KIPU Systems, LLC v. Zencharts, LLC et al
Plaintiff: KIPU Systems, LLC
Defendant: Zencharts, LLC, Anton Aladzhov, Zen Medical, LLC, Callahan Holdings, Inc., Yanko Karkalichev, Solutions Recovery, LLC, Website Consultants, Inc., Daniel J. Callahan, Sean Callahan, Seamus Callahan, Richard Glaser, Keith Houilhan, Solutions Recovery Center, LLC and Keith Hootie
Case Number: 1:2017cv24733
Filed: December 31, 2017
Court: US District Court for the Southern District of Florida
Office: Miami Office
County: Miami-Dade (Office: Miami)
Presiding Judge: Edwin G Torres
Referring Judge: Kathleen M Williams
Nature of Suit: Trademark
Cause of Action: 18 U.S.C. § 1836
Jury Demanded By: Defendant
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Docket Report

This docket was last retrieved on December 16, 2021. A more recent docket listing may be available from PACER.

Date Filed Document Text
November 13, 2019 Opinion or Order Filing 294 Plaintiff's CERTIFICATE of Compliance Re Admitted Evidence for exhibit(s): 9,13,14,17,18,40,62,73,76-82,89,91,92,106,108,119,123-125,127-129,131,132,134,136-139, 143-147,149-151,153-155,158,159,161-163,165,166,170,174,175,177,189-191,197,198,213, 216,217,219,220,221,227,238,257,260,275,339,355,435-437,446,450,500-506,508,525,530, 531,535,536,537,540,542,545,546,549,550,555-564,566,579,580-582,587,588,598-606,627, 628,636,684-696,703,798,799,800 , Defendants' Demonstrative A-G and Plaintiff's Demonstrative A-C by Christopher B Spuches on behalf of KIPU Systems, LLC (Spuches, Christopher)
November 13, 2019 Opinion or Order Filing 293 TRIAL EXHIBITS Defendants Demonstrative A-G, Plaintiff's Demonstrative A-C, and Trial Exhibits 9,13,14,17,18,40,62,73,76-82,89,91,92,106,108,119,123-125,127-129,131,132,134,136-139, 143-147,149-151,153-155,158,159,161-163,165,166,170,174,175,177,189-191,197,198,213, 216,217,219,220,221,227,238,257,260,275,339,355,435-437,446,450,500-506,508,525,530, 531,535,536,537,540,542,545,546,549,550,555-564,566,579,580-582,587,588,598-606,627, 628,636,684-696,703,798,799,800 by KIPU Systems, LLC. (Attachments: #1 Exhibit 9, #2 Exhibit 13, #3 Exhibit 14, #4 Exhibit 17, #5 Exhibit 18, #6 Exhibit 40, #7 Exhibit 62, #8 Exhibit 73, #9 Exhibit 76, #10 Exhibit 77, #11 Exhibit 78, #12 Exhibit 79, #13 Exhibit 80, #14 Exhibit 81, #15 Exhibit 82, #16 Exhibit 89, #17 Exhibit 91, #18 Exhibit 92, #19 Exhibit 106, #20 Exhibit 108, #21 Exhibit 119, #22 Exhibit 123, #23 Exhibit 124, #24 Exhibit 125, #25 Exhibit 127, #26 Exhibit 128, #27 Exhibit 129, #28 Exhibit 131, #29 Exhibit 132, #30 Exhibit 134, #31 Exhibit 136, #32 Exhibit 137, #33 Exhibit 138, #34 Exhibit 139, #35 Exhibit 143, #36 Exhibit 144, #37 Exhibit 145, #38 Exhibit 146, #39 Exhibit 147, #40 Exhibit 149, #41 Exhibit 150, #42 Exhibit 151, #43 Exhibit 153, #44 Exhibit 154, #45 Exhibit 155, #46 Exhibit 158, #47 Exhibit 159, #48 Exhibit 161, #49 Exhibit 162, #50 Exhibit 163, #51 Exhibit 165, #52 Exhibit 166, #53 Exhibit 170, #54 Exhibit 174, #55 Exhibit 175, #56 Exhibit 177, #57 Exhibit 189, #58 Exhibit 190, #59 Exhibit 191, #60 Exhibit 197, #61 Exhibit 198, #62 Exhibit 213, #63 Exhibit 216, #64 Exhibit 217, #65 Exhibit 219, #66 Exhibit 220, #67 Exhibit 221, #68 Exhibit 227, #69 Exhibit 238, #70 Exhibit 257, #71 Exhibit 260, #72 Exhibit 275, #73 Exhibit 339, #74 Exhibit 355, #75 Exhibit 435, #76 Exhibit 436, #77 Exhibit 437, #78 Exhibit 446, #79 Exhibit 450, #80 Exhibit 500, #81 Exhibit 501, #82 Exhibit 502, #83 Exhibit 503, #84 Exhibit 504, #85 Exhibit 505, #86 Exhibit 506, #87 Exhibit 508, #88 Exhibit 525, #89 Exhibit 530, #90 Exhibit 531, #91 Exhibit 535, #92 Exhibit 536, #93 Exhibit 537, #94 Exhibit 540, #95 Exhibit 542, #96 Exhibit 545, #97 Exhibit 546, #98 Exhibit 549, #99 Exhibit 550, #100 Exhibit 555, #101 Exhibit 556, #102 Exhibit 557, #103 Exhibit 558, #104 Exhibit 559, #105 Exhibit 560, #106 Exhibit 561, #107 Exhibit 562, #108 Exhibit 563, #109 Exhibit 564, #110 Exhibit 566, #111 Exhibit 579, #112 Exhibit 580, #113 Exhibit 581, #114 Exhibit 582, #115 Exhibit 587, #116 Exhibit 588, #117 Exhibit 598, #118 Exhibit 599, #119 Exhibit 600, #120 Exhibit 601, #121 Exhibit 602, #122 Exhibit 603, #123 Exhibit 604, #124 Exhibit 605, #125 Exhibit 606, #126 Exhibit 627, #127 Exhibit 628, #128 Exhibit 636, #129 Exhibit 703, #130 Exhibit 798, #131 Exhibit 800, #132 Exhibit Defendants Demonstrative A, #133 Exhibit Defendants Demonstrative B, #134 Exhibit Defendants Demonstrative C, #135 Exhibit Defendants Demonstrative D, #136 Exhibit Defendants Demonstrative E, #137 Exhibit Defendants Demonstrative F, #138 Exhibit Defendants Demonstrative G, #139 Exhibit Plaintiff's Demonstrative A, #140 Exhibit Plaintiff's Demonstrative B, #141 Exhibit Plaintiff's Demonstrative C, #142 Exhibit 799, #143 Exhibit 684, #144 Exhibit 685, #145 Exhibit 686, #146 Exhibit 687, #147 Exhibit 688, #148 Exhibit 689, #149 Exhibit 690, #150 Exhibit 691, #151 Exhibit 692, #152 Exhibit 693, #153 Exhibit 694, #154 Exhibit 695, #155 Exhibit 696)(Spuches, Christopher)
November 4, 2019 Opinion or Order Filing 292 JURY VERDICT FORM. (mso)
November 4, 2019 Opinion or Order Filing 291 Jury Note. (mso)
November 4, 2019 Opinion or Order Filing 290 Court's Jury Instructions. (mso)
November 4, 2019 Opinion or Order Filing 289 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: Jury Trial completed on 11/4/2019. Jury reached a verdict. Verdict published and read in open Court. Jurors were polled. Jurors excused. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 31, 2019 Opinion or Order Filing 288 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 9 Jury Trial on 10/31/2019. Court and parties finalize the jury instructions and verdict form. Court conducted a charge conference. Jury began deliberations. Jury excused for the afternoon and will return on 11/1/2019 to resume their deliberations. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 30, 2019 Opinion or Order Filing 287 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 8 Jury Trial on 10/30/2019. The Court and jury heard further witness testimony and reviewed admitted exhibits on the record. Jurors were excused for the afternoon and will return on 10/31/2019 to resume trial. Court reviewed jury instructions with the parties. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 29, 2019 Opinion or Order Filing 286 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 7 Jury Trial on 10/29/2019. The Court and jury heard further witness testimony and reviewed admitted exhibits on the record. Court adjourned. Jurors were excused for the afternoon and will return on 10/30/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 29, 2019 Opinion or Order Filing 284 MEMORANDUM in Opposition re #281 MOTION for Judgment as a Matter of Law by KIPU Systems, LLC. (Spuches, Christopher)
October 28, 2019 Opinion or Order Filing 285 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 6 Jury Trial on 10/28/2019. The Court and the jury heard further witness testimony and reviewed admitted exhibits on the record. The Plaintiff rests. Defense made an ore tenus motion for directed verdict. Court reserved ruling. Court adjourned. Jurors were excused for the afternoon and will return on 10/29/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 28, 2019 Opinion or Order Filing 283 Notice of Supplemental Authority in Support of Objection to Lost Profit Evidence by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC (Attachments: #1 Supplement Authority) (Brumby, Charles)
October 28, 2019 Opinion or Order Filing 282 TRANSCRIPT of Trial excerpt held on 10/21/19 before Judge Kathleen M. Williams, Volume Number 1 of 1, 1-114 pages, Court Reporter: Vernita Allen-Williams, 305-523-5048 / Vernita_Allen-Williams@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 11/18/2019. Redacted Transcript Deadline set for 11/29/2019. Release of Transcript Restriction set for 1/26/2020. (vas)
October 28, 2019 Opinion or Order Filing 281 MOTION for Judgment as a Matter of Law by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
October 25, 2019 Opinion or Order Filing 280 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 5 Jury Trial on 10/25/2019. The Court and the jury heard further witness testimony and reviewed admitted exhibits on the record. Court adjourned. Jurors were excused for the afternoon and will return on 10/28/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 24, 2019 Opinion or Order Filing 279 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 4 Jury Trial on 10/24/2019. The Court and the jury heard further witness testimony and reviewed additional admitted exhibits on the record. (See attachment for the parties stipulated exhibits). Court adjourned. Jurors were excused for the afternoon and will return on 10/25/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 23, 2019 Opinion or Order Filing 278 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 3 Jury Trial on 10/23/2019. The Court and the jury heard further witness testimony and reviewed additional admitted exhibits on the record. The Court adjourned. Jurors were excused for the afternoon and will return on 10/24/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso) Modified docket entry on 10/24/2019 to add stipulated exhibit lists (mso).
October 22, 2019 Opinion or Order Filing 277 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: DAY # 2 Jury Trial on 10/22/2019. The Court and the jury heard further witness testimony and reviewed additional admitted exhibits on the record. The Court adjourned. Jurors were excused for the afternoon and will return on 10/23/2019 to resume trial. Counsel of record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 22, 2019 Opinion or Order Filing 275 MOTION in Limine to Limit Plaintiff from Expanding Unfair Competition Claim by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Zencharts, LLC. (Brumby, Charles)
October 21, 2019 Opinion or Order Filing 276 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: Jury Selection/Voir Dire held on 10/21/2019. DAY # 1 Jury Trial begun on 10/21/2019. The Court and the jury heard opening statements made by Plaintiff's counsel and Defense counsel. The Court and the jury heard witness testimony and reviewed admitted exhibits on the record. The Court adjourned. The Jurors were excused and will return on 10/22/2019 to resume trial. Counsel of record present. Court Reporter: Vernita Allen-Williams, 305-523-5048 / Vernita_Allen-Williams@flsd.uscourts.gov. (mso)
October 21, 2019 Opinion or Order Filing 274 Statement of: Acts Constituting Unfair Competition Count V of Second Amended Complaint, by KIPU Systems, LLC(a Florida limited liability company) (Martorella, Jason)
October 21, 2019 Opinion or Order Filing 273 Witness List Second Amended by KIPU Systems, LLC.. (Spuches, Christopher)
October 18, 2019 Opinion or Order Filing 272 Exhibit and Witness List JOINT NOTICE OF FILING AMENDED EXHIBIT AND WITNESS LISTS by KIPU Systems, LLC.. (Attachments: #1 Exhibit Exhibit A - Plaintiffs Amended Exhibit List, #2 Exhibit Exhibit B - Defendants Amended Exhibit List, #3 Exhibit Exhibit C - Plaintiffs Amended Witness List, #4 Exhibit Exhibit D - Defendants Amended Exhibit List)(Spuches, Christopher)
October 17, 2019 Opinion or Order Filing 271 ORDER GRANTING IN PART DEFENDANTS' MOTION FOR LEAVE TO BRING ELECTRONIC EQUIPMENT INTO THE COURTHOUSE. Signed by Judge Kathleen M. Williams on 10/17/2019. See attached document for full details. (dpa)
October 17, 2019 Opinion or Order Filing 270 ORDER GRANTING IN PART PLAINTIFF'S MOTION FOR LEAVE TO BRING ELECTRONIC EQUIPMENT INTO THE COURTHOUSE. Signed by Judge Kathleen M. Williams on 10/17/2019. See attached document for full details. (dpa)
October 16, 2019 Opinion or Order Filing 269 ORDER granting in part and denying in part #169 #173 Motions for Partial Summary Judgment. Signed by Judge Kathleen M. Williams on 10/16/2019. See attached document for full details. (dpa)
October 16, 2019 Opinion or Order Filing 268 ORDER DENYING #171 Motion ; DENYING #175 Motion in Limine; GRANTING IN PART AND DENYING IN PART #194 Motion in Limine; DENYING AS MOOT #227 Motion for Hearing; DENYING #244 Appeal/Objection of Magistrate Judge Order to District Court. Jury trial in this matter is RESET for October 21, 2019 at 9:00 a.m. Signed by Judge Kathleen M. Williams on 10/16/2019. See attached document for full details. (ebz)
October 16, 2019 Opinion or Order Filing 267 NOTICE of Attorney Appearance by Jason Alan Martorella on behalf of KIPU Systems, LLC (Martorella, Jason)
October 16, 2019 Opinion or Order Reset Hearings Jury Trial RESET for 10/21/2019 09:00 AM before Judge Kathleen M. Williams per #268 . (ebz) Modified text on 10/16/2019 (asl).
