Oueiss v. Bin Salman Bin Abdulaziz Al Saud et al
Plaintiff: Ghada Oueiss
Defendant: Faisal al Bannai, Bader Al-Asaker, Turki Al-Owerde, Awwad Al Otaibi, Mohammed Bin Salman Bin Abdulaziz Al Saud, Sharon Collins, Saudi Arabian Cultural Mission, Christanne Schey, Tarek Abou Zeinab, John Doe, Hussam Al-Jundi, Faisal Al Menaia, Mohammed Bin Zayed Al Nahyan, Annette Smith, Al Arabiya, Saud Al Qahtani, Saudi 24 TV, DarkMatter, Prince Mohammed Bin Salman Abdulaziz Foundation doing business as MiSK Foundation, Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC, Sharon Van Rider and Sam Jundi
Amicus Curiae: Electronic Frontier Foundation
Case Number: 1:2020cv25022
Filed: December 9, 2020
Court: US District Court for the Southern District of Florida
Presiding Judge: James Lawrence King
Referring Judge: Lauren Fleischer Louis
2 Judge: K Michael Moore
Nature of Suit: Assault Libel & Slander
Jury Demanded By: Plaintiff
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Docket Report

This docket was last retrieved on March 29, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 29, 2022 Opinion or Order Filing 200 ORDER GRANTING #161 ; #162 ; #163 ; #164 ; #165 ; #166 ; #167 ; #168 ; #169 Motions to Dismiss. Plaintiff's Amended Complaint #135 is DISMISSED WITHOUT PREJUDICE. The Clerk of Court is INSTRUCTED to CLOSE this case. All pending motions, if any, are DENIED AS MOOT. Signed by Judge K. Michael Moore on 3/28/2022. See attached document for full details. (elm)
March 29, 2022 Opinion or Order Filing 199 ORDER DENYING #190 Motion for Leave to File Amicus Curiae Brief, and DENYING #191 Motion to Strike Motion for Leave to File Amicus Brief. The Clerk of Court is INSTRUCTED to TERMINATE Electronic Frontier Foundation as an amicus curiae of record. Signed by Judge K. Michael Moore on 3/28/2022. See attached document for full details. (elm)
November 16, 2021 Filing 198 RESPONSE to #197 Notice of Supplemental Authority by Prince Mohammed Bin Salman Abdulaziz Foundation. (Cochran, Justin)
November 10, 2021 Filing 197 Notice of Supplemental Authority re #172 Response in Opposition to Motion,,,,, by Ghada Oueiss (Attachments: #1 Exhibit A - Opinion - WhatsApp, Inc. v. NSO Group Technologies, Inc., No. 20-16408 (9th Cir.)) (Marcus, Jeffrey)
October 27, 2021 Filing 196 REPLY to Response to Motion re #191 MOTION to Strike #190 MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiff Against Defendant DarkMatter's Motion to Dismiss , #190 MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiff Against Defendant DarkMatter's Motion to Dismiss filed by Electronic Frontier Foundation. (Shullman, Deanna)
October 25, 2021 Opinion or Order Filing 195 PAPERLESS ORDER. THIS CAUSE came before the Court upon putative amicus curiae and nonparty Electronic Frontier Foundation's ("EFF") #189 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing as to Mukund Rathi, Esq. UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #189 is GRANTED. Mukund Rathi may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to mukund@eff.org. Signed by Judge K. Michael Moore on 10/22/2021. (elm)
October 25, 2021 Opinion or Order Filing 194 PAPERLESS ORDER. THIS CAUSE came before the Court upon proposed amicus curiae and nonparty Electronic Frontier Foundation's ("EFF") #188 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing as to Sophia Cope, Esq. UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #188 is GRANTED. Sophia Cope may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to sophia@eff.org. Signed by Judge K. Michael Moore on 10/22/2021. (elm)
October 25, 2021 Filing 193 Clerks Notice to Filer re #191 OPPOSITION/RESPONSE (and) MOTION to Strike. Two or More Document Events Filed as One; ERROR - Only one event was selected by the Filer but more than one event was applicable to the document filed. The docket entry was corrected by the Clerk. It is not necessary to refile this document but in the future, the Filer must select all applicable events. (sk)
October 20, 2021 Filing 192 OPPOSITION/RESPONSE to Motion re #190 MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiff Against Defendant DarkMatter's Motion to Dismiss filed by DarkMatter. Replies due by 10/27/2021. (Per Chambers) - For PDF, see ECF No. #191 10/20/2021 MOTION to Strike. (sk)
October 20, 2021 Filing 191 MOTION to Strike #190 MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiff Against Defendant DarkMatter's Motion to Dismiss by DarkMatter. Responses due by 11/3/2021 (Binhak, Stephen)
October 19, 2021 Filing 190 MOTION for Leave to File Amicus Curiae Brief in Support of Plaintiff Against Defendant DarkMatter's Motion to Dismiss by Electronic Frontier Foundation. (Attachments: #1 Amicus Brief)(Shullman, Deanna)
October 19, 2021 Filing 189 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Mukund Rathi. Filing Fee $ 200.00 Receipt # AFLSDC-15102413 by Electronic Frontier Foundation. Responses due by 11/2/2021 (Attachments: #1 Text of Proposed Order Proposed Order)(Shullman, Deanna) Modified text on 10/19/2021 (mee).
October 19, 2021 Filing 188 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Sophia Cope. Pay.gov Agency Tracking ID FLSDC-AFLSDC-15102053. Filing Fee $ 200.00 by Electronic Frontier Foundation. Attorney Deanna Kendall Shullman added to party Electronic Frontier Foundation(pty:am). Responses due by 11/2/2021 (Attachments: #1 Text of Proposed Order Proposed Order)(Shullman, Deanna)
October 15, 2021 Filing 187 Notice of Correction - Clerk's Notice to Filer on 10/14/2021 at entries 184, 185, and 186 entered in error. Modifications have been made by the Clerk's Office to entries #181 , #182 , and #183 . These modifications correct the Clerk's error which incorrectly notified filers that "[t]he filed document was not correctly linked to the related docket entry." No further action needed. (yar)
October 14, 2021 Filing 186 Clerks Notice to Filer re #183 Reply to Response to Motion. Incorrect Document Link; ERROR - The filed document was not correctly linked to the related docket entry. The correction was made by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual. (ebz)
October 14, 2021 Filing 185 Clerks Notice to Filer re #182 Reply to Response to Motion. Incorrect Document Link; ERROR - The filed document was not correctly linked to the related docket entry. The correction was made by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual. (ebz)
October 14, 2021 Filing 184 Clerks Notice to Filer re #181 Reply to Response to Motion. Incorrect Document Link; ERROR - The filed document was not correctly linked to the related docket entry. The correction was made by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual. (ebz)
October 14, 2021 Filing 183 MIDDLE EAST NEWS FZ-LLC'S REPLY IN FURTHER SUPPORT OF #169 MOTION TO DISMISS #135 FIRST AMENDED COMPLAINT. Modified to reflect correct link on 10/15/2021 (mr1).
October 14, 2021 Filing 182 MASHAREA WA ENJAZAT IT CORPORATION LLC'S REPLY IN FURTHER SUPPORT OF #168 MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT #135 Amended Complaint/Amended Notice of Removal. Modified to correct link on 10/15/2021 (mr1).
October 14, 2021 Filing 181 SAUD AL QAHTANI'S REPLY TO PLAINTIFF'S OPPOSITION to #164 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal. Modified to reflect correct link on 10/15/2021 (mr1).
October 14, 2021 Filing 180 REPLY to Response to Motion re #167 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, filed by Bader Al-Asaker. (Cochran, Justin)
October 14, 2021 Filing 179 REPLY to Response to Motion re #166 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, filed by Prince Mohammed Bin Salman Abdulaziz Foundation. (Cochran, Justin)
October 14, 2021 Filing 178 REPLY to Response to Motion re #165 MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, filed by DarkMatter. (Binhak, Stephen)
October 14, 2021 Filing 177 REPLY to Response to Motion re #163 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, filed by Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (Kruppa, Andrew)
October 14, 2021 Filing 176 REPLY to #172 Response in Opposition to Motion,,,,, by Sam Jundi, Christanne Schey, Annette Smith, Sharon Van Rider. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit)(Jimenez, Marcos)
October 14, 2021 Filing 175 Reply to Response in Support re #161 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, filed by Mohammed Bin Salman Bin Abdulaziz Al Saud. (Brodsky, Benjamin) Modified text on 10/14/2021 (jas).
