Garrison et al v. Sullivan & Cromwell LLP Document 1: Complaint, Attachment 1

Florida Southern District Court
Case No. 1:24-cv-20630-XXXX
Filed February 16, 2024

COMPLAINT CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17301225, filed by Shengyun Huang, Gregg Podalsky, Brandon Orr, Edwin Garrison, Vitor Vozza, Sunil Kavuri, Alexander Chernyavsky, Leandro Cabo, Chukwudozie Ezeokoli, Julie Papadakis, Kyle Rupprecht, Warren Winter, Vijeth Shetty, Ryan Henderson, Michael Norris, Michael Livieratos. (Attachments: # (1) Civil Cover Sheet, # (2) Exhibit 1, # (3) Exhibit 2, # (4) Exhibit 3, # (5) Summon(s))(Moskowitz, Adam)

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Page 1 Case 1:24-cv-20630-XXXX Document
1-1 COVER
EnteredSHEET
on FLSD Docket 02/16/2024 Page 1 of CIVIL
JS 44 (Rev. 04/21) FLSD Revised 12/02/
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a)
PLAINTIFFS (':,1*$55,621HWDORQEHKDOIRI
DEFENDANTS 68//,9$1 &520:(////3
WKHPVHOYHVDQGDOORWKHUVVLPLODUO\VLWXDWHG
(b) County of Residence of First Listed Plaintiff Miami-Dade County
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES)
(IN U.S. PLAINTIFF CASES ONLY)
NOTE:
(c) Attorneys (Firm Name, Address, and Telephone Number)
IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (If Known)
$GDP0RVNRZLW]DQG-RVHSK0.D\H
7+(026.2:,7=/$:),503//&
0DU\6WUHHW6XLWH
&RFRQXW*URYH)/
(d) Check County Where Action Arose:
II. BASIS OF JURISDICTION
‫ ܆‬
U.S. Government
‫܆‬
Plaintiff
‫ ܆‬
U.S. Government
Defendant
IV. NATURE OF SUIT
CONTRACT
‫܆‬
MIAMI- DADE
‫ ܆‬153 Recovery of Overpayment
of Veteran’s Benefits
‫ ܆‬160 Stockholders’ Suits
‫ ܆‬190 Other Contract
‫ ܆‬195 Contract Product Liability
‫ ܆‬196 Franchise
REAL PROPERTY
Diversity
(Indicate Citizenship of Parties in Item III)
‫܆‬
‫ ܆‬345 Marine Product
Liability
‫ ܆‬350 Motor Vehicle
‫ ܆‬355 Motor Vehicle
Product Liability
‫ ܆‬360 Other Personal
Injury
‫ ܆‬362 Personal Injury Med. Malpractice
CIVIL RIGHTS
INDIAN RIVER
OKEECHOBEE
HIGHLANDS
and One Box for Defendant)
PTF DEF
DEF