October 15, 2019 Opinion or Order Filing 266 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: Final Pretrial Conference held on 10/15/2019. Counsel of Record present. Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
October 11, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 265 [misc] restricted/sealed until further notice. (1162176)
October 11, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 264 [misc] restricted/sealed until further notice. (1162176)
October 10, 2019 Opinion or Order Filing 263 ORDER ON DEPOSITION DESIGNATIONS. Signed by Magistrate Judge Edwin G. Torres on 10/10/2019. See attached document for full details. (EGT)
October 7, 2019 Opinion or Order Filing 262 PAPERLESS ORDER granting #243 Motion for Hearing. This MATTER is SET for a Pretrial Conference on 10/15/2019 at 09:30 AM in Miami Division before Judge Kathleen M. Williams. Calendar call set for October 8, 2019 is CANCELED. Jury trial set for the week of October 15, 2019 is CONTINUED and will be reset by separate order. Signed by Judge Kathleen M. Williams on 10/7/2019. (dpa)
October 3, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 258 [motion] restricted/sealed until further notice. (1401318)
October 3, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 259 [misc] restricted/sealed until further notice. (1401318)
October 3, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 260 [misc] restricted/sealed until further notice. (1401318)
October 3, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 261 [misc] restricted/sealed until further notice. (1401318)
October 2, 2019 Opinion or Order Filing 255 PAPERLESS ORDER. Pursuant to the Court's Paperless Order 252 granting the motions to seal, the Parties are ORDERED to file unredacted versions of the exhibits under seal by October 3, 2019 at 12:00 pm. Signed by Judge Kathleen M. Williams on 10/2/2019. (dpa)
October 2, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 256 [misc] restricted/sealed until further notice. (1162176)
October 2, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 257 [misc] restricted/sealed until further notice. (1162176)
September 30, 2019 Opinion or Order Filing 254 REPLY to #244 OBJECTION of Magistrate Judge #241 Order on Motion for Sanctions to District Court by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
September 30, 2019 Opinion or Order Filing 253 CLERK'S NOTICE of Compliance by Sealing 193 , 199 , 201 , and 224 pursuant to 252 Paperless Order (nc)
September 30, 2019 Opinion or Order Filing 252 PAPERLESS ORDER granting #200 #203 #230 Motions to Seal. Signed by Judge Kathleen M. Williams on 9/30/2019. (dpa)
September 24, 2019 Opinion or Order Filing 251 ORDER granting #246 Plaintiff's Unopposed Motion to Seal Exhibits. Signed by Magistrate Judge Edwin G. Torres on 9/24/2019. See attached document for full details. (js02)
September 23, 2019 Opinion or Order Filing 250 Plaintiff's RESPONSE to #244 OBJECTION of Magistrate Judge #241 Order on Motion for Sanctions to District Court by KIPU Systems, LLC(a Florida limited liability company). (Martorella, Jason)
September 18, 2019 Opinion or Order ***CORRECTED NOTICE OF HEARING FOR CALENDAR CALL*** Calendar Call set for 10/8/2019 11:00 AM in Miami Division before Judge Kathleen M. Williams. (mso)
September 18, 2019 Opinion or Order Set/Reset Hearings. Calendar Call set for 10/1/2019 at 1:00 AM in Miami Division before Senior Judge Patricia A. Seitz. (mso)
September 17, 2019 Opinion or Order Filing 249 PAPERLESS ORDER granting #232 Motion for Extension of Time. The Parties' filings shall be deemed timely. Signed by Judge Kathleen M. Williams on 9/17/2019. (dpa)
September 17, 2019 Opinion or Order Filing 248 PAPERLESS ORDER REFERRING #245 DEPOSITION DESIGNATIONS AND #246 PLAINTIFF'S MOTION TO SEAL. Pursuant to 28 U.S.C. 636 and the Magistrate Rules of the Local Rules for the Southern District of Florida, the Parties' deposition designations #245 and Plaintiffs motion to seal #246 are REFERRED to United States Magistrate Judge Edwin G. Torres for any appropriate action required by law. Signed by Judge Kathleen M. Williams on 9/17/2019. (dpa)
September 17, 2019 Opinion or Order Filing 247 PAPERLESS ORDER granting #242 Motion for Extension of Time. The filed deposition designations shall be deemed timely. Signed by Judge Kathleen M. Williams on 9/17/2019. (dpa)
September 10, 2019 Opinion or Order Filing 246 Plaintiff's MOTION to Seal Certain Exhibits to Parties' Joint Notice of Filing Deposition Designations per Local Rule 5.4 by KIPU Systems, LLC(a Florida limited liability company). (Spuches, Christopher)
September 10, 2019 Opinion or Order Filing 245 NOTICE by KIPU Systems, LLC(a Florida limited liability company) of Filing Deposition Designations (Attachments: #1 Exhibit Exhibit 1 (Ocean Recovery 30(b)(6)), #2 Exhibit Exhibit 2 (Pathway to Hope 30(b)(6)), #3 Exhibit Exhibit 3 (Henderson), #4 Exhibit Exhibit 4 (Potere), #5 Exhibit Exhibit 5 (M. Walsh), #6 Exhibit Exhibit 6 (P. Walsh), #7 Exhibit Exhibit 7 (W. Walsh), #8 Exhibit Exhibit 8 (Houlihan), #9 Exhibit Exhibit 9 (Karkalichev), #10 Exhibit Exhibit 10 (Kipu 30(b)(6))) (Spuches, Christopher)
September 9, 2019 Opinion or Order Filing 244 OBJECTION of Magistrate Judge #241 Order on Motion for Sanctions to District Court (Brumby, Charles)
September 6, 2019 Opinion or Order Filing 243 Joint MOTION for Hearing Pretrial Conference by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
September 6, 2019 Opinion or Order Filing 242 Joint MOTION for Extension of Time to Extend September 6, 2019 Deadline in Scheduling Order re #109 Order on Motion to Dismiss for Failure to State a Claim,,, Order on Motion for More Definite Statement,,, Order on Motion for Extension of Time,, by KIPU Systems, LLC. Responses due by 9/20/2019 (Spuches, Christopher)
August 26, 2019 Opinion or Order Filing 241 ORDER denying 193 Defendant's Motion for Sanctions. Signed by Magistrate Judge Edwin G. Torres on 8/26/2019. See attached document for full details. (js02)
August 21, 2019 Opinion or Order Filing 240 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand , COUNTERCLAIM against KIPU Systems, LLC(a Florida limited liability company) by Zencharts, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Brumby, Charles)
August 21, 2019 Opinion or Order Filing 239 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand , COUNTERCLAIM against KIPU Systems, LLC(a Florida limited liability company) by Solutions Recovery Center, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I)(Brumby, Charles)
August 21, 2019 Opinion or Order Filing 238 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Website Consultants, Inc.. (Brumby, Charles)
August 21, 2019 Opinion or Order Filing 237 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Sean Callahan. (Brumby, Charles)
August 21, 2019 Opinion or Order Filing 236 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Yanko Karkalichev. (Brumby, Charles)
August 21, 2019 Opinion or Order Filing 235 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Richard Glaser. (Brumby, Charles)
August 21, 2019 Opinion or Order Filing 234 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Daniel J. Callahan. (Brumby, Charles)
August 20, 2019 Opinion or Order Filing 233 PRETRIAL STIPULATION by KIPU Systems, LLC (Attachments: #1 Exhibit Ex A - Plaintiffs Trial Exhibit List, #2 Exhibit Ex B - Defendants Trial Exhibit List, #3 Exhibit Ex C - Plaintiffs Witness List - Final, #4 Exhibit Ex D - Defendants Witness List - Final)(Spuches, Christopher)
August 19, 2019 Opinion or Order Filing 232 Joint MOTION for Extension of Time to File Pretrial Stipulation, Exhibit Lists, Witness Lists, and Jury Instructions re 212 Order on Motion for Extension of Time by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Responses due by 9/3/2019 (Attachments: #1 Text of Proposed Order Proposed Order)(Brumby, Charles)
August 13, 2019 Opinion or Order Filing 231 RESPONSE to Motion re #165 Plaintiff's MOTION for Preliminary Injunction filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 8/20/2019. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Brumby, Charles)
August 9, 2019 Opinion or Order Filing 230 Unopposed MOTION to Seal DE 224 per Local Rule 5.4 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Attachments: #1 Text of Proposed Order) (Brumby, Charles)
August 8, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 229 [misc] restricted/sealed until further notice. (1401318)
August 6, 2019 Opinion or Order Filing 227 Unopposed MOTION for Hearing re 193 MOTION for Sanctions by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
August 6, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 228 [misc] restricted/sealed until further notice. (1162176)
August 2, 2019 Opinion or Order Filing 226 PAPERLESS ORDER CANCELING PRELIMINARY INJUNCTION HEARING. In light of the Parties' stipulated notice #225 withdrawing Plaintiff's motion for a preliminary injunction, the hearing set for August 14, 2019 is CANCELED. Signed by Judge Kathleen M. Williams on 8/2/2019. (dpa)
August 2, 2019 Opinion or Order Filing 225 NOTICE OF WITHDRAWAL OF MOTION by KIPU Systems, LLC re #165 Plaintiff's MOTION for Preliminary Injunction filed by KIPU Systems, LLC (Spuches, Christopher)
August 1, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 224 [respm] restricted/sealed until further notice. (nc)
July 31, 2019 Opinion or Order Filing 223 Second AMENDED COMPLAINT against Daniel J. Callahan, Sean Callahan, Richard Glaser, Keith Houilhan, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zen Medical, LLC, Zencharts, LLC filed in response to Order Granting Motion for Leave, filed by KIPU Systems, LLC. (Attachments: #1 Exhibit Exhibit A (2013 License Agreement), #2 Exhibit Exhibit B (2013 TOS), #3 Exhibit Exhibit C (2014 TOS), #4 Exhibit Exhibit D (Screen Shot), #5 Exhibit Exhibit E (WHOIS Information))(Spuches, Christopher)
July 25, 2019 Opinion or Order Filing 222 RESPONSE in Opposition re 193 MOTION for Sanctions filed by KIPU Systems, LLC. Replies due by 8/1/2019. (Attachments: #1 Exhibit Exhibit A - E-mail, #2 Exhibit Exhibit B - E-mail, #3 Exhibit Exhibit C - E-mail, #4 Exhibit Exhibit D - Declaration of Brian Bell, #5 Exhibit Composite Exhibit E - E-mail)(Spuches, Christopher)
July 23, 2019 Opinion or Order Filing 221 REPLY to Response to Motion re #194 MOTION in Limine filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Brumby, Charles)
July 23, 2019 Opinion or Order Filing 220 PAPERLESS ORDER granting #196 Plaintiff's Motion for Leave to File an Amended Complaint for the Limited Purpose of Withdrawing Certain Claims for good cause shown in the unopposed motion. Clerks Notice: Filer must separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge. Signed by Magistrate Judge Edwin G. Torres on 7/23/2019. (js02)
July 23, 2019 Opinion or Order Filing 219 PAPERLESS ORDER granting #208 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Kye Handy. The Clerk shall add pro hac counsel as co-counsel of record for the named Defendants. Signed by Magistrate Judge Edwin G. Torres on 7/23/2019. (EGT)
