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 293 |
Filed: 6/5/2023, Entered: None |
Order (PAPERLESS or pdf attached) |
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 Request |
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| 292 |
Filed: 6/2/2023, Entered: None |
Stipulation of Dismissal - ATY |
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Request |
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| 291 |
Filed: 5/31/2023, Entered: None |
Transcript |
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Request |
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 290 |
Filed: 5/4/2023, Entered: None |
Order on Motion for Sanctions |
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| 289 |
Filed: 5/3/2023, Entered: None |
Notice (Other) |
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Request |
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| 287 |
Filed: 5/2/2023, Entered: None |
Notice (Other) |
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Request |
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| 286 |
Filed: 5/1/2023, Entered: None |
Order (PAPERLESS or pdf attached) |
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Request |
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| 285 |
Filed: 4/28/2023, Entered: None |
NOTICE OF SUPPLEMENTAL AUTHORITY |
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Request |
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| 283 |
Filed: 4/25/2023, Entered: None |
Appear |
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Request |
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| 282 |
Filed: 4/6/2023, Entered: None |
Order (PAPERLESS or pdf attached) |
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Request |
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| 280 |
Filed: 4/3/2023, Entered: None |
Response to Motion |
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Request |
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| 279 |
Filed: 4/3/2023, Entered: None |
Miscellaneous Relief |
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Request |
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| 278 |
Filed: 3/31/2023, Entered: None |
Order (PAPERLESS or pdf attached) |
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Request |
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| 276 |
Filed: 3/22/2023, Entered: None |
Motion to Seal (Public) |
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Request |
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| 275 |
Filed: 3/21/2023, Entered: None |
Sanctions |
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Request |
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| 274 |
Filed: 3/20/2023, Entered: None |
Notice (Other) |
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Request |
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| 272 |
Filed: 3/13/2023, Entered: None |
extension of time |
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Request |
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| 270 |
Filed: 2/16/2023, Entered: None |
extension of time |
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Request |
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| 269 |
Filed: 1/30/2023, Entered: None |
Notice of Court Practice/to Appear/Other |
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Request |
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| 267 |
Filed: 1/28/2023, Entered: None |
Notice (Other) |
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Request |
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| 266 |
Filed: 1/27/2023, Entered: None |
Hearing |
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Request |
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| 265 |
Filed: 1/27/2023, Entered: None |
Exhibit List |
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Request |
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| 263 |
Filed: 1/24/2023, Entered: None |
Bring Electronic Equipment |
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Request |
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| 261 |
Filed: 1/24/2023, Entered: 1/24/2023 |
Notice of Compliance |
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NOTICE of Compliance regarding plaintiffs' witness list by Adam M. Ludwin, Esq., Joanna Zeitlin re [258] Calendar Call,,,,,, (Buschel, Robert)
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Request |
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| 260 |
Filed: 1/24/2023, Entered: 1/24/2023 |
Proposed Voir Dire Questions |
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Proposed Voir Dire Questions by Matthew B Proman. (Gelber, Daniel)
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Request |
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| 259 |
Filed: 1/24/2023, Entered: 1/24/2023 |
Motion to Bring Electronic Equipment |
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Unopposed MOTION to Bring Electronic Equipment into the courtroom by Adam M. Ludwin, Esq., Joanna Zeitlin. Responses due by 2/7/2023 (Attachments: # (1) Text of Proposed Order)(Buschel, Robert)
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Request |
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| 258 |
Filed: 1/24/2023, Entered: 1/24/2023 |
Calendar Call |
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PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Calendar Call held on 1/24/2023, 9:20-9:35am, 3 to 4 day trial, plaintiff to provide names of their witnesses to defense counsels only by noon today; proposed jury questions to be filed by noon today, trial set 1/30/23 at 9am. Attorney Appearance(s): Robert Craig Buschel, Adam Michael Ludwin, Daniel S. Gelber, Andrew Thomas Figueroa, Barbara Ratchel Llanes, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov. NOTICE OF POLICY RE ELECTRONIC SUBMISSION OF EXHIBITS. Local Rule 5.3 provides that within ten (10) days of the conclusion of a hearing or trial, a party must file in CM/ECF an electronic version of most exhibits offered or introduced into evidence. Before electronically filing, the filer must redact any sensitive, confidential, or private information in accordance with Fed. R. Civ. P. 5.2, Fed. R. Crim. P. 49.1, and CM/ECF Administrative Procedures, Section 6, or seek an order from the Court either to seal the exhibit or to exempt the exhibit from electronic filing under subsection (b)(3)(C) of the rule. Failure to electronically file exhibits and the Certificate of Compliance Re Admitted Evidence within ten (10) days may result in the imposition of sanctions. The Local Rule, the Certificate of Compliance Re Admitted Evidence, and the Quick Reference Guide to Electronically Filing Trial Exhibits can be found on the Court's website: http://www.flsd.uscourts.gov. (pm)
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| 257 |
Filed: 1/24/2023, Entered: 1/24/2023 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER denying [247] Plaintiffs' Motion for Witnesses to Appear at Trial Via Zoom, for the reasons stated in Defendant's Opposition. SO ORDERED. Signed by Judge Rodney Smith on 1/24/2023. (agy)
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| 256 |
Filed: 1/24/2023, Entered: 1/24/2023 |
Order on motion for summary judgment |
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ORDER granting in part and denying in part [203] Motion for Summary Judgment; denying [205] Motion for Partial Summary Judgment. Signed by Judge Rodney Smith on 1/24/2023. See attached document for full details. (pm)
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| 255 |
Filed: 1/23/2023, Entered: 1/23/2023 |
Exhibit List |
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Exhibit List Plaintiffs' Supplemental by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin.. (Buschel, Robert)
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Request |
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| 254 |
Filed: 1/23/2023, Entered: 1/23/2023 |
proposed jury instructions |
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Proposed Jury Instructions by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Buschel, Robert)
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Request |
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| 253 |
Filed: 1/20/2023, Entered: 1/20/2023 |
order on motion in limine |
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ORDER granting in part and denying in part [236] Motion in Limine. Signed by Judge Rodney Smith on 1/20/2023. See attached document for full details. (agy)
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Request |
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| 252 |
Filed: 1/20/2023, Entered: 1/20/2023 |
order on motion in limine |
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PAPERLESS ORDER denying [215] Defendant's Omnibus Motion in Limine. Specifically, Motions I, II, and III are DENIED; regarding Motions IV and V, the Court will permit evidentiary objections on these grounds to be raised at trial and will DEFER TO TRIAL any further rulings. SO ORDERED. Signed by Judge Rodney Smith on 1/20/2023. (agy)
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| 251 |
Filed: 1/19/2023, Entered: 1/19/2023 |
order on motion to strike |
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ORDER granting in part and denying in part [202] Motion to Strike [202] Defendant's MOTION to Strike Report and Preclude Testimony of Plaintiffs Expert Sameer Somal at Trial and Incorporated Memorandum of Law. Signed by Judge Rodney Smith on 1/19/2023. See attached document for full details. (agy)
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Request |
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| 250 |
Filed: 1/17/2023, Entered: 1/17/2023 |
Reply to Response to motion |
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REPLY to Response to Motion re [247] MOTION for certain witnesses to appear at trial via Zoom filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit USPTO assignment of Title for application, # (2) Exhibit News Release by BidMyListing)(Buschel, Robert)
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Request |
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| 249 |
Filed: 1/10/2023, Entered: 1/10/2023 |
Response to motion |
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RESPONSE to Motion re [247] MOTION for certain witnesses to appear at trial via Zoom filed by Matthew B Proman. Replies due by 1/17/2023. (Attachments: # (1) Exhibit A - Letter from R. Lukes to Adam Ludwin re. declines to testify, # (2) Exhibit B - Third-Party Josh Altman's Response to Amended Subpoena)(Gelber, Daniel)
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Request |
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| 248 |
Filed: 1/9/2023, Entered: 1/9/2023 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [240] Notice (Other), Plaintiffs Amended Proposed Interrogatory Verdict Form (Buschel, Robert)
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Request |
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| 247 |
Filed: 1/9/2023, Entered: 1/9/2023, Terminated: 1/24/2023 |
Motion for Miscellaneous Relief |
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MOTION for certain witnesses to appear at trial via Zoom by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Text of Proposed Order)(Buschel, Robert)
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Request |
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| 246 |
Filed: 1/3/2023, Entered: 1/3/2023 |
Notice re Hearing |
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CORRECTED PAPERLESS NOTICE of Telephonic Calendar Call set for 1/10/2023 09:15 AM in Fort Lauderdale Division before Judge Rodney Smith. Counsel shall call the toll-free number 1-877-873-8018 from a landline phone five (5) minutes prior to the start of the hearing. Then, enter Access Code Number 9406706 followed by the pound (#) sign; to bypass the security code, press the star key (*); enter the conference and state your name and the name of the party you represent Telephonic Calendar Call set for 1/24/2023 09:20 AM in Fort Lauderdale Division before Judge Rodney Smith. (pm)
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| 245 |
Filed: 1/3/2023, Entered: 1/3/2023 |
Notice re Hearing |
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PAPERLESS NOTICE of Telephonic Hearing: **TIME CHANGE ONLY** Telephonic Calendar Call set for 1/10/2023 09:15 AM in Fort Lauderdale Division before Judge Rodney Smith. Counsel shall call the toll-free number 1-877-873-8018 from a landline phone five (5) minutes prior to the start of the hearing. Then, enter Access Code Number 9406706 followed by the pound (#) sign; to bypass the security code, press the star key (*); enter the conference and state your name and the name of the party you represent. (pm)
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| 244 |
Filed: 1/3/2023, Entered: 1/3/2023 |
Scheduling Order |
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FOURTH AMENDED ORDER SETTING CIVIL TRIAL DATE AND PRETRIAL DEADLINES. JURY TRIAL set for 1/30/2023 in Fort Lauderdale Division before Judge Rodney Smith. CALENDAR CALL set for 1/24/2023 at 09:00 AM in Fort Lauderdale Division before Judge Rodney Smith. Signed by Judge Rodney Smith on 1/3/2023. See attached document for full details. (caw) 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.
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Request |
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| 243 |
Filed: 1/3/2023, Entered: 1/3/2023 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [239] Pretrial Stipulation, Plaintiffs' objections to Defendant's proposed Exhibits (Buschel, Robert)
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Request |
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| 242 |
Filed: 1/3/2023, Entered: 1/3/2023 |
Proposed Voir Dire Questions |
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Proposed Voir Dire Questions by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Buschel, Robert)
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Request |
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| 241 |
Filed: 12/28/2022, Entered: 12/28/2022 |
Notice - Other |
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NOTICE by Matthew B Proman of Filing Objections to Plaintiffs Exhibit List (Attachments: # (1) Exhibit A - Defendant's Objections to Plfs Exhibit List.) (Figueroa, Andrew)
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Request |
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| 240 |
Filed: 12/27/2022, Entered: 12/27/2022 |
Notice - Other |
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NOTICE by Matthew B Proman Parties Notice of Filing Proposed Jury Instructions and Proposed Verdict Forms (Attachments: # (1) Exhibit A - Parties Proposed Jury Instructions, # (2) Exhibit B - Plaintiffs Proposed Verdict Form, # (3) Exhibit C - Mr. Promans Proposed Verdict Form) (Figueroa, Andrew)
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Request |
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| 239 |
Filed: 12/27/2022, Entered: 12/27/2022 |
Pretrial Stipulation |
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PRETRIAL STIPULATION Joint by Matthew B Proman (Attachments: # (1) Exhibit A - Plaintiffs Exhibit List, # (2) Exhibit B - Defendant's Exhibit List, # (3) Exhibit C - Plaintiffs Witness List, # (4) Exhibit D - Defendant's Witness List)(Figueroa, Andrew)
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Request |
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| 238 |
Filed: 12/26/2022, Entered: 12/26/2022 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin intent to admit evidence (BidMyListing) (Buschel, Robert)
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Request |
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| 237 |
Filed: 11/14/2022, Entered: 11/14/2022 |
Response to motion |
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RESPONSE to Motion re [236] MOTION in Limine filed by Matthew B Proman. Replies due by 11/21/2022. (Gelber, Daniel)
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Request |
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| 236 |
Filed: 10/28/2022, Entered: 10/28/2022, Terminated: 1/20/2023 |
Motion in Limine |
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MOTION in Limine by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Buschel, Robert)
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Request |
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| 235 |
Filed: 10/26/2022, Entered: 10/26/2022 |
Order |
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THIRD AMENDED ORDER SETTING CIVIL TRIAL DATE AND PRETRIAL DEADLINES: Pretrial Stipulation due by 12/27/2022. Calendar Call set for 1/10/2023 9:00 AM before Judge Rodney Smith. Jury Trial set for 1/17/2023 before Judge Rodney Smith. Signed by Judge Rodney Smith on 10/26/2022. See attached document for full details. (mab)
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Request |
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| 234 |
Filed: 10/25/2022, Entered: 10/25/2022 |
Order on Motion to continue |
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PAPERLESS ORDER granting [229] Motion to Continue. The Trial and Calendar Call shall be continued to a date in January 2023. An Amended Trial Order to follow. SO ORDERED. Signed by Judge Rodney Smith on 10/25/2022. (agy)
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| 233 |
Filed: 10/25/2022, Entered: 10/25/2022 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER granting in part and denying in part [219] Motion. Plaintiff shall file his Motion in Limine that complies with this Court's Order and Local Rules regarding such motions on or before October 28, 2022. SO ORDERED. Signed by Judge Rodney Smith on 10/25/2022. (agy)
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| 232 |
Filed: 10/25/2022, Entered: 10/25/2022 |
order on motion in limine |
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PAPERLESS ORDER striking [216] Motion in Limine. Signed by Judge Rodney Smith on 10/25/2022. (agy)
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| 231 |
Filed: 10/17/2022, Entered: 10/17/2022 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin take judicial notice - Proman declaration (Buschel, Robert)
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Request |
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| 230 |
Filed: 10/17/2022, Entered: 10/17/2022 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin to admit evidence of business records (Buschel, Robert)
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Request |
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| 229 |
Filed: 10/12/2022, Entered: 10/12/2022, Terminated: 10/25/2022 |
Motion to Continue |
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Defendant's MOTION to Continue the Trial re [227] Order on Expedited Motion,, by Matthew B Proman. Responses due by 10/26/2022 (Attachments: # (1) Exhibit A - Defendant Declaration of Good Cause, # (2) Exhibit B - Order Granting Defendant's Opposed Motion to Continue Trial)(Figueroa, Andrew)
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Request |
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| 228 |
Filed: 10/7/2022, Entered: 10/7/2022 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Robert Craig Buschel on behalf of Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Attorney Robert Craig Buschel added to party Adam M. Ludwin, Esq.(pty:pla), Attorney Robert Craig Buschel added to party Ludwin Law Group, P.A.(pty:pla), Attorney Robert Craig Buschel added to party Joanna Zeitlin(pty:pla). (Buschel, Robert)
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Request |
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| 227 |
Filed: 10/7/2022, Entered: 10/7/2022 |
Order on Expedited Motion |
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PAPERLESS ORDER granting [222] Expedited Motion for Continuance. The Motion is granted for the reasons stated in Plaintiff's Motion. The Court shall not grant Plaintiff additional extensions of time to continue trial, short of an exceptional and unforeseen circumstance.This case is set for trial during the Courts two-week trial calendar beginning on December 5, 2022. The Calendar Call will be held at 9:00am on Tuesday, November 29, 2022. Joint pretrial stipulations, depositions designations and counter-designations, proposed joint jury instructions, and proposed joint verdict form, shall be filed by November 7, 2022. SO ORDERED. Signed by Judge Rodney Smith on 10/7/2022. (agy)
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Filed: None, Entered: None |
set/reset deadlines/hearings |
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Reset Hearings per DE [227]: Calendar Call reset for 11/29/2022 at 9:00 AM in Fort Lauderdale Division before Judge Rodney Smith. Trial reset for 12/5/2022 in Fort Lauderdale Division before Judge Rodney Smith. (pes)
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| 226 |
Filed: 10/5/2022, Entered: 10/5/2022 |
Response to motion |
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RESPONSE to Motion re [222] EXPEDITED MOTION for relief from the Court's Amended Scheduling Order [D.E. 197], and to Continue Trial Scheudled for the Two-Week Trial Calendar Beginning on November 7, 2022 and to Extend All Pending Pre-Trial Deadlines and to Extend all Pretr filed by Matthew B Proman. Replies due by 10/12/2022. (Gelber, Daniel)
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Request |
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| 225 |
Filed: 10/4/2022, Entered: 10/4/2022 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Barbara Ratchel Llanes on behalf of Matthew B Proman. Attorney Barbara Ratchel Llanes added to party Matthew B Proman(pty:dft). (Llanes, Barbara)
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Request |
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| 224 |
Filed: 10/3/2022, Entered: 10/3/2022 |
Order |
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PAPERLESS ORDER re [222] EXPEDITED MOTION for relief from the Court's Amended Scheduling Order [D.E. 197]. Defendant is instructed to file by 5:00 P.M. on Wednesday, October 5, 2022, a brief Opposition no more than ten (10) pages in length responding to Plaintiffs' Expedited Motion. Failure to comply may result in granting Plaintiffs' Expedited Motion. SO ORDERED. Signed by Judge Rodney Smith on 10/3/2022. (agy)
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| 223 |
Filed: 10/3/2022, Entered: 10/3/2022 |
Order on motion to amend/correct |
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PAPERLESS ORDER granting [206] Motion to Amend/Correct Statement of Facts in Support of [DE 205] Plaintiff's Mtn. for Partial Summary Judgment. The Court will accept Plaintiff's filing at [DE 206-1] as the Amended Statement of Facts in Support of their Mtn. for Partial Summary Judgment. The filing at [DE 205-1] is Stricken and will not be considered in determining the Motion. No further action required. SO ORDERED.The Court reminds the parties that this case is scheduled for trial on November 7, with calendar call scheduled for November 1. Signed by Judge Rodney Smith on 10/3/2022. (agy)
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| 222 |
Filed: 10/3/2022, Entered: 10/3/2022, Terminated: 10/7/2022 |
Expedited Motion |
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EXPEDITED MOTION for relief from the Court's Amended Scheduling Order [D.E. 197], and to Continue Trial Scheudled for the Two-Week Trial Calendar Beginning on November 7, 2022 and to Extend All Pending Pre-Trial Deadlines and to Extend all Pretrial Deadlines by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Affidavit Affidavit in Support of Motion)(Ludwin, Adam)
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Request |
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| 221 |
Filed: 7/25/2022, Entered: 7/25/2022 |
Response to motion |
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RESPONSE to Motion re [219] MOTION for Relief from the one-page requirement for motions in limine and responses, nunc pro tunc, or in the alternative motion for relief to amend filed by Matthew B Proman. Replies due by 8/1/2022. (Gelber, Daniel)
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Request |
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| 220 |
Filed: 7/21/2022, Entered: 7/21/2022 |
settlement conference |
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PAPERLESS Minute Entry for proceedings held before Magistrate Judge William Matthewman: Settlement Conference via Zoom Video Teleconference held on 7/21/2022. Negotiations held. The Court declared an impasse. Total time in court: 2 hour(s) : 15 minutes. Attorney Appearance(s): Adam Michael Ludwin, Daniel S. Gelber, Andrew Thomas Figueroa. Other appearances: Joanna Zeitlin, Matthew B. Proman. (Digital 10:00:30) (kza)
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| 219 |
Filed: 7/15/2022, Entered: 7/15/2022, Terminated: 10/25/2022 |
Motion for Miscellaneous Relief |
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MOTION for Relief from the one-page requirement for motions in limine and responses, nunc pro tunc, or in the alternative motion for relief to amend by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 218 |
Filed: 7/8/2022, Entered: 7/8/2022 |
response in opposition to motion |
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RESPONSE in Opposition re [215] Defendant's MOTION in Limine (Omnibus) filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 7/15/2022. (Ludwin, Adam)
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Request |
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| 217 |
Filed: 7/8/2022, Entered: 7/8/2022 |
Response to motion |
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RESPONSE to Motion re [216] MOTION in Limine filed by Matthew B Proman. Replies due by 7/15/2022. (Attachments: # (1) Exhibit A - July 28, 2018 Email, # (2) Exhibit B - Depositions Transcript of Adam Ludwin, # (3) Exhibit C - Plaintiffs' Witness Disclosure)(Gelber, Daniel)
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Request |
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| 216 |
Filed: 6/25/2022, Entered: 6/25/2022, Terminated: 10/25/2022 |
Motion in Limine |
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STRICKEN - MOTION in Limine by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit, # (4) Exhibit, # (5) Exhibit, # (6) Exhibit, # (7) Exhibit, # (8) Exhibit, # (9) Exhibit, # (10) Exhibit, # (11) Exhibit, # (12) Exhibit)(Ludwin, Adam) Modified/Stricken per DE [232] on 10/26/2022 (pes).
