Case number 0:20-cv-62355
Remember Everyone Deployed Inc. v. AC2T Inc. et al > Documents
| Date Field | Doc. No. | Description (Pages) |
|---|---|---|
| Mar 29, 2022 | 117 | Stipulation of Dismissal (2) Docket Text: STIPULATION of Dismissal With Prejudice by Remember Everyone Deployed Inc. (Bravo, Gustavo) |
| Mar 29, 2022 | 118 | Order Dismissing/Closing Case (1) Docket Text: ORDER Dismissing Case (With Prejudice) Signed by Magistrate Judge Jared M. Strauss on 3/29/2022. See attached document for full details. (drz) |
| Mar 15, 2022 | 114 | Administrative Order (1) Docket Text: Order Administratively Closing Case. Motions terminated: [97] MOTION TO DISMISS [71] Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM filed by Rick Ware Racing, LLC, Premium Motorsports LLC. Signed by Magistrate Judge Jared M. Strauss on 3/15/2022. See attached document for full details. (drz) |
| Mar 15, 2022 | 115 | Main Document (1) Docket Text: FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK. (Attachments: # (1) Administrative Order) (drz) |
| Mar 15, 2022 | 115 | Administrative Order (1) |
| Mar 15, 2022 | N/A | Status Conference (0) Docket Text: PAPERLESS Minute Entry for proceedings held before Magistrate Judge Jared M. Strauss: Telephonic Status Conference held on 3/15/2022. Attorney Appearance(s): Gustavo Alfonso Bravo, Neil David Kodsi, John Nading, Devika Persaud, Alan Wilmont. (Digital JMS_06_03-15-2022) (at) |
| Mar 14, 2022 | 113 | Notice of Settlement (4) Docket Text: NOTICE of Settlement by Remember Everyone Deployed Inc.(a Florida not for profit corporation) (Kodsi, Neil) |
| Mar 10, 2022 | 112 | Notice (Other) (6) Docket Text: NOTICE by Remember Everyone Deployed Inc. re [105] Order, Set/Reset Deadlines of Joint Liability (Bravo, Gustavo) |
| Mar 9, 2022 | N/A | Set/Reset Deadlines (0) Docket Text: Set/Reset Response/Answer Due Deadline: Brennan Poole response/answer due 3/29/2022. (emd) |
| Mar 9, 2022 | 106 | Motion for Extension of Time to File Response/Reply/Answer (5) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [97] MOTION TO DISMISS [71] Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Remember Everyone Deployed Inc.. (Bravo, Gustavo) |
| Mar 9, 2022 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [106] Motion for Extension of Time. Response to [97] Motion to Dismiss due by 3/14/2022. Signed by Magistrate Judge Jared M. Strauss on 3/9/2022. (emd) |
| Mar 9, 2022 | 108 | Main Document (5) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Michael A. Harris. Filing Fee $ 200.00 Receipt # AFLSDC-15460568 by Brennan Poole. Attorney Steven M. De Falco added to party Brennan Poole(pty:dft). Responses due by 3/23/2022 (Attachments: # (1) Text of Proposed Order)(De Falco, Steven) |
| Mar 9, 2022 | 108 | Text of Proposed Order (1) |
| Mar 9, 2022 | 109 | Main Document (8) Docket Text: Set Aside Per Order DE#[11]-Unopposed MOTION to Set Aside Default by Brennan Poole. (Attachments: # (1) Exhibit A - Declaration of Brennan Poole, # (2) Text of Proposed Order)(De Falco, Steven) Modified on 3/10/2022 (drz). |
| Mar 9, 2022 | 109 | Exhibit A - Declaration of Brennan Poole (2) |
| Mar 9, 2022 | 109 | Text of Proposed Order (1) |
| Mar 9, 2022 | N/A | Order on Motion to Appear Pro Hac Vice (0) Docket Text: PAPERLESS ORDER granting [108] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Michael A. Harris. Mr. Harris is permitted to appear before this Court on behalf of Defendant Brennan Poole for all purposes relating to this action. Failure to abide by any Court order may result in immediate revocation of counsel's pro hac vice status. The Clerk is directed to provide Notice of Electronic Filings to Mr. Harris at mah@pdhlaw.com. Signed by Magistrate Judge Jared M. Strauss on 3/9/2022. (emd) |
| Mar 9, 2022 | N/A | Order on Motion to Set Aside Default (0) Docket Text: PAPERLESS ORDER granting [109] Unopposed Motion to Set Aside Default. DE [104] Clerk's Entry of Default is set aside as to Defendant Brennan Poole (however, the Clerk's Entry of Default remains in place as to Defendant On Point Motorsports, Inc.). Defendant Brennan Poole shall respond to [71] Second Amended Complaint by 3/29/2022. Signed by Magistrate Judge Jared M. Strauss on 3/9/2022. (emd) |
| Mar 1, 2022 | 104 | Clerk's Entry/Non-Entry of Default (2) Docket Text: Clerks Entry of Default as to On Point Motorsports, Inc., Brennan Poole - Motions Terminated: [103] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 3/1/2022. (drz) |
| Mar 1, 2022 | 105 | Order (3) Docket Text: ORDER REQUIRING MOTION FOR DEFAULT FINAL JUDGMENT OR NOTICE OF JOINT LIABILITY by 3/10/2022. Signed by Magistrate Judge Jared M. Strauss on 3/1/2022. See attached document for full details. (emd) |
| Feb 28, 2022 | N/A | Clerk's Notice of Docket Correction and Instruction to Filer - Attorney (0) Docket Text: Clerks Notice to Filer re [101] Notice of Attorney Appearance. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match the typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and Local Rule 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (drz) |
| Feb 28, 2022 | 103 | Main Document (4) Docket Text: Plaintiff's MOTION for Clerks Entry of Default as to On Point Motorsports, Inc., Brennan Poole by Remember Everyone Deployed Inc.. (Attachments: # (1) Exhibit Ex A - Declaration of G. Bravo in Support of Motion for Clerk's Default)(Bravo, Gustavo) |
| Feb 28, 2022 | 103 | Exhibit Ex A - Declaration of G. Bravo in Support of Motion for Clerk's Def (3) |
| Feb 25, 2022 | N/A | Order Setting Status Conference (0) Docket Text: PAPERLESS ORDER Setting Telephonic Status Conference: Status Conference Re: Scheduling/Deadlines/Procedural Matters set for 3/14/2022 at 2:00 PM before Magistrate Judge Jared M. Strauss. Counsel for the parties shall use the following dial-in information: Dial-in Number (888) 557-8511; Access Code 9883094. Please dial in at least 10 minutes before the status conference begins. The parties shall not use speakerphone. In addition, the parties should avoid using a cell phone if possible. Signed by Magistrate Judge Jared M. Strauss on 2/25/2022. (emd) |
