Stone Technology (HK) Co., Ltd. v. Global Geeks, Inc.
Plaintiff: Stone Technology (HK) Co., Ltd.
Defendant: Global Geeks, Inc.
Case Number: 1:2020cv23251
Filed: August 5, 2020
Court: US District Court for the Southern District of Florida
Presiding Judge: Beth Bloom
Referring Judge: Lauren Fleischer Louis
Nature of Suit: Contract: Recovery/Enforcement
Cause of Action: 28 U.S.C. § 1330 Breach of Contract
Jury Demanded By: Defendant
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Docket Report

This docket was last retrieved on September 29, 2021. A more recent docket listing may be available from PACER.

Date Filed Document Text
September 29, 2021 Opinion or Order Filing 190 ORDER OF DISMISSAL WITH PREJUDICE. The Notice, ECF No. #188 is APPROVED and ADOPTED; The above-styled case is DISMISSED WITH PREJUDICE; Each party shall bear its own attorneys fees and costs; To the extent not otherwise disposed of, all pending motions are denied as MOOT and all deadlines are TERMINATED; The Clerk of Court is directed to CLOSE this case. Motions terminated: #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #77 Defendant's MOTION for Summary Judgment filed by Global Geeks, Inc., #184 REPORT AND RECOMMENDATIONS re #77 Defendant's MOTION for Summary Judgment filed by Global Geeks, Inc., #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., [8. Signed by Judge Beth Bloom on 9/29/2021. See attached document for full details. (amb)
September 29, 2021 Filing 189 NOTICE of Settlement by Stone Technology (HK) Co., Ltd.(an HK COMPANY) (Liu, Jianyin)
September 29, 2021 Filing 188 NOTICE of Voluntary Dismissal of Stone's Second Amended Complaint and GlobalGeeks' Counterclaim by Stone Technology (HK) Co., Ltd.(an HK COMPANY) (Liu, Jianyin)
September 28, 2021 Opinion or Order Filing 187 ORDER AMENDING SCHEDULING ORDER AND CERTAIN PRETRIAL DEADLINES: Pretrial Stipulation due by 12/6/2021. Trial set for 12/20/2021 at 9:00 AM in Miami Division before Judge Beth Bloom. Calendar Call set for 12/14/2021 at 1:45 PM in Miami Division before Judge Beth Bloom. Signed by Judge Beth Bloom on 9/27/2021. See attached document for full details. (ail)
September 20, 2021 Filing 186 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Lauren Fleischer Louis: Motion Hearing held on 9/20/2021 re #173 Expedited Motion to Disqualify. Motion is denied. Written order to follow. Total time in court: 32 minutes. Attorney Appearance(s): Jianyin Liu, Benjamin J. Eichel, Glen Matthew Lindsay. (Digital 09:25:52) (aw)
September 20, 2021 Opinion or Order Filing 185 ORDER denying #173 Expedited Motion to Disqualify James Liu, Esq. as Trial Counsel. Signed by Magistrate Judge Lauren Fleischer Louis on 9/20/2021. See attached document for full details. (pdy)
September 20, 2021 Filing 184 REPORT AND RECOMMENDATIONS re #77 Defendant's MOTION for Summary Judgment filed by Global Geeks, Inc., #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd. Objections to R&R due by 10/4/2021. Signed by Magistrate Judge Lauren Fleischer Louis on 9/20/2021. See attached document for full details. (pdy)
September 17, 2021 Filing 183 REPLY to Response to Motion re #173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case filed by Global Geeks, Inc.. (Lindsay, Glen)
September 14, 2021 Filing 182 RESPONSE in Opposition re #173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 9/21/2021. (Attachments: #1 Exhibit Email Communication Between Benjamin Eichel and Jianyin Liu, #2 Exhibit Email with Joint Witness List sent by Stone to GG, #3 Exhibit GGs Email to Stone on Aug. 23, 2021)(Liu, Jianyin)
September 3, 2021 Filing 181 NOTICE by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #133 Scheduling Order,, of Filing Objections and Counter-Designation to GlobalGeeks' Deposition Designations (Liu, Jianyin)
September 3, 2021 Opinion or Order Filing 180 PAPERLESS ORDER granting #178 Defendant's Unopposed Motion for Counsel to Appear Telephonically at the October 5, 2021 Calendar Call. GlobalGeek's lead counsel may appear telephonically at calendar call on October 5, 2021. To participate in the calendar call, counsel shall, by landline telephone, call 1-877-336-1829, using access code 4742152 and security code 5680. Signed by Judge Beth Bloom (ks01)
September 3, 2021 Filing 179 NOTICE by Global Geeks, Inc. re #149 Statement of Objections and Counter-Designations of Depositions for Trial (Lindsay, Glen)
September 3, 2021 Filing 178 Defendant's MOTION Telephonic Appearance at Calendar Call re #142 Order,, Set/Reset Deadlines/Hearings, by Global Geeks, Inc.. (Attachments: #1 Text of Proposed Order)(Lindsay, Glen)
September 2, 2021 Opinion or Order Filing 177 PAPERLESS ORDER. THIS MATTER is before the Court upon Defendant Global Geek's Motion to Disqualify James Liu, Esq. as Trial Counsel #173 . Plaintiff Stone Technology (HK) Co. Ltd. responded by filing an Expedited Motion to Strike #175 . Defendant has responded in opposition #176 . A hearing is set on Defendant's Motion to Disqualify on 9/20/2021 at 9:30 AM in the Miami Division before Magistrate Judge Lauren Fleischer Louis. Plaintiff's Expedited Motion to Strike is DENIED. Plaintiff shall respond to the Motion to Disqualify by no later than 9/14/2021. Signed by Magistrate Judge Lauren Fleischer Louis on 9/2/2021. (pdy)
September 2, 2021 Filing 176 RESPONSE in Opposition re #175 EXPEDITED MOTION Strike GlobalGeeks' Motion to Disqualify (DE 173) re #173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case filed by Global Geeks, Inc.. Replies due by 9/9/2021. (Attachments: #1 Exhibit Exh A - Emails, #2 Exhibit Exh B - Emails)(Lindsay, Glen)
September 1, 2021 Filing 175 EXPEDITED MOTION Strike GlobalGeeks' Motion to Disqualify (DE 173) re #173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A - Email Stipulation of Testimony)(Liu, Jianyin)
September 1, 2021 Opinion or Order Filing 174 ORDER REFERRING MOTION TO MAGISTRATE JUDGE FOR FINAL DISPOSITION. ORDER REFERRING #173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case filed by Global Geeks, Inc.. Motions referred to Judge Lauren Fleischer Louis. Signed by Judge Beth Bloom on 9/1/2021. See attached document for full details. (amb)
August 31, 2021 Filing 173 EXPEDITED MOTION to Disqualify James Liu, Esq. as Trial Counsel in this Case by Global Geeks, Inc.. (Attachments: #1 Memorandum, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit)(Lindsay, Glen)
August 30, 2021 Filing 172 Proposed Jury Instructions by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
August 30, 2021 Filing 171 NOTICE by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #13 Scheduling Order,,,,, Order Referring Case to Mediation,,,,, Order Referring Case to Magistrate Judge,,,, of Filing Joint Pre-Trial Stipulation (Liu, Jianyin)
August 30, 2021 Filing 170 Exhibit List per Order (DE 133) by Stone Technology (HK) Co., Ltd.(an HK COMPANY).. (Liu, Jianyin)
August 30, 2021 Filing 169 Exhibit List Amended by Global Geeks, Inc... (Lindsay, Glen)
August 30, 2021 Opinion or Order Filing 168 ORDER denying #162 EMERGENCY MOTION with Certification of Emergency included to Extend Deadline of Filing Jury Instructions and Pre-Trial Stipulation Signed by Judge Beth Bloom on 8/30/2021. See attached document for full details. (jas)
August 30, 2021 Filing 167 Exhibit List by Global Geeks, Inc... (Lindsay, Glen)
August 30, 2021 Filing 166 NOTICE of Striking #164 Response to Motion, filed by Global Geeks, Inc. by Global Geeks, Inc., Global Geeks, Inc. (Lindsay, Glen)
August 30, 2021 Filing 165 RESPONSE to Motion re #162 EMERGENCY MOTION with Certification of Emergency included to Extend Deadline of Filing Jury Instructions and Pre-Trial Stipulation filed by Global Geeks, Inc.. Replies due by 9/7/2021. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Lindsay, Glen)
August 30, 2021 Filing 164 (STRICKEN per DE #166 ) RESPONSE to Motion re #162 EMERGENCY MOTION with Certification of Emergency included to Extend Deadline of Filing Jury Instructions and Pre-Trial Stipulation filed by Global Geeks, Inc.. Replies due by 9/7/2021. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Lindsay, Glen) Text Modified on 8/30/2021 (amb).
