Technolojoy, LLC et al v. BHPH Consulting Services, LLC et al
| Technolojoy, LLC, Ibrahim Algahim and Ibrahim F. Algahim |
| BHPH Consulting Services, LLC, Anatoliy Slutskiy and BHPH Consulting Services, LLC doing business as BHPH Capital Services |
| Sean Fouzailoff |
| 1:2019cv23770 |
| September 10, 2019 |
| US District Court for the Southern District of Florida |
| Jonathan Goodman |
| Federico A Moreno |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity-Other Contract |
| Defendant |
Docket Report
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This docket was last retrieved on July 28, 2023. A more recent docket listing may be available from PACER.
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Filing 304
TRANSCRIPT NOTIFICATION - Transcript(s) ordered on: 04-18-23 by Fernando S. Aran, Esq. has/have been filed by Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov re #289 Notice of Appeal,, #292 Court Reporter Acknowledgment, 287 Notice of Appeal,, #291 Transcript Information Form. (Pastor-Hernandez, Gilda)
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Filing 303
TRANSCRIPT of Jury Trial Proceedings held on 02-16-23 before Judge Federico A. Moreno, 1-35 pages, re: #289 Notice of Appeal,, 287 Notice of Appeal,, Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. USCA Case Number: 23-10874-D. 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 8/18/2023. Redacted Transcript Deadline set for 8/28/2023. Release of Transcript Restriction set for 10/26/2023. (Pastor-Hernandez, Gilda)
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Filing 302
TRANSCRIPT of Jury Trial Proceedings held on 02-15-23 before Judge Federico A. Moreno, 1-155 pages, re: #289 Notice of Appeal,, 287 Notice of Appeal,, Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. USCA Case Number: 23-10874-D. 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 8/18/2023. Redacted Transcript Deadline set for 8/28/2023. Release of Transcript Restriction set for 10/26/2023. (Pastor-Hernandez, Gilda)
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Filing 301
TRANSCRIPT of Jury Trial Proceedings held on 02-14-23 before Judge Federico A. Moreno, 1-171 pages, re: #289 Notice of Appeal,, 287 Notice of Appeal,, Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. USCA Case Number: 23-10874-D. 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 8/18/2023. Redacted Transcript Deadline set for 8/28/2023. Release of Transcript Restriction set for 10/26/2023. (Pastor-Hernandez, Gilda)
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Filing 300
TRANSCRIPT of Jury Trial Proceedings held on 02-13-23 before Judge Federico A. Moreno, 1-85 pages, re: #289 Notice of Appeal,, 287 Notice of Appeal,, Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. USCA Case Number: 23-10874-D. 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 8/18/2023. Redacted Transcript Deadline set for 8/28/2023. Release of Transcript Restriction set for 10/26/2023. (Pastor-Hernandez, Gilda)
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Filing 299
NOTICE of Change of Address, Email or Law Firm Name by Matthew Ty Person (Person, Matthew)
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Filing 298
REPLY by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Person, Matthew)
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Filing 297
RESPONSE in Opposition re #296 MOTION to Withdraw as Attorney by Matt Person for / filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 7/6/2023. (amb)
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Filing 296
MOTION to Withdraw as Attorney by Matt Person for / by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 7/3/2023 (Attachments: #1 Text of Proposed Order Order Granting Motion to Withdraw)(Person, Matthew)
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Filing 295
Second AMENDED COMPLAINT against BHPH Consulting Services, LLC, filed by Technolojoy, LLC. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit)(Aran, Fernando)
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Filing 294
NOTICE by Technolojoy, LLC (Attachments: #1 Exhibit Opinion (re Second Amended Complaint)) (Aran, Fernando)
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Filing 293
RESPONSE to Motion re #269 MOTION for Reconsideration of Final Judgment filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 5/15/2023. (Person, Matthew)
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Filing 292
COURT REPORTER ACKNOWLEDGMENT re #289 Notice of Appeal,, #291 Transcript Information Form. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. Estimated filing date of transcript 05-17-23. USCA number 23-10874-D. (Pastor-Hernandez, Gilda)
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Filing 291
TRANSCRIPT INFORMATION FORM by Technolojoy, LLC re 287 Notice of Appeal,,. trial transcript(s) ordered. Order placed by Fernando S. Aran. Email sent to Court Reporter Coordinator. (Aran, Fernando)
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Filing 290
Acknowledgment of Receipt of NOA from USCA re 287 Notice of Appeal, filed by Technolojoy, LLC. Date received by USCA: 03/20/2023. USCA Case Number: 23-10874-D. (jes)
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Filing 289
Notice of Compliance of Filing Fee by Technolojoy, LLC. Filing fee $ 505.00 receipt number AFLSDC-16443190. Within fourteen days of the filing date of a Notice of Appeal, the appellant must complete the Eleventh Circuit Transcript Order Form regardless of whether transcripts are being ordered [Pursuant to FRAP 10(b)]. For information go to our FLSD website under All Forms and look for Transcript Order Form #www.flsd.uscourts.gov/forms/all-forms. (Aran, Fernando) Modified text on 3/20/2023 (apz).