July 22, 2019 Opinion or Order Filing 218 REPLY to Response to Motion re #173 MOTION for Partial Summary Judgment and Memorandum of Law filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
July 22, 2019 Opinion or Order Filing 217 REPLY to Response to Motion re #175 MOTION in Limine to Exclude Expert Testimony filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
July 19, 2019 Opinion or Order Filing 216 Clerks Notice to Filer re 213 MOTION to Seal Plaintiff, KIPU Systems, LLC's Reply to Defendants' Opposition to Plaintiff's Motion to Exclude Defendant ZenCharts LLC's Expert Witness Alan R. Barbee re ECF No. 199 per Order authorizing the submissio. Wrong Event Selected; ERROR - The Filer selected the wrong event. This document is not a Motion and has been corrected by the Clerk. It is not necessary to refile this document. (nc)
July 19, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 213 [motion] restricted/sealed until further notice. (nc)
July 19, 2019 Opinion or Order Filing 215 Statement of: Undisputed Material Facts (Reply) by KIPU Systems, LLC(a Florida limited liability company) re 201 Response/Reply (Other),, (Martorella, Jason)
July 19, 2019 Opinion or Order Filing 214 REPLY to Response to Motion re #169 Plaintiff's MOTION for Partial Summary Judgment and Supporting Memorandum of Law filed by KIPU Systems, LLC(a Florida limited liability company). (Martorella, Jason)
July 16, 2019 Opinion or Order Filing 212 PAPERLESS ORDER granting #210 Motion for Extension of Time. The Motion is GRANTED for the time period requested. Signed by Judge Kathleen M. Williams on 7/16/2019. (dpa)
July 16, 2019 Opinion or Order Filing 211 RESPONSE in Opposition re #194 MOTION in Limine filed by KIPU Systems, LLC. Replies due by 7/23/2019. (Spuches, Christopher)
July 11, 2019 Opinion or Order Filing 210 Joint MOTION for Extension of Time to Extend July 25, 2019 Deadline in Scheduling Order re #109 Order on Motion to Dismiss for Failure to State a Claim,,, Order on Motion for More Definite Statement,,, Order on Motion for Extension of Time,, by KIPU Systems, LLC. Responses due by 7/25/2019 (Spuches, Christopher)
July 9, 2019 Opinion or Order Filing 209 PAPERLESS ORDER Setting Hearing on #165 Plaintiff's Motion for Preliminary Injunction. This case is set for a Hearing on Plaintiffs Motion for Preliminary Injunction #165 before the Honorable Kathleen Williams at the United States District Court, 400 North Miami Avenue, Room 11-3, Miami, Florida on August 14, 2019 at 9:00 a.m. Signed by Judge Kathleen M. Williams on 7/9/2019. (dpa)
July 9, 2019 Opinion or Order Filing 208 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Kye Handy. Filing Fee $ 75.00 Receipt # 113C-11795251 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Responses due by 7/23/2019 (Brumby, Charles)
July 9, 2019 Opinion or Order Filing 207 PAPERLESS ORDER granting #206 Motion for Extension of Time, for good cause shown in the unopposed motion:Plaintiff's response to motion for sanctions 193 extended to July 25, 2019. Signed by Magistrate Judge Edwin G. Torres on 7/9/2019. (EGT)
July 9, 2019 Opinion or Order Filing 206 Unopposed MOTION for Extension of Time to File Response to Defendants' Motion for Sanctions re 193 MOTION for Sanctions by KIPU Systems, LLC. Responses due by 7/23/2019 (Spuches, Christopher)
July 3, 2019 Opinion or Order Filing 205 KIPU Systems LLC's ANSWER to Counterclaim and Affirmative Defenses to Solutions Recovery Center LLC's Amended Counterclaim by KIPU Systems, LLC(a Florida limited liability company). (Spuches, Christopher)
July 3, 2019 Opinion or Order Filing 204 KIPU Systems LLC's ANSWER to Counterclaim and Affirmative Defenses to Zencharts LLC's Amended Counterclaim by KIPU Systems, LLC(a Florida limited liability company). (Spuches, Christopher)
July 2, 2019 Opinion or Order Filing 203 MOTION to Seal DEs 193, 199 and 201 per Local Rule 5.4 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
July 1, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 199 [respm] restricted/sealed until further notice. (nc)
July 1, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 201 [respm] restricted/sealed until further notice. (nc)
July 1, 2019 Opinion or Order Filing 202 RESPONSE in Opposition re #169 Plaintiff's MOTION for Partial Summary Judgment and Supporting Memorandum of Law filed by Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 7/8/2019. (Brumby, Charles)
July 1, 2019 Opinion or Order Filing 200 MOTION to Seal Certain Exhibits to Response in Opposition per Local Rule 5.4 by KIPU Systems, LLC(a Florida limited liability company). (Spuches, Christopher)
July 1, 2019 Opinion or Order Filing 198 Statement of: Counterstatement of Material Facts by KIPU Systems, LLC(a Florida limited liability company) re #174 Statement,, (Attachments: #1 Exhibit 1 - Deposition of Yanko Karkalichev, #2 Exhibit 2 - Declaration of Brian Bell, #3 Exhibit 3 - Declaration of Jeffery Fiorentino, #4 Exhibit 4 - ZenChart Financials, #5 Exhibit 5 - Blass Rebuttal Report)(Spuches, Christopher)
July 1, 2019 Opinion or Order Filing 197 MEMORANDUM in Opposition re #173 MOTION for Partial Summary Judgment and Memorandum of Law by KIPU Systems, LLC. (Spuches, Christopher)
July 1, 2019 Opinion or Order Filing 196 Unopposed MOTION for Leave to File Second Amended Complaint for the Limited Purpose of Withdrawing Certain Claims by KIPU Systems, LLC. (Attachments: #1 Exhibit Exhibit 1 - Second Amended Complaint)(Spuches, Christopher)
June 28, 2019 Opinion or Order Filing 195 RESPONSE in Opposition re #175 MOTION in Limine to Exclude Expert Testimony of Alan Blass filed by KIPU Systems, LLC. Replies due by 7/8/2019. (Attachments: #1 Exhibit Expert Report of Alan I Blass, #2 Exhibit Expert Response to Rebuttal Report on Lost Profits)(Spuches, Christopher)
June 25, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 193 [motion] restricted/sealed until further notice. (nc)
June 25, 2019 Opinion or Order Filing 194 MOTION in Limine by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Brumby, Charles)
June 19, 2019 Opinion or Order Filing 192 PAPERLESS ORDER granting #190 Motion for Extension of Time. Plaintiff shall file its reply in support of its motion for a preliminary injunction on or before June 28, 2019. Signed by Judge Kathleen M. Williams on 6/19/2019. (dpa)
June 19, 2019 Opinion or Order Filing 191 PAPERLESS ORDER granting #188 Motion to Seal. Signed by Judge Kathleen M. Williams on 6/19/2019. (dpa)
June 14, 2019 Opinion or Order Filing 190 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #187 Response in Opposition to Motion,, by KIPU Systems, LLC. (Spuches, Christopher)
June 11, 2019 Opinion or Order Filing 189 NOTICE of Attorney Appearance by Javier Jesus Rodriguez on behalf of KIPU Systems, LLC(a Florida limited liability company). Attorney Javier Jesus Rodriguez added to party KIPU Systems, LLC(pty:cd). (Rodriguez, Javier)
June 10, 2019 Opinion or Order Filing 188 Unopposed MOTION to Seal Exhibits to DE 187 per Local Rule 5.4 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
June 10, 2019 Opinion or Order Filing 187 RESPONSE in Opposition re #165 Plaintiff's MOTION for Preliminary Injunction filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 6/17/2019. (Attachments: #1 Exhibit Ex. A, #2 Exhibit Ex. B, #3 Exhibit Ex. C, #4 Exhibit Ex. D, #5 Exhibit Ex. E, #6 Exhibit Ex. F, #7 Exhibit Ex. G, #8 Exhibit Ex. H, #9 Exhibit Ex. I, #10 Exhibit Ex. J, #11 Exhibit Ex. K, #12 Exhibit Ex. L, #13 Exhibit Ex. M, #14 Exhibit Ex. N, #15 Exhibit Ex. O, #16 Exhibit Ex. P, #17 Exhibit Ex. Q)(Brumby, Charles)
June 7, 2019 Opinion or Order SYSTEM ENTRY - Docket Entry 186 [misc] restricted/sealed until further notice. (1162176)
June 6, 2019 Opinion or Order Filing 185 PAPERLESS ORDER granting #177 Motion for Extension of Time. Pursuant to the discussions held on the record the responses to the Daubert motions and the motions for summary judgment shall be filed on or before July 1, 2019 and the replies shall be filed on or before July 22, 2019. Signed by Judge Kathleen M. Williams on 6/6/2019. (dpa)
June 6, 2019 Opinion or Order Filing 184 CLERK'S NOTICE of Compliance by Sealing #174 Exhibits, and #175 Exhibits pursuant to 182 Paperless Order (nc)
June 6, 2019 Opinion or Order Filing 183 CLERK'S NOTICE of Compliance by Sealing [165-5],[165-8],[165-9], and [165-10] pursuant to 180 Paperless Order (nc)
June 6, 2019 Opinion or Order Filing 182 PAPERLESS ORDER granting #172 #176 Motions for leave to file under Seal. Signed by Judge Kathleen M. Williams on 6/6/2019. (dpa)
June 6, 2019 Opinion or Order Filing 181 PAPERLESS ORDER granting #168 Motion for Leave to File Under Seal. 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 Kathleen M. Williams on 6/6/2019. (dpa)
June 6, 2019 Opinion or Order Filing 180 PAPERLESS ORDER granting #166 Motion to Seal. Signed by Judge Kathleen M. Williams on 6/6/2019. (dpa)
May 29, 2019 Opinion or Order Filing 179 ORDER denying #156 Plaintiff's Motion for Leave to File an Amended Complaint. Signed by Magistrate Judge Edwin G. Torres on 5/29/2019. See attached document for full details. (js02)
May 24, 2019 Opinion or Order Filing 178 REPLY to Response to Motion re #156 Plaintiff's MOTION for Leave to File Amend Complaint Solely for the Limited Purpose of Withdrawing Certain Claims filed by KIPU Systems, LLC. (Spuches, Christopher)
May 24, 2019 Opinion or Order Filing 177 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #175 MOTION in Limine to Exclude Expert Testimony, #171 Plaintiff's MOTION to Exclude Defendant Zencharts LLC's Expert Witness Alan R. Barbee , #169 Plaintiff's MOTION for Partial Summary Judgment and Supporting Memorandum of Law by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Attachments: #1 Text of Proposed Order)(Brumby, Charles)
May 20, 2019 Opinion or Order Filing 176 Unopposed MOTION to Seal Exhibits to DE 174 and 175 per Local Rule 5.4 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Brumby, Charles)
May 20, 2019 Opinion or Order Filing 175 MOTION in Limine to Exclude Expert Testimony by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Zencharts, LLC. (Attachments: #1 Exhibit Ex 1, #2 Exhibit Ex 2, #3 Exhibit Ex 3, #4 Exhibit Ex 4, #5 Exhibit Ex 5, #6 Exhibit Ex 6, #7 Exhibit Ex 7, #8 Exhibit Ex 8, #9 Exhibit Ex 9, #10 Exhibit Ex 10, #11 Exhibit Ex 11)(Brumby, Charles) Modified by Sealing Exhibits pursuant to 182 Paperless Order on 6/6/2019 (nc).
May 20, 2019 Opinion or Order Filing 174 Statement of: Material Facts by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC re #173 MOTION for Partial Summary Judgment and Memorandum of Law (Attachments: #1 A, #2 B, #3 C, #4 D, #5 E, #6 F, #7 G, #8 H, #9 I, #10 J, #11 K, #12 L, #13 M, #14 N, #15 O, #16 P, #17 Q, #18 R, #19 S, #20 T, #21 U)(Brumby, Charles) Modified by Sealing Exhibits pursuant to 182 Paperless Order on 6/6/2019 (nc). Modified on 6/6/2019 (nc).