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Request |
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| 215 |
Filed: 6/24/2022, Entered: 6/24/2022, Terminated: 1/20/2023 |
Motion in Limine |
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Defendant's MOTION in Limine (Omnibus) by Matthew B Proman. (Gelber, Daniel)
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Request |
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| 214 |
Filed: 6/17/2022, Entered: 6/17/2022 |
Reply to Response to motion |
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RESPONSE to Motion re [203] MOTION for Summary Judgment filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam) Modified document link on 6/21/2022 (kpe).
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Request |
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| 213 |
Filed: 6/16/2022, Entered: 6/16/2022 |
Reply to Response to motion |
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REPLY to Response to Motion re [203] Defendant's MOTION for Summary Judgment and Incorporated Memorandum of Law filed by Matthew B Proman. (Gelber, Daniel)
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Request |
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| 212 |
Filed: 6/15/2022, Entered: 6/15/2022 |
Reply to Response to motion |
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REPLY to Response to Motion re [202] Defendant's MOTION to Strike Report and Preclude Testimony of Plaintiffs Expert Sameer Somal at Trial and Incorporated Memorandum of Law filed by Matthew B Proman. (Gelber, Daniel)
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Request |
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| 211 |
Filed: 6/10/2022, Entered: 6/10/2022 |
Response/Reply (Other) |
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RESPONSE to [205] MOTION for Partial Summary Judgment to Plaintiffs [Sic] Statement Of Undisputed Motion Material Facts In Support Of Summary Judgment by Matthew B Proman. (Gelber, Daniel)
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Request |
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| 210 |
Filed: 6/10/2022, Entered: 6/10/2022 |
Response to motion |
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RESPONSE to Motion re [205] MOTION for Partial Summary Judgment filed by Matthew B Proman. Replies due by 6/17/2022. (Gelber, Daniel)
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Request |
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| 209 |
Filed: 6/10/2022, Entered: 6/10/2022 |
response in opposition to motion |
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RESPONSE in Opposition re [204] Statement of Undisputed Facts filed by Joanna Zeitlin. Replies due by 6/17/2022. (Ludwin, Adam) Modified document link on 6/10/2022 (kpe).
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Request |
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| 208 |
Filed: 6/9/2022, Entered: 6/10/2022 |
response in opposition to motion |
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RESPONSE in Opposition re [203] Defendant's MOTION for Summary Judgment and Incorporated Memorandum of Law filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 6/16/2022. (Ludwin, Adam)
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Request |
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| 207 |
Filed: 6/8/2022, Entered: 6/8/2022 |
Response to motion |
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RESPONSE to Motion re [202] Defendant's MOTION to Strike Report and Preclude Testimony of Plaintiffs Expert Sameer Somal at Trial and Incorporated Memorandum of Law filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 6/15/2022. (Ludwin, Adam)
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Request |
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| 206 |
Filed: 6/5/2022, Entered: 6/5/2022, Terminated: 10/3/2022 |
Motion to Amend/Correct |
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Unopposed MOTION to Amend/Correct [205] MOTION for Partial Summary Judgment by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 6/21/2022 (Attachments: # (1) Exhibit A - Amended Statement of Facts)(Ludwin, Adam)
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Request |
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| 205 |
Filed: 5/27/2022, Entered: 5/27/2022, Terminated: 1/24/2023 |
Motion for partial summary judgment |
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MOTION for Partial Summary Judgment by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 6/10/2022 (Attachments: # (1) STRICKEN - Supplement Statement of Undisputed Facts, # (2) Exhibit A, # (3) Exhibit B, # (4) Exhibit C, # (5) Exhibit D, # (6) Exhibit E, # (7) Exhibit F, # (8) Exhibit G)(Ludwin, Adam) Modified to strike 205-1 per DE [223] on 10/4/2022 (pes).
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Request |
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| 204 |
Filed: 5/26/2022, Entered: 5/26/2022 |
statement |
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Statement of: Undisputed Facts in Support of Motion for Summary Judgment and Incorporated Memorandum of Law by Matthew B Proman re [203] Defendant's MOTION for Summary Judgment and Incorporated Memorandum of Law (Attachments: # (1) Exhibit A - Joanna Zeitlin's Responses to Defendant's First Interrogatories, # (2) Exhibit B - Joanna Zeitlin Amended Responses to Defendant's First Interrogatories, # (3) Exhibit C - Ludwin Law Responses to Defendant's First Interrogatories, # (4) Exhibit D - Ludwin Law Amended Responses to Defendant's First Interrogatories, # (5) Exhibit E - Plaintiffs Responses to Defendant's Amended Requests for Production)(Gelber, Daniel)
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Request |
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| 203 |
Filed: 5/26/2022, Entered: 5/26/2022, Terminated: 1/24/2023 |
Motion for Summary Judgment |
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Defendant's MOTION for Summary Judgment and Incorporated Memorandum of Law by Matthew B Proman. Responses due by 6/9/2022 (Gelber, Daniel)
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Request |
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| 202 |
Filed: 5/25/2022, Entered: 5/25/2022, Terminated: 1/19/2023 |
Motion to Strike |
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Defendant's MOTION to Strike Report and Preclude Testimony of Plaintiffs Expert Sameer Somal at Trial and Incorporated Memorandum of Law by Matthew B Proman. Responses due by 6/8/2022 (Attachments: # (1) Exhibit 1 - Plaintiffs Expert Witness Report, # (2) Appendix A to Plaintiffs Expert Witness Report, # (3) Appendix B to Plaintiffs Expert Witness Report, # (4) Appendix C to Plaintiffs Expert Witness Report, # (5) Appendix D to Plaintiffs Expert Witness Report, # (6) Appendix E to Plaintiffs Expert Witness Report, # (7) Appendix F to Plaintiffs Expert Witness Report, # (8) Appendix G to Plaintiffs Expert Witness Report)(Gelber, Daniel)
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Request |
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| 201 |
Filed: 5/3/2022, Entered: 5/3/2022 |
Status Conference |
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PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Status Conference held on 5/3/2022. Attorney Appearance(s): Adam Michael Ludwin, Daniel S. Gelber, Andrew Thomas Figueroa, Gerald Edward Greenberg, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov. (pm)
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| 200 |
Filed: 5/2/2022, Entered: 5/2/2022 |
Order |
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ORDER SCHEDULING SETTLEMENT CONFERENCE VIA ZOOM VTC. Zoom Settlement Conference set for 7/21/2022 at 10:00 AM before Magistrate Judge William Matthewman. Signed by Magistrate Judge William Matthewman on 5/2/2022. See attached document for full details. (ail)
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Request |
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| 199 |
Filed: 4/27/2022, Entered: 4/27/2022 |
Order Referring Case to Magistrate Judge |
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ORDER REFERRING CASE to Magistrate Judge William Matthewman for Settlement Conference. Signed by Judge Rodney Smith on 4/27/2022. See attached document for full details. (ls)
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Request |
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| 198 |
Filed: 4/27/2022, Entered: 4/27/2022 |
Order on Motion for Extension of Time of Discovery Cutoff Deadline |
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PAPERLESS ORDER DENYING [185] Plaintiffs' Motion for an Extension of Time to Make Expert Witness Disclosures Based on Defendant's Failure to Comply with Court Order [DE 184; Plaintiffs' Discoveries that Defendant is being Untruthful and Improperly Withholding Discovery as Stated in the Court's Order [DE 184]; and for Sanctions. Signed by Judge Rodney Smith on 4/27/2022. (zgs)
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| 197 |
Filed: 4/21/2022, Entered: 4/22/2022 |
Scheduling Order |
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FINAL ORDER SETTING CIVIL TRIAL DATE, PRETRIAL DEADLINES, AND REFERRAL TO MAGISTRATE JUDGE: ( Jury Trial set for 11/7/2022 before Judge Rodney Smith., Calendar Call set for 11/1/2022 09:00 AM before Judge Rodney Smith., Expert Discovery due by 5/13/2022., Fact Discovery due by 5/13/2022., In Limine Motions due by 6/24/2022., Dispositive Motions due by 5/27/2022., Motions due by 6/24/2022., Pretrial Stipulation due by 10/7/2022.) Signed by Judge Rodney Smith on 4/21/2022. See attached document for full details. (pcs) 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.