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Transmission of Notice of Appeal, Orders/Judgment under appeal, and Docket Sheet to US Court of Appeals re 287 Notice of Appeal, Notice has been electronically mailed. (apz)
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Filing 288
Clerk's Notice to Filer re #286 Notice (Other). Notice of Appeal Requires a Fee; CORRECTIVE ACTION REQUIRED Appellate Filing Fee Not Paid. The Filer must file a Notice of Compliance of Filing Fee-Notice of Appeal and electronically pay the correct fee of $505.00 wi 24 hrs of this notice.Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see DE 387 . It is not necessary to refile this document. (apz)
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Filing 287
Notice of Appeal re #285 Order on Motion to Amend/Correct, #264 Judgment, #283 Order on Motion to Amend/Correct, #284 Order on Motion for Reconsideration by Technolojoy, LLC. Receipt#: FILING FEE: (NOT PAID). Within fourteen days of the filing date of a Notice of Appeal, the appellant must complete the Eleventh Circuit Transcript Order Form regardless of whether transcripts are being ordered [Pursuant to FRAP 10(b)]. For information go to our FLSD website under All Forms and look for Transcript Order Form #www.flsd.uscourts.gov/forms/all-forms. (SEE DE #286 FOR IMAGE.) (apz)
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Filing 286
NOTICE by Technolojoy, LLC re DE #264 Final Judgment, DE #283 Order, DE #284 Order, and DE #285 Order (Attachments: #1 Exhibit Final Judgment, #2 Exhibit Order Denying Motion to Amend Pleadings, #3 Exhibit Order Denying Motion for Reconsideration of Final Judgment, #4 Exhibit Order Denying Motion Pursuant to Federal Rule of Civil Procedure 60(A)) (Aran, Fernando) (linked docket entry) Modified text on 3/17/2023 (apz).
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Filing 285
ORDER denying #267 Motion Pursuant to Federal Rule of Civil Procedure 60(a). Signed by Judge Federico A. Moreno on 3/8/2023. See attached document for full details. (mmd)
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Filing 284
ORDER denying #269 Motion for Reconsideration. Signed by Judge Federico A. Moreno on 3/6/2023. See attached document for full details. (mmd)
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Filing 283
ORDER denying #268 Motion to Amend Pleadings. Signed by Judge Federico A. Moreno on 2/28/2023. See attached document for full details. (mmd) Text Modified on 3/6/2023 (amb).