| Feb 25, 2022 | N/A | Order (0) Docket Text: PAPERLESS ORDER. This matter came before the Court sua sponte. Plaintiff previously indicated that Defendants On Point Motorsports, Inc. and Brennan Poole were served on November 9, 2021 and January 20, 2022, respectively. See DE [80], [92]. Therefore, provided that service was proper, they were initially required to respond to the Second Amended Complaint by November 30, 2021 and February 10, 2022, respectively. However, those deadlines have been extended to February 24, 2022. See DE 95. Nonetheless, Defendants On Point Motorsports, Inc. and Brennan Poole have not yet responded to the Second Amended Complaint. Therefore, by March 1, 2022, Plaintiff shall file: (1) a motion for clerk's entry of default as to Defendants On Point Motorsports, Inc. and Brennan Poole; or (2) if Plaintiff believes that such a motion would be premature or otherwise inappropriate, a response indicating why Plaintiff so contends. Signed by Magistrate Judge Jared M. Strauss on 2/25/2022. (emd) |
| Feb 25, 2022 | N/A | Order (0) Docket Text: PAPERLESS ORDER Rescheduling Telephonic Status Conference Re: Scheduling/Deadlines/Procedural Matters for 3/15/2022 at 10:30 AM before Magistrate Judge Jared M. Strauss. Counsel for the parties shall use the following dial-in information: Dial-in Number (888) 557-8511; Access Code 9883094. Please dial in at least 10 minutes before the status conference begins. The parties shall not use speakerphone. In addition, the parties should avoid using a cell phone if possible. Signed by Magistrate Judge Jared M. Strauss on 2/25/2022. (emd) |
| Feb 25, 2022 | 101 | Notice of Attorney Appearance (2) Docket Text: NOTICE of Attorney Appearance by Darren Adam Heitner on behalf of Premium Motorsports LLC, Rick Ware Racing, LLC (Heitner, Darren) |
| Feb 24, 2022 | 97 | Motion to Dismiss for Failure to State a Claim (12) Docket Text: MOTION TO DISMISS [71] Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Premium Motorsports LLC, Rick Ware Racing, LLC. Responses due by 3/10/2022 (Heitner, Darren) |
| Feb 22, 2022 | 96 | Answer to Counterclaim (18) Docket Text: ANSWER to Counterclaim by Remember Everyone Deployed Inc.(a Florida not for profit corporation). (Bravo, Gustavo) |
| Feb 9, 2022 | 94 | Motion for Extension of Time to File Response/Reply/Answer (4) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [92] Certificate of Service, PLAINTIFFS SECOND AMENDED COMPLAINT by Premium Motorsports LLC, Rick Ware Racing, LLC. (Heitner, Darren) |
| Feb 9, 2022 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [94] Motion for Extension of Time. Defendants On Point Motorsports, Inc., Brennan Poole, Premium Motorsports LLC, and Rick Ware Racing, LLC shall file separate answers or a single combined responsive motion by 2/24/2022. No further extensions will be granted. Signed by Magistrate Judge Jared M. Strauss on 2/9/2022. (emd) |
| Feb 7, 2022 | 93 | Order on Motion to Dismiss (4) Docket Text: ORDER denying [82] Motion to Dismiss and Strike. Signed by Magistrate Judge Jared M. Strauss on 2/7/2022. See attached document for full details. (emd) |
| Jan 21, 2022 | 92 | Main Document (5) Docket Text: CERTIFICATE OF SERVICE by Remember Everyone Deployed Inc. re [87] Order to Show Cause, Verified Notice of Service of Second Amended Complaint as to Defendant Brennan Poole (Attachments: # (1) Exhibit Declaration of Kristina Aguero in Support of Service)(Bravo, Gustavo) |
| Jan 21, 2022 | 92 | Exhibit Declaration of Kristina Aguero in Support of Service (25) |
| Jan 18, 2022 | 91 | Notice of Withdrawal of Motion (2) Docket Text: NOTICE OF WITHDRAWAL OF MOTION by Premium Motorsports LLC, Rick Ware Racing, LLC re [89] MOTION for Sanctions Pursuant to Rule 11 and Incorporated Memorandum of Law filed by Rick Ware Racing, LLC, Premium Motorsports LLC (Heitner, Darren) |
| Jan 13, 2022 | 90 | Main Document (16) Docket Text: RESPONSE in Opposition re [89] MOTION for Sanctions Pursuant to Rule 11 and Incorporated Memorandum of Law filed by Remember Everyone Deployed Inc.(a Florida not for profit corporation). Replies due by 1/20/2022. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2)(Kodsi, Neil) |
| Jan 13, 2022 | 90 | Exhibit 1 (6) |
| Jan 13, 2022 | 90 | Exhibit 2 (10) |
| Dec 30, 2021 | 89 | Motion for Sanctions (16) Docket Text: MOTION for Sanctions Pursuant to Rule 11 and Incorporated Memorandum of Law by Premium Motorsports LLC, Rick Ware Racing, LLC. (Heitner, Darren) |
| Dec 10, 2021 | 87 | Order to Show Cause (1) Docket Text: ORDER TO PERFECT SERVICE. On or before January 24, 2022, Plaintiff shall perfect service upon Defendant Brennan Poole or show cause as to why this case should not be dismissed against Poole for failure to perfect service of process. Signed by Magistrate Judge Jared M. Strauss on 12/10/2021. See attached document for full details. (emd) |
| Dec 10, 2021 | 88 | Reply to Response to Motion (7) Docket Text: Plaintiff's REPLY to Response to Motion re [82] MOTION to Dismiss with Prejudice [76] Answer to Amended Complaint,,,,, Counterclaim,,,, MOTION to Strike [76] Answer to Amended Complaint,,,,, Counterclaim,,,, filed by Remember Everyone Deployed Inc.(a Florida not for profit corporation). (Bravo, Gustavo) |
| Dec 7, 2021 | 86 | Status Report (5) Docket Text: STATUS REPORT REGARDING SERVICE OF SECOND AMENDED COMPLAINT AS TO BRENNAN POOLE by Remember Everyone Deployed Inc.(a Florida not for profit corporation) (Kodsi, Neil) |
| Dec 3, 2021 | 85 | Response in Opposition to Motion (18) Docket Text: RESPONSE in Opposition re [82] MOTION to Dismiss with Prejudice [76] Answer to Amended Complaint,,,,, Counterclaim,,,, MOTION to Strike [76] Answer to Amended Complaint,,,,, Counterclaim,,,, filed by AC2T Inc.(a Mississippi corporation), Jeremy Hirsh(an individual). Replies due by 12/10/2021. (O'Quinn, Ryan) |
| Dec 2, 2021 | 83 | Main Document (4) Docket Text: MOTION for Extension of Time to File Response/Reply/Answer as to [71] Amended Complaint/Amended Notice of Removal, by Premium Motorsports LLC, Rick Ware Racing, LLC. Attorney Darren Adam Heitner added to party Premium Motorsports LLC(pty:dft), Attorney Darren Adam Heitner added to party Rick Ware Racing, LLC(pty:dft). (Attachments: # (1) Text of Proposed Order Proposed Order)(Heitner, Darren) |
