Text: ORDER Granting in Part and Denying in Part [24] Motion to Dismiss. Signed by Judge Robert N. Scola, Jr on 12/1/2021. See attached document for full details. (cds) |
| Nov 3, 2021 | 35 | Exhibit B - TSG Parties' Answer, Affirmative Defenses and Counterclaims, No (40) |
| Nov 3, 2021 | 35 | Exhibit A - Complaint, No. 1, Celebrity Cards Int'l, Inc. v Johnson, et al. (29) |
| Nov 3, 2021 | 35 | Main Document (1) Docket Text: AFFIDAVIT in Support re [24] MOTION to Dismiss [20] Amended Complaint/Amended Notice of Removal filed by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. (Attachments: # (1) Exhibit A - Complaint, No. 1, Celebrity Cards Int'l, Inc. v Johnson, et al., 1:13-cv-22197-UU (S.D. Fla. June 19, 2013), # (2) Exhibit B - TSG Parties' Answer, Affirmative Defenses and Counterclaims, No. 21, Assa Realty LLC v The Solution Group Corp, et al., 1:17-cv-22557-RNS (S.D. Fla. Aug. 28, 2017))(Adams, Nathan) |
| Nov 3, 2021 | 34 | Reply to Response to Motion (16) Docket Text: Defendant's REPLY to Response to Motion re [24] MOTION to Dismiss [20] Amended Complaint/Amended Notice of Removal filed by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. (Adams, Nathan) |
| Oct 27, 2021 | 33 | Exhibit E: Complaint for Damages and Injunctive Relief, Bluegreen Vacations Unli (55) |
| Oct 27, 2021 | 33 | Exhibit D: Amended Complaint, Matonis v. Care Holdings Group, L.L.C., No. 1:19-c (21) |
| Oct 27, 2021 | 33 | Exhibit C: Reply to Applicants Opposition to Motion to Suspend Proceedings, Proe (133) |
| Oct 27, 2021 | 33 | Exhibit B: Amended Complaint, Azimuth Unlimited, LLC v. Sea Tel, Inc., No. 10-60 (10) |
| Oct 27, 2021 | 33 | Exhibit A: Plaintiffs Amended Complaint for Injunctive Relief, Declaratory Relie (18) |
| Oct 27, 2021 | 33 | Main Document (2) Docket Text: AFFIDAVIT in Opposition re [24] MOTION to Dismiss [20] Amended Complaint/Amended Notice of Removal filed by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. (Attachments: # (1) Exhibit A: Plaintiffs Amended Complaint for Injunctive Relief, Declaratory Relief and Damages, Ameritox, Ltd. v. Millennium Laboratories, Inc., No. 8:11-CV-00775-SCB-TPM (M.D. Fla. June 14, 2012), # (2) Exhibit B: Amended Complaint, Azimuth Unlimited, LLC v. Sea Tel, Inc., No. 10-60253-CIV-MARTINEZ-BROWN (S.D. Fla. Oct. 6, 2010), # (3) Exhibit C: Reply to Applicants Opposition to Motion to Suspend Proceedings, Proeduca Altus, S.A. v. Technology Trade Group, Inc., No. 91265499 (P.T.A.B. Sept. 30, 2021), # (4) Exhibit D: Amended Complaint, Matonis v. Care Holdings Group, L.L.C., No. 1:19-cv-20247-UU (S.D. Fla. Feb. 8, 2019), # (5) Exhibit E: Complaint for Damages and Injunctive Relief, Bluegreen Vacations Unlimited, Inc. v. Timeshare Lawyers, P.A., No. 1:20-cv-24681-RNS (S.D. Fla. Nov. 13, 2020))(Brafman, David) |
| Oct 27, 2021 | 32 | Response in Opposition to Motion (27) Docket Text: RESPONSE in Opposition re [24] MOTION to Dismiss [20] Amended Complaint/Amended Notice of Removal filed by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. Replies due by 11/3/2021. (Brafman, David) |
| Oct 20, 2021 | 31 | Scheduling Order (7) Docket Text: Scheduling Order and Order of Referral to Mediation: ( Jury Trial set for 9/26/2022 before Judge Robert N. Scola Jr.., Calendar Call set for 9/20/2022 09:00 AM in Miami Division before Judge Robert N. Scola Jr..), ORDER REFERRING CASE to Mediation. Signed by Judge Robert N. Scola, Jr on 10/20/2021. See attached document for full details. (cds) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here. |
| Oct 19, 2021 | 30 | SCHEDULING REPORT - Rule 26(f)/16.1 (7) Docket Text: Joint SCHEDULING REPORT - Rule 26(f) by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A. (Brafman, David) |