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Filing 282
RELEASE OF EXHIBITS: Plaintiff Exhibits 199-202 released to Denis de Silva, Ogletree Deakins (pc)
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Filing 281
CLERK'S Notice of Release of Exhibit(s) provided to Defendant Re D.E. #206 Exhibits,,,,,, Released to Attorney(s)/Party(s) Defendant. (rrs)
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Filing 280
RESPONSE to Motion re #269 MOTION for Reconsideration of Final Judgment filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 3/8/2023. (Attachments: #1 Exhibit Final Judgment)(Person, Matthew)
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Filing 279
RESPONSE to Motion re #268 MOTION to Amend/Correct the pleadings under Civ.R. 15(b)(2) filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 3/8/2023. (Person, Matthew)
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Filing 278
RESPONSE to Motion re #267 MOTION to Amend/Correct Final Judgment filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 3/8/2023. (Person, Matthew)
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Filing 277
ORDER granting #270 Motion to Withdraw as Attorney. James Richard Dunn withdrawn from case. Signed by Judge Federico A. Moreno on 2/28/2023. See attached document for full details. (mmd)
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Filing 276
CLERK'S Second Notice Directing Counsel to Retrieve Exhibit(s) sent to Defendant Re D.E. #206 Exhibits,,,,,, Attorney(s)/Party(s) Defendant shall retrieve original exhibits within five days. For retrieval information, please contact the Clerks Office - Records Section of the Wilkie D. Ferguson, Jr., U.S. Courthouse, 400 North Miami Avenue, Miami, FL 33128, (305) 523-5210. (rrs)
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Filing 275
CLERK'S Second Notice Directing Counsel to Retrieve Exhibit(s) sent to Plaintiff Re D.E. #202 Exhibit List,,,,,, Attorney(s)/Party(s) Plaintiff shall retrieve original exhibits within five days. For retrieval information, please contact the Clerks Office - Records Section of the Wilkie D. Ferguson, Jr., U.S. Courthouse, 400 North Miami Avenue, Miami, FL 33128, (305) 523-5210. (rrs)
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Filing 274
NOTICE/STIPULATION of Substitution of Counsel by Matthew Ty Person on behalf of BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy instead of prior counsel of record James R. Dunn. (Attachments: #1 Text of Proposed Order Proposed Order) (Person, Matthew)
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Filing 273
RESPONSE to Motion re #267 MOTION to Amend/Correct Final Judgment filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 3/6/2023. (Person, Matthew)
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Filing 272
NOTICE/STIPULATION of Substitution of Counsel by Matthew Ty Person on behalf of BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy instead of prior counsel of record James Dunn. . Attorney Matthew Ty Person added to party BHPH Consulting Services, LLC(pty:dft), Attorney Matthew Ty Person added to party Sean Fouzailoff(pty:dft), Attorney Matthew Ty Person added to party Anatoliy Slutskiy(pty:dft). (Person, Matthew)
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Filing 271
MOTION to Withdraw as Attorney Consent signed by clients by James "Jim" R. Dunn for /, MOTION to Withdraw Document #270 MOTION to Withdraw as Attorney by James "Jim" R. Dunn for / by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 3/9/2023 (Dunn, James)
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Filing 270
MOTION to Withdraw as Attorney by James "Jim" R. Dunn for / by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Responses due by 3/9/2023 (Dunn, James)
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Filing 269
MOTION for Reconsideration of Final Judgment by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
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Filing 268
MOTION to Amend/Correct the pleadings under Civ.R. 15(b)(2) by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 3/8/2023 (Aran, Fernando)
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Filing 267
MOTION to Amend/Correct Final Judgment by Ibrahim F. Algahim, Technolojoy, LLC. Responses due by 3/8/2023 (Aran, Fernando)
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Filing 266
CLERK'S Notice Directing Counsel to Retrieve Exhibit(s) sent to Plaintiff Re D.E. #202 Exhibit List,,,,,, #199 Exhibit List,,,,,,,,,, #200 Exhibit List,,,,,,,,,, #201 Exhibit List,,,,,,,,,, Attorney(s)/Party(s) Plaintiff shall retrieve original exhibits within five days. For retrieval information, please contact the Clerks Office - Records Section of the Wilkie D. Ferguson, Jr., U.S. Courthouse, 400 North Miami Avenue, Miami, FL 33128, (305) 523-5210. (rrs)
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Filing 265
CLERK'S Notice Directing Counsel to Retrieve Exhibit(s) sent to Defendant Re D.E. #206 Exhibits,,,,,, Attorney(s)/Party(s) Defendant shall retrieve original exhibits within five days. For retrieval information, please contact the Clerks Office - Records Section of the Wilkie D. Ferguson, Jr., U.S. Courthouse, 400 North Miami Avenue, Miami, FL 33128, (305) 523-5210. (rrs)
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Filing 264
FINAL JUDGMENT. Signed by Judge Federico A. Moreno on 2/16/2023. See attached document for full details. (mmd)
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Filing 263
Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial completed on 2/16/2023. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (sc)
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Filing 262
JURY VERDICT. (sc)
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Filing 261
Jury Notes. (sc)
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Filing 260
Jury Instructions. (sc)
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Filing 259
Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial held on 2/15/2023. Day 3.. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (sc)