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Request |
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| 196 |
Filed: 4/20/2022, Entered: 4/20/2022 |
Clerk's Notice of Docket Correction - Chambers and Clerks |
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Clerks Notice of Docket Correction re [195] ORDER DENYING IN PART AND DEFERRING IN PART PLAINTIFFS' OMNIBUS MOTION [DE 185] - corrected by attaching document. (kza)
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Request |
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| 195 |
Filed: 4/20/2022, Entered: 4/20/2022 |
Order |
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ORDER DENYING IN PART AND DEFERRING IN PART PLAINTIFFS' OMNIBUS MOTION [DE 185]: 1. Plaintiffs' Motion for Order to Show Cause [DE 185] is DENIED. 2. Plaintiffs' Motion to Compel Better Discovery Responses [DE 185] is DENIED. 3. The Court respectfully DEFERS to the Honorable United States District Judge Rodney Smith for a RULING on Plaintiffs Motion for Extension of Time to File Expert Witness Disclosures [DE 185]. 4. The Court declines to sanction either party at this time, whether pursuant to its inherent authority or under the authority of Federal Rule of Civil Procedure 37. Signed by Magistrate Judge William Matthewman on 4/20/2022. See attached document for full details. (kza)
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| 194 |
Filed: 4/19/2022, Entered: 4/19/2022 |
Notice of Supplemental Authority |
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Notice of Supplemental Authority , the Transcript of the January 20, 2022 Deposition of Defendant, Matthew Proman by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Attachments: # (1) Exhibit A - Deposition Transcript) (Ludwin, Adam)
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Request |
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| 193 |
Filed: 4/19/2022, Entered: 4/19/2022 |
Status Conference |
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PAPERLESS Minute Entry for proceedings held before Magistrate Judge William Matthewman: Status Conference Re: Discovery Matters held on 4/19/2022. The Court discussed all outstanding discovery matters with counsel. Argument held. The Court took the matter under advisement. Written order to be issued. Total time in court: 34 minutes. Attorney Appearance(s): Adam Michael Ludwin, Daniel S. Gelber, Andrew Thomas Figueroa, Gerald Edward Greenberg, (recorded on Zoom VTC) (kza)
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| 192 |
Filed: 4/19/2022, Entered: 4/19/2022 |
Notice re Hearing |
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PAPERLESS NOTICE of Hearing: **TIME CHANGE ONLY** Status Conference set for 4/21/2022 12:00 PM in Fort Lauderdale Division before Judge Rodney Smith. (pm)
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| 191 |
Filed: 4/14/2022, Entered: 4/14/2022 |
Notice of Compliance |
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NOTICE of Compliance (Joint) by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [184] Order on Motion for Clarification,,, Order on Motion for Miscellaneous Relief,, (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit, # (4) Exhibit) (Ludwin, Adam)
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Request |
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| 190 |
Filed: 4/13/2022, Entered: 4/13/2022 |
Notice - Other |
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NOTICE re re Zoom Info for Status Conference Re: Discovery Matters on 4/19/2022 at 01:30 PM in West Palm Beach Division before Magistrate Judge William Matthewman - To log in through ZoomGov Meeting, use Meeting ID: 160 540 3826 and Passcode: 246129. (kza)
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| 189 |
Filed: 4/11/2022, Entered: 4/11/2022 |
Order on Motion for Leave to Appear |
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PAPERLESS ORDER DENYING [188] Defendant's Motion to Appear by telephone or Video Conference for the Court's April 21, 2022 Status Conference. Signed by Judge Rodney Smith on 4/11/2022. (zgs)
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| 188 |
Filed: 4/8/2022, Entered: 4/8/2022, Terminated: 4/11/2022 |
Motion for Leave to Appear |
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Defendant's MOTION for Leave to Appear by Telephone or Video Conference for the Court's April 21, 2022 at 11:00 a.m. Status Conference . Attorney/Representative: Daniel S. Gelber by Matthew B Proman. Responses due by 4/22/2022 (Attachments: # (1) Exhibit 1 - Order on Motion to Appear by Telephonic or Video Conference)(Gelber, Daniel)
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Request |
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| 187 |
Filed: 4/6/2022, Entered: 4/6/2022 |
Order Setting Status Conference |
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PAPERLESS ORDER Setting Status Conference: A status conference has been set for April 21, 2022 at 11:00 a.m. The parties and their respective counsel shall appear in person. Failure to appear may result in the imposition of sanctions, which may include dismissal of the action or a default judgment. Signed by Judge Rodney Smith on 4/6/2022. (zgs)
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| 186 |
Filed: 4/4/2022, Entered: 4/4/2022 |
Response to motion |
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RESPONSE to Motion re [185] MOTION for Extension of Time of Discovery Cutoff Deadline MOTION for Order to Show Cause MOTION to Compel Better Discovery Responses MOTION for Sanctions filed by Matthew B Proman. Replies due by 4/11/2022. (Attachments: # (1) Exhibit 1 - Email)(Gelber, Daniel)
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Request |
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| Save 25% on a pre-paid one year subscription. |
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| 185 |
Filed: 4/1/2022, Entered: 4/1/2022, Terminated: 4/27/2022 |
Motion for Extension of Time of Discovery Cutoff Deadline |
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MOTION for Extension of Time of Discovery Cutoff Deadline , MOTION for Order to Show Cause , MOTION to Compel Better Discovery Responses ( Responses due by 4/15/2022), MOTION for Sanctions by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit)(Ludwin, Adam)
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Request |
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| 184 |
Filed: 3/22/2022, Entered: 3/22/2022 |
Order on motion for clarification |
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OMNIBUS ORDER denying as moot [170] Motion for Clarification; denying as moot [171] Motion Motion to Re-Notice. After careful consideration of the subpoena, Defendants request to quash the subpoena is hereby GRANTED IN PART and DENIED IN PART. This Court QUASHES the oral deposition component of the subpoena but will ALLOW and REQUIRE the production of the requested documents. Based on this determination, Defendants alternative request for a protective order is DENIED. Signed by Magistrate Judge William Matthewman on 3/21/2022. See attached document for full details. (drz)
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Request |
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| |
Filed: None, Entered: None |
set/reset deadlines/hearings |
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Set Hearings Per Order DE#[184]. Status Conference Re: Discovery Matters via Zoom video teleconference set for 4/19/2022 at 01:30 PM in West Palm Beach Division before Magistrate Judge William Matthewman. (drz)
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| 183 |
Filed: 3/17/2022, Entered: 3/17/2022 |
Status Conference |
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PAPERLESS Minute Entry for proceedings held before Magistrate Judge William Matthewman: Status Conference Re Discovery held via Zoom Video Teleconference on 3/17/2022. Counsel informed the Court that Motions [DEs 168, 170 and 171] can be denied as moot. Discussion held on pending discovery matters. Rulings were entered on the record. The court directed the parties to confer further. The Court took the issue of the Subpoena regarding Bid My Listing under advisement. Written order to be issued. Total time in court: 56 minutes. Attorney Appearance(s): Adam Michael Ludwin, Daniel S. Gelber, Andrew Thomas Figueroa, Gerald Edward Greenberg. (Digital 13:32:36) (kza)
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| 182 |
Filed: 3/17/2022, Entered: 3/17/2022 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin OF FILING SUPPLEMENTAL HEARING DOCUMENT (Attachments: # (1) Exhibit Hearing Transcript) (Ludwin, Adam)
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Request |
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| 181 |
Filed: 3/14/2022, Entered: 3/14/2022 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [177] Order Setting Status Conference,,,,,,, (JOINTLY FILED) (Attachments: # (1) Exhibit Plaintiffs supplemental discovery, # (2) Exhibit Matthew Proman email confirming obligation to serve discovery documentation by March 4, 2022, # (3) Exhibit Matthew Promans March 4 Responses and Objections, # (4) Exhibit Matthew Proman Amended Discovery Responses, # (5) Exhibit Third-party subpoena, # (6) Exhibit Email from Los Angeles Assistant District Attorney, Ryan Tracy, regarding order entered by Criminal Court Judge Requiring Defendant, Matthew Proman, to pay restitution to Adam Ludwin) (Ludwin, Adam)
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Request |
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| 180 |
Filed: 3/11/2022, Entered: 3/11/2022 |
Notice of withdrawal of motion |
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NOTICE OF WITHDRAWAL OF MOTION by Matthew B Proman re [168] MOTION to Compel better responses to his first Request for Production filed by Matthew B Proman (Figueroa, Andrew)
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Request |
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| 179 |
Filed: 3/8/2022, Entered: 3/8/2022 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Gerald Edward Greenberg on behalf of Matthew B Proman. Attorney Gerald Edward Greenberg added to party Matthew B Proman(pty:dft). (Greenberg, Gerald)
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Request |
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| 178 |
Filed: 3/7/2022, Entered: 3/7/2022 |
Response to order to show cause |
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RESPONSE TO ORDER TO SHOW CAUSE re [172] Order to Show Cause by Joanna Zeitlin, Adam M. Ludwin, Esq., Ludwin Law Group, P.A.. (Attachments: # (1) Exhibit - Mediation Report)(Ludwin, Adam)
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Request |
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| 177 |
Filed: 3/7/2022, Entered: 3/7/2022 |
Order Setting Status Conference |
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PAPERLESS ORDER Setting Status Conference: This matter is before the Court sua sponte. In light of the incessant, silly and unprofessional discovery bickering that has been ongoing by the parties since the filing of this case, and noting the recent appearance of counsel for Defendant Proman, who had been appearing pro se after withdrawal of his prior counsel, the Court hereby sets a status conference re: discovery for March 17, 2022 at 1:30 pm, via Zoom video tele-conference (VTC). Prior to the status conference hearing, the Court hereby ORDERS counsel for the Plaintiffs and counsel for the Defendant to meet and confer in good faith by telephone or videoconference (not solely by email) for as long as necessary to attempt to resolve or limit all outstanding discovery motions and disputes in this case. On or before March 14, 2022, the parties shall file a Joint Notice briefly and concisely addressing each pending discovery motion and/or dispute, and briefly and concisely stating the parties' respective positions on each pending discovery motion and/or dispute. The Court shall rule on all discovery motions and disputes at the upcoming status conference hearing. Taking frivolous or dilatory discovery positions, failing to personally confer in good faith, failing to comply with this Order, or failing to comply with all discovery rules and orders, SHALL result in sanctions on the offending party and/or counsel. The Court advises the parties and counsel that all discovery shall be completed on or before May 13, 2022 [DE 174] and delays or dilatory conduct shall not be permitted. Further, strict compliance with the Courts Order Setting Discovery Procedure [DE 58] is mandated. All pending discovery motions shall be promptly and timely responded to by the parties. The Undersigned Magistrate Judges Courtroom Deputy will provide the Zoom VTC login information prior to the hearing. Signed by Magistrate Judge William Matthewman on 3/7/2022. (cpe)
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| 176 |
Filed: 3/4/2022, Entered: 3/4/2022 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Andrew Thomas Figueroa on behalf of Matthew B Proman. Attorney Andrew Thomas Figueroa added to party Matthew B Proman(pty:dft). (Figueroa, Andrew)
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Request |
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| 175 |
Filed: 3/4/2022, Entered: 3/4/2022 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Daniel S. Gelber on behalf of Matthew B Proman. Attorney Daniel S. Gelber added to party Matthew B Proman(pty:dft). (Gelber, Daniel)
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Request |
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| 174 |
Filed: 3/4/2022, Entered: 3/4/2022 |
Scheduling Order |
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SECOND AMENDED ORDER SETTING CIVIL TRIAL DATE,PRETRIAL DEADLINES, AND REFERRAL TO MAGISTRATE JUDGE: ( Jury Trial set for 11/7/2022 before Judge Rodney Smith., Calendar Call set for 11/1/2022 09:00 AM before Judge Rodney Smith., Expert Discovery due by 5/13/2022., Fact Discovery due by 5/13/2022., In Limine Motions due by 6/24/2022., Dispositive Motions due by 5/27/2022., Motions due by 6/24/2022., Pretrial Stipulation due by 10/7/2022.). Signed by Judge Rodney Smith on 3/4/2022. 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.
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Request |
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| 173 |
Filed: 3/4/2022, Entered: 3/4/2022 |
Order on motion to amend/correct |
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PAPERLESS ORDER GRANTING IN PART [169] Defendant Matthew Proman's Motion for an Order Extending All deadlines Contained in the Court's Amended Order Setting Civil Trial Date, Pretrial Deadlines, and Referral to Magistrate Judge. Absent extraordinary circumstances, no further extensions will be granted. The Court will enter a Second Amended Trial Order reflecting the approved changes. Signed by Judge Rodney Smith on 3/4/2022. (zgs)
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| 172 |
Filed: 3/3/2022, Entered: 3/3/2022 |
Order to Show Cause |
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ORDER TO SHOW CAUSE re [48] ORDER Scheduling Mediation. Show Cause Response due by 3/7/2022. Signed by Judge Rodney Smith on 3/3/2022. See attached document for full details. (drz)
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| 171 |
Filed: 3/1/2022, Entered: 3/1/2022, Terminated: 3/22/2022 |
Motion for Miscellaneous Relief |
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MOTION For an Order Requiring Plaintiffs to Re-Notice David Babcock's Deposition at Plaintiff's Cost and Expense by Matthew B Proman. (drz)
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Request |
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| 170 |
Filed: 2/25/2022, Entered: 2/25/2022, Terminated: 3/22/2022 |
Motion for Clarification |
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MOTION for clarification by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 3/11/2022 (Ludwin, Adam)
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Request |
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| 169 |
Filed: 2/25/2022, Entered: 2/25/2022, Terminated: 3/4/2022 |
Motion to Amend/Correct |
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MOTION FOR AN ORDER EXTENDING ALL DEADLINES CONTAINED IN THE COURT'S AMENDED ORDER SETTING CIVIL TRIAL DATE, PRETRIAL DEADLINES, AND AND REFERRAL TO MAGISTRATE JUDGE [99] Scheduling Order, Order Referring Case to Magistrate Judge by Matthew B Proman. Responses due by 3/11/2022 (drz)
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Request |
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| 168 |
Filed: 2/25/2022, Entered: 2/25/2022, Terminated: 3/11/2022 |
Motion to Compel |
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MOTION to Compel better responses to his first Request for Production by Matthew B Proman. Responses due by 3/11/2022 (Attachments: # (1) Exhibit)(drz)
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Request |
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| 167 |
Filed: 2/24/2022, Entered: 2/24/2022 |
Notice - Other |
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NOTICE OF FILING SUBPOENA by Matthew B Proman. (Attachments: # (1) Exhibit) (drz)
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Request |
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| 166 |
Filed: 2/18/2022, Entered: 2/18/2022 |
order on motion for miscellaneous relief |
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ORDER GRANTING PLAINTIFFS MOTION FOR AN ORDER PERMITTING THE LOS ANGELES COUNTY DISTRICT ATTORNEY, BUREAU OF INVESTIGATION, TO PRODUCE DOCUMENTATION [DE 157]. Signed by Magistrate Judge William Matthewman on 2/18/2022. See attached document for full details. (spe)
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Request |
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| 165 |
Filed: 2/18/2022, Entered: 2/18/2022 |
Order |
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PAPERLESS ORDER granting in part and denying in part [134] Plaintiffs' Omnibus Motion. Based upon Plaintiffs' styling its Motion as an emergency, the Court entered an Interim Order [135], which, inter alia, admonished Plaintiffs' counsel for improperly labeling its Motion as an emergency. Now that the Motion has been fully briefed, the Court turns to the substance of the Motion. Based upon Defendant Proman's failure to fully comply in discovery, Plaintiffs' request contempt, the striking of pleadings, judicial default, and for other sanctions. Because the Motion only addresses Defendant Proman's conduct in discovery as it pertains to fully providing documents to Plaintiffs in advance of Defendant Proman's deposition, the Court denies without prejudice Plaintiffs' request for contempt, the striking of pleadings, and judicial default, as the Motion is wholly insufficient to warrant such relief. Plaintiffs may renew its request for such sanctions upon the filing of a proper and fulsome motion, setting forth the basis for such relief with attached supporting documentation. As such, the Court will treat the Motion as a motion to compel and for sanctions. Defendant Proman's response in opposition [160] takes the position that either he provided responsive documents, there are no responsive documents, or that he did not want to provide documents that potentially reveal his location and places that he frequents. As addressed in a prior Order [164], Defendant Proman has not established any legal basis to redact such information. However, for clarity of record and to assist Defendant Proman in fully complying with his discovery obligations, by or before February 24, 2022, Plaintiffs shall serve amended discovery requests to Defendant Proman, which are specific, tailored to what discovery is outstanding, and which lists the responsive documents already in Plaintiffs' possession, if any. Defendant Proman shall provide responses and responsive documents by or before March 4, 2022. Signed by Magistrate Judge William Matthewman on 2/18/2022. (jb02)
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| 164 |
Filed: 2/18/2022, Entered: 2/18/2022 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER granting in part and denying in part [151] Defendant Proman's Omnibus Motion. Defendant Proman's Request No. 1, for permission to communicate with Plaintiffs' counsel only in writing, is GRANTED. The Court is fully familiar with this case and the history between Defendant Proman and Plaintiffs' counsel and finds that written communication is the best way to ensure that both sides behave appropriately in this case. This ruling applies to communications only and does not impede upon either side's ability to take depositions and try this matter before a jury. Moreover, if the parties are in agreement to communicate by recorded conversation, they may do so. However, the Court warns that Florida is a "two-party consent" state and recording a conversation without every person's consent is a crime in Florida and may also subject the violator to civil penalties. Defendant Proman's Request No. 2, to redact personal info from bank account statements, is DENIED, as the request is clearly untimely, belated, and without merit. All bank account statements shall be produced by Defendant Proman to Plaintiffs by or before March 4, 2022. Defendant Proman's Request No. 3, for a protective order against Plaintiffs' counsel Adam Ludwin, is DENIED, as Defendant Proman has failed to establish any legal basis for a protective order from Plaintiffs' counsel. The parties are ORDERED to stop all the discovery nonsense going on in this case forthwith, or suffer sanctions for any frivolous, dilatory, or unreasonable discovery conduct. Signed by Magistrate Judge William Matthewman on 2/18/2022. (jb02)
