Rajaee v. Davis et al
Plaintiff: Ashkan Rajaee
Defendant: Tyler Brandon Davis, Scott Carpenter, J. Douglas Kirk, ESQ Joseph W Scalia, Kerri A Williams-Horn, Joshua Paul Lintz, Micah Bailey, Jonathan Gerber, Jenifer Bryn Guadagnin, Kenneth R Reynolds, Michael Hawes, Amanda Frye, TOPDEVZ, LLC, Porter Consulting, LLC, Mason Building and Design LLC, Talentcrowd, LLC, Cummins & White, LLP, Kirk & Toberty, LLC, Law Offices of Joseph W. Scalia APC, Purdy & Bailey, LLP, Miller Miller Gerber LLP, Kenneth R. Reynolds, INC, Sandhills Global, Inc., Express Tech-Financing, LLC, 402 Ventures, LLC, Blockchain Game Partners, Inc. a Wyoming Corporation doing business as Gala Games, Drivetime Car Sales Company, LLC, Mode Transportation, LLC, Medical Staffing Solutions, Inc., Intellicheck, Inc., Scott McKinney, Shawn Peed, Adam Price, Aaron Price, Aaron Mciver, Peter Grisolano, Sean Clancy, Anthony Vargas, James Marsh, Frank Lubin, Russ Embry and Does 1 through 99
Case Number: 3:2024cv00001
Filed: January 2, 2024
Court: US District Court for the Southern District of California
Presiding Judge: Karen S Crawford
Referring Judge: Robert S Huie
Nature of Suit: Other Fraud
Cause of Action: 28 U.S.C. § 1332 fr Diversity-Fraud
Jury Demanded By: Defendant
Docket Report

This docket was last retrieved on March 1, 2024. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 1, 2024 Filing 87 NOTICE AMENDED NOTICE OF MOTION AND MOTION TO DISMISS ASSERTED BY DEFENDANTS SCOTT MCKINNEY AND SHAWN PEED FOR LACK OF PERSONAL JURISDICTION by Scott McKinney, Shawn Peed (Yudelson, David)
March 1, 2024 Filing 86 NOTICE AMENDED NOTICE OF MOTION AND MOTION TO DISMISS WITH PREJUDICE ASSERTED BY DEFENDANTS SANDHILLS GLOBAL, INC., EXPRESS TECH-FINANCING, LLC, AND 402 VENTURES, LLC by 402 Ventures, LLC, Express Tech-Financing, LLC, Sandhills Global, Inc. (Yudelson, David)
March 1, 2024 Filing 85 REPLY to Response to Motion re #23 MOTION to Dismiss with Prejudice DEFENDANT SANDHILLS GLOBAL, INC., EXPRESS TECH-FINANCING, LLC AND 402 VENTURES, LLCS REPLY TO PLAINTIFFS OPPOSITION TO THEIR MOTION TO DISMISS PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE 8(a)(2), 12(b)(1), & 12(b)(6) filed by 402 Ventures, LLC, Express Tech-Financing, LLC, Sandhills Global, Inc.. (Yudelson, David)
March 1, 2024 Filing 84 REPLY to Response to Motion re #24 MOTION to Dismiss DEFENDANTS SHAWN PEED AND SCOTT MCKINNEYS REPLY TO PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION filed by Scott McKinney, Shawn Peed. (Yudelson, David)
February 29, 2024 Filing 83 REPLY to Response to Motion re #25 MOTION to Dismiss Pursuant to FRCP 12(b) and 12(b)(6) and Joinder in Motion of Defendants Scott Carpenter, Esq., and Cummins & White, LLP, to Dismiss filed by Russ Embry, Intellicheck, Inc., Frank Lubin. (Guess, Philip) (alns).
February 28, 2024 Filing 82 MOTION to Dismiss Defendants Mode Transportation, LLC, Sean Clancy and Anthony Vargas Notice of Motion and Motion to Dismiss Pursuant to Federal Rules of Civil Procedure 12(B)(1) and 12(B)(6) and Notice of Joinder and Joinder to Defendants Scott Carpenter, Esq. and Cummins & White, LLP's Motion to Dismiss [Doc. No. 8] by Sean Clancy, Mode Transportation, LLC, Anthony Vargas. (Attachments: #1 Memo of Points and Authorities)(Mysliwiec, John) (alns).
February 28, 2024 Filing 81 DECLARATION re #79 MOTION to Dismiss for Lack of Jurisdiction Defendants Sean Clancy and Anthony Vargas Notice of Motion and Motion to Dismiss Plaintiffs Complaint for Lack of Personal Jurisdiction Pursuant to Federal Rules of Civil Procedure (12(b)(2), #80 Declaration, Declaration of Anthony Vargas by Defendants Sean Clancy, Mode Transportation, LLC, Anthony Vargas. (Mysliwiec, John) (alns).