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Filing 258
FINAL ORDER OF DISMISSAL as to Plaintiff Ibrahim Algahim's Claims. Signed by Judge Federico A. Moreno on 2/15/2023. See attached document for full details. (mmd)
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Filing 257
ORDER denying as moot #252 Motion for Protective Order. Signed by Judge Federico A. Moreno on 2/15/2023. See attached document for full details. (mmd)
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Filing 256
Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial held on 2/14/2023. Day 2.. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (sc)
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Filing 254
NOTICE of Attorney Appearance by Marissel Descalzo on behalf of Jorge Robert Raynaud (Descalzo, Marissel)
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Filing 253
Clerk's Notice of Filing Deficiency Re: #252 MOTION for Protective Order filed by Jorge Robert Raynaud. Document(s) were filed conventionally that should have been filed electronically (CM/ECF Administrative Procedures). (drz)
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Filing 255
Minute Entry for proceedings held before Judge Federico A. Moreno: Jury Trial begun on 2/13/2023. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (sc)
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Filing 252
Non-Party Witness Jorge Robert Raynaud's MOTION for Protective Order by Jorge Robert Raynaud. Attorney Marissel Descalzo added to party Jorge Robert Raynaud(pty:ip). (drz)
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Filing 251
CERTIFICATE OF SERVICE by BHPH Consulting Services, LLC re Set/Reset Trial Management Order Deadlines, Set/Reset Motion/R&R Deadlines and Hearings, Set/Reset Hearings Raunaud Subpoena reflecting start of trial at 1400 2/13/23 (Dunn, James)
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Filing 250
TRIAL EXHIBITS 6 by BHPH Consulting Services, LLC. Related document: #206 Exhibits,,,,,, filed by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit AMENDED EXHIBIT 6, Google Sheets document featuring notes and communicaitons between reps of BHPH and Technolojoy, including columns on the right that were cut off in prior uploaded version)(Dunn, James)
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Filing 249
PAPERLESS ORDER denying #248 Motion for Sanctions as untimely since Plaintiffs could have filed the motion as early as February 3rd, 2023. In any event the receipts seem to assist the Plaintiffs at trial, thus there is no prejudice to Plaintiffs. Plaintiffs can make arguments at trial based on the exhibits that were on the previously submitted exhibit list, as well as the new documentation received from the Defendants on February 2, 2023. Trial will begin with jury selection on Monday February 13, 2023 at 2 pm. Signed by Judge Federico A. Moreno on 2/10/2023. (mmd)
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Filing 248
Plaintiff's MOTION for Sanctions or Alternatively to Show Cause by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Aran, Fernando)
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Filing 247
TRIAL EXHIBITS and Plaintiffs' Notice of Filing Additional Trial Exhibits Numbers 119, 120, 121, 123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 134, 135, 136, 137, 138 by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Exhibit 119, #2 Exhibit 120, #3 Exhibit 121, #4 Exhibit 122, #5 Exhibit 123, #6 Exhibit 124, #7 Exhibit 125, #8 Exhibit 126, #9 Exhibit 127, #10 Exhibit 128, #11 Exhibit 129, #12 Exhibit 130, #13 Exhibit 131, #14 Exhibit 132, #15 Exhibit 133, #16 Exhibit 134, #17 Exhibit 135, #18 Exhibit 136, #19 Exhibit 137, #20 Exhibit 138)(Aran, Fernando)
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Filing 246
PAPERLESS ORDER granting #234 Motion to Bring Electronic Equipment into the courtroom. Signed by Judge Federico A. Moreno on 2/6/2023. (mmd)
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Filing 245
PAPERLESS ORDER denying as moot #226 Motion to Exclude Expert. The Court cancels the hearing set for February 7, 2023 at 2:30 pm. The Court will commence jury selection on Monday February 13, 2023 at 2:00 PM. Signed by Judge Federico A. Moreno on 2/6/2023. (mmd)
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Jury Trial set for 2/13/2023 at 02:00 PM before Judge Federico A. Moreno.) (mmd)
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Filing 244
CERTIFICATE OF SERVICE by BHPH Consulting Services, LLC a subpoena of J. Raynaud, and copy of the Order setting trial for the February 13, 2023, Trial. (Attachments: #1 Exhibit Return of Service J. Raynaud for 2/13/23)(Dunn, James)
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Filing 243
NOTICE by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy re #239 Order Setting Hearing on Motion,, Trial Management Order, Withdrawal of Defendants' Expert, L. Baum, CPA (Dunn, James)
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Filing 242
TRIAL EXHIBITS 27 by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Exhibit Supplemental Report by L. Baum CPA, Exhibit 27)(Dunn, James)
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Filing 241
NOTICE by Technolojoy, LLC of Service of Subpoena To Appear and Testify at a Hearing or Trial in a Civil Action (Attachments: #1 Exhibit A) (Aran, Fernando)
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Filing 240
Exhibit List In Advance of February 7, 2023 Hearing on Plaintiff's Motion to Exclude Expert by Technolojoy, LLC.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16)(Aran, Fernando)
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Filing 239
ORDER Setting Hearing on Motion to Exclude Expert #226 . Evidentiary Hearing set for 2/7/2023 02:30 PM before Judge Federico A. Moreno. ORDER SETTING TRIAL: Jury Trial set for 2/13/2023 09:00 AM in Miami Division before Judge Federico A. Moreno. Signed by Judge Federico A. Moreno on 1/25/2023. See attached document for full details. (mmd)
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Filing 237
