Technolojoy, LLC et al v. BHPH Consulting Services, LLC et al
Plaintiff: Technolojoy, LLC, Ibrahim Algahim and Ibrahim F. Algahim
Defendant: BHPH Consulting Services, LLC, Anatoliy Slutskiy and BHPH Consulting Services, LLC doing business as BHPH Capital Services
Counter Claimant: Sean Fouzailoff
Case Number: 1:2019cv23770
Filed: September 10, 2019
Court: US District Court for the Southern District of Florida
Presiding Judge: Jonathan Goodman
Referring Judge: Federico A Moreno
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. ยง 1332 Diversity-Other Contract
Jury Demanded By: Defendant
Docket Report

This docket was last retrieved on December 1, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
December 1, 2022 Opinion or Order Filing 227 Defendant's MOTION to Continue UNOPPOSED MOTION TO ENLARGE TIME FOR DEFENDANTS TO REPLY TO MOTION TO STRIKE EXPERT [DE#226] TO DECEMBER 15, 2022 re #226 MOTION to Exclude Expert filed by Technolojoy, LLC by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 12/15/2022 (Dunn, James)
November 23, 2022 Opinion or Order Filing 226 MOTION to Exclude Expert by Technolojoy, LLC. (Attachments: #1 Exhibit 1 - Original Expert Report, #2 Exhibit 2 - Supplemental Expert Report, #3 Exhibit 3 - Deposition Transcript (Lewis Baum CPA), #4 Exhibit 4 - Credit Card Statements, #5 Exhibit 5 - Relevant Excerpts of Baum Deposition Testimony, #6 Exhibit 6 - Relevant Excerpts of Fouzailoff Deposition Testimony)(Aran, Fernando)
November 21, 2022 Opinion or Order Filing 225 ORDER OF CONTINUANCE and ORDER REVISING PRETRIAL DEADLINES: Calendar Call set for 1/24/2023 02:00 PM before Judge Federico A. Moreno. Jury Trial set for two-week period starting 1/30/2023 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 11/21/2022. See attached document for full details. (mmd)
November 18, 2022 Opinion or Order Filing 224 NOTICE OF UNAVAILABILITY by BHPH Consulting Services, LLC, Anatoliy Slutskiy for dates of Dec 5-Jan 5 (Dunn, James)
November 15, 2022 Opinion or Order Filing 223 PAPERLESS ORDER granting #222 Motion to Withdraw as Attorney. Nicholas Anhold representing Technolojoy, LLC (Plaintiff) and Algahim, Ibrahim F. (Plaintiff) withdrawn from case. Komlavi Atsou, Esq. of the law firm Ogletree, Deakins, Nash, Smoak, and Stewart P.C. is substituted as counsel of record for the law firm Fisher & Phillips, LLP. Fernando S. Aran, Esq. remains counsel of record for the Plaintiff. Signed by Judge Federico A. Moreno on 11/15/2022. (mmd)
November 11, 2022 Opinion or Order Filing 222 MOTION to Withdraw as Attorney by Technolojoy, LLC. Responses due by 11/28/2022 (Aran, Fernando)
November 10, 2022 Opinion or Order Filing 221 CLERK'S NOTICE - Attorney Admissions has updated the contact information for PHV attorney Komlavi Atsou re #220 Notice of Change of Address, Email or Law Firm Name. (cw)
November 9, 2022 Opinion or Order Filing 220 NOTICE of Change of Address, Email or Law Firm Name by Fernando S. Aran (Aran, Fernando)
September 7, 2022 Opinion or Order Filing 219 PAPERLESS ORDER granting #218 Motion to Continue Deposition Deadline of BHPH'S EXPERT LEW BAUM. The deadline to depose the expert witness is extended to September 22, 2022. Signed by Judge Federico A. Moreno on 9/7/2022. (mmd)
August 29, 2022 Opinion or Order Filing 218 Joint MOTION to Continue Deposition Deadline of BHPH'S EXPERT re #197 Order on Motion to Strike,, Order on Motion in Limine,, Order on Motion to Continue,,, by BHPH Consulting Services, LLC. Responses due by 9/12/2022 (Dunn, James)
August 18, 2022 Opinion or Order Filing 217 Witness List Identifying L. Baum, CPA, as Def Expert by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
August 17, 2022 Opinion or Order Filing 216 CERTIFICATE OF SERVICE by BHPH Consulting Services, LLC of Expert Report by L. Baum CPA (Dunn, James)
August 16, 2022 Opinion or Order Filing 215 ORDER OF CONTINUANCE: Calendar Call set for 11/29/2022 02:00 PM before Judge Federico A. Moreno. Jury Trial set for two-week period starting 12/5/2022 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 8/15/2022. See attached document for full details. (mmd)
August 11, 2022 Opinion or Order Filing 214 NOTICE OF UNAVAILABILITY by Technolojoy, LLC (Aran, Fernando)
July 8, 2022 Opinion or Order Filing 213 REPLY to #212 Response/Reply (Other) DEFENDANTS REPLY TO RESPONSE REGARDING OBJECTIONS TO TRIAL EXHIBITS by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
June 29, 2022 Opinion or Order Filing 212 Plaintiff's RESPONSE to Defendants' Objections to Plaintiff's Trial Exhibits by Technolojoy, LLC. (Aran, Fernando)
June 29, 2022 Opinion or Order Filing 211 Plaintiff's Objections to Defendant's Trial Exhibits by Technolojoy, LLC. (Aran, Fernando)
June 29, 2022 Opinion or Order Filing 210 ORDER denying #205 Motion for Prejudgment Attachment. Signed by Judge Federico A. Moreno on 6/28/2022. See attached document for full details. (mmd)
June 17, 2022 Opinion or Order Filing 209 RESPONSE in Opposition re #205 Plaintiff's MOTION for Judgment Plaintiff's Motion for Pre-Judgment Attachment of Defendant Sean Fouzailoff's Property filed by Sean Fouzailoff. Replies due by 6/24/2022. (Attachments: #1 Exhibit Exhibit 1, Docket Showing no Final Judgment entered in Broward Circuit Quiet Title case)(Dunn, James)
June 17, 2022 Opinion or Order Filing 208 Objections to Pltf Exhibits to #202 Exhibit List,,,,,, #201 Exhibit List,,,,,,,,,, by BHPH Consulting Services, LLC. (Dunn, James)
June 17, 2022 Opinion or Order Filing 207 Proposed Jury Instructions by BHPH Consulting Services, LLC. (Dunn, James)
June 17, 2022 Opinion or Order Filing 206 TRIAL EXHIBITS 1-27 by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit Ex-1, Final Invoices From BHPH to Technolojoy, #2 Exhibit Ex-2, Draft/Non-Final Invoices from BHPH to Technolojoy, #3 Exhibit Ex-3, Photos of boxes of packed phones, #4 Exhibit Ex-4, Chart comparing Ex 1 to Ex 2 and Ex 3, #5 Exhibit Ex-5, AmEx Refund Letters, #6 Exhibit Ex-6, Google Sheets document featuring notes and communicaitons between reps of BHPH and Technolojoy, #7 Exhibit Ex-7, EMS table showing chargeback amounts, #8 Exhibit Ex-8, Text messages exchanged between BHPH and Technolojoy, #9 Exhibit Ex-9, AmEx Dispute Letters, #10 Exhibit Ex-10, Raw data, payments by Pltf to BHPH, #11 Exhibit Ex-11, Table matching payments to invoice numbers, #12 Exhibit Ex-12, table comparing pltf docs to def docs, #13 Exhibit Ex-13, Plaintiffs' chart from Plaintiffs' complaint, #14 Exhibit Ex-14, AmEx Production, #15 Exhibit Ex-15, BHPH Bank Statements 3166, 7225, #16 Exhibit Ex-16 Paypal Production for BHPH, #17 Exhibit Ex-17, Paypal Production for TJ, #18 Exhibit Ex-18, Plaintiff Exhibit 109-989-2028, #19 Exhibit Ex-19, Plaintiff Exhibit 109, continued, #20 Exhibit Ex-20, JP Morgan Chase Production, #21 Exhibit Ex-21, Zoho Invoices, #22 Exhibit Ex-22, Elavon Statements, #23 Exhibit Ex-23, EMS supplemental chargebacks, sales, #24 Exhibit Ex-24, Report/Letter, Pltf Expert, #25 Exhibit Ex-25, TJ's Exhibit 102-4, reflecting 32,500 wire, #26 Exhibit Ex-26, EMS Statements, #27 Exhibit Ex-27, Wires in and out including 115k to J Reynaud)(Dunn, James)
June 9, 2022 Opinion or Order Filing 205 Plaintiff's MOTION for Judgment Plaintiff's Motion for Pre-Judgment Attachment of Defendant Sean Fouzailoff's Property by Technolojoy, LLC. (Attachments: #1 Exhibit 1- Final Judgment, #2 Exhibit 2- Affidavit)(Aran, Fernando)
June 2, 2022 Opinion or Order Filing 204 NOTICE by Technolojoy, LLC of Withdrawing Expert Nathaniel Turner (Aran, Fernando)
May 20, 2022 Opinion or Order Filing 203 Proposed Jury Instructions by Technolojoy, LLC. (Aran, Fernando)
May 20, 2022 Opinion or Order Filing 202 Exhibit List Revised by Technolojoy, LLC.. (Attachments: #1 Exhibit Demonstrative 98, #2 Exhibit 98-1, #3 Exhibit 98-2, #4 Exhibit 98-3, #5 Exhibit 98-4, #6 Exhibit 98-5, #7 Exhibit 98-6, #8 Exhibit Demonstrative 99, #9 Exhibit 99-1, #10 Exhibit 99-2, #11 Exhibit 99-3, #12 Exhibit Demonstrative 100, #13 Exhibit 100-1, #14 Supplement 100-2, #15 Exhibit 100-3, #16 Exhibit 100-4, #17 Exhibit Demonstrative 101, #18 Exhibit 101-1, #19 Exhibit 101-2, #20 Exhibit Demonstrative 102, #21 Exhibit 102-1, #22 Exhibit 102-2, #23 Exhibit 102-3, #24 Exhibit 102-4, #25 Exhibit Demonstrative 103, #26 Exhibit 103-1, #27 Exhibit Demonstrative 104, #28 Exhibit 104-1, #29 Exhibit 104-2, #30 Exhibit 104-3, #31 Exhibit 104-4, #32 Exhibit 104-5, #33 Exhibit 104-6, #34 Exhibit Demonstrative 105, #35 Exhibit 105-1, #36 Exhibit 105-2, #37 Exhibit 105-3, #38 Exhibit Demonstrative 106, #39 Exhibit 106-1, #40 Exhibit 106-2, #41 Exhibit 106-3, #42 Exhibit 106-4, #43 Exhibit 106-5, #44 Exhibit 106-6, #45 Exhibit 106-7, #46 Exhibit 106-8, #47 Exhibit Demonstrative 107, #48 Exhibit 107-1, #49 Exhibit 107-2, #50 Exhibit 108, #51 Exhibit 109, #52 Exhibit 110-1, #53 Exhibit 110-2, #54 Exhibit 110-3, #55 Exhibit 111-1, #56 Exhibit 111-2, #57 Exhibit 111-3, #58 Exhibit 112-1, #59 Exhibit 112-2, #60 Exhibit 112-3, #61 Exhibit 113, #62 Exhibit 114-1, #63 Exhibit 114-2, #64 Exhibit 114-3, #65 Exhibit 115-1, #66 Exhibit 115-2, #67 Exhibit 115-3, #68 Exhibit 116, #69 Exhibit 117, #70 Exhibit Demonstrative 118)(Aran, Fernando)