| Dec 2, 2021 | 83 | Text of Proposed Order Proposed Order (2) |
| Dec 2, 2021 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER Requiring Separate Answers or Combined Responsive Motion, Denying as Moot [83] Motion for Extension of Time to Respond to Second Amended Complaint, and Requiring Plaintiff to File Status Report. Defendants On Point Motorsports, Inc., Brennan Poole, Premium Motorsports LLC, and Rick Ware Racing, LLC shall file separate answers or a single combined responsive motion within the time allowed for the last-served Defendant to respond to the Second Amended Complaint. Accordingly, the motion for extension of time is denied as moot. Additionally, by 12/7/2021, Plaintiff shall file a status report regarding the status of service on Defendant Brennan Poole. Signed by Magistrate Judge Jared M. Strauss on 12/2/2021. (emd) |
| Nov 22, 2021 | 82 | Motion to Dismiss (13) Docket Text: MOTION to Dismiss with Prejudice [76] Answer to Amended Complaint,,,,, Counterclaim,,,, , MOTION to Strike [76] Answer to Amended Complaint,,,,, Counterclaim,,,, by Remember Everyone Deployed Inc.(a Florida not for profit corporation). Responses due by 12/6/2021 (Bravo, Gustavo) |
| Nov 18, 2021 | 81 | Notice of Change of Address, Email or Law Firm Name (2) Docket Text: NOTICE of Change of Address, Email or Law Firm Name by Neil David Kodsi (Kodsi, Neil) |
| Nov 17, 2021 | 80 | Main Document (5) Docket Text: STATUS REPORT REGARDING SERVICE OF SECOND AMENDED COMPLAINT by Remember Everyone Deployed Inc.(a Florida not for profit corporation) (Attachments: # (1) Exhibit Affidavit of Service as to On Point Motorsports Inc.)(Kodsi, Neil) |
| Nov 17, 2021 | 80 | Exhibit Affidavit of Service as to On Point Motorsports Inc. (3) |
| Nov 13, 2021 | N/A | Order on Motion for Extension of Time (0) Docket Text: PAPERLESS ORDER. The deadlines in DE [64] are hereby stayed pending further order of the Court. Therefore, DE [78] is denied as moot. By 11/17/2021, Plaintiff shall file a status report regarding the status of its attempts to serve the new defendants and should indicate when it expects to complete service. In preparing the status report, Plaintiff should consider the representation made in paragraph 39 of DE [65]. Signed by Magistrate Judge Jared M. Strauss on 11/13/2021. (emd) |
| Nov 12, 2021 | 78 | Main Document (3) Docket Text: Joint MOTION for Extension of Time to Extend Pretrial and Trial Schedule re [64] Order on Motion to Reopen Case,,, by AC2T Inc.(a Mississippi corporation), Jeremy Hirsh(an individual). Responses due by 11/29/2021 (Attachments: # (1) Text of Proposed Order Proposed Order)(O'Quinn, Ryan) |
| Nov 12, 2021 | 78 | Text of Proposed Order Proposed Order (2) |
| Nov 8, 2021 | 76 | Main Document (54) Docket Text: ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand to Second Amended Complaint, Amended COUNTERCLAIM against Remember Everyone Deployed Inc. by AC2T Inc., Jeremy Hirsh. (Attachments: # (1) Exhibit Exhibit 1, # (2) Exhibit Exhibit 2, # (3) Exhibit Exhibit 3, # (4) Exhibit Exhibit 4, # (5) Exhibit Exhibit 5, # (6) Exhibit Exhibit 6, # (7) Exhibit Exhibit 7, # (8) Exhibit Exhibit 8, # (9) Exhibit Exhibit 9, # (10) Exhibit Exhibit 10, # (11) Exhibit Exhibit 11, # (12) Exhibit Exhibit 12, # (13) Exhibit Exhibit 13, # (14) Exhibit Exhibit 14, # (15) Exhibit Exhibit 15, # (16) Exhibit Exhibit 16, # (17) Exhibit Exhibit 17, # (18) Exhibit Exhibit 18, # (19) Exhibit Exhibit 19, # (20) Exhibit Exhibit 20, # (21) Exhibit Exhibit 21, # (22) Exhibit Exhibit 22, # (23) Exhibit Exhibit 23, # (24) Exhibit Exhibit 24, # (25) Exhibit Exhibit 25, # (26) Exhibit Exhibit 26, # (27) Exhibit Exhibit 27, # (28) Exhibit Exhibit 28, # (29) Exhibit Exhibit 29, # (30) Exhibit Exhibit 30, # (31) Exhibit Exhibit 31)(O'Quinn, Ryan) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 1 (11) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 2 (21) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 3 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 4 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 5 (11) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 6 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 7 (4) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 8 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 9 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 10 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 11 (4) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 12 (4) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 13 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 14 (6) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 15 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 16 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 17 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 18 (3) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 19 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 20 (12) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 21 (4) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 22 (6) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 23 (7) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 24 (6) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 25 (7) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 26 (7) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 27 (7) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 28 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 29 (7) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 30 (5) |
| Nov 8, 2021 | 76 | Exhibit Exhibit 31 (4) |
| Nov 8, 2021 | N/A | Order on Motion to Dismiss (0) Docket Text: PAPERLESS ORDER denying as moot [68] Motion to Dismiss in light of Amended Counterclaim (DE [76]). Signed by Magistrate Judge Jared M. Strauss on 11/8/2021. (emd) |
| Oct 28, 2021 | 75 | Summons Issued (4) Docket Text: Summons Issued as to On Point Motorsports, Inc., Brennan Poole, Premium Motorsports LLC, Rick Ware Racing, LLC. (drz) |