February 28, 2024 Filing 80 DECLARATION re #79 MOTION to Dismiss for Lack of Jurisdiction Defendants Sean Clancy and Anthony Vargas Notice of Motion and Motion to Dismiss Plaintiffs Complaint for Lack of Personal Jurisdiction Pursuant to Federal Rules of Civil Procedure (12(b)(2) Declaration of Sean Clancy by Defendants Sean Clancy, Mode Transportation, LLC, Anthony Vargas. (Mysliwiec, John) (alns).
February 28, 2024 Filing 79 MOTION to Dismiss for Lack of Jurisdiction Defendants Sean Clancy and Anthony Vargas Notice of Motion and Motion to Dismiss Plaintiffs Complaint for Lack of Personal Jurisdiction Pursuant to Federal Rules of Civil Procedure (12(b)(2) by Sean Clancy, Mode Transportation, LLC, Anthony Vargas. (Attachments: #1 Memo of Points and Authorities)(Mysliwiec, John) (alns).
February 28, 2024 Filing 78 REPLY to Response to Motion re #18 MOTION to Dismiss for Failure to State a Claim filed by Talentcrowd, LLC. (Attachments: #1 Proof of Service)(Leetham, Tamara) (alns).
February 28, 2024 Filing 77 RESPONSE in Opposition re #33 MOTION to Dismiss for Lack of Jurisdiction filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 33 Defendant Gala Games Motion to Dismiss)(Rajaee, Ashkan )
February 27, 2024 Filing 76 RESPONSE in Opposition re #32 MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition to ECF 32 Amanda Frye's Motion to Dismiss, #2 Supplement Plaintiff s Objections to Evidence file ISO Amanda Frye Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 27, 2024 Filing 75 RESPONSE in Opposition re #30 MOTION to Strike #1 Complaint,,, filed by Ashkan Rajaee. (Rajaee, Ashkan )(alns).
February 27, 2024 Filing 74 RESPONSE in Opposition re #29 MOTION to Dismiss for Lack of Jurisdiction Pursuant to FRCP 12(b)(1) & 12(b)(6) filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 29 Defendnats Kirk and Kirk and Toberty's Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 27, 2024 Filing 73 REPLY to Response to Motion re #17 MOTION to Strike #1 Complaint,,, Anti-SLAPP filed by Kenneth R. Reynolds, INC, Kenneth R Reynolds. (Attachments: #1 Proof of Service)(Brooks, Kenny) (alns).
February 27, 2024 Filing 72 REPLY to Response to Motion re #16 MOTION to Dismiss filed by Kenneth R. Reynolds, INC, Kenneth R Reynolds. (Attachments: #1 Proof of Service)(Brooks, Kenny) (alns).
February 26, 2024 Filing 71 REPLY to Response to Motion re #9 MOTION to Stay re #1 Complaint,,, MOTION to Strike #1 Complaint,,, filed by Scott Carpenter, Cummins & White, LLP. (Attachments: #1 Notice Response to Plaintiff's Objections to Evidence, #2 Notice Defendants' Objections to Plaintiff's Purported Evidence, #3 Proof of Service)(Joens, Timothy) (alns).
February 26, 2024 Filing 70 REPLY to Response to Motion re #8 MOTION to Dismiss for Failure to State a Claim MOTION to Dismiss for Lack of Jurisdiction filed by Scott Carpenter, Cummins & White, LLP. (Attachments: #1 Proof of Service)(Joens, Timothy) (alns).
February 26, 2024 Filing 69 MOTION to Dismiss (FRCP 12B) by Mason Building and Design LLC. (Attachments: #1 Memo of Points and Authorities, #2 Proof of Service)(Brooks, Kenny)Attorney Kenny C Brooks added to party Mason Building and Design LLC(pty:dft) M (alns).
February 26, 2024 Filing 68 MOTION to Dismiss (FRCP 12B) by Kerri A Williams-Horn. (Attachments: #1 Memo of Points and Authorities, #2 Proof of Service)(Brooks, Kenny)Attorney Kenny C Brooks added to party Kerri A Williams-Horn(pty:dft) (alns).
February 26, 2024 Filing 67 Clerk's ENTRY OF DEFAULT as to James Marsh, Medical Staffing Solutions, Inc. (All non-registered users served via U.S. Mail Service)(alns) (anh).