May 20, 2022 Opinion or Order Filing 201 Exhibit List Revised by Technolojoy, LLC.. (Attachments: #1 Exhibit Demonstrative 67, #2 Exhibit 67-1, #3 Exhibit 67-2, #4 Exhibit Demonstrative 68, #5 Exhibit 68-1, #6 Exhibit 68-2, #7 Exhibit Demonstrative 69, #8 Exhibit 69-1, #9 Exhibit 69-2, #10 Exhibit Demonstrative 70, #11 Exhibit 70-1, #12 Exhibit 70-2, #13 Exhibit Demonstrative 71, #14 Exhibit 71-1, #15 Exhibit 71-2, #16 Exhibit Demonstrative 72, #17 Exhibit 72-1, #18 Exhibit 72-2, #19 Exhibit Demonstrative 73, #20 Exhibit 73-1, #21 Exhibit 73-2, #22 Exhibit Demonstrative 74, #23 Exhibit 74-1, #24 Exhibit 74-2, #25 Exhibit Demonstrative 75, #26 Exhibit 75-1, #27 Exhibit 75-2, #28 Exhibit Demonstrative 76, #29 Exhibit 76-1, #30 Exhibit 76-2, #31 Exhibit Demonstrative 77, #32 Exhibit 77-1, #33 Exhibit 77-2, #34 Exhibit Demonstrative 78, #35 Exhibit 78-1, #36 Exhibit 78-2, #37 Exhibit Demonstrative 79, #38 Exhibit 79-1, #39 Exhibit 79-2, #40 Exhibit Demonstrative 80, #41 Exhibit 80-1, #42 Exhibit 80-2, #43 Exhibit 80-3, #44 Exhibit 80-4, #45 Exhibit Demonstrative 81, #46 Exhibit 81-1, #47 Exhibit 81-2, #48 Exhibit Demonstrative 82, #49 Exhibit 82-1, #50 Exhibit 82-2, #51 Exhibit Demonstrative 83, #52 Exhibit 83-1, #53 Exhibit 83-2, #54 Exhibit Demonstrative 84, #55 Exhibit 84-1, #56 Exhibit 84-2, #57 Exhibit 84-3, #58 Exhibit Demonstrative 85, #59 Exhibit 85-1, #60 Exhibit 85-2, #61 Exhibit 85-3, #62 Exhibit Demonstrative 86, #63 Exhibit 86-1, #64 Exhibit 86-2, #65 Exhibit 86-3, #66 Exhibit Demonstrative 87, #67 Exhibit 87-1, #68 Exhibit 87-2, #69 Exhibit 87-3, #70 Exhibit Demonstrative 88, #71 Exhibit 88-1, #72 Exhibit 88-2, #73 Exhibit Demonstrative 89, #74 Exhibit 89-1, #75 Exhibit 89-2, #76 Exhibit Demonstrative 90, #77 Exhibit 90-1, #78 Exhibit 90-2, #79 Exhibit Demonstrative 91, #80 Exhibit 91-1, #81 Exhibit 91-2, #82 Exhibit Demonstrative 92, #83 Exhibit 92-1, #84 Exhibit 92-2, #85 Exhibit Demonstrative 93, #86 Exhibit 93-1, #87 Exhibit 93-2, #88 Exhibit Demonstrative 94, #89 Exhibit 94-1, #90 Exhibit 94-2, #91 Exhibit Demonstrative 95, #92 Exhibit 95-1, #93 Exhibit 95-2, #94 Exhibit Demonstrative 96, #95 Exhibit 96-1, #96 Exhibit 96-2, #97 Exhibit 96-3, #98 Exhibit 96-4, #99 Exhibit 97, #100 Exhibit 97-1)(Aran, Fernando)
May 20, 2022 Opinion or Order Filing 200 Exhibit List Revised by Technolojoy, LLC.. (Attachments: #1 Exhibit Demonstrative 34, #2 Exhibit 34-1, #3 Exhibit 34-2, #4 Exhibit Demonstrative 35, #5 Exhibit 35-1, #6 Exhibit 35-2, #7 Exhibit Demonstrative 36, #8 Exhibit 36-1, #9 Exhibit 36-2, #10 Exhibit Demonstrative 37, #11 Exhibit 37-1, #12 Exhibit 37-2, #13 Exhibit Demonstrative 38, #14 Exhibit 38-1, #15 Exhibit 38-2, #16 Exhibit Demonstrative 39, #17 Exhibit 39-1, #18 Exhibit 39-2, #19 Exhibit Demonstrative 40, #20 Exhibit 40-1, #21 Exhibit 40-2, #22 Exhibit Demonstrative 41, #23 Exhibit 41-1, #24 Exhibit 41-2, #25 Exhibit Demonstrative 42, #26 Exhibit 42-1, #27 Exhibit 42-2, #28 Exhibit Demonstrative 43, #29 Exhibit 43-1, #30 Exhibit 43-2, #31 Exhibit Demonstrative 44, #32 Exhibit 44-1, #33 Exhibit 44-2, #34 Exhibit Demonstrative 45, #35 Exhibit 45-1, #36 Exhibit 45-2, #37 Exhibit Demonstrative 46, #38 Exhibit 46-1, #39 Exhibit 46-2, #40 Exhibit Demonstrative 47, #41 Exhibit 47-1, #42 Exhibit 47-2, #43 Exhibit Demonstrative 48, #44 Exhibit 48-1, #45 Exhibit 48-2, #46 Exhibit Demonstrative 49, #47 Exhibit 49-1, #48 Exhibit 49-2, #49 Exhibit Demonstrative 50, #50 Exhibit 50-1, #51 Exhibit 50-2, #52 Exhibit Demonstrative 51, #53 Exhibit 51-1, #54 Exhibit 51-2, #55 Exhibit Demonstrative 52, #56 Exhibit 52-1, #57 Exhibit 52-2, #58 Exhibit Demonstrative 53, #59 Exhibit 53-1, #60 Exhibit 53-2, #61 Exhibit Demonstrative 54, #62 Exhibit 54-1, #63 Exhibit 54-2, #64 Exhibit Demonstrative 55, #65 Exhibit 55-1, #66 Exhibit 55-2, #67 Exhibit Demonstrative 56, #68 Exhibit 56-1, #69 Exhibit 56-2, #70 Exhibit Demonstrative 57, #71 Exhibit 57-1, #72 Exhibit 57-2, #73 Exhibit Demonstrative 58, #74 Exhibit 58-1, #75 Exhibit 58-2, #76 Exhibit Demonstrative 59, #77 Exhibit 59-1, #78 Exhibit 59-2, #79 Exhibit Demonstrative 60, #80 Exhibit 60-1, #81 Exhibit 60-2, #82 Exhibit Demonstrative 61, #83 Exhibit 61-1, #84 Exhibit 61-2, #85 Exhibit Demonstrative 62, #86 Exhibit 62-1, #87 Exhibit 62-2, #88 Exhibit Demonstrative 63, #89 Exhibit 63-1, #90 Exhibit 63-2, #91 Exhibit Demonstrative 64, #92 Exhibit 64-1, #93 Exhibit 64-2, #94 Exhibit Demonstrative 65, #95 Exhibit 65-1, #96 Exhibit 65-2, #97 Exhibit Demonstrative 66, #98 Exhibit 66-1, #99 Exhibit 66-2)(Aran, Fernando)
May 20, 2022 Opinion or Order Filing 199 Exhibit List Revised by Technolojoy, LLC.. (Attachments: #1 Exhibit Demonstrative 1, #2 Exhibit 1-1, #3 Exhibit 1-2, #4 Exhibit Demonstrative 2, #5 Exhibit 2-1, #6 Exhibit 2-2, #7 Exhibit Demonstrative 3, #8 Exhibit 3-1, #9 Exhibit 3-2, #10 Exhibit Demonstrative 4, #11 Exhibit 4-1, #12 Exhibit 4-2, #13 Exhibit Demonstrative 5, #14 Exhibit 5-1, #15 Exhibit 5-2, #16 Exhibit Demonstrative 6, #17 Exhibit 6-1, #18 Exhibit 6-2, #19 Exhibit Demonstrative 7, #20 Exhibit 7-1, #21 Exhibit 7-2, #22 Exhibit Demonstrative 8, #23 Exhibit 8-1, #24 Exhibit 8-2, #25 Exhibit Demonstrative 9, #26 Exhibit 9-1, #27 Exhibit 9-2, #28 Exhibit Demonstrative 10, #29 Exhibit 10-1, #30 Exhibit 10-2, #31 Exhibit Demonstrative 11, #32 Exhibit 11-1, #33 Exhibit 11-2, #34 Exhibit Demonstrative 12, #35 Exhibit 12-1, #36 Exhibit 12-2, #37 Exhibit Demonstrative 13, #38 Exhibit 13-1, #39 Exhibit 13-2, #40 Exhibit Demonstrative 14, #41 Exhibit 14-1, #42 Exhibit 14-2, #43 Exhibit Demonstrative 15, #44 Exhibit 15-1, #45 Exhibit 15-2, #46 Exhibit Demonstrative 16, #47 Exhibit 16-1, #48 Exhibit 16-2, #49 Exhibit Demonstrative 17, #50 Exhibit 17-1, #51 Exhibit 17-2, #52 Exhibit Demonstrative 18, #53 Exhibit 18-1, #54 Exhibit 18-2, #55 Exhibit Demonstrative 19, #56 Exhibit 19-1, #57 Exhibit 19-2, #58 Exhibit Demonstrative 20, #59 Exhibit 20-1, #60 Exhibit 20-2, #61 Exhibit Demonstrative 21, #62 Exhibit 21-1, #63 Exhibit 21-2, #64 Exhibit Demonstrative 22, #65 Exhibit 22-1, #66 Exhibit 22-2, #67 Exhibit Demonstrative 23, #68 Exhibit 23-1, #69 Exhibit 23-2, #70 Exhibit Demonstrative 24, #71 Exhibit 24-1, #72 Exhibit 24-2, #73 Exhibit Demonstrative 25, #74 Exhibit 25-1, #75 Exhibit 25-2, #76 Exhibit Demonstrative 26, #77 Exhibit 26-1, #78 Exhibit 26-2, #79 Exhibit Demonstrative 27, #80 Exhibit 27-1, #81 Exhibit 27-2, #82 Exhibit Demonstrative 28, #83 Exhibit 28-1, #84 Exhibit 28-2, #85 Exhibit Demonstrative 29, #86 Exhibit 29-1, #87 Exhibit 29-2, #88 Exhibit Demonstrative 30, #89 Exhibit 30-1, #90 Exhibit 30-2, #91 Exhibit Demonstrative 31, #92 Exhibit 31-1, #93 Exhibit 31-2, #94 Exhibit Demonstrative 32, #95 Exhibit 32-1, #96 Exhibit 32-2, #97 Exhibit Demonstrative 33, #98 Exhibit 33-1, #99 Exhibit 33-2)(Aran, Fernando)
April 19, 2022 Opinion or Order Filing 198 Minute Entry for proceedings held before Judge Federico A. Moreno: Calendar Call held on 4/19/2022. Court Reporter: Patricia Diaz, 305-523-5178 / Patricia_Diaz@flsd.uscourts.gov. (sc)
April 19, 2022 Opinion or Order Filing 197 OMNIBUS ORDER and ORDER OF CONTINUANCE. Calendar Call set for 10/4/2022 02:00 PM before Judge Federico A. Moreno., Jury Trial set for two-week period starting 10/11/2022 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 4/19/2022. See attached document for full details. (mmd)
April 18, 2022 Opinion or Order Filing 196 RESPONSE in Opposition re #189 Plaintiff's MOTION in Limine To Preclude Admission of Altered Invoices, Preclude Reference to Altered Invoices as "True and Accurate", and Secure Admission of Exhibits Demonstrating Defendants' Fraud filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 4/25/2022. (Dunn, James)
April 18, 2022 Opinion or Order Filing 195 STIPULATION Joint Proposed Stipulations by Technolojoy, LLC (Aran, Fernando)
April 18, 2022 Opinion or Order Filing 194 RESPONSE in Opposition re #192 MOTION to Continue Trial in Response to Newly Disclosed Documents re #187 Exhibits, filed by Technolojoy, LLC Plaintiffs' Reply in Opposition to Defendants' Motion to Continue Trial in Response to Newly Disclosed Documents filed by Technolojoy, LLC. Replies due by 4/25/2022. (Aran, Fernando)
April 15, 2022 Opinion or Order Filing 193 MOTION to Strike #170 Witness List PLAINTIFFS WITNESSES ELLEN FOUZAILOFF COOPER AND DETECTIVE BRANDON E. BURGESS by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 4/29/2022 (Dunn, James)
