Lee v. Direct Sales Advantage LLC et al
| Thomas Franklin Lee |
| Direct Sales Advantage LLC, Chlomi Ohana, Hanan Bajayo and Family Moving Services, Inc doing business as Texas Movers Group |
| 0:2026cv60249 |
| January 29, 2026 |
| U.S. District Court for the Southern District of Florida |
| Melissa Damian |
| Jared M Strauss |
| Labor: Fair Standards |
| 29 U.S.C. § 0201 Fair Labor Standards Act |
| Plaintiff |
Docket Report
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This docket was last retrieved on July 26, 2026. A more recent docket listing may be available from PACER.
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Filing 28
PAPERLESS ORDER GRANTING #22 Motion for Leave to File separate Responses to Complaint nunc pro tunc to March 12, 2026, finding good cause and noting the parties' filing of separate Motions. Signed by Judge Melissa Damian on 7/26/2026. (MD)
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Filing 27
ORDER Scheduling Mediation before Mediator Sarah Zabel. Mediation Hearing set for 11/3/2026 10:00 AM. Signed by Judge Melissa Damian on 6/1/2026. See attached document for full details. (ls)
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| Filing 26 Plaintiff's NOTICE of Filing Proposed Order Scheduling Mediation. (Attachments: #1 Text of Proposed Order)(Cuthbertson, Dillon) Modified Text on 6/1/2026 (ls). |
| Filing 25 NOTICE of Mediator Selection and Hearing. Selected/Added Sarah Zabel as Mediator. Mediation Hearing set for 11/03/2026 at 10:00 a.m.. (Zabel, Sarah) Modified Text on 6/1/2026 (ls). |
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Filing 24
DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jared M. Strauss on 5/22/2026. See attached document for full details. (jva)
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Filing 23
ORDER Setting Trial and Pre-Trial Schedule: ( Jury Trial set for 4/19/2027 in Fort Lauderdale Division before Judge Melissa Damian., Calendar Call set for 4/14/2027 01:30 PM in Fort Lauderdale Division before Judge Melissa Damian., Mediation Deadline 11/11/2026.), ORDER REFERRING CASE to Mediation., and ORDER REFERRING CASE to Magistrate Judge Jared M. Strauss for Discovery Matters. Signed by Judge Melissa Damian on 5/22/2026. See attached document for full details. (ls) #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.
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| Filing 22 Defendant's MOTION for Leave to File Separate Responses and Motions by Hanan Bajayo, Direct Sales Advantage LLC. Responses due by 5/29/2026. (Attachments: #1 Exhibit EMAIL)(Kassier, Andrew) |
| Filing 21 Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Family Moving Services, Inc, Chlomi Ohana (Battaglia, Nicholas) |
| Filing 20 Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Thomas Franklin Lee (Cuthbertson, Dillon) |
| Filing 19 Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Hanan Bajayo, Direct Sales Advantage LLC (Kassier, Andrew) |
| Filing 18 Joint SCHEDULING REPORT - Rule by Thomas Franklin Lee (Attachments: #1 Text of Proposed Order)(Grondin, Adam) |
| Filing 17 REPLY in Support of Motion re #11 MOTION to Dismiss with Prejudice #1 Complaint. filed by Family Moving Services, Inc, Chlomi Ohana. (Battaglia, Nicholas) |
| Filing 16 NOTICE of Attorney Appearance by Michael Alan Levin on behalf of Hanan Bajayo, Direct Sales Advantage LLC. Attorney Michael Alan Levin added to party Hanan Bajayo(pty:dft), Attorney Michael Alan Levin added to party Direct Sales Advantage LLC(pty:dft). (Levin, Michael) |
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Filing 15
ORDER REQUIRING SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES. Joint Scheduling Report due by 5/13/2026 Signed by Judge Melissa Damian on 4/22/2026. See attached document for full details. (drz)
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| Filing 14 Defendant's REPLY to Plaintiff's #13 Consolidated Response in Opposition in Support of Motion re #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM , #10 Defendant's MOTION for Court to Grant #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM By Default. filed by Hanan Bajayo, Direct Sales Advantage LLC. (Kassier, Andrew) |
| Filing 13 Consolidated RESPONSE in Opposition re #11 MOTION to Dismiss with Prejudice #1 Complaint, , #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM , #10 Defendant's MOTION for Court to Grant #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM By Default filed by Thomas Franklin Lee. Replies due by 4/20/2026. (Cuthbertson, Dillon) Modified Text on 4/14/2026 (ls). |