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| 163 |
Filed: 2/17/2022, Entered: 2/17/2022 |
Reply to Response to motion |
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REPLY to Response to Motion re [157] MOTION PERMITTING THE LOS ANGELES COUNTY DISTRICT ATTORNEY, BUREAU OF INVESTIGATION, TO PRODUCE DOCUMENTATION filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 162 |
Filed: 2/16/2022, Entered: 2/16/2022 |
Response to motion |
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RESPONSE to Motion re [157] MOTION PERMITTING THE LOS ANGELES COUNTY DISTRICT ATTORNEY, BUREAU OF INVESTIGATION, TO PRODUCE DOCUMENTATION filed by Matthew B Proman. Replies due by 2/23/2022. (pcs)
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Request |
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| 161 |
Filed: 2/11/2022, Entered: 2/11/2022 |
Reply to Response to motion |
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REPLY to Response to Motion re [134] EMERGENCY MOTION with Certification of Emergency included filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit)(Ludwin, Adam)
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Request |
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| 160 |
Filed: 2/9/2022, Entered: 2/9/2022 |
Response to motion |
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RESPONSE to Motion re [134] PLAINTIFFS EMERGENCY MOTION FOR CONTEMPT; MOTION TO STRIKE DEFENDANTS PLEADINGS; MOTION FOR JUDICIAL DEFAULT; MOTION FOR SANCTIONS AS A RESULT OF DEFENDANTS CONTEMPTUOUS AND WILFULL DISREGARD FOR ORDERS ENTERED BY THIS COURT; SECOND RENEWED MOTION TO COMPEL BETTER RESPONSES TO PLAINTIFFS FIRST REQUESTS FOR PRODUCTION AND PLAINTIFFS SECOND REQUESTS FOR PRODUCTION; AND MOTION FOR RELIEF FROM THE SCHEDULING ORDER filed by Matthew B Proman. Replies due by 2/16/2022. (drz)
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Request |
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| 159 |
Filed: 2/7/2022, Entered: 2/8/2022 |
response in opposition to motion |
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RESPONSE in Opposition re [151] MOTION MOTION For Permisssion to Communicate with Plaintiff/Plaintiff's counsel in Writing Only and Redact Personal Information From Bank Statements and MOTION for Protective Order Against Adam Ludwin MOTION for Protective Order filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 2/14/2022. (Attachments: # (1) Exhibit)(Ludwin, Adam)
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Request |
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| 158 |
Filed: 2/7/2022, Entered: 2/7/2022 |
Order |
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PAPERLESS ORDER: The Court has reviewed Plaintiffs' Motion for an Order Permitting the Los Angeles County District Attorney, Bureau Of Investigation, To Produce Documentation [157]. Defendant shall respond on or before February 16, 2022 and Plaintiffs may reply by February 17, 2022. The Court will thereafter issue a written ruling or set the Motion for a hearing, if deemed necessary. Signed by Magistrate Judge William Matthewman on 2/7/2022. (jb02)
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| 157 |
Filed: 2/6/2022, Entered: 2/6/2022, Terminated: 2/18/2022 |
Motion for Miscellaneous Relief |
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MOTION PERMITTING THE LOS ANGELES COUNTY DISTRICT ATTORNEY, BUREAU OF INVESTIGATION, TO PRODUCE DOCUMENTATION by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 156 |
Filed: 2/2/2022, Entered: 2/2/2022 |
Response/Reply (Other) |
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RESPONSE to [141] Status Report Regarding Defendant's Failure to Respond to Plaintiff's Emergency Motion For Contempt, Motion to Strike Defendant's Pleadings, Motion For Judicial Default, and Motion For Sanctions as a Result of Defendant's Contemptuous and Wilful Disregard for Orders Entered by This Court and Motion for Relief from Scheduling Order by Matthew B Proman. (drz)
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Request |
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| 155 |
Filed: 2/2/2022, Entered: 2/2/2022 |
Notice of Change of Address, Email or Law Firm Name |
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NOTICE of Updated Physical Mailing Address, Email and Phone Number by Matthew B Proman (Address Updated in CM/ECF) (drz)
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Request |
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| 154 |
Filed: 2/2/2022, Entered: 2/2/2022 |
Consent by Pro Se Litigant (Non-Prisoner) to receive Notices of Electronic Filing |
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Consent by Pro Se Litigant (Non-Prisoner) Matthew B Proman to receive Notices of Electronic Filing at email address: mattpromandirect1@gmail.com (drz)
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Request |
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| 153 |
Filed: 2/2/2022, Entered: 2/2/2022 |
Order |
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PAPERLESS ORDER: The Court has reviewed Defendant Proman's Omnibus Motion [151]. Plaintiffs shall file a response by or before Monday, February 7, 2022. Defendant Proman may file a reply by or before Friday, February 11, 2022. The Court will thereafter issue a written ruling or set the Motion for a hearing, if deemed necessary. Signed by Magistrate Judge William Matthewman on 2/2/2022. (jb02)
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| 152 |
Filed: 2/2/2022, Entered: 2/2/2022 |
Order |
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PAPERLESS ORDER TO SHOW CAUSE: Pursuant to the Court's prior Order at docket entry 135, Defendant Proman was ordered to respond to Plaintiffs' Emergency Motion at docket entry 134 on or before January 25, 2022. Defendant Proman has failed to respond as ordered. Therefore, on or before Wednesday, February 9, 2022, Defendant Proman shall show cause, in writing, (1) why the Motion should not be granted; (2) why Defendant Proman failed to timely respond by January 25, 2022; and 3) why Defendant Proman failed to, once again, comply with an order of this Court. Defendant Proman's failure to respond to this Order to Show Cause may result in the Motion being granted by default pursuant to Local Rule 7.1(c). Plaintiffs shall be permitted to file a reply to Defendant's response on or before Friday, February 11, 2022. Signed by Magistrate Judge William Matthewman on 2/2/2022. (jb02)
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| 151 |
Filed: 2/1/2022, Entered: 2/1/2022, Terminated: 2/18/2022 |
Motion for Miscellaneous Relief |
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MOTION For Permission to Communicate with Plaintiff/Plaintiff's counsel in Writing Only and Redact Personal Information From Bank Statements and MOTION for Protective Order Against Adam Ludwin by Matthew B Proman. (drz)
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Request |
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| 150 |
Filed: 1/28/2022, Entered: 1/28/2022 |
Consent by Pro Se Litigant (Non-Prisoner) to receive Notices of Electronic Filing |
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Consent by Pro Se Litigant (Non-Prisoner) Matthew B Proman to receive Notices of Electronic Filing at email address: mattpromandirect1@gmail.com (drz)
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| 149 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Notice of Compliance |
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NOTICE of Compliance WITH ORDER DIRECTING CLERK TO UPDATE PRO SE DEFENDANT MATTHEW PROMANS MAILING ADDRESS AND ORDERING DEFENDANT TO TAKE ADDITIONAL STEPS REGARDING HIS CONTACT INFORMATION [D.E.138] by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [138] Order, (Ludwin, Adam)
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| 148 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Notice of Compliance |
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NOTICE of Compliance Regarding the filing of an Amended Notice of Service of the Court's Interim Order on Plaintiffs' Emergency Motion as Required by Paperless Order [D.E. 143] by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [136] Notice of Compliance filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 147 |
Filed: 1/27/2022, Entered: 1/27/2022 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER: The Court has carefully reviewed Defendant's Omnibus Motion [142]. Among other deficiencies, the motion fails to contain a certificate of conferral as required by S.D. Fla. Local Rule 7.1(a)(3). Further, the Motion fails to include the pro se Defendant's mailing address, e-mail address, and telephone number as required by Fed. R. Civ. P. 11(a). Further, the Court has repeatedly ordered Defendant to file a Notice of his current mailing address and telephone number, and to advise whether he will consent to receive electronic notifications from CM/ECF in this case, and he has failed to comply. Accordingly, Defendant's Motion [142] is DENIED WITHOUT PREJUDICE. Defendant Proman is reminded that he has an upcoming deadline pursuant to the Court's prior order at docket entry 138 that he must comply with. As a reminder, that Order states, in part, that "Defendant Proman is ORDERED to file a Notice by or before January 31, 2022 confirming his mailing address, adding his phone number, and advising whether he will or will not be completing and filing the appropriate Consent Form to receive electronic notifications[.]" The Clerk of Court is DIRECTED to mail a copy of this Paperless Order to pro se Defendant Proman at his address listed on the docket. Signed by Magistrate Judge William Matthewman on 1/27/2022. (jb02)
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| 146 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Order on Motion to Disqualify Counsel |
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PAPERLESS ORDER: The Court has carefully reviewed Defendant Proman's Motion to Disqualify Plaintiffs' counsel [140]. Among other deficiencies, the motion fails to contain a certificate of conferral as required by S.D. Fla. Local Rule 7.1(a)(3). Further, the Motion fails to include the pro se Defendant's mailing address, e-mail address and telephone number as required by Fed. R. Civ. P. 11(a). Further, the Court has repeatedly ordered Defendant to file a Notice of his current mailing address and telephone number, and to advise whether he will consent to receive electronic notifications from CM/ECF in this case, and he has failed to comply. Accordingly, Defendant's Motion [140] is DENIED WITHOUT PREJUDICE. Defendant Proman is reminded that he has an upcoming deadline pursuant to the Court's prior order at docket entry 138 that he must comply with. As a reminder, that Order states, in part, that "Defendant Proman is ORDERED to file a Notice by or before January 31, 2022 confirming his mailing address, adding his phone number, and advising whether he will or will not be completing and filing the appropriate Consent Form to receive electronic notifications[.]" The Clerk of Court is DIRECTED to mail a copy of this Paperless Order to pro se Defendant Proman at his address listed on the docket. Signed by Magistrate Judge William Matthewman on 1/27/2022. (jb02)
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| 145 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Order on motion to amend/correct |
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PAPERLESS ORDER: The Court has carefully reviewed Defendant's Motion to Amend Complaint [139]. Among other deficiencies, the motion fails to contain a certificate of conferral as required by S.D. Fla. Local Rule 7.1(a)(3). Further, the Motion fails to include the pro se Defendant's mailing address, e-mail address, and telephone number as required by Fed. R. Civ. P. 11(a). Further, the Court has repeatedly ordered Defendant to file a Notice of his current mailing address and telephone number, and to advise whether he will consent to receive electronic notifications from CM/ECF in this case, and he has failed to comply. Accordingly, Defendant's Motion [139] is DENIED WITHOUT PREJUDICE. Defendant Proman is reminded that he has an upcoming deadline pursuant to the Court's prior order at docket entry 138 that he must comply with. As a reminder, that Order states, in part, that "Defendant Proman is ORDERED to file a Notice by or before January 31, 2022 confirming his mailing address, adding his phone number, and advising whether he will or will not be completing and filing the appropriate Consent Form to receive electronic notifications[.]" The Clerk of Court is DIRECTED to mail a copy of this Paperless Order to pro se Defendant Proman at his address listed on the docket. Signed by Magistrate Judge William Matthewman on 1/27/2022. (jb02)
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| 144 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Order |
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PAPERLESS ORDER: This matter is before the Court upon review of Plaintiffs' Status Report and Motion [141]. The Court advises Plaintiffs that they cannot include a motion or motions within the body of a status report. Pursuant to Fed. R. Civ. P. 7(b),"[a] request for a court order must be made by motion," which must "state with particularity the grounds for seeking the order." Accordingly, the Court shall treat the motions portion of docket entry 141 as a nullity. Should Plaintiffs seek relief for the Court to rule upon, they shall file an appropriate motion or motions in accordance with our Local Rules and the Federal Rules of Civil Procedure. The Clerk of Court is DIRECTED to mail a copy of this Paperless Order to pro se Defendant Proman at his address listed on the docket. Signed by Magistrate Judge William Matthewman on 1/27/2022. (jb02)
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| 143 |
Filed: 1/27/2022, Entered: 1/27/2022 |
Order |
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PAPERLESS ORDER: This matter is before the Court sua sponte. The Court previously ordered Plaintiffs to file an amended Notice of Defendant's address in light of an apparent typographical error [DE 138, para. 2], and ordered Plaintiffs' counsel to email a copy of the Order at docket entry 138 to pro se Defendant Proman and file a Notice of having done so in the record [DE 138, para. 4]. Plaintiffs failed to comply and Plaintiffs' counsel is ORDERED to do so by tomorrow, January 28, 2022. The Clerk of Court is DIRECTED to mail a copy of this Paperless Order to pro se Defendant Proman at his address listed on the docket. Signed by Magistrate Judge William Matthewman on 1/27/2022. (jb02)
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| 142 |
Filed: 1/26/2022, Entered: 1/26/2022, Terminated: 1/27/2022 |
Motion for Miscellaneous Relief |
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MOTION For Permisssion to Communicate with Plaintiff/Plaintiff's counsel in Writing Only and Redact Personal Information From Bank Statements and MOTION for Protective Order Against Adam Ludwin by Matthew B Proman. (drz)
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| 141 |
Filed: 1/26/2022, Entered: 1/26/2022 |
Status report |
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STATUS REPORT and Request to Temporarily Seal Purported Motions to be filed by Defendant which contain false, liable and inflammatory statements as well as false allegations regarding confidential communications allegedly made at mediation in the instant action.. by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 140 |
Filed: 1/24/2022, Entered: 1/25/2022 |
Motion to Disqualify Counsel |
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MOTION to Disqualify Counsel by Matthew B Proman. Responses due by 2/7/2022 (drz)
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Request |
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| 139 |
Filed: 1/24/2022, Entered: 1/25/2022 |
Motion to Amend/Correct |
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MOTION to Amend [1] Complaint, by Matthew B Proman. Responses due by 2/7/2022 (drz)
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Request |
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| 138 |
Filed: 1/24/2022, Entered: 1/24/2022 |
Order |
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ORDER DIRECTING CLERK TO UPDATE PRO SE DEFENDANT MATTHEW PROMAN'S MAILING ADDRESS AND ORDERING DEFENDANT TO TAKE ADDITIONAL STEPS REGARDING HIS CONTACT INFORMATION re [136] Plaintiffs' Notice of Compliance. Signed by Magistrate Judge William Matthewman on 1/24/2022. See attached document for full details. (kza)
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Request |
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| 137 |
Filed: 1/23/2022, Entered: 1/24/2022 |
transcript |
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TRANSCRIPT of Motion Hearing held on 12/28/21 before Magistrate Judge William Matthewman, 1-47 pages, Court Reporter: Joanne Mancari, 305-523-5635. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/14/2022. Redacted Transcript Deadline set for 2/23/2022. Release of Transcript Restriction set for 4/25/2022. (hh)
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Request |
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| 136 |
Filed: 1/21/2022, Entered: 1/21/2022 |
Notice of Compliance |
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NOTICE of Compliance WITH INTERIM ORDER ON PLAINTIFFS EMERGENCY MOTION, FILED JANUARY 20, 2020 by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 135 |
Filed: 1/20/2022, Entered: 1/20/2022 |
Order |
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INTERIM ORDER ON PLAINTIFFS' EMERGENCY MOTION [DE 134]: The requested relief may be urgent to Plaintiffs; however, the Motion should not have been styled an emergency motion as the Motion does not allege a true emergency. The deposition set for this morning, January 20, 2022, at 10:00 a.m. via Zoom SHALL proceed as ORDERED by this Court. [DE 119]. The Court reserves ruling on all other requests for relief stated in the Motion. The Court ORDERS Defendant Proman to file a response to the Motion on or before January 25, 2022, and Plaintiffs to file a reply on or before January 26, 2022. Plaintiffs are DIRECTED to immediately email a copy of this Order to Defendant Proman. Plaintiffs counsel is further DIRECTED to file a Notice advising the Court of Defendant Proman's current mailing address and email address by or before January 21, 2022. Additionally, Defendant Proman is ORDERED to immediately file a notice with the Court of his current mailing address and phone number. Signed by Magistrate Judge William Matthewman on 1/20/2022. See attached document for full details. (kza)
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Request |
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| 134 |
Filed: 1/19/2022, Entered: 1/19/2022, Terminated: 2/18/2022 |
Emergency Motion with Certification of Emergency |
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EMERGENCY MOTION with Certification of Emergency included by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 2/2/2022 (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit, # (4) Exhibit, # (5) Exhibit)(Ludwin, Adam)
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| 133 |
Filed: 1/18/2022, Entered: 1/18/2022 |
Order |
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PAPERLESS ORDER: The Court has reviewed the Notice Of Compliance In Connection With Their Motion To Withdraw Upon Their Discharge By The Defendant Matthew Proman [132], which was filed pursuant to the Order On Counsel For Defendant Matthew Proman's Motion To Withdraw Upon Their Discharge By The Defendant Matthew Proman [130]. In light of the Notice, counsel for Defendant Proman shall be relieved of all further responsibility in this case, and Defendant Proman has elected to proceed pro se in this action. The Clerk is DIRECTED to amend the docket to show that Charles M. Tatelbaum, Esq. and Randy Zelin, Esq. no longer represent any party in this case. Signed by Magistrate Judge William Matthewman on 1/18/2022. (jb02)
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| 132 |
Filed: 1/18/2022, Entered: 1/18/2022 |
Notice of Compliance |
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NOTICE of Compliance in Connection with Their Motion to Withdraw Upon Their Discharge by Matthew B Proman re [130] Order on Motion to Withdraw as Attorney, (Attachments: # (1) Exhibit January 13 Memo, # (2) Exhibit January 17 memo, # (3) Exhibit D.E. 99, # (4) Exhibit D.E. 119, # (5) Exhibit D.E. 124, # (6) Exhibit D.E. 129, # (7) Exhibit D.E. 131) (Tatelbaum, Charles)
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Request |
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| 131 |
Filed: 1/13/2022, Entered: 1/13/2022 |
Order of Instructions to Pro Se Litigant |
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INSTRUCTIONS TO PRO SE LITIGANT MATTHEW PROMAN. Signed by Magistrate Judge William Matthewman on 1/13/2022. See attached document for full details. (drz)
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Request |
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| 130 |
Filed: 1/13/2022, Entered: 1/13/2022 |
Order on Motion to withdraw as attorney |
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ORDER ON COUNSEL FOR DEFENDANT MATTHEW PROMANS MOTION TO WITHDRAW UPON THEIR DISCHARGE BY THE DEFENDANT MATTHEW PROMAN granting [122] Motion to to Withdraw Upon Their Discharge by the Defendant Matthew Proman. Signed by Magistrate Judge William Matthewman on 1/13/2022. See attached document for full details. (drz)