August 30, 2021 Filing 163 Proposed Voir Dire Questions by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
August 30, 2021 Filing 162 EMERGENCY MOTION with Certification of Emergency included to Extend Deadline of Filing Jury Instructions and Pre-Trial Stipulation by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 9/13/2021 (Liu, Jianyin)
August 28, 2021 Filing 161 Witness List Jointly Filed by GlobalGeeks and Stone for Trial with Estimated Time by Stone Technology (HK) Co., Ltd.(an HK COMPANY).. (Liu, Jianyin)
August 27, 2021 Filing 160 NOTICE by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #133 Scheduling Order,, Joint List of Stipulated Facts (Liu, Jianyin)
August 25, 2021 Opinion or Order Filing 159 ORDER Adopting #141 Report and Recommendations on #83 Motion to Compel;denying #83 Motion to Compel filed by Global Geeks, Inc. Signed by Judge Beth Bloom on 8/25/2021. See attached document for full details. (ail)
August 25, 2021 Opinion or Order Filing 158 PAPERLESS ORDER denying #156 Plaintiff's EXPEDITED MOTION to Revise Designation of Deposition Portions. The Court finds no good cause to modify the deposition designation deadline set forth in the Scheduling Order, ECF No. #133 . Additionally, the Court has already addressed the issue of Plaintiff's witnesses appearing virtually at trial. See ECF No. #136 . Signed by Judge Beth Bloom (ks01)
August 25, 2021 Filing 157 RESPONSE in Opposition re #156 EXPEDITED MOTION to Revise Designation of Deposition Portions re #133 Scheduling Order,, filed by Global Geeks, Inc.. Replies due by 9/1/2021. (Attachments: #1 Exhibit Exhibit A)(Lindsay, Glen)
August 25, 2021 Filing 156 EXPEDITED MOTION to Revise Designation of Deposition Portions re #133 Scheduling Order,, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
August 24, 2021 Filing 155 Statement of: GlobalGeeks' Neutral Statement of Case by Global Geeks, Inc. re 144 Order on Expedited Motion, #133 Scheduling Order,, (Lindsay, Glen)
August 24, 2021 Filing 154 NOTICE by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #133 Scheduling Order,, of Filing Joint List of All Witnesses for Trial (Liu, Jianyin)
August 23, 2021 Opinion or Order Filing 153 PAPERLESS ORDER granting in part and denying in part #152 Expedited Motion. The deadline to file a Notice of Settlement is postponed to Oct. 7, 2021, at Noon. Signed by Judge Beth Bloom (BB)
August 23, 2021 Filing 152 EXPEDITED MOTION Postponing Deadline to File a Notice of Settlement re #133 Scheduling Order,, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
August 23, 2021 Filing 151 Statement of: Neutral Statement of the Case by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re 144 Order on Expedited Motion, #133 Scheduling Order,, (Liu, Jianyin)
August 23, 2021 Filing 150 NOTICE by Global Geeks, Inc.(a New Jersey Corporation) of Deposition Designations for Trial (Lindsay, Glen)
August 22, 2021 Filing 149 Statement of: Deposition Portions to Be Used at Trial by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #133 Scheduling Order,, (Liu, Jianyin)
August 20, 2021 Opinion or Order Filing 148 PAPERLESS ORDER denying #147 Expedited Motion. The Court suggests that the attorneys, who are being compensated for their intellect and skill, also use their professionalism and civility tools to work together and arrive at a result consistent with the Court's Order. Signed by Judge Beth Bloom (BB)
August 20, 2021 Filing 147 Second EXPEDITED MOTION Instructions on Stipulated Facts re 146 Order on Expedited Motion, #133 Scheduling Order,, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A- GGs Email on Aug. 20, 2021)(Liu, Jianyin)
August 19, 2021 Opinion or Order Filing 146 PAPERLESS ORDER granting #145 Expedited Motion. For further and final clarification, a "Stipulated Fact" is one that both parties agree is not in dispute and, therefore, uncontested. As such, that particular fact does not require proof at trial. Signed by Judge Beth Bloom (BB)
August 19, 2021 Filing 145 EXPEDITED MOTION More Instruction on Stipulation of Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
August 17, 2021 Opinion or Order Filing 144 PAPERLESS ORDER granting #143 Expedited Motion. The parties are permitted to separately file a Neutral Statement of the Case as part of the Joint Pretrial Stipulation. Signed by Judge Beth Bloom (BB)
August 13, 2021 Filing 143 EXPEDITED MOTION More Instruction on Joint Neutral Statement re #133 Scheduling Order,, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit GlobalGeeks' Version of Neutral Statement, #2 Exhibit Stone's Version of Neutral Statement)(Liu, Jianyin)
August 11, 2021 Opinion or Order Filing 142 ORDER CONTINUING CALENDAR CALL AND TRIAL DATES: Calendar Call set for 10/5/2021 at 1:45 PM in Miami Division before Judge Beth Bloom., Jury Trial set for 10/12/2021 at 9:00 AM in Miami Division before Judge Beth Bloom. Signed by Judge Beth Bloom on 8/10/2021. See attached document for full details. (ail)
August 10, 2021 Filing 141 REPORT AND RECOMMENDATIONS re #83 Defendant's MOTION to Compel Second Chair Counsel for Plaintiff, Stone Technology (HK) Co. Ltd. filed by Global Geeks, Inc. Recommending that the Motion be DENIED, without prejudice. Objections to R&R due by 8/24/2021 Signed by Magistrate Judge Lauren F. Louis on 8/9/2021. See attached document for full details. (ail) Text Modified on 8/10/2021 (ail).