February 26, 2024 Opinion or Order Filing 66 ORDER Approving the Pro Hac Vice Application of Monica S. Call (Re: ECF No. #65 Request to Appear Pro Hac Vice). Signed by District Judge Robert S. Huie on 2/26/2024.(jrd)
February 26, 2024 Filing 65 Request to Appear Pro Hac Vice (Filing fee received: $224.00 receipt number ACASDC-18617686.)(Application to be reviewed by Clerk.) (Call, Monica)(jrd)
February 26, 2024 Filing 64 RESPONSE in Opposition re #27 MOTION to Strike #1 Complaint,,, filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 27 Purdy & Bailey and Micah Bailey Motion to Strike)(Rajaee, Ashkan ) (alns).
February 26, 2024 Filing 63 RESPONSE in Opposition re #28 MOTION to Dismiss for Failure to State a Claim MOTION to Dismiss for Lack of Jurisdiction filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition to Defendants Purdy & Bailey and Micah Bailey s Motion to Dismiss ECF 28, #2 Supplement Plaintiff s Objections to Evidence file ISO Purdy & Bailey and Micah Bailey Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 26, 2024 Filing 62 Notice: Judge Crawfords Civil Chambers Rules, General Considerations for Written Discovery, and Zoom Guidelines are updated effective February 22, 2024 and are available on the Courts website. The parties must familiarize themselves with these publications. (All non-registered users served via U.S. Mail Service)(no document attached) (alns)
February 22, 2024 Filing 61 RESPONSE in Opposition re #25 MOTION to Dismiss Pursuant to FRCP 12(b) and 12(b)(6) and Joinder in Motion of Defendants Scott Carpenter, Esq., and Cummins & White, LLP, to Dismiss [Doc. No. 8] filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 25 Intellicheck Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 22, 2024 Filing 60 RESPONSE in Opposition re #24 MOTION to Dismiss filed by Ashkan Rajaee. (Attachments: #1 Declaration 2-Plaintiff s Declaration ISO Opposition ECF 24 McKinney-Peed Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 21, 2024 Filing 59 NOTICE of Joinder by Peter Grisolano, Aaron Mciver re #45 MOTION to Dismiss for Lack of Jurisdiction Defendant Drivetime Car Sales Company, LLC's Notice of Motion and Motion to Dismiss Plaintiff's Complaint Pursuant to Federal Rules of Civil Procedure 12(b(1) and 12(b)(6) (Attachments: #1 Memo of Points and Authorities, #2 Proof of Service)(Schroedter, Maggie) (alns).
February 21, 2024 Filing 58 RESPONSE in Opposition re #23 MOTION to Dismiss with Prejudice filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 23 Sandhills Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 21, 2024 Filing 57 MOTION to Dismiss for Lack of Jurisdiction (Personal) by Peter Grisolano, Aaron Mciver. (Attachments: #1 Memo of Points and Authorities, #2 Declaration of Peter Grisolano, #3 Declaration of Aaron McIver, #4 Proof of Service)(Robberson, Mary)Attorney Mary R. Robberson added to party Peter Grisolano(pty:dft), Attorney Mary R. Robberson added to party Aaron Mciver(pty:dft) (alns).
February 21, 2024 Filing 56 RESPONSE in Opposition re #18 MOTION to Dismiss for Failure to State a Claim filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition ECF 18 Talentcrowd Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 21, 2024 Filing 55 RESPONSE in Opposition re #17 MOTION to Strike #1 Complaint,,, Anti-SLAPP filed by Ashkan Rajaee. (Rajaee, Ashkan ) (alns).
February 21, 2024 Filing 54 RESPONSE in Opposition re #16 MOTION to Dismiss filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition to Defendants Reynolds Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 20, 2024 Filing 53 MOTION for Entry of Default Against Defendants Medical Staffing Solutions, Inc and James Marsh by Ashkan Rajaee. (Rajaee, Ashkan ) (alns).
February 16, 2024 Filing 52 RESPONSE re #22 Notice of Joinder TO MOTION OF DEFENDANTS SCOTT CARPENTER, ESQ., AND CUMMINS & WHITE, LLP, TO DISMISS #8 filed by Ashkan Rajaee. (Rajaee, Ashkan ) (alns).
February 16, 2024 Filing 51 RESPONSE in Opposition re #7 MOTION to Strike #1 Complaint,,, filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition To Defendants Miller Miller Gerber and Gerber Motion to Strike)(Rajaee, Ashkan ) (alns).
February 16, 2024 Filing 50 RESPONSE in Opposition re #8 MOTION to Dismiss for Failure to State a Claim MOTION to Dismiss for Lack of Jurisdiction filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition to Carpenter & Cummins and White Motion to Dismiss, #2 Declaration Todd Belluomini s Declaration ISO Opposition to Carpenter & Cummins and White Motion to Dismiss)(Rajaee, Ashkan ) (alns).