September 24, 2021 Opinion or Order Filing 174 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants' Consent Motion for Leave to File Excess Pages. #173 . Therein, all fifteen (15) Defendants in this action join to request leave to file reply briefs in support of their motions to dismiss collectively totaling no more than 120 pages, with specific page limits allotted to various groups of Defendants. Id. at 1. Local Rules "serve more than a technical purpose, and are held in great esteem by courts around the country." State Farm Mut. Auto. Ins. Co. v. B&A Diagnostic, Inc., 145 F. Supp. 3d 1154, 1158 (S.D. Fla. 2015). Local Rule 7.1(c) provides that without prior permission from the Court, a reply memorandum shall not exceed ten (10) pages. S.D. Fla. L.R. 7.1(c)(2). A "reply memorandum shall be strictly limited to rebuttal of matters raised in the memorandum in opposition without reargument of matters covered in the movant's initial memorandum of law." Id. 7.1(c)(1). Here, Defendants argue that if each Defendant were to file a separate ten (10)-page reply brief, as the Local Rules allow, their reply briefs would collectively total 150 pages. Id. at 2. Defendants are correct that if each Defendant filed a motion to dismiss individually, the Court would also allow them to file reply briefs individually, which would collectively total up to 150 pages. However, here some Defendants joined with others to file a total of nine (9) motions to dismiss, and thus the Court anticipates nine (9) reply briefs and a collective total of no more than ninety (90) pages in support thereof. To the extent Defendants argue that their requested collective total of 120 pages in reply briefs serves the interest of judicial economy, the Court rejects that argument. The Court has reviewed the various motions to dismiss and finds that there are three general bases for dismissal alleged that are common to most Defendants; specifically, each Motion alleges some combination of the following: (1) lack of personal jurisdiction; (2) lack of subject matter jurisdiction; and/or (3) failure to state a claim upon which relief may be requested. Defendants have had adequate opportunities to brief the thrust of their arguments in their opening motions. Now, Defendants must narrow their arguments to rebuttal of matters Plaintiff raised in her opposition, which totals sixty (60) pages and addresses all nine (9) motions to dismiss on behalf of all fifteen (15) Defendants. The Court finds that the page limit set by the local rules is appropriate. UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendants' Consent Motion for Leave to File Excess Pages #173 is DENIED. Signed by Judge K. Michael Moore on 9/24/2021. (hwr)
September 23, 2021 Filing 173 Consent MOTION for Leave to File Excess Pages (on behalf of Defendants) by Mohammed Bin Salman Bin Abdulaziz Al Saud. (Attachments: #1 Text of Proposed Order)(Brodsky, Benjamin)
September 20, 2021 Filing 172 RESPONSE in Opposition re #167 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, , #166 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, , #161 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, , #168 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, , #163 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, , #164 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM , #169 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, , #162 MOTION to Dismiss with Prejudice #135 Amended Complaint/Amended Notice of Removal, , #165 MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, filed by Ghada Oueiss. Replies due by 9/27/2021. (Marcus, Jeffrey)
September 7, 2021 Opinion or Order Filing 171 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's Unopposed Motion to File One Omnibus Opposition to Defendants' Motions to Dismiss and for an Enlargement of Pages for Omnibus Opposition. #170 . Therein, Plaintiff seeks leave to file an omnibus opposition of no more than sixty (60) pages in response to nine (9) motions to dismiss filed on behalf of all Defendants in this action. See generally id. Plaintiff argues the extension sought "will present Ms. Oueiss with an opportunity to fully address each of the Defendants' distinguishing factual circumstances and arguments, which weigh on the merits of each of their arguments in favor of dismissal," and "will serve to streamline this case and allow for a more effective resolution of all Motions to Dismiss that have been filed in this matter." Id. at 2-3. The Court finds good cause to enlarge the page limit set by Rule 7.1(c) of the Local Rules of the Southern District of Florida. See generally id. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Plaintiff's Unopposed Motion to File One Omnibus Opposition to Defendants' Motions to Dismiss and for an Enlargement of Pages for Omnibus Opposition #170 is GRANTED. Plaintiff's forthcoming omnibus response in opposition to all pending motion to dismiss shall not exceed sixty (60) pages. Signed by Judge K. Michael Moore on 9/7/2021. (hwr)
September 3, 2021 Filing 170 Unopposed MOTION for Leave to File Excess Pages and to File One Omnibus Opposition to Defendants' Motions to Dismiss by Ghada Oueiss. (Attachments: #1 Text of Proposed Order)(Marcus, Jeffrey)
August 2, 2021 Filing 169 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, ( Responses due by 8/16/2021) by Middle East News, FZ-LLC. (Baltodano-Sheehan, Evelyn)
August 2, 2021 Filing 168 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, ( Responses due by 8/16/2021) by Masharea wa Enjazat IT Corporation LLC. (Baltodano-Sheehan, Evelyn)
August 2, 2021 Filing 167 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, by Bader Al-Asaker. Responses due by 8/16/2021 (Cochran, Justin)
August 2, 2021 Filing 166 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, by Prince Mohammed Bin Salman Abdulaziz Foundation. Responses due by 8/16/2021 (Cochran, Justin)
August 2, 2021 Filing 165 MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, by DarkMatter. Responses due by 8/16/2021 (Binhak, Stephen)
August 2, 2021 Filing 164 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Saud Al Qahtani. Responses due by 8/16/2021 (Markus, David)
August 2, 2021 Filing 163 MOTION TO DISMISS #135 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #135 Amended Complaint/Amended Notice of Removal, ( Responses due by 8/16/2021) by Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (Kruppa, Andrew)
August 2, 2021 Filing 162 MOTION to Dismiss with Prejudice #135 Amended Complaint/Amended Notice of Removal, by Sam Jundi, Christanne Schey, Annette Smith, Sharon Van Rider. Responses due by 8/16/2021 (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Jimenez, Marcos)
August 2, 2021 Filing 161 MOTION to Dismiss #135 Amended Complaint/Amended Notice of Removal, by Mohammed Bin Salman Bin Abdulaziz Al Saud. Responses due by 8/16/2021 (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Affidavit)(Brodsky, Benjamin)
July 28, 2021 Opinion or Order Filing 160 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Sharon Van Rider, Christianne Schey, Sam Jundi, and Annette Smith's ("USA Defendants") Unopposed Motion for Leave to File Additional Pages. #159 . Therein, USA Defendants request leave to file a thirty (30) page motion to dismiss Plaintiff's Amended Complaint because USA Defendants "intend to argue that Plaintiff's new pleading fails to state a claim upon which relief can be granted, based both on discretionary principles and substantive flaws." Id. at 2. USA Defendants acknowledge that Plaintiff brings three claims against them, all under Florida law. Id. However, in the initial Complaint, Plaintiff brought eight claims against USA Defendants, including violations of both federal law and Florida law. See generally #1 . And, USA Defendants were able to file an initial Motion to Dismiss within the twenty (20) page limitation imposed by the Court's Local Rules. See #32 . Here, the Court does not find good cause to enlarge the page limitation where Plaintiff's claims against USA Defendants have been reduced to three claims under Florida law. See generally #135 . Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that USA Defendants' Unopposed Motion for Leave to File Additional Pages #159 is DENIED. USA Defendants' forthcoming motion to dismiss shall not exceed twenty (20) pages. Signed by Judge K. Michael Moore on 7/28/2021. (hwr)
July 27, 2021 Filing 159 Unopposed MOTION for Leave to File Excess Pages by Sam Jundi, Christanne Schey, Annette Smith, Sharon Van Rider. Attorney Marcos Daniel Jimenez added to party Sam Jundi(pty:dft), Attorney Marcos Daniel Jimenez added to party Sharon Van Rider(pty:dft). (Attachments: #1 Text of Proposed Order)(Jimenez, Marcos)
July 27, 2021 Opinion or Order Filing 158 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Dark Matter's ("Defendant") Unopposed Motion for Leave to File Additional Pages. #157 . Therein, Defendant requests leave to file a thirty (30) page motion to dismiss Plaintiff's Amended Complaint because Defendant intends to raise several defenses including lack of personal jurisdiction, common-law foreign official immunity, and failure to state a claim upon which relief can be granted. Id. at 2. Defendant argues that an enlargement of the page limit set by Rule 7.1(c) of the Local Rules of the Southern District of Florida is needed "[t]o address all of the matters that are appropriate for the Court to consider on these issues." Id. at 3. The Court finds good cause to enlarge the page limit set by the Local Rules of the Southern District of Florida. See generally id. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendant's Unopposed Motion for Leave to File Additional Pages #157 is GRANTED. Defendant's forthcoming motion to dismiss shall not exceed thirty (30) pages. Signed by Judge K. Michael Moore on 7/27/2021. (hwr)
July 26, 2021 Filing 157 Unopposed MOTION for Leave to File Excess Pages by DarkMatter. (Attachments: #1 Text of Proposed Order)(Binhak, Stephen)
July 26, 2021 Opinion or Order Filing 156 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Mohammed bin Salman bin Abdulaziz Al Saud's ("Defendant") Consent Motion for Leave to File Excess Pages. #155 . Therein, Defendant requests leave to file a brief of no more than fifty (50) pages in support of his forthcoming motion to dismiss the Amended Complaint. Id. at 1. Defendant argues that an enlargement of the page limit set by Rule 7.1(c) of the Local Rules of the Southern District of Florida is justified "[g]iven the complexity and number of the issues raised by [Plaintiff's] numerous claims." Id. at 2. Further, Defendant "expects that many of the arguments made in his briefing will be adopted by other Defendants," and an enlargement of the page limit will "serve to streamline the presentation of issues to the Court and reduce the overall amount of briefing submitted to the Court." Id. While the Court previously granted Defendant's request for an enlargement of the page limit in responding to Plaintiff's initial Complaint, given the volume of incoming motions to dismiss that the Court anticipates and in the interest of judicial economy, the Court will only permit a brief enlargement of the page limit. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendant's Consent Motion for Leave to File Excess Pages #155 is GRANTED IN PART and DENIED IN PART. Defendant's forthcoming motion to dismiss shall not exceed thirty (30) pages. Signed by Judge K. Michael Moore on 7/26/2021. (hwr)
July 23, 2021 Filing 155 Consent MOTION for Leave to File Excess Pages by Mohammed Bin Salman Bin Abdulaziz Al Saud. (Attachments: #1 Exhibit)(Brodsky, Benjamin)
July 1, 2021 Opinion or Order Filing 154 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Masharea wa Enjazat IT Corporation LLC and Middle East News, FZ-LLC's ("Defendants") Motion for John Lu to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #152 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #152 is GRANTED. John Lu may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to jlu@milbank.com. Signed by Judge K. Michael Moore on 7/1/2021. (hwr)
July 1, 2021 Opinion or Order Filing 153 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Masharea wa Enjazat IT Corporation LLC and Middle East News, FZ-LLC's ("Defendants") Motion for Adam Fee to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #151 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #151 is GRANTED. Adam Fee may appear pro hac vice in this matter. The Clerk of Court shall provide electronic notification of all electronic filings to afee@milbank.com. Signed by Judge K. Michael Moore on 7/1/2021. (hwr)
June 30, 2021 Filing 152 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for John Lu. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See #67 Motion to Appear Pro Hac Vice, by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC. Responses due by 7/14/2021 (Attachments: #1 Text of Proposed Order)(Baltodano-Sheehan, Evelyn)
June 30, 2021 Filing 151 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Adam Fee. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See #66 Motion to Appear Pro Hac Vice, by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC. Responses due by 7/14/2021 (Attachments: #1 Text of Proposed Order)(Baltodano-Sheehan, Evelyn)
June 29, 2021 Filing 150 NOTICE of Striking #147 Notice of Attorney Appearance filed by Middle East News, FZ-LLC, Masharea wa Enjazat IT Corporation LLC, #148 Notice of Attorney Appearance filed by Middle East News, FZ-LLC, Masharea wa Enjazat IT Corporation LLC by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria)
June 25, 2021 Filing 149 Clerks Notice to Filer re #147 Notice of Attorney Appearance, #148 Notice of Attorney Appearance. Wrong Event Selected - Parties must file a Motion to Appear Pro Hac Vice; CORRECTIVE ACTION REQUIRED - The Filer must file a Notice of Striking, then file a Motion to Appear Pro Hac Vice as required by Local Rule 4(b)(2) of the Rules Governing the Admission, Practice, Peer Review and Attorney Discipline. (cw)
June 24, 2021 Filing 148 STRICKEN NOTICE of Attorney Appearance by Daria Pustilnik on behalf of Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria) Modified per DE#150 Notice of Striking on 6/30/2021 (ebz).