May 20, 2019 Opinion or Order Filing 173 MOTION for Partial Summary Judgment and Memorandum of Law by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Responses due by 6/3/2019 (Brumby, Charles)
May 20, 2019 Opinion or Order Filing 172 Plaintiff's MOTION to Seal Certain Exhibits to Motion to Exclude Defendant Zenchart LLC's Expert Witness Alan R. Barbee per Local Rule 5.4 by KIPU Systems, LLC. (Spuches, Christopher)
May 20, 2019 Opinion or Order Filing 171 Plaintiff's MOTION to Exclude Defendant Zencharts LLC's Expert Witness Alan R. Barbee by KIPU Systems, LLC. (Attachments: #1 Exhibit Exhibit 1 -Expert Report of Alan R. Barbee, #2 Exhibit Exhibit 2 - Zenchart's Responses to KIPU's Second Set of Interrogatories)(Spuches, Christopher)
May 20, 2019 Opinion or Order Filing 170 Statement of: Undisputed Material Facts in Support of Motion for Partial Summary Judgment by KIPU Systems, LLC (Attachments: #1 Exhibit Exhibit 1 - Declaration of Fiorentino, #2 Exhibit Exhibit 2 - Deposition Transcript of D. Callahan, #3 Exhibit Exhibit 3 - Declaration of Brian Bell, #4 Exhibit Exhibit 4 - Deposition Transcript of Glaser, #5 Exhibit Exhibit 5 - Deposition Transcript of S. Callahan, #6 Exhibit Exhibit 6 - Deposition Transcript of Karkalichev, #7 Exhibit Exhibit 7 - Deposition Transcript of Franoszek)(Spuches, Christopher)
May 20, 2019 Opinion or Order Filing 169 Plaintiff's MOTION for Partial Summary Judgment and Supporting Memorandum of Law by KIPU Systems, LLC. Responses due by 6/3/2019 (Spuches, Christopher)
May 18, 2019 Opinion or Order Filing 168 Unopposed MOTION for Leave to File Summary Judgment Exhibits Under Seal by KIPU Systems, LLC(a Florida limited liability company). Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:pla), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd), Attorney Jason Alan Martorella added to party KIPU Systems, LLC(pty:cd). (Martorella, Jason)
May 17, 2019 Opinion or Order Filing 167 RESPONSE in Opposition re #156 Plaintiff's MOTION for Leave to File Amend Complaint Solely for the Limited Purpose of Withdrawing Certain Claims filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 5/24/2019. (Brumby, Charles)
May 17, 2019 Opinion or Order Filing 166 Unopposed MOTION to Seal Certain Filed Documents per Local Rule 5.4 by KIPU Systems, LLC. (Spuches, Christopher)
May 10, 2019 Opinion or Order Filing 165 Plaintiff's MOTION for Preliminary Injunction by KIPU Systems, LLC. (Attachments: #1 Exhibit Declaration of Jeffrey Fiorentino In Support of Motion for Preliminary Injunction, #2 Exhibit Declaration of Brian Bell In Support of Motion for Preliminary Injunction, #3 Exhibit 2013 License Agreement In Support of Motion for Preliminary Injunction, #4 Exhibit 2013 TOS In Support of Motion for Preliminary Injunction, #5 Exhibit Deposition of Transcript of Richard Glaser April 24, 2019 In Support of Motion for Preliminary Injunction, #6 Exhibit 2014 TOS In Support of Motion for Preliminary Injunction, #7 Exhibit Access Log In Support of Motion for Preliminary Injunction, #8 Exhibit Deposition of Transcript of Sean Callahan April 10, 2019 In Support of Motion for Preliminary Injunction, #9 Exhibit Deposition of Transcript of Yanko Karkallichev December 11, 2018 In Support of Motion for Preliminary Injunction, #10 Exhibit Deposition of Transcript of Daniel J. Callahan April 11, 2019 In Support of Motion for Preliminary Injunction, #11 Exhibit Expert Report of Alan I. Blass CPA CFE PA Confidential In Support of Motion for Preliminary Injunction)(Spuches, Christopher) Modified by Sealing Exhibits [165-5],[165-8],[165-9],[165-10] pursuant to 180 Paperless Order on 6/6/2019 (nc).
May 9, 2019 Opinion or Order Filing 164 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand , Amended COUNTERCLAIM against KIPU Systems, LLC by Solutions Recovery Center, LLC. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit)(Brumby, Charles)
May 9, 2019 Opinion or Order Filing 163 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand , Amended COUNTERCLAIM against KIPU Systems, LLC by Zencharts, LLC. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit)(Brumby, Charles)
May 9, 2019 Opinion or Order Filing 162 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Website Consultants, Inc.. (Brumby, Charles)
May 9, 2019 Opinion or Order Filing 161 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Sean Callahan. (Brumby, Charles)
May 9, 2019 Opinion or Order Filing 160 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Richard Glaser. (Brumby, Charles)
May 9, 2019 Opinion or Order Filing 159 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Yanko Karkalichev. (Brumby, Charles)
May 9, 2019 Opinion or Order Filing 158 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Daniel J. Callahan. (Brumby, Charles)
May 9, 2019 Opinion or Order Filing 157 TRANSCRIPT of Status Conference held on 3/28/19 before Judge Kathleen M. Williams, 1-56 pages, Court Reporter: Vernita Allen-Williams, 305-523-5048 / Vernita_Allen-Williams@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/30/2019. Redacted Transcript Deadline set for 6/10/2019. Release of Transcript Restriction set for 8/7/2019. (vas)
May 3, 2019 Opinion or Order Filing 156 Plaintiff's MOTION for Leave to File Amend Complaint Solely for the Limited Purpose of Withdrawing Certain Claims by KIPU Systems, LLC. (Spuches, Christopher)
April 18, 2019 Opinion or Order Filing 155 PAPERLESS ORDER granting #154 Motion to Withdraw as Attorney. Jake Matthew Greenberg terminated from case as counsel for Plaintiff, which remains represented by separate counsel in the action. Signed by Magistrate Judge Edwin G. Torres on 4/18/2019. (EGT)
April 18, 2019 Opinion or Order Filing 154 Unopposed MOTION to Withdraw as Attorney by Jake M. Greenberg for / by KIPU Systems, LLC. Responses due by 5/2/2019 (Greenberg, Jake)
April 16, 2019 Opinion or Order Filing 153 PAPERLESS ORDER denying as moot #147 Motion to Dismiss for Lack of Jurisdiction. In light of Plaintiff's notice of voluntary dismissal of Defendant Aladzhov #151 152 this motion is DENIED AS MOOT. Signed by Judge Kathleen M. Williams on 4/16/2019. (dpa)
April 16, 2019 Opinion or Order Filing 152 PAPERLESS Order Dismissing Defendant Anton Aladzhov. THIS MATTER is before the Court on Plaintiff's notice of voluntary dismissal of its claims against Defendant Anton Aladzhov. #151 . Upon a review of the notice and the record, it is ORDERED AND ADJUDGED that Plaintiff's claims against Defendant Anton Aladzhov are DISMISSED WITHOUT PREJUDICE. Signed by Judge Kathleen M. Williams on 4/16/2019. (dpa)
April 16, 2019 Opinion or Order Filing 151 NOTICE of Voluntary Dismissal , Without Prejudice, as to Anton Aladzhov by KIPU Systems, LLC(a Florida limited liability company) (Greenberg, Jake)
April 12, 2019 Opinion or Order Filing 150 Minute Entry for proceedings held before Magistrate Judge Edwin G. Torres: Discovery Hearing held on 4/12/2019. (Digital 15:50:23) (mdc)
April 12, 2019 Opinion or Order Attorney Cameron Christopher Murphy and Joshua B. Spector terminated per Order at DE 140. (bb)
April 11, 2019 Opinion or Order Filing 149 DISCOVERY ORDER re 3/8/2019 hearing. Signed by Magistrate Judge Edwin G. Torres on 4/11/2019. See attached document for full details. (EGT)
April 10, 2019 Opinion or Order Filing 148 TRANSCRIPT of Hearing held on 3/8/19 before Magistrate Judge Edwin G. Torres, 1-47 pages, Court Reporter: Joanne Mancari, 305-523-5635. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/1/2019. Redacted Transcript Deadline set for 5/13/2019. Release of Transcript Restriction set for 7/9/2019. (hh)
March 29, 2019 Opinion or Order Filing 147 Amended MOTION to Dismiss for Lack of Jurisdiction #118 Amended Complaint, by Anton Aladzhov. Responses due by 4/12/2019 (Attachments: #1 Exhibit Ex. 1, Affidavit)(Brumby, Charles)
March 28, 2019 Opinion or Order Filing 146 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: Miscellaneous Hearing held on 3/28/2019. Counsel of record present. Court Reporter: Vernita Allen-Williams, 305-523-5048 / Vernita_Allen-Williams@flsd.uscourts.gov. (mso)
March 28, 2019 Opinion or Order Filing 145 OMNIBUS ORDER FOLLOWING MOTIONS HEARING. Signed by Judge Kathleen M. Williams on 3/28/2019. See attached document for full details. (dpa)
March 28, 2019 Opinion or Order Filing 144 NOTICE of Attorney Appearance by Mark Evan Stein on behalf of KIPU Systems, LLC(a Florida limited liability company). Attorney Mark Evan Stein added to party KIPU Systems, LLC(pty:cd), Attorney Mark Evan Stein added to party KIPU Systems, LLC(pty:cd), Attorney Mark Evan Stein added to party KIPU Systems, LLC(pty:pla), Attorney Mark Evan Stein added to party KIPU Systems, LLC(pty:cd), Attorney Mark Evan Stein added to party KIPU Systems, LLC(pty:cd). (Stein, Mark)
March 22, 2019 Opinion or Order Filing 143 PAPERLESS NOTICE of Hearing: A Discovery Hearing is set for 4/12/2019 at 03:30 PM in Miami Division before Magistrate Judge Edwin G. Torres. (js02)
March 20, 2019 Opinion or Order Filing 142 PAPERLESS ORDER denying as moot #64 Motion to Dismiss for Lack of Jurisdiction. The Motion #64 is denied as moot in light of the filing of an amended complaint. Signed by Judge Kathleen M. Williams on 3/20/2019. (dpa)
March 15, 2019 Opinion or Order Filing 141 PAPERLESS ORDER. The hearing set for March 28, 2019 at 10:00 AM is RESET for March 28, 2019 at 2:00 PM in the Miami Division before Judge Kathleen M. Williams. The motion for a preliminary injunction #38 will be heard at a later date. All other outstanding motions will be heard during the March 28, 2019 hearing. **TIME CHANGE ONLY** Signed by Judge Kathleen M. Williams on 3/15/2019. (jws)
March 13, 2019 Opinion or Order Filing 140 PAPERLESS ORDER granting #139 Motion to Withdraw as Attorney. Robert Houpt Thornburg and Allen Dyer law firm withdrawn from case as counsel for Plaintiff, which remains represented by other counsel of record in the action. Signed by Magistrate Judge Edwin G. Torres on 3/13/2019. (EGT)
March 13, 2019 Opinion or Order Filing 139 Unopposed MOTION to Withdraw as Attorney Co-Counsel by Allen, Dyer, Doppelt + Gilchrist, P.A. for / by KIPU Systems, LLC. Responses due by 3/27/2019 (Attachments: #1 Text of Proposed Order)(Thornburg, Robert)
February 28, 2019 Opinion or Order Filing 138 PAPERLESS ORDER SETTING HEARING. This case is set for a hearing on all outstanding issues in this matter before the Honorable Kathleen Williams at the United States District Court, 400 North Miami Avenue, Room 11-3, Miami, Florida on March 28, 2019 at 10:00 a.m. Signed by Judge Kathleen M. Williams on 3/28/2019. (dpa)