April 15, 2022 Opinion or Order Filing 192 MOTION to Continue Trial in Response to Newly Disclosed Documents re #187 Exhibits, filed by Technolojoy, LLC by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 4/29/2022 (Attachments: #1 Exhibit Notice of Duces Tecum Depo)(Dunn, James)
April 15, 2022 Opinion or Order Filing 191 RESPONSE in Opposition re #184 Defendant's MOTION to Strike #170 Witness List MOTION TO STRIKE PLAINTIFFS EXPERT WITNESS NATHANIEL TURNER AND MOTION IN LIMINE TO EXCLUDE FROM EVIDENCE THE NATHANIEL TURNER LETTER AND CHARTS RELATED THERETO filed by Technolojoy, LLC. Replies due by 4/22/2022. (Aran, Fernando)
April 12, 2022 Opinion or Order Filing 190 PRETRIAL STIPULATION Plaintiffs' Unilateral Proposed Pretrial Stipulations by Technolojoy, LLC (Aran, Fernando)
April 12, 2022 Opinion or Order Filing 189 Plaintiff's MOTION in Limine To Preclude Admission of Altered Invoices, Preclude Reference to Altered Invoices as "True and Accurate", and Secure Admission of Exhibits Demonstrating Defendants' Fraud by Technolojoy, LLC. (Aran, Fernando)
April 12, 2022 Opinion or Order Filing 188 PAPERLESS ORDER granting #185 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Nicholas Anhold. Signed by Judge Federico A. Moreno on 4/12/2022. (mmd)
April 12, 2022 Opinion or Order Filing 187 TRIAL EXHIBITS 51, 52, 53 by Technolojoy, LLC. Related document: #178 Exhibits,,,,,,,,,,,, filed by Technolojoy, LLC. (Attachments: #1 Exhibit 51 - E-mailed Invoices from Defendant BHPH Consulting Services, LLC to Technolojoy, LLC, #2 Exhibit 52 - Documents in Support of Turner's Expert Report/Opinion [ECF#178-45], #3 Exhibit 53 - Report for Purchasing Inventory for Years 2018, 2019, and 2020)(Aran, Fernando)
April 12, 2022 Opinion or Order Filing 186 NOTICE by Technolojoy, LLC Plaintiffs' Notice of Uploading Supplemental Exhibits onto Court's Docket (Aran, Fernando)
April 8, 2022 Opinion or Order Filing 185 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Nicholas Anhold. Filing Fee $ 200.00 Receipt # AFLSDC-15544926 by Technolojoy, LLC. Responses due by 4/22/2022 (Attachments: #1 Certification Certification of Nicholas Anhold, #2 Text of Proposed Order Proposed Order Granting Motion to Appear Pro Hac Vice)(Aran, Fernando)
April 5, 2022 Opinion or Order Filing 184 Defendant's MOTION to Strike #170 Witness List MOTION TO STRIKE PLAINTIFFS EXPERT WITNESS NATHANIEL TURNER AND MOTION IN LIMINE TO EXCLUDE FROM EVIDENCE THE NATHANIEL TURNER LETTER AND CHARTS RELATED THERETO by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 4/19/2022 (Dunn, James)
March 8, 2022 Opinion or Order Filing 183 ORDER granting in part and denying in part #113 #138 Cross-Motions for Summary Judgment and denying #148 Motion in Limine without prejudice. Signed by Judge Federico A. Moreno on 3/8/2022. See attached document for full details. (mmd)
October 13, 2021 Opinion or Order Filing 182 PAPERLESS ORDER granting #176 Motion to Withdraw by attorney Madilyn Maruna for the Plaintiffs. Signed by Judge Federico A. Moreno on 10/13/2021. (mmd)
October 13, 2021 Opinion or Order Filing 181 PAPERLESS ORDER granting #180 Motion for Clarification and Continuance of Trial. Calendar Call set for 4/19/2022 at 02:00 PM before Judge Federico A. Moreno. Jury Trial set for the two-week period starting 4/25/2022 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 10/13/2021. (mmd)
October 13, 2021 Opinion or Order Attorney Madilyn M. Maruna representing Technolojoy, LLC (Plaintiff) and Algahim, Ibrahim F. (Plaintiff) and Algahim, Ibrahim F. (Counter Defendant); and Technolojoy, LLC (Counter Defendant); terminated. Notice of Termination delivered by US Mail to Madilyn Maruna. (ls)(per DE #182)
October 12, 2021 Opinion or Order Filing 180 MOTION for clarification 179 Trial Management Order, CONTINUE JANUARY TRIAL DATE AS SLUTSKIYS WIFE IS SCHEDULED TO GIVE BIRTH FEBRUARY 4, 2022 by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 10/26/2021 (Dunn, James)
October 12, 2021 Opinion or Order Filing 179 PAPERLESS ORDER CONTINUING TRIAL due to the pending motion for summary judgment and the limitation on the number of jurors that can be brought into the courthouse due to the pandemic. Calendar Call set for 1/25/2022 02:00 PM in Miami Division before Judge Federico A. Moreno. Jury Trial set for the two-week period starting 1/31/2022 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 10/12/2021. (mmd)
October 11, 2021 Opinion or Order Filing 178 TRIAL EXHIBITS by Technolojoy, LLC. (Attachments: #1 Exhibit 1 - Text Messages between Technolojoy and BHPH Consulting Services, LLC (BHPH) from 12/1/2018 to 7/11/2019, #2 Exhibit 2 - Google Sheet, #3 Exhibit 3 - Google Sheet Comments, #4 Exhibit 4 - E-mails showing Google Sheet comments, #5 Exhibit 5 - Invoice Nos. 150 through 260, #6 Exhibit 6 - BHPH's Incoming Inventory List, #7 Exhibit 7 - Sample invoices with handwritten notes, #8 Exhibit 8 - BHPH's Refund Statement, #9 Exhibit 9 - BHPH's e-mails to Elavon regarding chargebacks, #10 Exhibit 10 - BHPHs e-mail dated July 6, 2019, #11 Exhibit 11 - BHPHs e-mail dated July 5, 2019, #12 Exhibit 12 - BHPHs e-mail dated July 5, 2019, #13 Exhibit 13 - BHPHs e-mail dated July 5, 2019, #14 Exhibit 14 - BHPHs e-mail dated July 5, 2019, #15 Exhibit 15 - BHPHs e-mail dated July 5, 2019, #16 Exhibit 16 - BHPHs e-mail dated July 5, 2019 regarding alleged three refunds, #17 Exhibit 17 - E-mail forwarded from Technolojoy to BHPH dated July 6, 2019 at 5:40 PM, #18 Exhibit 18 - BHPHs e-mail dated July 28, 2019 to Amex regarding Technolojoys requests for chargeback, #19 Exhibit 19 - BHPHs Notice to Cease and Desist dated July 12, 2019, #20 Exhibit 20 - BHPHs application with credit card processing vendor, #21 Exhibit 21 - Biography of Tony Slutskiy, #22 Exhibit 22 - Copy of photograph showing BHPH's workstation, #23 Exhibit 23 - FedExs Shipment Information Report, #24 Exhibit 24 - E-mails between BHPH and Zoho, #25 Exhibit 25 - Draft Declaration BHPH prepared for Zoho, #26 Exhibit 26 - Complaint Referral Form, #27 Exhibit 27 - Complaint Referral Form, #28 Exhibit 28 - Invoice Nos. 220, 221, 224, 238, #29 Exhibit 29 - GoToMeeting notice, #30 Exhibit 30 - E-mail from Technolojoy to BHPH dated July 8, 2019, #31 Exhibit 31 - E-mail from Technolojoy to BHPH dated July 8, 2019, #32 Exhibit 32 - Credit card statements for Amex Plum Card, #33 Exhibit 33 - Credit card statements for Amex Cash Magnet Card, #34 Exhibit 34 - Credit card statements for Amex Plum Card, #35 Exhibit 35 - Credit card statements for Amex Business Platinum Card, #36 Exhibit 36 - Credit card statements for Capital One Spark Business Card, #37 Exhibit 37 - Credit card statements for PNC Cash Rewards Visa Signature Business Card, #38 Exhibit 38 - Credit card statements for PNC Cash Rewards Visa Signature Business Card, #39 Exhibit 39 - Activity on Barclay credit card for May 2019, #40 Exhibit 40 - Activity on Chase credit card for May 2019, #41 Exhibit 41 - Activity on Amex Business Platinum Card, #42 Exhibit 42 - Activity on Amex Plum Card, #43 Exhibit 43 - Activity on Amex Cash Magnet Card, #44 Exhibit 44 - Activity on Amex Plum Card, #45 Exhibit 45 - Expert Report of Nathaniel Turner, #46 Exhibit 46 - First Amended Complaint, #47 Exhibit 47 - BHPHs Answer and Counterclaim, #48 Exhibit 48 - BHPHs Answer to First Amended Complaint, #49 Exhibit 49 - BHPHs response to Plaintiffs discovery requests, #50 Exhibit 50 - Declarations of Sean Fouzailoff)(Aran, Fernando)
October 11, 2021 Opinion or Order Filing 177 NOTICE by Technolojoy, LLC Plaintiffs' Notice of Uploading Exhibits onto Court's Docket, or in the Alternative, Motion for Leave to Upload Exhibits onto Court's Docket (Aran, Fernando)
October 11, 2021 Opinion or Order Filing 176 MOTION for Leave to File Withdraw as Counsel for Plaintiffs by Technolojoy, LLC. (Aran, Fernando)
October 8, 2021 Opinion or Order Filing 175 TRIAL EXHIBITS Amended/Supplement Exhibit 14 by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Related document: #173 Exhibit List,,, filed by Sean Fouzailoff, Anatoliy Slutskiy, BHPH Consulting Services, LLC. (Attachments: #1 Exhibit Part 1, #2 Exhibit Part 2, #3 Exhibit Part 3, #4 Exhibit Part 4, #5 Exhibit Part 5, #6 Exhibit Part 6)(Dunn, James)
October 8, 2021 Opinion or Order Filing 174 Witness List Amended adding EMS Custodian of Records by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