June 24, 2021 Filing 147 STRICKEN NOTICE of Attorney Appearance by Daria Pustilnik on behalf of Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria) Modified per DE#150 Notice of Striking on 6/30/2021 (ebz).
June 24, 2021 Filing 146 NOTICE of Striking #142 Notice for PHV Attorney to Receive Electronic Notification filed by Middle East News, FZ-LLC, Masharea wa Enjazat IT Corporation LLC, #143 Notice for PHV Attorney to Receive Electronic Notification filed by Middle East News, FZ-LLC, Masharea wa Enjazat IT Corporation LLC by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria)
June 23, 2021 Filing 145 Clerks Notice to Filer re #143 Notice for PHV Attorney to Receive Electronic Notification. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match the typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and Local Rule 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (ebz)
June 23, 2021 Filing 144 Clerks Notice to Filer re #142 Notice for PHV Attorney to Receive Electronic Notification. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match the typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and Local Rule 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (ebz)
June 23, 2021 Filing 143 STRICKEN Notice to the Court for Pro Hac Vice Attorney to Receive Electronic Notification by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria) Modified per DE#146 Notice of Striking on 6/25/2021 (ebz).
June 23, 2021 Filing 142 STRICKEN Notice to the Court for Pro Hac Vice Attorney to Receive Electronic Notification by Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC (Pustilnik, Daria) Modified per DE#146 Notice of Striking on 6/25/2021 (ebz).
June 23, 2021 Filing 141 NOTICE of Attorney Appearance by Daria Pustilnik on behalf of Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC. Attorney Daria Pustilnik added to party Masharea wa Enjazat IT Corporation LLC(pty:dft), Attorney Daria Pustilnik added to party Middle East News, FZ-LLC(pty:dft). (Pustilnik, Daria)
June 23, 2021 Filing 140 NOTICE of Attorney Appearance by Evelyn Baltodano-Sheehan on behalf of Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC. Attorney Evelyn Baltodano-Sheehan added to party Masharea wa Enjazat IT Corporation LLC(pty:dft), Attorney Evelyn Baltodano-Sheehan added to party Middle East News, FZ-LLC(pty:dft). (Baltodano-Sheehan, Evelyn)
June 21, 2021 Opinion or Order Filing 139 PAPERLESS ORDER. THIS CAUSE came before the Court upon the Parties' Joint Motion for Briefing Schedule on Defendants' Motions to Dismiss the Amended Complaint. #138 . Therein, the Parties request an extended briefing schedule with the following deadlines: August 2, 2021 for Defendants to file motions to dismiss the Amended Complaint; September 20, 2021 for Plaintiff to file briefs in opposition to the motions to dismiss; and October 14, 2021 for Defendants to file reply briefs. Id. at 1. Rule 6(b) of the Federal Rules of Civil Procedure provides that "[w]hen an act may or must be done within a specified time, the court may, for good cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires...." Fed. R. Civ. P. 6(b)(1). Here, the Parties argue that good cause exists "given the serious allegations made in the 98-page, 311-paragrapah Amended Compliant and the host of complex factual and legal issues, including issues of personal and subject-matter jurisdiction and immunity, that Plaintiff's claims implicate." #138 at 2-3. The Court finds good cause to grant an extended briefing schedule. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Parties' Joint Motion for Briefing Schedule on Defendants' Motions to Dismiss the Amended Complaint #138 is GRANTED. Defendants' motions to dismiss shall be due on or before August 2, 2021; Plaintiff's responses in opposition shall be due on or before September 20, 2021; and Defendants' replies shall be due on or before October 14, 2021. Signed by Chief Judge K. Michael Moore on 6/21/2021. (hwr)
June 18, 2021 Filing 138 Joint MOTION for Briefing Schedule on Defendants' Motions to Dismiss the Amended Complaint re #135 Amended Complaint/Amended Notice of Removal, by Mohammed Bin Salman Bin Abdulaziz Al Saud. (Brodsky, Benjamin)
June 16, 2021 Filing 137 CLERK'S NOTICE of Compliance re 136 Order on Motions. Party Mohammed Bin Zayed Al Nahyan, Sharon Collins, Saudi 24 TV (a broadcast television station owned by the Kingdom of Saudi Arabia), Saudi Arabian Cultural Mission, Faisal al Bannai, Al Arabiya (a broadcast television station owned by the Ki ngdom of Saudi Arabia) and Hussam Al-Jundi terminated. (jas)
June 15, 2021 Opinion or Order Filing 136 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's filing of an Amended Complaint. #135 . The Amended Complaint moots Defendants' Motions to Dismiss #32 , #98 , #104 , #106 , #108 , #109 , #110 , #111 , #112 , #113 , #114 . Further, the Amended Complaint adds parties and eliminates the following parties: Mohammed Bin Zayed Al Nahyan, Faisal al Bannai, Saudi 24 TV, Al Arabiya, Saudi Arabian Cultural Mission, Sharon Collins, and Hussam Al-Jundi. See #135 at 1. UPON CONSIDERATION of the Amended Complaint #135 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that Defendants' Motions to Dismiss are DENIED AS MOOT. It is FURTHER ORDERED that the Clerk of Court shall TERMINATE Defendants Mohammed Bin Zayed Al Nahyan, Faisal al Bannai, Saudi 24 TV, Al Arabiya, Saudi Arabian Cultural Mission, Sharon Collins, and Hussam Al-Jundi as parties to this action. Signed by Chief Judge K. Michael Moore on 6/15/2021. (hwr)
June 14, 2021 Filing 135 AMENDED COMPLAINT against Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Saud Al Qahtani, Bader Al-Asaker, Turki Al-Owerde, Mohammed Bin Salman Bin Abdulaziz Al Saud, DarkMatter, John Doe, Prince Mohammed Bin Salman Abdulaziz Foundation, Christanne Schey, Annette Smith, Masharea wa Enjazat IT Corporation LLC, Middle East News, FZ-LLC, Sharon Van Rider, Sam Jundi, filed by Ghada Oueiss.(Rashbaum, Daniel)
May 18, 2021 Opinion or Order Filing 134 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's Unopposed Motion for Extension of Time to File Amended Complaint. #133 . Therein, Plaintiff requests a twenty-one (21) day extension of time to file her Amended Complaint "which will contain several new allegations regarding the hacking of her mobile device, among other allegations" and the additional time sought is needed "to integrate her factual findings into the Amended Complaint." Id. at 2. UPON CONSIDERATION of the Motion #133 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #133 is GRANTED. Plaintiff's Amended Complaint shall be due on or before June 14, 2021. Signed by Chief Judge K. Michael Moore on 5/18/2021. (hwr)
May 17, 2021 Filing 133 Unopposed MOTION for Extension of Time to File Amended Complaint by Ghada Oueiss. Responses due by 6/1/2021 (Rashbaum, Daniel)
April 7, 2021 Filing 132 Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Prince Mohammed Bin Salman Abdulaziz Foundation (Cochran, Justin)
April 5, 2021 Opinion or Order Filing 131 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's Motion for an Order Authorizing Expedited Jurisdictional Discovery Against the Foreign Defendants Or, in the Alternative, a Motion for Extension of Time to File an Amended Complaint. #129 . Therein, Plaintiff argues that "jurisdictional discovery is necessary as it will reveal that each of the Foreign Defendants conspired with one another--as well as the American Defendants (including two of the key co-conspirators domiciled in Florida)--to engage in the tortious acts committed against [Plaintiff]." Id. at 2. Further, Plaintiff argues that she "intends to file an Amended Complaint as she has recently discovered additional information relating to the hacking of her personal mobile device, among other facts." Id. Plaintiff requests that she be granted forty-five (45) days to file an Amended Complaint, and that the pending Motions to Dismiss--the last of which was filed on March 26, 2021--along with the accompanying briefing schedule, be held in abeyance. Id. Rule 15(a) of the Federal Rules of Civil Procedure provides that "[a] party may amend its pleading once as a matter of course within... 21 days after service of a motion under Rule 12(b), (e), or (f)." Fed. R. Civ. P. 15(a)(1)(B). Beyond that, "a party may amend its pleading only with the opposing party's written consent or the court's leave" and "[t]he court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2). The decision whether to grant leave to amend is committed to the sound discretion of the trial court. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines, Inc., 713 F.2d 618, 622 (11th Cir. 1983). However, "[u]nless there is a substantial reason to deny leave to amend, the discretion of the district court is not broad enough to permit denial." Dussouy v. Gulf Coast Inv. Corp., 660 F.2d 594, 598 (5th Cir. 1981). On April 5, 2021, the Court entered an Order granting eight (8) Motions to Stay filed by eighteen (18) named Defendants in this action. #130 . Therein, the Court ordered that "all pretrial obligations in this matter, including discovery, are STAYED until the Court resolves the pending Motions to Dismiss." Id. at 6. With the last Motion to Dismiss filed on March 26, 2021, Plaintiff's deadline to file an Amended Complaint under Fed. R. Civ. P. 15(a)(1)(B) is April 16, 2021. However, the Court does not find a substantial reason to deny Plaintiff's request to extend the time within which to file an Amended Complaint, and the Court will allow Plaintiff to do so under Fed. R. Civ. P. 15(a)(2). Accordingly, UPON CONSIDERATION of the Motion #129 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #129 is GRANTED IN PART and DENIED IN PART. Plaintiff's request for jurisdictional discovery is DENIED AS MOOT. See generally #130 . Plaintiff's Amended Complaint in this action shall be due on or before May 24, 2021. Because the filing of an Amended Complaint will moot the pending Motions to Dismiss, further briefing on the Motions to Dismiss #32 , #98 , #104 , #106 , #108 , #109 , #110 , #111 , #112 , #113 , #114 is hereby HELD IN ABEYANCE. Signed by Chief Judge K. Michael Moore on 4/5/2021. (hwr)
April 5, 2021 Opinion or Order Filing 130 ORDER GRANTING Motions to Stay #83 , #84 , #86 , #87 , #89 , #90 , #93 , #107 . Signed by Chief Judge K. Michael Moore on 4/5/2021. See attached document for full details. (hwr)
April 2, 2021 Filing 129 Plaintiff's MOTION for an Order Authorizing Expedited Jurisdictional Discovery Against the Foreign Defendants , or in the Alternative, Motion for Extension of Time to File Amended Complaint by Ghada Oueiss. (Rashbaum, Daniel)
April 1, 2021 Filing 128 RESPONSE in Support re #89 MOTION to Stay Discovery and Pretrial Deadlines filed by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. (Cochran, Justin)