August 5, 2021 Opinion or Order Filing 140 PAPERLESS ORDER granting #139 Motion for Leave to Appear GlobalGeek's lead counsel may participate in the September 7, 2021 calendar call using a landline telephone. Counsel shall call 1-877-336-1829; Access code is 4742152 and security code 5680. Signed by Judge Beth Bloom (BB)
August 5, 2021 Filing 139 MOTION for Leave to Appear Calendar Call 9/7/2021 @ 9:00am by Telephone. Attorney/Representative: Benjamin J. Eichel, Esq. by Global Geeks, Inc.(a New Jersey Corporation). Responses due by 8/19/2021 (Attachments: #1 Text of Proposed Order)(Lindsay, Glen)
August 3, 2021 Filing 138 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Lauren Fleischer Louis: Motion Hearing held on 8/3/2021 re #83 Defendant's Motion to Compel Second Chair Counsel for Plaintiff. Total time in court: 35 minutes. Attorney Appearance(s): Jianyin Liu, Benjamin J. Eichel, Glen Matthew Lindsay. (Digital 16:00:02) (aw)
July 23, 2021 Opinion or Order Filing 137 PAPERLESS ORDER Setting Motion Hearing re #83 Defendant's Motion to Compel Second Chair Counsel. A Telephonic Motion Hearing is set for August 3, 2021 at 4:00 PM in Miami Division before Magistrate Judge Lauren Fleischer Louis.Telephonic appearance may be made by: dialing 1 (866) 434-5269, entering access code number 9978869 followed by the (#) sign, and entering security code number 5710 followed by the (#) sign. Signed by Magistrate Judge Lauren Fleischer Louis on 7/23/2021. (aw)
July 13, 2021 Opinion or Order Filing 136 ORDER denying #131 Renewed EXPEDITED MOTION For Virtual Appearance of Two Witnesses Signed by Judge Beth Bloom on 7/12/2021. See attached document for full details. (ail)
July 12, 2021 Opinion or Order Filing 135 ORDER REFERRING #77 Defendant's MOTION for Summary Judgment filed by Global Geeks, Inc., #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #83 Defendant's MOTION to Compel Second Chair Counsel for Plaintiff, Stone Technology (HK) Co. Ltd. filed by Global Geeks, Inc.. Motions referred to Judge Lauren Fleischer Louis. Signed by Judge Beth Bloom on 7/12/2021. See attached document for full details. (ail)
July 12, 2021 Filing 134 RESPONSE in Opposition re #131 Renewed EXPEDITED MOTION For Virtual Appearance of Two Witnesses re 130 Order on Expedited Motion, filed by Global Geeks, Inc.. Replies due by 7/19/2021. (Attachments: #1 Exhibit EXHIBIT A, #2 Exhibit EXHIBIT B, #3 Exhibit EXHIBIT C, #4 Exhibit EXHIBIT D, #5 Exhibit EXHIBIT E)(Lindsay, Glen)
July 12, 2021 Opinion or Order Filing 133 ORDER SCHEDULING TRIAL AND ORDER OF INSTRUCTIONS BEFORE CALENDAR CALL: Jury Trial set for 9/13/2021 at 9:00 AM in Miami Division before Judge Beth Bloom. Calendar Call set for 9/7/2021 at 1:45 PM in Miami Division before Judge Beth Bloom. Signed by Judge Beth Bloom on 7/10/2021. See attached document for full details. (ail) #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.
July 6, 2021 Opinion or Order Filing 132 PAPERLESS ORDER requiring Defendant's expedited response to #131 Plaintiff's Renewed EXPEDITED MOTION For Virtual Appearance of Two Witnesses by no later than July 12, 2021. Signed by Judge Beth Bloom (ks01)
July 6, 2021 Filing 131 Renewed EXPEDITED MOTION For Virtual Appearance of Two Witnesses re 130 Order on Expedited Motion, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Text of Proposed Order Proposed Order)(Liu, Jianyin)
July 6, 2021 Opinion or Order Filing 130 PAPERLESS ORDER denying without prejudice #129 Plaintiff's Expedited Motion for Virtual Appearance of Witnesses in Trial. Plaintiff may resubmit the motion with a list of each witness expected to appear remotely and succinct identifying information regarding their relevance or anticipated participation in this case. Signed by Judge Beth Bloom (ks01)
July 6, 2021 Filing 129 EXPEDITED MOTION Virtual Appearance of Witnesses by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
June 29, 2021 Filing 128 Statement of: Index of Exhibits by Global Geeks, Inc. re #123 Response/Reply (Other), #121 Response/Reply (Other) (Lindsay, Glen)
June 28, 2021 Filing 127 Statement of: Index to Exhibits for Reply [ECF No. 125, 126] to GlobalGeeks Response to Motion for Summary Judgment and Statement of Material Facts by Stone Technology (HK) Co., Ltd. re #125 Reply to Response to Motion, #126 Statement (Liu, Jianyin)
June 28, 2021 Filing 126 Statement of: Reply Statement of Material Facts to GlobalGeeks' Additional Facts in Response by Stone Technology (HK) Co., Ltd. re #109 Statement (Liu, Jianyin)
June 28, 2021 Filing 125 REPLY to Response to Motion re #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd.. (Liu, Jianyin)
June 28, 2021 Opinion or Order Filing 124 PAPERLESS ORDER granting #119 Plaintiff's Unopposed Expedited Motion to Increase Page Limit for Reply Memo. Plaintiff may submit a reply to ECF No. #82 of fourteen (14) pages or less. Signed by Judge Beth Bloom (ks01)
June 28, 2021 Filing 123 Defendant's REPLY Statement of Material Facts in Support of its Motion for Summary Judgment by Global Geeks, Inc.(a New Jersey Corporation). (Lindsay, Glen)
June 28, 2021 Filing 122 REPLY in Support of GlobalGeeks, Inc's Motion to Compel Second Chair Counsel for Plaintiff, Stone Technology (HK) Co. Ltd. by Global Geeks, Inc.(a New Jersey Corporation). (Lindsay, Glen)
June 28, 2021 Filing 121 Defendant's REPLY in Support of GlobalGeeks, Inc's Motion for Summary Judgment by Global Geeks, Inc.(a New Jersey Corporation). (Lindsay, Glen)
June 28, 2021 Filing 120 NOTICE by Global Geeks, Inc.(a New Jersey Corporation) of Corrected Statement of Material Facts in Response to Stone's 2nd Amended Statement of Material Facts in Support of its Motion for Summary Judgment (Attachments: #1 Exhibit A) (Lindsay, Glen)
June 28, 2021 Filing 119 EXPEDITED MOTION Increase the Pages of Reply Memo to 14 Pages or Less re #108 Response in Opposition to Motion by Stone Technology (HK) Co., Ltd.. (Liu, Jianyin)
June 26, 2021 Filing 118 Statement of: Amended Index to Exhibits for Reply [ECF No. 114, 115] by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #114 Statement, #115 Statement (Liu, Jianyin)
June 26, 2021 Filing 117 NOTICE of Striking #116 Statement filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
June 25, 2021 Filing 116 (STRICKEN per DE #117 )Statement of: to Exhibits In Reply Memo and Reply Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #114 Statement, #115 Statement (Liu, Jianyin) Text Modified on 6/29/2021 (amb).