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Request |
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| 129 |
Filed: 1/12/2022, Entered: 1/12/2022 |
Response/Reply (Other) |
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RESPONSE to [128] Status Report by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 128 |
Filed: 1/12/2022, Entered: 1/12/2022 |
Status report |
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STATUS REPORT From Counsel for Defendant Matthew Proman by Matthew B Proman (Tatelbaum, Charles)
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Request |
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| 127 |
Filed: 1/11/2022, Entered: 1/11/2022 |
Order |
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PAPERLESS ORDER: This matter is before the Court upon careful review of Counsel for Defendant Matthew Proman's Motion to Withdraw Upon Their Discharge by the Defendant Matthew Proman [122], and Plaintiffs' Response [126]. So that the Court is fully advised, by or before 2:00 PM tomorrow, January 12, 2022, Defendant's counsel shall file a Status Report to advise of (a) the status of Defendant's discovery production, (b) whether Defendant Proman intends to proceed pro se or hire new counsel, and (c) if Defendant Proman intends to proceed pro se, whether he will be completing and filing the appropriate Consent Form to receive electronic notifications [2] which can be located on the Court's website under the Forms section (https://www.flsd.uscourts.gov/forms/all-forms). Signed by Magistrate Judge William Matthewman on 1/11/2022. (jb02)
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| 126 |
Filed: 1/10/2022, Entered: 1/10/2022 |
Response to motion |
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RESPONSE to Motion re [122] MOTION to Withdraw as Attorney by Randy Zelin and Charles Tatelbaum for / filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 1/18/2022. (Ludwin, Adam)
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Request |
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| 125 |
Filed: 1/10/2022, Entered: 1/10/2022 |
Order |
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PAPERLESS ORDER: This matter is before the Court sua sponte. Over the weekend, the Court was copied on email correspondence of back-and-forth communications between Defendant Proman and Plaintiff and counsel of record Ludwin. Local Rule 7.7 prohibits such correspondence unless invited by the Court, and the Court is not inviting such correspondence and should not be copied on such email correspondence between the parties. This behavior shall not continue going forward. Signed by Magistrate Judge William Matthewman on 1/10/2022. (jb02)
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| 124 |
Filed: 1/7/2022, Entered: 1/7/2022 |
Order |
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ORDER AWARDING ATTORNEY'S FEES AND COSTS TO PLAINTIFFS AND AGAINST DEFENDANT MATTHEW PROMAN: it is hereby ORDERED that Defendant shall reimburse Plaintiffs for their reasonable attorneys fees in the amount of $7,320 and their reasonable costs in the amount of $2,905.60, for a total award of $10,225.60 to be paid by Defendant Proman to Plaintiffs. Defendant shall make such payment to Plaintiffs' counsels trust account by or before January 19, 2022. Thereafter, the parties shall file a Notice in the record advising that payment has been made or advising that payment has not been made within the time period ordered by the Court. In the event of non-payment, Plaintiffs may move for entry of a judgment against Defendant and/or for any other appropriate relief. Signed by Magistrate Judge William Matthewman on 1/7/2022. See attached document for full details. (kza)
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Request |
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| 123 |
Filed: 1/3/2022, Entered: 1/3/2022 |
Order |
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PAPERLESS ORDER: The Court has reviewed Counsel for Defendant Matthew Proman's Motion to Withdraw Upon Their Discharge by the Defendant Matthew Proman [122]. The Court notes that there are several critical deadlines that are swiftly approaching in this case--better responses and amended production to Plaintiffs' discovery are due by January 14, 2022, Defendant Promans deposition is scheduled for January 20, 2022, and the discovery cutoff deadline is February 25, 2022. In light of these deadlines and so the Court is fully advised, Plaintiffs shall file a response to the motion to withdraw by or before January 10, 2022, and Defendant shall reply by or before January 12, 2022. The Court reminds Defendant's counsel that the pending motion to withdraw does not relieve counsel from ensuring timely and thorough compliance with all deadlines and obligations in this case. If Defendant's counsel chooses, counsel may advise the Court if amended production/responses are produced in advance of the currently scheduled deadline. Signed by Magistrate Judge William Matthewman on 1/3/2022. (jb02)
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| 122 |
Filed: 12/31/2021, Entered: 12/31/2021, Terminated: 1/13/2022 |
Motion to withdraw as attorney |
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MOTION to Withdraw as Attorney by Randy Zelin and Charles Tatelbaum for / by Matthew B Proman. Responses due by 1/14/2022 (Tatelbaum, Charles)
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Request |
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| 121 |
Filed: 12/30/2021, Entered: 12/30/2021 |
Notice of Supplemental Authority |
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Notice of Supplemental Authority re [110] Memorandum of Fees and Costs - Declaration of Attorney Michael L. Feinstein Regarding the Reasonableness of Fees sought by Plaintiffs by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Attachments: # (1) Affidavit) (Ludwin, Adam)
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Request |
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| 120 |
Filed: 12/29/2021, Entered: 12/29/2021 |
Reply to Response to motion |
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REPLY to Response to Motion re [114] MOTION to Compel Bettter Responses to Plaintiffs' First and Second Requests for Production filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 119 |
Filed: 12/28/2021, Entered: 12/28/2021 |
Order on motion to compel |
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OMNIBUS ORDER FOLLOWING DECEMBER 28, 2021 HEARING: the in-person deposition of Defendant Proman on January 7, 2022 at 9:30 AM is hereby CANCELED. The deposition of Defendant Proman will take place via Zoom VTC and is hereby SCHEDULED for January 20, 2022 at 10:00 AM; granting in part and denying in part [114] Plaintiff's Motion to Compel - Better responses and amended production to Plaintiffs First Requests for Production and Plaintiffs Second Requests for Production shall be due by or before January 14, 2022. In light of the rescheduled deposition of Defendant Proman, the Court finds it necessary to extend the deadline for the parties to disclose experts, expert witness summaries, and reports from January 14, 2022 to January 28, 2022 and to extend the rebuttal expert witness disclosures, summaries and reports to February 4, 2022. The Court notes that Defendant Proman indicated that he may terminate counsel because he is no longer financially able to afford counsel. [DE 117]. Should Defendants counsel seek to withdraw as counsel for Defendant Proman in this case, an appropriate motion shall be filed. Signed by Magistrate Judge William Matthewman on 12/28/2021. See attached document for full details. (kza)
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Request |
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| 118 |
Filed: 12/28/2021, Entered: 12/28/2021 |
Motion Hearing |
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PAPERLESS Minute Entry for proceedings held before Magistrate Judge William Matthewman: The hearing was held via Zoom Video Teleconference. Status Conference Re Defendant's Deposition and Motion Hearing held on 12/28/2021 re [114] Plaintiffs' Renewed MOTION to Compel Better Responses to Plaintiffs' First and Second Requests for Production. Argument held. The Court permitted the Defendant Matthew Proman to address the Court. The Defendant apologized to the Court for his behavior at the first deposition. The Court ordered that the Defendant's deposition be reset to January 20, 2022 at 10 a.m. via Zoom Video. The Court advised Defense counsel that a written motion to withdraw would need to be filed if it becomes necessary. The Court entered rulings on the record regarding Plaintiff's motion. The Court ordered the Defendant to provide responses to the requests for production on or before January 14, 2022. The Court extended the Expert witness report deadlines. Written order to be issued. Total time in court: 1 hour(s) : 16 minutes. Attorney Appearance(s): Adam Michael Ludwin for Plaintiffs, Charles M. Tatelbaum and Randy Zelin for Defendant. Other appearances: Defendant: Matthew Proman. (Digital 11:34:21) (kza)
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| 117 |
Filed: 12/28/2021, Entered: 12/28/2021 |
supplement |
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SUPPLEMENT to [116] Response in Opposition to Motion, by Matthew B Proman (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Tatelbaum, Charles)
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Request |
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| 116 |
Filed: 12/27/2021, Entered: 12/27/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [114] MOTION to Compel Bettter Responses to Plaintiffs' First and Second Requests for Production filed by Matthew B Proman. Replies due by 1/3/2022. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G)(Tatelbaum, Charles)
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Request |
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| 115 |
Filed: 12/23/2021, Entered: 12/23/2021 |
Order Setting Hearing on Motion |
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PAPERLESS ORDER EXPEDITING A RESPONSE AND ADDING MOTION TO BE HEARD AT HEARING: The Court has reviewed Plaintiffs' Motion to Compel [114]. In light of the quickly approaching discovery cutoff deadline and because the deposition at issue is set for January 7, 2022, the Court finds it necessary to expedite a response and add this motion to be heard during the December 28, 2021 hearing [111]. Defendant shall file a response by or before 2:00 PM on December 27, 2021. No reply shall be filed. In advance of the scheduled hearing, the Court directs the parties' counsel to confer, either in person or by telephone, in good faith and for as long as necessary to address the pending discovery dispute. The Court shall consider sanctions or cost-shifting against any party or counsel who fails to comply with all discovery obligations, fails to comply with applicable rules and orders, or who takes a frivolous, dilatory, or unreasonable discovery position. If the parties resolve the disputes raised in whole or in part prior to the hearing, the Court shall be promptly notified. Signed by Magistrate Judge William Matthewman on 12/23/2021. (jb02)
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| 114 |
Filed: 12/22/2021, Entered: 12/22/2021, Terminated: 12/28/2021 |
Motion to Compel |
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MOTION to Compel Bettter Responses to Plaintiffs' First and Second Requests for Production by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 1/5/2022 (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit)(Ludwin, Adam)
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Request |
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| 113 |
Filed: 12/22/2021, Entered: 12/22/2021 |
Response/Reply (Other) |
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RESPONSE to [110] Memorandum in Opposition to Plaintiffs' Memorandum of Attorney's Fees and Costs by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 112 |
Filed: 12/22/2021, Entered: 12/22/2021 |
Notice - Other |
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NOTICE by Matthew B Proman re [111] Order,,,,, Order Setting Status Conference,,,, Notice of Disposition of Parallel Criminal Proceeding (Tatelbaum, Charles)
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Request |
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| 111 |
Filed: 12/17/2021, Entered: 12/17/2021 |
Order |
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PAPERLESS ORDER SETTING STATUS CONFERENCE: Presently, the in-person deposition of Defendant Proman is set for January 7, 2022 at 9:30 AM [109] at the U.S. Courthouse in West Palm Beach, Florida, due to Defendant Proman's prior outrageous deposition misconduct during a Zoom deposition. In light of the rise of the Omicron variant, the Court finds it necessary to hold a status conference to discuss the logistics of the deposition in advance of the January 7, 2022 deposition. Accordingly, the Court hereby ORDERS that a status conference shall be held on December 28, 2021, at 11:30 AM, to take place via Zoom Video Teleconference (VTC). To log in through ZoomGov Meeting, using Meeting ID: 160 540 3826 and Passcode: 246129. Counsel for both parties shall appear and Defendant Proman shall appear from an attorney's office or other professional location where he is seated and presentable during the hearing. Any distractions or misconduct by Defendant Proman during the Zoom VTC hearing shall result in severe sanctions. Signed by Magistrate Judge William Matthewman on 12/17/2021. (jb02)
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| 110 |
Filed: 12/15/2021, Entered: 12/15/2021 |
MEMORANDUM |
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MEMORANDUM in Support Award of Sanctions Against Defendant by Adam M. Ludwin, Esq.. (Attachments: # (1) Affidavit)(Ludwin, Adam)
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Request |
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| 109 |
Filed: 12/7/2021, Entered: 12/7/2021 |
Order on Motion to continue |
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ORDER GRANTING DEFENDANT MATTHEW PROMAN'S MOTION FOR A CONTINUANCE OF HIS APPEARANCE ON DECEMBER 8, 2021 [DE 100]. The in-person deposition of Defendant Proman is RESET to January 7, 2022 at 9:30 a.m. at the United States Courthouse 701 Clematis Street, Third Floor, Courtroom Six, West Palm Beach, Florida before Magistrate Judge William Matthewman. Signed by Magistrate Judge William Matthewman on 12/7/2021. See attached document for full details. (kza)
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| 108 |
Filed: 12/6/2021, Entered: 12/6/2021 |
Reply to Response to motion |
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REPLY to Response to Motion re [100] MOTION to Continue December 8, 2021 Deposition re [86] Order on Motion to Continue,,,, Set/Reset Hearings filed by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 107 |
Filed: 12/6/2021, Entered: 12/6/2021 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER granting [106] Motion Of Charles Tatelbaum, Local Counsel For The Defendant, To Be Excused From Any Hearing Or Deposition To Be Held On December 8, 2021. Good cause shown, Charles M. Tatelbaum's personal appearance and participation at the deposition scheduled for December 8, 2021 is excused as long as pro hac vice counsel is in personal attendance. Signed by Magistrate Judge William Matthewman on 12/6/2021. (jb02)
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| 106 |
Filed: 12/6/2021, Entered: 12/6/2021, Terminated: 12/6/2021 |
Motion for Miscellaneous Relief |
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Motion of Charles Tatelbaum, Local Counsel for the Defendant, To be Excused From Any Hearing or Deposition to be Held on December 8, 2021 by Matthew B Proman. (Tatelbaum, Charles) Modified Text on 12/6/2021 (drz).
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Request |
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| 105 |
Filed: 12/6/2021, Entered: 12/6/2021 |
Order |
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PAPERLESS ORDER: The Court has reviewed Plaintiffs' response to Defendant's Motion for Continuance [104], which attaches recent photos of Defendant Proman out in public without a mask, apparently ignoring his alleged doctor's instructions. Moreover, the fact that Defendant Proman has chosen not to get the readily available COVID-19 vaccine is not cause to further delay and frustrate discovery in this case. In light of Defendant Proman's extreme misconduct in this case as specified in the Court's prior Order [74], the Court is extremely reluctant to delay the in-person deposition again. The Court is also highly skeptical of Defendant Proman's assertions in light of his prior behavior in this case and the photos attached to Plaintiffs' response. However, the Court will allow Defendant to file a reply, subject to the provisions of Federal Rule of Civil Procedure 11, to Plaintiffs' response by 8:00 p.m. EST, today, December 6, 2021. The Court will then issue a prompt ruling on Defendant's Motion for Continuance [104] after review of a timely reply, or after the failure to timely file such reply. Signed by Magistrate Judge William Matthewman on 12/6/2021. (jb02)
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| 104 |
Filed: 12/6/2021, Entered: 12/6/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [100] MOTION to Continue December 8, 2021 Deposition re [86] Order on Motion to Continue,,,, Set/Reset Hearings filed by Adam M. Ludwin, Esq.. Replies due by 12/13/2021. (Attachments: # (1) Exhibit)(Ludwin, Adam)
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Request |
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| 103 |
Filed: 12/3/2021, Entered: 12/3/2021 |
Order |
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PAPERLESS ORDER: In light of Defendant's supplemental notice of conferral [102], which states that Plaintiffs object to the requested relief in Defendant's Motion for Continuance [100], Plaintiffs shall file a response to the Motion [100] forthwith and in no event later than 12:00 PM Noon on Monday, December 6, 2021. No reply shall be filed by Defendant unless ordered by the Court. Signed by Magistrate Judge William Matthewman on 12/3/2021. (jb02)
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| 102 |
Filed: 12/3/2021, Entered: 12/3/2021 |
Certificate of Counsel |
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CERTIFICATE of Counsel re [100] MOTION to Continue December 8, 2021 Deposition re [86] Order on Motion to Continue,,,, Set/Reset Hearings, [101] Order,,,,, by Charles M. Tatelbaum on behalf of Matthew B Proman (Tatelbaum, Charles)
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Request |
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| 101 |
Filed: 12/3/2021, Entered: 12/3/2021 |
Order |
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PAPERLESS ORDER REQUIRING SUPPLEMENTAL NOTICE OF CONFERRAL: The Court has carefully reviewed Defendant Matthew Proman's Motion For A Continuance Of His Appearance On December 8, 2021 [100]. The certificate of conferral states that Defendant's counsel "has attempted to confer with Plaintiffs' counsel in a good faith effort to resolve the issues raised in this motion and has been unable to do so." Attached to the Motion is an email from Defendant's counsel to Plaintiffs' counsel requesting Plaintiffs' position on the requested relief, which was sent on December 1, 2021 at 10:10 PM. However, as Defendant's counsel is well aware, the Court requires conferral either in person or by telephone [58] [60] [90] [94]. Because Defendant Matthew Proman's in-person deposition is scheduled for December 8, 2021, Defendant's counsel is required to immediately call Plaintiffs' counsel to confer regarding the requested relief in Defendant's Motion. By the end of the day, today, December 3, 2021, Defendant shall file a supplemental notice of conferral advising the Court of the Plaintiffs' position on Defendant's Motion after conferring in good faith as required. Signed by Magistrate Judge William Matthewman on 12/3/2021. (jb02)
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| 100 |
Filed: 12/3/2021, Entered: 12/3/2021, Terminated: 12/7/2021 |
Motion to Continue |
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MOTION to Continue December 8, 2021 Deposition re [86] Order on Motion to Continue,,,, Set/Reset Hearings by Matthew B Proman. Responses due by 12/17/2021 (Attachments: # (1) Exhibit Positive Covid Test, # (2) Exhibit Letter From Doctor-October 26, # (3) Exhibit Letter From Doctor-December 1, # (4) Exhibit Email to Ludwin, # (5) Exhibit Declaration from Criminal Attorney)(Tatelbaum, Charles)
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Request |
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| 99 |
Filed: 11/23/2021, Entered: 11/23/2021 |
Scheduling Order |
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AMENDED ORDER SETTING CIVIL TRIAL DATE, PRETRIAL DEADLINES, AND REFERRAL TO MAGISTRATE JUDGE: ( Jury Trial set for 8/1/2022 before Judge Rodney Smith., Calendar Call set for 7/26/2022 09:00 AM before Judge Rodney Smith., Expert Discovery due by 2/25/2022., Fact Discovery due by 2/25/2022., Mediation Deadline 3/11/2022., In Limine Motions due by 6/17/2022., Dispositive Motions due by 3/18/2022., Motions due by 6/17/2022., Pretrial Stipulation due by 6/17/2022.). Signed by Judge Rodney Smith on 11/23/2021. 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.
