Philadelphia Indemnity Insurance Company v. Free Speech Foundation, Inc. et al
| Philadelphia Indemnity Insurance Company |
| Free Speech Foundation, Inc. doing business as America's Frontline Doctors, Simone Gold, Kevin Jenkins and Trent Loos |
| Trent Loos |
| Simone Gold and Free Speech Foundation, Inc. |
| 8:2025cv00551 |
| March 7, 2025 |
| U.S. District Court for the Middle District of Florida |
| James S Moody |
| Christopher P Tuite |
| Insurance |
| 28 U.S.C. § 2201 Declaratory Judgment |
| Defendant |
Docket Report
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This docket was last retrieved on August 14, 2025. A more recent docket listing may be available from PACER.
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| Filing 55 ANSWER to #48 Crossclaim by Trent Loos. Related document: #48 Answer to Complaint Crossclaimfiled by Simone GoldFree Speech Foundation, Inc.(Rodriguez, Rachel) Modified on 8/15/2025 to edit the docket text (MLB). |
| Filing 54 NOTICE of Lead Counsel Designation by John Colbroock De Koker, III on behalf of Philadelphia Indemnity Insurance Company. Lead Counsel: John C. DeKoker III. (De Koker, John) |
| Filing 53 NOTICE of Lead Counsel Designation by David Lawrence Perry, II on behalf of Free Speech Foundation, Inc., Simone Gold. Lead Counsel: Peter Ticktin. (Perry, David) |
| Filing 52 NOTICE TO COUNSEL John Colbroock De Koker, III and Valerie Shea of Local Rule 2.02(a), which states, "The first paper filed on behalf of a party must designate only one lead counsel who - unless the party changes the designation - remains lead counsel throughout the action." Counsel must file a Notice of Lead Counsel Designation identifying lead counsel. (Signed by Deputy Clerk). (JVC) |
| Filing 51 NOTICE OF HEARING re: #37 Free Speech Foundation, Inc. (Free Speech) and Simone Gold's corrected motion to disqualify attorney Rachel Rodriguez and to strike Rodriguez's allegedly unauthorized answer for Free Speech and #42 Trent Loos and Free Speech's motion to place Free Speech into receivership, to strike Peter Ticktin's designation as Free Speech's lead attorney, and either to designate Rodriguez as lead attorney or to allow two designations of lead counsel. Oral argument on these motions is set for September 23, 2025, at 9 a.m. in Tampa Courtroom 12B before Magistrate Judge Christopher P. Tuite.(MEL) |
Filing 50
ENDORSED ORDER granting #49 Cross-Defendant Trent Loos's Unopposed Motion for Extension of Time to File Answer. Cross-Defendant Trent Loos's deadline to file his response to Cross-Plaintiffs Gold and Gold AFLD's Crossclaims is extended to August 14, 2025. Signed by Judge James S. Moody, Jr. on 7/31/2025. (SMB)
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| Filing 49 First MOTION for Extension of Time to File Answer to Crossclaims by Trent Loos. (Rodriguez, Rachel) |
| Filing 48 Amended ANSWER and affirmative defenses to #1 Complaint with Jury Demand , CROSSCLAIM against Trent Loos by Simone Gold, Free Speech Foundation, Inc. (Ticktin, Peter) Modified text on 7/14/2025 (LNR). |
| Filing 47 NOTICE by Free Speech Foundation, Inc., Simone Gold re #46 Response in Opposition to Motion, #45 Response in Opposition to Motion (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, #9 Exhibit I)(Ticktin, Peter) |
| Filing 46 RESPONSE in Opposition re #42 MOTION to Appoint Receiver and Strike Lead Counsel Designation Dkt 18 filed by Free Speech Foundation, Inc., Simone Gold. (Ticktin, Peter) |
| Filing 45 RESPONSE in Opposition re #37 Amended MOTION to Disqualify Counsel MOTION to Strike filed by Free Speech Foundation, Inc., Simone Gold. (Ticktin, Peter) |
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Filing 44
CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 5/26/2026; Dispositive motions due by 10/2/2026; Pretrial Conference set for WEDNESDAY, FEBRUARY 3, 2027, AT 9:45 A.M. in Tampa Courtroom 17 before Judge James S. Moody Jr. JURY TRIAL is set on the MARCH 2027 trial term in Tampa Courtroom 17 before Judge James S. Moody Jr. Conduct mediation hearing by 8/3/2026. Lead counsel to coordinate dates. Signed by Judge James S. Moody, Jr. on 6/26/2025. (SMB)
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| Filing 43 NOTICE of Appearance by David Lawrence Perry, II on behalf of Free Speech Foundation, Inc., Simone Gold (Perry, David) |
| Filing 42 MOTION to Appoint Receiver and Strike Lead Counsel Designation Dkt 18 by Free Speech Foundation, Inc., Trent Loos. (Rodriguez, Rachel) |
| Filing 41 RESPONSE in Opposition re #37 Amended MOTION to Disqualify Counsel MOTION to Strike and Cross-Motion to Disqualify Attorney PeterTicktin filed by Free Speech Foundation, Inc., Trent Loos. (Attachments: #1 Exhibit Rodriguez Declaration)(Rodriguez, Rachel) |