February 27, 2019 Opinion or Order Filing 137 Notification of Ninety Days Expiring by Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC re #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM filed by Richard Glaser, Sean Callahan, Solutions Recovery Center, LLC, Yanko Karkalichev, Website Consultants, Inc., Zencharts, LLC, Daniel J. Callahan, Anton Aladzhov. Attorney Charles Brumby added to party Anton Aladzhov(pty:dft), Attorney Charles Brumby added to party Daniel J. Callahan(pty:dft), Attorney Charles Brumby added to party Sean Callahan(pty:dft), Attorney Charles Brumby added to party Richard Glaser(pty:dft), Attorney Charles Brumby added to party Yanko Karkalichev(pty:dft), Attorney Charles Brumby added to party Solutions Recovery Center, LLC(pty:dft), Attorney Charles Brumby added to party Website Consultants, Inc.(pty:dft), Attorney Charles Brumby added to party Zencharts, LLC(pty:dft). (Brumby, Charles)
February 12, 2019 Opinion or Order Filing 136 PAPERLESS NOTICE of Hearing: Discovery Hearing set for March 8, 2019 at 01:30 PM in the Miami Division before Magistrate Judge Edwin G. Torres, James Lawrence King Federal Justice Building, 99 NE 4th Street, Tenth Floor, Courtroom 5, Miami, Florida, 33132. (abu)
February 5, 2019 Opinion or Order Filing 135 DISCOVERY ORDER re Hearing held 1/25/2019. Signed by Magistrate Judge Edwin G. Torres on 2/5/2019. See attached document for full details. (EGT)
February 5, 2019 Opinion or Order Filing 134 DISCOVERY ORDER re Hearing held 10/28/2018. Signed by Magistrate Judge Edwin G. Torres on 2/5/2019. See attached document for full details. (EGT)
January 25, 2019 Opinion or Order Filing 133 PAPERLESS NOTICE of Hearing: **TIME CHANGE ONLY** The Discovery Hearing set for January 25, 2019 has been changed to 2:00 PM. The hearing will take place in the Miami Division before Magistrate Judge Edwin G. Torres. (abu)
January 14, 2019 Opinion or Order Filing 132 NOTICE of Compliance with Order Setting Discovery Procedures by KIPU Systems, LLC re 130 Notice re Hearing, (Greenberg, Jake)
January 14, 2019 Opinion or Order Filing 131 PAPERLESS ORDER re Notice of Hearing. The movant for the upcoming discovery hearing shall submit a proposed order to the undersigned in accordance with the Court's Standing Order on Discovery Procedures by noon on 1/21/2019. Docket Order Signed by Magistrate Judge Edwin G. Torres on 1/14/2019. (js02)
January 7, 2019 Opinion or Order Filing 130 PAPERLESS NOTICE of Hearing: Discovery Hearing set for 1/25/2019 at 01:30 PM in the Miami Division before Magistrate Judge Edwin G. Torres, James Lawrence King Bldg., Courtroom 5 - Tenth Floor, 99 N.E. 4th Street, Miami, Florida. Any deadlines to respond that involve the materials at issue will hereby be stayed pending resolution at the hearing. (abu)
December 19, 2018 Opinion or Order Filing 129 MEDIATION REPORT by Leslie J. Lott. Disposition: Adjourned.(Lott, Leslie)
November 14, 2018 Opinion or Order Filing 128 RESPONSE in Support re #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM filed by Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Gregory, Geremy)
November 7, 2018 Opinion or Order Filing 127 RESPONSE in Opposition re #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM filed by KIPU Systems, LLC. Replies due by 11/14/2018. (Greenberg, Jake)
November 6, 2018 Opinion or Order Filing 126 PAPERLESS ORDER RESCHEDULING MEDIATION. The mediation conference in this matter shall be held with Leslie Lott on December 12, 2018, at 10:00 a.m. at Agentis PLLC, 55 Alhambra Plaza, Suite 800, Coral Gables, Florida 33134. This date shall not be rescheduled without leave of Court, which will not be granted absent a motion setting forth good cause. The parties are responsible for ensuring that within three business days of the mediation, a mediation report is filed, indicating whether the case settled (in full or in part), was continued with the consent of the parties, or whether the mediator declared an impasse. Signed by Judge Kathleen M. Williams on 11/6/2018. (dpa)
November 6, 2018 Opinion or Order Filing 125 REPLY to Response to Motion re #123 MOTION to Amend/Correct #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM filed by Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Gregory, Geremy)
October 31, 2018 Opinion or Order Filing 124 RESPONSE in Opposition re #123 MOTION to Amend/Correct #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM filed by KIPU Systems, LLC. Replies due by 11/7/2018. (Spuches, Christopher)
October 29, 2018 Opinion or Order Filing 123 MOTION to Amend/Correct #121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM by Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC(a Florida limited liability company). Responses due by 11/13/2018 (Attachments: #1 Exhibit)(Gregory, Geremy)
October 26, 2018 Opinion or Order Filing 122 NOTICE by KIPU Systems, LLC(a Florida limited liability company) re #82 Scheduling Order,,,, Order Referring Case to Mediation,,, Amended Re-Notice of Filing Proposed Order Scheduling Mediation (Attachments: #1 Text of Proposed Order Amended Order Scheduling Mediation) (Spuches, Christopher)
October 24, 2018 Opinion or Order Filing 121 MOTION TO DISMISS #118 Amended Complaint, FOR FAILURE TO STATE A CLAIM by Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Responses due by 11/7/2018 (Gregory, Geremy)
October 18, 2018 Opinion or Order Filing 120 REPLY to Response to Motion re #114 Plaintiff's MOTION TO DISMISS #111 Answer to Complaint,, Counterclaim, #110 Answer to Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM Plaintiffs Motion to Dismiss Solutions Recovery Center, LLCs Amended Counterclaim [D.E. 110] and C Plaintiff's Reply to ZenCharts and Solutions Recovery Center's Response in Opposition to Plaintiff's Motion to Dismiss Amended Counterclaim filed by KIPU Systems, LLC(a Florida limited liability company). (Greenberg, Jake)
October 11, 2018 Opinion or Order Filing 119 RESPONSE in Opposition re #114 Plaintiff's MOTION TO DISMISS #111 Answer to Complaint,, Counterclaim, #110 Answer to Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM Plaintiffs Motion to Dismiss Solutions Recovery Center, LLCs Amended Counterclaim [D.E. 110] and C filed by Solutions Recovery Center, LLC, Zencharts, LLC. Replies due by 10/18/2018. (Gregory, Geremy)
October 10, 2018 Opinion or Order Filing 118 First AMENDED COMPLAINT against Anton Aladzhov, Daniel J. Callahan, Sean Callahan, Richard Glaser, Keith Houilhan, Yanko Karkalichev, Solutions Recovery, LLC, Website Consultants, Inc., Zen Medical, LLC, Zencharts, LLC filed in response to Order Granting Motion for Leave, filed by KIPU Systems, LLC. (Attachments: #1 Exhibit EXHIBIT A, #2 Exhibit EXHIBIT B, #3 Exhibit EXHIBIT C, #4 Exhibit EXHIBIT D, #5 Exhibit EXHIBIT E)(Spuches, Christopher)
October 10, 2018 Opinion or Order Filing 117 PAPERLESS ORDER granting #112 Motion to Amend/Correct Complaint, for good cause shown as well as the absence of timely opposition. Clerks Notice: Filer must promptly and separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge. Signed by Magistrate Judge Edwin G. Torres on 10/10/2018. (EGT)
October 9, 2018 Opinion or Order Filing 116 NOTICE of Compliance AMENDED NOTICE OF COMPLIANCE WITH ORDER SETTING DISCOVERY PROCEDURES by KIPU Systems, LLC(a Florida limited liability company) (Greenberg, Jake)
September 28, 2018 Opinion or Order Filing 115 NOTICE of Compliance NOTICE OF COMPLIANCE WITH ORDER SETTING DISCOVERY PROCEDURES by KIPU Systems, LLC(a Florida limited liability company) re 113 Notice re Hearing, (Greenberg, Jake)
September 27, 2018 Opinion or Order Filing 114 Plaintiff's MOTION TO DISMISS #111 Answer to Complaint,, Counterclaim, #110 Answer to Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM Plaintiffs Motion to Dismiss Solutions Recovery Center, LLCs Amended Counterclaim [D.E. 110] and Count IV of ZenCharts, LLCs Amended Counterclaim [D.E. 111] for Failure to State a Claim by KIPU Systems, LLC(a Florida limited liability company). Responses due by 10/11/2018 (Greenberg, Jake)
September 26, 2018 Opinion or Order Filing 113 PAPERLESS NOTICE of Hearing: Discovery Hearing set for 10/26/2018 at 02:30 PM in the Miami Division before Magistrate Judge Edwin G. Torres, James Lawrence King Bldg., Courtroom 5 - Tenth Floor, 99 N.E. 4th Street, Miami, Florida. (abu)
September 24, 2018 Opinion or Order Filing 112 Plaintiff's MOTION to Amend/Correct #1 Complaint,,, by KIPU Systems, LLC. Responses due by 10/9/2018 (Attachments: #1 Proposed First Amended Complaint)(Thornburg, Robert)
September 13, 2018 Opinion or Order Filing 111 ANSWER and Affirmative Defenses to Complaint with Jury Demand , Amended COUNTERCLAIM against KIPU Systems, LLC by Zencharts, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Gregory, Geremy)
September 13, 2018 Opinion or Order Filing 110 ANSWER and Affirmative Defenses to Complaint with Jury Demand , Amended COUNTERCLAIM against KIPU Systems, LLC by Solutions Recovery Center, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K)(Gregory, Geremy)
August 27, 2018 Opinion or Order Filing 109 ORDER granting in part and denying in part #43 Motion to Dismiss for Failure to State a Claim; granting in part and denying in part #43 Motion for More Definite Statement; granting in part and denying in part #96 Motion for Extension of Time; (Calendar Call set for 10/8/2019 11:00 AM in Miami Division before Judge Kathleen M. Williams., Jury Trial set for 10/15/2019 in Miami Division before Judge Kathleen M. Williams.); Signed by Judge Kathleen M. Williams on 8/27/2018. See attached document for full details. (jas)
August 24, 2018 Opinion or Order Filing 108 NOTICE OF WITHDRAWAL OF MOTION by Solutions Recovery Center, LLC re #45 MOTION for Summary Judgment (Partial) filed by Solutions Recovery Center, LLC (Gregory, Geremy)
August 23, 2018 Opinion or Order Filing 107 STIPULATED PROTECTIVE ORDER TO GOVERN DISSEMINATION OF CERTAINCONFIDENTIAL AND SENSITIVE INFORMATION; granting #105 Joint MOTION for Protective Order and Confidentiality Order and Incorporated Memorandum of Law filed by KIPU Systems, LLC. Signed by Judge Kathleen M. Williams on 8/23/2018. See attached document for full details. (jas)
August 23, 2018 Opinion or Order Filing 106 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams: Status Conference held on 8/23/2018. Attorney Appearance(s): Walter H. Boone, Christopher B Spuches, Jake Matthew Greenberg, Robert Houpt Thornburg, Joshua B. Spector, Court Reporter: Patricia Sanders, 305-523-5548 / Patricia_Sanders@flsd.uscourts.gov. (mso)
August 21, 2018 Opinion or Order Filing 105 Joint MOTION for Protective Order and Confidentiality Order and Incorporated Memorandum of Law by KIPU Systems, LLC. (Attachments: #1 Order Granting Joint Motion for Entry of a Confidentiality and Protective Order and Incorporated Memorandum of Law)(Spuches, Christopher)
August 16, 2018 Opinion or Order Filing 104 Clerks Notice to Filer re #103 Notice (Other). Docket Text Does Not Match Document; ERROR - The Filer failed to enter a title in the docket text that matches the title of the document. The correction was made by the Clerk. It is not necessary to refile the document. (jas)
August 15, 2018 Opinion or Order Filing 103 NOTICE of Filing Corrected Declaration of Richard Glasar by Zencharts, LLC (Attachments: #1 Exhibit) (Gregory, Geremy) Modified text on 8/16/2018 (jas).