| Oct 27, 2021 | 74 | Main Document (3) Docket Text: NOTICE of Filing Proposed Summons(es) by Remember Everyone Deployed Inc. (Attachments: # (1) Summon(s) proposed Summons directed to Rick Ware Racing, LLC, # (2) Summon(s) proposed Summons directed to Premium Motorsports, LLC, # (3) Summon(s) proposed Summons directed to On Point Motorsports Inc., # (4) Summon(s) proposed Summons directed to Brennan Poole) (Kodsi, Neil) |
| Oct 27, 2021 | 74 | Summon(s) proposed Summons directed to Rick Ware Racing, LLC (2) |
| Oct 27, 2021 | 74 | Summon(s) proposed Summons directed to Premium Motorsports, LLC (2) |
| Oct 27, 2021 | 74 | Summon(s) proposed Summons directed to On Point Motorsports Inc. (2) |
| Oct 27, 2021 | 74 | Summon(s) proposed Summons directed to Brennan Poole (2) |
| Oct 26, 2021 | 72 | Main Document (4) Docket Text: Joint MOTION for Extension of Time to File Response/Reply/Answer as to [68] MOTION to Dismiss with Prejudice [61] Answer to Amended Complaint,,,,, Counterclaim,,,, and to Strike Improper Allegations and Exhibits by AC2T Inc., Jeremy Hirsh. (Attachments: # (1) Text of Proposed Order Proposed Order)(O'Quinn, Ryan) |
| Oct 26, 2021 | 72 | Text of Proposed Order Proposed Order (1) |
| Oct 26, 2021 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [72] Motion for Extension of Time. Response to [68] Motion to Dismiss due by 11/24/2021. Signed by Magistrate Judge Jared M. Strauss on 10/26/2021. (emd) |
| Oct 25, 2021 | 71 | Main Document (30) Docket Text: Second AMENDED COMPLAINT FOR DAMAGES against AC2T Inc., Jeremy Hirsh, Brennan Poole, On Point Motorsports, Inc., Premium Motorsports LLC, Rick Ware Racing, LLC filed in response to Order Granting Motion for Leave, filed by Remember Everyone Deployed Inc.. (Attachments: # (1) Exhibit)(Kodsi, Neil) |
| Oct 25, 2021 | 71 | Exhibit (88) |
| Oct 23, 2021 | 70 | Order on Motion for Leave to File (7) Docket Text: ORDER granting [65] Motion for Leave to File Second Amended Complaint. Clerk's Notice: Filer must separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge. Amended Complaint due by 10/26/2021. Signed by Magistrate Judge Jared M. Strauss on 10/23/2021. See attached document for full details. (emd) |
| Oct 15, 2021 | 69 | Reply to Response to Motion (12) Docket Text: Plaintiff's REPLY to Response to Motion re [65] Plaintiff's MOTION for Leave to File Second Amended Complaint filed by Remember Everyone Deployed Inc.. (Bravo, Gustavo) |
| Oct 12, 2021 | 68 | Motion to Dismiss (12) Docket Text: MOTION to Dismiss with Prejudice [61] Answer to Amended Complaint,,,,, Counterclaim,,,, and to Strike Improper Allegations and Exhibits by Remember Everyone Deployed Inc.. Responses due by 10/26/2021 (Bravo, Gustavo) |
| Oct 8, 2021 | 67 | Main Document (15) Docket Text: RESPONSE in Opposition re [65] Plaintiff's MOTION for Leave to File Second Amended Complaint filed by AC2T Inc., Jeremy Hirsh. Replies due by 10/15/2021. (Attachments: # (1) Exhibit Exhibit 1)(O'Quinn, Ryan) |
| Oct 8, 2021 | 67 | Exhibit Exhibit 1 (3) |
| Sep 27, 2021 | 66 | Main Document (3) Docket Text: NOTICE by Remember Everyone Deployed Inc. re [65] Plaintiff's MOTION for Leave to File Second Amended ComplaintNOTICE OF FILING SUBSTITUTE EXHIBIT TO MOTION FOR LEAVE (Attachments: # (1) Exhibit Proposed 2d Am Complaint (9-27-2021)) (Bravo, Gustavo) |
| Sep 27, 2021 | 66 | Exhibit Proposed 2d Am Complaint (9-27-2021) (119) |
| Sep 24, 2021 | 65 | Main Document (14) Docket Text: Plaintiff's MOTION for Leave to File Second Amended Complaint by Remember Everyone Deployed Inc.. (Attachments: # (1) Exhibit Proposed 2nd Amended Complaint)(Bravo, Gustavo) |
| Sep 24, 2021 | 65 | Exhibit Proposed 2nd Amended Complaint (119) |
| Sep 14, 2021 | N/A | Set/Reset Deadlines (0) Docket Text: Set/Reset Answer Due Deadline: Remember Everyone Deployed Inc. response due 10/12/2021 Per Order DE#[64]. (drz) |
| Sep 14, 2021 | N/A | Order on Motion to Appear Pro Hac Vice (0) Docket Text: PAPERLESS ORDER granting [59] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney John Nading; granting [60] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Devika Persaud. Mr. Nading and Ms. Persaud are permitted to appear before this Court on behalf of Defendants, AC2T Inc. and Jeremy Hirsh, for all purposes relating to this action. Failure to abide by any Court order may result in immediate revocation of counsel's pro hac vice status. The Clerk is directed to provide Notice of Electronic Filings to Mr. Nading at john.nading@us.dlapiper.com and Ms. Persaud at devika.persaud@us.dlapiper.com. Signed by Magistrate Judge Jared M. Strauss on 9/14/2021. (emd) |
| Sep 14, 2021 | N/A | Status Conference (0) Docket Text: PAPERLESS Minute Entry for proceedings held before Magistrate Judge Jared M. Strauss: Telephonic Status Conference held on 9/14/2021. Attorney Appearance(s): Gustavo Alfonso Bravo, Neil David Kodsi, Ryan D. O'Quinn, John N. Nading, and Devika Persaud (Digital JMS_01_09-14-2021) (at) |
| Sep 14, 2021 | 64 | Order on Motion to Reopen Case (4) Docket Text: ORDER REOPENING CASE AND SETTING TRIAL AND PRETRIAL SCHEDULE granting [57] Motion to Reopen Case. Discovery due by 1/11/2022. Expert Discovery due by 1/11/2022. Dispositive Motions due by 3/14/2022. In Limine Motions due by 4/11/2022. Motions due by 3/14/2022. Pretrial Order due by 4/11/2022. Jury Trial set for 6/6/2022 in Fort Lauderdale Division before Magistrate Judge Jared M. Strauss. Pretrial Conference set for 5/27/2022 01:30 PM in Fort Lauderdale Division before Magistrate Judge Jared M. Strauss. Status Conference set for 5/9/2022 01:30 PM in Fort Lauderdale Division before Magistrate Judge Jared M. Strauss. Signed by Magistrate Judge Jared M. Strauss on 9/14/2021. See attached document for full details. (drz) |
| Sep 13, 2021 | 59 | Main Document (3) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for John M. Nading. Filing Fee $ 200.00 Receipt # AFLSDC-15006211 by AC2T Inc., Jeremy Hirsh. Responses due by 9/27/2021 (Attachments: # (1) Certification, # (2) Text of Proposed Order)(O'Quinn, Ryan) |
| Sep 13, 2021 | 59 | Certification (1) |