TRIAL EXHIBITS 27 by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Related document: #206 Exhibits,,,,,, filed by BHPH Consulting Services, LLC. (Attachments: #1 Exhibit Baum Report, #2 Exhibit Baum Report)(Dunn, James)
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Filing 238
Minute Entry for proceedings held before Judge Federico A. Moreno: Calendar Call held on 1/24/2023. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (sc)
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Filing 236
CERTIFICATE OF SERVICE by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy Return of Service of Subpoena to J. Raynaud for 1/24/23, at 1400, and, 1/30/23 at 0900. (Dunn, James)
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Filing 235
TRIAL EXHIBITS Corrected 102-1 by Technolojoy, LLC. Related document: #202 Exhibit List,,,,,, filed by Technolojoy, LLC. (Attachments: #1 Exhibit 102-1)(Aran, Fernando)
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Filing 234
MOTION to Bring Electronic Equipment into the courtroom by Technolojoy, LLC. Responses due by 1/25/2023 (Aran, Fernando)
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Filing 233
RESPONSE in Support re #226 MOTION to Exclude Expert filed by Technolojoy, LLC. (Attachments: #1 Exhibit Fouzailoff Depo Excerpts)(Aran, Fernando)
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Set/Reset Deadlines/Hearings per DE 232 re #226 MOTION to Exclude Expert . Replies due by 1/4/2023. (amb)
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Filing 232
PAPERLESS ORDER granting #231 Motion for Extension of Time to File Reply in Support of Motion to Exclude Expert. Plaintiff may file a reply brief by no later than January 4, 2023. Signed by Judge Federico A. Moreno on 12/22/2023. (mmd)
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Filing 231
Plaintiff's MOTION for Extension of Time to File Response/Reply/Answer by Technolojoy, LLC. (Aran, Fernando)
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Filing 230
HEARING EXHIBITS Exhibit to Response in Opposition to Motion to Strike Expert, Deposition Transcript of L. Baum, C.P.A., by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Related document: #229 Response in Opposition to Motion filed by Sean Fouzailoff, Anatoliy Slutskiy, BHPH Consulting Services, LLC, #226 MOTION to Exclude Expert filed by Technolojoy, LLC. (Attachments: #1 Deposition Complete Transcript of Deposition of L. Baum, C.P.A)(Dunn, James)
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Filing 229
RESPONSE in Opposition re #226 MOTION to Exclude Expert filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. Replies due by 12/21/2022. (Dunn, James)
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Filing 228
PAPERLESS ORDER granting #227 Motion for Extension of Time for Defendants to Respond to Motion to Strike Expert to December 15, 2022. Defendant may file a response by December 15, 2022. Signed by Judge Federico A. Moreno on 12/6/2022. (mmd)
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Set/Reset Deadlines/Hearings per DE 228 re #226 MOTION to Exclude Expert . Responses due by 12/15/2022. (amb)
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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)
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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)
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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)
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Filing 224
NOTICE OF UNAVAILABILITY by BHPH Consulting Services, LLC, Anatoliy Slutskiy for dates of Dec 5-Jan 5 (Dunn, James)
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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)
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Filing 222
MOTION to Withdraw as Attorney by Technolojoy, LLC. Responses due by 11/28/2022 (Aran, Fernando)
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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)
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Filing 220
NOTICE of Change of Address, Email or Law Firm Name by Fernando S. Aran (Aran, Fernando)
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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)
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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)
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Filing 217
Witness List Identifying L. Baum, CPA, as Def Expert by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
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Filing 216
CERTIFICATE OF SERVICE by BHPH Consulting Services, LLC of Expert Report by L. Baum CPA (Dunn, James)
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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)
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Filing 214
NOTICE OF UNAVAILABILITY by Technolojoy, LLC (Aran, Fernando)
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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)
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Filing 212
Plaintiff's RESPONSE to Defendants' Objections to Plaintiff's Trial Exhibits by Technolojoy, LLC. (Aran, Fernando)
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Filing 211
Plaintiff's Objections to Defendant's Trial Exhibits by Technolojoy, LLC. (Aran, Fernando)
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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)
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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)
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Filing 208
Objections to Pltf Exhibits to #202 Exhibit List,,,,,, #201 Exhibit List,,,,,,,,,, by BHPH Consulting Services, LLC. (Dunn, James)
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Filing 207
Proposed Jury Instructions by BHPH Consulting Services, LLC. (Dunn, James)
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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)
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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)
