THE COLLECTION, LLC et al v. PORSCHE CARS NORTH AMERICA, INC. et al
| THE COLLECTION, LLC, Florida Department of Highway Safety and Motor Vehicles and State of Florida |
| PORSCHE CARS NORTH AMERICA, INC., DR. ING H.C.F. PORSCHE and PORSCHE LATIN AMERICA, INC. |
| 1:2022cv23789 |
| November 18, 2022 |
| US District Court for the Southern District of Florida |
| Joan A Lenard |
| Lauren Fleischer Louis |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity-Notice of Removal |
| Both |
Docket Report
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This docket was last retrieved on January 5, 2023. A more recent docket listing may be available from PACER.
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Filing 49
PAPERLESS ORDER GRANTING #48 Unopposed Motion for Extension of Time. Plaintiff shall have until and including March 10, 2023 to file a proposed order scheduling mediation. This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 1/5/2023. (gie)
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| Filing 48 Unopposed MOTION for Extension of Time to select a mediator and submit a Proposed Order scheduling mediation by THE COLLECTION, LLC. Responses due by 1/19/2023 (Attachments: #1 Text of Proposed Order)(Burstyn, Sean) |
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Filing 47
ORDER of Referral to Mediation and Directing Plaintiff's Counsel to Submit (Within Fourteen Days) Proposed Order Scheduling Mediation. Mediation Deadline 1/19/2024. Signed by Judge Joan A. Lenard on 12/22/2022. See attached document for full details. (Attachments: #1 Appendix) (dp)
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Filing 46
Order Adopting Joint Scheduling Report, Setting Pretrial Conference and Trial, Establishing Pretrial Deadlines, and Establishing Pretrial and Trial Procedures: Jury Trial set for 9/23/2024 09:00 AM in Miami Division before Judge Joan A. Lenard. Calendar Call set for 9/18/2024 04:00 PM in Miami Division before Judge Joan A. Lenard. Pretrial Conference set for 9/9/2024 02:00 PM in Miami Division before Judge Joan A. Lenard. Signed by Judge Joan A. Lenard on 12/22/2022. See attached document for full details. (dp)
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Filing 45
PAPERLESS ORDER GRANTING #44 Joint Motion for Extensions of Time. Defendants shall have until and including January 17, 2023 to respond to Plaintiff's Motion to Remand, and Plaintiff shall have until and including March 10, 2023 to respond to Defendants' Motions to Dismiss (if necessary). This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 12/22/2022. (gie)
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| Filing 44 Joint MOTION for Extension of Time To Respond To Plaintiff's Motion To Remand and for Plaintiff To Respond To Defendants' Motions To Dismiss by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC.. Responses due by 1/5/2023 (Rogers, Daniel) |
| Filing 43 Joint SCHEDULING REPORT - Rule 16.1 by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC. (Attachments: #1 Exhibit 1-Joint Consent to Jurisdiction by US Magistrate Judge, #2 Exhibit 2-Joint Scheduling Form)(Rogers, Daniel) |
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Filing 42
PAPERLESS ORDER GRANTING #35 Plaintiff's Expedited Motion to Stay Briefing on Defendants' Motions to Dismiss the Complaint Pending Resolution of the Collection's Motion to Remand.THIS CAUSE is before the Court on Plaintiff's Expedited Motion to Stay Briefing on Defendants' Motions to Dismiss the Complaint Pending Resolution of the Collection's Motion to Remand, (D.E. #35 ), filed December 13, 2022. Defendants Porsche Cars North America, Inc. and Porsche Latin America, Inc. filed a Response on December 16, 2022, (D.E. #37 ), to which Plaintiff filed a Reply on December 19, 2022, (D.E. #39 ). Upon review of the Motion, Response, Reply, and the record, the Court finds as follows."'