Rechul v. Crisp Marketing, LLC
Plaintiff: Weronika Rechul
Defendant: Crisp Marketing, LLC
Case Number: 0:2020cv61042
Filed: May 28, 2020
Court: US District Court for the Southern District of Florida
Presiding Judge: Rodolfo A Ruiz
Referring Judge: Rodolfo A Ruiz
2 Judge: Jared M Strauss
Nature of Suit: Other Statutory Actions
Cause of Action: 28 U.S.C. § 1331
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on July 10, 2020. A more recent docket listing may be available from PACER.

Date Filed Document Text
July 10, 2020 Opinion or Order Filing 43 ORDER Scheduling Mediation before James F. Holderman. Mediation Hearing set for 9/24/2020 10:00 AM. Signed by Judge Rodolfo A. Ruiz, II on 7/10/2020. See attached document for full details. (kpe) (Main Document 43 replaced and Text modified on 7/15/2020) (gp).
July 9, 2020 Filing 42 NOTICE of Mediator Selection and Hearing. Selected/Added James F. Holderman as Mediator. Mediation Hearing set for 9/24/2020 at 10:00 am. (Kaufman, Avi)
June 29, 2020 Opinion or Order Filing 41 PAPERLESS ORDER granting #39 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney G. David Carter. Signed by Judge Rodolfo A. Ruiz, II on 6/29/2020. (btr)
June 25, 2020 Filing 40 REPLY to Response to Motion re #28 MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, "Defendant's Reply to Plaintiff's Opposition to Defendant's Motion to Dismiss" filed by Crisp Marketing, LLC. (Betpera, Artin)
June 24, 2020 Filing 39 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for G. David Carter. Filing Fee $ 200.00 Receipt # AFLSDC-13077466 by Crisp Marketing, LLC. Responses due by 7/8/2020 (Attachments: #1 Certification of David Carter, #2 Text of Proposed Order)(Betpera, Artin)
June 19, 2020 Opinion or Order Filing 38 PAPERLESS ORDER SETTING DISCOVERY PROCEDURES. No discovery motions shall be filed with the Court unless specifically authorized by Order. In the event a discovery dispute does arise, counsel are instructed to meet and confer in a good faith attempt to resolve the dispute. If, after conferring, the parties cannot resolve their discovery dispute, the movant must seek relief within 14 days after the grounds for relief occur by contacting Chambers (954-769-5450) and scheduling a discovery hearing. The movant shall have first conferred with opposing counsel and obtained three alternative dates and times that both counsel are available for a hearing. The attorney or other person with knowledge who telephones the Court shall have the following information: (a) the nature of the discovery dispute; (b) the efforts made to confer with opposing counsel; and (c) three agreed upon dates for a hearing. The Court will then set the matter for hearing and order the parties to submit a joint status report on the issues. Where there has been a complete failure to respond to discovery, and where good faith efforts have been made (without success) to obtain that discovery, counsel need not obtain agreed upon dates, but shall so inform the Court telephonically of the issue, and the Court will set the matter for hearing. Finally, when the parties have stipulated to the entry of an order, such as a stipulated confidentiality order, the parties shall not file a motion for entry of the stipulated order. Instead, counsel shall email to Chambers (strauss@flsd.uscourts.gov) a copy of the proposed stipulated order in Word format, with a statement that the parties have agreed to entry of the proposed order. Signed by Magistrate Judge Jared M. Strauss on 6/19/2020. (emd)
June 19, 2020 Opinion or Order Filing 37 ORDER Setting Jury Trial Schedule, Requiring Mediation, And Referring Certain Matters To Magistrate Judge: ( Jury Trial set for 3/29/2021 in Fort Lauderdale Division before Judge Rodolfo A Ruiz., Calendar Call set for 3/23/2021 11:00 AM in Fort Lauderdale Division before Judge Rodolfo A Ruiz., Amended Pleadings due by 7/31/2020., Discovery due by 12/1/2020., Expert Discovery due by 12/1/2020., Joinder of Parties due by 7/31/2020., Mediation Deadline 12/8/2020., In Limine Motions due by 1/12/2021., Dispositive Motions due by 12/15/2020., Motions due by 12/15/2020., Pretrial Stipulation due by 1/12/2021.) ( Mediation Deadline 12/8/2020.) Signed by Judge Rodolfo A Ruiz on 6/19/2020. See attached document for full details. (kpe) #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.
