Pieces of Inspiration, Inc. v. United Healthcare Services, Inc. et al
Plaintiff: Pieces of Inspiration, Inc.
Defendant: United Healthcare Services, Inc. and United Healthcare Insurance Company
Case Number: 0:2022cv61277
Filed: July 8, 2022
Court: US District Court for the Southern District of Florida
Presiding Judge: Raag Singhal
Referring Judge: Alicia O Valle
Nature of Suit: Insurance
Cause of Action: 28 U.S.C. § 1332 Diversity-Notice of Removal
Jury Demanded By: Both
Docket Report

This docket was last retrieved on August 30, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
August 30, 2022 Filing 24 MOTION TO DISMISS #22 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by United Healthcare Insurance Company, United Healthcare Services, Inc.. Responses due by 9/13/2022 (Attachments: #1 Exhibit A - List Created by United Identifying the Plans at Issue, #2 Exhibit B - Sample of the Plans at Issue, #3 Exhibit C - Order, Columna, Inc. v. CIGNA Health & Life Ins. Co, Case No. 9:19-cv-80170-BER, Doc. 68 at 10-11 (S.D. Fla. Feb. 6, 2020), #4 Exhibit D - Order, Surgery Ctr. of Viera v. CIGNA Health & Life Ins. Co., Case No. 6:22:cv-00127-PGB-DCI, Doc. 28 at 5-8 (M.D. Fla. June 17, 2022), #5 Exhibit E - Order, Vanguard Plastic Surgery, PLLC v. UnitedHealthcare Ins. Co., No. 0:21-cv-62403-WPD, (Doc, 16) (S.D. Fla. Feb. 9, 2022))(Gerson, Shari)
August 17, 2022 Opinion or Order Filing 23 PAPERLESS ORDER denying as moot #19 Motion to Dismiss in light of #22 Plaintiff's Third Amended Complaint. Signed by Judge Raag Singhal on 8/17/2022. (pls)
August 16, 2022 Filing 22 Third AMENDED COMPLAINT against United Healthcare Insurance Company, United Healthcare Services, Inc. filed in response to Order Granting Motion for Leave, filed by Pieces of Inspiration, Inc.. (Attachments: #1 Exhibit A - Multiplan Agreement)(Curtis, Edward)
August 16, 2022 Opinion or Order Filing 21 PAPERLESS ORDER granting #20 Motion for Leave to File. Clerks Notice: Filer must separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge. Signed by Judge Raag Singhal on 8/16/2022. (pls)
August 15, 2022 Filing 20 First MOTION for Leave to File Third Amended Complaint by Pieces of Inspiration, Inc.. (Attachments: #1 Exhibit Exhibit A - Third Amended Complaint)(Curtis, Edward)
August 1, 2022 Filing 19 Corrected MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM by United Healthcare Insurance Company, United Healthcare Services, Inc.. Responses due by 8/15/2022 (Attachments: #1 Exhibit A - List Created by United Identifying the Plans at Issue, #2 Exhibit B - Sampling of the Plans at Issue, #3 Exhibit C - Order, Columna, Inc. v. CIGNA Health & Life Ins. Co, Case No. 9:19-cv-80170-BER, Doc. 68 at 10-11 (S.D. Fla. Feb. 6, 2020), #4 Exhibit D - Order, Surgery Ctr. of Viera v. CIGNA Health & Life Ins. Co., Case No. 6:22:cv-00127-PGB-DCI, Doc. 28 at 5-8 (M.D. Fla. June 17, 2022), #5 Exhibit E - Order, Vanguard Plastic Surgery, PLLC v. UnitedHealthcare Ins. Co., No. 0:21-cv-62403-WPD, (Doc, 16) (S.D. Fla. Feb. 9, 2022))(Gerson, Shari)
August 1, 2022 Opinion or Order Filing 18 PAPERLESS ORDER denying without prejudice #16 Motion to Dismiss for failure to comply with Local Rule 7.1(c)(2) and the 3 Notice of Court Practice. Signed by Judge Raag Singhal on 8/1/2022. (pls)
July 29, 2022 Opinion or Order Filing 17 ORDER SETTING TRIAL AND PRE-TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: ( Jury Trial set for 6/20/2023 09:00 AM before Judge Raag Singhal., Calendar Call set for 6/16/2023 10:00 AM in Fort Lauderdale Division before Judge Raag Singhal., Amended Pleadings due by 9/27/2022., Discovery due by 2/24/2023., Expert Discovery due by 2/24/2023., Fact Discovery due by 2/24/2023., Joinder of Parties due by 9/27/2022., Mediation Deadline 3/3/2023., In Limine Motions due by 5/6/2023., Dispositive Motions due by 3/11/2023., Motions due by 3/11/2023., Pretrial Stipulation due by 6/7/2023.), ORDER REFERRING CASE to Mediation. ( Mediation Deadline 3/3/2023.), ORDER REFERRING CASE to Magistrate Judge Alicia O.Valle for all discovery. Signed by Judge Raag Singhal on 7/29/2022. See attached document for full details. (mee) #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.