February 16, 2024 Opinion or Order Filing 49 ORDER Denying #26 Plaintiff's Motion to Compel Setting of Rule 26(f) Conference. Signed by Magistrate Judge Karen S. Crawford on 2/16/2024. (rmc) Modified on 2/16/2024 to correct signature name (rmc).
February 15, 2024 Filing 48 RESPONSE in Opposition re #9 MOTION to Stay re #1 Complaint,,, MOTION to Strike #1 Complaint,,, filed by Ashkan Rajaee. (Attachments: #1 Declaration Plaintiff s Declaration ISO Opposition to Carpenter & Cummins and White LLP Motion to Strike, #2 Supplement Plaintiff s Objections to Evidence file ISO Carpenter & Cummins and White LLP Motion to Strike)(Rajaee, Ashkan ) (rmc).
February 14, 2024 Filing 47 MOTION to Dismiss for Lack of Jurisdiction (Personal) by Drivetime Car Sales Company, LLC. (Attachments: #1 Memo of Points and Authorities, #2 Declaration of Aaron McIver, #3 Exhibit A, #4 Exhibit B, #5 Proof of Service)(Robberson, Mary)Attorney Mary R. Robberson added to party Drivetime Car Sales Company, LLC(pty:dft) (alns).
February 14, 2024 Filing 46 SUMMONS Returned Executed by Ashkan Rajaee. James Marsh, Medical Staffing Solutions, Inc. served. (Attachments: #1 Proof of Service)(Rajaee, Ashkan ) (alns).
February 14, 2024 Filing 45 MOTION to Dismiss for Lack of Jurisdiction Defendant Drivetime Car Sales Company, LLC's Notice of Motion and Motion to Dismiss Plaintiff's Complaint Pursuant to Federal Rules of Civil Procedure 12(b(1) and 12(b)(6) by Drivetime Car Sales Company, LLC. (Attachments: #1 Memo of Points and Authorities)(Schroedter, Maggie) (alns).
February 13, 2024 Opinion or Order Filing 44 ORDER Approving the Pro Hac Vice Application of John V. Matson (Re: ECF No. #42 Request to Appear Pro Hac Vice). Signed by District Judge Robert S. Huie on 2/13/2024.(jrd)
February 13, 2024 Opinion or Order Filing 43 ORDER Granting Motion For Extension Of Time To Respond To Plaintiffs Complaint(ECF No. #41 ). Signed by District Judge Robert S. Huie on 2/13/2024. (All non-registered users served via U.S. Mail Service)(alns)
February 13, 2024 Filing 42 Request to Appear Pro Hac Vice, No payment Submitted. (Application to be reviewed by Clerk.) (Matson, John) (jrd)
February 12, 2024 Filing 41 Joint MOTION for Extension of Time to File Response/Reply to Complaint by Mode Transportation, LLC. (Attachments: #1 Declaration Declaration of John Mysliwiec)(Mysliwiec, John) (alns).
February 12, 2024 Filing 40 Request to Appear Pro Hac Vice ( Filing fee received: $ 224 receipt number ACASDC-18578023.) (Application to be reviewed by Clerk.) (Matson, John) QC mail sent - not signed (rmc).
February 9, 2024 Filing 39 NOTICE of Joinder by Kenneth R Reynolds re #35 Response in Opposition to Motion (Brooks, Kenny) (alns).
February 9, 2024 Filing 38 DEMAND for Trial by Jury by Kenneth R Reynolds. (Attachments: #1 Proof of Service)(Brooks, Kenny) (alns).
February 9, 2024 Filing 37 Proof Of Service Of Defendant Mode Transportation, LLCs Notice Of Motion And Ex Parte Motion For Extension Of Time To Answer Or Otherwise Respond To The Verified Complaint by Mode Transportation, LLC. (Mysliwiec, John) (alns). (alns).
February 9, 2024 Opinion or Order Filing 36 ORDER Granting Motion For Extension Of Time To Respond To Plaintiffs Complaint(ECF No. #34 ). Signed by District Judge Robert S. Huie on 2/9/2024. (All non-registered users served via U.S. Mail Service)(alns) (anh).
February 8, 2024 Filing 35 RESPONSE in Opposition re #26 MOTION to Compel Setting of Rule 26 Conference filed by Scott Carpenter, Cummins & White, LLP. (Attachments: #1 Proof of Service)(Joens, Timothy) (alns).
February 8, 2024 Filing 34 Ex Parte MOTION for Extension of Time to File Answer re #1 Complaint,,, of Rajaee filed 01/02/2024 by Kerri A Williams-Horn. (Attachments: #1 Memo of Points and Authorities Extension time, #2 Declaration K Reynolds, #3 Proof of Service Ex parte extend time)(Reynolds, Kenneth)Attorney Kenneth Ross Reynolds added to party Kerri A Williams-Horn(pty:dft) (alns).