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Filing 204
NOTICE by Technolojoy, LLC of Withdrawing Expert Nathaniel Turner (Aran, Fernando)
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Filing 203
Proposed Jury Instructions by Technolojoy, LLC. (Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 195
STIPULATION Joint Proposed Stipulations by Technolojoy, LLC (Aran, Fernando)
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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)
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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)
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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)
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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)
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Filing 190
PRETRIAL STIPULATION Plaintiffs' Unilateral Proposed Pretrial Stipulations by Technolojoy, LLC (Aran, Fernando)
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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)
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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)
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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)
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Filing 186
NOTICE by Technolojoy, LLC Plaintiffs' Notice of Uploading Supplemental Exhibits onto Court's Docket (Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 176
MOTION for Leave to File Withdraw as Counsel for Plaintiffs by Technolojoy, LLC. (Aran, Fernando)
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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)
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Filing 174
Witness List Amended adding EMS Custodian of Records by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
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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)
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Filing 172
Witness List by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy.. (Dunn, James)
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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)
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Filing 170
Witness List by Technolojoy, LLC.. (Aran, Fernando)
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Filing 169
Exhibit List by Technolojoy, LLC.. (Aran, Fernando)
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Filing 168
NOTICE of Change of Address, Email or Law Firm Name by Fernando S. Aran (Aran, Fernando)
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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)
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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)
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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)
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Filing 164
RESPONSE in Support re #148 MOTION in Limine filed by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 157
REPLY to #149 Response in Opposition to Motion,,,, by BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Dunn, James)
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Filing 156
Statement of: Reply Statement of Material Facts by Ibrahim F. Algahim, Technolojoy, LLC re #155 Reply to Response to Motion (Aran, Fernando)
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Filing 155
REPLY to Response to Motion re #138 Plaintiff's MOTION for Summary Judgment filed by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
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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)
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Filing 153
Statement of: Material Facts by Ibrahim F. Algahim, Technolojoy, LLC re #138 Plaintiff's MOTION for Summary Judgment (Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 140
Joint MOTION for Extension of Time to File Response/Reply/Answer by Technolojoy, LLC. (Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 118
NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Sean Fouzailoff)(Aran, Fernando)
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Filing 117
NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Anatoliy Slutskiy)(Aran, Fernando)
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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)
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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)
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Filing 114
NOTICE of Filing Discovery: Deposition Transcript by Ibrahim F. Algahim, Technolojoy, LLC. (Attachments: #1 Deposition Deposition of Ibrahim Algahim)(Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Set/Reset Hearings. See #99 ORDER OF CONTINUANCE. Calendar Call set for 10/19/2021 02:00 PM before Judge Federico A. Moreno. (sk)
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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)
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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)
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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)
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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)
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Filing 103
CLAIM Counterclaim by Ibrahim F. Algahim, Technolojoy, LLC. (Aran, Fernando)
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Filing 102
MEDIATION REPORT by Israel U. Reyes. Disposition: Adjourned.(Reyes, Israel)
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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)
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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)
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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).