| Oct 18, 2021 | 29 | Protective Order (11) Docket Text: STIPULATED PROTECTIVE ORDER. Signed by Judge Robert N. Scola, Jr on 10/18/2021. See attached document for full details. (cds) |
| Oct 15, 2021 | N/A | Clerk's Notice of Docket Correction and Instruction to Filer - Attorney (0) Docket Text: Clerks Notice to Filer re [27] Stipulation. Proposed Order Docketed as Main Document; CORRECTIVE ACTION REQUIRED - Filer must File a Notice of Striking, then resubmit the proposed order as instructed in the CM/ECF Administrative Procedures (cds) |
| Oct 14, 2021 | 27 | Stipulation (10) Docket Text: STIPULATION Stipulated Protective Order by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A. (Brafman, David) |
| Oct 14, 2021 | N/A | Order on Motion to Appear Pro Hac Vice (0) Docket Text: PAPERLESS ORDER granting [25] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Daniel C. Neustadt. Signed by Magistrate Judge Jonathan Goodman on 10/14/2021. (jzn) |
| Oct 13, 2021 | 25 | Motion to Appear Pro Hac Vice (5) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Daniel C. Neustadt. Filing Fee $ 200.00 Receipt # AFLSDC-15089930 by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Responses due by 10/27/2021 (Spector, David) |
| Oct 13, 2021 | 24 | App. F - Educause website (4) |
| Oct 13, 2021 | 24 | App. E - 2011 catalog (92) |
| Oct 13, 2021 | 24 | App. D - accrediting agencies (5) |
| Oct 13, 2021 | 24 | App. C - DOE statement (3) |
| Oct 13, 2021 | 24 | App. B - program list (18) |
| Oct 13, 2021 | 24 | App. A - UNIR website (3) |
| Oct 13, 2021 | 24 | Main Document (23) Docket Text: MOTION to Dismiss [20] Amended Complaint/Amended Notice of Removal by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Responses due by 10/27/2021 (Attachments: # (1) App. A - UNIR website, # (2) App. B - program list, # (3) App. C - DOE statement, # (4) App. D - accrediting agencies, # (5) App. E - 2011 catalog, # (6) App. F - Educause website)(Spector, David) |
| Oct 1, 2021 | N/A | Order on Motion to Appear Pro Hac Vice (0) Docket Text: PAPERLESS ORDER granting [22] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Scott D. Baker. Signed by Magistrate Judge Jonathan Goodman on 10/1/2021. (jzn) |
| Oct 1, 2021 | 22 | Certification of Scott Baker (1) |
| Oct 1, 2021 | 22 | Main Document (3) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Scott D. Baker. Filing Fee $ 200.00 Receipt # BFLSDC-15060613 by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. Responses due by 10/15/2021 (Attachments: # (1) Certification of Scott Baker)(Brafman, David) |
| Sep 30, 2021 | N/A | Order on Motion to Dismiss (0) Docket Text: PAPERLESS ORDER: denying as moot the Defendants' motion to dismiss. [17]. The Plaintiffs' amended complaint moots the Defendants' motion to dismiss a prior pleading. See generally Taylor v. Alabama, 275 F. App'x 836, 838 (11th Cir. 2008). Signed by Judge Robert N. Scola, Jr. (ntd) |
| Sep 29, 2021 | 20 | Amended Complaint/Amended Notice of Removal (29) Docket Text: AMENDED COMPLAINT against Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc., filed by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A..(Brafman, David) |
| Sep 24, 2021 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER: granting the Plaintiffs' unopposed motion for extension of time. [18]. The Plaintiffs shall respond to the Defendants' motion to dismiss or otherwise file an amended complaint on or before September 29, 2021. Signed by Judge Robert N. Scola, Jr. (ntd) |
| Sep 23, 2021 | 18 | Text of Proposed Order on Plaintiffs' Unopposed Motion for Extension of Tim (2) |