[T]he power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.'" Donato v. Allergan Sales, LLC, Case No. 3:20-cv-679-J-39JRK, 2020 WL 13348664, at *1 (M.D. Fla. Aug. 13, 2020) (quoting Landis v. N. Am. Co., 299 U.S. 248, 254 (1936)). "Deciding whether to stay a case 'calls for the exercise of judgment, which must weigh competing interests and maintain an even balance.'" Id. (quoting Landis, 299 U.S. at 254-55). "The party moving for a stay bears the burden of showing 'good cause and reasonableness.'" Id. (quoting Feldman v. Flood, 176 F.R.D. 651, 652 (M.D. Fla. 1997)). "In deciding whether to grant a stay, 'courts generally examine three factors: (1) whether a stay will unduly prejudice or tactically disadvantage the non-moving party; (2) whether a stay will simplify the issues and streamline the trial; and (3) whether a stay will reduce the burden of litigation on the parties and on the court.'" Id. (quoting eCOMSYSTEMS, Inc. v. Shared Mktg. Servs., Inc., No. 8:10cv1531T33AEP, 2011 WL 280942, at *2 (M.D. Fla. Jan. 26, 2011)).The Court finds that all three factors weigh in favor of a stay of briefing on Defendants' Motions to Dismiss pending the Court's resolution of Plaintiff's #41 Motion to Remand. Initially, the Court observes that "[b]ecause it challenges the Court's subject matter jurisdiction, the Court must resolve a motion to remand prior to taking up any motion to dismiss." Hill v. Nat'l Ins. Underwriters, Inc., CASE NO. 12-62498-CIV-ZLOCH, 2013 WL 11971265, at *1 (S.D. Fla. Aug. 7, 2013). If the Court ultimately determines that remand is appropriate, a stay of briefing would reduce the burden of litigating the Motions to Dismiss on the Parties and the Court, and would simplify the issues for this Court's disposition. Although a stay will provide Plaintiffs more time to respond to the Motions to Dismiss, a stay will not unduly prejudice Defendants, nor place Defendants at a tactical disadvantage. Therefore, the Court finds that a stay of briefing on Defendants' Motions to Dismiss is appropriate in this case.However, a stay cannot be "immoderate or of an indefinite duration." CTI Container Leasing Corp. v. Uiterwyk Corp., 685 F.2d 1284, 1288 (11th Cir. 1982). Therefore, if the Court denies the Motion to Remand, Plaintiff shall respond to Defendants' Motions to Dismiss within ten days of the Court's Order denying the Motion to Remand. If no Order has been entered by February 17, 2023, Plaintiff's Response shall be filed on or before February 24, 2023.This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 12/20/2022. (gie)
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| Filing 41 MOTION to Remand to State Court by THE COLLECTION, LLC. (Attachments: #1 Exhibit A_M. Garilli, #2 Exhibit B_N. Edwards, #3 Exhibit C_Porsche's Notice of Publication for a New Point)(Burstyn, Sean) |
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Filing 40
PAPERLESS ORDER STRIKING #38 Motion to Remand this Action Back to State Court. Local Rule 7.1(c) states: "Absent prior permission of the Court, neither a motion and its incorporated memorandum of law nor the opposing memorandum of law shall exceed twenty (20) pages[.]" Plaintiff's Motion is twenty-two pages, and it did not seek prior permission of the Court to exceed the page limit established by the Local Rules. Accordingly, the #28 Motion to Remand this Action Back to State Court is STRICKEN for failure to comply with the Local Rules. This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 12/20/2022. (gie)
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| Filing 39 REPLY to Response to Motion re #35 EXPEDITED MOTION For a Stay of Motion to Dismiss Briefing re #34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM , #33 MOTION TO DISMISS #1 Notice of Removal (State Court Compla filed by THE COLLECTION, LLC. (Burstyn, Sean) |
| Filing 38 (STRICKEN PER DE#40) MOTION to Remand to State Court by THE COLLECTION, LLC. (Attachments: #1 Exhibit A_M. Garilli, #2 Exhibit B_N. Edwards, #3 Exhibit C_Porsche's Notice of Publication for a New Point)(Burstyn, Sean)Text Modified on 12/20/2022 (cqs). |
| Filing 37 RESPONSE in Opposition re #35 EXPEDITED MOTION For a Stay of Motion to Dismiss Briefing re #34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM , #33 MOTION TO DISMISS #1 Notice of Removal (State Court Compla filed by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC.. Replies due by 12/27/2022. (Rogers, Daniel) |
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Filing 36
PAPERLESS ORDER EXPEDITING BRIEFING. Defendant shall have until and including December 16, 2022 to respond to Plaintiff's #35 Expedited Motion to Stay Briefing on Defendants' Motions to Dismiss the Complaint Pending Resolution of the Collection's Motion to Remand. The Response shall not exceed eight (8) double-spaced pages, excluding signature block and certificates. Plaintiff shall have until and including December 19, 2022 to file a Reply, which shall not exceed six (6) double-spaced pages, excluding signature block and certificates. The Court sua sponte GRANTS Plaintiff an extension of time--until and including December 29, 2022--to file a Response to Defendants' Motions to Dismiss, (D.E. #33 , #34 ), as the instant Motion indicates that Defendants do not oppose such an extension, (D.E. #35 at 7). This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 12/14/2022. (gie)