October 8, 2021 Opinion or Order Filing 173 Exhibit List by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Attachments: #1 Exhibit 1-True and correct copies of invoices, #2 Exhibit 2-Draft copies of invoices, #3 Exhibit 3-Photos from boxes, #4 Exhibit 4-Chart comparing 1,2, and,3, #5 Exhibit 5-AmEx Refund Letters, #6 Exhibit 6-Google Sheets, #7 Exhibit 7-EMS table, chargebacks, settlement, #8 Exhibit 8-Text messages, #9 Exhibit 9-AmEx Refund/Dispute letters, #10 Exhibit 10-Raw Data payments made by pltf to def, #11 Exhibit 11-Chart matching payments to invoice numbers, #12 Exhibit 12-Table comparing Pltf docs to Def Docs, #13 Exhibit 13-Original Complaint Chart drafted by Pltf, #14 Exhibit 15-AmEx Payment docs (14 is too large to upload))(Dunn, James)
October 8, 2021 Opinion or Order Filing 172 Witness List by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
October 7, 2021 Opinion or Order Filing 171 CLERK'S NOTICE - Attorney Admissions has updated the contact information for PHV attorney Komlavi Atsou re #168 Notice of Change of Address, Email or Law Firm Name. (pt)
October 6, 2021 Opinion or Order Filing 170 Witness List by Technolojoy, LLC.. (Aran, Fernando)
October 6, 2021 Opinion or Order Filing 169 Exhibit List by Technolojoy, LLC.. (Aran, Fernando)
October 6, 2021 Opinion or Order Filing 168 NOTICE of Change of Address, Email or Law Firm Name by Fernando S. Aran (Aran, Fernando)
September 21, 2021 Opinion or Order Filing 167 AFFIDAVIT in Opposition re #139 MOTION for Leave to File , #151 Plaintiff's MOTION to Strike Sean Fouzailoff's Declaration AMENDED DECLARATION OF SEAN FOUZAILOFF (A) IN SUPPORT OF BHPHS MOTION FOR SUMMARY JUDGMENT, and (B) IN OPPOSITION OF PLAINTIFFS MOTION FOR SUMMARY JUDGMENT filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
September 15, 2021 Opinion or Order Filing 166 PAPERLESS ORDER granting #151 Plaintiff's Motion to Strike Declaration of Sean Fouzailoff and GRANTING Defendant leave to file an Amended Declaration of Sean Fouzailoff. Defendant shall file the Amended Declaration of Sean Fouzailoff by September 22, 2021. Signed by Judge Federico A. Moreno on 9/15/2021. (mmd)
September 14, 2021 Opinion or Order Filing 165 REPLY to #154 Response in Opposition to Motion,, ---In support of Motion for Leave to Amend July 28, 2021, and August 9, 2021, Declarations filed by BHPH Consulting Services, LLC, Sean Fouzailoff, and Anatoliy Slutskiy by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
September 10, 2021 Opinion or Order Filing 164 RESPONSE in Support re #148 MOTION in Limine filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
September 7, 2021 Opinion or Order Filing 163 RESPONSE in Opposition re #148 MOTION in Limine filed by Ibrahim F. Algahim, Technolojoy, LLC. Replies due by 9/14/2021. (Attachments: #1 Exhibit [D.E. 136-1, Exhibit II], #2 Exhibit [D.E. 136-1, Exhibit JJ])(Aran, Fernando)
September 7, 2021 Opinion or Order Filing 162 REPLY to Response to Motion re #151 Plaintiff's MOTION to Strike Sean Fouzailoff's Declaration filed by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
September 7, 2021 Opinion or Order Filing 161 PAPERLESS ORDER granting #160 Motion for Leave to File Opposition to Plaintiff's Statement of Facts. Signed by Judge Federico A. Moreno on 9/7/2021. (mmd)
September 2, 2021 Opinion or Order Filing 160 MOTION for Leave to File \OPPOSITION TO PLAINTIFFS ADDITIONAL FACTS [DE 150] FILED WITH CONSENT OF PLAINTIFF by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
September 2, 2021 Opinion or Order Filing 159 Statement of: MATERIAL FACTS IN OPPOSITION TO PLAINTIFFS ADDITIONAL FACTS [DE 150] by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re #150 Statement (Dunn, James)
September 2, 2021 Opinion or Order Filing 158 Statement of: Material Facts In Response, Matching Plaintiff's New Paragraph Numbering by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re 152 Order on Motion for Leave to File, #153 Statement (Dunn, James)
September 1, 2021 Opinion or Order Filing 157 REPLY to #149 Response in Opposition to Motion,,,, by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
September 1, 2021 Opinion or Order Filing 156 Statement of: Reply Statement of Material Facts by Ibrahim F. Algahim, Technolojoy, LLC re #155 Reply to Response to Motion (Aran, Fernando)
September 1, 2021 Opinion or Order Filing 155 REPLY to Response to Motion re #138 Plaintiff's MOTION for Summary Judgment filed by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
August 30, 2021 Opinion or Order Filing 154 RESPONSE in Opposition re #151 Plaintiff's MOTION to Strike Sean Fouzailoff's Declaration And Motion for Leave to Amend July 28, 2021, and August 9, 2021, Declarations filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 9/7/2021. (Attachments: #1 Affidavit Amended Declaration of Sean Fouzailoff Including Perjery Reference as related to July 28, 2021, #2 Affidavit Amended Declaration of Sean Fouzailoff Including Perjery Reference as related to August 9, 2021)(Dunn, James)
August 27, 2021 Opinion or Order Filing 153 Statement of: Material Facts by Ibrahim F. Algahim, Technolojoy, LLC re #138 Plaintiff's MOTION for Summary Judgment (Aran, Fernando)
August 27, 2021 Opinion or Order Filing 152 PAPERLESS ORDER granting #145 Motion for Leave to File Statement of Material Facts consistent with Local Rule 56.1. Signed by Judge Federico A. Moreno on 8/27/2021. (mmd)
August 25, 2021 Opinion or Order Filing 151 Plaintiff's MOTION to Strike Sean Fouzailoff's Declaration by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 9/8/2021 (Attachments: #1 Memorandum Memorandum in Support)(Aran, Fernando)
August 25, 2021 Opinion or Order Filing 150 Statement of: Material Facts in Opposition to Defendants' Statement of Material Facts by Ibrahim F. Algahim, Technolojoy, LLC re #149 Response in Opposition to Motion,,,, (Aran, Fernando)
August 25, 2021 Opinion or Order Filing 149 RESPONSE in Opposition re #113 Defendant's MOTION for Summary Judgment filed by Ibrahim F. Algahim, Technolojoy, LLC. Replies due by 9/1/2021. (Attachments: #1 Affidavit August 25, 2021 Affidavit of Ibrahim Algahim, #2 Affidavit Affidavit of Nathaniel Turner, #3 Exhibit Relevant Pages from Algahim Deposition Transcript, #4 Exhibit Relevant Pages from Fouzailoff Deposition Transcript, #5 Exhibit Relevant Pages from Slutskiy Deposition Transcript, #6 Exhibit Referenced Text Messages - Exhibit A, #7 Exhibit Fouzailoff Deposition Exhibit B, #8 Exhibit Fouzailoff Deposition Exhibit C, #9 Exhibit Fouzailoff Deposition Exhibit G, #10 Exhibit Fouzailoff Deposition Exhibit H, #11 Exhibit Fouzailoff Deposition Exhibit II, #12 Exhibit Fouzailoff Deposition Exhibit JJ, #13 Exhibit Fouzailoff Deposition Exhibit M, #14 Exhibit Fouzailoff Deposition Exhibit O, #15 Exhibit Fouzailoff Deposition Exhibit P, #16 Exhibit Fouzailoff Deposition Exhibit, #17 Exhibit Fouzailoff Deposition Exhibit R)(Aran, Fernando)
August 25, 2021 Opinion or Order Filing 148 MOTION in Limine by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Deposition of S. Fouzailoff, #2 Deposition Exhibit II (Indigo indigo))(Dunn, James)
August 25, 2021 Opinion or Order Filing 147 Statement of: Material Facts in Opposition to MSJ by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re #138 Plaintiff's MOTION for Summary Judgment (Dunn, James)
August 25, 2021 Opinion or Order Filing 146 RESPONSE in Opposition re #138 Plaintiff's MOTION for Summary Judgment filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 9/1/2021. (Attachments: #1 Affidavit Declaration of Sean Fouzailoff dated August 9, 2021, #2 Exhibit Exhibit A- True/Correct/Final Invoices, #3 Exhibit Exhibit B- Draft Invoices, #4 Exhibit Exhibit E-AmEx Letters Showing Refunds, #5 Exhibit Exhibit F-Google Sheets Doc With Comments, #6 Exhibit Exhibit G-EMS Table Showing Chargebacks, #7 Exhibit Exhibit H-EMS Settlement Agreement and Guarantee by Fouzailoff, #8 Exhibit Exhibit K- Credit Card Processor Raw Data, #9 Exhibit Exhibit 9 Deposition, part of which was Exhibit J, #10 Exhibit Declaration of Sean Fouzailoff dated July 28, 2021)(Dunn, James)
August 19, 2021 Opinion or Order Filing 145 Plaintiff's MOTION for Leave to File Statement Material Facts Consistent With Local rule 56.1 by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Plaintiffs' Statement of Material Facts)(Aran, Fernando)
August 11, 2021 Opinion or Order Filing 144 PAPERLESS ORDER granting the parties' #140 Joint Motion to Extend Filing Deadline for Responses in Opposition to Motions for Summary Judgment. The parties shall file their responses in opposition to the motions for summary judgment #113 #138 by August 25, 2021. Signed by Judge Federico A. Moreno on 8/11/2021. (jz01)
August 10, 2021 Opinion or Order Filing 143 SUPPLEMENT to #113 Defendant's MOTION for Summary Judgment Exhibit M-Declaration of Sean Fouzailoff by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy (Dunn, James)
August 10, 2021 Opinion or Order Filing 142 Statement of: Material Facts by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re #113 Defendant's MOTION for Summary Judgment (Dunn, James)
