Healthcare Sales Enablement, Inc. v. Geyfman
Plaintiff: Healthcare Sales Enablement, Inc.
Defendant: Anatoly Geyfman and PATIENTFINDER
Case Number: 1:2019cv20125
Filed: January 9, 2019
Court: US District Court for the Southern District of Florida
Presiding Judge: Darrin P Gayles
Referring Judge: Alicia M Otazo-Reyes
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332
Jury Demanded By: None
Docket Report

This docket was last retrieved on March 8, 2019. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 8, 2019 Filing 37 Joint SCHEDULING REPORT - Rule 16.1 by Healthcare Sales Enablement, Inc. (Attachments: #1 Exhibit A)(Aleman, Bayardo)
February 28, 2019 Filing 36 REPLY to Response to Motion re #32 Plaintiff's MOTION for Hearing (Status Conference) filed by Healthcare Sales Enablement, Inc.. (Thornton, Ryan)
February 27, 2019 Filing 35 REFERRAL to Magistrate Judge Alicia M. Otazo-Reyes per DE 34. (vjk)
February 27, 2019 Opinion or Order Filing 34 PAPERLESS ORDER REFERRING CASE to Magistrate Judge Alicia Otazo-Reyes for all pretrial matters, including entry of a scheduling order. Signed by Judge Darrin P. Gayles (lfn)
February 27, 2019 Filing 33 RESPONSE in Opposition re #32 Plaintiff's MOTION for Hearing (Status Conference) filed by Anatoly Geyfman. Replies due by 3/6/2019. (Attachments: #1 Exhibit A - 1.9.19 email re motion for injunction)(Halberstam, Mendy)
February 27, 2019 Filing 32 Plaintiff's MOTION for Hearing (Status Conference) by Healthcare Sales Enablement, Inc.. (Thornton, Ryan)
February 25, 2019 Opinion or Order Filing 31 PAPERLESS ORDER denying as moot #26 Joint Motion for Extension of Time. The parties shall submit their Joint Proposed Scheduling Report in accordance with [ECF No.6] on or before March 8, 2019. Signed by Judge Darrin P. Gayles (lfn)
February 25, 2019 Opinion or Order Filing 30 ORDER denying #7 Motion to Remand to State Court. The parties shall submit a Joint Scheduling Report in accordance with this Courts procedures. [ECF No. 6]. Signed by Judge Darrin P. Gayles See attached document for full details. (lfn)
February 11, 2019 Filing 29 NOTICE by Anatoly Geyfman re #1 Notice of Removal (State Court Complaint), of Filing Corrected Exhibit (Attachments: #1 Exhibit 1 - Complaint) (Butler, Daniel)
February 6, 2019 Filing 28 Notice of Pending, Refiled, Related or Similar Actions by Healthcare Sales Enablement, Inc. (Attachments: #1 Exhibit Geyfman Demand for Arbitration, #2 Exhibit Geyfman Carevoyance Oregon Complaint) (Aleman, Bayardo)
February 6, 2019 Filing 27 Certificate of Interested Parties by Anatoly Geyfman identifying Other Affiliate Carevoyance, Inc. for Anatoly Geyfman (Butler, Daniel)
February 6, 2019 Filing 26 Unopposed MOTION for Extension of Time to Submit Joint Scheduling Report, Proposed Scheduling Order, Certificate of Interested Parties and Corporate Disclosure Statements re #6 Order Requiring Joint Scheduling Report,,,, by Healthcare Sales Enablement, Inc.. Responses due by 2/20/2019 (Aleman, Bayardo)
January 30, 2019 Filing 25 NOTICE by Healthcare Sales Enablement, Inc. re #24 Response in Opposition to Motion, Notice of Withdrawal of #24 Response in Opposition (Aleman, Bayardo)
January 30, 2019 Filing 24 (WITHDRAW per DE #25 ) RESPONSE in Opposition re #21 Defendant's MOTION to Strike Affidavit Partially MOTION for Leave to File Sur-Reply With Funding Exhibit Under Seal filed by Healthcare Sales Enablement, Inc.. Replies due by 2/6/2019. (Aleman, Bayardo) Modified text on 1/31/2019 (mc).
