Brothers v. Lennox National Account Services LLC et al
Plaintiff: Brittany Brothers
Defendant: Lennox National Account Services LLC and Staff Perm, LLC
Case Number: 0:2023cv60740
Filed: April 19, 2023
Court: US District Court for the Southern District of Florida
Presiding Judge: Raag Singhal
Referring Judge: Alicia O Valle
Nature of Suit: Civil Rights: Americans with Disabilities - Employment
Cause of Action: 28 U.S.C. ยง 1446 Notice of Removal
Jury Demanded By: Defendant
Docket Report

This docket was last retrieved on June 1, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 1, 2023 Opinion or Order Filing 14 ORDER SETTING TRIAL AND PRE-TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: (Jury Trial set for 5/20/2024 09:00 AM in Fort Lauderdale Division before Judge Raag Singhal., Calendar Call set for 5/15/2024 10:30 AM via Zoom before Judge Raag Singhal., Status Conference set for 8/3/2023 03:45 PM before Judge Raag Singhal., Amended Pleadings due by 7/21/2023., Discovery due by 1/31/2024., Expert Discovery due by 1/31/2024., Joinder of Parties due by 7/21/2023., Mediation Deadline 2/7/2024., In Limine Motions due by 3/20/2024., Dispositive Motions due by 2/14/2024., Motions due by 2/14/2024., Pretrial Stipulation due by 5/5/2024.) Signed by Judge Raag Singhal on 6/1/2023. See attached document for full details. (pc) #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.
May 24, 2023 Filing 13 Joint SCHEDULING REPORT - Rule 16.1 by Brittany Brothers (Attachments: #1 Text of Proposed Order)(Horowitz, Max)
May 3, 2023 Filing 12 DEFENDANT LENNOX NATIONAL ACCOUNT SERVICES LLCS ANSWER and Affirmative Defenses to Complaint re the Notice of Removal by Lennox National Account Services LLC. (DeMaio, David)
April 27, 2023 Filing 11 Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Staff Perm, LLC (Ershock, Alex)
April 27, 2023 Filing 10 Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by Lennox National Account Services LLC identifying Corporate Parent Lennox International Inc., Other Affiliate Lennox Industries Inc. for Lennox National Account Services LLC (DeMaio, David)
April 26, 2023 Filing 9 ANSWER and Affirmative Defenses to Complaint re the Notice of Removal with Jury Demand by Staff Perm, LLC. (Ershock, Alex)
April 26, 2023 Filing 8 Notice of Pending, Refiled, Related or Similar Actions by Brittany Brothers (Horowitz, Max)
April 26, 2023 Filing 7 Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Brittany Brothers (Horowitz, Max)
April 26, 2023 Opinion or Order Filing 6 PAPERLESS ORDER granting #5 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document. Lennox National Account Services LLC's Response/Answer is due by 5/3/2023. Signed by Judge Raag Singhal on 4/26/2023. (am00)
April 25, 2023 Filing 5 Defendant's MOTION for Extension of Time to File Response/Reply/Answer as to #1 Notice of Removal (State Court Complaint),, Unopposed Motion for Enlargement of Time to Respond to Complaint by Lennox National Account Services LLC. (Attachments: #1 Text of Proposed Order)(DeMaio, David)
April 20, 2023 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 4/20/2023. (am00)
April 20, 2023 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 (and responses to 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 (and responses).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 4/20/2023. (am00)
April 19, 2023 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. (pc)
April 19, 2023 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 402.00 receipt number AFLSDC-16552357, filed by Staff Perm, LLC. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A - State Court Complaint, #3 Exhibit B - Sate Court Civil Cover Sheet, #4 Exhibit C - State Court Clerk Certificate of Compliance, #5 Exhibit D - State Court Summons-Staff Perm, #6 Exhibit E - State Court Summons-Lennox National, #7 Exhibit F - State Court Return of Service-Lennox National, #8 Exhibit G - State Court Return of Service-Staff Perm, #9 Exhibit H - State Court Docket)(Ershock, Alex) (state court complaint see Exh. A, no Answer/Motion to Dismiss filed) Modified text on 4/20/2023 (pc).

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Plaintiff: Brittany Brothers
Represented By: Max Lloyd Horowitz
Represented By: Ruben Martin Saenz
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Defendant: Lennox National Account Services LLC
Represented By: Beran Nar
Represented By: David M. DeMaio
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Defendant: Staff Perm, LLC
Represented By: Alex Brandon Claude Ershock
Represented By: Daniel R. Levine
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