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Request |
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| 98 |
Filed: 11/23/2021, Entered: 11/23/2021 |
Order on Motion for Extension of Time of Discovery Cutoff Deadline |
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PAPERLESS ORDER DENYING AS MOOT [96] Motion for Relief from the Scheduling Order. The Court has entered an Amended Trial Order. Signed by Judge Rodney Smith on 11/23/2021. (zgs)
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| 97 |
Filed: 11/23/2021, Entered: 11/23/2021 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER DENYING AS MOOT [83] Motion for Relief from the Scheduling Order to Disclose Expert Witnesses Signed by Judge Rodney Smith on 11/23/2021. (zgs)
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| 96 |
Filed: 11/21/2021, Entered: 11/21/2021, Terminated: 11/23/2021 |
Motion for Extension of Time of Discovery Cutoff Deadline |
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MOTION for Extension of Time of Discovery Cutoff Deadline by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 95 |
Filed: 11/9/2021, Entered: 11/10/2021 |
transcript |
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TRANSCRIPT of Motion Hearing (Plaintiff's Motion to Compel) held on 10/7/21 before Magistrate Judge William Matthewman, 1-55 pages, Court Reporter: Bonnie J. Lewis, 305-523-5635. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 11/30/2021. Redacted Transcript Deadline set for 12/10/2021. Release of Transcript Restriction set for 2/7/2022. (hh)
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Request |
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| 94 |
Filed: 11/9/2021, Entered: 11/9/2021 |
Order on motion to compel |
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PAPERLESS ORDER: The Court has carefully reviewed Plaintiffs' Renewed Motion To Compel Better Responses To Plaintiffs' First Requests For Production And Motion For Contempt And For Sanctions [87], Defendant's Response [89], and the parties' Joint Notice [93]. The Joint Notice advises that "Plaintiffs have received responses from Defendant via facsimile on November 3, 2021 and no longer believe a fraud has been committed against the Court, and believe that Defendant's failure to serve responses timely resulted from a series of unintended technological errors." In light of this, the Court's Order to Show Cause is hereby DISCHARGED. In addition, Plaintiffs' Motion [67] is DENIED WITHOUT PREJUDICE. After reviewing the amended responses, the Motion may be renewed, if necessary, based upon good faith, and after further personal telephonic conferral. Moreover, the parties and their counsel are PROHIBITED from filing any further discovery motions in this case without first personally conferring in good faith by telephone in an honest effort to resolve the dispute before bringing it to the Court. If the Court finds that a discovery motion is filed without such personal telephonic conferral or a good faith effort to personally confer, or if counsel for one side fails to return phone calls or refuses to confer telephonically, sanctions SHALL be imposed on the offending party and counsel. The Court simply will not tolerate any more game playing in discovery and any further lack of professionalism in this case. Signed by Magistrate Judge William Matthewman on 11/9/2021. (jb02)
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| 93 |
Filed: 11/8/2021, Entered: 11/8/2021 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [90] Order,,,, Jointly filed (Ludwin, Adam)
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Request |
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| 92 |
Filed: 11/8/2021, Entered: 11/8/2021 |
Notice of Conventional Filing |
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SECOND AMENDED NOTICE OF CONVENTIONAL FILING OF SEPTEMBER 15 2021, VIDEO DEPOSITION OF DEFENDANT MATTHEW PROMAN ON DVD of [76] Notice of Conventional Filing, [71] Order, by Adam M. Ludwin, Esq. ( DVD not Attached to Filing) (drz)
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Request |
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| 91 |
Filed: 11/8/2021, Entered: 11/8/2021 |
Response to motion |
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RESPONSE to Motion re [87] MOTION to Compel Better Responses to Plaintiff's First Requests for Production MOTION for Contempt MOTION for Sanctions filed by Matthew B Proman. Replies due by 11/15/2021. (Attachments: # (1) Exhibit A-Randy Zelin Email, # (2) Exhibit B-Ludwin Email)(Tatelbaum, Charles)
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Request |
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| 90 |
Filed: 11/5/2021, Entered: 11/5/2021 |
Order |
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PAPERLESS ORDER REQUIRING A JOINT NOTICE: The Court has carefully reviewed Plaintiffs' Renewed Motion To Compel Better Responses To Plaintiffs' First Requests For Production And Motion For Contempt And For Sanctions [87] and Defendant's Response [89]. By or before November 8, 2021, the parties shall file a Joint Notice to advise whether Plaintiffs received the faxed responses sent by Defendant on November 3, 2021 and whether Plaintiffs' assertion in their Motion that "Defendant's Notice of Compliance is nothing short of a fraud" is now incorrect in light of what appears to be an unintended technological error in sending the better responses. The Court notes that it appears that these issues now consuming the Court's limited time could all have easily been avoided if opposing counsel simply picked up the telephone and actually spoke to each other. On a going forward basis, any further lack of good faith personal communication and conferral may result in sanctions on all parties and all counsel. Signed by Magistrate Judge William Matthewman on 11/5/2021. (jb02)
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| 89 |
Filed: 11/4/2021, Entered: 11/4/2021 |
Response to order to show cause |
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RESPONSE TO ORDER TO SHOW CAUSE re [88] Order,,,,,,,,,,,,, by Matthew B Proman. (Attachments: # (1) Exhibit Cell Phone Call, # (2) Exhibit Ludwin-Auto Reply, # (3) Exhibit Email communication, # (4) Exhibit Email communicaton, # (5) Exhibit Email Signature Block-Zelin, # (6) Exhibit Email Signature Block-Ludwin, # (7) Exhibit Email to Admin @ Ludwin's office, # (8) Exhibit Email Communication with paralegal, # (9) Exhibit Email communication, # (10) Exhibit Email communication, # (11) Exhibit Email communication, # (12) Exhibit Affidavit of Holly Berkower)(Tatelbaum, Charles)
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| 88 |
Filed: 11/3/2021, Entered: 11/3/2021 |
Order |
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PAPERLESS ORDER TO SHOW CAUSE: The Court has carefully reviewed Plaintiffs' Renewed Motion To Compel Better Responses To Plaintiffs' First Requests For Production And Motion For Contempt And For Sanctions, and the entire record in this case. First, the Court is extremely frustrated that all counsel in this case seemingly refuse or are unable to speak to each other by telephone as they have been ordered to do. Second, the Court is quite concerned by what appears to be a pattern in this case of dilatory, obstructionist behavior by Defendant Proman and Defendant Proman's counsel, Mr. Zelin. Defendant Proman and Mr. Zelin appear to continue to demonstrate to the Court a pattern and practice of failing to comply with Court orders and applicable rules governing this case, including failing to confer in good faith, as required under our local rules, and to do so personally, as required by the undersigned. For instance, in the Court's prior Order [82], the Court instructed that "Defendant Proman's counsel shall immediately call Plaintiff's counsel and attempt to speak to him directly to get his position on this Motion." Attached to Defendant's Motion is an email by Defendant's counsel instructing Plaintiff's counsel to "call my cell." [84-2]. This is insufficient and does not comply with the Court's Order. The Order was clear: Defendant's counsel was to call Plaintiff's counsel. Moreover, in Plaintiff's recently filed motion, Plaintiff's counsel states that "Plaintiff attempted to meet and confer in a good faith in an effort to resolve the issues herein. However, Defendant did not respond to the undersigned's attempts to reach Defendant via email, telephone, or text message." [83]. There is also seemingly a pattern of failing to participate in good faith in discovery. In a prior Order [75], Defendant was instructed to serve better responses to Plaintiffs' Requests for Production by October 18, 2021. It is now November 3, 2021. According to Plaintiffs' Renewed Motion, no documents have been produced. Additionally, the Court has already sanctioned Defendant Proman for his obstructionist behavior during his deposition and the Court reserved ruling on sanctioning Mr. Zelin as well for his behavior during Defendant Proman's deposition. In light of this behavior, by or before November 8, 2021, a response to this Order to Show Cause shall be filed, showing cause in writing as to why Defendant Proman and Mr. Zelin's conduct in discovery should not be sanctioned as authorized under the applicable rules, including Rule 37, and the inherent authority of this Court, see Chambers v. NASCO, Inc., 501 U.S. 32, 45-46 (1991), including but not limited to, an award of attorney's fees and costs against Defendant Proman and Mr. Zelin, treating this matter as a contempt of Court, striking of Defendant Proman's pleadings, and entry of a default judgment against him. Plaintiffs may file a reply by or before November 10, 2021. Defendant shall also file a response to Plaintiffs' Renewed Motion, pursuant to the Court's Order Setting Discovery Procedure and all applicable rules on or before November 8, 2021 and Plaintiff may reply by November 10, 2021. Signed by Magistrate Judge William Matthewman on 11/3/2021. (jb02)
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| 87 |
Filed: 11/2/2021, Entered: 11/2/2021, Terminated: 11/9/2021 |
Motion to Compel |
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MOTION to Compel Better Responses to Plaintiff's First Requests for Production ( Responses due by 11/16/2021), MOTION for Contempt ( Responses due by 11/16/2021), MOTION for Sanctions by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit A - Emails)(Ludwin, Adam)
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Request |
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| Save 25% on a pre-paid one year subscription. |
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| 86 |
Filed: 11/2/2021, Entered: 11/2/2021 |
Order on Motion to continue |
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PAPERLESS ORDER granting [81] Defendant Matthew Proman's Motion For A Continuance Of His Appearance On November 8, 2021. Defendant Proman's in-person deposition is hereby RESET to December 8, 2021 at 10:00 AM. The deadlines for filings related to the amount of attorney's fees and costs to be awarded against Defendant Proman and in favor of Plaintiff Ludwin are similarly extended to correspond with the reset deposition. Plaintiffs shall file an appropriate Memorandum of Attorney's Fees and Costs by December 15, 2021, Defendant may respond in opposition by December 22, 2021, and Plaintiff may reply by December 29, 2021. The parties shall otherwise comply with the instructions set forth in the Court's prior Order [74]. The discovery deadline is extended solely for the purpose of this deposition due to the unique and extenuating circumstances surrounding the deposition of Defendant Proman. If an extension of the discovery deadline is sought for any other purpose or for any further period of time, a further motion shall be filed for consideration by U.S. District Judge Rodney Smith. Signed by Magistrate Judge William Matthewman on 11/2/2021. (jb02)
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| 85 |
Filed: 11/2/2021, Entered: 11/2/2021 |
Response to motion |
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RESPONSE to Motion re [81] MOTION to Continue Defendant Proman's in-person Deposition Scheduled for November 8, 2021 re [74] Order on Motion to Compel,,, Order on Motion for Sanctions,,, Order on Motion for Miscellaneous Relief,, filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 11/9/2021. (Attachments: # (1) Exhibit A- Email chain with Defendant's Counsels, # (2) Exhibit B - Proposed Stipulated Order on Defendant's Motion to Continue Deposition)(Ludwin, Adam)
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Request |
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Filed: None, Entered: None |
set/reset hearings |
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Set/Reset Hearings per DE 86: Deposition reset for 12/8/2021 10:00 AM in West Palm Beach Division before Magistrate Judge William Matthewman. (jb02)
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Filed: None, Entered: None |
[[ITALIC]]Description not available[[/ITALIC]] |
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SYSTEM ENTRY - Docket Entry 84 [motion] restricted/sealed until further notice. (740439)
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| 83 |
Filed: 10/28/2021, Entered: 10/28/2021, Terminated: 11/23/2021 |
Motion for Miscellaneous Relief |
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MOTION FOR RELIEF FROM THE SCHEDULING ORDER TO DISCLOSE EXPERT WITNESSES by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam) Modified Text on 10/28/2021 (drz).
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Request |
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| 82 |
Filed: 10/28/2021, Entered: 10/28/2021 |
Order |
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PAPERLESS ORDER: The Court has carefully reviewed Defendant Matthew Proman's Motion For A Continuance Of His Appearance On November 8, 2021 [81]. In the Court's prior Order [74], as a result of Defendant Matthew Proman's intentional, bad faith misconduct, Defendant Proman was ordered to appear in person for his deposition at the United States Courthouse in West Palm Beach on November 8, 2021. In the Order, the Court noted that, if Defendant Proman sought to reschedule his in-person deposition due to a COVID-19 diagnosis, an appropriate motion should be filed with attached proof, including, at a minimum, "medical records, doctors' reports, appropriate affidavit(s), a diagnosis and prognosis, test results, and a clear statement of why he cannot travel for his November 8, 2021 deposition and when he will be able to resume traveling." Now, Defendant Proman's Motion seeks to continue the deposition because he contracted COVID-19 on September 30, 2021, he has a preexisting condition, and continues to have unresolved symptoms related to COVID-19. The Motion attaches a letter from his doctor that states that Defendant Proman should avoid air travel until December 1, 2021 and he should be reevaluated at that time. This is wholly insufficient to comply with the Court's prior Order [74]. As a result, by or before October 29, 2021, Defendant Proman's counsel shall file under seal: (1) a copy of the positive COVID-19 test result; and (2) a sworn Declaration or Affidavit under the penalty of perjury by Defendant Proman stating the specific date he was tested for COVID-19, the date he was advised he was positive for COVID-19, and the name and address of the facility where he was tested. The Motion also indicates that Defendant Proman's counsel was unable to properly confer with Plaintiff's counsel. Therefore, Defendant Proman's counsel shall immediately call Plaintiff's counsel and attempt to speak to him directly to get his position on this Motion. So that the Court is fully advised, by or before November 1, 2021, Plaintiff's counsel shall file a response to the Motion stating whether Plaintiff opposes the request for continuance and if so, why. Signed by Magistrate Judge William Matthewman on 10/28/2021. (jb02)
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| 81 |
Filed: 10/28/2021, Entered: 10/28/2021, Terminated: 11/2/2021 |
Motion to Continue |
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MOTION to Continue Defendant Proman's in-person Deposition Scheduled for November 8, 2021 re [74] Order on Motion to Compel,,, Order on Motion for Sanctions,,, Order on Motion for Miscellaneous Relief,, by Matthew B Proman. Responses due by 11/12/2021 (Attachments: # (1) Text of Proposed Order Proposed Order, # (2) Exhibit Letter from Doctor, # (3) Exhibit Email to O/C, # (4) Exhibit Auto Reply, # (5) Exhibit Email to Administrator)(Tatelbaum, Charles)
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Request |
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| 80 |
Filed: 10/18/2021, Entered: 10/18/2021 |
Notice of Compliance |
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NOTICE of Compliance to Serve Better Responses to Plaintiffs' Request for Production by Matthew B Proman re [75] Order on Motion to Compel,,, Order on Motion for Sanctions,, (Tatelbaum, Charles)
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Request |
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| 79 |
Filed: 10/15/2021, Entered: 10/15/2021 |
Clerks Notice of Docket Correction and Instruction to Filer - Attorney |
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Clerks Notice to Filer re [78] Notice (Other). Conventional Filing Filed Electronically; CORRECTIVE ACTION REQUIRED - The Filer failed to submit the document in the conventional paper format. The Filer must file a Notice of Striking, then refile the document in the conventional paper format. (drz)
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| 78 |
Filed: 10/15/2021, Entered: 10/15/2021 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin re [76] Notice of Conventional Filing, [77] Clerk's Notice of Filing Deficiency (Ludwin, Adam)
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Request |
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| 77 |
Filed: 10/15/2021, Entered: 10/15/2021 |
Clerk's Notice of Filing Deficiency |
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Clerk's Notice of Filing Deficiency Re: [76] Notice of Conventional Filing filed by Adam M. Ludwin, Esq.. Document(s) missing required signature(s) (Fed.R.Civ.P. 11(a)). (mee)
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| 76 |
Filed: 10/15/2021, Entered: 10/15/2021 |
Notice of Conventional Filing |
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Notice of Conventional Filing of September 15,2021 video Deposition of Defendant Matthew Proman on DVD [73] Notice (Other) by Adam M. Ludwin, Esq. (mee) Modified on 10/15/2021 (mee).