| Sep 13, 2021 | 59 | Text of Proposed Order (2) |
| Sep 13, 2021 | 60 | Main Document (3) Docket Text: MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Devika Persaud. Filing Fee $ 200.00 Receipt # AFLSDC-15006313 by AC2T Inc., Jeremy Hirsh. Responses due by 9/27/2021 (Attachments: # (1) Certification, # (2) Text of Proposed Order)(O'Quinn, Ryan) |
| Sep 13, 2021 | 60 | Certification (1) |
| Sep 13, 2021 | 60 | Text of Proposed Order (2) |
| Sep 13, 2021 | 61 | Main Document (50) Docket Text:Defendants' ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand and, COUNTERCLAIM against Remember Everyone Deployed Inc. by Jeremy Hirsh, AC2T Inc.. (Attachments: # (1) Exhibit Exhibit 1, # (2) Exhibit Exhibit 2, # (3) Exhibit Exhibit 3, # (4) Exhibit Exhibit 4, # (5) Exhibit Exhibit 5, # (6) Exhibit Exhibit 6, # (7) Exhibit Exhibit 7, # (8) Exhibit Exhibit 8, # (9) Exhibit Exhibit 9, # (10) Exhibit Exhibit 10, # (11) Exhibit Exhibit 11, # (12) Exhibit Exhibit 12, # (13) Exhibit Exhibit 13, # (14) Exhibit Exhibit 14, # (15) Exhibit Exhibit 15, # (16) Exhibit Exhibit 16, # (17) Exhibit Exhibit 17, # (18) Exhibit Exhibit 18, # (19) Exhibit Exhibit 19, # (20) Exhibit Exhibit 20, # (21) Exhibit Exhibit 21, # (22) Exhibit Exhibit 22, # (23) Exhibit Exhibit 23, # (24) Exhibit Exhibit 24, # (25) Exhibit Exhibit 25, # (26) Exhibit Exhibit 26, # (27) Exhibit Exhibit 27, # (28) Exhibit Exhibit 28, # (29) Exhibit Exhibit 29, # (30) Exhibit Exhibit 30, # (31) Exhibit Exhibit 31)(O'Quinn, Ryan) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 1 (11) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 2 (21) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 3 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 4 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 5 (11) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 6 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 7 (4) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 8 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 9 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 10 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 11 (4) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 12 (4) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 13 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 14 (6) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 15 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 16 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 17 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 18 (3) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 19 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 20 (12) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 21 (4) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 22 (6) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 23 (7) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 24 (6) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 25 (7) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 26 (7) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 27 (7) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 28 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 29 (7) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 30 (5) |
| Sep 13, 2021 | 61 | Exhibit Exhibit 31 (4) |
| Sep 5, 2021 | N/A | Order Setting/Cancelling Hearing (0) Docket Text: PAPERLESS Order Setting Telephonic Status Conference for 9/14/2021 at 9:00 AM before Magistrate Judge Jared M. Strauss. Counsel for the parties shall use the following dial-in information: Dial-in Number (888) 557-8511; Access Code 9883094. Please dial in at least 10 minutes before the status conference begins. The parties shall not use speakerphone. In addition, the parties should avoid using a cell phone if possible. Signed by Magistrate Judge Jared M. Strauss on 9/5/2021. (emd) |
| Sep 3, 2021 | 57 | Motion to Reopen Case (4) Docket Text: Joint MOTION to Reopen Case by Remember Everyone Deployed Inc.. (Kodsi, Neil) |
| Aug 23, 2021 | 55 | Motion for Extension of Time (4) Docket Text: Joint MOTION for Extension of Time file either a Stipulation of Dismissal or a Motion to Reopen the case re [54] Order Dismissing Case,, by Remember Everyone Deployed Inc.. Responses due by 9/7/2021 (Kodsi, Neil) |
| Aug 23, 2021 | N/A | Order on Motion for Extension of Time (0) Docket Text: PAPERLESS ORDER granting [55] Motion for Extension of Time. By 9/3/2021, the parties shall file an appropriate motion, stipulation, or notice to dismiss this case. Alternatively, if the parties are unable to complete their expected settlement, they shall file a motion to reopen by 9/3/2021. Signed by Magistrate Judge Jared M. Strauss on 8/23/2021. (emd) |
| Jul 23, 2021 | 54 | Order Dismissing/Closing Case (1) Docket Text: ORDER ADMINISTRATIVELY CLOSING CASE. The Clerk shall CLOSE this case for administrative purposes only, without prejudice to either party filing a motion to reopen if the parties are unable to complete their expected settlement. On or before August 23, 2021, the parties shall file an appropriate motion, stipulation, or notice to dismiss this case. All deadlines are hereby TERMINATED, and any pending motions are DENIED AS MOOT. Signed by Magistrate Judge Jared M. Strauss on 7/23/2021. See attached document for full details. (osd) |
| Jul 16, 2021 | 52 | Main Document (3) Docket Text: Joint SCHEDULING REPORT - Rule 16.1 by Remember Everyone Deployed Inc. (Attachments: # (1) Text of Proposed Order Proposed Scheduling Order)(Bravo, Gustavo) |
| Jul 16, 2021 | 52 | Text of Proposed Order Proposed Scheduling Order (4) |
| Jul 16, 2021 | 53 | Scheduling Order (4) Docket Text: AMENDED ORDER SETTING TRIAL AND PRETRIAL SCHEDULE: Jury Trial set for 4/4/2022 in Fort Lauderdale Division before Magistrate Judge Jared M. Strauss. Status Conference set for 3/4/2022 01:30 PM in Fort Lauderdale Division before Magistrate Judge Jared M. Strauss. Pretrial Conference set for 3/25/2022 01:30 PM before Magistrate Judge Jared M. Strauss. Discovery due by 11/12/2021. Expert Discovery due by 11/12/2021. In Limine Motions due by 2/11/2022. Dispositive Motions due by 1/14/2022. Motions due by 1/14/2022. Pretrial Stipulation due by 2/11/2022. Signed by Magistrate Judge Jared M. Strauss on 7/16/2021. See attached document for full details. (drz) 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. Modified on 7/19/2021 (drz). |