July 29, 2022 Filing 16 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM by United Healthcare Insurance Company, United Healthcare Services, Inc.. Responses due by 8/12/2022 (Attachments: #1 Exhibit A - List Created by United Identifying the Plans at Issue, #2 Exhibit B - Sampling of the Plans at Issue, #3 Exhibit C - Order, Columna, Inc. v. CIGNA Health & Life Ins. Co, Case No. 9:19-cv-80170-BER, Doc. 68 at 10-11 (S.D. Fla. Feb. 6, 2020), #4 Exhibit D - Order, Surgery Ctr. of Viera v. CIGNA Health & Life Ins. Co., Case No. 6:22:cv-00127-PGB-DCI, Doc. 28 at 5-8 (M.D. Fla. June 17, 2022), #5 Exhibit E - Order, Vanguard Plastic Surgery, PLLC v. UnitedHealthcare Ins. Co., No. 0:21-cv-62403-WPD, (Doc, 16) (S.D. Fla. Feb. 9, 2022))(Gerson, Shari)
July 28, 2022 Filing 15 Joint SCHEDULING REPORT - Rule 16.1 by United Healthcare Insurance Company, United Healthcare Services, Inc. (Attachments: #1 Text of Proposed Order)(Gerson, Shari)
July 27, 2022 Opinion or Order Filing 14 PAPERLESS ORDER granting #13 Motion for Extension of Time. The parties shall submit the joint scheduling report by 7/28/2022. Signed by Judge Raag Singhal on 7/27/2022. (pls)
July 27, 2022 Reset Deadlines. Joint Scheduling Report due by 7/28/2022 per d.e. 14 Order. (mee)
July 26, 2022 Filing 13 Unopposed MOTION for Extension of Time to Submit a Joint Scheduling Report and Proposed Order re #5 Order Requiring Joint Scheduling Report by Pieces of Inspiration, Inc.. Responses due by 8/9/2022 (Shomar, Henny)
July 26, 2022 Opinion or Order Filing 12 PAPERLESS ORDER granting #11 Motion. The parties may exceed their respective page limits by five (5) pages in the anticipated motion to dismiss and responsive briefings thereto. Signed by Judge Raag Singhal on 7/26/2022. (pls)
July 25, 2022 Filing 11 Unopposed MOTION for 5-Page Expansion of Page Limitation by United Healthcare Insurance Company, United Healthcare Services, Inc.. (Garcia, Kelly Jean)
July 15, 2022 Filing 10 Certificate of Other Affiliates/Corporate Disclosure Statement by United Healthcare Insurance Company, United Healthcare Services, Inc. identifying Corporate Parent Unitedhealth Group Incorporated for United Healthcare Insurance Company, United Healthcare Services, Inc. (Gerson, Shari)
July 14, 2022 Filing 9 First Certificate of Other Affiliates/Corporate Disclosure Statement by Pieces of Inspiration, Inc. (Curtis, Edward)
July 12, 2022 Reset Answer Due Deadline: United Healthcare Insurance Company answer due 7/29/2022; United Healthcare Services, Inc. answer due 7/29/2022. Per d.e. 8 Order. (mee)
July 12, 2022 Opinion or Order Filing 8 PAPERLESS ORDER granting #7 Motion for Extension of Time. Answer/Response to Complaint due 7/29/2022. Signed by Judge Raag Singhal on 7/12/2022. (pls)
July 11, 2022 Filing 7 Unopposed MOTION for Extension of Time to Respond to Plaintiff's Second Amended Complaint by United Healthcare Insurance Company, United Healthcare Services, Inc.. Responses due by 7/25/2022 (Garcia, Kelly Jean)
July 11, 2022 Filing 6 NOTICE of Attorney Appearance by Kelly Jean Howard Garcia on behalf of United Healthcare Insurance Company, United Healthcare Services, Inc.. Attorney Kelly Jean Howard Garcia added to party United Healthcare Insurance Company(pty:dft), Attorney Kelly Jean Howard Garcia added to party United Healthcare Services, Inc.(pty:dft). (Garcia, Kelly Jean)
July 11, 2022 Opinion or Order Filing 5 ORDER REQUIRING SCHEDULING REPORT. Joint Scheduling Report due by 7/26/2022. Signed by Judge Raag Singhal on 7/11/2022. See attached document for full details. (mee)
July 10, 2022 Opinion or Order Filing 4 PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONSWithin SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges as interested parties unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 7/11/2022. (pls)
July 10, 2022 Filing 3 NOTICE OF COURT PRACTICEUnless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes.Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions.Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted).Exhibits to pleadings and motions shall be docketed in accordance with the Courts CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket EntryA party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings.Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 7/11/2022. (pls)
July 8, 2022 Filing 2 Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle 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. (swr)
July 8, 2022 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Second Amended Complaint) Filing fee $ 402.00 receipt number AFLSDC-15775393, filed by United Healthcare Insurance Company. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A - Second Amended Complaint and Documents served on UHIC, #3 Exhibit B - Documents served on UHS, #4 Exhibit C - UHS's business profile with the Florida Department of State, #5 Exhibit D - UHIC's business profile with the Florida Department of State)(Gerson, Shari) Defendant's Motion to Dismiss Filed in Exhibit B/No Answers Filed. Modified Text on 7/8/2022 (swr).

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Plaintiff: Pieces of Inspiration, Inc.
Represented By: Corey Daniel Cohen
Represented By: Edward Royce Curtis
Represented By: Henny Lawrence Shomar
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Defendant: United Healthcare Services, Inc.
Represented By: Shari Lyn Gerson
Represented By: Kelly Jean Howard Garcia
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Defendant: United Healthcare Insurance Company
Represented By: Shari Lyn Gerson
Represented By: Kelly Jean Howard Garcia
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