August 8, 2018 Opinion or Order Filing 102 PAPERLESS ORDER Setting Status Conference. The Parties shall appear for a status conference before the Honorable Kathleen M. Williams on August 23, 2018 at 3:00 p.m. The Parties shall be prepared to discuss all pending motions. Signed by Judge Kathleen M. Williams on 8/8/2018. (dpa)
August 7, 2018 Opinion or Order Filing 101 NOTICE by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC re 97 ORDER Scheduling Mediation,, (Attachments: #1 Text of Proposed Order) (Gregory, Geremy)
August 3, 2018 Opinion or Order Filing 100 REPLY to #96 First MOTION for Extension of Time Pre-Trial Deadlines re #82 Scheduling Order,,,, Order Referring Case to Mediation,,, by KIPU Systems, LLC(a Florida limited liability company). (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit)(Greenberg, Jake)
July 30, 2018 Opinion or Order Filing 99 RESPONSE in Opposition re #96 First MOTION for Extension of Time Pre-Trial Deadlines re #82 Scheduling Order,,,, Order Referring Case to Mediation,,, filed by Daniel J. Callahan, Sean Callahan, Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 8/6/2018. (Attachments: #1 Exhibit, #2 Exhibit)(Gregory, Geremy)
July 18, 2018 Opinion or Order Filing 98 PAPERLESS NOTICE of Hearing: **TIME CHANGE ONLY**: The discovery hearing set for July 20, 2018 at 03:30 PM is hereby RESET to 2:30 P.M. All other procedures and obligations remain in place. (abu)
July 17, 2018 Opinion or Order Filing 97 PAPERLESS ORDER SCHEDULING MEDIATION. The mediation conference in this matter shall be held with Leslie Lott, Esq. on September 14, 2018, at 10:00 AM at 501 Brickell Key Drive, Suite 300, Miami, Florida 33131. This date shall not be rescheduled without leave of Court. The parties are responsible for ensuring that by September 14, 2018 , a mediation report is filed, indicating whether the case settled (in full or in part), was continued with the consent of the parties, or whether the mediator declared an impasse. Signed by Judge Kathleen M. Williams on 7/17/2018. (dpa)
July 16, 2018 Opinion or Order Filing 96 First MOTION for Extension of Time Pre-Trial Deadlines re #82 Scheduling Order,,,, Order Referring Case to Mediation,,, by KIPU Systems, LLC(a Florida limited liability company). Responses due by 7/30/2018 (Attachments: #1 Text of Proposed Order)(Spuches, Christopher)
July 16, 2018 Opinion or Order Filing 95 Notice of Entry of Parties Listed on #82 Scheduling Order,,,, Order Referring Case to Mediation,,, into CM/ECF. NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Leslie J. Lott. (Attachments: #1 Text of Proposed Order Order Scheduling Mediation) (Spuches, Christopher)
July 16, 2018 Opinion or Order Filing 94 NOTICE of Hearing by ATTORNEY: Discovery Hearing set for 7/20/2018 03:30 PM in Miami Division before Magistrate Judge Edwin G. Torres. (Gregory, Geremy)
July 13, 2018 Opinion or Order Filing 93 Clerks Notice to Filer re #91 Notice (Other),. Mediator Not Added; ERROR - The Filer failed to add the mediator. Filer is instructed to file a Notice of Entry of Parties and add the the mediator. (jas)
July 13, 2018 Opinion or Order Filing 92 PAPERLESS RE-NOTICE of Hearing: Discovery Hearing set for July 20, 2018 at 03:30 PM in the Miami Division before Magistrate Judge Edwin G. Torres, James Lawrence King Federal Justice Building, 99 NE 4th Street, Tenth Floor, Courtroom 5, Miami, Florida, 33132. (abu)
July 12, 2018 Opinion or Order Filing 91 NOTICE by KIPU Systems, LLC(a Florida limited liability company) re #82 Scheduling Order,,,, Order Referring Case to Mediation,,, Notice of Filing Proposed Order Scheduling Mediation (Attachments: #1 Text of Proposed Order Proposed Order Scheduling Mediation) (Spuches, Christopher)
June 29, 2018 Opinion or Order Filing 90 ORDER terminating #80 Motion for Protective Order; terminating #88 Motion for Protective Order; terminating #89 Motion for Protective Order.The matters raised in these pending motions shall be heard together with all other discovery issues noticed for July 20, 2018, at 3:30 p.m.No further discovery motions shall be filed in this case, as per the Court's Order Setting Discovery Procedures. Going forward any served objections to Rule 45 subpoenas or notices of deposition shall operate to stay enforcement of the requested discovery and such objections shall be scheduled on the discovery calendar for resolution. Objections to Rule 33, 34 or 36 requests shall be made in accordance with those Rules.Docket Order Signed by Magistrate Judge Edwin G. Torres on 6/29/2018. (EGT)
June 29, 2018 Opinion or Order Filing 89 MOTION for Protective Order by Zencharts, LLC. (Attachments: #1 Exhibit A - Notice of Intent to Serve SDT on Non-Party for Infinity, #2 Exhibit B - Notice of Intent to Serve SDT on Non-Party for Collison, #3 Exhibit C - Infinity and ZenCharts Mutual NDA, #4 Exhibit D - 4th Declaration of Richard Glaser, #5 Exhibit E - Email Correspondence)(Gregory, Geremy)
June 28, 2018 Opinion or Order Filing 88 MOTION for Protective Order by Daniel J. Callahan, Seamus Callahan, Sean Callahan, Callahan Holdings, Inc., Richard Glaser, Yanko Karkalichev, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC. (Attachments: #1 Exhibit A - Kipu Systems LLCs First Set of Requests for Production to Website Consultants Inc., #2 Exhibit B - Kipu Systems LLCs First Set of Requests for Production to Seamus Callahan, #3 Exhibit C - Kipu Systems LLCs First Set of Requests for Production to Richard Glaser, #4 Exhibit D - Kipu Systems LLCs First Set of Requests for Production to Sean Callahan, #5 Exhibit E - Kipu Systems LLC's First Set of Requests for Production to Daniel Callahan, #6 Exhibit F - Email Exchange)(Gregory, Geremy)
June 28, 2018 Opinion or Order Filing 87 RESPONSE in Support re #80 MOTION for Protective Order filed by Zencharts, LLC. (Attachments: #1 Exhibit A - Order Granting, In Part, ZenCharts and Sean Callahan's Motion for Protective Order and Motion to Quash, #2 Exhibit B - Order Denying Trustees Expedited Motion to Renew Order on Motion to Compel)(Gregory, Geremy)
June 27, 2018 Opinion or Order Filing 86 ORDER granting #85 Motion to Take Deposition of Keith Houlihan, for good cause shown in the unopposed motion. Signed by Magistrate Judge Edwin G. Torres on 6/27/2018. (EGT)
June 22, 2018 Opinion or Order Filing 85 Unopposed MOTION to Take Deposition from Keith Houlihan Unopposed Motion for Leave to Take Videotaped Deposition of Prisoner, Keith Houlihan, and Incorporated Memorandum of Law by KIPU Systems, LLC. (Attachments: #1 Text of Proposed Order Order Granting Unopposed Motion for Leave to Take Videotaped Deposition of Prisoner, Keith Houlihan)(Spuches, Christopher)
June 22, 2018 Opinion or Order Filing 84 RESPONSE in Opposition re #80 MOTION for Protective Order Plaintiff's Response in Opposition to ZenCharts LLC's Motion for Protective Order filed by KIPU Systems, LLC. Replies due by 6/29/2018. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G)(Spuches, Christopher)
June 13, 2018 Opinion or Order Filing 83 NOTICE of Hearing on #80 Motion for Protective Order. Discovery Hearing set for July 20, 2018 at 03:30 PM in Miami Division before Magistrate Judge Edwin G. Torres in the James Lawrence King Federal Justice Building, 99 NE 4th Street, Tenth Floor, Courtroom 5, Miami, Florida, 33132. (abu)
June 12, 2018 Opinion or Order Filing 81 ORDER re #80 Motion for Protective Order. Upon our review of the Motion, we find that compliance with the subpoena should be stayed pending resolution of the dispute. A Notice of Hearing on the matter will be forthcoming shortly. Docket Order Signed by Magistrate Judge Edwin G. Torres on 6/12/2018. (abu)
June 11, 2018 Opinion or Order Filing 82 SCHEDULING ORDER: (Jury Trial set for 5/28/2019 in Miami Division before Judge Kathleen M. Williams., Calendar Call set for 5/21/2019 11:00 AM before Judge Kathleen M. Williams., Amended Pleadings due by 7/15/2018., Discovery due by 12/21/2018., Expert Discovery due by 12/21/2018., Joinder of Parties due by 7/15/2018., Mediation Deadline 9/14/2018., In Limine Motions due by 2/25/2019., Dispositive Pretrial Motions due by 1/18/2019., Joint Pretrial Stipulation due by 3/25/2019.), ORDER REFERRING CASE to Mediation. Signed by Judge Kathleen M. Williams on 6/11/2018. (jas) #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.
June 11, 2018 Opinion or Order Filing 80 MOTION for Protective Order by Zencharts, LLC. (Attachments: #1 Exhibit 1 - Plaintiff--Counter-Defendant, Kipu's Notice of Intent to Serve Subpoena Duces Tecum on Non-Party, #2 Exhibit 2 - Counsel for the Trustee's transmittal of documents to Kipu dated 10.19.17, #3 Exhibit 3 - Excerpts from the Glaser Deposition, #4 Exhibit 4 - Excerpts of Zen2, #5 Exhibit 5 - Portions of Kipu ECF Filing, #6 Exhibit 6 - Bankruptcy Proceeding ECF Doc. 89 MPO, #7 Exhibit 7 - Bankruptcy Proceeding ECF Doc. 102 Amended Order, #8 Exhibit 8 - Excerpts from 03.22.18 Hearing, #9 Exhibit 9 - Bankruptcy Proceeding ECF Doc. 115 Compel Order, #10 Exhibit 10 - Bankruptcy Proceeding ECF Doc. No. 132 Motion for Protective Order, #11 Exhibit 11 - Transmittal dated 05.23.18 and draft of Stipulated Protective Order, #12 Exhibit 12 - Transmittal dated 05.31.18 and copy of Stipulated Protective Order, #13 Exhibit 13 - Email dated 06.08.18 to counsel for Plaintiff, #14 Exhibit 14 - Email response dated 06.08.18 from Counsel for Plaintiff)(Gregory, Geremy)
June 11, 2018 Opinion or Order Filing 79 PAPERLESS ORDER striking #77 and #78 , Zencharts LLCs discovery notices. Local Rule 26.1 prohibits parties from filing certain discovery materials, including the material filed by Zencharts LLC. See S.D. Fla. L.R. 26.1(b) ([T]he following discovery requests, responses, objections, notices or any associated proof of service shall not be filed until they are used in the proceeding or the court orders their filing: (1) deposition transcripts; (2) interrogatories; (3) requests for documents, electronically stored information or things, or to permit entry upon land; (4) requests for admission; and (5) notices of taking depositions or notices of serving subpoenas. Accordingly, the notices are stricken. Future failure to comply with all applicable rules may result in sanctions. Signed by Judge Kathleen M. Williams on 6/11/2018. (dpa)
June 11, 2018 Opinion or Order Filing 78 STRICKEN per DE# 79 , NOTICE by Zencharts, LLC (Deposition of Gilbert Fiorentino) (Gregory, Geremy) Modified text on 6/11/2018 (jas).
June 11, 2018 Opinion or Order Filing 77 STRICKEN per DE# 79 , NOTICE by Zencharts, LLC (Deposition of Jeffrey Fiorentino) (Gregory, Geremy) Modified text on 6/11/2018 (jas).