February 7, 2024 Filing 33 MOTION to Dismiss for Lack of Jurisdiction by Blockchain Game Partners, Inc., Aaron Price, Adam Price. (Attachments: #1 Declaration of Aaron Price in Support, #2 Declaration of Adam Price in Support)(Walker, Jessica)Attorney Jessica Nicole Walker added to party Blockchain Game Partners, Inc.(pty:dft), Attorney Jessica Nicole Walker added to party Aaron Price(pty:dft), Attorney Jessica Nicole Walker added to party Adam Price(pty:dft) (alns).
February 6, 2024 Filing 32 MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) by Amanda Frye. (Attachments: #1 Memo of Points and Authorities, #2 Request for Judicial Notice, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Proof of Service)(Leetham, Tamara)Attorney Tamara M. Leetham added to party Amanda Frye(pty:dft) (alns).
February 6, 2024 Filing 31 DEMAND for Trial by Jury by J. Douglas Kirk, Kirk & Toberty, LLC. (Attachments: #1 Proof of Service Proof of Service)(Joens, Timothy) (alns).
February 6, 2024 Filing 30 MOTION to Strike #1 Complaint,,, by J. Douglas Kirk, Kirk & Toberty, LLC. (Attachments: #1 Memo of Points and Authorities Memorandum of Points & Authorities in Support of Special Motion to Strike, #2 Declaration Declaration of J. Douglas Kirk in Support of Special Motion to Strike, #3 Exhibit Exhibit A - Judgment #1, #4 Exhibit Exhibit B - Judgment #2, #5 Exhibit Exhibit C - Objections to Subpoena, #6 Proof of Service Proof of Service)(Joens, Timothy) (alns).
February 6, 2024 Filing 29 MOTION to Dismiss for Lack of Jurisdiction Pursuant to FRCP 12(b)(1) & 12(b)(6) by J. Douglas Kirk, Kirk & Toberty, LLC. (Attachments: #1 Memo of Points and Authorities Memorandum of Points & Authorities in Support of Motion to Dismiss Pursuant to FRCP 12(b)(1) & 12(b)(6), #2 Proof of Service Proof of Service)(Joens, Timothy)Attorney Timothy L. Joens added to party J. Douglas Kirk(pty:dft), Attorney Timothy L. Joens added to party Kirk & Toberty, LLC(pty:dft) (alns).
February 5, 2024 Filing 28 MOTION to Dismiss for Failure to State a Claim , MOTION to Dismiss for Lack of Jurisdiction by Micah Bailey, Purdy & Bailey, LLP. (Attachments: #1 Memo of Points and Authorities, #2 Request for Judicial Notice, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10)(Bailey, Micah) (alns).
February 5, 2024 Filing 27 MOTION to Strike #1 Complaint,,, by Micah Bailey, Purdy & Bailey, LLP. (Attachments: #1 Memo of Points and Authorities, #2 Declaration)(Bailey, Micah)Attorney Micah L. Bailey added to party Micah Bailey(pty:dft), Attorney Micah L. Bailey added to party Purdy & Bailey, LLP(pty:dft) (alns).
February 5, 2024 Filing 26 MOTION to Compel Setting of Rule 26 Conference by Ashkan Rajaee. (Attachments: #1 Declaration Declaration ISO Motion to compel)(Rajaee, Ashkan )
February 1, 2024 Filing 25 MOTION to Dismiss Pursuant to FRCP 12(b) and 12(b)(6) and Joinder in Motion of Defendants Scott Carpenter, Esq., and Cummins & White, LLP, to Dismiss by Russ Embry, Intellicheck, Inc., Frank Lubin. (Attachments: #1 Memo of Points and Authorities)(Guess, Philip)Attorney Philip M. Guess added to party Russ Embry(pty:dft), Attorney Philip M. Guess added to party Intellicheck, Inc.(pty:dft), Attorney Philip M. Guess added to party Frank Lubin(pty:dft) (alns).
February 1, 2024 Filing 24 MOTION to Dismiss by Scott McKinney, Shawn Peed. (Attachments: #1 Memo of Points and Authorities, #2 Dec of Shawn Peed, #3 Dec of Scott McKinney)(Yudelson, David)Attorney David A. Yudelson added to party Scott McKinney(pty:dft), Attorney David A. Yudelson added to party Shawn Peed(pty:dft) (alns).