‫ ܆‬
Incorporated or Principal Place
of Business In This State
‫ ܆‬
‫܆‬
Citizen of Another State
‫ ܆‬
‫ ܆‬
Incorporated and Principal Place
of Business In Another State
‫ ܆‬
‫ ܆‬;
Citizen or Subject of a
Foreign Country
‫ ܆‬
‫ ܆‬
Foreign Nation
‫ ܆‬
‫ ܆‬
(Place an “X” in One Box Only)
TORTS
Click here for: Nature of Suit Code Descriptions
FORFEITURE/PENALTY
BANKRUPTCY
PERSONAL INJURY
‫ ܆‬365 Personal Injury Product Liability
‫ ܆‬367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
‫ ܆‬625 Drug Related Seizure
of Property 21 USC ‫ ܆‬690 Other
‫ ܆‬422 Appeal 28 USC ‫ ܆‬423 Withdrawal
28 USC INTELLECTUAL PROPERTY
RIGHTS
‫ ܆‬820 Copyrights
‫ ܆‬830 Patent
Patent – Abbreviated
‫ ܆‬835New
Drug Application
‫ ܆‬840 Trademark
Defend Trade Secrets
‫ ܆‬Act of
368 Asbestos Personal
‫ ܆‬Injury Product Liability
PERSONAL PROPERTY
‫ ܆‬370 Other Fraud
‫ ܆‬371 Truth in Lending
‫ ܆‬380 Other Personal
Property Damage
‫ ܆‬385 Property Damage
Product Liability
LABOR
710 Fair Labor Standards Acts
720 Labor/Mgmt. Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
‫ ܆‬790 Other Labor Litigation
‫ ܆‬791 Employee Retirement
Income Security Act
‫܆‬
‫܆‬
‫܆‬
‫܆‬
‫܆‬
‫܆‬
‫܆‬
‫܆‬
‫܆‬
PRISONER PETITIONS
‫ ܆‬441 Voting
‫܆‬
(For Diversity Cases Only)
PTF
Citizen of This State
‫ ܆‬340 Marine
ST. LUCIE
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)
‫܆‬
‫ ܆‬220 Foreclosure
V.
MARTIN
(U.S. Government Not a Party)
‫ ܆‬440 Other Civil Rights
‫܆‬
‫܆‬
‫܆‬
PALM BEACH
Federal Question
‫ ܆‬210 Land Condemnation
‫܆‬
BROWARD
(Place an “X” in One Box Only)
PERSONAL INJURY
‫ ܆‬110 Insurance
‫ ܆‬120 Marine
‫ ܆‬310 Airplane
‫ ܆‬130 Miller Act
‫ ܆‬315 Airplane Product
‫ ܆‬140 Negotiable Instrument
Liability
‫ ܆‬150 Recovery of Overpayment
‫ ܆‬320 Assault, Libel &
& Enforcement of Judgment
Slander
‫ ܆‬151 Medicare Act
‫ ܆‬330 Federal Employers’
Recovery of Defaulted
Liability
‫ ܆‬Student Loans
(Excl. Veterans)
MONROE
Habeas Corpus:
‫܆‬
OTHER STATUTES
‫ ܆‬375 False Claims Act
‫ ܆‬376 Qui Tam (31 USC 3729(a))
400 State Reapportionment
‫ ܆‬410 Antitrust
‫ ܆‬430 Banks and Banking
‫ ܆‬450 Commerce
‫ ܆‬460 Deportation
Racketeer Influenced
‫ ܆‬and Corrupt Organizations
Consumer Credit
‫ ܆‬480(USC 1681 or 1692)
Telephone
Consumer
SOCIAL SECURITY
‫ ܆‬Protection Act (TCPA)
861 HIA (1395ff)
‫ ܆‬490 Cable/Sat TV
862 Black Lung (923)
‫ ܆‬850 Securities/Commodities/
863 DIWC/DIWW (405(g))
Exchange
864 SSID Title XVI
‫ ܆‬890 Other Statutory Actions
865 RSI (405(g))
‫ ܆‬891 Agricultural Acts
‫ ܆‬893 Environmental Matters
‫ ܆‬895 Freedom of Information Act
‫ ܆‬896 Arbitration
FEDERAL TAX SUITS
‫ ܆‬899 Administrative Procedure
870 Taxes (U.S. Plaintiff or
Act/Review or Appeal of
Defendant)
Agency Decision
871 IRS—Third Party 26 USC ‫ ܆‬950 Constitutionality of
State Statutes
‫ ܆‬463 Alien Detainee
‫܆‬
Motions to Vacate
230 Rent Lease & Ejectment
‫ ܆‬442 Employment
‫ ܆‬Sentence
Housing/
240 Torts to Land
‫ ܆‬530 General
‫ ܆‬Accommodations
245 Tort Product Liability
IMMIGRATION
‫ ܆‬445 Amer. w/Disabilities - ‫ ܆‬535 Death Penalty
290 All Other Real Property
Employment
Other:
‫ ܆‬462 Naturalization Application
‫ ܆‬446 Amer. w/Disabilities - ‫ ܆‬540 Mandamus & Other ‫ ܆‬465 Other Immigration
Other
‫ ܆‬550 Civil Rights
Actions
‫ ܆‬448 Education
‫ ܆‬555 Prison Condition
560 Civil Detainee –
‫ ܆‬Conditions of
Confinement
(Place an “X” in One Box Only)
ORIGIN
‫ ܆‬6 Multidistrict
Transferred from
1 Original
‫ ܆‬7 Appeal to
‫ ܆‬8 Multidistrict
‫ ܆‬2 Removed ‫ ܆‬3 Re-filed ‫ ܆‬4 Reinstated ‫ ܆‬5 another district
Remanded from
Litigation
or
(See VI
from State
Proceeding
District Judge
Litigation ‫ ܆‬9 Appellate Court
Transfer
(specify)
Reopened
below)
Court
– Direct
from Magistrate
File
Judgment
VI. RELATED/
RE-FILED CASE(S)
(See instructions): a) Re-filed Case
JUDGE:
‫܆‬YES ‫ ܆‬NO
Judge K. Michael Moore
FY
b) Related Cases ‫܆‬YES ‫ ܆‬NO
DOCKET NUMBER: PG
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):
VII. CAUSE OF ACTION Fla. Stat. §517.07. and § 501.201,
LENGTH OF TRIAL via
VIII. REQUESTED IN
COMPLAINT:
days estimated (for both sides to try entire case)
; CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P.
DEMAND $
CHECK YES only if demanded in complaint:
JURY DEMAND:
ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE
SIGNATURE OF ATTORNEY OF RECORD
6
FOR OFFICE USE ONLY : RECEIPT #
/s/ Adam Moskowitz
AMOUNT
IFP
JUDGE
MAG JUDGE
‫ ܆‬Yes
‫ ܆‬No
Page 2 Case 1:24-cv-20630-XXXX Document 1-1 Entered on FLSD Docket 02/16/2024 Page 2 of
JS 44 (Rev. 04/21) FLSD Revised 12/02/
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the
use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil
complaint filed. The attorney filing a case should complete the form as follows:
I.
(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official,
giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation
cases, the county of residence of the “defendant” is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section “(see attachment)”.
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in
one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and
box 1 or 2 should be marked. Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box is checked, the citizenship of the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature of Suit. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of
suit code that is most applicable. Click here for: Nature of Suit Code Descriptions.
V.
Origin. Place an “X” in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
for removal is granted, check this box.
Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this
box is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.
Remanded from Appellate Court. (8) Check this box if remanded from Appellate Court.
VI.
Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the
corresponding judges name for such cases.
VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC Brief Description: Unauthorized reception of cable service
VIII. Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
Date and Attorney Signature. Date and sign the civil cover sheet.
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