| Jul 9, 2021 | N/A | Set/Reset Deadlines (0) Docket Text: Set/Reset Answer Due Deadline: AC2T Inc. Answer due 7/23/2021; Jeremy Hirsh Answer due 7/23/2021. (emd) |
| Jul 9, 2021 | 49 | Order Referring Case to Magistrate Judge (1) Docket Text: ORDER REFERRING CASE to Magistrate Judge Jared M. Strauss to conduct all proceedings. Judge Rodolfo A. Ruiz, II no longer assigned as presider/referral judge(s) in case. Signed by Judge Rodolfo A. Ruiz, II on 7/9/2021. See attached document for full details. (gp) |
| Jul 9, 2021 | N/A | Order on Motion to Dismiss for Failure to State a Claim (0) Docket Text: PAPERLESS ORDER denying [41] Motion to Dismiss for the reasons stated in [45] Report and Recommendation. Signed by Magistrate Judge Jared M. Strauss on 7/9/2021. (emd) |
| Jul 9, 2021 | N/A | Order (0) Docket Text: PAPERLESS ORDER. By 7/16/2021, the parties shall file a proposed agreed scheduling order. Signed by Magistrate Judge Jared M. Strauss on 7/9/2021. (emd) |
| Jul 8, 2021 | 48 | Consent to Jurisdiction by US Magistrate Judge (2) Docket Text: Notice and Consent to Jurisdiction US Magistrate Judge signed by all parties . Filed by Remember Everyone Deployed Inc. (Kodsi, Neil) |
| Jul 6, 2021 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [46] Unopposed Motion for Extension of Time to File Response to Report and Recommendation. Defendants shall file any objections to the Report and Recommendation on or before July 15, 2021. Signed by Judge Rodolfo A. Ruiz, II on 7/6/2021. (as03) |
| Jun 30, 2021 | 46 | Motion for Extension of Time to File Response/Reply/Answer (3) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [45] REPORT AND RECOMMENDATIONS re [41] MOTION TO DISMISS [38] Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh by AC2T Inc., Jeremy Hirsh. (O'Quinn, Ryan) |
| Jun 24, 2021 | 45 | Report and Recommendations (18) Docket Text: REPORT AND RECOMMENDATION, recommending that [41] MOTION TO DISMISS be DENIED. Objections to R&R due by 7/8/2021. Signed by Magistrate Judge Jared M. Strauss on 6/24/2021. See attached document for full details. (emd) |
| Jun 15, 2021 | 44 | Reply to Response to Motion (12) Docket Text: REPLY to Response to Motion re [41] MOTION TO DISMISS [38] Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh. (O'Quinn, Ryan) |
| Jun 8, 2021 | 43 | Response in Opposition to Motion (10) Docket Text: RESPONSE in Opposition re [41] MOTION TO DISMISS [38] Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM and Memorandum of Law in Support filed by Remember Everyone Deployed Inc.. Replies due by 6/15/2021. (Bravo, Gustavo) |
| May 28, 2021 | 42 | Order Referring Motion (1) Docket Text: ORDER REFERRING [41] MOTION TO DISMISS [38] Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh. Motions referred to Judge Jared M. Strauss. Signed by Judge Rodolfo A. Ruiz, II on 5/28/2021. See attached document for full details. (as03) |
| May 25, 2021 | 41 | Motion to Dismiss for Failure to State a Claim (14) Docket Text: MOTION TO DISMISS [38] Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM and Memorandum of Law in Support by AC2T Inc., Jeremy Hirsh. Responses due by 6/8/2021 (O'Quinn, Ryan) |
| May 19, 2021 | N/A | Set/Reset Hearings (0) Docket Text: Reset Hearings per [ECF 40] Order. Calendar Call set for 11/16/2021 11:00 AM in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II. Jury Trial set for 11/22/2021 in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II. (gp) |
| May 17, 2021 | 39 | Main Document (7) Docket Text: Joint MOTION to Continue Trial and Extend Pretrial Deadlines re [34] Order on Motion to Amend/Correct,,, by Remember Everyone Deployed Inc.. Responses due by 6/1/2021 (Attachments: # (1) Exhibit A - Declaration of Gustavo A. Bravo, # (2) Exhibit B - Proposed Order)(Kodsi, Neil) |
| May 17, 2021 | 39 | Exhibit A - Declaration of Gustavo A. Bravo (4) |
| May 17, 2021 | 39 | Exhibit B - Proposed Order (3) |
| May 17, 2021 | N/A | Order on Motion to Continue (0) Docket Text: PAPERLESS ORDER granting in part and denying in part [39] Joint Motion to Continue Trial and Extend Pretrial Deadlines. The Court is bewildered that the parties would wait until 8 P.M. on the night before their discovery deadline to inform the Court that they have conducted zero discovery in this case and need months of additional time. After all, this case was removed to this Court back in November 2020 and the Court did not stay discovery pending resolution of the motion to dismiss. Despite the presumptuous nature of the parties' request, given that Plaintiff recently retained new counsel, the Court will grant the Motion in part and extend deadlines as follows: The parties shall exchange expert witness summaries or reports by June 21, 2021; the parties shall exchange rebuttal expert witness summaries or reports by July 6, 2021; all discovery, including expert discovery, shall be completed by July 19, 2021; the parties must complete mediation and file a mediation report by July 26, 2021; the parties shall file all pre-trial motions, including motions for summary judgment, and Daubert motions by August 2, 2021; the parties shall submit a joint pre-trial stipulation, proposed jury instructions and verdict form, or proposed findings of fact and conclusions of law, as applicable, and shall file any motions in limine (other than Daubert motions) by August 30, 2021. The jury trial in this case is continued to the Court's two-week trial calendar beginning on November 22, 2021. Counsel for all parties shall also appear at a calendar call at 11:00 a.m. on November 16, 2021. Of course, if the parties believe the schedule set forth herein is too stringent, they are free to consent to trial and final disposition before the Magistrate Judge. The deadline for submitting a consent is August 2, 2021. Signed by Judge Rodolfo A. Ruiz, II on 5/17/2021. (as03) |