June 6, 2018 Opinion or Order Filing 76 NOTICE of Attorney Appearance by Alexis Sophia Read on behalf of Zen Medical, LLC. Attorney Alexis Sophia Read added to party Zen Medical, LLC(pty:dft). (Read, Alexis)
May 31, 2018 Opinion or Order Filing 75 PAPERLESS ORDER denying as moot #73 Motion for Extension of Time. In light of Defendant Aladzhov's filing of a reply #74 , the motion for extension of time #73 is denied as moot. Signed by Judge Kathleen M. Williams on 5/31/2018. (dpa)
May 29, 2018 Opinion or Order Filing 74 REPLY to Response to Motion re #64 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint,,, filed by Anton Aladzhov. (Gregory, Geremy)
May 29, 2018 Opinion or Order Filing 73 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #72 Response/Reply (Other) by Anton Aladzhov. (Attachments: #1 Text of Proposed Order)(Gregory, Geremy)
May 22, 2018 Opinion or Order Filing 72 Plaintiff's RESPONSE to #64 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint,,, by KIPU Systems, LLC. (Attachments: #1 Exhibit Declaration of Cameron Murphy)(Spuches, Christopher)
May 8, 2018 Opinion or Order Filing 71 REPLY to Response to Motion re #66 MOTION to Strike Or, in the Alternative, Motion for Leave to File Sur-Reply filed by Daniel J. Callahan, Seamus Callahan, Sean Callahan, Richard Glaser, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. (Gregory, Geremy)
May 8, 2018 Opinion or Order Filing 70 PAPERLESS ORDER granting #69 Unopposed Motion for Extension of Time. Plaintiff shall file its response to Defendant Anton Aladzhov's motion to dismiss #64 by May 23, 2018. Signed by Judge Kathleen M. Williams on 5/8/2018. (dpa)
May 7, 2018 Opinion or Order Filing 69 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #64 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint,,, by KIPU Systems, LLC. (Attachments: #1 Text of Proposed Order)(Greenberg, Jake)
May 3, 2018 Opinion or Order Filing 68 REPLY to Response to Motion re #45 MOTION for Summary Judgment (Partial) filed by Solutions Recovery Center, LLC. (Gregory, Geremy)
May 1, 2018 Opinion or Order Filing 67 RESPONSE in Opposition re #66 MOTION to Strike Or, in the Alternative, Motion for Leave to File Sur-Reply filed by KIPU Systems, LLC. Replies due by 5/8/2018. (Spuches, Christopher)
April 30, 2018 Opinion or Order Filing 66 MOTION to Strike Or, in the Alternative, Motion for Leave to File Sur-Reply by Daniel J. Callahan, Seamus Callahan, Sean Callahan, Richard Glaser, Solutions Recovery Center, LLC, Zencharts, LLC. Responses due by 5/14/2018 (Attachments: #1 Exhibit A)(Gregory, Geremy)
April 27, 2018 Opinion or Order Filing 65 REPLY to Response to Motion re #43 Plaintiff's MOTION TO DISMISS #33 Answer to Complaint,,,,, Counterclaim,,,, #32 Answer to Complaint,,,,, Counterclaim,,,, FOR FAILURE TO STATE A CLAIM Plaintiff's MOTION for More Definite Statement filed by KIPU Systems, LLC. (Spuches, Christopher)
April 25, 2018 Opinion or Order Filing 64 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint,,, by Anton Aladzhov. Attorney Geremy Walden Gregory added to party Anton Aladzhov(pty:dft). Responses due by 5/9/2018 (Attachments: #1 Exhibit 1)(Gregory, Geremy)
April 25, 2018 Opinion or Order Filing 63 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Yanko Karkalichev. Attorney Geremy Walden Gregory added to party Yanko Karkalichev(pty:dft). (Gregory, Geremy)
April 24, 2018 Opinion or Order Filing 62 PAPERLESS ORDER granting #59 Motion for Extension of Time. Defendant, Solutions Recovery Center LLC, shall have until May 3, 2018 to file its Reply in support of its Motion for Partial Summary Judgment. Signed by Judge Kathleen M. Williams on 4/24/2018. (dpa)
April 24, 2018 Opinion or Order Filing 61 PAPERLESS ORDER granting #56 Motion for Extension of Time. Kipu Systems LLC, shall file its Reply in support of its Motion to Dismiss by April 27, 2018. Signed by Judge Kathleen M. Williams on 4/24/2018. (dpa)
April 23, 2018 Opinion or Order Filing 60 NOTICE by KIPU Systems, LLC re #51 Order, #1 Complaint,,, Notice of Service upon Defendants Yanko Karkalichev and Anton Aladzhov (Thornburg, Robert)
April 20, 2018 Opinion or Order Filing 59 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #57 Response to Motion,, by Solutions Recovery Center, LLC. (Attachments: #1 Text of Proposed Order)(Gregory, Geremy)
April 19, 2018 Opinion or Order Filing 58 Plaintiff's RESPONSE to #46 Statement Plaintiff's Response to Solutions Recovery Center, LLC's Statement of Facts by KIPU Systems, LLC. (Spuches, Christopher)
April 19, 2018 Opinion or Order Filing 57 RESPONSE to Motion re #45 MOTION for Summary Judgment (Partial) Plaintiff, KIPU SYSTEMS LLC's Response to Defendants' Motion for Summary Judgment filed by KIPU Systems, LLC. Replies due by 4/26/2018. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit 1, #3 Exhibit Exhibit 2, #4 Exhibit Exhibit 3, #5 Exhibit Exhibit 4, #6 Exhibit Exhibit 5, #7 Exhibit Exhibit 6, #8 Exhibit Exhibit 7, #9 Exhibit Exhibit 8, #10 Exhibit Exhibit 9, #11 Exhibit Exhibit 10, #12 Exhibit Exhibit B, #13 Exhibit Exhibit C, #14 Exhibit Exhibit D, #15 Exhibit Exhibit E, #16 Exhibit Exhibit F)(Spuches, Christopher)
April 17, 2018 Opinion or Order Filing 56 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #55 Response in Opposition to Motion, Unopposed Motion for Extension of Time to File Reply by KIPU Systems, LLC. (Attachments: #1 Text of Proposed Order Order granting Motion for Extension of time)(Spuches, Christopher)
April 13, 2018 Opinion or Order Filing 55 RESPONSE in Opposition re #43 Plaintiff's MOTION TO DISMISS #33 Answer to Complaint,,,,, Counterclaim,,,, #32 Answer to Complaint,,,,, Counterclaim,,,, FOR FAILURE TO STATE A CLAIM Plaintiff's MOTION for More Definite Statement filed by Solutions Recovery Center, LLC, Zencharts, LLC. Replies due by 4/20/2018. (Gregory, Geremy)
April 13, 2018 Opinion or Order Filing 54 REPLY to Response to Motion re #38 Plaintiff's MOTION for Preliminary Injunction filed by KIPU Systems, LLC. (Attachments: #1 Exhibit A)(Thornburg, Robert)
April 4, 2018 Opinion or Order Filing 53 Joint SCHEDULING REPORT - Rule 16.1 by KIPU Systems, LLC (Thornburg, Robert)
March 30, 2018 Opinion or Order Filing 52 ORDER ON JOINT AGREED MOTION FOR EXTENSION OF TIME TO FILE RESPONSES. Kipu Systems, LLC shall file its response to the Motion for Partial Summary Judgment DE #45 on or before 4/19/2018; Kipu Systems, LLC shall file its reply in support of Plaintiff Kipu Systems, LLC's Motion for Preliminary Injunction DE #38 on or before 4/13/2018; Solutions Recovery Center, LLC and ZenCharts LLC shall file their response to Plaintiff's "Motion for a More Definite Statement of Solutions Recovery Center, LLC and ZenCharts, LLC's Counterclaims and to Dismiss Solutions Recovery Center, LLC's Count II and ZenCharts, LLC's Count II and Count IV for Failure to State a Claim" DE #43 , on or before 4/13/2018. Signed by Judge Kathleen M. Williams on 3/30/2018. (jas)
March 29, 2018 Opinion or Order Filing 51 ORDER granting 9 Plaintiff's Ex Parte MOTION Authorizing Alternative Service of Process on Yanko Karkalichev and Anton Aladzhov. Signed by Magistrate Judge Edwin G. Torres on 3/29/2018. (js02)
March 28, 2018 Opinion or Order Filing 50 Clerks Entry of Default as to Zen Medical, LLC. Signed by DEPUTY CLERK on 3/28/2018. (jas)
March 28, 2018 Opinion or Order Filing 49 Plaintiff's MOTION for Clerks Entry of Default as to Zen Medical, LLC by KIPU Systems, LLC(a Florida limited liability company). (Spuches, Christopher)
March 26, 2018 Opinion or Order Filing 48 Joint MOTION for Extension of Time to File Response/Reply/Answer as to #38 Plaintiff's MOTION for Preliminary Injunction , #45 MOTION for Summary Judgment (Partial), #43 Plaintiff's MOTION TO DISMISS #33 Answer to Complaint,,,,, Counterclaim,,,, #32 Answer to Complaint,,,,, Counterclaim,,,, FOR FAILURE TO STATE A CLAIM Plaintiff's MOTION for More Definite Statement Joint Agreed Motion for Extension of time to File Responses by KIPU Systems, LLC(a Florida limited liability company). (Attachments: #1 Text of Proposed Order Order on Joint Motion for Extension of time)(Spuches, Christopher)
March 23, 2018 Opinion or Order Filing 47 RESPONSE in Opposition re #38 Plaintiff's MOTION for Preliminary Injunction filed by Daniel J. Callahan, Seamus Callahan, Sean Callahan, Richard Glaser, Solutions Recovery Center, LLC, Website Consultants, Inc., Zencharts, LLC. Replies due by 3/30/2018. (Attachments: #1 Exhibit A - Declaration of Richard Glaser, #2 Exhibit B - USTPO Registration, #3 Exhibit C - USTPO Feb. Ltr.)(Gregory, Geremy)
March 22, 2018 Opinion or Order Filing 46 Statement of: Undisputed Facts by Solutions Recovery Center, LLC re #45 MOTION for Summary Judgment (Partial) (Gregory, Geremy)
March 22, 2018 Opinion or Order Filing 45 MOTION for Summary Judgment (Partial) by Solutions Recovery Center, LLC. Responses due by 4/5/2018 (Attachments: #1 Exhibit A - KIPU Contract, #2 Exhibit B - Declaration of Richard Glaser, #3 Exhibit C - 2013 TOS, #4 Exhibit D - 2014 TOS)(Gregory, Geremy)
March 19, 2018 Opinion or Order Filing 44 ORDER denying #42 Motion to Strike Affirmative Defenses, based on the violation of Local Rule 7.1 and the absence of a certificate of conferral. Motions to strike are not exempted from operation of that Rule, in contrast with motions to dismiss. The substantive issues raised in the motion may be renewed at the summary judgment stage or in response to an amended answer/counterclaim.Docket Order Signed by Magistrate Judge Edwin G. Torres on 3/19/2018. (EGT)
March 16, 2018 Opinion or Order Filing 43 Plaintiff's MOTION TO DISMISS #33 Answer to Complaint,,,,, Counterclaim,,,, #32 Answer to Complaint,,,,, Counterclaim,,,, FOR FAILURE TO STATE A CLAIM , Plaintiff's MOTION for More Definite Statement by KIPU Systems, LLC(a Florida limited liability company). Responses due by 3/30/2018 (Attachments: #1 Exhibit A - Slip Opinion)(Thornburg, Robert)
March 16, 2018 Opinion or Order Filing 42 MOTION to Strike #33 Answer to Complaint,,,,, Counterclaim,,,, #27 Answer to Complaint, #35 Answer to Complaint, #23 Answer to Complaint, #26 Answer to Complaint, #32 Answer to Complaint,,,,, Counterclaim,,,, #24 Answer to Complaint, #25 Answer to Complaint, #36 Answer to Complaint by KIPU Systems, LLC(a Florida limited liability company). Responses due by 3/30/2018 (Thornburg, Robert)
March 13, 2018 Opinion or Order Filing 41 PAPERLESS ORDER granting #39 Motion for Extension of Time. Plaintiff shall have until March 16, 2018 to respond to Defendants' counterclaims and affirmative defenses. Defendants shall have until March 23, 2018 to respond to Plaintiff's motion for a preliminary injunction. Signed by Judge Kathleen M. Williams on 3/13/2018. (dpa)
March 8, 2018 Opinion or Order Filing 40 Clerks Notice to Filer re #39 Joint MOTION for Extension of Time to Respond to Plaintiff's Motion for Preliminary Injunction and Defendants' Counterclaims and Affirmative Defenses re #33 Answer to Complaint, Counterclaim,,,,,,,, #35 Answer to Complaint, #38 . Wrong Motion Relief(s) Selected; ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs. (ls)
March 7, 2018 Opinion or Order Filing 39 Joint Motion for Extension of Time to File Response/Reply/Answer as to #33 Answer to Complaint, Counterclaim, #35 Answer to Complaint, #38 Plaintiff's MOTION for Preliminary Injunction , #32 Answer to Complaint, Counterclaim, #24 Answer to Complaint, #25 Answer to Complaint, #27 Answer to Complaint, #23 Answer to Complaint, #26 Answer to Complaint, #36 Answer to Complaint by KIPU Systems, LLC. Responses due by 3/21/2018 (Attachments: #1 Text of Proposed Order)(Thornburg, Robert) Modified Relief on 3/8/2018 (ls).
