Everson v. Ultimate Resort Vacations et al
| Arlena Everson |
| Turks and Caicos Collection, Ultimate Resort Vacations d/b/a Turks and Caicos Collection, Caicos Dream Tours, BLUE HAVEN MARINA LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina, BLUE HAVEN DEVELOPMENTS LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina, WATERLOO INVESTMENT HOLDINGS LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina, WATERLOO HOTEL MANAGEMENT LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina and WATERLOO HOTEL MANAGEMENT (BERMUDA) LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina |
| 0:2024cv62061 |
| November 1, 2024 |
| U.S. District Court for the Southern District of Florida |
| Raag Singhal |
| P.I.: Other |
| 28 U.S.C. § 1441 Notice of Removal |
| Plaintiff |
Docket Report
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This docket was last retrieved on December 21, 2024. A more recent docket listing may be available from PACER.
| Document Text |
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Filing 24
PAPERLESS ORDER granting #23 Defendant's Unopposed Motion for Extension of Time to Respond to Plaintiff's First Amended Complaint. Defendant has up to and including January 21, 2025 to file its response. Signed by Judge Raag Singhal on 12/21/2024. (nni)
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| Filing 23 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #20 Amended Complaint/Amended Notice of Removal, by Caicos Dream Tours. (Attachments: #1 Text of Proposed Order)(Meza, Veronica) |
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Filing 22
PAPERLESS ORDER granting #21 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document by Ultimate Resort Vacations and WATERLOO HOTEL MANAGEMENT LIMITED. Response/Answer due 1/21/2025. Signed by Judge Raag Singhal on 12/19/2024. (pb00)
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| Filing 21 MOTION for Extension of Time to File Response/Reply/Answer as to #20 Amended Complaint/Amended Notice of Removal, by Ultimate Resort Vacations, WATERLOO HOTEL MANAGEMENT LIMITED. Attorney Chelsea Emma Koff added to party WATERLOO HOTEL MANAGEMENT LIMITED(pty:dft). (Koff, Chelsea) |
| Filing 20 First AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL against Caicos Dream Tours, Turks and Caicos Collection, Ultimate Resort Vacations, WATERLOO INVESTMENT HOLDINGS LIMITED, WATERLOO HOTEL MANAGEMENT (BERMUDA) LIMITED, WATERLOO HOTEL MANAGEMENT LIMITED, BLUE HAVEN DEVELOPMENTS LIMITED, BLUE HAVEN MARINA LIMITED, filed by Arlena Everson.(Aklepi, Eliana) |
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Filing 19
PAPERLESS ORDER granting #18 Unopposed Motion for Extension of Time to Amend Complaint. Plaintiff's Amended Complaint due by 12/17/2024. The Motion to Dismiss #15 filed by Turks and Caicos Collection and Ultimate Resort Vacations is DENIED AS MOOT. The Motion to Dismiss #16 filed by Caicos Dream Tours is DENIED AS MOOT. Signed by Judge Raag Singhal on 12/2/2024. (pb00)
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| Filing 18 Unopposed MOTION for Extension of Time to Amend COMPLAINT IN LIEU OF RESPONDING TO DEFENDANTS' MOTIONS TO DISMISS [D.E. 15, 16] by Arlena Everson. Responses due by 12/11/2024. (Attachments: #1 Text of Proposed Order)(Aklepi, Eliana) |
| Filing 17 Defendant's NOTICE of Joinder in Argument for Dismiss Based on Forum Non Conveniens Grounds Filed on November 13, 2024 by Co-Defendants by Caicos Dream Tours re #15 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), MOTION TO DISMISS #1 Notice of Removal (State Court Complaint), FOR FAILURE TO STATE A CLAIM (Meza, Veronica) |
| Filing 16 Defendant's MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by Caicos Dream Tours. Responses due by 12/2/2024. (Attachments: #1 Exhibit A - Declaration of Mike Hesse in Support of Motion to Dismiss)(Meza, Veronica) |
| Filing 15 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , MOTION TO DISMISS #1 Notice of Removal (State Court Complaint), FOR FAILURE TO STATE A CLAIM by Turks and Caicos Collection, Ultimate Resort Vacations. Responses due by 11/27/2024. (Attachments: #1 Exhibit DECLARATION OF HEATHER ALLEN)(Koff, Chelsea) |
| Filing 14 Certificate of Other Affiliates/Corporate Disclosure Statement by Turks and Caicos Collection, Ultimate Resort Vacations identifying Other Affiliate BLUE HAVEN RESORT AND MARINA, Other Affiliate Blue Haven Resort Ltd., Other Affiliate Blue Haven Marina Ltd., Other Affiliate Waterloo Hotel Management (Bermuda) Ltd., Other Affiliate Waterloo Investments Holdings Ltd., Other Affiliate Waterloo Hotel Management Ltd., Other Affiliate Blue Haven Resort, Other Affiliate Alejandro Rodriguez, Other Affiliate Craig Steven Barnett, Other Affiliate Lord Michael Ashcroft for Turks and Caicos Collection, Ultimate Resort Vacations (Koff, Chelsea) |