| May 11, 2021 | 38 | Main Document (24) Docket Text: AMENDED COMPLAINT against All Defendants filed in response to Order Granting Motion for Leave, filed by Remember Everyone Deployed Inc.. (Attachments: # (1) Exhibit to Amended Complaint)(Bravo, Gustavo) |
| May 11, 2021 | 38 | Exhibit to Amended Complaint (88) |
| Apr 29, 2021 | 37 | Notice (Other) (2) Docket Text: NOTICE by AC2T Inc., Jeremy Hirsh of Withdrawal of Attorney within Same Firm (Gershoni, Elan) |
| Apr 27, 2021 | 35 | Notice of Attorney Appearance (1) Docket Text: NOTICE of Attorney Appearance by Gustavo Alfonso Bravo on behalf of Remember Everyone Deployed Inc.. Attorney Gustavo Alfonso Bravo added to party Remember Everyone Deployed Inc.(pty:pla). (Bravo, Gustavo) |
| Apr 27, 2021 | 36 | Notice of Attorney Appearance (2) Docket Text: NOTICE of Attorney Appearance by Neil David Kodsi on behalf of Remember Everyone Deployed Inc.. Attorney Neil David Kodsi added to party Remember Everyone Deployed Inc.(pty:pla). (Kodsi, Neil) |
| Apr 21, 2021 | N/A | Set/Reset Deadlines/Hearings (0) Docket Text: Set/Reset Deadlines/Hearings per Order DE#[34]. In Limine Motions due by 6/29/2021. (drz) |
| Apr 20, 2021 | 34 | Order on Motion to Amend/Correct (5) Docket Text: AMENDED ORDER SETTING JURY TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE granting [33] Motion to Modify Scheduling Order and to Extend Defendants Response Deadline to Plaintiffs Complaint. Amended Complaint due by 5/11/2021. Deadline to obtain new counsel 4/27/2021. Discovery due by 5/18/2021. Expert Discovery due by 5/18/2021. Mediation Deadline 5/25/2021. Dispositive Motions due by 6/1/2021. In Limine Motions due by 6/29/2021. Motions due by 6/1/2021. Pretrial Stipulation due by 6/29/2021. Calendar Call set for 9/7/2021 11:00 AM in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II. Jury Trial set for 9/13/2021 in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II. Signed by Judge Rodolfo A. Ruiz, II on 4/20/2021. See attached document for full details. (drz) Modified on 4/21/2021 (drz). |
| Apr 12, 2021 | N/A | Activate Terminated Attorney (0) Docket Text: Attorney Jodi-Ann Rene Tillman representing Remember Everyone Deployed Inc. (Plaintiff) Activated. (Tillman, Jodi-Ann) |
| Apr 12, 2021 | 32 | Notice of Compliance (2) Docket Text: NOTICE of Compliance by Remember Everyone Deployed Inc. re [31] Order on Motion to Withdraw as Attorney, (Tillman, Jodi-Ann) |
| Apr 12, 2021 | 33 | Motion to Amend/Correct (4) Docket Text: Defendant's MOTION to Amend/Correct [16] Scheduling Order and to Extend Defendants' Response Deadline to Plaintiff's Complaint by AC2T Inc., Jeremy Hirsh. Responses due by 4/26/2021 (O'Quinn, Ryan) |
| Apr 9, 2021 | 31 | Order on Motion to Withdraw as Attorney (2) Docket Text: ORDER granting [30] Motion to Withdraw as Attorney. Joseph William Bain representing Remember Everyone Deployed Inc. (Plaintiff); Attorney Joseph Marc Goldstein representing Remember Everyone Deployed Inc. (Plaintiff); Attorney Jodi-Ann Rene Tillman representing Remember Everyone Deployed Inc. (Plaintiff) withdrawn from case. Deadline to obtain new counsel 4/27/2021. Signed by Judge Rodolfo A. Ruiz, II on 4/9/2021. See attached document for full details. (as03) |
| Apr 1, 2021 | 30 | Main Document (3) Docket Text: Unopposed MOTION to Withdraw as Attorney by Joseph M. Goldstein, Joseph W. Bain, and Jodi-Ann Tillman for / by Remember Everyone Deployed Inc.. Responses due by 4/15/2021 (Attachments: # (1) Text of Proposed Order)(Tillman, Jodi-Ann) |
| Apr 1, 2021 | 30 | Text of Proposed Order (2) |
| Mar 29, 2021 | 29 | Order on Motion to Dismiss/Lack of Jurisdiction (2) Docket Text: ORDER granting in part and denying in part [11] Motion to Dismiss for Lack of Jurisdiction; Adopting [28] Report and Recommendations. Signed by Judge Rodolfo A. Ruiz, II on 3/29/2021. See attached document for full details. (as03) |
| Mar 8, 2021 | 28 | Report and Recommendations (26) Docket Text: REPORT AND RECOMMENDATIONS re [27] Order Referring Motion, [11] Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh. Recommending granting in part and denying in part. Objections to R&R due by 3/22/2021. Signed by Magistrate Judge Jared M. Strauss on 3/8/2021. See attached document for full details. (osd) |
| Feb 12, 2021 | 27 | Order Referring Motion (1) Docket Text: ORDER REFERRING [11] Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh. Motions referred to Judge Jared M. Strauss. Signed by Judge Rodolfo A. Ruiz, II on 2/12/2021. See attached document for full details. (as03) |
| Feb 7, 2021 | 26 | ORDER Scheduling Mediation (1) Docket Text: ORDER Scheduling Mediation. Signed by Judge Rodolfo A. Ruiz, II on 2/7/2021. See attached document for full details. (as03) |
| Jan 26, 2021 | 25 | Main Document (2) Docket Text: NOTICE by Remember Everyone Deployed Inc. of Filing Joint Proposed Order Scheduling Mediation (Attachments: # (1) Text of Proposed Order) (Tillman, Jodi-Ann) |
| Jan 26, 2021 | 25 | Text of Proposed Order (1) |
| Jan 22, 2021 | N/A | Order on Motion for Extension of Time to Mediate (0) Docket Text: PAPERLESS ORDER granting [22] Joint Motion for Extension of Time to Submit Mediation Order. The parties shall file their proposed order scheduling mediation on or before January 26, 2021. Signed by Judge Rodolfo A. Ruiz, II on 1/22/2021. (as03) |
| Jan 21, 2021 | N/A | Clerk's Notice of Docket Correction and Instruction to Filer - Attorney (0) Docket Text: Clerks Notice to Filer re [22] Joint MOTION for Extension of Time to Submit Mediation Order re [16] Scheduling Order. Wrong Motion Relief(s) Selected; ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs. (ls) |
| Jan 19, 2021 | 22 | Motion for Extension of Time to Mediate (3) Docket Text: Joint Motion for Extension of Time to Mediate/Submit Mediation Order by Remember Everyone Deployed Inc.. Responses due by 2/2/2021 (Tillman, Jodi-Ann) Modified Relief on 1/21/2021 (ls). |
| Jan 15, 2021 | 21 | Reply to Response to Motion (12) Docket Text: REPLY to Response to Motion re [11] Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support filed by AC2T Inc., Jeremy Hirsh. (O'Quinn, Ryan) |