April 1, 2021 Filing 127 REPLY to Response to Motion re #87 Defendant's MOTION to Adopt/Join #84 MOTION to Stay Discovery and Pretrial Deadlines, #83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES Joinder by Defendants Faisal Al Menaia, Awwad Al Otaibi, Turki Al Owedre and Tar filed by Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (Kruppa, Andrew)
April 1, 2021 Filing 126 REPLY to Response to Motion re #84 MOTION to Stay Discovery and Pretrial Deadlines filed by Saud Al Qahtani. (Markus, David)
April 1, 2021 Filing 125 REPLY to Response to Motion re #90 MOTION to Stay Discovery and Pretrial Deadlines filed by Al Arabiya, Saudi 24 TV. (Baltodano-Sheehan, Evelyn)
April 1, 2021 Filing 124 REPLY to Response to Motion re #86 Amended MOTION to Stay re #85 MOTION to Stay Discovery Pending Ruling on Jurisdictional Matters filed by DarkMatter, Faisal al Bannai. (Binhak, Stephen)
April 1, 2021 Filing 123 REPLY to Response to Motion re #83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES filed by Mohammed Bin Salman Bin Abdulaziz Al Saud, Saudi Arabian Cultural Mission. (Brodsky, Benjamin)
April 1, 2021 Filing 122 RESPONSE in Support re #93 Defendant's MOTION to Stay Discovery and Pretrial Deadlines with Supporting Memorandum of Law filed by Hussam Al-Jundi, Sharon Collins, Christanne Schey, Annette Smith. (Jimenez, Marcos)
March 31, 2021 Opinion or Order Filing 121 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Amended Motion for Ze-Wen Julius Chen to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #120 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #120 is GRANTED. Ze-Wen Julius Chen may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to chenj@akingump.com. Signed by Chief Judge K. Michael Moore on 3/31/2021. (hwr)
March 30, 2021 Filing 120 Amended MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Ze-Wen Julius Chen. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See #101 Motion to Appear Pro Hac Vice, by Mohammed Bin Zayed Al Nahyan. Responses due by 4/13/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Heise, Mark)
March 30, 2021 Opinion or Order Filing 119 PAPERLESS ORDER. THIS CAUSE came before the Court upon a sua sponte examination of the record. On March 29, 2021, the Court entered a Paperless Order granting Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Motion for Z.W. Julius Chen to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing #101 . 116 . However, the Clerk's Office has determined that attorney Z.W. Julius Chen is not a member of the Bar(s) listed in the Motion #101 . Accordingly, it is ORDERED AND ADJUDGED that the Paperless Order 116 is STRICKEN. The Clerk of Court is instructed to STRIKE the Paperless Order granting Defendant's Motion for Z.W. Julius Chen to Appear Pro Hac Vice 116 . It is FURTHER ORDERED that any subsequent motion for Z.W. Julius Chen to appear pro hac vice shall include the name in which he is admitted to the Bar. Signed by Chief Judge K. Michael Moore on 3/30/2021. (hwr)
March 29, 2021 Opinion or Order Filing 118 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Motion for Hal S. Shapiro to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #103 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #103 is GRANTED. Hal S. Shapiro may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to hshapiro@akingump.com. Signed by Chief Judge K. Michael Moore on 3/29/2021. (hwr)
March 29, 2021 Opinion or Order Filing 117 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Motion for Pratik A. Shah to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #102 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #102 is GRANTED. Pratik A. Shah may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to pshah@akingump.com. Signed by Chief Judge K. Michael Moore on 3/29/2021. (hwr)
March 29, 2021 Opinion or Order Filing 116 STRICKEN per DE# 119 , PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Motion for Z.W. Julius Chen to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #101 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #101 is GRANTED. Z.W. Julius Chen may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to chenj@akingump.com. Signed by Chief Judge K. Michael Moore on 3/29/2021. (hwr) Modified text on 3/30/2021 (jas).
March 29, 2021 Opinion or Order Filing 115 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant H.H. Sheikh Mohamed Bin Zayed Al Nahyan's ("Defendant") Motion for Stephen M. Baldini to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #100 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #100 is GRANTED. Stephen M. Baldini may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to sbaldini@akingump.com. Signed by Chief Judge K. Michael Moore on 3/29/2021. (hwr)
March 26, 2021 Filing 114 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Complaint ( Responses due by 4/9/2021) by Saudi 24 TV. (Attachments: #1 Declaration of Turki A. Salman)(Baltodano-Sheehan, Evelyn)
March 26, 2021 Filing 113 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Complaint ( Responses due by 4/9/2021) by Prince Mohammed Bin Salman Abdulaziz Foundation. (Cochran, Justin)
March 26, 2021 Filing 112 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Complaint ( Responses due by 4/9/2021) by Bader Al-Asaker. (Cochran, Justin)
March 26, 2021 Filing 111 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Complaint ( Responses due by 4/9/2021) by Al Arabiya. (Attachments: #1 Declaration of Mamdouh Eissa M. Alshammari)(Baltodano-Sheehan, Evelyn)
March 26, 2021 Filing 110 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint , MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM ( Responses due by 4/9/2021) by Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (Attachments: #1 Exhibit 1)(Kruppa, Andrew)
March 26, 2021 Filing 109 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint , MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM ( Responses due by 4/9/2021) by Saud Al Qahtani. (Attachments: #1 Exhibit)(Markus, David)
March 26, 2021 Filing 108 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint , MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM ( Responses due by 4/9/2021) by DarkMatter, Faisal al Bannai. (Attachments: #1 Text of Proposed Order)(Binhak, Stephen)
March 26, 2021 Filing 107 Defendant's MOTION to Stay Discovery and Pretrial Deadlines by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Heise, Mark)
March 26, 2021 Filing 106 Defendant's MOTION to Dismiss with Prejudice #1 Complaint by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Heise, Mark)
March 26, 2021 Filing 105 AFFIDAVIT in Support re #104 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint filed by Saudi Arabian Cultural Mission. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Brodsky, Benjamin)
March 26, 2021 Filing 104 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint by Saudi Arabian Cultural Mission. Responses due by 4/9/2021 (Brodsky, Benjamin)
March 26, 2021 Filing 103 Defendant's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Hal S. Shapiro. Filing Fee $ 200.00 Receipt # AFLSDC-14557959 by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Heise, Mark)
March 26, 2021 Filing 102 Defendant's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Pratik A. Shah. Filing Fee $ 200.00 Receipt # AFLSDC-14557951 by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Heise, Mark)
March 26, 2021 Filing 101 Defendant's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Z.W. Julius Chen. Filing Fee $ 200.00 Receipt # AFLSDC-14557941 by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Heise, Mark)
March 26, 2021 Filing 100 Defendant's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Stephen M. Baldini. Filing Fee $ 200.00 Receipt # AFLSDC-14557927 by Mohammed Bin Zayed Al Nahyan. Responses due by 4/9/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Heise, Mark)
March 26, 2021 Filing 99 AFFIDAVIT in Support re #98 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint filed by Mohammed Bin Salman Bin Abdulaziz Al Saud. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Brodsky, Benjamin)
March 26, 2021 Filing 98 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint by Mohammed Bin Salman Bin Abdulaziz Al Saud. Responses due by 4/9/2021 (Brodsky, Benjamin)
March 25, 2021 Filing 97 RESPONSE in Opposition to Defendants' Motions to Stay Discovery and Pretrial Deadlines #83 #84 [85-86] #87 #89 #90 #93 by Ghada Oueiss. (Attachments: #1 Declaration of Jeffrey E. Marcus, Esq.)(Rashbaum, Daniel)
March 23, 2021 Opinion or Order Filing 96 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants DarkMatter and Faisal Al Bannai's ("Defendants") Unopposed Motion for Leave to File a Motion to Dismiss Which Exceeds Twenty Pages. #95 . Therein, Defendants request leave to exceed the page limit set by Rule 7.1(c) of the Local Rules of the Southern District of Florida. Id. at 1-2. Defendants argue that an enlargement of the page limit is warranted because Defendants "intend to file a single Motion to Dismiss the Complaint" and they "intend to raise several defenses including lack of personal jurisdiction... and failure to state claim upon which relief can be granted." Id. at 1. The Court finds good cause to enlarge the page limitation set by the Local Rules of the Southern District of Florida. See generally id. Accordingly, UPON CONSIDERATION of the Motion #95 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendants' Unopposed Motion for Leave to File a Motion to Dismiss Which Exceeds Twenty Pages #95 is GRANTED. Defendants' forthcoming Motion to Dismiss shall not exceed thirty (30) pages. Signed by Chief Judge K. Michael Moore on 3/23/2021. (hwr)
March 22, 2021 Filing 95 Unopposed MOTION for Leave to File Excess Pages (Motion to Dismiss) by DarkMatter, Faisal al Bannai. (Attachments: #1 Text of Proposed Order)(Binhak, Stephen)
March 22, 2021 Filing 94 Joint SCHEDULING REPORT - Rule 26(f) by Ghada Oueiss (Attachments: #1 Exhibit A - Plaintiff's Proposed Order Setting Pretrial Deadlines, Pretrial Conference and Trial Date)(Mays, Jason)
March 12, 2021 Filing 93 Defendant's MOTION to Stay Discovery and Pretrial Deadlines with Supporting Memorandum of Law by Hussam Al-Jundi, Sharon Collins, Christanne Schey, Annette Smith. Responses due by 3/26/2021 (Jimenez, Marcos)