August 10, 2021 Opinion or Order Filing 141 PAPERLESS ORDER granting #139 BHPH, Sean Fouzailoff, and Anatoliy Slutskiy's Motion for Leave to File Declaration and Statement of Material Facts. 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 Federico A. Moreno on 8/10/2021. (jz01)
August 9, 2021 Opinion or Order Filing 140 Joint MOTION for Extension of Time to File Response/Reply/Answer by Technolojoy, LLC. (Aran, Fernando)
August 4, 2021 Opinion or Order Filing 139 MOTION for Leave to File by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Supplement Sattement of Material Facts Related to MSJ, #2 Exhibit M-Decl of S. Fouzailoff, #3 Text of Proposed Order)(Dunn, James)
July 28, 2021 Opinion or Order Filing 138 Plaintiff's MOTION for Summary Judgment by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 8/11/2021 (Attachments: #1 Memorandum Memorandum in Support, #2 Affidavit Affidavit of Ibrahim Algahim, #3 Exhibit Deposition Exhibit A - Referenced Text Message, #4 Transcripts Referenced Pages - Slutskiy Transcript, #5 Transcripts Referenced Pages - Fouzailoff Transcript, #6 Transcripts Referenced Pages - Algahim Transcript, #7 Exhibit Deposition Exhibit B - Google Sheet, #8 Exhibit Deposition Exhibit C - Google Sheet Comments, #9 Exhibit Deposition Exhibit G - Invoices, #10 Exhibit Deposition Exhibit W - Posts)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 137 SUPPLEMENT to #113 Defendant's MOTION for Summary Judgment Attachment Exhibit L With All Pages by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy (Attachments: #1 Supplement To Summary Judgment Exhibit D-Spreadsheet Comparing Invoices)(Dunn, James)
July 28, 2021 Opinion or Order Filing 136 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits G - KK Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 135 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibit F Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 134 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits B - E Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 133 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (2) Exhibit A Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 132 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (1) of Exhibit A Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 131 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits G - PP Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 130 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibit F Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 129 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits B - EE Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 128 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (2) of Exhibit A Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 127 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (1) of Exhibit A Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 126 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits 11 - 19 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 125 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (5) of Exhibit 10 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 124 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (4) of Exhibit 10 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 123 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (3) of Exhibit 10 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 122 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (2) of Exhibit 10 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 121 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits 1-9 and Part (1) of Exhibit 10 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 120 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (3) of Exhibit 6 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 119 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (2) of Exhibit 6 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 118 NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Sean Fouzailoff)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 117 NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Anatoliy Slutskiy)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 116 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Part (1) of Exhibit 6 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 115 NOTICE of Filing Discovery: Deposition Exhibits by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit Exhibits 1-6 Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 114 NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Ibrahim Algahim)(Aran, Fernando)
July 28, 2021 Opinion or Order Filing 113 Defendant's MOTION for Summary Judgment by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 8/11/2021 (Attachments: #1 Exhibit A-True/Correct/Final Invoices, #2 Exhibit B-Draft Invoices, #3 Exhibit C-Photos from Boxes, #4 Exhibit D-Spreadsheet Comparing Invoices, #5 Exhibit E-AmEx Letters Showing Refunds, #6 Exhibit F- Google Sheets With Notes, #7 Exhibit G- EMS Table, #8 Exhibit H- EMS Settlement Agreement, #9 Exhibit I- Text Messages, #10 Exhibit J- AmEx Dispute Letter, #11 Exhibit K- Credit Card Processor Raw Data, #12 L-Credit Card Payments Matched to Invoice Number, #13 Deposition Depo of Sean Fouzailoff 6-24-21)(Dunn, James)
July 27, 2021 Opinion or Order Filing 112 ANSWER and Affirmative Defenses to Complaint with Jury Demand To Fraud Counts IV-VI by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
July 21, 2021 Opinion or Order Reset Answer Due Deadline: BHPH Consulting Services, LLC response due 7/27/2021; Sean Fouzailoff response due 7/27/2021; Anatoliy Slutskiy response due 7/27/2021. (ls)(per DE #111)
July 21, 2021 Opinion or Order Filing 111 ORDER denying #105 Motion to Dismiss Fraud Claims. Signed by Judge Federico A. Moreno on 7/21/2021. See attached document for full details. (jz01)
July 7, 2021 Opinion or Order Filing 110 PAPERLESS ORDER granting #109 Joint Motion for Extension of Time to file Motions for Summary Judgment. The deadline to file motions for summary judgment is extended until July 28, 2021. Signed by Judge Federico A. Moreno on 7/7/2021. (mmd)
July 6, 2021 Opinion or Order Filing 109 Joint MOTION for Extension of Time TO EXTEND SUMMARY JUDGMENT FILING DEADLINE by Technolojoy, LLC. Responses due by 7/20/2021 (Aran, Fernando)
July 6, 2021 Opinion or Order Filing 108 Clerks Notice of Docket Correction re #99 ORDER OF CONTINUANCE. Calendar Call set for 10/19/2021 02:00 PM before Judge Federico A. Moreno. Docket Text Modified by Clerk. (sk)
July 6, 2021 Opinion or Order Set/Reset Hearings. See #99 ORDER OF CONTINUANCE. Calendar Call set for 10/19/2021 02:00 PM before Judge Federico A. Moreno. (sk)
June 29, 2021 Opinion or Order Filing 107 REPLY to Response to Motion re #105 MOTION TO DISMISS #101 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM COUNTS IV-VI filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
June 22, 2021 Opinion or Order Filing 106 RESPONSE in Opposition re #105 MOTION TO DISMISS #101 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM COUNTS IV-VI filed by Technolojoy, LLC. Replies due by 6/29/2021. (Aran, Fernando)
June 8, 2021 Opinion or Order Filing 105 MOTION TO DISMISS #101 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM COUNTS IV-VI by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 6/22/2021 (Dunn, James)
June 8, 2021 Opinion or Order Filing 104 ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand TO COUNTS I-III, and COUNTS VII-VII, COUNTERCLAIM INCORPORATED BY REFERENCE TO DE# 39 against All Plaintiffs by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
May 28, 2021 Opinion or Order Filing 103 CLAIM Counterclaim by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
May 26, 2021 Opinion or Order Filing 102 MEDIATION REPORT by Israel U. Reyes. Disposition: Adjourned.(Reyes, Israel)
May 25, 2021 Opinion or Order Filing 101 First AMENDED COMPLAINT against All Defendants filed in response to Order Granting Motion for Leave, filed by Technolojoy, 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)(Aran, Fernando)
May 14, 2021 Opinion or Order Filing 100 ORDER Granting in part Motion to Dismiss #85 , Granting Leave to File an Amended Complaint, and denying #84 Motion to Strike Counterclaim. Signed by Judge Federico A. Moreno on 5/14/2021. See attached document for full details. (mmd)
April 13, 2021 Opinion or Order Filing 99 ORDER OF CONTINUANCE AND ORDER REVISING PRETRIAL DEADLINES: Calendar Call set for 10/19/2021 02:00 PM before Judge Federico A. Moreno. Jury Trial set for two-week period starting 10/25/2021 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 4/13/2021. See attached document for full details. (mmd) Modified text/status per Chambers on 7/6/2021 (sk).