| Filing 40 CASE MANAGEMENT REPORT. (Shea, Valerie) |
| Filing 39 NOTICE of Lead Counsel Designation by Rachel L Rodriguez on behalf of Trent Loos. Lead Counsel: Rachel L.T. Rodriguez. (Rodriguez, Rachel) |
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Filing 38
ENDORSED ORDER re: Defendants #36 Free Speech Foundation, Inc. and Simone Gold's Motion to Disqualify Attorney Rachel Rodriguez and to Strike the Unauthorized Answer (Dkt. 30) Filed by Rachel Rodriguez Purportedly for Free Speech Foundation, Inc. (hereinafter, Defendants' Motion). In light of the fact that Defendants filed an amended motion (#37), Defendants' Motion is denied as moot. Signed by Magistrate Judge Christopher P. Tuite on 6/12/2025. (MEL)
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| Filing 37 Amended MOTION to Disqualify Counsel by Free Speech Foundation, Inc., Simone Gold. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Ticktin, Peter). Added MOTION to Strike on 6/11/2025 (LNR). |
| Filing 36 MOTION to Disqualify Counsel Rachel Rodriguez by Free Speech Foundation, Inc., Simone Gold. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Ticktin, Peter) |
| Filing 35 NOTICE TO COUNSEL Rachel L Rodriguez of Local Rule 2.02(a), which states, "The first paper filed on behalf of a party must designate only one lead counsel who - unless the party changes the designation - remains lead counsel throughout the action." Counsel must file a Notice of Lead Counsel Designation identifying lead counsel. (Signed by Deputy Clerk). (GL) |
| Filing 34 ANSWER and affirmative defenses to #1 Complaint with Jury Demand by Free Speech Foundation, Inc., Simone Gold. (Ticktin, Peter) Modified text on 6/3/2025 (GL). |
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Filing 33
ORDER: Defendants' Motion to Dismiss (Dkt. #23) is denied. Defendants shall file their Answer within fourteen (14) days of this Order. Signed by Judge James S. Moody, Jr. on 5/20/2025. (SMB)
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Filing 32
ENDORSED ORDER granting #31 Motion for David Grassmick to Withdraw as Attorney by Philadelphia Indemnity Insurance. (Attorney David E. Grassmick terminated.) Signed by Judge James S. Moody, Jr, on 5/15/2025. (SMB)
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| Filing 31 MOTION for David Grassmick to Withdraw as Attorney by Philadelphia Indemnity Insurance Company. (Shea, Valerie) Modified docket text on 5/16/2025 (JOS). |
| Filing 30 ANSWER and affirmative defenses to #1 Complaint by Free Speech Foundation, Inc., Trent Loos.(Rodriguez, Rachel) |
| Filing 29 DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Free Speech Foundation, Inc.. (Rodriguez, Rachel) |
| Filing 28 DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Trent Loos. (Rodriguez, Rachel) |
| Filing 27 NOTICE of Appearance by Rachel L Rodriguez on behalf of Free Speech Foundation, Inc., Trent Loos (Rodriguez, Rachel) |
| Filing 26 DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Kevin Jenkins. (Schmidt, Jorge) |
| Filing 25 RESPONSE to Motion re #23 MOTION to Dismiss and Memorandum of Law filed by Philadelphia Indemnity Insurance Company. (Shea, Valerie) |
| Filing 24 ANSWER to #1 Complaint by Kevin Jenkins.(Schmidt, Jorge) |
| Filing 23 MOTION to Dismiss and Memorandum of Law by Free Speech Foundation, Inc., Simone Gold. (Ticktin, Peter) |
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Filing 20
ENDORSED ORDER granting #19 Defendants Free Speech Foundation, Inc. and Simone Gold's Unopposed Motion for Extension of Time. Defendant Free Speech Foundation, Inc. and Simone Gold's deadline to respond to Plaintiff's Complaint is extended to April 16, 2025. Signed by Judge James S. Moody, Jr. on 4/9/2025. (SMB)
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| Filing 19 Unopposed MOTION for Extension of Time to File Answer re #1 Complaint by Free Speech Foundation, Inc., Simone Gold. (Ticktin, Peter) |
| Filing 18 NOTICE of Appearance by Peter Ticktin on behalf of Free Speech Foundation, Inc., Simone Gold (Ticktin, Peter) |
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Filing 17
ENDORSED ORDER granting Plaintiff's #16 Motion for Special Admission of a Non-Resident Lawyer as to attorney John C. De Koker III. If counsel has not already done so, within fourteen (14) days hereof, he shall complete the e-filer registration (more information available at https://www.flmd.uscourts.gov/for-lawyers). Signed by Magistrate Judge Christopher P. Tuite on 4/4/2025. (ACL)
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| Filing 16 MOTION for John C. De Koker III to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-23204575 for $150 by Philadelphia Indemnity Insurance Company. (Attachments: #1 Exhibit A to MPV - DeKoker Oath)(Shea, Valerie) Motions referred to Magistrate Judge Christopher P. Tuite. |