January 30, 2019 Opinion or Order Filing 23 PAPERLESS ORDER denying #21 Defendant's Motion to Partially Strike Affidavit or for Leave to File Sur-Reply with Funding Exhibit Under Seal. The Motion is denied in its entirety. Signed by Judge Darrin P. Gayles (lfn)
January 29, 2019 Filing 22 NOTICE by Healthcare Sales Enablement, Inc. re #21 Defendant's MOTION to Strike Affidavit Partially MOTION for Leave to File Sur-Reply With Funding Exhibit Under Seal Notice of Intent to File Opposition to #21 by Wednesday, January 29, 2019 (Aleman, Bayardo)
January 29, 2019 Filing 21 Defendant's MOTION to Strike Affidavit Partially ( Responses due by 2/12/2019), MOTION for Leave to File Sur-Reply With Funding Exhibit Under Seal by Anatoly Geyfman. (Halberstam, Mendy)
January 28, 2019 Filing 20 REPLY to Response to Motion re #7 Plaintiff's MOTION to Remand to State Court (Expedited) filed by Healthcare Sales Enablement, Inc.. (Attachments: #1 Exhibit Declaration of David Thornton)(Aleman, Bayardo)
January 25, 2019 Filing 19 Clerks Notice to Filer re 18 Sealed Document. Document Not Captioned; In The Future The Filer must File a Notice of Filing With the Attached Exhibits with the proper caption pursuant to Local Rules. It is not necessary to refile this document. (nc)
January 25, 2019 Filing 17 RESPONSE to Motion re #7 Plaintiff's MOTION to Remand to State Court filed by Anatoly Geyfman. Replies due by 2/1/2019. (Attachments: #1 Exhibit A - Declaration of David Thornton, #2 Exhibit B - Declaration of Anatoly Geyfman, #3 Exhibit C - Sealed Document)(Halberstam, Mendy)
January 25, 2019 SYSTEM ENTRY - Docket Entry 18 [misc] restricted/sealed until further notice. (1135633)
January 18, 2019 Filing 16 NOTICE by Healthcare Sales Enablement, Inc. re #12 MOTION for Leave to File One Document Under Seal (Aleman, Bayardo)
January 18, 2019 Opinion or Order Filing 15 PAPERLESS ORDER granting #12 Defendant's Unopposed Motion to File One Exhibit Under Seal. Defendant may file its' exhibit 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 Darrin P. Gayles (lfn)
January 18, 2019 Opinion or Order Filing 14 PAPERLESS ORDER granting #11 Plaintiff's Motion to Stay Briefing. The pending deadlines for #4 Defendant's Motion to Dismiss and #8 Corrected Motion to Compel Conditional Arbitration are stayed pending the Court's resolution of Plaintiff's #7 Expedited Motion to Remand. Accordingly, the Court shall reset the deadlines at a later date. Signed by Judge Darrin P. Gayles (lfn)
January 18, 2019 Filing 13 NOTICE by Anatoly Geyfman re #11 MOTION to Stay Pending Resolution of Motion to Remand of Non-Objection to Stay in Light of ECF No. 10 (Halberstam, Mendy)
January 18, 2019 Filing 12 MOTION for Leave to File One Document Under Seal by Anatoly Geyfman. (Halberstam, Mendy)
January 18, 2019 Filing 11 MOTION to Stay Pending Resolution of Motion to Remand by Healthcare Sales Enablement, Inc.. Responses due by 2/1/2019 (Aleman, Bayardo)
January 18, 2019 Opinion or Order Filing 10 PAPERLESS ORDER re #7 Plaintiff's MOTION to Remand to State Court. Defendant, Anatoly Geyfman, is directed to file his Response to Plaintiff's Motion on or before January 25, 2019. Signed by Judge Darrin P. Gayles (lfn)
January 17, 2019 Filing 9 NOTICE of Striking #5 MOTION to Compel Conditional Arbitration of Damage Claims filed by Anatoly Geyfman as Filed in Error (Corrected Motion Filed at ECF No. 8) by Anatoly Geyfman (Halberstam, Mendy)
January 17, 2019 Filing 8 Corrected MOTION to Compel Conditional Arbitration by Anatoly Geyfman. Responses due by 1/31/2019 (Attachments: #1 Exhibit A - Employment Agreement)(Halberstam, Mendy)