April 6, 2021 Opinion or Order Filing 98 Joint MOTION for Extension of Time of Discovery Cutoff Deadline and Amend Scheduling Order [DE 78] by Technolojoy, LLC. (Aran, Fernando)
February 23, 2021 Opinion or Order Filing 97 ORDER on #88 #91 Motions to Quash. Signed by Magistrate Judge Jonathan Goodman on 2/23/2021. See attached document for full details. (km03)
February 12, 2021 Opinion or Order Filing 96 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Jonathan Goodman: Zoom Discovery Hearing held on 2/12/2021. Post-Hearing Administrative Order to follow. Total time in court: 47 minutes. Attorney Appearance(s): Fernando S. Aran, Madilyn M. Maruna, Komlavi Atsou, James Richard Dunn, (Digital JG_01_02-12-2021/ Zoom) (fbn)
February 3, 2021 Opinion or Order Filing 95 PAPERLESS ORDER setting Zoom Discovery Hearing on #88 Defendants' Motion to Quash Subpoena to Devtov, Inc. and #91 Defendants' Motion to Quash Subpoena to JP Morgan Chase Bank for 2/12/2021 at 03:30 PM in the Miami Division before Magistrate Judge Jonathan Goodman. All parties will need to download the Zoom App for cell phone, tablet (iPad), and for those using a desktop or a laptop equipped with a webcam to click on the meeting link and install the plug-in when prompted. Then enter the Meeting ID and Password. Each participant needs to log in 10 minutes early, to make sure there are no glitches. The hearing will be conducted via ZOOM, as follows: Join ZoomGov Meeting https://www.zoomgov.com/j/1608143498?pwd=UG1tdER2VzhKUDVHdjAvRHBMVVdGUT09. Meeting ID: 160 814 3498. Passcode: 585854.This Zoom hearing is the digital equivalent of an actual, in-court hearing, so counsel are expected to dress as though they are in an actual federal courtroom.Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the court. Signed by Magistrate Judge Jonathan Goodman on 2/3/2021. (fbn)
February 3, 2021 Opinion or Order PAPERLESS ORDER setting Zoom Discovery Hearing on #88 Defendants' Motion to Quash Subpoena to Devtov, Inc. and #91 Defendants' Motion to Quash Subpoena to JP Morgan Chase Bank for 2/12/2021 at 03:30 PM in the Miami Division before Magistrate Judge Jonathan Goodman. All parties will need to download the Zoom App for cell phone, tablet (iPad), and for those using a desktop or a laptop equipped with a webcam to click on the meeting link and install the plug-in when prompted. Then enter the Meeting ID and Password. Each participant needs to log in 10 minutes early, to make sure there are no glitches. The hearing will be conducted via ZOOM, as follows: Join ZoomGov Meeting https://www.zoomgov.com/j/1608143498?pwd=UG1tdER2VzhKUDVHdjAvRHBMVVdGUT09. Meeting ID: 160 814 3498. Passcode: 585854. This Zoom hearing is the digital equivalent of an actual, in-court hearing, so counsel are expected to dress as though they are in an actual federal courtroom.Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the court. Signed by Magistrate Judge Jonathan Goodman on 2/3/2021. (fbn)
February 2, 2021 Opinion or Order Filing 94 PAPERLESS ORDER setting Zoom Discovery Hearing on #88 Defendants' Motion to Quash Subpoena to Devtov, Inc. and #91 Defendants' Motion to Quash Subpoena to JP Morgan Chase Bank for 2/12/2021 at 03:30 PM in the Miami Division before Magistrate Judge Jonathan Goodman. No further briefing on these motions will be permitted. The specific Zoom link and instructions will follow by subsequent paperless order. Signed by Magistrate Judge Jonathan Goodman on 2/2/2021. (km03)
February 1, 2021 Opinion or Order Filing 93 RESPONSE in Opposition re #91 MOTION to Quash Paragraphs 1-3, and, 6, of the Subpoena Directed to Third Party JP Morgan Chase Bank, N.A., filed by Technolojoy, LLC. Replies due by 2/8/2021. (Aran, Fernando)
January 28, 2021 Opinion or Order Filing 92 ORDER REFERRING #88 MOTION to Quash Subpoena Directed to Non-Party Devtov, Inc. and #91 MOTION to Quash Paragraphs 1-3, and, 6, of the Subpoena Directed to Third Party JP Morgan Chase Bank, N.A. Motions referred to Judge Jonathan Goodman. Signed by Judge Federico A. Moreno on 1/8/2021. See attached document for full details. (mmd)
January 23, 2021 Opinion or Order Filing 91 MOTION to Quash Paragraphs 1-3, and, 6, of the Subpoena Directed to Third Party JP Morgan Chase Bank, N.A., by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Exhibit JP Morgan Subpoena, #2 Text of Proposed Order)(Dunn, James)
January 19, 2021 Opinion or Order Filing 89 NOTICE by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re #88 MOTION to Quash Subpoena Directed to Non-Party Devtov, Inc (Attachments: #1 Text of Proposed Order on BHPH's Motion to Quash Subpoena Directed to Devtov, Inc. [DE 88-1]) (Dunn, James)
January 18, 2021 Opinion or Order Filing 88 MOTION to Quash Subpoena Directed to Non-Party Devtov, Inc by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Exhibit Executed Subpoena to Devtov, Inc., #2 Affidavit of Sean Fouzailoff)(Dunn, James)
January 15, 2021 Opinion or Order Filing 90 Entry docketed in error. (lk) Modified text and restricted imeage on 1/19/2021 (lk).
January 15, 2021 Opinion or Order Filing 87 RESPONSE in Support re #34 Plaintiff's MOTION to Strike or Alternatively, To Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law filed by Technolojoy, LLC. (Aran, Fernando)
January 15, 2021 Opinion or Order Filing 86 RESPONSE in Opposition re #13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM filed by Ibrahim F. Algahim. Replies due by 1/22/2021. (Aran, Fernando)
January 15, 2021 Opinion or Order Filing 85 NOTICE of Filing by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re 74 Order on Motion to Reopen Case, 75 Order, #77 Order (Attachments: #1 Exhibit [DE 13] Motion to Dismiss Counts II-IX, XI-XII, and individual claims of Plaintiff, #2 Exhibit [DE 32] Defendants' Reply in Support of the Motion to Dismiss, #3 Exhibit [DE 39] Second Amended Answer to I, X, and XII, Aff Defenses,and Counterclaims, #4 Exhibit [DE 39-1] Exhibits to Counterclaims, #5 Exhibit [DE 36] Defendants' Response in Opposition to Motion to Strike) (Dunn, James) Modified text on 1/15/2021 (kpe).
January 14, 2021 Opinion or Order Filing 84 MOTION to Strike by Technolojoy, LLC. Responses due by 1/28/2021 (Aran, Fernando)
January 11, 2021 Opinion or Order Filing 83 Clerks Notice of Docket Correction re #82 Order. Wrong Document attached. Reattached the correct document to D.E #82 ; The correct document has also been attached to this notice. (ra)
January 11, 2021 Opinion or Order Filing 82 ORDER GRANTING MOTION FOR SUBSTITUTION OF COUNSEL. Signed by Judge Federico A. Moreno on 1/11/2021. See attached document for full details. (mmd) (Main Document 82 replaced on 1/11/2021) (ra).
January 8, 2021 Opinion or Order Filing 81 NOTICE/STIPULATION of Substitution of Counsel by James Richard Dunn on behalf of BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy instead of prior counsel of record John B. T. Murray, Jr., and Gunster Yoakley & Stewart, P.A.. (Attachments: #1 Text of Proposed Order) (Dunn, James)
January 8, 2021 Opinion or Order Filing 80 NOTICE of Attorney Appearance by James Richard Dunn on behalf of BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Attorney James Richard Dunn added to party BHPH Consulting Services, LLC(pty:cc), Attorney James Richard Dunn added to party BHPH Consulting Services, LLC(pty:cc), Attorney James Richard Dunn added to party BHPH Consulting Services, LLC(pty:dft), Attorney James Richard Dunn added to party Sean Fouzailoff(pty:dft), Attorney James Richard Dunn added to party Anatoliy Slutskiy(pty:dft). (Dunn, James)
January 8, 2021 Opinion or Order Attorney John Brian Thomas Murray, Jr representing BHPH Consulting Services, LLC (Defendant) and Fouzailoff, Sean (Defendant) and Slutskiy, Anatoliy (Defendant); and BHPH Consulting Services, LLC (Counter Claimant); and BHPH Consulting Services, LLC (Counter Claimant); terminated per DE #81 (jbs)
January 5, 2021 Opinion or Order Filing 79 ORDER REFERRING CASE to Mediation. Signed by Judge Federico A. Moreno on 1/5/2021. See attached document for full details. (mmd)
January 5, 2021 Opinion or Order Filing 78 SCHEDULING ORDER: Jury Trial set for two-week period starting 8/2/2021 before Judge Federico A. Moreno. Calendar Call set for 7/27/2021 02:00 PM before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 1/5/2021. See attached document for full details. (mmd) #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.