February 1, 2024 Filing 23 MOTION to Dismiss with Prejudice by 402 Ventures, LLC, Express Tech-Financing, LLC, Sandhills Global, Inc.. (Attachments: #1 Memo of Points and Authorities, #2 Proposed Order)(Yudelson, David)Attorney David A. Yudelson added to party 402 Ventures, LLC(pty:dft), Attorney David A. Yudelson added to party Express Tech-Financing, LLC(pty:dft), Attorney David A. Yudelson added to party Sandhills Global, Inc.(pty:dft) (alns).
February 1, 2024 Filing 22 NOTICE of Joinder by Jonathan Gerber re #8 MOTION to Dismiss for Failure to State a Claim MOTION to Dismiss for Lack of Jurisdiction (Gerber, Jonathan) (alns).
February 1, 2024 Opinion or Order Filing 21 ORDER denying #19 Motion for Entry of Default. The proof of service filed by Plaintiff as to Defendant Sandhill Global Inc. does not contain sufficient detail to satisfy the Court that service has been properly effected pursuant to Cal. Civ. Proc. Code 416.10. The motion for default is denied without prejudice to refiling based on additional evidence of proper service. Signed by District Judge Robert S. Huie on 2/1/2024. (no document attached) (Huie, Robert)
February 1, 2024 Filing 20 NOTICE Request for Jury Trial by Scott Carpenter, Cummins & White, LLP re #1 Complaint,,, (Attachments: #1 Proof of Service Proof of Service)(Joens, Timothy) (alns).
February 1, 2024 Filing 19 MOTION for Entry of Default Against Sandhills Global, Inc. by Ashkan Rajaee. (Rajaee, Ashkan )
January 31, 2024 Filing 18 MOTION to Dismiss for Failure to State a Claim by Talentcrowd, LLC. (Attachments: #1 Memo of Points and Authorities, #2 Request for Judicial Notice, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10)(Leetham, Tamara)Attorney Tamara M. Leetham added to party Talentcrowd, LLC(pty:dft) (alns).
January 31, 2024 Filing 17 MOTION to Strike #1 Complaint,,, Anti-SLAPP by Kenneth R. Reynolds, INC, Kenneth R Reynolds. (Attachments: #1 Memo of Points and Authorities, #2 Declaration Declaration of Kenneth Reynolds, #3 Proof of Service)(Brooks, Kenny) (alns).
January 31, 2024 Filing 16 MOTION to Dismiss by Kenneth R. Reynolds, INC, Kenneth R Reynolds. (Attachments: #1 Memo of Points and Authorities, #2 Proof of Service)(Brooks, Kenny)Attorney Kenny C Brooks added to party Kenneth R. Reynolds, INC(pty:dft), Attorney Kenny C Brooks added to party Kenneth R Reynolds(pty:dft) (alns).
January 31, 2024 Opinion or Order Filing 15 ORDER Granting Motion For Extension Of Time To Respond To Plaintiffs Complaint(ECF No. #10 ). Signed by District Judge Robert S. Huie on 1/31/2024. (All non-registered users served via U.S. Mail Service)(alns) (anh).
January 31, 2024 Filing 14 Ex Parte MOTION for Extension of Time to File Answer re #1 Complaint,,, by Mode Transportation, LLC. (Attachments: #1 Declaration ISO Ex Parte Motion)(Mysliwiec, John)Attorney John Mysliwiec added to party Mode Transportation, LLC(pty:dft) (alns).
January 31, 2024 Opinion or Order Filing 13 ORDER: Discovery Intake Call held regarding plaintiff's request to compel defendants Scott Carpenter and Cummins & White, LLP to participate in a Fed. R. Civ. P. 26(f) conference. Plaintiff must file and serve his motion on or before February 5, 2024. Defendants Carpenter and Cummins & White, LLP must file and serve their opposition brief on or before February 9, 2024. Briefs must be properly formatted and limited to 10 pages, excluding exhibits. Signed by Magistrate Judge Karen S. Crawford on 1/31/2023.(no document attached) (kxb)
January 31, 2024 Filing 12 SUMMONS Returned Executed by Ashkan Rajaee. Blockchain Game Partners, Inc. served. (Rajaee, Ashkan )
January 31, 2024 Filing 11 SUMMONS Returned Executed by Ashkan Rajaee. Scott Carpenter, Sean Clancy, Kirk & Toberty, LLC, Frank Lubin, Mason Building and Design LLC, Adam Price, Sandhills Global, Inc., Kerri A Williams-Horn served. (Attachments: #1 Proof of Service, #2 Proof of Service, #3 Proof of Service, #4 Proof of Service, #5 Proof of Service, #6 Proof of Service, #7 Proof of Service)(Rajaee, Ashkan )
January 30, 2024 Filing 10 Ex Parte MOTION for Extension of Time to File Answer re #1 Complaint,,, Motion for Extension of Time to Respond to Plaintiff's Complaint by Drivetime Car Sales Company, LLC, Peter Grisolano, Aaron Mciver. (Attachments: #1 Memo of Points and Authorities, #2 Declaration of Maggie E. Schroedter, #3 Exhibit A to Declaration of Schroedter, #4 Proof of Service)(Schroedter, Maggie)Attorney Maggie E. Schroedter added to party Drivetime Car Sales Company, LLC(pty:dft), Attorney Maggie E. Schroedter added to party Peter Grisolano(pty:dft), Attorney Maggie E. Schroedter added to party Aaron Mciver(pty:dft) (alns).