March 11, 2021 Opinion or Order Filing 92 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's Consent Motion to File One Omnibus Response in Opposition to Defendants' Motions to Stay and for an Extension of Time to File the Omnibus Response. #91 . Therein, Plaintiff requests that the Court permit her to (1) file one Omnibus Opposition to several pending Motions to Stay from various Defendants in this matter #83 , #84 , #85 , #86 , #87 , #89 , #90 , as well as one that is imminently forthcoming; (2) file the Omnibus Opposition with fourteen (14) days of the Court's Order on the instant Motion; and (3) exceed the page limit set by the Court's Local Rules for the Omnibus Opposition to allow an additional ten (10) pages, for a total of thirty (30). Id. at 34. Plaintiff argues that "it is in the best interests of judicial efficiency and economy for her to file an Omnibus Opposition to each Motion to Stay, addressing all legal and factual arguments at once, to avoid presenting the Court with numerous filings and significant legal issues in a piecemeal fashion." Id. at 4. UPON CONSIDERATION of the Motion #91 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #91 is GRANTED. Plaintiff's Omnibus Opposition to the various Motions to Stay that are currently pending #83 , #84 , #85 , #86 , #87 , #89 , #90 , and one additional forthcoming motion, shall be due on or before March 25, 2021, and shall not exceed thirty (30) pages in length. Signed by Chief Judge K. Michael Moore on 3/11/2021. (hwr)
March 10, 2021 Filing 91 Consent MOTION for Extension of Time to File Response/Reply/Answer as to #90 MOTION to Stay Discovery and Pretrial Deadlines, #85 MOTION to Stay Discovery Pending Ruling on Jurisdictional Matters, #89 MOTION to Stay Discovery and Pretrial Deadlines, #87 Defendant's MOTION to Adopt/Join #84 MOTION to Stay Discovery and Pretrial Deadlines, #83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES Joinder by Defendants Faisal Al Menaia, Awwad Al Otaibi, Turki Al Owedre and Tar, #84 MOTION to Stay Discovery and Pretrial Deadlines, #83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES, #86 Amended MOTION to Stay re #85 MOTION to Stay Discovery Pending Ruling on Jurisdictional Matters , and to File One Omnibus Response of 30 Pages by Ghada Oueiss. (Rashbaum, Daniel)
March 9, 2021 Filing 90 MOTION to Stay Discovery and Pretrial Deadlines by Al Arabiya, Saudi 24 TV. Responses due by 3/23/2021 (Attachments: #1 Text of Proposed Order)(Baltodano-Sheehan, Evelyn)
March 9, 2021 Filing 89 MOTION to Stay Discovery and Pretrial Deadlines by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. Responses due by 3/23/2021 (Attachments: #1 Text of Proposed Order)(Cochran, Justin)
March 9, 2021 Filing 88 CERTIFICATE of Counsel Dark Matter Corporate Disclosure Statement by Stephen James Binhak on behalf of DarkMatter (Binhak, Stephen)
March 9, 2021 Filing 87 Defendant's MOTION to Adopt/Join #84 MOTION to Stay Discovery and Pretrial Deadlines, #83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES Joinder by Defendants Faisal Al Menaia, Awwad Al Otaibi, Turki Al Owedre and Tarek AbouZeinab in Motions to Stay Discovery and Pretrial Deadlines Filed by Mohammed Bin Salman Bin Abdulaziz Al Saud, The Saudi Arabian Cultural Mission (DE 83) and Saud Alqahtani (DE84) by Tarek Abou Zeinab, Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (Kruppa, Andrew)
March 9, 2021 Filing 86 Amended MOTION to Stay re #85 MOTION to Stay Discovery Pending Ruling on Jurisdictional Matters by DarkMatter, Faisal al Bannai. Responses due by 3/23/2021 (Attachments: #1 Text of Proposed Order)(Binhak, Stephen)
March 8, 2021 Filing 85 MOTION to Stay Discovery Pending Ruling on Jurisdictional Matters by DarkMatter, Faisal al Bannai. Responses due by 3/22/2021 (Attachments: #1 Text of Proposed Order)(Binhak, Stephen)
March 5, 2021 Filing 84 MOTION to Stay Discovery and Pretrial Deadlines by Saud Al Qahtani. Responses due by 3/19/2021 (Attachments: #1 Text of Proposed Order)(Markus, David)
March 3, 2021 Filing 83 MOTION to Stay DISCOVERY AND PRETRIAL DEADLINES by Mohammed Bin Salman Bin Abdulaziz Al Saud, Saudi Arabian Cultural Mission. Attorney Benjamin Henry Brodsky added to party Saudi Arabian Cultural Mission(pty:dft). Responses due by 3/17/2021 (Brodsky, Benjamin)
March 1, 2021 Opinion or Order Filing 82 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants DarkMatter and Faisal al Bannai's ("Defendants") Motion for James E. Tysse to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #79 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #79 is GRANTED. James E. Tysse may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to jtysse@akingump.com. Signed by Chief Judge K. Michael Moore on 3/1/2021. (hwr)
March 1, 2021 Opinion or Order Filing 81 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants DarkMatter and Faisal al Bannai's ("Defendants") Motion for Anthony T. Pierce to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #78 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #78 is GRANTED. Anthony T. Pierce may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to apierce@akingump.com. Signed by Chief Judge K. Michael Moore on 3/1/2021. (hwr)
March 1, 2021 Opinion or Order Filing 80 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants DarkMatter and Faisal al Bannai's ("Defendants") Motion for Natasha G. Kohne to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #77 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #77 is GRANTED. Natasha G. Kohne may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to nkohne@akingump.com. Signed by Chief Judge K. Michael Moore on 3/1/2021. (hwr)
February 28, 2021 Filing 79 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for James E. Tysse. Filing Fee $ 200.00 Receipt # AFLSDC-14463267 by DarkMatter, Faisal al Bannai. Responses due by 3/15/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Binhak, Stephen)
February 28, 2021 Filing 78 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Anthony T. Pierce. Filing Fee $ 200.00 Receipt # AFLSDC-14463265 by DarkMatter, Faisal al Bannai. Responses due by 3/15/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Binhak, Stephen)
February 28, 2021 Filing 77 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Natasha G. Khone. Filing Fee $ 200.00 Receipt # AFLSDC-14463263 by DarkMatter, Faisal al Bannai. Responses due by 3/15/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Binhak, Stephen)
February 22, 2021 Opinion or Order Filing 76 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Bader Al-Asaker and Prince Mohammed Bin Salman Abdulaziz Foundation's ("Defendants") Unopposed Motion to Withdraw as Attorney. #75 . Therein, Defendants move to permit Candace R. Jackson of Zuckerman Spaeder LLP to withdraw as counsel for Defendants. Id. Defendants argue that counsel of record Justin R. Cochran, William W. Taylor, III, and Ivano M. Ventresca of Zuckerman Spaeder LLP will continue to represent Defendants in this matter. Id. UPON CONSIDERATION of the Motion #75 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendants' Unopposed Motion to Withdraw as Attorney #75 is GRANTED. Candace R. Jackson shall be relieved of all further responsibilities related to Defendants in these proceedings. The Clerk of Court is INSTRUCTED to remove Candace R. Jackson as counsel for Defendants. Signed by Chief Judge K. Michael Moore on 2/22/2021. (hwr)
February 19, 2021 Filing 75 Unopposed MOTION to Withdraw as Attorney by Candace R. Jackson for / by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. Responses due by 3/5/2021 (Cochran, Justin)
February 16, 2021 Filing 74 NOTICE of Change of Address, Email or Law Firm Name by Stephen James Binhak (Binhak, Stephen)
February 11, 2021 Opinion or Order Filing 73 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Saudi 24 TV and Al Arabiya's ("Defendants") Motion for John Lu to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #67 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #67 is GRANTED. John Lu may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to jlu@milbank.com. Signed by Chief Judge K. Michael Moore on 2/11/2021. (hwr)
February 11, 2021 Opinion or Order Filing 72 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Saudi 24 TV and Al Arabiya's ("Defendants") Motion for Adam Fee to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #66 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #66 is GRANTED. Adam Fee may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to afee@milbank.com. Signed by Chief Judge K. Michael Moore on 2/11/2021. (hwr)
February 11, 2021 Opinion or Order Filing 71 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Al Arabiya and Saudi 24 TV's ("Defendants") Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. #68 . Therein, Defendants request an extension through March 26, 2021 to respond to Plaintiff's Complaint. Id. at 1. Defendants argue that the extension is warranted because "Plaintiff's claims raise complex factual and legal issues, including issues of personal and subject-matter jurisdiction and immunity," and "the extension would align [Defendants'] deadline for responding to the complaint with that of several other defendants which would promote judicial efficiency because [Defendants] expect that they will adopt in whole or in part some of the arguments made by other defendants whose response deadline is March 26, 2021." Id. at 2. UPON CONSIDERATION of the Motion #63 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendants' Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint is GRANTED. Defendants' response to Plaintiff's Complaint shall be due on or before March 26, 2021. Signed by Chief Judge K. Michael Moore on 2/11/2021. (hwr)
February 11, 2021 Opinion or Order Filing 70 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Tarek Abou Zeinab's ("Defendant") Unopposed Motion for Extension of Time to Respond to the Complaint. #63 . Therein, Defendant requests an extension through March 26, 2021 to respond to Plaintiff's Complaint. Id. at 2. Defendant argues that the extension will afford him sufficient time to investigate the "host of complex factual and legal issues, including issues of personal and subject-matter jurisdiction and immunity" raised in Plaintiff's Complaint, and will "provide for the same response deadline currently set for the majority of other Defendants in this matter." Id. UPON CONSIDERATION of the Motion #63 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendant's Unopposed Motion for Extension of Time to Respond to the Complaint is GRANTED. Defendant's response to Plaintiff's Complaint shall be due on or before March 26, 2021. Signed by Chief Judge K. Michael Moore on 2/11/2021. (hwr)
February 11, 2021 Filing 69 CLERK'S NOTICE - Local counsel, Evelyn B. Sheehan, must file documents under the name listed on the SDFL Roll of Attorneys, Evelyn Baltodano-Sheehan. See #www.flsd.uscourts.gov/name-changes. It is not necessary to refile these motions. re #67 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for John Lu. Filing Fee $ 200.00 Receipt # AFLSDC-14369293, #66 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Adam Fee. Filing Fee $ 200.00 Receipt # AFLSDC-14369279. (pt)
February 10, 2021 Filing 68 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by Al Arabiya, Saudi 24 TV. (Attachments: #1 Text of Proposed Order)(Pustilnik, Daria)
February 10, 2021 Filing 67 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for John Lu. Filing Fee $ 200.00 Receipt # AFLSDC-14369293 by Al Arabiya, Saudi 24 TV. Responses due by 2/24/2021 (Attachments: #1 Text of Proposed Order)(Baltodano-Sheehan, Evelyn)