| Sep 23, 2021 | 18 | Main Document (3) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [17] MOTION to Dismiss with Prejudice [1] Complaint, by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. (Attachments: # (1) Text of Proposed Order on Plaintiffs' Unopposed Motion for Extension of Time to Respond to Defendants' Motion to Dismiss and Stay)(Brafman, David) |
| Sep 15, 2021 | 17 | Ex 5 - eligibility requirements (6) |
| Sep 15, 2021 | 17 | Ex 4 - WHOIS documents (2) |
| Sep 15, 2021 | 17 | Ex 3 - WHOIS documents (5) |
| Sep 15, 2021 | 17 | Ex 2 - Homepage of www.unir.edu (3) |
| Sep 15, 2021 | 17 | Ex 1 - USPTP documents (5) |
| Sep 15, 2021 | 17 | Main Document (23) Docket Text: MOTION to Dismiss with Prejudice [1] Complaint, by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Responses due by 9/29/2021 (Attachments: # (1) Ex 1 - USPTP documents, # (2) Ex 2 - Homepage of www.unir.edu, # (3) Ex 3 - WHOIS documents, # (4) Ex 4 - WHOIS documents, # (5) Ex 5 - eligibility requirements)(Spector, David) |
| Sep 15, 2021 | N/A | Order on Motion to Appear Pro Hac Vice (0) Docket Text: PAPERLESS ORDER: granting the Plaintiffs' motion to appear pro hac vice. [15]. Attorney Ira S. Sacks is given permission to appear and participate in this matter on behalf of the Plaintiffs. The Clerk is directed to provide this attorney with notification of all electronic filings via the e-mail address set forth in the motion. Signed by Judge Robert N. Scola, Jr. (ntd) |
| Sep 15, 2021 | 15 | Certification of Ira S. Sacks (2) |
| Sep 15, 2021 | 15 | Main Document (3) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Ira S. Sacks. Filing Fee $ 200.00 Receipt # AFLSDC-15011237 by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. Responses due by 9/29/2021 (Attachments: # (1) Certification of Ira S. Sacks)(Brafman, David) |
| Aug 13, 2021 | 14 | Certificate of Other Affiliates/Corporate Disclosure Statement (2) Docket Text: Defendant's Corporate Disclosure Statement by Technology Trade Group, Inc. (Spector, David) |
| Aug 12, 2021 | N/A | Order on Motion for Disclosure (0) Docket Text: PAPERLESS ORDER: This matter is before the Court upon the Defendants stipulation for extension of time [11] and corporate disclosure statement [8]. While the Court appreciates the parties coming to an agreement on the proposed extension of time, the proper means to seek an extension of time is to file a motion, not a stipulation, with the Court, asking for leave from the Court to extend deadlines. As such, the Court construes the parties' stipulation as a joint motion and grants the relief sought. The deadline for the Defendants to respond to the complaint is now September 15, 2021. The Court notes that the Defendants have agreed to waive the assertion of an insufficient service of process defense. Confusingly, the Defendant Technology Trade Group, Inc. filed its corporate disclosure statement as a motion. As no relief is being sought from the Court, the Court denies the Defendant's motion. Signed by Judge Robert N. Scola, Jr. (sda) |
| Aug 12, 2021 | N/A | Clerk's Notice of Docket Correction and Instruction to Filer - Attorney (0) Docket Text: Clerks Notice to Filer re [11] Stipulation. Wrong Filer Name(s) Selected; ERROR - The wrong filer name was selected. The correction was made by the Clerk. It is not necessary to refile this document. (cds) |
| Aug 12, 2021 | 11 | Text of Proposed Order Proposed Order (1) |
| Aug 12, 2021 | 11 | Main Document (2) Docket Text: STIPULATION by Jane Doe, John Doe, Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc., XYZ Corporation (Attachments: # (1) Text of Proposed Order Proposed Order)(Adams, Nathan) Modified Filers on 8/12/2021 (cds). |