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| Reset Deadlines as to #35 EXPEDITED MOTION For a Stay of Motion to Dismiss Briefing re #34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM , #33 MOTION TO DISMISS #1 Notice of Removal (State Court Compla. Responses due by 12/16/2022 Replies due by 12/19/2022. PER DE#36 (cds) |
| Reset Deadlines/Hearings as to #33 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM , #34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM . Responses due by 12/29/2022. PER DE#36 (cds) |
| Filing 35 EXPEDITED MOTION For a Stay of Motion to Dismiss Briefing re #34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM , #33 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM by THE COLLECTION, LLC. (Attachments: #1 Text of Proposed Order Granting Motion to Stay, #2 Text of Proposed Order Granting Request for Expedited Responses)(Burstyn, Sean) |
| Filing 34 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM by PORSCHE LATIN AMERICA, INC.. Responses due by 12/27/2022 (Rogers, Daniel) |
| Filing 33 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),, FOR FAILURE TO STATE A CLAIM by PORSCHE CARS NORTH AMERICA, INC.. Responses due by 12/27/2022 (Attachments: #1 Exhibit A)(Rogers, Daniel) |
| Filing 32 Second AMENDED NOTICE OF REMOVAL against THE COLLECTION, LLC, filed by PORSCHE CARS NORTH AMERICA, INC.. (Attachments: #1 Exhibit A-Summons, #2 Exhibit B-Civil Cover Sheet, #3 Exhibit C-Complaint, #4 Exhibit D-Declaration of J. Lawrence, #5 Exhibit E-Franchise Agreement, #6 Exhibit F-Declaration of C. Klein, #7 Exhibit G-ECF 49 Joint Pretrial Stip, #8 Exhibit H-Notice of Filing of Notice of Removal, #9 Exhibit I-Notice of Filing of Amended Notice of Removal)(Rogers, Daniel) |
| Filing 31 Certificate of Other Affiliates/Corporate Disclosure Statement and Certificate of Interested Parties by THE COLLECTION, LLC identifying Corporate Parent The Collection Properties, LLC, Corporate Parent Coral Gables Imports, Inc. for THE COLLECTION, LLC (Burstyn, Sean) |
| Filing 30 STATUS REPORT REMOVAL STATUS REPORT by PORSCHE CARS NORTH AMERICA, INC. (Attachments: #1 Exhibit 1-State Court Civil Cover Sheet, #2 Exhibit 2-Complaint, #3 Exhibit 3-Notice of Special Set Hearing, #4 Exhibit 4-Mandatory Order to Confer, #5 Exhibit 5-Notice and Order of Motion, #6 Exhibit 6-Notice and Order of Adherence, #7 Exhibit 7-Order Setting Initial Case Management Conference, #8 Exhibit 8-Plaintiff's Verified Motion To Disqualify, #9 Exhibit 9-Order Granting Verified Motion To Disqualify, #10 Exhibit 10-Notice of Appearance of Todd R. Friedman, #11 Exhibit 11-Amended Order Granting Verified Motion To Disqualify, #12 Exhibit 12-Summons Received for Porsche Latin America, Inc., #13 Exhibit 13-Summons Received for Porsche Cars North America, Inc., #14 Exhibit 14-Summons Received for DR.-ING. H.C. F. Porsche, #15 Exhibit 15-Issued Summons to Porsche Latin America, Inc., #16 Exhibit 16-Issued Summons to Porsche Cars North America, Inc., #17 Exhibit 17-Issued Summons to DR.-ING. H.C.F. Porsche, #18 Exhibit 18-Transfer Order on Recusal, #19 Exhibit 19-Service on Porsche Latin America, Inc. Returned, #20 Exhibit 20-Service on Porsche Cars North America, Inc. Returned, #21 Exhibit 21-Notice of Appearance of Brian Torres, #22 Exhibit 22-PCNA Notice of Confidential Information, #23 Exhibit 23-PCNA Notice of Removal to US District Court, #24 Exhibit 24-PCNA Notice of Filing of Amended Notice of Removal)(Rogers, Daniel) |
| Filing 29 Notice of NO Pending, Refiled, Related or Similar Actions by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC. (Rogers, Daniel) |
| Filing 28 Certificate of Other Affiliates CERTIFICATE OF INTERESTED PERSONS AND CORPORATE DISCLOSURE STATEMENT by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC. (Rogers, Daniel) |
| Filing 27 Clerk's Notice to Filer re #24 Notice (Other), #23 Notice (Other). Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#25 and 26]. It is not necessary to refile this document. (cqs) |
| Filing 26 NOTICE of Attorney Appearance Pro Hac Vice (for image see DE#24) RE: Michael D. Educate by Daniel Brandon Rogers on behalf of PORSCHE LATIN AMERICA, INC. (cqs) |