June 25, 2021 Filing 115 Statement of: Reply to Additional Facts in GlobalGeeks' Response by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #94 Statement, (Liu, Jianyin)
June 25, 2021 Filing 114 Statement of: Reply Memorandum of Laws in Opposition to GlobalGeeks's Response by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #93 Response in Opposition to Motion (Attachments: #1 Exhibit Exhibit 11 - Receipt of Transportation)(Liu, Jianyin)
June 25, 2021 Opinion or Order Filing 113 PAPERLESS ORDER granting #112 Plaintiff's Motion for Leave to Increase Page Limit for Reply Memo. Plaintiff may submit a reply to ECF No. #71 of twenty (20) pages or less. Signed by Judge Beth Bloom (ks01)
June 25, 2021 Filing 112 MOTION for Leave to File Reply Memorandum with 20 Pages by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
June 23, 2021 Filing 111 NOTICE by Global Geeks, Inc. re #109 Statement of Materia Facts (Attachments: #1 Exhibit Corrected Exhibit A GGeeksDisc000023/24) (Lindsay, Glen)
June 23, 2021 Filing 110 Statement of: Index of Exhibits by Global Geeks, Inc. re #109 Statement, #108 Response in Opposition to Motion (Lindsay, Glen)
June 23, 2021 Filing 109 Statement of: Material Facts by Global Geeks, Inc. re #84 Statement (Attachments: #1 Exhibit Exhibit A - Stone's Emails 23/24)(Lindsay, Glen)
June 23, 2021 Filing 108 RESPONSE in Opposition re #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law filed by Global Geeks, Inc.. Replies due by 6/30/2021. (Lindsay, Glen)
June 23, 2021 Filing 107 Statement of: Index to Exhibits for Amended Response [ECF No. 105, 106] to GlobalGeeks Motion for Summary Judgment and Statement of Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #105 Response in Opposition to Motion, #106 Statement (Liu, Jianyin)
June 23, 2021 Filing 106 Statement of: Response to GlobalGeeks' Statement of Material Facts in Support of Its Motion for Summary Judgment with Additional Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #78 Statement, (Liu, Jianyin)
June 23, 2021 Filing 105 RESPONSE in Opposition re #77 Defendant's MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 6/30/2021. (Liu, Jianyin)
June 22, 2021 Filing 104 NOTICE of Striking #100 Statement filed by Stone Technology (HK) Co., Ltd., #99 Response in Opposition to Motion filed by Stone Technology (HK) Co., Ltd., #101 Statement, filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
June 22, 2021 Opinion or Order Filing 103 PAPERLESS ORDER granting #102 Plaintiff's Unopposed Motion for Extension of Time. Plaintiff shall file its reply to ECF No. #71 by June 25, 2021. Signed by Judge Beth Bloom (ks01)
June 22, 2021 Filing 102 MOTION for Extension of Time Two Days' Extension to File Reply re #93 Response in Opposition to Motion by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 7/6/2021 (Liu, Jianyin)
June 22, 2021 Set/Reset Deadline as to #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law. Replies due by 6/25/2021.SEE DE 103 ORDER (ail)
June 20, 2021 Filing 101 (STRICKEN per DE #104 ) Statement of: Index to Exhibits for Response [ECF No. 99, 100] to GlobalGeeks Motion for Summary Judgment and Statement of Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #100 Statement, #99 Response in Opposition to Motion (Liu, Jianyin) Text Modified on 6/23/2021 (amb).
June 20, 2021 Filing 100 (STRICKEN per DE #104 ) Statement of: of Response to GlobalGeeks' Statement of Material Facts in Support of Motion for Summary Judgment by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #78 Statement, (Liu, Jianyin) Text Modified on 6/23/2021 (amb).
June 20, 2021 Filing 99 (STRICKEN per DE #104 ) RESPONSE in Opposition re #77 Defendant's MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 6/28/2021. (Liu, Jianyin) Text Modified on 6/23/2021 (amb).
June 20, 2021 Filing 98 NOTICE of Filing Discovery: Philip Peng's pril 27, 2021 Depo Transcript by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A: Philip Peng's April 27, 2021 Depo Transcript)(Liu, Jianyin)
June 19, 2021 Filing 97 RESPONSE in Opposition re #83 Defendant's MOTION to Compel Second Chair Counsel for Plaintiff, Stone Technology (HK) Co. Ltd. filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 6/28/2021. (Liu, Jianyin)
June 17, 2021 Filing 96 Statement of: INDEX of EXHIBITS by Global Geeks, Inc. re #95 Statement, #93 Response in Opposition to Motion (Lindsay, Glen)
June 17, 2021 Filing 95 Statement of: Material Facts Amended by Global Geeks, Inc. re #72 Statement, (Attachments: #1 Exhibit EXHIBIT A - DECLARATION OF AHMAD LOUL DATED JUNE 16, 2021, #2 Exhibit EXHIBIT B - GEEKS0042, #3 Exhibit EXHIBIT C - GEEKS0306)(Lindsay, Glen)
June 16, 2021 Filing 94 Statement of: of Material Facts in Response to Stone's Statement of Material Facts in Support of its Motion for Summary Judgment by Global Geeks, Inc. re #72 Statement, (Attachments: #1 Exhibit EXHIBIT A - DECLARATION OF AHMAD LOUL DATED JUNE 16, 2021, #2 Exhibit EXHIBIT B - GEEKS0306)(Lindsay, Glen)
June 16, 2021 Filing 93 RESPONSE in Opposition re #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Global Geeks, Inc.. Replies due by 6/23/2021. (Lindsay, Glen)
June 16, 2021 Filing 92 NOTICE of Filing Discovery: Abdul Louls' April 15, 2021 Depo Transcript by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A -Abdul Loul's April 15, 2021 Depo Transcript)(Liu, Jianyin)
June 10, 2021 Opinion or Order Filing 91 PAPERLESS ORDER denying #89 Plaintiff's Motion for Attorney Fees Under 28 U.S.C. s. 1927. Defendant had a good-faith basis to file the Motion to Strike, ECF No. #87 , and there is therefore no basis upon which an award of attorneys' fees would be appropriate. Signed by Judge Beth Bloom (ks01)
June 10, 2021 Opinion or Order Filing 90 PAPERLESS ORDER denying #87 Defendant's Expedited Motion to Strike Plaintiff's Motion for Rule 56 Partial Summary Judgment, ECF No. #82 ("Motion for Partial Summary Judgment"). The Motion for Partial Summary Judgment relates to the Second Amended Complaint, ECF No. #34 , whereas Plaintiff's Motion for Rule 56 Summary Judgment, ECF No. #71 , relates to the claims asserted in the Counterclaim, ECF No. #41 . As the motions relate to different pleadings, they do not violate Local Rule 7.1(c)(2). Signed by Judge Beth Bloom (ks01)
June 10, 2021 Filing 89 MOTION for Attorney Fees by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 6/24/2021 (Liu, Jianyin)
June 10, 2021 Filing 88 RESPONSE in Opposition re #87 EXPEDITED MOTION to Strike Stone Technologies (HK) Co. Ltd.'s Motion for Rule 56 Partial Summary Judgment re #84 Statement, #86 Statement, #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law, #85 St filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 6/17/2021. (Liu, Jianyin)
