LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION v. HARBISON et al
Plaintiff: LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION
Defendant: CHRISTOPHER HARBISON and REGINA HARBISON
Case Number: 0:2024cv60305
Filed: February 23, 2024
Court: US District Court for the Southern District of Florida
Presiding Judge: Raag Singhal
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. ยง 1332 Diversity-Notice of Removal
Jury Demanded By: None
Docket Report

This docket was last retrieved on April 17, 2024. A more recent docket listing may be available from PACER.

Date Filed Document Text
April 17, 2024 Filing 32 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 5/1/2024. (Amir, Ofer)
April 17, 2024 Filing 31 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 5/1/2024. (Amir, Ofer)
April 17, 2024 Filing 30 NOTICE OF WITHDRAWAL OF MOTION by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION re #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION, #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer)
April 15, 2024 Opinion or Order Filing 29 PAPERLESS ORDER granting #28 Motion for Extension of Time to File Reply to Motion. Reply is due by 4/18/2024. Signed by Judge Raag Singhal on 4/15/2024. (jgr)
April 12, 2024 Filing 28 First MOTION for Extension of Time to File Response/Reply/Answer as to #26 Response in Opposition to Motion, #27 Response in Opposition to Motion, For Plaintiff by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Amir, Ofer)
April 5, 2024 Filing 27 RESPONSE in Opposition re #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), Opposition to Plaintiff's Motion to Strike Portions of Defendants' Motion to Dismiss and Supporting Memorandum of Law filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/12/2024. (McCoy, Kevin)
April 5, 2024 Filing 26 RESPONSE in Opposition re #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/12/2024. (McCoy, Kevin)
March 29, 2024 Filing 25 REPLY to #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), Defendants' Reply in Support of their Motion to Dismiss for Lack of Personal Jurisdiction or in the Alternative, to Transfer, and Memorandum of Law by CHRISTOPHER HARBISON, REGINA HARBISON. (McCoy, Kevin)
March 26, 2024 Opinion or Order Filing 24 PAPERLESS ORDER granting #23 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney R. Thomas Avery. Mr. Avery may appear and participate in this action onbehalf of Defendants Christopher Harbison and Regina Harbison. Signed by Judge Raag Singhal on 3/26/2024. (jgr)
March 25, 2024 Filing 23 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for R. Thomas Avery. Filing Fee $ 200.00 Receipt # AFLSDC-17395025 by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 4/8/2024. (Attachments: #1 Exhibit A, #2 Exhibit B)(McCoy, Kevin)
March 22, 2024 Filing 22 (WITHDRAWN PER DE#30) First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 4/5/2024. (Amir, Ofer) Modified text on 4/18/2024 (scn).
March 22, 2024 Filing 21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 4/5/2024. (Amir, Ofer)
March 22, 2024 Filing 20 RESPONSE in Opposition re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Replies due by 3/29/2024. (Amir, Ofer)
March 22, 2024 Filing 19 AFFIDAVIT in Opposition re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Attachments: #1 Exhibit Contract, #2 Exhibit Billing, #3 Exhibit Additional Billing, #4 Exhibit Federal Court Chart, #5 Exhibit Federal Court Chart, #6 Exhibit Articles of Incorporation, #7 Exhibit Emails, #8 Exhibit Emails, #9 Exhibit Checks and Shipping)(Amir, Ofer)
March 15, 2024 Opinion or Order Filing 18 PAPERLESS ORDER granting #17 Motion for Extension of Time. Plaintiff shall have until 3/22/2024 to file a response to Defendants' Motion to Dismiss. Signed by Judge Raag Singhal on 3/15/2024. (jgr)
March 14, 2024 Filing 17 First MOTION for Extension of Time Respond to Motion to Dismiss by Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 3/28/2024. (Amir, Ofer)
March 11, 2024 Filing 16 Civil Complaint Cover Sheet by United States Attorney (Amir, Ofer)
March 6, 2024 Filing 15 Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by CHRISTOPHER HARBISON, REGINA HARBISON (McCoy, Kevin)
March 4, 2024 Opinion or Order Filing 14 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 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 3/4/2024. (jgr)
March 4, 2024 Filing 13 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 3/4/2024. (jgr)
March 1, 2024 Filing 12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 3/15/2024. (Attachments: #1 Exhibit Ex. 1 Rakusin Ref Report, #2 Exhibit Ex. 2 Declaration of Schwartz, #3 Exhibit Ex. 3 Declaration of R. Harbison)(McCoy, Kevin)
March 1, 2024 Opinion or Order Filing 11 PAPERLESS ORDER granting #9 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Aaron E. Schwartz. Signed by Judge Raag Singhal on 3/1/2024. (pb00)
March 1, 2024 Filing 10 NOTICE of Filing Proposed Order by CHRISTOPHER HARBISON, REGINA HARBISON re #9 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Aaron E. Schwartz. Filing Fee $ 200.00 Receipt # AFLSDC-17335093 (Attachments: #1 Text of Proposed Order Proposed Order) (McCoy, Kevin)
March 1, 2024 Filing 9 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Aaron E. Schwartz. Filing Fee $ 200.00 Receipt # AFLSDC-17335093 by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 3/15/2024. (Attachments: #1 Exhibit Certification of Aaron E. Schwartz)(McCoy, Kevin)
February 28, 2024 Filing 8 NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. All Parties. (Attachments: #1 Summon(s) Summons, #2 Exhibit Complaint, #3 Exhibit Request to Produce, #4 Exhibit Request to Produce, #5 Exhibit Waiver of service)(Amir, Ofer) Modified text on 2/29/2024 (scn).
February 28, 2024 Filing 7 NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. All Parties. (Attachments: #1 Summon(s) Summons, #2 Exhibit Complaint, #3 Exhibit Request to Produce, #4 Exhibit Request to Produce, #5 Exhibit Waiver of Service)(Amir, Ofer) Modified text on 2/29/2024 (scn).
February 28, 2024 Filing 6 Summons Issued as to CHRISTOPHER HARBISON, REGINA HARBISON. (scn)
February 27, 2024 Filing 5 NOTICE of Filing Proposed Summons(es) for Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer)
February 27, 2024 Filing 4 NOTICE of Filing Proposed Summons(es) for Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer)
February 23, 2024 Filing 3 Bar Letter re: Admissions sent to attorney R. Thomas Avery and Aaron E. Schwartz, mailing date February 23, 2024, (pt)
February 23, 2024 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 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. (wce)
February 23, 2024 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 405.00 receipt number AFLSDC-17316106, filed by REGINA HARBISON, CHRISTOPHER HARBISON. (No Answer/ Motion to Dismiss Filed)(Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B, #4 Docket Sheet Docket Sheet)(McCoy, Kevin) Modified Text on 2/23/2024 (wce).

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Plaintiff: LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION
Represented By: Ofer Moshe Amir
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Defendant: CHRISTOPHER HARBISON
Represented By: Kevin P. McCoy
Represented By: Aaron E. Schwartz
Represented By: R. Thomas Avery
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Defendant: REGINA HARBISON
Represented By: Kevin P. McCoy
Represented By: Aaron E. Schwartz
Represented By: R. Thomas Avery
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