February 10, 2021 Filing 66 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Adam Fee. Filing Fee $ 200.00 Receipt # AFLSDC-14369279 by Al Arabiya, Saudi 24 TV. Responses due by 2/24/2021 (Attachments: #1 Text of Proposed Order)(Baltodano-Sheehan, Evelyn)
February 10, 2021 Filing 65 NOTICE of Attorney Appearance by Daria Pustilnik on behalf of Al Arabiya, Saudi 24 TV. Attorney Daria Pustilnik added to party Al Arabiya(pty:dft), Attorney Daria Pustilnik added to party Saudi 24 TV(pty:dft). (Pustilnik, Daria)
February 10, 2021 Filing 64 NOTICE of Attorney Appearance by Evelyn Baltodano-Sheehan on behalf of Al Arabiya, Saudi 24 TV. Attorney Evelyn Baltodano-Sheehan added to party Al Arabiya(pty:dft), Attorney Evelyn Baltodano-Sheehan added to party Saudi 24 TV(pty:dft). (Baltodano-Sheehan, Evelyn)
February 10, 2021 Filing 63 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by Tarek Abou Zeinab. (Attachments: #1 Text of Proposed Order Text of Proposed Order)(Kruppa, Andrew)
February 10, 2021 Filing 62 NOTICE of Attorney Appearance by Andrew Russell Kruppa on behalf of Tarek Abou Zeinab. Attorney Andrew Russell Kruppa added to party Tarek Abou Zeinab(pty:dft). (Kruppa, Andrew)
February 10, 2021 Filing 61 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Ghada Oueiss. (Attachments: #1 Proof of Service - Tarek Abou Zeinab)(Mays, Jason)
February 9, 2021 Opinion or Order Filing 60 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Saud Al Qahtani's Motion for Barry J. Pollack to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #53 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #53 is GRANTED. Barry J. Pollack may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to barryjpollack@gmail.com. Signed by Chief Judge K. Michael Moore on 2/9/2021. (hwr)
February 9, 2021 Opinion or Order Filing 59 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Bader Al-Asaker and Prince Mohammed Bin Salman Abdulaziz Foundation d/b/a MiSK Foundation's ("Defendants") Motion for William W. Taylor, III to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #51 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #51 is GRANTED. William W. Taylor, III may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to wtaylor@zuckerman.com. Signed by Chief Judge K. Michael Moore on 2/9/2021. (hwr)
February 9, 2021 Opinion or Order Filing 58 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Bader Al-Asaker and Prince Mohammed Bin Salman Abdulaziz Foundation d/b/a MiSK Foundation's ("Defendants") Motion for Ivano M. Ventresca to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #50 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #50 is GRANTED. Ivano M. Ventresca may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to iventresca@zuckerman.com. Signed by Chief Judge K. Michael Moore on 2/9/2021. (hwr)
February 9, 2021 Opinion or Order Filing 57 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Bader Al-Asaker and Prince Mohammed Bin Salman Abdulaziz Foundation d/b/a MiSK Foundation's ("Defendants") Motion for Candace R. Jackson to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #49 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #49 is GRANTED. Candace R. Jackson may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to cjackson-akiwumi@zuckerman.com. Signed by Chief Judge K. Michael Moore on 2/9/2021. (hwr)
February 8, 2021 Opinion or Order Filing 56 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Faisal Al Menaia, Awwad Al Otaibi, and Turki Al Owerde's ("Defendants") Unopposed Motion for Benjamin D. Wood to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #46 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #46 is GRANTED. Benjamin D. Wood may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to Benjamin.wood@squirepb.com. Signed by Chief Judge K. Michael Moore on 2/8/2021. (hwr)
February 8, 2021 Opinion or Order Filing 55 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Faisal Al Menaia, Awwad Al Otaibi, and Turki Al Owerde's ("Defendants") Unopposed Motion for Mitchell R. Berger to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #45 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #45 is GRANTED. Mitchell R. Berger may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to mitchell.berger@squirepb.com. Signed by Chief Judge K. Michael Moore on 2/8/2021. (hwr)
February 8, 2021 Opinion or Order Filing 54 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Mohamed Bin Zayed Al Nahyan's ("Defendant") Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. #47 . Therein, Defendant requests a forty-four (44) day extension of time to respond to Plaintiff's Complaint. Id. at 1. Defendant argues that "[t]he extension is sought in light of ongoing disruptions resulting from the COVID-19 virus and the process involved in preparing a response on behalf of [Defendant], given his position in the United Arab Emirates" and granting an extension will align Defendant's deadline to respond with that of several other defendants." Id. UPON CONSIDERATION of the Motion #47 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendant's Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint is GRANTED. Defendant's response to Plaintiff's Complaint shall be due on or before March 26, 2021. Signed by Chief Judge K. Michael Moore on 2/8/2021. (hwr)
February 8, 2021 Filing 53 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Barry J. Pollack. Filing Fee $ 200.00 Receipt # AFLSDC-14351451 by Saud Al Qahtani. Responses due by 2/22/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Markus, David)
February 8, 2021 Filing 52 NOTICE of Attorney Appearance by David Oscar Markus on behalf of Saud Al Qahtani. Attorney David Oscar Markus added to party Saud Al Qahtani(pty:dft). (Markus, David)
February 5, 2021 Filing 51 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for William W. Taylor, III. Filing Fee $ 200.00 Receipt # AFLSDC-14345692 by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. Responses due by 2/19/2021 (Cochran, Justin)
February 5, 2021 Filing 50 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Ivano M. Ventresca. Filing Fee $ 200.00 Receipt # AFLSDC-14345682 by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. Responses due by 2/19/2021 (Cochran, Justin)
February 5, 2021 Filing 49 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Candace R. Jackson. Filing Fee $ 200.00 Receipt # AFLSDC-14345652 by Bader Al-Asaker, Prince Mohammed Bin Salman Abdulaziz Foundation. Attorney Justin Richard Cochran added to party Bader Al-Asaker(pty:dft), Attorney Justin Richard Cochran added to party Prince Mohammed Bin Salman Abdulaziz Foundation(pty:dft). Responses due by 2/19/2021 (Cochran, Justin)
February 5, 2021 Opinion or Order Filing 48 PAPERLESS ORDER. THIS CAUSE came before the Court upon Plaintiff's Consent Motion to Extend Time to File Opposition to USA Defendants' Motion to Dismiss the Complaint and Postpone the Parties' Deadline for Holding Scheduling Conference. #44 . Therein, Plaintiff requests an extension of time to file her response to Defendants Sharon Collins, Hussam Al-Jundi, Christanne Schey, and Annette Smith's ("USA Defendants") Motion to Dismiss #32 , and all other Defendants' initial responsive pleadings, to forty-five (45) days after all Defendants who have already appeared in the case file their first responsive pleading to the Complaint. Id. Plaintiff argues that a uniform deadline "will streamline this case and allow for a more efficient resolution of any motions to dismiss filed." Id. at 5. Plaintiff further requests that the Court postpone the Parties' deadline for holding a scheduling conference to March 10, 2021, as all named Defendants have not yet formally appeared in this case. Id. at 1. UPON CONSIDERATION of the Motion #44 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #44 is GRANTED. Plaintiff's response to any forthcoming initial responsive pleadings filed by the Defendants who have appeared in the case as of the date of this Order shall be due within forty-five (45) days of the filing of the last such responsive pleading. The parties shall hold a scheduling conference on or before March 10, 2021, and shall file a joint scheduling report no later than ten (10) days thereafter. Signed by Chief Judge K. Michael Moore on 2/5/2021. (hwr)
February 5, 2021 Filing 47 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by Mohammed Bin Zayed Al Nahyan. Attorney Mark Jurgen Heise added to party Mohammed Bin Zayed Al Nahyan(pty:dft). (Attachments: #1 Text of Proposed Order Proposed Order)(Heise, Mark)
February 5, 2021 Filing 46 Unopposed MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Benjamin D. Wood. Filing Fee $ 200.00 Receipt # AFLSDC-14341416 by Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. Responses due by 2/19/2021 (Kruppa, Andrew)
February 5, 2021 Filing 45 Unopposed MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Mitchell R. Berger. Filing Fee $ 200.00 Receipt # AFLSDC-14341398 by Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. Responses due by 2/19/2021 (Kruppa, Andrew)
February 4, 2021 Filing 44 Consent MOTION for Extension of Time to File Response/Reply/Answer as to #32 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM , and to Postpone the Parties' Deadline for Holding Scheduling Conference by Ghada Oueiss. (Rashbaum, Daniel)
February 4, 2021 Opinion or Order Filing 43 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Mohammed bin Salman bin Abdulaziz Al Saud's Motion for Andrew C. Shen to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #39 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #39 is GRANTED. Andrew C. Shen may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to ashen@kellogghansen.com. Signed by Chief Judge K. Michael Moore on 2/4/2021. (hwr)
February 4, 2021 Opinion or Order Filing 42 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Mohammed bin Salman bin Abdulaziz Al Saud's Motion for Gregory G. Rapawy to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #38 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #38 is GRANTED. Gregory G. Rapawy may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to grapawy@kellogghansen.com. Signed by Chief Judge K. Michael Moore on 2/4/2021. (hwr)
February 4, 2021 Opinion or Order Filing 41 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendant Mohammed bin Salman bin Abdulaziz Al Saud's Motion for Michael K. Kellogg to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. #37 . UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #37 is GRANTED. Michael K. Kellogg may appear pro hac vice in this matter. The Clerk of the Court shall provide electronic notification of all electronic filings to mkellogg@kellogghansen.com. Signed by Chief Judge K. Michael Moore on 2/4/2021. (hwr)
February 3, 2021 Filing 40 NOTICE of Attorney Appearance by Stephen James Binhak on behalf of DarkMatter, Faisal al Bannai. Attorney Stephen James Binhak added to party DarkMatter(pty:dft), Attorney Stephen James Binhak added to party Faisal al Bannai(pty:dft). (Binhak, Stephen)