January 17, 2019 Filing 7 Plaintiff's MOTION to Remand to State Court by Healthcare Sales Enablement, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Aleman, Bayardo)
January 16, 2019 Opinion or Order Filing 6 ENDORSED ORDER REQUIRING JOINT SCHEDULING REPORT AND PROPOSED SCHEDULING ORDER. Pursuant to S.D. Fla. Local Rule 16.1, on or before February 6, 2019, the parties shall prepare and file a Joint Scheduling Report, as well as Certificates of Interested Parties and Corporate Disclosure Statements.The parties shall also file a Proposed Scheduling Order, adhering to the format and guidance of the attached form. If the parties deviate in any way from that format and guidance, they shall contemporaneously submit a written explanation, which provides their purported justification for each and every deviation. If the parties fail to submit such written explanation, the Court may enter a Scheduling Order that does not take into account the parties' proposed dates.Failure to comply with this Order shall be grounds for dismissal without prejudice and without further notice. Signed by Judge Darrin P. Gayles See attached document for full details. (lfn)
January 16, 2019 Filing 5 STRICKEN - MOTION to Compel Conditional Arbitration of Damage Claims by Anatoly Geyfman. Responses due by 1/30/2019 (Attachments: #1 Exhibit A - Employment Agreement)(Halberstam, Mendy) Modified to strike per DE #9 on 1/18/2019 (pes).
January 16, 2019 Filing 4 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint), FOR FAILURE TO STATE A CLAIM Upon Which Relief Can Be Granted, for Lack of Personal Jurisdiction and Improper Venue by Anatoly Geyfman. Responses due by 1/30/2019 (Attachments: #1 Exhibit A - Declaration of Anatoly Geyfman, #2 Exhibit B - 6-21-2018 Action by Unanimous Written Consent of Board of Directors, #3 Exhibit C - PatientFinder Exercise of Repurchase Option, #4 Exhibit D - Action by Written Consent Shareholders, #5 Exhibit E - License and Asset Purchase Assignment, #6 Exhibit F - 6-13-2018 E-mail Correspondence, #7 Exhibit G - Oregon Complaint)(Halberstam, Mendy)
January 10, 2019 Filing 3 NOTICE OF COURT PRACTICE. Unless otherwise specified by the Court, every motion shall be double-spaced in Times New Roman 12-point typeface. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Failure to comply with ANY of these procedures may result in the imposition of appropriate sanctions, including but not limited to, the striking of the motion or dismissal of this action. Signed by Judge Darrin P. Gayles (lfn)
January 9, 2019 Filing 2 Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia M. Otazo-Reyes 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. (jao)
January 9, 2019 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 400.00 receipt number 113C-11297991, filed by Anatoly Geyfman. No Answer and/or Motion to Dismiss Filed. (Attachments: #1 Exhibit A - Service Documents, #2 Exhibit B - Action by Written Consent of the Stockholders, #3 Exhibit C - License and Asset Purchase Agreement, #4 Civil Cover Sheet)(Halberstam, Mendy) Modified on 1/10/2019 (jao).

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Defendant: Anatoly Geyfman
Represented By: Mendy Halberstam
Represented By: Daniel Joseph Butler
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Defendant: PATIENTFINDER
Represented By: Mendy Halberstam
Represented By: Daniel Joseph Butler
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Plaintiff: Healthcare Sales Enablement, Inc.
Represented By: Bayardo E. Aleman
Represented By: Ryan Thomas Thornton
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