| Aug 12, 2021 | N/A | Clerk's Notice of Docket Correction and Instruction to Filer - Attorney (0) Docket Text: Clerks Notice to Filer re [9] Notice of Attorney Appearance,. Wrong Filer Name(s) Selected; ERROR - The wrong filer name was selected. The correction was made by the Clerk. It is not necessary to refile this document. (cds) |
| Aug 12, 2021 | 9 | Notice of Attorney Appearance (2) Docket Text: NOTICE of Attorney Appearance by David Ira Spector on behalf of , Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc., . Attorney David Ira Spector added to party Maria Moreno(pty:dft), Attorney David Ira Spector added to party Carol Palacios(pty:dft), Attorney David Ira Spector added to party Omar Palacios(pty:dft), Attorney David Ira Spector added to party Technology Trade Group, Inc.(pty:dft), (Spector, David) Modified Filers on 8/12/2021 (cds). |
| Aug 12, 2021 | 8 | Motion for Disclosure (2) Docket Text: MOTION for Disclosure DEFENDANT TECHNOLOGY TRADE GROUP INC.'S CORPORATE DISCLOSURE STATEMENT by Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Attorney Nathan Aldrich Adams, IV added to party Technology Trade Group, Inc.(pty:dft). (Adams, Nathan) |
| Aug 12, 2021 | 7 | Notice of Attorney Appearance (2) Docket Text: NOTICE of Attorney Appearance by Nathan Aldrich Adams, IV on behalf of Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. Attorney Nathan Aldrich Adams, IV added to party Maria Moreno(pty:dft), Attorney Nathan Aldrich Adams, IV added to party Carol Palacios(pty:dft), Attorney Nathan Aldrich Adams, IV added to party Omar Palacios(pty:dft), Attorney Nathan Aldrich Adams, IV added to party Technology Trade Group, Inc. (Adams, Nathan) Modified Text on 8/12/2021 (cds). |
| Aug 12, 2021 | N/A | Terminate Attorneys (0) Docket Text: Attorney Nathan Aldrich Adams, IV representing Doe, John (Defendant) and Doe, Jane (Defendant) and XYZ Corporation (Defendant); terminated. PE DE#[7] (cds) |
| Aug 12, 2021 | N/A | Terminate Attorneys (0) Docket Text: Attorney David Ira Spector representing Doe, John (Defendant) and Doe, Jane (Defendant) and XYZ Corporation (Defendant); terminated. PER DE#[9] (cds) |
| Jul 26, 2021 | 6 | Order (11) Docket Text: MAGISTRATE JUDGE GOODMAN'S DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jonathan Goodman on 7/26/2021. See attached document for full details. (fbn) |
| Jul 23, 2021 | 5 | Order Referring Case to Magistrate Judge (4) Docket Text: Order Requiring Discovery and Scheduling Conference and Order Referring Discovery Matters to the Magistrate Judge Jonathan Goodman. Signed by Judge Robert N. Scola, Jr on 7/23/2021. See attached document for full details. (cds) |
| Jul 23, 2021 | 4 | Summons Issued (4) Docket Text: Summons Issued as to Maria Moreno, Carol Palacios, Omar Palacios, Technology Trade Group, Inc.. (cds) |
| Jul 22, 2021 | 3 | Form AO 120/121 (25) Docket Text: FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (cds) |
| Jul 22, 2021 | N/A | Clerk's Notice of Judge Assignment (0) Docket Text: Clerks Notice of Judge Assignment to Judge Robert N. Scola, Jr. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (cds) |
| Jul 22, 2021 | 1 | Summon(s) to Maria Moreno (2) |
| Jul 22, 2021 | 1 | Summon(s) to Carol Palacios (2) |
| Jul 22, 2021 | 1 | Summon(s) to Omar Palacios (2) |
| Jul 22, 2021 | 1 | Summon(s) to Technology Trade Group (2) |
| Jul 22, 2021 | 1 | Civil Cover Sheet Civil Cover Sheet (1) |
| Jul 22, 2021 | 1 | Main Document (24) Docket Text: COMPLAINT against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-14868454, filed by Proeduca Altus, S.A., Universidad Internacional De La Rioja, S.A.. (Attachments: # (1) Civil Cover Sheet Civil Cover Sheet, # (2) Summon(s) to Technology Trade Group, # (3) Summon(s) to Omar Palacios, # (4) Summon(s) to Carol Palacios, # (5) Summon(s) to Maria Moreno)(Brafman, David) |