February 3, 2021 Filing 39 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Andrew C. Shen. Filing Fee $ 200.00 Receipt # AFLSDC-14332279 by Mohammed Bin Salman Bin Abdulaziz Al Saud. Responses due by 2/17/2021 (Brodsky, Benjamin)
February 3, 2021 Filing 38 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Gregory G. Rapawy. Filing Fee $ 200.00 Receipt # AFLSDC-14332260 by Mohammed Bin Salman Bin Abdulaziz Al Saud. Responses due by 2/17/2021 (Brodsky, Benjamin)
February 3, 2021 Filing 37 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Michael K. Kellogg. Filing Fee $ 200.00 Receipt # AFLSDC-14332230 by Mohammed Bin Salman Bin Abdulaziz Al Saud. Responses due by 2/17/2021 (Brodsky, Benjamin)
February 3, 2021 Filing 36 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Ghada Oueiss. Al Arabiya served on 1/20/2021, answer due 2/10/2021. (Attachments: #1 Proof of Service - Al Arabiya)(Mays, Jason)
February 2, 2021 Opinion or Order Filing 35 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Mohammed bin Salman bin Abdulaziz Al Saud ("the Crown Prince"), Faisal Al Menaia, Awwad Al Otaibi, Turki Al Owerde, Saud Al Qahtani, Bader Al Asaker, and the Prince Mohammed bin Salman Abdulaziz Foundation's (collectively, "Moving Defendants") Consent Motion for Extension of Time to Respond to the Complaint and for Leave to File Excess Pages. #33 . Therein, Moving Defendants request an extension of time to March 26, 2021, to respond to the Complaint, and the Crown Prince moves for leave to exceed the page limit set by Rule 7.1(c) of the Local Rules of the Southern District of Florida. Id. Moving Defendants argue that Plaintiff's claims "raise a host of complex factual and legal issues, including issues of personal and subject-matter jurisdiction and immunity, that require investigation in advance of filing a motion to dismiss." Id. at 2. Additionally, the extension sought by Moving Defendants would allow the response deadline to align with the deadline for other defendants in this matter, and will promote judicial efficiency because "Moving Defendants propose that the Crown Prince will file a lead brief, with other Moving Defendants filing separate briefs that adopt in whole or in part some of the arguments made by the Crown Prince, as well as any individualized arguments." Id. at 2-3. The Crown Prince argues that an enlargement of the 20-page limit set by the Local Rules of the Southern District of Florida is warranted "[g]iven the complexity and number of the issues raised by [Plaintiff's] numerous claims" and the expectation that "many of the arguments made in [the Crown Prince's] briefing will be adopted by other Moving Defendants." Id. at 3. Based on the foregoing, the Court finds good cause to extend the response deadline and enlarge the page limitation set by the Local Rules of the Southern District of Florida. See generally id. Accordingly, UPON CONSIDERATION of the Motion #33 , the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Moving Defendants' Consent Motion for Extension of Time to Respond to the Complaint and for Leave to File Excess Pages #33 is GRANTED. The Crown Prince's forthcoming motion to dismiss shall not exceed fifty (50) pages, and Moving Defendants' response(s) to Plaintiff's Complaint shall be due on or before March 26, 2021. Signed by Chief Judge K. Michael Moore on 2/2/2021. (hwr)
February 1, 2021 Filing 34 NOTICE of Attorney Appearance by Andrew Russell Kruppa on behalf of Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. Attorney Andrew Russell Kruppa added to party Faisal Al Menaia(pty:dft), Attorney Andrew Russell Kruppa added to party Awwad Al Otaibi(pty:dft), Attorney Andrew Russell Kruppa added to party Turki Al-Owerde(pty:dft). (Kruppa, Andrew)
February 1, 2021 Filing 33 Consent MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint , Consent MOTION for Leave to File Excess Pages by Mohammed Bin Salman Bin Abdulaziz Al Saud. Attorney Benjamin Henry Brodsky added to party Mohammed Bin Salman Bin Abdulaziz Al Saud(pty:dft). (Brodsky, Benjamin)
January 29, 2021 Filing 32 MOTION TO DISMISS #1 Complaint FOR FAILURE TO STATE A CLAIM by Hussam Al-Jundi, Sharon Collins, Christanne Schey, Annette Smith. Responses due by 2/12/2021 (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Jimenez, Marcos)
January 26, 2021 Filing 31 WAIVER OF SERVICE Returned Executed by DarkMatter. DarkMatter waiver sent on 12/26/2020, answer due 3/26/2021. (Binhak, Stephen)
January 26, 2021 Filing 30 WAIVER OF SERVICE Returned Executed by Faisal al Bannai. Faisal al Bannai waiver sent on 12/26/2020, answer due 3/26/2021. (Binhak, Stephen)
January 25, 2021 Filing 29 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Ghada Oueiss. Tarek Abou Zeinab served on 1/20/2021, answer due 2/10/2021; Faisal Al Menaia served on 1/22/2021, answer due 2/12/2021; Awwad Al Otaibi served on 1/22/2021, answer due 2/12/2021; Saud Al Qahtani served on 1/21/2021, answer due 2/11/2021; Bader Al-Asaker served on 1/21/2021, answer due 2/11/2021; Turki Al-Owerde served on 1/22/2021, answer due 2/12/2021; Mohammed Bin Salman Bin Abdulaziz Al Saud served on 1/21/2021, answer due 2/11/2021; Mohammed Bin Zayed Al Nahyan served on 1/20/2021, answer due 2/10/2021; DarkMatter served on 1/20/2021, answer due 2/10/2021; Prince Mohammed Bin Salman Abdulaziz Foundation served on 1/21/2021, answer due 2/11/2021; Saudi 24 TV served on 1/20/2021, answer due 2/10/2021; Faisal al Bannai served on 1/18/2021, answer due 2/8/2021. (Attachments: #1 Proof of Service - Mohammed Bin Salman Bin Abdulaziz Al Saud, #2 Proof of Service - Mohammed Bin Zayed Al Nahyan, #3 Proof of Service - Faisal al Bannai, #4 Proof of Service - Saud Al Qahtani, #5 Proof of Service - Bader Al-Asaker, #6 Proof of Service - DarkMatter, #7 Proof of Service - Prince Mohammed Bin Salman Abdulaziz Foundation d/b/a MiSK Foundation, #8 Proof of Service - Tarek Abou Zeinab, #9 Proof of Service - Turki Al-Owerde, #10 Proof of Service - Awwad Al Otaibi, #11 Proof of Service - Faisal Al Menaia, #12 Proof of Service - Saudi 24 TV)(Mays, Jason)
January 21, 2021 Filing 28 Summons Issued as to Faisal Al Menaia, Awwad Al Otaibi, Turki Al-Owerde. (kpe)
January 20, 2021 Filing 27 NOTICE of Filing Proposed Summons(es) for Defendants Turki Al-Owerde, Awwad Al Otaibi, and Faisal Al Menaia by Ghada Oueiss (Attachments: #1 Summon(s) Turki Al-Owerde, #2 Summon(s) Awwad Al Otaibi, #3 Summon(s) Faisal Al Menaia) (Mays, Jason)
January 20, 2021 Filing 26 Summons Reissued as to Al Arabiya, Saudi Arabian Cultural Mission. (mc)
January 19, 2021 Filing 25 NOTICE of Filing Proposed Summons(es) for Defendants Al Arabiya and Saudi Arabian Cultural Mission by Ghada Oueiss (Attachments: #1 Amended Summons - Al Arabiya, #2 Amended Summons - Saudi Arabian Cultural Mission) (Mays, Jason)
January 18, 2021 Opinion or Order Filing 24 PAPERLESS ORDER REFERRING PRETRIAL DISCOVERY MATTERS TO MAGISTRATE JUDGE LAUREN FLEISCHER LOUIS. PURSUANT to 28 U.S.C. 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the above-captioned Cause is referred to United States Magistrate Judge Lauren Fleischer Louis to take all necessary and proper action as required by law with respect to any and all pretrial discovery matters. Any motion affecting deadlines set by the Court's Scheduling Order is excluded from this referral, unless specifically referred by separate Order. It is FURTHER ORDERED that the parties shall comply with Magistrate Judge Lauren Fleischer Louis' discovery procedures. Signed by Chief Judge K. Michael Moore on 1/18/2021. (hwr)
January 18, 2021 Opinion or Order Filing 23 PAPERLESS PRETRIAL ORDER. This order has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of a responsive pleading, a copy of this Order. It is further ORDERED that S.D. Fla. L.R. 16.1 shall apply to this case and the parties shall hold a scheduling conference no later than twenty (20) days after the filing of the first responsive pleading by the last responding defendant, or within sixty (60) days after the filing of the complaint, whichever occurs first. However, if all defendants have not been served by the expiration of this deadline, Plaintiff shall move for an enlargement of time to hold the scheduling conference, not to exceed 90 days from the filing of the Complaint. Within ten (10) days of the scheduling conference, counsel shall file a joint scheduling report. Failure of counsel to file a joint scheduling report within the deadlines set forth above may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs. The parties should note that the time period for filing a joint scheduling report is not tolled by the filing of any other pleading, such as an amended complaint or Rule 12 motion. The scheduling conference may be held via telephone. At the conference, the parties shall comply with the following agenda that the Court adopts from S.D. Fla. L.R. 16.1: (1) Documents (S.D. Fla. L.R. 16.1.B.1 and 2) - The parties shall determine the procedure for exchanging a copy of, or a description by category and location of, all documents and other evidence that is reasonably available and that a party expects to offer or may offer if the need arises. Fed. R. Civ. P. 26(a)(1)(B). (a) Documents include computations of the nature and extent of any category of damages claimed by the disclosing party unless the computations are privileged or otherwise protected from disclosure. Fed. R. Civ. P. 26(a)(1)(C). (b) Documents include insurance agreements which may be at issue with the satisfaction of the judgment. Fed. R. Civ. P. 26(a)(1)(D). (2) List of Witnesses - The parties shall exchange the name, address and telephone number of each individual known to have knowledge of the facts supporting the material allegations of the pleading filed by the party. Fed. R. Civ. P. 26(a)(1)(A). The parties have a continuing obligation to disclose this information. (3) Discussions and Deadlines (S.D. Fla. L.R. 16.1.B.2) - The parties shall discuss the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case. Failure to comply with this Order or to exchange the information listed above may result in sanctions and/or the exclusion of documents or witnesses at the time of trial. S.D. Fla. L.R. 16.1.I. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuit's Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court.Telephonic appearances are not permitted for any purpose. Upon reaching a settlement in this matter the parties are instructed to notify the Court by telephone and to file a Notice of Settlement within twenty-four (24) hours. Signed by Chief Judge K. Michael Moore on 1/18/2021. (hwr)
January 18, 2021 Opinion or Order Filing 22 ORDER GRANTING IN PART and DENYING IN PART 5 Ex Parte Motion for an Order Authorizing Alternative Service of Process; GRANTING IN PART and DENYING IN PART 19 Supplemental Ex Parte Motion for an Order Authorizing Alternative Service of Process. Signed by Chief Judge K. Michael Moore on 1/17/2021. See attached document for full details. (hwr)