January 29, 2024 Filing 9 MOTION to Stay re #1 Complaint,,, , MOTION to Strike #1 Complaint,,, by Scott Carpenter, Cummins & White, LLP. (Attachments: #1 Memo of Points and Authorities Memorandum of Points and Authorities in Support of Special Motion to Strike, #2 Declaration Declaration of Scott Carpenter in Support of Special Motion to Strike, #3 Exhibit Exhibit A in Support of Special Motion to Strike, #4 Exhibit Exhibit B in Support of Special Motion to Strike)(Joens, Timothy) (alns).
January 29, 2024 Filing 8 MOTION to Dismiss for Failure to State a Claim , MOTION to Dismiss for Lack of Jurisdiction by Scott Carpenter, Cummins & White, LLP. (Attachments: #1 Memo of Points and Authorities Memorandum of Points and Authorities in Support of Motion to Dismiss)(Joens, Timothy)Attorney Timothy L. Joens added to party Scott Carpenter(pty:dft), Attorney Timothy L. Joens added to party Cummins & White, LLP(pty:dft) (alns).
January 29, 2024 Filing 7 MOTION to Strike #1 Complaint,,, by Jonathan Gerber. (Gerber, Jonathan)Attorney Jonathan L. Gerber added to party Jonathan Gerber(pty:dft) (alns).
January 18, 2024 Filing 6 SUMMONS Returned Executed by Ashkan Rajaee. Cummins & White, LLP, Drivetime Car Sales Company, LLC, Russ Embry, Express Tech-Financing, LLC, Amanda Frye, Peter Grisolano, Intellicheck, Inc., Kenneth R. Reynolds, INC, Scott McKinney, Aaron Mciver, Miller Miller Gerber LLP, Mode Transportation, LLC, Shawn Peed, Aaron Price, Purdy & Bailey, LLP, Kenneth R Reynolds, Talentcrowd, LLC served. (Attachments: #1 Proof of Service SUMMONS Returned Executed Aaron Price, #2 Proof of Service SUMMONS Returned Executed Amanda Frye, #3 Proof of Service SUMMONS Returned Executed Cummins and White, #4 Proof of Service SUMMONS Returned Executed Drivetime, #5 Proof of Service SUMMONS Returned Executed Express Tech Financing, #6 Proof of Service SUMMONS Returned Executed Intellicheck, #7 Proof of Service SUMMONS Returned Executed Kenneth R. Reynolds, #8 Proof of Service SUMMONS Returned Executed Kenneth R. Reynolds, Inc, #9 Proof of Service SUMMONS Returned Executed Miller Miller Gerber, #10 Proof of Service SUMMONS Returned Executed Mode Transportation, #11 Proof of Service SUMMONS Returned Executed Peter Grisolano, #12 Proof of Service SUMMONS Returned Executed Purdy and Bailey, #13 Proof of Service SUMMONS Returned Executed Russ Embry, #14 Proof of Service SUMMONS Returned Executed Scott McKinney, #15 Proof of Service SUMMONS Returned Executed Shawn Peed, #16 Proof of Service SUMMONS Returned Executed Talentcrowd)(Rajaee, Ashkan )
January 18, 2024 Filing 5 SUMMONS Returned Executed by Ashkan Rajaee. 402 Ventures, LLC served. (Rajaee, Ashkan )
January 8, 2024 Opinion or Order Filing 4 ORDER granting #3 Motion for Leave to Electronically File Documents. Signed by District Judge Robert S. Huie on 01/08/2024. (no document attached) (crm)
January 2, 2024 Filing 3 MOTION for Leave to Electronically File Documents by Ashkan Rajaee. (alns) (anh).
January 2, 2024 Filing 2 Summons Issued. Counsel receiving this notice electronically should print this summons and serve it in accordance with Rule 4, Fed.R.Civ.P and LR 4.1. Summons has been provided to plaintiffs not receiving notice electronically. (stn) (anh).