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Filing 12
ORDER Requiring Response to Motion: denying without prejudice #10 Defendant's Motion for Court to Grant #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM By Default. Show Cause or Response due by 4/13/2026 as to #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM. Signed by Judge Melissa Damian on 4/9/2026. See attached document for full details. (ls)
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| Filing 11 MOTION to Dismiss with Prejudice #1 Complaint, by Family Moving Services, Inc, Chlomi Ohana. Responses due by 4/16/2026. (Attachments: #1 Text of Proposed Order Proposed Order Granting Motion to Dismiss)(Battaglia, Nicholas) |
| Filing 10 Defendant's MOTION for Court to Grant #8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM By Default by Hanan Bajayo, Direct Sales Advantage LLC. Responses due by 4/13/2026. (Kassier, Andrew) Modified Relief on 4/9/2026 (ls). |
| Filing 9 NOTICE of Attorney Appearance by Nicholas Giovanni Battaglia on behalf of Family Moving Services, Inc, Chlomi Ohana. Attorney Nicholas Giovanni Battaglia added to party Family Moving Services, Inc(pty:dft), Attorney Nicholas Giovanni Battaglia added to party Chlomi Ohana(pty:dft). (Battaglia, Nicholas) |
| Filing 8 Defendant's MOTION TO DISMISS #1 Complaint, FOR FAILURE TO STATE A CLAIM by Hanan Bajayo, Direct Sales Advantage LLC. Responses due by 3/26/2026. (Kassier, Andrew) |
| Filing 7 NOTICE of Attorney Appearance by Andrew Michael Kassier on behalf of Hanan Bajayo, Direct Sales Advantage LLC. Attorney Andrew Michael Kassier added to party Hanan Bajayo(pty:dft), Attorney Andrew Michael Kassier added to party Direct Sales Advantage LLC(pty:dft). (Kassier, Andrew) |
| Filing 6 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Thomas Franklin Lee. Hanan Bajayo served on 2/23/2026, response/answer due 3/16/2026. (Cuthbertson, Dillon) |
| Filing 5 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Thomas Franklin Lee. Direct Sales Advantage LLC served on 2/23/2026, response/answer due 3/16/2026. (Cuthbertson, Dillon) |
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Filing 4
PAPERLESS ORDER ON COURT PRACTICE IN CASES WITH MULTIPLE DEFENDANTS THIS CAUSE is before the Court upon a sua sponte review of the record. To better manage the orderly progress of the case, it is hereby ORDERED as follows:1. Plaintiff shall file proof of service, as to each Defendant, within seven (7) days of perfecting service on each Defendant. 2. Defendants shall file their responses and motions jointly. a. If there are conflicts of position, the co-Defendants shall file a motion for leave to file separate responses or motions, in which they must describe what those conflicts are.b. If the co-Defendants need more than twenty (20) pages for their joint responses or motions, they shall file a motion for leave to file excess pages, which the Court will consider expeditiously. 3. The co-Defendants may file separate answers to the Complaint. Unless otherwise ordered by the Court, the time for responsive pleadings--for all Defendants--begins to run once all Defendants have either (1) been served or (2) waived service. If the Defendants face response periods of different lengths--say, because one Defendant has been personally served whereas another has waived service--all Defendants will be subject to the longest of those response periods. 4. Although all Defendants will be subject to the longest of all response periods, each served Defendant must still file a notice of appearance within twenty-one (21) days of being served with the Complaint (or sixty (60) days if service is waived).5. Failure to comply with these procedures may result in sanctions, including the striking of the motion(s) or response(s). Signed by Judge Melissa Damian on 1/30/2026. (mul)
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| Filing 3 Summons Issued as to Hanan Bajayo, Direct Sales Advantage LLC, Family Moving Services, Inc, Chlomi Ohana. (scn) |
| Filing 2 Clerks Notice of Judge Assignment to Judge Melissa Damian. 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. (scn) |
| Filing 1 COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-19168612, filed by Thomas Franklin Lee. (Attachments: #1 Civil Cover Sheet, #2 Summon(s), #3 Exhibit A - Plaintiff's Statement of Claim)(Cuthbertson, Dillon) |
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