December 24, 2020 Opinion or Order Filing 77 ORDER GRANTING MOTION FOR CLARIFICATION. Signed by Judge Federico A. Moreno on 12/24/2020. See attached document for full details. (mmd)
December 23, 2020 Opinion or Order Filing 76 NOTICE by Technolojoy, LLC (Aran, Fernando)
December 22, 2020 Opinion or Order Set/Reset Answer Due Deadline as per DE 75 : All Defendants. (lk)
December 22, 2020 Opinion or Order Filing 75 PAPERLESS ORDER requiring Defendants to file a response to the Complaint by no later than January 15, 2020. Signed by Judge Federico A. Moreno on 12/22/2020. (mmd)
December 1, 2020 Opinion or Order Filing 74 PAPERLESS ORDER granting #73 Motion to Reopen Case. Signed by Judge Federico A. Moreno on 12/1/2020. (mmd)
November 30, 2020 Opinion or Order Filing 73 MOTION to Reopen Case by Technolojoy, LLC. Attorney Fernando S. Aran added to party Technolojoy, LLC(pty:cd), Attorney Fernando S. Aran added to party Technolojoy, LLC(pty:cd). (Attachments: #1 Exhibit Proposed Order)(Aran, Fernando)
August 6, 2020 Opinion or Order Filing 72 Clerks Notice to Filer re #70 Report Regarding. Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#71]. It is not necessary to refile this document. (lk)
August 5, 2020 Opinion or Order Filing 71 JOINT STATUS REPORT by Technolojoy, LLC. See image at DE #70 (lk)
August 5, 2020 Opinion or Order Filing 70 REPORT REGARDING Joint Status by Technolojoy, LLC (Aran, Fernando)
July 22, 2020 Opinion or Order Filing 69 ORDER granting #67 #68 Motions to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Madilyn Maruna and Komlavi Atsou. Signed by Judge Federico A. Moreno on 7/22/2020. See attached document for full details. (mmd)
July 21, 2020 Opinion or Order Filing 68 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Madilyn M. Maruna. Filing Fee $ 200.00 Receipt # AFLSDC-13215725 by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 8/4/2020 (Attachments: #1 Exhibit Certification, #2 Exhibit Proposed Order)(Aran, Fernando)
July 21, 2020 Opinion or Order Filing 67 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Komlavi Atsou. Filing Fee $ 200.00 Receipt # AFLSDC-13215506 by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 8/4/2020 (Attachments: #1 Exhibit Certification, #2 Exhibit Proposed Order)(Aran, Fernando)
July 21, 2020 Opinion or Order Filing 66 NOTICE of Attorney Appearance by Fernando S. Aran on behalf of Ibrahim F. Algahim, Technolojoy, LLC. Attorney Fernando S. Aran added to party Ibrahim F. Algahim (pty:pla), Attorney Fernando S. Aran added to party Technolojoy, LLC(pty:pla). (Aran, Fernando)
July 9, 2020 Opinion or Order Filing 65 ORDER granting #64 Motion to Withdraw as Attorney. Veronica Mae Rabinowitz, Pedro Armando Perez-Roura , and Christian Enrique Rodriguez withdrawn from case. Deadline to obtain new counsel 8/5/2020. Signed by Judge Federico A. Moreno on 7/8/2020. See attached document for full details. (mmd) Modified text on 7/9/2020 (wc).
July 7, 2020 Opinion or Order Filing 64 MOTION to Withdraw as Attorney for Plaintiffs, Technolojoy LLC, and Ibrahim F. Algahim by Veronica M. Rabinowitz for / by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 7/21/2020 (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
May 7, 2020 Opinion or Order Filing 63 ORDER CLOSING CASE FOR STATISTICAL PURPOSES AND PLACING MATTER IN CIVIL SUSPENSE FILE. Closing Case. Signed by Judge Federico A. Moreno on 5/7/2020. See attached document for full details. (mmd)
May 7, 2020 Opinion or Order Deadline(s)/Hearing(s) terminated as per DE #63 . (lk)
May 4, 2020 Opinion or Order Filing 62 Joint MOTION for Reconsideration of Order Denying Motion to Continue Pre-Trial Deadlines and Mediation Deadline by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
April 30, 2020 Opinion or Order Filing 61 ORDER denying #60 Motion to Extend Pretrial Deadlines. Signed by Judge Federico A. Moreno on 4/30/2020. See attached document for full details. (mmd)
April 22, 2020 Opinion or Order Filing 60 Joint MOTION to Continue Pre-Trial Deadlines and Mediation Deadline by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 5/6/2020 (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
April 13, 2020 Opinion or Order Filing 59 ORDER SCHEDULING MEDIATION. Signed by Judge Federico A. Moreno on 4/13/2020. See attached document for full details. (mmd)
April 9, 2020 Opinion or Order Filing 58 NOTICE by Ibrahim F. Algahim Amended Notice of Mediation (Rabinowitz, Veronica)
March 27, 2020 Opinion or Order Filing 57 NOTICE by Ibrahim F. Algahim re #55 Notice (Other), #56 Notice (Other) of Withdrawal of Notices (Perez-Roura, Pedro)
March 27, 2020 Opinion or Order Filing 56 NOTICE by Ibrahim F. Algahim of Intent to Serve Subpoena (Perez-Roura, Pedro)
March 27, 2020 Opinion or Order Filing 55 NOTICE by Ibrahim F. Algahim of Intent to Serve Subpoena (Perez-Roura, Pedro)
March 24, 2020 Opinion or Order Filing 54 CLERK'S NOTICE - Attorney Admissions has not updated address and/or email information for attorney(s) Pedro A. Perez-Roura re #53 Notice of Change of Address. After filing a Notice of Change of Address, Attorney Pedro A. Perez-Roura is instructed to go to their PACER account, Manage My Account, to complete the process of updating their information. (cco)
March 24, 2020 Opinion or Order Filing 53 NOTICE of Change of Address by Pedro Armando Perez-Roura (Perez-Roura, Pedro)
March 19, 2020 Opinion or Order Filing 52 Clerks Notice to Filer re #50 Notice (Other). Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#51]. It is not necessary to refile this document. (lk)
March 18, 2020 Opinion or Order Filing 51 NOTICE of Mediator Selection and Hearing. Selected/Added Israel Reyes as Mediator. Mediation Hearing set for 5/19/20 at 10:00am. See image at DE #50 (lk)
March 18, 2020 Opinion or Order Filing 50 NOTICE by Ibrahim F. Algahim, Technolojoy, LLC re #20 Order Referring Case to Mediation (Rabinowitz, Veronica)
March 17, 2020 Opinion or Order Filing 49 CLERK'S NOTICE - Attorney Admissions has not updated address and/or email information for attorney John Brian Thomas Murray, Jr. re #48 Notice of Change of Address. Attorney John Brian Thomas Murray, Jr. is directed to update their information via the attorneys PACER account, Manage My Account. Pursuant to CM/ECF NextGen procedures, all updates to an attorneys contact information and primary email address must be made through the attorneys PACER account. (pt)
March 17, 2020 Opinion or Order Filing 48 NOTICE of Change of Address by John Brian Thomas Murray, Jr (Murray, John)
February 28, 2020 Opinion or Order Filing 47 ORDER OF CONTINUANCE and ORDER REVISING PRETRIAL DEADLINES: Calendar Call set for 12/15/2020 02:00 PM before Judge Federico A. Moreno. Jury Trial set for two-week period 12/21/2020 before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 2/27/2020. See attached document for full details. (mmd)
February 27, 2020 Opinion or Order Filing 46 RESPONSE in Opposition re #45 Plaintiff's MOTION to Continue Pre-Trial Deadlines AND JOINING IN PART TO PLAINTIFFS MOTION TO CONTINUE PRE-TRIAL DEADLINES filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 3/5/2020. (Murray, John)
February 25, 2020 Opinion or Order Filing 45 Plaintiff's MOTION to Continue Pre-Trial Deadlines by Ibrahim F. Algahim. Responses due by 3/10/2020 (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
February 14, 2020 Opinion or Order Filing 44 NOTICE of Attorney Appearance by Pedro Armando Perez-Roura on behalf of Ibrahim F. Algahim. Attorney Pedro Armando Perez-Roura added to party Ibrahim F. Algahim (pty:cd), Attorney Pedro Armando Perez-Roura added to party Ibrahim F. Algahim (pty:pla), Attorney Pedro Armando Perez-Roura added to party Ibrahim F. Algahim (pty:cd). (Perez-Roura, Pedro)
January 6, 2020 Opinion or Order Filing 43 Plaintiff's REPLY In Support of Plaintiff's Motion to Strike, or Alternatively, Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law by Ibrahim F. Algahim. (Rabinowitz, Veronica)
December 23, 2019 Opinion or Order Set/Reset Deadlines/Hearings as per DE 41 re: #34 Plaintiff's MOTION to Strike or Alternatively, To Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law. Replies due by 1/4/2020. (lk)
December 23, 2019 Opinion or Order Set/Reset Deadlines/Hearings as per DE 42 to #34 Plaintiff's MOTION to Strike or Alternatively, To Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law. Replies due by 1/6/2020. (lk)
December 23, 2019 Opinion or Order Filing 42 AMENDED PAPERLESS ORDER granting #40 Plaintiffs' Unopposed Motion for Extension of Time to File Reply to Defendant BHPH's Response in Opposition to Plaintiffs' Motion to Strike or Dismiss Counterclaim. Plaintiffs may file a reply brief by no later than January 6, 2020. Signed by Judge Federico A. Moreno on 12/23/2019. See attached document for full details. (mmd)
December 23, 2019 Opinion or Order Filing 41 PAPERLESS ORDER granting #40 Plaintiffs' Unopposed Motion for Extension of Time to File Reply to Defendant BHPH's Response in Opposition to Plaitniffs' Motion to Strike or Dismiss Counterclaim. Plaintiffs may file a reply brief by no later than January 4, 2020. Signed by Judge Federico A. Moreno on 12/23/2019. (mmd)
December 20, 2019 Opinion or Order Filing 40 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #36 Response in Opposition to Motion, by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
December 18, 2019 Opinion or Order Filing 39 Second Amended ANSWER and Affirmative Defenses to Complaint (Counts I, X, and XIII), COUNTERCLAIM against Ibrahim F. Algahim, Technolojoy, LLC by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit A)(Murray, John)
December 18, 2019 Opinion or Order Filing 38 ORDER granting #33 Motion for Leave to File. 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 Federico A. Moreno on 12/16/2019. See attached document for full details. (mmd)
December 17, 2019 Opinion or Order Filing 37 ORDER DENYING AS WITHDRAWN MOTION TO COMPEL ARBITRATION. Signed by Judge Federico A. Moreno on 12/16/2019. See attached document for full details. (mmd)
December 17, 2019 Opinion or Order Filing 36 RESPONSE in Opposition re #34 Plaintiff's MOTION to Strike or Alternatively, To Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law filed by BHPH Consulting Services, LLC. Replies due by 12/24/2019. (Murray, John)