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Filing 98
Joint MOTION for Extension of Time of Discovery Cutoff Deadline and Amend Scheduling Order [DE 78] by Technolojoy, LLC. (Aran, Fernando)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 90
Entry docketed in error. (lk) Modified text and restricted imeage on 1/19/2021 (lk).
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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)
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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)
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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).
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Filing 84
MOTION to Strike by Technolojoy, LLC. Responses due by 1/28/2021 (Aran, Fernando)
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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)
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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).
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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)
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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)
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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)
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Filing 79
ORDER REFERRING CASE to Mediation. Signed by Judge Federico A. Moreno on 1/5/2021. See attached document for full details. (mmd)
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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.
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Filing 77
ORDER GRANTING MOTION FOR CLARIFICATION. Signed by Judge Federico A. Moreno on 12/24/2020. See attached document for full details. (mmd)
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Filing 76
NOTICE by Technolojoy, LLC (Aran, Fernando)
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Set/Reset Answer Due Deadline as per DE 75 : All Defendants. (lk)
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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)
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Filing 74
PAPERLESS ORDER granting #73 Motion to Reopen Case. Signed by Judge Federico A. Moreno on 12/1/2020. (mmd)
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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)
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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)
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Filing 71
JOINT STATUS REPORT by Technolojoy, LLC. See image at DE #70 (lk)
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Filing 70
REPORT REGARDING Joint Status by Technolojoy, LLC (Aran, Fernando)
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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)
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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)
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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)
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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)
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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).
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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)
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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)
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Deadline(s)/Hearing(s) terminated as per DE #63 . (lk)
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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)
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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)
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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)
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Filing 59
ORDER SCHEDULING MEDIATION. Signed by Judge Federico A. Moreno on 4/13/2020. See attached document for full details. (mmd)
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Filing 58
NOTICE by Ibrahim F. Algahim Amended Notice of Mediation (Rabinowitz, Veronica)
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Filing 57
NOTICE by Ibrahim F. Algahim re #55 Notice (Other), #56 Notice (Other) of Withdrawal of Notices (Perez-Roura, Pedro)
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Filing 56
NOTICE by Ibrahim F. Algahim of Intent to Serve Subpoena (Perez-Roura, Pedro)
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Filing 55
NOTICE by Ibrahim F. Algahim of Intent to Serve Subpoena (Perez-Roura, Pedro)
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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)
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Filing 53
NOTICE of Change of Address by Pedro Armando Perez-Roura (Perez-Roura, Pedro)
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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)
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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)
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Filing 50
NOTICE by Ibrahim F. Algahim, Technolojoy, LLC re #20 Order Referring Case to Mediation (Rabinowitz, Veronica)
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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)
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Filing 48
NOTICE of Change of Address by John Brian Thomas Murray, Jr (Murray, John)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 29
NOTICE of Mediator Selection. Added Israel Reyes. (Rabinowitz, Veronica)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 20
ORDER REFERRING CASE to Mediation. Signed by Judge Federico A. Moreno on 11/14/2019. See attached document for full details. (mmd)
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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).
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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)
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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)
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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)
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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)
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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)
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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)
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Filing 12
ANSWER and Affirmative Defenses to Complaint with Jury Demand to Counts I and XIII by BHPH Consulting Services, LLC. (Murray, John)
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Set/Reset Answer Due Deadline: All Defendants as per DE 11 . (lk)
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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)
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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)
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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)
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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)
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Filing 7
Summons Issued as to BHPH Consulting Services, LLC, Sean Fouzailoff, Anatoliy Slutskiy. (Attachments: #1 Summon(s), #2 Summon(s))(lk)
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Filing 6
NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
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Filing 5
NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
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Filing 4
NOTICE of Filing Proposed Summons(es) by Technolojoy, LLC (Rabinowitz, Veronica)
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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)
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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)
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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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