June 19, 2020 Opinion or Order Filing 36 PAPERLESS ORDER granting #33 Motion to Withdraw. Attorney Jennifer Itzkoff is hereby DISCHARGED of all further responsibilities related to Defendant in these proceedings. Defendant shall continue to be represented by Attorney Artin Betpera of the law firm Womble Bond Dickson (US) LLP. Signed by Judge Rodolfo A Ruiz on 6/19/2020. (btr)
June 18, 2020 Filing 35 RESPONSE in Opposition re #28 MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, filed by Weronika Rechul. Replies due by 6/25/2020. (Kaufman, Avi)
June 18, 2020 Filing 34 STIPULATION of Dismissal Partial and Without Prejudice by Weronika Rechul (Kaufman, Avi)
June 16, 2020 Filing 33 MOTION to Withdraw as Attorney (as to Jennifer Itzkoff for Defendant Crisp Marketing, LLC) by Jennifer Itzkoff for / by Crisp Marketing, LLC. Responses due by 6/30/2020 (Attachments: #1 Text of Proposed Order)(Betpera, Artin)
June 12, 2020 Filing 32 Certificate of Other Affiliates/Corporate Disclosure Statement by Crisp Marketing, LLC (Betpera, Artin)
June 12, 2020 Filing 31 Certificate of Other Affiliates by Weronika Rechul (Kaufman, Avi)
June 12, 2020 Filing 30 STATUS REPORT re Transfer by Weronika Rechul (Kaufman, Avi)
June 12, 2020 Filing 29 Joint SCHEDULING REPORT - Rule 26(f) by Weronika Rechul (Attachments: #1 Text of Proposed Order)(Kaufman, Avi)
June 11, 2020 Filing 28 MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, ( Responses due by 6/25/2020) by Crisp Marketing, LLC. (Attachments: #1 Memorandum in Support of Mtn to Dismiss, #2 Supplement Request for Judicial Ntc in Support of Mtn to Dismiss, #3 Exhibit A to Request for Judicial Ntc (Corporate Info. Detail))(Betpera, Artin)
June 9, 2020 Filing 27 STIPULATION of Dismissal (Partial Dismissal - Plaintiff's First Cause of Action only) by Crisp Marketing, LLC (Betpera, Artin)
June 5, 2020 Opinion or Order Filing 26 ORDER Requiring Transfer Status Report, ( Status Report due by 6/12/2020.) Signed by Judge Rodolfo A Ruiz on 6/4/2020. See attached document for full details. (kpe)
June 5, 2020 Opinion or Order Filing 25 ORDER REQUIRING JOINT SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES. Joint Scheduling Report and Certificates of Interested Parties due by 6/12/2020. Signed by Judge Rodolfo A Ruiz on 6/4/2020. See attached document for full details. (kpe)
May 29, 2020 Filing 24 NOTICE of Attorney Appearance by Avi Robert Kaufman on behalf of Weronika Rechul. Attorney Avi Robert Kaufman added to party Weronika Rechul(pty:pla). (Kaufman, Avi)
May 28, 2020 Filing 23 Bar Letter re: Admissions sent to attorney Anthony I. Paronich, Alex M. Washkowitz, G. David Carter, Jennifer Itzkoff, mailing date 05/28/2020. (cco)
May 28, 2020 Filing 22 Clerks Notice of Judge Assignment to Judge Rodolfo A Ruiz. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (jua)
May 28, 2020 Filing 21 Case transferred in from Massachusetts; Case Number 1:20-cv-10171. Electronic file including transfer order and docket sheet received. .(jua).
May 28, 2020 Filing 20 Case transferred Electronically to the Southern District of Florida, Fort Lauderdale Division. (McKillop, Matthew)
May 27, 2020 Filing 19 Judge Rya W. Zobel: ORDER entered. re #18 Stipulation, filed by Crisp Marketing, LLC. (Urso, Lisa)
May 6, 2020 Filing 18 STIPULATION to Transfer Action to US District Court for Southern District of Florida - Fort Lauderdale Division by Crisp Marketing, LLC. (Betpera, Artin) (Additional attachment(s) added on 5/27/2020: #1 Proposed Order) (McKillop, Matthew).