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Request |
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| 75 |
Filed: 10/15/2021, Entered: 10/15/2021 |
Order on motion to compel |
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PAPERLESS ORDER granting in part and denying in part [59] Plaintiffs' Motion To Compel, To Overrule The Objections, And To Provide Complete And Responsive Answers To Requests For Production And For Sanctions. As thoroughly stated on the record during the October 7, 2021 hearing on the Motion, Defendant shall serve better responses to Plaintiffs' Requests for Production by or before Monday, October 18, 2021. All other relief requested in the Motion is denied. Signed by Magistrate Judge William Matthewman on 10/15/2021. (jb02)
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| 74 |
Filed: 10/13/2021, Entered: 10/13/2021 |
Order on motion to compel |
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ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFFS' MOTION TO COMPEL DEPOSITION RESPONSES, FOR ADDITIONAL MISCELLANEOUS RELIEF AND FOR SANCTIONS [DE 64]: The deposition of Defendant Matthew Proman shall be held on Monday, November 8, 2021 at 10:00 a.m. at the United States Courthouse 701 Clematis Street, Third Floor, Courtroom Six, West Palm Beach, Florida. Mr. Ludwin, Defendant Proman, and Defendant Promans counsel, Mr. Zelin, SHALL APPEAR IN PERSON at the November 8, 2021 deposition.. Signed by Magistrate Judge William Matthewman on 10/13/2021. See attached document for full details. (kza)
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| 73 |
Filed: 10/13/2021, Entered: 10/13/2021 |
Notice - Other |
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NOTICE by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin OF CONVENTIONAL FILING OF SEPTEMBER 15, 2021, VIDEO DEPOSITION OF DEFENDANT MATTHEW PROMAN ON DVD (Ludwin, Adam)
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Request |
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Filed: None, Entered: None |
set/reset hearings |
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Set/Reset Hearings Deposition set for 11/8/2021 at 10:00 AM in West Palm Beach Division before Magistrate Judge William Matthewman. (kza)
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Filed: None, Entered: None |
set/reset hearings |
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Set/Reset Hearings Deposition set for 11/8/2021 at 10:00 AM in West Palm Beach Division before Magistrate Judge William Matthewman. (kza)
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| 72 |
Filed: 10/12/2021, Entered: 10/12/2021 |
Letter |
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Letter from Adam M. Ludwin to Magistrate Judge William Matthewman received on October 8, 2021 re: Court's Request for a Physical Copy of video recording of the deposition of Defendant, Matthew Proman, conducted on September 15, 2021. (kza)
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Request |
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| 71 |
Filed: 10/12/2021, Entered: 10/12/2021 |
Order |
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PAPERLESS ORDER: The Court is in receipt of correspondence and a USB drive provided by Plaintiffs' counsel to the Court on October 8, 2021, which was submitted in response to the Court's instruction at the October 7, 2021 hearing [70]. For security reasons, the Court cannot accept the USB drive and the Clerk will promptly mail it back to Plaintiffs' counsel. To comply with the Court's October 7, 2021 instruction, Plaintiffs SHALL conventionally file with the Clerk's Office the September 15, 2021 recording of the deposition of Defendant Proman in its entirety by or before October 18, 2021. That filing shall consist of a Notice of Conventional filing and a DVD of the video deposition. In addition, the Court notes that the correspondence does not indicate that opposing counsel was provided a copy of such. Therefore, the Court will separately file the correspondence in the record. In the future, any authorized correspondence addressed to the Court shall make clear that opposing counsel received a copy of such. Signed by Magistrate Judge William Matthewman on 10/12/2021. (jb02)
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| 70 |
Filed: 10/7/2021, Entered: 10/8/2021 |
Motion Hearing |
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PAPERLESS Minute Entry for proceedings held before Magistrate Judge William Matthewman: The hearing was held via Zoom Video Teleconference. Motion Hearing held on 10/7/2021 re [64] Plaintiffs' MOTION (a) for an order overruling all improper objections raised by, and on behalf of, Defendant; (b) requiring Defendant to produce satisfactory answers during Plaintiffs rescheduled Deposition; (c) for an additional time to conduct Defendant's deposition and [59] Plaintiffs' MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production and for Sanctions. Argument held. The Court granted in part and denied in part Plaintiffs' motion [DE 64]. Written order to be issued. As to Plaintiffs' motion [DE 59] - the Court will grant in part and deny in part the motion and require Defendant to provide better answers to the requests for production on or before October 18, 2021. Written order to be issued. Total time in court: 1 hour(s) : 23 minutes. Attorney Appearance(s): Adam Michael Ludwin for Plaintiffs, Charles M. Tatelbaum and Randy Zelin for Defendant. (Digital 14:30:48) (kza)
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| 69 |
Filed: 10/7/2021, Entered: 10/7/2021 |
Notice of Supplemental Authority |
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Notice of Supplemental Authority re [64] MOTION to Compel MOTION for Sanctions MOTION (a) for an order overruling all improper objections raised by, and on behalf of, Defendant; (b) requiring Defendant to produce satisfactory answers during Plaintiffs rescheduled Deposition; (c) for an additional time to conduct Defendants depos, [59] MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production MOTION for Sanctions REGARDING CALCULATIONS OF FEES AND COSTS by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Attachments: # (1) Exhibit A) (Ludwin, Adam)
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Request |
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| 68 |
Filed: 10/6/2021, Entered: 10/6/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [64] MOTION to Compel MOTION for Sanctions MOTION (a) for an order overruling all improper objections raised by, and on behalf of, Defendant; (b) requiring Defendant to produce satisfactory answers during Plaintiffs rescheduled Deposition; (c) for an additional time to conduct Defendants depos filed by Matthew B Proman. Replies due by 10/13/2021. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H)(Tatelbaum, Charles)
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Request |
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| 67 |
Filed: 10/6/2021, Entered: 10/6/2021 |
Notice of Compliance |
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NOTICE of Compliance With Court Order Docket Entry 60 by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 66 |
Filed: 10/6/2021, Entered: 10/6/2021 |
Notice of Compliance |
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NOTICE of Compliance With Court Order Docket Entry 65 by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 65 |
Filed: 10/5/2021, Entered: 10/5/2021 |
Order |
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PAPERLESS ORDER EXPEDITING BRIEFING AND ADDING MOTION TO HEARING: The Court has carefully reviewed Plaintiffs' Motion To Compel Deposition Responses, For Additional Miscellaneous Relief And For Sanctions [64]. The Motion will be addressed at the upcoming hearing [60] via Zoom on October 7, 2021, at 2:30 p.m. in the West Palm Beach Division before Magistrate Judge William Matthewman. Defendant shall file a response by noon 12:00 p.m. on October 7, 2021. No reply shall be filed. Plaintiff shall email (Matthewman@flsd.uscourts.gov) the video deposition at issue to the Court by or before noon 12:00 p.m. on October 6, 2021 and file noticing of having done so in the record. Signed by Magistrate Judge William Matthewman on 10/5/2021. (jb02)
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| 64 |
Filed: 10/4/2021, Entered: 10/4/2021, Terminated: 10/13/2021 |
Motion to Compel |
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MOTION to Compel ( Responses due by 10/18/2021), MOTION for Sanctions , MOTION (a) for an order overruling all improper objections raised by, and on behalf of, Defendant; (b) requiring Defendant to produce satisfactory answers during Plaintiffs rescheduled Deposition; (c) for an additional time to conduct Defendants deposition; (d) for the appointment of a Special Master to oversee the Defendants rescheduled deposition; (e) for Defendant to be required to appear in person for the Defendants rescheduled deposition; (f) for an award of sanctions for Plaintiffs reasonable expenses incurred, which includes Plaintiffs reasonable attorneys fees, and costs relating to the court reporter, deposition transcripts from Defendants first deposition; (g) for a protective order which prevents Plaintiff and Plaintiffs counsel from continuing to undertake the improper and dilatory conduct present at Defendants first deposition. by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit A - Notice of Taking Deposition Duces Tecum of Matthew Proman, # (2) Exhibit B - Deposition Transcripts)(Ludwin, Adam)
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Request |
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| 63 |
Filed: 10/3/2021, Entered: 10/3/2021 |
Reply to Response to motion |
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Corrected REPLY to Response to Motion re [59] MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production MOTION for Sanctions filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit A)(Ludwin, Adam)
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Request |
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| 62 |
Filed: 10/1/2021, Entered: 10/1/2021 |
Reply to Response to motion |
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REPLY to Response to Motion re [59] MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production MOTION for Sanctions filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit A - Deposition Excerpt of Matthew Proman)(Ludwin, Adam)
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Request |
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| 61 |
Filed: 9/27/2021, Entered: 9/27/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [59] MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production MOTION for Sanctions filed by Matthew B Proman. Replies due by 10/4/2021. (Attachments: # (1) Exhibit FELONY COMPLAINT, # (2) Exhibit RESPONSE TO REQUEST FOR PRODUCTION, # (3) Exhibit REQUEST FOR PRODUCTION, # (4) Exhibit EMAIL REGARDING SERVICE, # (5) Exhibit SERVICE OF COURT DOCUMENTS)(Tatelbaum, Charles)
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Request |
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| 60 |
Filed: 9/21/2021, Entered: 9/21/2021 |
Order |
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PAPERLESS ORDER SETTING HEARING AND REQUIRING A JOINT NOTICE: The Court has carefully reviewed Plaintiffs' Motion To Compel, To Overrule The Objections, And To Provide Complete And Responsive Answers To Requests For Production And For Sanctions [59]. This Motion exceeds the page limit set forth in the Court's Order Setting Discovery Procedure [58]. The Motion also fails to comply with Southern District of Florida Local Rule 7.1(a)(3), which requires counsel for the moving party to certify at the end of the motion and above the signature block that counsel has "confer[red] (orally or in writing), or ma[de] reasonable effort to confer (orally or in writing), with all parties or non-parties who may be affected by the relief sought in the motion." However, in light of the facts alleged in the Motion and in the interest of judicial economy and conservation of party resources, the Court will nevertheless consider the Motion, but will address these deficiencies at the scheduled hearing. All future discovery motions, responses, and replies shall comply with Court orders and the applicable rules. Defendant shall respond by September 28, 2021, and Plaintiff shall reply by October 1, 2021. The parties shall carefully read and otherwise comply with the Order Setting Discovery Procedure [58]. A hearing on the Motion shall be conducted via Zoom video teleconference (VTC) on October 7, 2021, at 2:30 p.m. in the West Palm Beach Division before Magistrate Judge William Matthewman. The undersigned's Courtroom Deputy, Ken Zuniga, will, at a later date, email instructions for accessing the Zoom VTC hearing to counsel. In advance of the scheduled hearing, the Court directs the parties' counsel to confer, either in person or by telephone, in good faith and for as long as necessary to address the pending discovery dispute. Thereafter, counsel for the parties shall file, on or before October 5, 2021, a Joint Notice advising whether the discovery dispute has been resolved, and if not, what specific issues remain for determination by the Court and a brief recitation of the position of Plaintiff and Defendant on each specific issue. The Court shall consider sanctions or cost-shifting under Rule 37 or other applicable rules and law against any party or counsel who fails to comply with all discovery obligations, fails to comply with applicable rules and orders, or who takes a frivolous, dilatory, or unreasonable discovery position. If the parties resolve the disputes raised in this Motion in whole or in part prior to the hearing, the Court shall be promptly notified. Signed by Magistrate Judge William Matthewman on 9/21/2021. (jb02)
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| 59 |
Filed: 9/20/2021, Entered: 9/20/2021, Terminated: 10/15/2021 |
Motion to Compel |
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MOTION to Compel Full and Complete Responses to Plaintiff's Request for Production ( Responses due by 10/4/2021), MOTION for Sanctions by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Exhibit A - Plaintiff's First Requests for Production, # (2) Exhibit B - Defendant's Responses to Plaintiff's Requests for Production)(Ludwin, Adam)
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Request |
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| 58 |
Filed: 9/3/2021, Entered: 9/3/2021 |
Order |
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ORDER SETTING DISCOVERY PROCEDURE re [41] Scheduling Order,,,, Order Referring Case to Magistrate Judge. Signed by Magistrate Judge William Matthewman on 9/3/2021. See attached document for full details. (drz)
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Request |
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| 57 |
Filed: 9/1/2021, Entered: 9/1/2021 |
Order Referring Case to Magistrate Judge |
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CORRECTED REFERRAL TO MAGISTRATE JUDGE William Matthewman for Pretrial Non-Dispositive Matters. Magistrate Judge Alicia O. Valle no longer assigned as presider/referral judge(s) in case. Signed by Judge Rodney Smith on 9/1/2021. See attached document for full details. (drz)
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Request |
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| 56 |
Filed: 8/30/2021, Entered: 8/30/2021 |
Order on Motion to continue |
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PAPERLESS ORDER GRANTING [55] Defendant Matthew Proman's Motion for a Brief Continuance of Deposition Scheduled for August 30, 2021 (the "Motion"). Based on the nature of the dispute and to promote judicial economy, the undersigned finds that a response to the Motion is unnecessary. Accordingly, by Friday, September 3, 2021, the parties must telephonically meet and confer to select a mutually agreeable date for Defendant Proman's deposition, which must be conducted by September 17, 2021. Signed by Magistrate Judge Alicia O. Valle on 8/30/2021. (dpr)
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| 55 |
Filed: 8/27/2021, Entered: 8/27/2021, Terminated: 8/30/2021 |
Motion to Continue |
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Defendant's MOTION to Continue Defendant Proman's Deposition Scheduled for August 30, 2021 by Matthew B Proman. Responses due by 9/10/2021 (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Text of Proposed Order)(Tatelbaum, Charles)
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Request |
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| 54 |
Filed: 7/28/2021, Entered: 7/28/2021 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER GRANTING [53] Defendants' Motion for Leave of Court to Conduct the Mediation Scheduled for August 26, 2021 Virtually. The parties may conduct mediation remotely. Signed by Judge Rodney Smith on 7/28/2021. (zgs)
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| 53 |
Filed: 7/28/2021, Entered: 7/28/2021, Terminated: 7/28/2021 |
Motion for Miscellaneous Relief |
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MOTION Defendant Matthew Proman's Motion for Leave of Court to Conduct The Mediation Scheduled for August 26, 2021 Virtually re [48] ORDER Scheduling Mediation by Matthew B Proman. (Attachments: # (1) Exhibit Notice of Mediation in Another Judge Stettin matter, # (2) Text of Proposed Order Proposed Order Granting Motion)(Tatelbaum, Charles)
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Request |
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| 52 |
Filed: 7/9/2021, Entered: 7/9/2021 |
Answer to amended complaint |
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ANSWER to Amended Complaint by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 51 |
Filed: 6/24/2021, Entered: 6/24/2021 |
Amended Complaint/Amended Notice of Removal |
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AMENDED COMPLAINT against Matthew B Proman filed in response to Order Granting Motion for Leave, filed by Joanna Zeitlin, Adam M. Ludwin, Esq., Ludwin Law Group, P.A.. (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit)(Ludwin, Adam)
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Request |
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| 50 |
Filed: 6/21/2021, Entered: 6/21/2021 |
Order on motion to amend/correct |
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ORDER GRANTING [49] MOTION FOR LEAVE TO AMEND THE COMPLAINT. Clerks 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 6/24/2021. Signed by Judge Rodney Smith on 6/21/2021. See attached document for full details. (drz)
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Request |
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| 49 |
Filed: 6/19/2021, Entered: 6/19/2021, Terminated: 6/21/2021 |
Motion to Amend/Correct |
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Unopposed MOTION to Amend/Correct Complaint by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 7/6/2021 (Attachments: # (1) Exhibit Proposed Amended Complaint)(Ludwin, Adam)
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Request |
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| 48 |
Filed: 6/11/2021, Entered: 6/14/2021 |
Order scheduling Mediation. |
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ORDER Scheduling Mediation before Judge Herbert Stettin. Mediation Hearing set for 8/26/2021. Signed by Judge Rodney Smith on 6/11/2021. See attached document for full details. (drz)
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Request |
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| 47 |
Filed: 6/10/2021, Entered: 6/10/2021 |
Notice of Entry of Parties Listed into CM/ECF |
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Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Herbert Stettin. (Tatelbaum, Charles)
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Request |
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| 46 |
Filed: 6/10/2021, Entered: 6/10/2021 |
Clerk's Notice of Docket Correction - Chambers and Clerks |
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Clerks Notice of Docket Correction re [44] Clerks Notice of Docket Correction and Instruction to Filer - Attorney,. Correction Other. Wrong Error Notice Entered by Clerk. For Correct Notice See DE#[45]. (drz)
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| 45 |
Filed: 6/10/2021, Entered: 6/10/2021 |
Clerks Notice of Docket Correction and Instruction to Filer - Attorney |
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Clerks Notice to Filer re [43] Notice (Other). Parties/Mediator Not Added; ERROR - The Filer failed to add all parties from the complaint/petition/removal, etc. or the mediator. Filer is instructed to file a Notice of Entry of Parties Listed into CM/ECF and add the additional parties/mediator. (drz)
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| 44 |
Filed: 6/10/2021, Entered: 6/10/2021 |
Clerks Notice of Docket Correction and Instruction to Filer - Attorney |
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Clerks Notice to Filer re [43] Notice (Other). Pro Se Party Address Not Added; CORRECTIVE ACTION REQUIRED - Pursuant to Administrative Order 2005-38, Filer must electronically file a Notice of Current Pro Se Party Address within five (5) business days if the Motion to Withdraw is Granted. (drz)
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| 43 |
Filed: 6/10/2021, Entered: 6/10/2021 |
Notice - Other |
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NOTICE by Matthew B Proman Joint Notice of Scheduling Mediation (Tatelbaum, Charles)
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Request |
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| 42 |
Filed: 6/3/2021, Entered: 6/3/2021 |
Order referring case to mediation |
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ORDER OF REFERRAL TO MEDIATION. Mediation Deadline 12/6/2021. Signed by Judge Rodney Smith on 6/3/2021. See attached document for full details. (drz)
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Request |
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| 41 |
Filed: 6/3/2021, Entered: 6/3/2021 |
Scheduling Order |
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ORDER SETTING CIVIL TRIAL DATE, PRETRIAL DEADLINES, AND REFERRAL TO MAGISTRATE JUDGE: ( Jury Trial set for 4/25/2022 before Judge Rodney Smith., Calendar Call set for 4/19/2022 09:00 AM before Judge Rodney Smith., Amended Pleadings due by 6/19/2021., Expert Discovery due by 11/22/2021., Fact Discovery due by 11/22/2021., Joinder of Parties due by 6/19/2021., Mediation Deadline 12/6/2021., In Limine Motions due by 3/18/2022., Dispositive Motions due by 12/3/2021., Motions due by 3/18/2022., Pretrial Stipulation due by 3/18/2022.). Signed by Judge Rodney Smith on 6/3/2021. 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.