| Filing 15 WAIVER of service returned executed on March 13, 2025 by Philadelphia Indemnity Insurance Company as to Trent Loos. (Shea, Valerie) |
| Filing 14 WAIVER of service returned executed on March 13, 2025 by Philadelphia Indemnity Insurance Company as to Kevin Jenkins. (Shea, Valerie) |
| Filing 13 SUMMONS issued as to Free Speech Foundation, Inc. (KME) |
| Filing 12 SUMMONS issued as to Free Speech Foundation, Inc. (ARL) |
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Filing 11
ENDORSED ORDER granting Plaintiff's #8 Renewed and Revised Motion for Special Admission of a Non-Resident Lawyer to Represent Plaintiff Philadelphia Indemnity Insurance Company as to attorney David Grassmick. If counsel has not already done so, within fourteen (14) days hereof, he shall complete the e-filer registration (more information available at https://www.flmd.uscourts.gov/for-lawyers). Signed by Magistrate Judge Christopher P. Tuite on 3/11/2025. (MEL)
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| Filing 10 PROPOSED summons to be issued by Philadelphia Indemnity Insurance Company. (Shea, Valerie) |
| Filing 9 PROPOSED summons to be issued by Philadelphia Indemnity Insurance Company. (Shea, Valerie) |
| Filing 8 MOTION to Correct 7 Order on Motion to Amend / Correct / Modify / Supplement Renewed and Revised Motion for Special Admission of a Non-Resident Lawyer to Represent Plaintiff by Philadelphia Indemnity Insurance Company. (Attachments: #1 Exhibit A - DG Oath)(Shea, Valerie) |
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Filing 7
ENDORSED ORDER denying without prejudice Plaintiff's amended #6 Motion for Special Admission of a Non-Resident Lawyer as to attorney David Grassmick. In support of this ruling, the undersigned notes that a copy of Plaintiff's amended motion, along with a proposed order, was sent directly to the undersigned's personal email address, which is improper, and that the motion's signature block confusingly identifies Mr. Grassmick (as well as Valerie Shea) as "Attorneys for Defendant, Philadelphia Indemnity Insurance Company." If Plaintiff seeks again to renew its pro hac vice motion regarding Mr. Grassmick, it shall not only comply with the requirements of Local Rule 2.01 but shall also attest that it will not transmit materials to a judge's personal email address unless specifically authorized to do so. Signed by Magistrate Judge Christopher P. Tuite on 3/10/2025. (MEL)
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| Filing 6 MOTION to Correct 5 Order on Motion to Appear Pro Hac Vice by Philadelphia Indemnity Insurance Company. (Attachments: #1 Exhibit A - DG Oath)(Shea, Valerie) |
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Filing 5
ENDORSED ORDER denying without prejudice Plaintiff's #2 Motion for Special Admission of a Non-Resident Lawyer as to attorney David Grassmick. The motion does not comply with Local Rule 2.01(b)(1)(C) and (E). If counsel elects to refile the motion, he shall use as a go-by the "Sample Motion for Special Admission" available on the Middle District of Florida website. See https://www.flmd.uscourts.gov/form/motion-special-admission. Signed by Magistrate Judge Christopher P. Tuite on 3/10/2025. (MEL)
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| Filing 4 NEW CASE ASSIGNED to Judge James S. Moody, Jr and Magistrate Judge Christopher P. Tuite. New case number: 8:25-cv-551-JSM-CPT. Motion(s) REFERRED: #2 MOTION for David Grassmick to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-23103133 for $150 . Motion(s) referred to Magistrate Judge Christopher P. Tuite. (ARL) |
| Filing 3 DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Philadelphia Indemnity Insurance Company identifying Corporate Parent Philadelphia Indemnity Insurance Company, Other Affiliate Tokio Marine Holdings, Inc., Other Affiliate Tokio Marine North America, Inc., Other Affiliate Tokio Marine and Nichido Fire Insurance Company, Ltd., Other Affiliate Philadelphia Consolidated Holding Corp for Philadelphia Indemnity Insurance Company. (Shea, Valerie) Modified on 3/10/2025 to edit text. (FLY) |
| Filing 2 MOTION for David Grassmick to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-23103133 for $150 by Philadelphia Indemnity Insurance Company. (Attachments: #1 Exhibit A - Oath of DG)(Shea, Valerie) |
| Filing 1 COMPLAINT for Declaratory Judgment against Free Speech Foundation, Inc. , Simone Gold, Kevin Jenkins, Trent Loos (Filing fee $405 receipt number AFLMDC-23101832) filed by Philadelphia Indemnity Insurance Company. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Civil Cover Sheet)(Shea, Valerie) Modified on 3/7/2025 to edit text. (LD). |
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