| Jan 8, 2021 | 20 | Response in Opposition to Motion (12) Docket Text: RESPONSE in Opposition re [11] Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support filed by Remember Everyone Deployed Inc.. Replies due by 1/15/2021. (Tillman, Jodi-Ann) |
| Dec 31, 2020 | 19 | Order (7) Docket Text: DISCOVERY PROCEDURES ORDER re [16] Scheduling Order. Signed by Magistrate Judge Jared M. Strauss on 12/31/2020. See attached document for full details. (osd) |
| Dec 30, 2020 | 16 | Scheduling Order (5) Docket Text: SCHEDULING ORDER. Signed by Judge Rodolfo A. Ruiz, II on 12/30/2020. See attached document for full details. (as03) |
| Dec 29, 2020 | 14 | Main Document (4) Docket Text: Joint SCHEDULING REPORT - Rule 16.1 by Remember Everyone Deployed Inc. (Attachments: # (1) Text of Proposed Order)(Tillman, Jodi-Ann) |
| Dec 29, 2020 | 14 | Text of Proposed Order (5) |
| Dec 29, 2020 | 15 | Certificate of Other Affiliates/Corporate Disclosure Statement (2) Docket Text: Plaintiff's Certificate of Other Affiliates /Interested Parties by Remember Everyone Deployed Inc. (Tillman, Jodi-Ann) |
| Dec 29, 2020 | N/A | Scheduling Order (0) Docket Text: ORDER SETTING JURY TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: Jury Trial set for 9/13/2021 in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II., Calendar Call set for 9/7/2021 11:00 AM in Fort Lauderdale Division before Judge Rodolfo A. Ruiz II., Amended Pleadings due by 2/9/2021., Discovery due by 5/18/2021., Expert Discovery due by 5/18/2021., Fact Discovery due by 5/18/2021., Joinder of Parties due by 2/9/2021., Mediation Deadline 5/25/2021., In Limine Motions due by 6/29/2021., Dispositive Motions due by 6/1/2021., Motions due by 6/1/2021., Pretrial Stipulation due by 6/29/2021. ORDER REFERRING CASE to Magistrate Judge Jared M. Strauss for Discovery Matters. Signed by Judge Rodolfo A. Ruiz, II on 12/29/2020. See attached document for full details. (scn) 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. |
| Dec 29, 2020 | N/A | Clerk's Notice of Docket Correction - Chambers and Clerks (0) Docket Text: Clerks Notice of Docket Correction re [17] Scheduling Order see DE# [16] for image. Deadlines/Hearings not set when DE#16 was docketed. Correction Other. (scn) |
| Dec 24, 2020 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [12] Plaintiff's Unopposed Motion for Extension of Time to Respond to Defendants' Motion to Dismiss Complaint. Plaintiff shall file its response to the Motion to Dismiss on or before January 8, 2021. Signed by Judge Rodolfo A. Ruiz, II on 12/24/2020. (as03) |
| Dec 23, 2020 | 12 | Main Document (3) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [11] Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support by Remember Everyone Deployed Inc.. (Attachments: # (1) Text of Proposed Order)(Tillman, Jodi-Ann) |
| Dec 23, 2020 | 12 | Text of Proposed Order (1) |
| Dec 15, 2020 | 11 | Motion to Dismiss/Lack of Jurisdiction (17) Docket Text: Defendant's MOTION to Dismiss for Lack of Jurisdiction [1] Notice of Removal (State Court Complaint), and Memorandum of Law in Support by AC2T Inc., Jeremy Hirsh. Responses due by 12/29/2020 (O'Quinn, Ryan) |
| Dec 10, 2020 | 10 | Order Requiring Joint Scheduling Report (1) Docket Text: ORDER REQUIRING JOINT SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES; Joint Scheduling Report due by 12/29/2020 Signed by Judge Rodolfo A. Ruiz, II on 12/8/2020. See attached document for full details. (jao) |
| Dec 4, 2020 | 9 | Main Document (6) Docket Text: Defendant's Removal Status Report to [7] Order by AC2T Inc., Jeremy Hirsh. (Attachments: # (1) Exhibit Exhibit A)(Crespo, Janelly) |
| Dec 4, 2020 | 9 | Exhibit Exhibit A (117) |
| Nov 30, 2020 | 8 | Certificate of Other Affiliates/Corporate Disclosure Statement (2) Docket Text: Plaintiff's Corporate Disclosure Statement by Remember Everyone Deployed Inc. (Tillman, Jodi-Ann) |
| Nov 22, 2020 | 7 | Order (2) Docket Text: ORDER REQUIRING REMOVAL STATUS REPORT. Signed by Judge Rodolfo A. Ruiz, II on 11/22/2020. See attached document for full details. (as03) |
| Nov 21, 2020 | N/A | Order on Motion for Extension of Time to File Response/Reply/Answer (0) Docket Text: PAPERLESS ORDER granting [5] Defendants' Unopposed Expedited Motion for Extension of Time to Respond to Complaint. Defendants shall file a single combined response or separate answers to the Complaint on or before December 15, 2020. Signed by Judge Rodolfo A. Ruiz, II on 11/21/2020. (as03) |
| Nov 19, 2020 | 3 | Main Document (1) Docket Text: FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (Attachments: # (1) Supplement Complaint and Exhibits) (jao) |
| Nov 19, 2020 | 3 | Supplement Complaint and Exhibits (239) |
| Nov 19, 2020 | 4 | Certificate of Other Affiliates/Corporate Disclosure Statement (2) Docket Text: Defendant's Corporate Disclosure Statement and Certificate of Interested Persons by AC2T Inc. (O'Quinn, Ryan) |
| Nov 19, 2020 | 5 | Main Document (4) Docket Text: Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [1] Notice of Removal (State Court Complaint), to Complaint by AC2T Inc., Jeremy Hirsh. (Attachments: # (1) Text of Proposed Order Proposed Order)(Crespo, Janelly) |
| Nov 19, 2020 | 5 | Text of Proposed Order Proposed Order (1) |
| Nov 18, 2020 | 1 | Main Document (5) Docket Text: NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint for Damages) Filing fee $ 400.00 receipt number AFLSDC-13889414, filed by Jeremy Hirsh, AC2T Inc. No Answer and/or Motion to Dismiss Filed. (Attachments: # (1) Exhibit Exhibit A, # (2) Exhibit Exhibit B, # (3) Exhibit Exhibit C, # (4) Exhibit Exhibit D, # (5) Civil Cover Sheet Civil Cover Sheet)(Gershoni, Elan) Modified on 11/19/2020 (jao). |
| Nov 18, 2020 | 1 | Exhibit Exhibit A (107) |
| Nov 18, 2020 | 1 | Exhibit Exhibit B (5) |
| Nov 18, 2020 | 1 | Exhibit Exhibit C (4) |
| Nov 18, 2020 | 1 | Exhibit Exhibit D (118) |
| Nov 18, 2020 | 1 | Civil Cover Sheet Civil Cover Sheet (1) |
| Nov 18, 2020 | N/A | Clerk's Notice of Judge Assignment (0) Docket Text: Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss 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. (jao) |