June 10, 2021 Filing 87 EXPEDITED MOTION to Strike Stone Technologies (HK) Co. Ltd.'s Motion for Rule 56 Partial Summary Judgment re #84 Statement, #86 Statement, #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law, #85 Statement by Global Geeks, Inc.. (Attachments: #1 Memorandum Memorandum of Law to Expedited Motion to Strike, #2 Exhibit Exhibit - Email)(Lindsay, Glen)
June 9, 2021 Filing 86 Statement of: Index of Exhibits for Motion for Summary Judgment and Statement of Facts by Stone Technology (HK) Co., Ltd. re #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law, #84 Statement (Liu, Jianyin)
June 9, 2021 Filing 85 Statement of: of Correction to One Citation Error by Stone Technology (HK) Co., Ltd. re #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law (Liu, Jianyin)
June 9, 2021 Filing 84 Statement of: Material Facts in Support of Motion for Partial Summary Judgment by Stone Technology (HK) Co., Ltd. re #82 MOTION for Partial Summary Judgment with Support of Memorandum of Law (Liu, Jianyin)
June 9, 2021 Filing 83 Defendant's MOTION to Compel Second Chair Counsel for Plaintiff, Stone Technology (HK) Co. Ltd. by Global Geeks, Inc.. Responses due by 6/23/2021 (Attachments: #1 Memorandum Memorandum to Motion to Compel, #2 Exhibit Exhibit A to Motion to Compel - Initial Disclosures of Stone's)(Lindsay, Glen)
June 9, 2021 Filing 82 MOTION for Partial Summary Judgment with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.. Responses due by 6/23/2021 (Attachments: #1 Exhibit A - GG's Production Bate No. GEEKS0511-24, #2 Exhibit B - Memorandum of Laws, #3 Exhibit C - Email 90)(Liu, Jianyin)
June 9, 2021 Filing 81 NOTICE of Filing Discovery: Ahmad Loul's April 15, 2021 Depo Transcript by Stone Technology (HK) Co., Ltd.. (Attachments: #1 Exhibit A- Ahmad Loul's Apr 15, 2021 Depo Trans.)(Liu, Jianyin)
June 9, 2021 Filing 80 NOTICE by Global Geeks, Inc. re #77 Defendant's MOTION for Summary Judgment , #78 Statement, INDEX of EXHIBITS (Lindsay, Glen)
June 9, 2021 Filing 79 NOTICE by Global Geeks, Inc. re #77 Defendant's MOTION for Summary Judgment , #78 Statement, of Material Facts (Attachments: #1 Exhibit Exhibit O - GEEKS0253) (Lindsay, Glen)
June 9, 2021 Filing 78 Statement of: Material Facts by Global Geeks, Inc. re #77 Defendant's MOTION for Summary Judgment (Attachments: #1 Exhibit EXHIBIT G - PO 82811, #2 Exhibit EXHIBIT H - PO 82813, #3 Exhibit EXHIBIT I - PO 82800, #4 Exhibit EXHIBIT J - PO 82806, #5 Exhibit EXHIBIT N - GEEKS0055-0061, #6 Exhibit EXHIBIT O - GEEKS0253)(Lindsay, Glen)
June 9, 2021 Filing 77 Defendant's MOTION for Summary Judgment by Global Geeks, Inc.. Responses due by 6/23/2021 (Attachments: #1 Memorandum Memorandum of Law in Support of MSJ)(Lindsay, Glen)
June 9, 2021 Filing 76 NOTICE of Filing Discovery: Deposition by Global Geeks, Inc.. (Attachments: #1 Deposition Exhibit M - Deposition transcript of Ahmad Loul dated April 15, 2021)(Lindsay, Glen)
June 9, 2021 Filing 75 NOTICE of Filing Discovery: Deposition by Global Geeks, Inc.. (Attachments: #1 Deposition EXHIBIT L - Deposition Transcript of Lynn Huang dated May 5, 2021)(Lindsay, Glen)
June 9, 2021 Filing 74 NOTICE of Filing Discovery: Deposition by Global Geeks, Inc.(a New Jersey Corporation). (Attachments: #1 Deposition Exhibit E - Deposition Transcrit James Liu Esq May 4, 2021)(Lindsay, Glen)
June 3, 2021 Filing 73 Statement of: Index of Exhibits for Motion for Summary Judgment and Statement of Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law, #72 Statement, (Liu, Jianyin)
June 3, 2021 Filing 72 Statement of: Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #71 Amended MOTION for Summary Judgment with Support of Memorandum of Law (Attachments: #1 Exhibit A - Certificate of Email Authentication_ May 4, 2021.pdf, #2 Exhibit B- Stone's 1st RFP, #3 Exhibit C - Stone's Amended 2nd RFP, #4 Exhibit D - GG's Production Bate No. GEEKS0046, #5 Exhibit E - Email 56)(Liu, Jianyin)
June 3, 2021 Filing 71 Amended MOTION for Summary Judgment with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 6/17/2021 (Attachments: #1 Exhibit A -GG's Initial Disclosures, #2 Exhibit B - GEEKS0295-0299_Adobe.pdf, #3 Exhibit C - GG's Air Charter Contract, #4 Exhibit D - Sales Order btw Fine and GG, #5 Exhibit E - GG's Production Bate No. GGeekDisc000044, #6 Exhibit F - GlobalGeeks Objections and Answers to First Set of Interrogatories, #7 Exhibit G - GG's Production Bate No. GEEKS 0190-191 PO 82800.PDF)(Liu, Jianyin)
June 3, 2021 Opinion or Order Filing 70 PAPERLESS ORDER STRIKING #65 Amended Motion for Summary Judgment and #67 Amended Statement of Material Facts. See ECF No. #69 (Notice of Striking). Signed by Judge Beth Bloom (ks01)
June 2, 2021 Filing 69 NOTICE of Striking #67 Statement, filed by Stone Technology (HK) Co., Ltd., #65 Amended MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd., #61 Notice of Filing Discovery filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
June 2, 2021 Filing 68 NOTICE of Filing Discovery: Deposition Transcript by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A -Philip Peng's April 29, 2021 Depo Trans)(Liu, Jianyin)
June 2, 2021 Filing 67 Statement of: Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #65 Amended MOTION for Summary Judgment with Support of Memorandum of Law (Attachments: #1 Exhibit A - Certificate of Email Authentication_ May 4, 2021.pdf, #2 Exhibit B- Stone's 1st RFP, #3 Exhibit C - Stone's Amended 2nd RFP, #4 Exhibit D - GG's Production Bate No. GEEKS0046, #5 Exhibit E - Email 56)(Liu, Jianyin)
June 2, 2021 Opinion or Order Filing 66 PAPERLESS ORDER denying as moot #62 Motion for Summary Judgment. See Amended Motion at ECF No. #65 . Signed by Judge Beth Bloom (BB)
June 2, 2021 Filing 65 Amended MOTION for Summary Judgment with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 6/16/2021 (Attachments: #1 A -GG's Initial Disclosures, #2 B - GG's Bate No. GEEKS0295-99, #3 C - GG's Air Charter Contract, #4 D - Sales Order btw Fine and GG, #5 E - GG's Production Bate No. GGeekDisc000044, #6 F - GlobalGeeks Objections and Answers to First Set of Interrogatories, #7 G - GG's Production Bate No. GEEKS 0190-191 PO 82800.PDF)(Liu, Jianyin)
June 2, 2021 Filing 64 NOTICE of Striking #63 Statement, filed by Stone Technology (HK) Co., Ltd., #62 First MOTION for Summary Judgment with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
June 2, 2021 Filing 63 (STRICKEN per DE #64 ) Statement of: Material Facts by Stone Technology (HK) Co., Ltd.(an HK COMPANY) re #62 First MOTION for Summary Judgment with Support of Memorandum of Law (Attachments: #1 Exhibit A - Certificate of Email Authentication_ May 4, 2021.pdf, #2 Exhibit B- Stone's 1st RFP, #3 Exhibit C - Stone's AMENDED 2nd RFP, #4 Exhibit D - GG's Production Bate No. GEEKs0046, #5 Exhibit E - Email 56)(Liu, Jianyin) Text Modified on 6/3/2021 (amb).