| Filing 25 NOTICE of Attorney Appearance Pro Hac Vice Re :Owen H. Smith (for image see DE#23) by Daniel Brandon Rogers on behalf of PORSCHE LATIN AMERICA, INC. (cqs) |
| Filing 24 NOTICE by PORSCHE LATIN AMERICA, INC. NOTICE OF APPEARANCE PRO HAC VICE OF MICHAEL D. EDUCATE ON BEHALF OF DEFENDANT PORSCHE LATIN AMERICA, INC. (Rogers, Daniel) |
| Filing 23 NOTICE by PORSCHE LATIN AMERICA, INC. NOTICE OF APPEARANCE PRO HAC VICE OF OWEN H. SMITH ON BEHALF OF DEFENDANT PORSCHE LATIN AMERICA, INC. (Rogers, Daniel) |
| Filing 22 CLERK'S NOTICE re #21 Notice (Other). PHV Attorneys Owen Smith and Michael Educate have not been added to Defendant Porsche Latin America, Inc. Notice of Appearance does not comply with Rule 4(b)(4) of the Rules Governing the Admission, Practice, Peer Review, and Discipline of Attorneys, Local Rules of the Southern District of Florida. (cw) |
| Filing 21 NOTICE by PORSCHE LATIN AMERICA, INC. Notice of Appearance As Co-Counsel By Owen Smith and Michael Educate On Behalf of Defendant Porsche Latin America, Inc. (Rogers, Daniel) |
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Filing 20
PAPERLESS ORDER GRANTING #19 Plaintiff's Unopposed Motion to Redact Private Information Contained in Exhibit E of Defendant Porsche Cars North America Inc.'s Amended Notice of Removal. Defendant shall have until and including December 7, 2022 to file an Amended Notice of Removal with redactions to the private home address and corporate ownership percentage information contained therein. This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 11/30/2022. (gie)
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| Filing 19 Unopposed MOTION to redact private information contained in Exhibit E of Defendant Porsche Cars North America Inc.'s Amended Notice of Removal re #1 Notice of Removal (State Court Complaint),, #15 Amended Complaint/Amended Notice of Removal by THE COLLECTION, LLC. (Attachments: #1 Text of Proposed Order)(Burstyn, Sean) |
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Filing 18
ORDER granting #10 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Michael D. Educate. Signed by Judge Joan A. Lenard on 11/23/2022. See attached document for full details. (dp)
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Filing 17
ORDER granting #9 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Owen H. Smith. Signed by Judge Joan A. Lenard on 11/23/2022. See attached document for full details. (dp)
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Filing 16
PAPERLESS ORDER DENYING without prejudice #11 Defendant Porsche Cars North America, Inc.'s Unopposed Motion for Leave to File Under Seal Exhibit E to its Notice of Removal. Defendant requests leave to file the "franchise agreement" under seal, or, alternatively, submit it for an in camera inspection, because it allegedly "contains certain sensitive information regarding Plaintiff's ownership structure. This includes not only the ownership interests in Plaintiff (including the percentage of ownership in Plaintiff held by various parties), but also the ownership interests in the parties that own Plaintiff, as well as the percentage of ownership in those parties held by others." (Mot. para. 3.)"There is no question that a common law right of access exists as to civil proceedings." Wilson v. Am. Motors Corp. 759 F.2d 1568, 1570 (11th Cir. 1985). The Eleventh Circuit has held that although not "every hearing, deposition, conference or even trial... must be open to the public... 'where... the [court] attempts to deny access in order to inhibit the disclosure of sensitive information, it must be shown that the denial is necessitated by a compelling governmental interest, and is narrowly tailored to that interest.'" Newman v. Graddick, 696 F.2d 796, 802 (11th Cir. 1983) (quoting Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 606-07 (1982)); see also Wilson, 759 F.2d at 1570. The Parties have not shown why the "presumption of openness to civil proceedings" is overcome in this case, much less that sealing the franchise agreement is narrowly tailored to further a compelling governmental interest. Wilson, 759 F.2d at 1571.Accordingly, Defendant's Unopposed Motion for Leave to File Under Seal Exhibit E to its Notice of Removal is DENIED without prejudice. This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 11/23/2022. (gie)
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| Filing 15 AMENDED NOTICE OF REMOVAL against THE COLLECTION, LLC, filed by PORSCHE CARS NORTH AMERICA, INC.. (Attachments: #1 Exhibit Notice of Filing of Amended Notice of Removal)(Rogers, Daniel) |