January 2, 2024 Filing 1 COMPLAINT with Jury Demand against 402 Ventures, LLC, Micah Bailey, Blockchain Game Partners, Inc., Scott Carpenter, Cummins & White, LLP, Tyler Brandon Davis, Drivetime Car Sales Company, LLC, Express Tech-Financing, LLC, Amanda Frye, Jonathan Gerber, Jenifer Bryn Guadagnin, Michael Hawes, Kenneth R. Reynolds, INC, J. Douglas Kirk, Kirk & Toberty, LLC, Law Offices of Joseph W. Scalia APC, Joshua Paul Lintz, Mason Building and Design LLC, Miller Miller Gerber LLP, Mode Transportation, LLC, Porter Consulting, LLC, Purdy & Bailey, LLP, Kenneth R Reynolds, Sandhills Global, Inc., Joseph W Scalia, TOPDEVZ, LLC, Talentcrowd, LLC, Kerri A Williams-Horn ( Filing fee $ 405 receipt number 150427.), filed by Ashkan Rajaee. (Attachments: #1 Civil Cover Sheet, #2 Exhibit 1, #3 Exhibits 2, #4 Receipt)The new case number is 3:24-cv-1-RSH-KSC. Judge Robert S. Huie and Magistrate Judge Karen S. Crawford are assigned to the case.(stn) (anh).

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Search for this case: Rajaee v. Davis et al
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Plaintiff: Ashkan Rajaee
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Defendant: Tyler Brandon Davis
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Defendant: Scott Carpenter
Represented By: Timothy L. Joens
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Defendant: J. Douglas Kirk
Represented By: Timothy L. Joens
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Defendant: ESQ Joseph W Scalia
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Defendant: Kerri A Williams-Horn
Represented By: Kenneth Ross Reynolds
Represented By: Kenny C Brooks
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Defendant: Joshua Paul Lintz
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Defendant: Micah Bailey
Represented By: Micah L. Bailey
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Defendant: Jonathan Gerber
Represented By: Jonathan L. Gerber
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Defendant: Jenifer Bryn Guadagnin
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Defendant: Kenneth R Reynolds
Represented By: Kenny C Brooks
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Defendant: Michael Hawes
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Defendant: Amanda Frye
Represented By: Tamara M. Leetham
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Defendant: TOPDEVZ, LLC
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Defendant: Porter Consulting, LLC
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Defendant: Mason Building and Design LLC
Represented By: Kenny C Brooks
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Defendant: Talentcrowd, LLC
Represented By: Tamara M. Leetham
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Defendant: Cummins & White, LLP
Represented By: Timothy L. Joens
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Defendant: Kirk & Toberty, LLC
Represented By: Timothy L. Joens
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Defendant: Law Offices of Joseph W. Scalia APC
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Defendant: Purdy & Bailey, LLP
Represented By: Micah L. Bailey
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Defendant: Miller Miller Gerber LLP
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Defendant: Kenneth R. Reynolds, INC
Represented By: Kenny C Brooks
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Defendant: Sandhills Global, Inc.
Represented By: John V. Matson
Represented By: David A. Yudelson
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Defendant: Express Tech-Financing, LLC
Represented By: David A. Yudelson
Represented By: John V. Matson
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Defendant: 402 Ventures, LLC
Represented By: John V. Matson
Represented By: David A. Yudelson
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Defendant: Blockchain Game Partners, Inc. a Wyoming Corporation doing business as Gala Games
Represented By: Monica S. Call
Represented By: Tony Tootell
Represented By: Jessica Nicole Walker
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Defendant: Drivetime Car Sales Company, LLC
Represented By: Maggie E. Schroedter
Represented By: Mary R. Robberson
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Defendant: Mode Transportation, LLC
Represented By: John Mysliwiec
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Defendant: Medical Staffing Solutions, Inc.
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Defendant: Intellicheck, Inc.
Represented By: Philip M. Guess
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Defendant: Scott McKinney
Represented By: David A. Yudelson
Represented By: John V. Matson
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Defendant: Shawn Peed
Represented By: John V. Matson
Represented By: David A. Yudelson
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Defendant: Adam Price
Represented By: Monica S. Call
Represented By: Tony Tootell
Represented By: Jessica Nicole Walker
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Defendant: Aaron Price
Represented By: Monica S. Call
Represented By: Tony Tootell
Represented By: Jessica Nicole Walker
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Defendant: Aaron Mciver
Represented By: Maggie E. Schroedter
Represented By: Mary R. Robberson
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Defendant: Peter Grisolano
Represented By: Mary R. Robberson
Represented By: Maggie E. Schroedter
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Defendant: Sean Clancy
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Defendant: Anthony Vargas
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Defendant: James Marsh
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Defendant: Frank Lubin
Represented By: Philip M. Guess
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Defendant: Russ Embry
Represented By: Philip M. Guess
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Defendant: Does 1 through 99
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