June 2, 2021 Filing 62 (STRICKEN per DE #64 ) First MOTION for Summary Judgment with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 6/16/2021 (Attachments: #1 Exhibit A -GG's Initial Disclosures, #2 Exhibit B - GG's Production Bate No. GEEKS 0295-0299, #3 Exhibit C - GG's Air Charter Contract, #4 Exhibit D- Sales Order btw Fine and GG, #5 Exhibit E - GG's Production Bate No. GGeekDisc000044, #6 Exhibit F - GlobalGeeks Objections and Answers to First Set of Interrogatories, #7 Exhibit G - GG's Production Bate No. GEEKS 0190-191 PO 82800.PDF)(Liu, Jianyin) Text Modified on 6/3/2021 (amb).
May 31, 2021 Filing 61 (STRICKEN per DE #69 ) NOTICE of Filing Discovery: Deposition Transcript by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A- Guanghua Peng's April 29 2021 Depo Transcript)(Liu, Jianyin) Text Modified on 6/3/2021 (amb).
May 29, 2021 Filing 60 NOTICE of Filing Discovery: Document Production from Both Parties by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A -Email 22, #2 Exhibit B -Email 29, #3 Exhibit C -Email 44, #4 Exhibit D -Email 46, #5 Exhibit E -Email 50, #6 Exhibit F -Email 58, #7 Exhibit G -Email 95, #8 Exhibit H -Email 92, #9 Exhibit I -Email 67, #10 Exhibit J - GEEKS0344-0422, #11 Exhibit K - GEEKS0439-0449, #12 Exhibit L - GEEKS0525-0555, #13 Exhibit M - GEEKS0556-0559, #14 Exhibit N - GEEKS0560-0567, #15 Exhibit O - GEEKS0568-0569)(Liu, Jianyin)
May 28, 2021 Filing 59 FINAL MEDIATION REPORT by Anne Bloom. Disposition: Case did not settle. (Attachments: #1 Supplement Parties' Mediation Report)(Liu, Jianyin)
May 28, 2021 Filing 58 FINAL MEDIATION REPORT by Anne Bloom. Disposition: Case did not settle.(Bloom, Anne)
May 28, 2021 Opinion or Order Filing 57 ORDER TO SHOW CAUSE re #22 ORDER Scheduling Mediation. Show Cause Response due by 6/1/2021. Signed by Judge Beth Bloom on 5/28/2021. See attached document for full details. (ail)
May 4, 2021 Filing 56 Third NOTICE of Mediation Hearing. Revised for Zoom Rules Mediation Hearing set for 5/24/2021 at 10:00 am. (Bloom, Anne)
May 4, 2021 Filing 55 Second NOTICE of Mediation Hearing. Revised for location Mediation Hearing set for 5/24/2021 at 10:00 am. (Bloom, Anne)
February 19, 2021 Filing 54 ANSWER to Counterclaim re DE #41 Restated and Amended ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand to Second Amended Complaint, Amended COUNTERCLAIM against All Plaintiffs by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A-Accounting Reconciliation As of Mar. 26, 2020, #2 Exhibit B-Reconciled Accounting Between 04/01/2020 and 04/17/2020, #3 Exhibit C-Sales Report (Beijing-JFK April 7th) PO82800, #4 Exhibit D-Sales Report (Shanghai -NY April 10th and 14th) PO82806, #5 Exhibit E-May 12 2020 KN95 Project, #6 Exhibit F- Ahmad Loul's Email Regarding 500K WIRE, #7 Exhibit G-Agreement_between_GlobalGeeks_and_Stone.pdf)(Liu, Jianyin) Modified to correct link on 2/19/2021 (jua).
February 10, 2021 Opinion or Order Filing 53 PAPERLESS ORDER denying #44 Stone Technology's Corrected Motion to Dismiss for the reasons stated on the record. Specifically, by agreement, Count II of the Counterclaim was withdrawn pursuant to the stipulations of the parties on the record, and the Motion was denied as to Counts III, IV, and V of the Counterclaim. Stone Technology shall respond to the Counterclaim, ECF No. #41 , by no later than February 24, 2021. Signed by Judge Beth Bloom (ks01)
February 10, 2021 Filing 52 PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom: Motion Hearing held on 2/10/2021 re #44 Corrected MOTION TO DISMISS #41 . Total time in court: 1 hour. Attorney Appearance(s): Benjamin J. Eichel, Glen Matthew Lindsay, & Jianyin Liu. Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov. (ks01)
February 8, 2021 Opinion or Order Filing 51 PAPERLESS ORDER granting #50 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Benjamin J. Eichel. Signed by Judge Beth Bloom (BB)
February 8, 2021 Filing 50 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Benjamin J. Eichel. Filing Fee $ 200.00 Receipt # AFLSDC-14350842 by Global Geeks, Inc.(a New Jersey Corporation). Responses due by 2/22/2021 (Attachments: #1 Text of Proposed Order Proposed Order to Appear PHV)(Lindsay, Glen)
February 5, 2021 Opinion or Order Filing 49 ORDER Setting Hearing on Motion #44 Corrected MOTION TO DISMISS #41 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law : Telephonic Motion Hearing set for 2/10/2021 at 11:00 AM before Judge Beth Bloom. Signed by Judge Beth Bloom on 2/3/2021. See attached document for full details. (ail)
February 3, 2021 Filing 48 REPLY to #47 Response in Opposition to Motion, by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Liu, Jianyin)
January 29, 2021 Filing 47 RESPONSE in Opposition re #44 Corrected MOTION TO DISMISS #41 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law filed by Global Geeks, Inc.(a New Jersey Corporation). Replies due by 2/5/2021. (Lindsay, Glen)
January 28, 2021 Filing 46 ANSWER to Counterclaim with Affirmative Defenses by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit A-Accounting Reconciliation As of Mar. 26, 2020, #2 Exhibit B-Reconciled Accounting Between 04/01/2020 and 04/17/2020, #3 Exhibit C-Sales Report (Beijing-JFK April 7th) PO82800, #4 Exhibit D-Sales Report (Shanghai -NY April 10th and 14th) PO82806, #5 Exhibit E-May 12 2020 KN95 Project, #6 Exhibit F- Ahmad Loul's Email Regarding 500K WIRE, #7 Exhibit G-Agreement_between_GlobalGeeks_and_Stone.pdf)(Liu, Jianyin)
January 27, 2021 Opinion or Order Filing 45 PAPERLESS ORDER denying as moot #42 Motion to Dismiss for Failure to State a Claim due to the filing of the Corrected Motion to Dismiss, ECF No. #44 . Signed by Judge Beth Bloom (BB)
January 27, 2021 Filing 44 Corrected MOTION TO DISMISS #41 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 2/10/2021 (Liu, Jianyin)
January 27, 2021 Filing 43 NOTICE of Striking #42 First MOTION TO DISMISS #41 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
January 27, 2021 Filing 42 First MOTION TO DISMISS #41 Answer to Amended Complaint,, Counterclaim, FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 2/10/2021 (Liu, Jianyin)
January 12, 2021 Filing 41 Restated and Amended ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand to Second Amended Complaint, Amended COUNTERCLAIM against All Plaintiffs by Global Geeks, Inc.(a New Jersey Corporation). (Attachments: #1 Exhibit A)(Lindsay, Glen)
January 11, 2021 Opinion or Order Filing 40 ORDER granting in part and denying in part #37 Motion for Clarification. The Motion is GRANTED to the extent that Defendant requests leave to file anamended answer. By no later than January 20, 2021, Defendant may amend itsAnswer and Affirmative Defenses to the Second Amended Complaint, ECF No. #35 ,to properly reassert the Amended Counterclaim, ECF No. #19 , in a manner thatcomplies with this Courts Local Rules and the Federal Rules of Civil Procedure, asdiscussed in this Order. All future filings in this action by either party must strictly comply with the Federal Rules of Civil Procedure and this Districts Local Rules. The Motion is DENIED in all other respects. Signed by Judge Beth Bloom on 1/11/2021. See attached document for full details. (amb) Text Modified on 1/11/2021 (amb).