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Request |
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| 40 |
Filed: 6/1/2021, Entered: 6/1/2021 |
SCHEDULING REPORT - Rule 26(f)/16.1 |
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Joint SCHEDULING REPORT - Rule 16.1 by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Attachments: # (1) Text of Proposed Order)(Ludwin, Adam)
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Request |
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| 39 |
Filed: 6/1/2021, Entered: 6/1/2021 |
Consent to Jurisdiction by U.S. Magistrate Judge |
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Notice and Consent to Jurisdiction US Magistrate Judge signed by all parties . Filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 38 |
Filed: 5/27/2021, Entered: 5/27/2021 |
Initial Disclosures |
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Initial Disclosure(s) of Rule 26(a)(1) by Matthew B Proman (Tatelbaum, Charles)
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Request |
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| 37 |
Filed: 5/25/2021, Entered: 5/26/2021 |
Amended Order |
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AMENDED ORDER STRIKING DEFENDANT'S PROPOSED SCHEDULING ORDER re [36] Order on Motion to Strike, Signed by Judge Rodney Smith on 5/25/2021. See attached document for full details. (drz)
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Request |
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| 36 |
Filed: 5/24/2021, Entered: 5/25/2021 |
order on motion to strike |
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ORDER STRIKING DEFENDANTS PROPOSED SCHEUDLING ORDER granting [34] Motion to Strike [34] MOTION to Strike [32] SCHEDULING REPORT - Rule 26(f)/16.1 MOTION to Compel Compliance with Order [DE 28] and Local Rule 16.1 . Joint Scheduling Report due by 6/1/2021 Signed by Judge Rodney Smith on 5/24/2021. See attached document for full details. (drz)
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Request |
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| 35 |
Filed: 5/19/2021, Entered: 5/19/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [34] MOTION to Strike [32] SCHEDULING REPORT - Rule 26(f)/16.1 MOTION to Compel Compliance with Order [DE 28] and Local Rule 16.1 filed by Matthew B Proman. Replies due by 5/26/2021. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G)(Tatelbaum, Charles)
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Request |
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| 34 |
Filed: 5/7/2021, Entered: 5/7/2021, Terminated: 5/24/2021 |
Motion to Strike |
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MOTION to Strike [32] SCHEDULING REPORT - Rule 26(f)/16.1 , MOTION to Compel Compliance with Order [DE 28] and Local Rule 16.1 by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Responses due by 5/21/2021 (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit, # (4) Exhibit, # (5) Exhibit)(Ludwin, Adam)
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Request |
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| 33 |
Filed: 4/30/2021, Entered: 4/30/2021 |
Certificate of Other Affiliates/Corporate Disclosure Statement |
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Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Ludwin, Adam)
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Request |
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| 32 |
Filed: 4/29/2021, Entered: 4/29/2021 |
SCHEDULING REPORT - Rule 26(f)/16.1 |
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STRICKEN per Order DE#[36]-Defendant's SCHEDULING REPORT - Rule 26(f) by Matthew B Proman (Tatelbaum, Charles) Modified on 5/25/2021 (drz).
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Request |
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| 31 |
Filed: 4/29/2021, Entered: 4/29/2021 |
Consent to Jurisdiction by U.S. Magistrate Judge |
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STRICKEN per order DE#[36]-Defendant's Notice and Consent to Jurisdiction US Magistrate Judge NOT SIGNED by all parties . Filed by Matthew B Proman (Tatelbaum, Charles) Modified on 5/25/2021 (drz).
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Request |
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| 30 |
Filed: 4/29/2021, Entered: 4/29/2021 |
Certificate of Other Affiliates/Corporate Disclosure Statement |
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Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by Matthew B Proman (Tatelbaum, Charles)
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Request |
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| 29 |
Filed: 4/29/2021, Entered: 4/29/2021 |
Initial Disclosures |
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Initial Disclosure(s) of Defendant, Matthew Proman Re: [28] Order Requiring Joint Scheduling Report, by Matthew B Proman (Tatelbaum, Charles)
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Request |
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| 28 |
Filed: 4/15/2021, Entered: 4/15/2021 |
Order Requiring Joint Scheduling Report |
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ORDER REQUIRING JOINT SCHEDULING REPORT, CERTIFICATES OF INTERESTED PARTIES AND CORPORATE DISCLOSURE STATEMENTS. Joint Scheduling Report due by 4/30/2021 Signed by Judge Rodney Smith on 4/15/2021. See attached document for full details. (drz)
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Request |
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| 27 |
Filed: 3/23/2021, Entered: 3/23/2021 |
Order on Motion for Default Judgment |
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PAPERLESS ORDER DENYING AS MOOT [18] Plaintiff's Amended Motion for Judicial Default Against Defendant Matthew B. Proman. Signed by Judge Rodney Smith on 3/23/2021. (zgs)
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| 26 |
Filed: 3/23/2021, Entered: 3/23/2021 |
Order on Motion for Default Judgment |
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PAPERLESS ORDER DENYING AS MOOT [16] Plaintiff's Motion for Default Judgment Against Defendant Matthew B. Proman. Signed by Judge Rodney Smith on 3/23/2021. (zgs)
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| 25 |
Filed: 3/15/2021, Entered: 3/15/2021 |
Answer to Complaint |
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ANSWER and Affirmative Defenses to Complaint by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 24 |
Filed: 3/1/2021, Entered: 3/1/2021 |
Order on Motion to stay |
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ORDER denying [12] Motion to Stay this Civil Action Pending Resolution of the Parallel Criminal Action. Defendant shall file his Answer to Plaintiff's Complaint (DE [1]) no later than March 15, 2021. Signed by Judge Rodney Smith on 3/1/2021. See attached document for full details. (mc)
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Request |
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| 23 |
Filed: 2/4/2021, Entered: 2/4/2021 |
Affidavit in Opposition to Motion |
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AFFIDAVIT in Opposition re [18] Amended MOTION for Default Judgment to be entered against Defendant, Matthew Proman, for Defendant's failure to comply with the Court's Order [D.E. 11], requiring Defendant to file an Answer/Response to the Complaint "no later than De filed by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 22 |
Filed: 2/2/2021, Entered: 2/2/2021 |
Notice of Supplemental Authority |
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Notice of Supplemental Authority re [14] Response in Opposition to Motion, by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin (Attachments: # (1) Exhibit) (Ludwin, Adam)
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Request |
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| 21 |
Filed: 1/18/2021, Entered: 1/18/2021 |
Response/Reply (Other) |
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REPLY to [19] Response in Opposition to Motion, by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 20 |
Filed: 1/15/2021, Entered: 1/15/2021 |
order on motion for miscellaneous relief |
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PAPERLESS ORDER GRANTING [13] Motion for Relief from Local Rule 7.1(2). Plaintiff's Response to Defendant's Motion to Stay [DE 12] may exceed ten pages. Signed by Judge Rodney Smith on 1/15/2021. (zgs)
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| 19 |
Filed: 1/15/2021, Entered: 1/15/2021 |
response in opposition to motion |
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RESPONSE in Opposition re [18] Amended MOTION for Default Judgment to be entered against Defendant, Matthew Proman, for Defendant's failure to comply with the Court's Order [D.E. 11], requiring Defendant to file an Answer/Response to the Complaint "no later than De filed by Matthew B Proman. Replies due by 1/22/2021. (Tatelbaum, Charles)
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Request |
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| 18 |
Filed: 1/12/2021, Entered: 1/12/2021, Terminated: 3/23/2021 |
Motion for Default Judgment |
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Amended MOTION for Default Judgment to be entered against Defendant, Matthew Proman, for Defendant's failure to comply with the Court's Order [D.E. 11], requiring Defendant to file an Answer/Response to the Complaint "no later than December 14, 2020." by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 17 |
Filed: 1/12/2021, Entered: 1/12/2021 |
Response/Reply (Other) |
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Defendant's RESPONSE to [16] MOTION for Default Judgment to be entered against Defendant, Matthew Proman, for Defendant's failure to comply with the Court's Order [D.E. 11], requiring Defendant to file an Answer/Response to the Complaint "no later than December by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 16 |
Filed: 1/11/2021, Entered: 1/11/2021, Terminated: 3/23/2021 |
Motion for Default Judgment |
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MOTION for Default Judgment to be entered against Defendant, Matthew Proman, for Defendant's failure to comply with the Court's Order [D.E. 11], requiring Defendant to file an Answer/Response to the Complaint "no later than December 14, 2020." by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Ludwin, Adam)
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Request |
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| 15 |
Filed: 1/4/2021, Entered: 1/4/2021 |
Reply to Response to motion |
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REPLY to Response to Motion re [12] MOTION to Stay re [1] Complaint, Pending Resolution of the Parallel Criminal Action filed by Matthew B Proman. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D)(Tatelbaum, Charles)
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Request |
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| 14 |
Filed: 12/28/2020, Entered: 12/28/2020 |
response in opposition to motion |
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RESPONSE in Opposition re [12] MOTION to Stay re [1] Complaint, Pending Resolution of the Parallel Criminal Action filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 1/4/2021. (Ludwin, Adam)
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Request |
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| 13 |
Filed: 12/28/2020, Entered: 12/28/2020, Terminated: 1/15/2021 |
Motion for Miscellaneous Relief |
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MOTION PLAINTIFFS MOTION FOR RELIEF FROM LOCAL RULE 7.1 (2) REGARDING PLAINTIFFS RESPONSE TO DEFENDANTS MOTION FOR STAY [D.E. 12] by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. (Attachments: # (1) Text of Proposed Order)(Ludwin, Adam)
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Request |
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| 12 |
Filed: 12/14/2020, Entered: 12/14/2020, Terminated: 3/1/2021 |
Motion To Stay |
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MOTION to Stay re [1] Complaint, Pending Resolution of the Parallel Criminal Action by Matthew B Proman. Responses due by 12/28/2020 (Tatelbaum, Charles)
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Request |
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| 11 |
Filed: 12/8/2020, Entered: 12/8/2020 |
Order on Motion for Extension of Time to File Response/Reply/Answer |
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PAPERLESS ORDER GRANTING [8] Motion for Extension of Time to File Response/Answer to Complaint. Defendant's Response/Answer is due no later than December 14, 2020. Signed by Judge Rodney Smith on 12/8/2020. (lbn)
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| 10 |
Filed: 12/7/2020, Entered: 12/7/2020 |
response in opposition to motion |
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RESPONSE in Opposition re [8] MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, filed by Adam M. Ludwin, Esq., Ludwin Law Group, P.A., Joanna Zeitlin. Replies due by 12/14/2020. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D)(Ludwin, Adam)
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Request |
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| 9 |
Filed: 12/4/2020, Entered: 12/4/2020 |
Order |
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PAPERLESS ORDER: Defendant Matthew Proman's Motion for an Extension of Time to File a Response to Plaintiffs' Complaint [DE 8] indicates that Plaintiffs are opposed to the relief sought. Plaintiffs shall file a response in opposition, if any, no later than December 7, 2020. Signed by Judge Rodney Smith on 12/4/2020. (lbn)
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| 8 |
Filed: 12/4/2020, Entered: 12/4/2020, Terminated: 12/8/2020 |
Motion for Extension of Time to File Response/Reply/Answer |
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MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, by Matthew B Proman. (Tatelbaum, Charles)
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Request |
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| 7 |
Filed: 11/18/2020, Entered: 11/18/2020 |
Order on Motion to appear pro hac vice |
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PAPERLESS ORDER GRANTING [6] Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Randy Zelin, who appears as counsel for Defendant Matthew Proman. The Clerk shall permit Randy Zelin to receive Notices of Electronic Filing at email address rzelin@wilkauslander.com. Signed by Judge Rodney Smith on 11/18/2020. (lbn)
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| 6 |
Filed: 11/12/2020, Entered: 11/12/2020, Terminated: 11/18/2020 |
Motion to Appear Pro Hac Vice |
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MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Randy Zelin. Filing Fee $ 200.00 Receipt # BFLSDC-13855639 by Matthew B Proman. Responses due by 11/30/2020 (Tatelbaum, Charles)
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Request |
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| 5 |
Filed: 11/12/2020, Entered: 11/12/2020 |
Notice of Attorney Appearance |
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NOTICE of Attorney Appearance by Charles M. Tatelbaum on behalf of Matthew B Proman. Attorney Charles M. Tatelbaum added to party Matthew B Proman(pty:dft). (Tatelbaum, Charles)
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Request |
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| 4 |
Filed: 10/30/2020, Entered: 10/30/2020 |
summons returned executed |
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Acknowledgment of Service on [1] Complaint, by Joanna Zeitlin, Adam M. Ludwin, Esq., Ludwin Law Group, P.A.. Matthew B Proman (Attachments: # (1) Supplement Acknowledgment of Receipt of Process in this Cause and Acceptance of Service of Process in this Cause by Attorney Michael G. Raab, on behalf of Defendant, Matthew B. Proman, as of October 27, 2020)(Ludwin, Adam) Modified on to correct event type and text 11/2/2020 (jao).
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Request |
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| 3 |
Filed: 9/28/2020, Entered: 9/28/2020 |
Summons issued |
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Summons Issued as to Matthew B Proman. (cds)
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Request |
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| 2 |
Filed: 9/25/2020, Entered: 9/28/2020 |
Clerk's Notice of Judge Assignment |
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Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge William Matthewman 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)
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| 1 |
Filed: 9/25/2020, Entered: 9/25/2020 |
Complaint |
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COMPLAINT For DAMAGES AND INJUNCTIVE RELIEF against Matthew B Proman. Filing fees $ 400.00 receipt number AFLSDC-13588775, filed by Joanna Zeitlin, Ludwin Law Group, P.A., Adam Ludwin. (Attachments: # (1) Exhibit, # (2) Exhibit, # (3) Exhibit, # (4) Civil Cover Sheet, # (5) Summon(s))(Ludwin, Adam)
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