April 23, 2020 Filing 17 Judge Rya W. Zobel: ELECTRONIC ORDER entered granting #16 Motion for Extension of Time to File Response/Reply re #12 MOTION to Dismiss Responses due by 5/8/2020 (Urso, Lisa)
April 23, 2020 Filing 16 Assented to MOTION for Extension of Time to May 8, 2020 to File Response/Reply as to #12 MOTION to Dismiss by Weronika Rechul.(Paronich, Anthony)
April 10, 2020 Filing 15 Request for Judicial Notice by Crisp Marketing, LLC. (Attachments: #1 Exhibit A - NANPA (Area) Codes Map, #2 Exhibit B - Corporate Info Detail)(Betpera, Artin)
April 10, 2020 Filing 14 AFFIDAVIT in Support re #12 MOTION to Dismiss (Affidavit of Justin Ferreira). (Betpera, Artin)
April 10, 2020 Filing 13 MEMORANDUM in Support re #12 MOTION to Dismiss filed by Crisp Marketing, LLC. (Betpera, Artin)
April 10, 2020 Filing 12 MOTION to Dismiss by Crisp Marketing, LLC.(Betpera, Artin)
March 18, 2020 Filing 11 Judge Rya W. Zobel: ELECTRONIC ORDER entered granting #10 Motion for Extension of Time to Answer re #1 Complaint, Crisp Marketing, LLC answer due 4/10/2020. (Urso, Lisa)
March 17, 2020 Filing 10 Consent MOTION for Extension of Time to 04/10/2020 to File Answer or Respond to Complaint by Crisp Marketing, LLC.(Itzkoff, Jennifer)
February 26, 2020 Filing 9 Judge Rya W. Zobel: ELECTRONIC ORDER entered granting #7 Motion for Leave to Appear Pro Hac Vice G. David Carter. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. ; granting #8 Motion for Leave to Appear Pro Hac Vice Added Artin Betbera. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (Urso, Lisa)
February 25, 2020 Filing 8 MOTION for Leave to Appear Pro Hac Vice for admission of Artin Betpera Filing fee: $ 100, receipt number 0101-8125652 by Crisp Marketing, LLC.(Itzkoff, Jennifer)
February 25, 2020 Filing 7 MOTION for Leave to Appear Pro Hac Vice for admission of G. David Carter Filing fee: $ 100, receipt number 0101-8125590 by Crisp Marketing, LLC.(Itzkoff, Jennifer)
February 12, 2020 Filing 6 Judge Rya W. Zobel: ELECTRONIC ORDER entered granting #5 Motion for Extension of Time to Answer re #1 Complaint, Crisp Marketing, LLC answer due 3/20/2020. (Urso, Lisa)
February 12, 2020 Filing 5 Consent MOTION for Extension of Time to 03/21/2020 to File Answer by Crisp Marketing, LLC.(Itzkoff, Jennifer)
January 31, 2020 Filing 4 NOTICE of Appearance by Alex M. Washkowitz on behalf of Weronika Rechul (Washkowitz, Alex)
January 29, 2020 Filing 3 Summons Issued as to Crisp Marketing, LLC. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (Jones, Sherry)
January 29, 2020 Filing 2 ELECTRONIC NOTICE of Case Assignment. Judge Rya W. Zobel assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Jennifer C. Boal. (Finn, Mary)
January 28, 2020 Filing 1 COMPLAINT against Crisp Marketing, LLC Filing fee: $ 400, receipt number 0101-8077607 (Fee Status: Filing Fee paid), filed by Weronika Rechul. (Attachments: #1 Civil Cover Sheet, #2 Exhibit Civil Category Form)(Paronich, Anthony)

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Defendant: Crisp Marketing, LLC
Represented By: Jennifer Itzkoff
Represented By: G. David Carter
Represented By: Artin Betpera
Represented By: George David Carter
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Plaintiff: Weronika Rechul
Represented By: Alex M. Washkowitz
Represented By: Anthony I. Paronich
Represented By: Avi Robert Kaufman
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