January 11, 2021 Set/Reset Answer Due Deadline: Global Geeks, Inc. response due 1/20/2021 re DE #40 Order. (amb)
January 7, 2021 Filing 39 REPLY to Response to Motion re #37 MOTION for clarification 36 Order on Motion to Dismiss for Failure to State a Claim filed by Global Geeks, Inc.(a New Jersey Corporation). (Lindsay, Glen)
December 31, 2020 Filing 38 RESPONSE in Opposition re #37 MOTION for clarification 36 Order on Motion to Dismiss for Failure to State a Claim with Support of Memorandum of Law filed by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Replies due by 1/7/2021. (Liu, Jianyin)
December 18, 2020 Filing 37 MOTION for clarification 36 Order on Motion to Dismiss for Failure to State a Claim by Global Geeks, Inc.(a New Jersey Corporation). Responses due by 1/4/2021 (Lindsay, Glen)
November 28, 2020 Opinion or Order Filing 36 PAPERLESS ORDER denying as moot #24 Motion to Dismiss for Failure to State a Claim based upon the filing of Answer and Affirmative Defenses, ECF No. #35 . Signed by Judge Beth Bloom (BB)
November 12, 2020 Filing 35 ANSWER and Affirmative Defenses to Amended Complaint (Second) by Global Geeks, Inc.. (Lindsay, Glen)
October 29, 2020 Filing 34 Second AMENDED COMPLAINT against All Defendants filed in response to Order Granting Motion for Leave, filed by Stone Technology (HK) Co., Ltd.. (Attachments: #1 Exhibit Exhibit A: Master Agreement, #2 Exhibit Exhibit B -Accounting Reconciliation As of Mar. 26, 2020, #3 Exhibit Exhibit C - Reconciled Accounting Between 04/01/2020 and 04/17/2020, #4 Exhibit Exhibit D-Sales Report (Beijing-JFK April 7th) PO82800, #5 Exhibit Exhibit E-Sales Report (Shanghai -NY April 10th and 14th) PO82806, #6 Exhibit Exhibit F-PO82811, #7 Exhibit Exhibit G-PO82813, #8 Exhibit Exhibit H-May 12 2020 KN95 Project, #9 Exhibit Exhibit I - Ahmad Loul's Email)(Liu, Jianyin)
October 29, 2020 Opinion or Order Filing 33 ORDER granting in part and denying in part #29 Motion to Amend/Correct ; granting in part and denying in part #29 Motion to Adopt/Join. Signed by Judge Beth Bloom on 10/28/2020. See attached document for full details. (ail)
October 27, 2020 Filing 32 First REPLY to #31 Response in Opposition to Motion, by Stone Technology (HK) Co., Ltd.. (Attachments: #1 Exhibit Proposed 2nd Amended Complaint, #2 Exhibit Emails with Accounting Between GlobalGeeks and Stone)(Liu, Jianyin)
October 21, 2020 Filing 31 RESPONSE in Opposition re #29 First MOTION to Amend/Correct #1 Notice of Removal (State Court Complaint), ComplaintFirst MOTION to Adopt/Join #1 Notice of Removal (State Court Complaint), Ahamd Loul as Defendant, Stone Group USA, LLC as Plaintiff filed by Global Geeks, Inc.(a New Jersey Corporation). Replies due by 10/28/2020. (Attachments: #1 Exhibit A, #2 Exhibit B)(Lindsay, Glen)
October 14, 2020 Opinion or Order Filing 30 PAPERLESS ORDER requiring Defendants' expedited responses by October 21, 2020, to Plaintiff's Motion to Add Defendant and Amend First Amended Complaint, ECF No. #29 . Signed by Judge Beth Bloom (BB)
October 7, 2020 Filing 29 First MOTION to Amend/Correct #1 Notice of Removal (State Court Complaint), Complaint ( Responses due by 10/21/2020), First MOTION to Adopt/Join #1 Notice of Removal (State Court Complaint), Ahamd Loul as Defendant, Stone Group USA, LLC as Plaintiff by Stone Technology (HK) Co., Ltd.. (Attachments: #1 Exhibit 2nd Amended Complaint, #2 Exhibit Jan. 2020 Agreement)(Liu, Jianyin)
October 7, 2020 Filing 28 RESPONSE to #24 First MOTION TO DISMISS #19 Answer to Complaint, Counterclaim FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law by Global Geeks, Inc.(a New Jersey Corporation). (Lindsay, Glen)
September 30, 2020 Filing 27 RESPONSE to #19 Answer to Complaint, Counterclaim with Affirmative Defenses by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit Accounting Reconciliation As of Mar. 26, 2020, #2 Exhibit Reconciled Accounting Between 04/01/2020 and 04/17/2020, #3 Exhibit Sales Report (Beijing-JFK April 7th ) PO82800ales Report (Beijing-JFK April 7th ) PO82800ales Report (Beijing-JFK April 7th) PO82800, #4 Exhibit Sales Report (Shanghai -NY April 10th and 14th ) PO82806ales Report (Shanghai -NY April 10th and 14th ) PO82806ales Report (Shanghai -NY April 10th and 14th) PO82806, #5 Exhibit May 12 2020 KN95 Project, #6 Exhibit Ahmad Loul's Email Regarding 500K WIRE, #7 Exhibit Jan. 2020 Agreement)(Liu, Jianyin)
September 30, 2020 Filing 26 NOTICE of Striking #25 Answer to Counterclaim,, filed by Stone Technology (HK) Co., Ltd. by Stone Technology (HK) Co., Ltd., Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
September 30, 2020 Filing 25 STRICKEN per #26 Counter-Defendant's ANSWER to Counterclaim with Affirmative Defenses by Stone Technology (HK) Co., Ltd.(an HK COMPANY). (Attachments: #1 Exhibit Accounting Reconciliation As of Mar. 26, 2020, #2 Exhibit Reconciled Accounting Between 04/01/2020 and 04/17/2020, #3 Exhibit Sales Report (Beijing-JFK April 7th ) PO82800, #4 Exhibit Sales Report (Shanghai -NY April 10th and 14th ) PO82806, #5 Exhibit May 12 2020 KN95 Project, #6 Exhibit Ahmad Loul's Email Regarding 500K WIRE, #7 Exhibit Jan. 2020 Agreement)(Liu, Jianyin) Modified docket text on 9/30/2020 (nc).