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Filing 14
PAPERLESS ORDER GRANTING #12 Unopposed Motion for Extention of Time to Answer or Otherwise Respond to the Complaint. Defendants Porsche Cars North America, Inc. and Porsche Latin America, Inc. shall have until and including December 9, 2022 to respond to the Complaint. This entry constitutes the PAPERLESS ORDER in its entirety. Signed by Judge Joan A. Lenard on 11/22/2022. (gie)
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| Filing 13 Defendant's Corporate Disclosure Statement by PORSCHE LATIN AMERICA, INC. identifying Corporate Parent Dr. Ing h.c. F Porsche AG for PORSCHE LATIN AMERICA, INC. (Rogers, Daniel) |
| Filing 12 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #1 Notice of Removal (State Court Complaint),, by PORSCHE CARS NORTH AMERICA, INC., PORSCHE LATIN AMERICA, INC.. Attorney Daniel Brandon Rogers added to party PORSCHE LATIN AMERICA, INC.(pty:dft). (Attachments: #1 Text of Proposed Order)(Rogers, Daniel) |
| Filing 11 Unopposed MOTION to Seal Exhibit "E" To Its Notice Of Removal per Local Rule 5.4 by PORSCHE CARS NORTH AMERICA, INC.. (Attachments: #1 Text of Proposed Order) (Rogers, Daniel) |
| Filing 10 Unopposed MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Michael D. Educate. Filing Fee $ 200.00 Receipt # AFLSDC-16119478 by PORSCHE CARS NORTH AMERICA, INC.. Responses due by 12/6/2022 (Attachments: #1 Certification, #2 Text of Proposed Order)(Rogers, Daniel) |
| Filing 9 Unopposed MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Owen H. Smith. Filing Fee $ 200.00 Receipt # AFLSDC-16119436 by PORSCHE CARS NORTH AMERICA, INC.. Responses due by 12/6/2022 (Attachments: #1 Certification, #2 Text of Proposed Order)(Rogers, Daniel) |
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Filing 8
Order Setting Forth the Court's Policy on Motions for Extension or Stay of the Scheduling Order Deadlines. Signed by Judge Joan A. Lenard on 11/21/2022. See attached document for full details. (dp)
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Filing 7
Order Referring Discovery Disputes and Certain Pretrial Motions to Magistrate Judge Lauren F. Louis; Directing Parties to File Certificates of Interested Parties; Directing Parties to File a Notice of Refiling And/or of Related Cases; Requiring Completion of Form Consenting to Jurisdiction by Magistrate Judge; Notice of Court Practice in Removal Actions; and Directing Parties to File a Joint Scheduling Report and Form. Signed by Judge Joan A. Lenard on 11/21/2022. See attached document for full details. (Attachments: #1 Appendix, #2 Appendix) (dp)
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| Filing 6 Corporate Disclosure Statement by PORSCHE CARS NORTH AMERICA, INC. identifying Corporate Parent Dr. Ing h.c. F Porsche AG for PORSCHE CARS NORTH AMERICA, INC. (Rogers, Daniel) |
| Filing 5 Notice of Entry of Parties Listed on 3 Clerk's Notice to Filer re: Electronic Case, into CM/ECF. NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Florida Department of Highway Safety and Motor Vehicles and State of Florida. (Rogers, Daniel) |
| Filing 4 Bar Letter re: Admissions sent to attorney Owen H. Smith and Michael D. Educate, mailing date November 18, 2022, (pt) |
| Filing 3 Clerk's Notice to Filer re: Electronic Case. Parties Not Added. The Filer failed to add all parties associated with the case. Filer is instructed to add the additional parties by filing a Notice of Entry of Parties. It is not necessary to re-file this document. (nwn) |
| Filing 2 Clerks Notice of Judge Assignment to Judge Joan A. Lenard. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (nwn) |
| Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint And Demand For Jury Trial) Filing fee $ 402.00 receipt number AFLSDC-16112838, filed by PORSCHE CARS NORTH AMERICA, INC.. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A-Summons, State Court, #3 Exhibit B-Civil Cover Sheet-State Court, #4 Exhibit C-State Court Complaint, #5 Exhibit D-Declaration Joseph Lawrence, #6 Exhibit E-Placeholder Franchise Agreement, #7 Exhibit F-Declaration Christoph Klein, #8 Exhibit G-Joint Pretrial Stipulation, #9 Exhibit H-Notice of Filing Removal in State Court)(Rogers, Daniel) No Answer/Motion To Dismiss Filed. Modified Text/Attachment Description on 11/18/2022 (nwn). |
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