| Filing 13 Clerk's Notice to Filer re #12 Certificate of Other Affiliates/Corporate Disclosure Statement,,. Other Affiliates/Corporate Parents Not Entered; ERROR - The Filer failed to enter all Other Affiliates/Corporate Parents from the Certificate of Other Affiliates/Corporate Disclosure Statement. Filer is instructed to refile their Certificate of Other Affiliates/Corporate Disclosure Statement and enter the missing Other Affiliates/Corp Parents. Note - Other Affiliates/Corporate Parents do not appear on the docket sheet. (nan) |
| Filing 12 Certificate of Other Affiliates/Corporate Disclosure Statement by Turks and Caicos Collection, Ultimate Resort Vacations identifying Other Affiliate Waterloo Hotel Management Ltd. d/b/a Turks and Caicos Collection and d/b/a Blue Haven Resort, Other Affiliate Blue Haven Resort Ltd., Other Affiliate Blue Haven Marina Ltd., Other Affiliate Waterloo Hotel Management (Bermuda) Ltd., Other Affiliate Waterloo Investments Holdings Ltd., Other Affiliate Lord Michael Ashcroft for Turks and Caicos Collection, Ultimate Resort Vacations (Koff, Chelsea) |
| Filing 11 Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by Caicos Dream Tours identifying Corporate Parent CDT Holdings, Ltd. for Caicos Dream Tours (Meza, Veronica) |
| Filing 10 Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Arlena Everson (Aklepi, Eliana) |
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Filing 9
PAPERLESS ORDER granting #5 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document by Caicos Dream Tours. Response/Answer due 11/15/2024. Signed by Judge Raag Singhal on 11/2/2024. (pb00)
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Filing 8
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 11/2/2024. (pb00)
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| Filing 7 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). Motions for Extension of Time 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). Labeling Exhibits on CM/ECF Exhibits to pleadings and motions shall be docketed in accordance with the Court's 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.) Notices of Settlement 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 11/2/2024. (pb00) |
| Filing 6 Defendant's NOTICE of Filing Civil Cover Sheet by Caicos Dream Tours re 3 Clerk's Notice to Filer re: Electronic Case (Attachments: #1 Exhibit A) (Meza, Veronica) |
| Filing 5 Defendant's MOTION for Extension of Time to File Response/Reply/Answer as to #1 Notice of Removal (State Court Complaint), by Caicos Dream Tours. (Attachments: #1 Text of Proposed Order)(Meza, Veronica) |
| Filing 4 Defendant's Notice of Consent and Joinder in Removal by Turks and Caicos Collection, Ultimate Resort Vacations re #1 Notice of Removal (State Court Complaint),. Attorney Chelsea Emma Koff added to party Turks and Caicos Collection(pty:dft), Attorney Chelsea Emma Koff added to party Ultimate Resort Vacations(pty:dft). (Koff, Chelsea) |
| Filing 3 Clerk's Notice to Filer re: Electronic Case. No Civil Cover Sheet. Filer is instructed to file a Notice (Other) with the Civil Cover Sheet attached within 24 hours of the notice. (pc) |
| 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. (pc) |
| Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint and Demand for Jury Trial) Filing fee $ 405.00 receipt number AFLSDC-17953614, filed by Caicos Dream Tours. (Attachments: #1 Exhibit A)(Meza, Veronica) (Complaint see pg.8 of Attachment 1, no Answer/Motion to Dismiss filed) Modified text on 11/1/2024 (pc). |
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| Defendant: Turks and Caicos Collection | |
| Represented By: | Chelsea Emma Koff |
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| Defendant: Ultimate Resort Vacations d/b/a Turks and Caicos Collection | |
| Represented By: | Chelsea Emma Koff |
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| Defendant: Caicos Dream Tours | |
| Represented By: | Veronica Andrea Meza |
| Represented By: | Richard Leo Barry |
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| Defendant: BLUE HAVEN MARINA LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina | |
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| Defendant: BLUE HAVEN DEVELOPMENTS LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina | |
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| Defendant: WATERLOO INVESTMENT HOLDINGS LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina | |
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| Defendant: WATERLOO HOTEL MANAGEMENT LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina | |
| Represented By: | Chelsea Emma Koff |
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| Defendant: WATERLOO HOTEL MANAGEMENT (BERMUDA) LIMITED doing business as Turks and Caicos Collection and Blue Haven Resort and Marina | |
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| Plaintiff: Arlena Everson | |
| Represented By: | Geoffrey Edward Probst |
| Represented By: | Eliana Lital Aklepi |
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