September 24, 2020 Filing 24 First MOTION TO DISMISS #19 Answer to Complaint, Counterclaim FOR FAILURE TO STATE A CLAIM with Support of Memorandum of Law by Stone Technology (HK) Co., Ltd.(an HK COMPANY). Responses due by 10/8/2020 (Attachments: #1 Exhibit Agreement of Project Between GlobalGeeks and Stone Group)(Liu, Jianyin)
September 18, 2020 Filing 23 First NOTICE of Mediation Hearing. Mediation Hearing set for 5/24/2021 at 10:00 am. (Bloom, Anne)
September 16, 2020 Opinion or Order Filing 22 ORDER SCHEDULING MEDIATION before Anne Bloom. Mediation Deadline 5/27/2021. Signed by Judge Beth Bloom on 9/16/2020. See attached document for full details. (amb)
September 16, 2020 Filing 21 Joint NOTICE of Mediator Selection and Hearing. Selected/Added Global Geeks, Inc.(a New Jersey Corporation), Anne Bloom as Mediator. Mediation Hearing set for 5/24/2021 at 10:00 a.m.. (Attachments: #1 Text of Proposed Order)(Lindsay, Glen)
September 10, 2020 Opinion or Order Filing 20 PAPERLESS ORDER denying as moot #17 Plaintiff's Motion to Dismiss Counterclaim. See ECF No. #19 . Signed by Judge Beth Bloom (ks01)
September 10, 2020 Filing 19 Amended ANSWER and Affirmative Defenses to Complaint with Jury Demand , Amended COUNTERCLAIM against Stone Technology (HK) Co., Ltd. by Global Geeks, Inc.. (Lindsay, Glen)
August 27, 2020 Filing 18 First Corporate Disclosure Statement by Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
August 27, 2020 Filing 17 First MOTION TO DISMISS #7 ANSWER to Complaint (Notice of Removal), Counterclaim FOR FAILURE TO STATE A CLAIM with support of memorandum of law by Stone Technology (HK) Co., Ltd.. Responses due by 9/10/2020 (Attachments: #1 Exhibit Plaintiff's Amended Complaint in state court, #2 Exhibit Agreement of Smartphone Project, #3 Exhibit Purchase Orders of Smartphones and Their Fund Related Contracts)(Liu, Jianyin)
August 26, 2020 Opinion or Order Filing 16 GENERAL ORDER ON DISCOVERY OBJECTIONS AND PROCEDURES. Signed by Magistrate Judge Lauren Fleischer Louis on 8/26/2020. See attached document for full details. (aw)
August 26, 2020 Filing 15 Clerks Notice to Filer re #12 Certificate of Other Affiliates/Corporate Disclosure Statement. Other Affiliates/Corporate Parents Not Entered; ERROR - The Filer failed to enter all Other Affiliates/Corporate Parents from the Certificate of Other Affiliates/Corporate Disclosure Statement. Filer is instructed to refile their Certificate of Other Affiliates/Corporate Disclosure Statement and enter the missing Other Affiliates listed on the Certificate (Guanghua Peng,Carlos Toro, etc.) /Corp Parents. Note - Other Affiliates/Corporate Parents do not appear on the docket sheet. (ail)
August 26, 2020 Filing 14 Clerks Notice to Filer re #11 Certificate of Other Affiliates/Corporate Disclosure Statement. Other Affiliates/Corporate Parents Not Entered; ERROR - The Filer failed to enter all Other Affiliates/Corporate Parents from the Certificate of Other Affiliates/Corporate Disclosure Statement. Filer is instructed to refile their Certificate of Other Affiliates/Corporate Disclosure Statement and enter the missing Other Affiliates listed on the certificate (Joshua Hameier, Amanda Marte, Abdul Lou, etc.)/Corp Parents. Note - Other Affiliates/Corporate Parents do not appear on the docket sheet. (ail)
August 26, 2020 Opinion or Order Filing 13 ORDER SETTING TRIAL AND PRE-TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE. SCHEDULING ORDER: ( Amended Pleadings due by 10/26/2020., Discovery due by 5/18/2021., Expert Discovery due by 5/18/2021., Joinder of Parties due by 10/26/2020., Mediation Deadline 6/1/2021., In Limine Motions due by 6/9/2021., Dispositive Motions due by 6/9/2021., Motions due by 6/9/2021., Pretrial Stipulation due by 8/30/2021., Jury Trial set for 9/13/2021 09:00 AM in Miami Division before Judge Beth Bloom., Calendar Call set for 9/7/2021 01:45 PM in Miami Division before Judge Beth Bloom.), ORDER REFERRING CASE to Mediation. ( Mediation Deadline 6/1/2021.), ORDER REFERRING CASE to Magistrate Judge Lauren Fleischer Louis for Discovery Matters. Signed by Judge Beth Bloom on 8/26/2020. See attached document for full details. (amb) #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.
August 26, 2020 Filing 12 First Certificate of Other Affiliates/Corporate Disclosure Statement by Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
August 26, 2020 Filing 11 Defendant's Corporate Disclosure Statement by Global Geeks, Inc. (Lindsay, Glen)
August 26, 2020 Filing 10 Joint SCHEDULING REPORT - Rule 26(f) by Global Geeks, Inc. (Attachments: #1 Text of Proposed Order, #2 Exhibit Consent to Magistrate Form)(Lindsay, Glen)
August 17, 2020 Filing 9 NOTICE of Attorney Appearance by Jianyin Liu on behalf of Stone Technology (HK) Co., Ltd. (Liu, Jianyin)
August 12, 2020 Filing 8 NOTICE by Global Geeks, Inc. of Filing Circuit Court Docket (Lindsay, Glen)
August 11, 2020 Filing 7 ANSWER and Affirmative Defenses to Complaint re the Notice of Removal with Jury Demand , COUNTERCLAIM against Stone Technology (HK) Co., Ltd. by Global Geeks, Inc.. (Attachments: #1 Exhibit)(Lindsay, Glen)
August 6, 2020 Filing 6 NOTICE of Civil Sheet by Global Geeks, Inc. re #1 NOTICE OF REMOVAL (Lindsay, Glen) Text Modified on 8/7/2020 (ail). Text & Link Modified on 8/7/2020 (ail).
August 5, 2020 Opinion or Order Filing 5 ORDER ON POST-REMOVAL PROCEDURES, AND REQUIRING SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES. On or before August 12, 2020, Defendant shall answer or otherwise respond to the underlying complaint, unless Defendant has already done so in the Circuit Court Action. By August 26, 2020, the parties shall prepare and file a joint scheduling report, as required by Local Rule 16.1. Signed by Judge Beth Bloom on 8/5/2020. See attached document for full details. (wc)
August 5, 2020 Filing 4 Bar Letter re: Admissions sent to attorney Jianyin Liu, mailing date 08/05/2020, (cco)
August 5, 2020 Filing 3 Clerks Notice to Filer re: Electronic Case. No Civil Cover Sheet. Filer is instructed to file a Notice (Other) with the Civil Cover Sheet attached within 24 hours of the notice. (amb)
August 5, 2020 Filing 2 Clerks Notice of Judge Assignment to Judge Beth Bloom. 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. (amb)
August 5, 2020 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 400.00 receipt number CFLSDC-13299989, filed by Global Geeks, Inc.. (Attachments: #1 Exhibit State Court Pleadings)(Lindsay, Glen) (No Answer or Motion to Dismiss filed) Text Modified on 8/5/2020 (amb).

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Plaintiff: Stone Technology (HK) Co., Ltd.
Represented By: Jianyin Liu
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Defendant: Global Geeks, Inc.
Represented By: Glen Matthew Lindsay
Represented By: Benjamin J. Eichel
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