March 2, 2018 Opinion or Order Filing 38 Plaintiff's MOTION for Preliminary Injunction by KIPU Systems, LLC. (Attachments: #1 Exhibit A)(Thornburg, Robert)
March 1, 2018 Opinion or Order Filing 37 Corporate Disclosure Statement by Callahan Holdings, Inc. (Gregory, Geremy)
March 1, 2018 Opinion or Order Filing 36 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Callahan Holdings, Inc.. Attorney Geremy Walden Gregory added to party Callahan Holdings, Inc.(pty:dft). (Gregory, Geremy)
March 1, 2018 Opinion or Order Filing 35 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Seamus Callahan. Attorney Geremy Walden Gregory added to party Seamus Callahan(pty:dft). (Gregory, Geremy)
February 22, 2018 Opinion or Order Filing 34 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline by KIPU Systems, LLC(a Florida limited liability company). Zen Medical, LLC served on 2/17/2018, answer due 3/12/2018. (Spuches, Christopher)
February 16, 2018 Opinion or Order Filing 33 ANSWER and Affirmative Defenses to Complaint with Jury Demand , COUNTERCLAIM against KIPU Systems, LLC by Solutions Recovery Center, LLC. (Attachments: #1 Exhibit A - Email dated 10.01.13, #2 Exhibit B - Collective Emails dated 10.01.13, #3 Exhibit C - Kipu Contract, #4 Exhibit D - 2013 Kipu Terms of Service, #5 Exhibit E - Email dated 10.17.13, #6 Exhibit F - Email dated 10.29.13, #7 Exhibit G - Email dated 10.15.13, #8 Exhibit H - Email dated 10.15.13, #9 Exhibit I - Email dated 11.19.13, #10 Exhibit J - Email dated 11.25.13, #11 Exhibit K - Email dated 11.27.13, #12 Exhibit L - Amended Plea Agreement, #13 Exhibit M - Order dated 03.05.15, #14 Exhibit N - ZenCharts Domain Invoice, #15 Exhibit O - ZenCharts Corporate Minutes, #16 Exhibit P - Email dated 10.11.16, #17 Exhibit Q - Email dated 12.19.17, #18 Exhibit R - HIPAA Inquiry Letter, #19 Exhibit S - Department of Health Letter, #20 Exhibit T - Walstrom LinkedIn, #21 Exhibit U - Email dated 02.13.18)(Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 32 ANSWER and Affirmative Defenses to Complaint with Jury Demand , COUNTERCLAIM against KIPU Systems, LLC by Zencharts, LLC. (Attachments: #1 Exhibit A - Email dated 10.01.13, #2 Exhibit B - Collective Emails dated 10.01.13, #3 Exhibit C - Kipu Contract, #4 Exhibit D - 2013 Kipu Terms of Service, #5 Exhibit E - Email dated 10.17.13, #6 Exhibit F - Email dated 10.29.13, #7 Exhibit G - Email dated 10.15.13, #8 Exhibit H - Email dated 10.15.13, #9 Exhibit I - Email dated 11.19.13, #10 Exhibit J - Email dated 11.25.13, #11 Exhibit K - Email dated 11.27.13, #12 Exhibit L - Amended Plea Agreement, #13 Exhibit M - Order dated 03.05.15, #14 Exhibit N - ZenCharts Domain Invoice, #15 Exhibit O - ZenCharts Corporate Minutes, #16 Exhibit P - Email dated 10.11.16, #17 Exhibit Q - Email dated 12.19.17, #18 Exhibit R - HIPAA Inquiry Letter, #19 Exhibit S - Department of Health Letter, #20 Exhibit T - Walstrom LinkedIn, #21 Exhibit U - Email dated 02.13.18)(Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 31 Corporate Disclosure Statement by Zencharts, LLC (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 30 Corporate Disclosure Statement by Website Consultants, Inc. (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 29 Corporate Disclosure Statement by Solutions Recovery, LLC (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 28 Corporate Disclosure Statement by Solutions Recovery Center, LLC (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 27 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Solutions Recovery, LLC. (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 26 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Website Consultants, Inc.. (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 25 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Sean Callahan. (Gregory, Geremy)
February 16, 2018 Opinion or Order Filing 24 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Daniel J. Callahan. (Gregory, Geremy)
February 15, 2018 Opinion or Order Filing 23 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Richard Glaser. (Gregory, Geremy)
February 13, 2018 Opinion or Order Filing 22 Clerks Entry of Default as to Keith Houlihan. Signed by DEPUTY CLERK on 2/13/2018. (jas)
February 12, 2018 Opinion or Order Filing 21 MOTION for Clerks Entry of Default as to Keith Houilhan by KIPU Systems, LLC. (Spuches, Christopher)
February 7, 2018 Opinion or Order Filing 20 ORDER granting #18 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Adam K. Israel. The Court finds that the application satisfies the requirements of S.D. Fla. Local Atty. R. 4. Therefore, the Clerk is directed to add Adam K. Israel, Esq. as counsel of record for Defendants and allow counsel to be noticed electronically on CM/ECF.Docket Order Signed by Magistrate Judge Edwin G. Torres on 2/7/2018. (js02)
February 7, 2018 Opinion or Order Filing 19 ORDER granting #17 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Walter H. Boone. The Court finds that the application satisfies the requirements of S.D. Fla. Local Atty. R. 4. Therefore, the Clerk is directed to add Walter H. Boone, Esq. as counsel of record for Defendants and allow counsel to be noticed electronically on CM/ECF. Docket Order Signed by Magistrate Judge Edwin G. Torres on 2/7/2018. (js02)
February 7, 2018 Opinion or Order Filing 18 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Adam K. Israel. Filing Fee $ 75.00 Receipt # 113C-10392008 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC. Responses due by 2/21/2018 (Attachments: #1 Text of Proposed Order)(Gregory, Geremy)
February 7, 2018 Opinion or Order Filing 17 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Walter H. Boone. Filing Fee $ 75.00 Receipt # 113C-10391968 by Daniel J. Callahan, Sean Callahan, Richard Glaser, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC. Attorney Geremy Walden Gregory added to party Richard Glaser(pty:dft). Responses due by 2/21/2018 (Attachments: #1 Text of Proposed Order)(Gregory, Geremy)
January 31, 2018 Opinion or Order Filing 16 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline by KIPU Systems, LLC. Keith Houilhan served on 1/3/2018, answer due 1/24/2018. (Spuches, Christopher)
January 26, 2018 Opinion or Order Filing 15 ORDER granting in part and denying in part #13 Motion for Extension of Time to File Response/Answer to #1 Complaint. The motion is Granted in part, for good cause shown and notwithstanding Plaintiff's objection, but only for a reasonable period of time. The requested extension sought through March 30, 2018, is plainly excessive.Accordingly it is Ordered that: Daniel J. Callahan's Answer/response is due 2/16/2018; Sean Callahan's Answer/response is due 2/16/2018; Solutions Recovery Center, LLC's Answer/response is due 2/16/2018; Solutions Recovery, LLC's Answer/response is due 2/16/2018; Website Consultants, Inc.'s Answer/response is due 2/16/2018. Docket Order Signed by Magistrate Judge Edwin G. Torres on 1/26/2018. (EGT)
January 25, 2018 Opinion or Order Filing 14 RESPONSE to Motion re #13 MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint,,, Plaintiff's Response in Opposition to Motion for Extension of Time to Respond to Complaint filed by KIPU Systems, LLC. Replies due by 2/1/2018. (Attachments: #1 Exhibit Exhibit A)(Greenberg, Jake)
January 24, 2018 Opinion or Order Filing 13 MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint,,, by Daniel J. Callahan, Sean Callahan, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zencharts, LLC. Attorney Geremy Walden Gregory added to party Daniel J. Callahan(pty:dft), Attorney Geremy Walden Gregory added to party Sean Callahan(pty:dft), Attorney Geremy Walden Gregory added to party Solutions Recovery Center, LLC(pty:dft), Attorney Geremy Walden Gregory added to party Solutions Recovery, LLC(pty:dft), Attorney Geremy Walden Gregory added to party Website Consultants, Inc.(pty:dft), Attorney Geremy Walden Gregory added to party Zencharts, LLC(pty:dft). (Attachments: #1 Exhibit Proposed Order)(Gregory, Geremy)
January 23, 2018 Opinion or Order Filing 12 NOTICE by KIPU Systems, LLC re #1 Complaint,,, Notice of Filing Corrected Exhibit "C" (Attachments: #1 Exhibit Corrected Exhibit "C") (Greenberg, Jake)
January 22, 2018 Opinion or Order SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (945301)
January 19, 2018 Opinion or Order Filing 10 ORDER RE: 9 Sealed Order on Alternative Service of Process. Upon review of the sealed motion, a proposed order with the required findings under Rule 4 was not filed. A supplemental memorandum attaching the proposed order shall be filed. Such memorandum should also specifically represent whether the foreign jurisdiction at issue has expressly objected to service by electronic means under the Hague Convention. The initial memorandum does not reference that possible objection specifically.Docket Order Signed by Magistrate Judge Edwin G. Torres on 1/19/2018. (EGT)
January 18, 2018 Opinion or Order SYSTEM ENTRY - Docket Entry 9 [motion] restricted/sealed until further notice. (945301)
January 8, 2018 Opinion or Order Filing 8 CASE REFERRED to Magistrate Judge Edwin G. Torres per 7 Order. (asl)
January 8, 2018 Opinion or Order Filing 7 PAPERLESS ORDER OF REFERRAL AND ORDER REGARDING COURT PRACTICES AND PROCEDURES. Pursuant to 28 U.S.C. 636 and the Magistrate Rules of the Local Rules for the Southern District of Florida, all discovery disputes and non-dispositive pretrial motions are REFERRED to Magistrate Judge Edwin G. Torres. It is further ORDERED that the Parties shall adhere to the Federal Rules of Civil Procedure, the Local Rules for the Southern District of Florida, Judge Williams' Court Practices and Procedures, and Judge Torres' Standing Order Setting Discovery Procedures. Judge Williams' Court Practices and Procedures and Judge Torres' Standing Order Setting Discovery Procedures are available at the Court's website: #http://www.flsd.uscourts.gov/?page_id=13071. Signed by Judge Kathleen M. Williams on 1/8/2018. (dpa)
January 5, 2018 Opinion or Order Filing 6 Corporate Disclosure Statement by KIPU Systems, LLC identifying Corporate Parent Kipu Health, LLC for KIPU Systems, LLC (Greenberg, Jake)
January 2, 2018 Opinion or Order Filing 5 Summons Issued as to Anton Aladzhov, Daniel J. Callahan, Seamus Callahan, Sean Callahan, Callahan Holdings, Inc., Richard Glaser, Keith Houilhan, Yanko Karkalichev, Solutions Recovery Center, LLC, Solutions Recovery, LLC, Website Consultants, Inc., Zen Medical, LLC, Zencharts, LLC. (jas)
December 31, 2017 Opinion or Order Filing 4 FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (Attachments: #1 Complaint & Exhibits) (jas)
December 31, 2017 Opinion or Order Filing 3 Clerks Notice to Filer re: Electronic Case. Documents Improperly Arranged. The Filer did not properly attach the Civil Cover Sheet. Future filings must comply with the CM/ECF Civil Case Opening Guide. It is not necessary to re-file this document. (jas)
December 31, 2017 Opinion or Order Filing 2 Clerks Notice of Judge Assignment to Judge Kathleen M. Williams. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Edwin G. Torres 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. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (jas)
December 31, 2017 Opinion or Order Filing 1 COMPLAINT against Anton Aladzhov, Daniel Callahan, Sean Callahan, Richard Glaser, Keith Houilhan, Yanko Karkalichev, Martin Lnu, Tanyo Lnu, Zen Medical, LLC, Solutions Recovery, LLC, Callahan Holdings, Inc., Seamus Callahan, Solutions Recovery Center, LLC, Zencharts, LLC, Website Consultants, Inc.. Filing fees $ 400.00 receipt number 113C-10293512, filed by KIPU Systems, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Civil Cover Sheet, #7 Summon(s), #8 Summon(s), #9 Summon(s), #10 Summon(s), #11 Summon(s), #12 Summon(s), #13 Summon(s), #14 Summon(s), #15 Summon(s), #16 Summon(s), #17 Summon(s), #18 Summon(s), #19 Summon(s))(Spuches, Christopher)

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Search for this case: KIPU Systems, LLC v. Zencharts, LLC et al
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Defendant: Zencharts, LLC
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Anton Aladzhov
Represented By: Geremy Walden Gregory
Represented By: Charles Brumby
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Defendant: Zen Medical, LLC
Represented By: Alexis Sophia Read
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Defendant: Callahan Holdings, Inc.
Represented By: Geremy Walden Gregory
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Defendant: Yanko Karkalichev
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Solutions Recovery, LLC
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
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Defendant: Website Consultants, Inc.
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Daniel J. Callahan
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Sean Callahan
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Seamus Callahan
Represented By: Geremy Walden Gregory
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Defendant: Richard Glaser
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Kye C. Handy
Represented By: Charles Brumby
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Defendant: Keith Houilhan
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Defendant: Solutions Recovery Center, LLC
Represented By: Adam K. Israel
Represented By: Walter H. Boone
Represented By: Geremy Walden Gregory
Represented By: Charles Brumby
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Defendant: Keith Hootie
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Plaintiff: KIPU Systems, LLC
Represented By: Jake Matthew Greenberg
Represented By: Robert Houpt Thornburg
Represented By: Christopher B Spuches
Represented By: Joshua B. Spector
Represented By: Cameron Christopher Murphy
Represented By: Mark Evan Stein
Represented By: Jason Alan Martorella
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