December 11, 2019 Opinion or Order Filing 35 REPLY to Response to Motion re #15 Defendant's MOTION to Compel Arbitration filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Exhibit Affidavit of Sean Fouzailoff)(Murray, John)
December 11, 2019 Opinion or Order Filing 34 Plaintiff's MOTION to Strike or Alternatively, To Dismiss Defendant BHPH Consulting Services, LLC's Counterclaim and Incorporated Memorandum of Law by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 12/26/2019 (Rabinowitz, Veronica)
December 11, 2019 Opinion or Order Filing 33 Unopposed MOTION for Leave to File Second Amended Answer by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit Second Amended Answer, #2 Text of Proposed Order Proposed Order)(Murray, John)
December 11, 2019 Opinion or Order Filing 32 REPLY to Response to Motion re #13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Murray, John)
November 27, 2019 Opinion or Order Filing 31 RESPONSE in Opposition re #15 Defendant's MOTION to Compel Arbitration filed by Ibrahim F. Algahim, Technolojoy, LLC. Replies due by 12/4/2019. (Attachments: #1 Affidavit Exhibit A - Affidavit of Ibrahim F. Algahim in Support of Plaintiffs Response in Opposition to Defendants' Motion to Compel Arbitration, #2 Exhibit COMPOSITE EXHIBIT A to Affidavit, #3 Exhibit COMPOSITE EXHIBIT B to Affidavit)(Rabinowitz, Veronica)
November 27, 2019 Opinion or Order Filing 30 RESPONSE in Opposition re #13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM filed by Ibrahim F. Algahim, Technolojoy, LLC. Replies due by 12/4/2019. (Rabinowitz, Veronica)
November 27, 2019 Opinion or Order Filing 29 NOTICE of Mediator Selection. Added Israel Reyes. (Rabinowitz, Veronica)
November 27, 2019 Opinion or Order Filing 28 AMENDED ANSWER and Affirmative Defenses to Complaint (Counts I, X, and XIII), COUNTERCLAIM against Ibrahim F. Algahim, Technolojoy, LLC by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit Composite Exhibit A)(Murray, John)
November 26, 2019 Opinion or Order Filing 27 ORDER denying #25 Motion to Strike Defendants' First Affirmative Defense. Signed by Judge Federico A. Moreno on 11/26/2019. See attached document for full details. (mmc)
November 22, 2019 Opinion or Order Filing 26 NOTICE by Ibrahim F. Algahim, Technolojoy, LLC re #25 Plaintiff's MOTION to Strike Defendant's First Affirmative Defense and Incorporated Memorandum of Law (Rabinowitz, Veronica)
November 22, 2019 Opinion or Order Filing 25 Plaintiff's MOTION to Strike Defendant's First Affirmative Defense and Incorporated Memorandum of Law by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 12/6/2019 (Rabinowitz, Veronica)
November 21, 2019 Opinion or Order Filing 24 PAPERLESS ORDER granting #23 Defendants' Unopposed Motion for Extension of Time to File Replies in Support of Motion to Compel Arbitration and Motion to Dismiss. Defendants may file their reply briefs by no later than December 11, 2019. Signed by Judge Federico A. Moreno on 11/21/2019. (mmd)
November 19, 2019 Opinion or Order Filing 23 Defendant's MOTION for Extension of Time to File Response/Reply/Answer as to #13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM, #15 Defendant's MOTION to Compel Arbitration by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Text of Proposed Order Proposed Order)(Murray, John)
November 18, 2019 Opinion or Order Set/Reset Deadlines/Hearings as per DE 22 re: #13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM, #15 Defendant's MOTION to Compel Arbitration . Responses due by 11/27/2019 (lk)
November 18, 2019 Opinion or Order Filing 22 PAPERLESS ORDER granting #17 Plaintiffs' Unopposed Motion for Extension of Time to Respond to Defendants' Motion to Dismiss and Motion to Compel Arbitration. Plaintiffs may respond to the motions by no later than November 27, 2019. Signed by Judge Federico A. Moreno on 11/18/2019. (mmd)
November 15, 2019 Opinion or Order Filing 21 Clerks Notice of Docket Correction re #19 Scheduling Order,,. Document Restricted Due to Error; The correct document has been attached to this notice. (ra)
November 15, 2019 Opinion or Order Filing 20 ORDER REFERRING CASE to Mediation. Signed by Judge Federico A. Moreno on 11/14/2019. See attached document for full details. (mmd)
November 15, 2019 Opinion or Order Filing 19 SCHEDULING ORDER: Jury Trial set for two-week period starting 7/20/2020 before Judge Federico A. Moreno. Calendar Call set for 7/14/2020 02:00 PM before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 11/14/2019. See attached document for full details. (mmd) #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. Document Restricted Due to Error; The correct document has been attached to D.E #21 . Modified Text on 11/15/2019 (ra).
November 15, 2019 Opinion or Order Filing 18 ORDER denying #14 Defendants' Motion for Extension of Time to File Compulsory Counterclaim. Signed by Judge Federico A. Moreno on 11/14/2019. See attached document for full details. (mmd)
November 14, 2019 Opinion or Order Filing 17 Unopposed MOTION for Extension of Time to respond to Defendants' Motion to Dismiss and Motion to Compel Arbitration by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 11/29/2019 (Attachments: #1 Text of Proposed Order)(Rabinowitz, Veronica)
November 12, 2019 Opinion or Order Filing 16 NOTICE by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy of Filing Supplemental Rule 7.1(a)(3) Certificate to Motion to Compel Arbitration (DE 15) (Murray, John)
November 6, 2019 Opinion or Order Filing 15 Defendant's MOTION to Compel Arbitration by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 11/20/2019 (Attachments: #1 Exhibit Affidavit of Sean Fouzailoff)(Murray, John)
November 6, 2019 Opinion or Order Filing 14 Defendant's MOTION for Extension of Time To File Compulsory Counterclaim by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 11/20/2019 (Attachments: #1 Text of Proposed Order Proposed Order)(Murray, John)
November 6, 2019 Opinion or Order Filing 13 Defendant's MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM (AS TO COUNTS II THROUGH XII AND TO DISMISS ALL CLAIMS OF PLAINTIFF ALGAHIM by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 11/20/2019 (Murray, John)
November 6, 2019 Opinion or Order Filing 12 ANSWER and Affirmative Defenses to Complaint with Jury Demand to Counts I and XIII by BHPH Consulting Services, LLC. (Murray, John)
October 16, 2019 Opinion or Order Set/Reset Answer Due Deadline: All Defendants as per DE 11 . (lk)
October 15, 2019 Opinion or Order Filing 11 PAPERLESS ORDER granting #10 Defendants' Unopposed Motion for Extension of Time to File Response to Complaint. Defendants may file a response by no later than November 8, 2019. Signed by Judge Federico A. Moreno on 10/15/2019. (mmd)
October 14, 2019 Opinion or Order Filing 10 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Attorney John Brian Thomas Murray, Jr added to party BHPH Consulting Services, LLC(pty:dft), Attorney John Brian Thomas Murray, Jr added to party Sean Fouzailoff(pty:dft), Attorney John Brian Thomas Murray, Jr added to party Anatoliy Slutskiy(pty:dft). (Attachments: #1 Text of Proposed Order Proposed Order)(Murray, John)
September 30, 2019 Opinion or Order Filing 9 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Technolojoy, LLC, Ibrahim F. Algahim. Anatoliy Slutskiy served on 9/23/2019, answer due 10/15/2019. (Rabinowitz, Veronica)
September 30, 2019 Opinion or Order Filing 8 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Technolojoy, LLC, Ibrahim F. Algahim. BHPH Consulting Services, LLC served on 9/23/2019, answer due 10/15/2019. (Rabinowitz, Veronica)
September 19, 2019 Opinion or Order Filing 7 Summons Issued as to BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Summon(s), #2 Summon(s))(lk)
September 18, 2019 Opinion or Order Filing 6 NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
September 18, 2019 Opinion or Order Filing 5 NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
September 18, 2019 Opinion or Order Filing 4 NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
September 11, 2019 Opinion or Order Filing 3 Clerks Notice to Filer re: Electronic Case. Alias Not Added. The Filer failed to add the alias information for the party(ies). The correction was made. It is not necessary to re-file this document. (ar2)
September 10, 2019 Opinion or Order Filing 2 Clerks Notice of Judge Assignment to Judge Federico A. Moreno. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis 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. (ar2)
September 10, 2019 Opinion or Order Filing 1 COMPLAINT against All Defendants. Filing fees $ 400.00 receipt number 113C-11971814, filed by Technolojoy, LLC, Ibrahim Algahim. (Attachments: #1 Civil Cover Sheet, #2 Exhibit Exhibit A)(Rabinowitz, Veronica)

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Search for this case: Technolojoy, LLC et al v. BHPH Consulting Services, LLC et al
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Plaintiff: Technolojoy, LLC
Represented By: Veronica Mae Rabinowitz
Represented By: Christian Enrique Rodriguez
Represented By: Fernando S. Aran
Represented By: Komlavi Atsou
Represented By: Madilyn M. Maruna
Represented By: Nicholas Anhold
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Plaintiff: Ibrahim Algahim
Represented By: Veronica Mae Rabinowitz
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Plaintiff: Ibrahim F. Algahim
Represented By: Veronica Mae Rabinowitz
Represented By: Christian Enrique Rodriguez
Represented By: Fernando S. Aran
Represented By: Komlavi Atsou
Represented By: Madilyn M. Maruna
Represented By: Pedro Armando Perez-Roura
Represented By: Nicholas Anhold
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Counter claimant: Sean Fouzailoff
Represented By: John Brian Thomas Murray, Jr.
Represented By: James Richard Dunn
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Defendant: BHPH Consulting Services, LLC
Represented By: John Brian Thomas Murray, Jr.
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Defendant: Anatoliy Slutskiy
Represented By: John Brian Thomas Murray, Jr.
Represented By: James Richard Dunn
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Defendant: BHPH Consulting Services, LLC doing business as BHPH Capital Services
Represented By: John Brian Thomas Murray, Jr.
Represented By: James Richard Dunn
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