January 15, 2021 Opinion or Order Filing 21 PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants' Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. #20 . Therein, Defendants Sharon Van Rider (listed in the Complaint as Sharon Collins), Christanne Schey Sam Jundi (listed in the Complaint as Hussam Al-Jundi), and Annette Smith ("Defendants") request a ten (10) day extension of time to respond to Plaintiff's Complaint. Id. at 1. Defendants argue that "Defendants' counsel has encountered some personal and family health issues and therefore needs additional time to analyze the complaint and formulate a response." Id. UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that Defendants' Motion for Extension of Time to Respond to Plaintiff's Complaint is GRANTED. Defendants shall respond to Plaintiff's Complaint on or before January 29, 2021. Signed by Chief Judge K. Michael Moore on 1/15/2021. (hwr)
January 14, 2021 Filing 20 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by Hussam Al-Jundi, Sharon Collins, Christanne Schey, Annette Smith. (Attachments: #1 Text of Proposed Order)(Jimenez, Marcos)
January 7, 2021 SYSTEM ENTRY - Docket Entry 19 [motion] restricted/sealed until further notice. (991063)
January 6, 2021 Opinion or Order Filing 17 ORDER granting #6 Motion to Seal. Signed by Chief Judge K. Michael Moore on 1/6/2021. See attached document for full details. (hwr)
January 6, 2021 SYSTEM ENTRY - Docket Entry 18 [misc] restricted/sealed until further notice. (1405029)
January 5, 2021 Opinion or Order Filing 16 ORDER RECUSING JUDGE AND REASSIGNING CASE. Judge Kathleen M. Williams recused. Case reassigned to Chief Judge K. Michael Moore and Magistrate Judge Lauren Fleischer Louis for all further proceedings. Signed by Judge Kathleen M. Williams on 1/5/2020. See attached document for full details. (vjk)
January 5, 2021 Opinion or Order Filing 15 PAPERLESS ORDER granting #14 Motion for Extension of Time. Defendants Hussam Al-Jundi, Sharon Collins, Christanne Schey and Annette Smith shall respond to #1 Complaint no later than January 19, 2021. Signed by Magistrate Judge Chris M. McAliley on 1/5/2021. (rr00)
January 4, 2021 Filing 14 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Complaint by Hussam Al-Jundi, Sharon Collins, Christanne Schey, Annette Smith. Attorney Marcos Daniel Jimenez added to party Hussam Al-Jundi(pty:dft), Attorney Marcos Daniel Jimenez added to party Sharon Collins(pty:dft), Attorney Marcos Daniel Jimenez added to party Christanne Schey(pty:dft), Attorney Marcos Daniel Jimenez added to party Annette Smith(pty:dft). (Attachments: #1 Text of Proposed Order)(Jimenez, Marcos)
December 23, 2020 Filing 13 SUMMONS (Affidavit) Returned Executed on #1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Ghada Oueiss. Hussam Al-Jundi served on 12/16/2020, answer due 1/6/2021; Sharon Collins served on 12/16/2020, answer due 1/6/2021; Christanne Schey served on 12/16/2020, answer due 1/6/2021; Annette Smith served on 12/16/2020, answer due 1/6/2021. (Attachments: #1 Proof of Service - Sharon Collins, #2 Proof of Service - Christanne Schey, #3 Proof of Service - Annette Smith, #4 Proof of Service - Hussam Al-Jundi)(Mays, Jason)
December 21, 2020 Filing 12 Summons Issued as to Al Arabiya. (kpe)
December 21, 2020 Filing 11 NOTICE of Filing Proposed Summons(es) by Ghada Oueiss (Attachments: #1 Amended Summons - Al Arabiya) (Mays, Jason)
December 21, 2020 Filing 10 NOTICE of Attorney Appearance by Jason Mays on behalf of Ghada Oueiss. Attorney Jason Mays added to party Ghada Oueiss(pty:pla). (Mays, Jason)
December 21, 2020 Opinion or Order Filing 9 ORDER Of Referral And Notice Of Court Practices And Procedures. Signed by Judge Kathleen M. Williams on 12/20/2020. See attached document for full details. (kpe)
December 18, 2020 Opinion or Order Filing 8 ORDER OF RECUSAL. Senior Judge James Lawrence King recused. Case reassigned to Judge Kathleen M. Williams for all further proceedings. Signed by Senior Judge James Lawrence King on 12/18/2020. See attached document for full details. (yar)
December 17, 2020 Filing 7 Clerks Notice to Filer re 5 MOTION for an Order Authorizing Alternative Service on Foreign Defendants Pursuant to Fed. R. Civ. P. 4(f)(3) . Sealed/Ex Parte Document Filed Electronically; ERROR - __________. It is not necessary to refile the document but future sealed/ex parte filings must be filed in accordance with the CM/ECF Administrative Procedures. (nc)
December 16, 2020 SYSTEM ENTRY - Docket Entry 5 [motion] restricted/sealed until further notice. (nc)
December 16, 2020 Filing 6 Plaintiff's MOTION to Seal Exhibit "K" in Support of Plaintiff's Ex Parte Motion for an Order Authorizing Alternative Service, per Local Rule 5.4 by Ghada Oueiss. (Attachments: #1 Proposed Order) (Rashbaum, Daniel)
December 15, 2020 Filing 4 Summons Issued as to Tarek Abou Zeinab, Al Arabiya, Faisal Al Menaia, Saud Al Qahtani, Bader Al-Asaker, Hussam Al-Jundi, Mohammed Bin Salman Bin Abdulaziz Al Saud, Mohammed Bin Zayed Al Nahyan, Sharon Collins, DarkMatter, Prince Mohammed Bin Salman Abdulaziz Foundation, Saudi 24 TV, Saudi Arabian Cultural Mission, Christanne Schey, Annette Smith, Faisal al Bannai. (nc)
December 14, 2020 Filing 3 NOTICE of Filing Proposed Summons(es) by Ghada Oueiss (Attachments: #1 Summon(s) Mohammed Bin Salman Bin Abdulaziz Al Saud, #2 Summon(s) Mohammed Bin Zayed Al Nahyan, #3 Summon(s) DarkMatter, #4 Summon(s) Faisal al Bannai, #5 Summon(s) Saudi 24 TV, #6 Summon(s) Al Arabiya, #7 Summon(s) Prince Mohammed Bin Salman Abdulaziz Foundation d/b/a MiSK Foundation, #8 Summon(s) Saud Al Qahtani, #9 Summon(s) Bader Al-Asaker, #10 Summon(s) Saudi Arabian Cultural Mission, #11 Summon(s) Tarek Abou Zeinab, #12 Summon(s) Sharon Collins, #13 Summon(s) Christanne Schey, #14 Summon(s) Hussam Al-Jundi, #15 Summon(s) Annette Smith) (Rashbaum, Daniel)
December 9, 2020 Filing 2 Clerks Notice of Judge Assignment to Senior Judge James Lawrence King. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jacqueline Becerra 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. (kpe)
December 9, 2020 Filing 1 COMPLAINT against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-14006579, filed by Ghada Oueiss. (Attachments: #1 Civil Cover Sheet)(Rashbaum, Daniel)

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Search for this case: Oueiss v. Bin Salman Bin Abdulaziz Al Saud et al
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Defendant: Faisal al Bannai
Represented By: Stephen James Binhak
Represented By: Natasha G. Kohne
Represented By: James E. Tysse
Represented By: Anthony T. Pierce
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Defendant: Bader Al-Asaker
Represented By: Justin Richard Cochran
Represented By: William W. Taylor, III
Represented By: Ivano M. Ventresca
Represented By: Candace R. Jackson
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Defendant: Turki Al-Owerde
Represented By: Benjamin D. Wood
Represented By: Andrew Russell Kruppa
Represented By: Mitchell R. Berger
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Defendant: Awwad Al Otaibi
Represented By: Benjamin D. Wood
Represented By: Andrew Russell Kruppa
Represented By: Mitchell R. Berger
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Defendant: Mohammed Bin Salman Bin Abdulaziz Al Saud
Represented By: Gregory G. Rapawy
Represented By: Andrew C. Shen
Represented By: Benjamin Henry Brodsky
Represented By: Michael K. Kellogg
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Defendant: Sharon Collins
Represented By: Marcos Daniel Jimenez
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Defendant: Saudi Arabian Cultural Mission
Represented By: Benjamin Henry Brodsky
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Defendant: Christanne Schey
Represented By: Marcos Daniel Jimenez
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Defendant: Tarek Abou Zeinab
Represented By: Andrew Russell Kruppa
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Defendant: John Doe
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Defendant: Hussam Al-Jundi
Represented By: Marcos Daniel Jimenez
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Defendant: Faisal Al Menaia
Represented By: Benjamin D. Wood
Represented By: Andrew Russell Kruppa
Represented By: Mitchell R. Berger
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Defendant: Mohammed Bin Zayed Al Nahyan
Represented By: Mark Jurgen Heise
Represented By: Pratik A. Shah
Represented By: Stephen M. Baldini
Represented By: Hal S. Shapiro
Represented By: Ze-Wen Julius Chen
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Defendant: Annette Smith
Represented By: Marcos Daniel Jimenez
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Defendant: Al Arabiya
Represented By: Daria Pustilnik
Represented By: Evelyn Baltodano-Sheehan
Represented By: Adam Fee
Represented By: John Lu
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Defendant: Saud Al Qahtani
Represented By: David Oscar Markus
Represented By: Barry J. Pollack
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Defendant: Saudi 24 TV
Represented By: Daria Pustilnik
Represented By: Evelyn Baltodano-Sheehan
Represented By: Adam Fee
Represented By: John Lu
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Defendant: DarkMatter
Represented By: Stephen James Binhak
Represented By: Natasha G. Kohne
Represented By: James E. Tysse
Represented By: Anthony T. Pierce
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Defendant: Prince Mohammed Bin Salman Abdulaziz Foundation doing business as MiSK Foundation
Represented By: Justin Richard Cochran
Represented By: William W. Taylor, III
Represented By: Ivano M. Ventresca
Represented By: Candace R. Jackson
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Defendant: Masharea wa Enjazat IT Corporation LLC
Represented By: Adam Fee
Represented By: Daria Pustilnik
Represented By: Evelyn Baltodano-Sheehan
Represented By: John Lu
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Defendant: Middle East News, FZ-LLC
Represented By: Adam Fee
Represented By: Daria Pustilnik
Represented By: Evelyn Baltodano-Sheehan
Represented By: John Lu
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Defendant: Sharon Van Rider
Represented By: Marcos Daniel Jimenez
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Defendant: Sam Jundi
Represented By: Marcos Daniel Jimenez
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Plaintiff: Ghada Oueiss
Represented By: Daniel Lawrence Rashbaum
Represented By: Jeffrey David Marcus
Represented By: Jason Mays
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Amicus curiae: Electronic Frontier Foundation
Represented By: Deanna Kendall Shullman
Represented By: Mukund Rathi
Represented By: Sophia Cope
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