Boukheir v. The Downs Law Group, P.A.,
| Sabrina Boukheir |
| The Downs Law Group, P.A., |
| 1:2023cv22093 |
| June 6, 2023 |
| US District Court for the Southern District of Florida |
| Cecilia M Altonaga |
| Melissa Damian |
| Civil Rights: Jobs |
| 28 U.S.C. § 1441 Petition for Removal- Civil Rights Act |
| Defendant |
Docket Report
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This docket was last retrieved on August 19, 2023. A more recent docket listing may be available from PACER.
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Filing 44
Defendant's REPLY to Response to Motion re #39 MOTION for Reconsideration re #36 Order on Motion for Discovery filed by The Downs Law Group, P.A.,. (Hankin, Paul)
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Filing 43
ANSWER and Affirmative Defenses to Complaint re the Notice of Removal with Jury Demand First Amended Complaint by The Downs Law Group, P.A.,. (Hankin, Paul)
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Filing 42
Plaintiff's MOTION for Attorney Fees Pursuant to the Court's Order Following Discovery Hearing by Sabrina Boukheir. Responses due by 8/11/2023 (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Berkowitz, Jason)
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Filing 41
RESPONSE in Opposition re #39 MOTION for Reconsideration re #36 Order on Motion for Discovery filed by Sabrina Boukheir. Replies due by 8/1/2023. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Berkowitz, Jason)
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Filing 40
PAPERLESS ORDER. Plaintiff shall file a response to #39 Defendant's Motion for Reconsideration of the undersigned's #36 Order Following Discovery Hearing on or before July 27, 2023. Signed by Magistrate Judge Melissa Damian on 7/24/2023. (oco)
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Reset Deadlines as to #39 MOTION for Reconsideration re #36 Order on Motion for Discovery . Responses due by 7/27/2023 (ls)(per DE #40)
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Filing 39
MOTION for Reconsideration re #36 Order on Motion for Discovery by The Downs Law Group, P.A.,. (Hankin, Paul)
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Filing 38
ORDER denying #13 Motion to Dismiss. Defendant shall file its answer to the First Amended Complaint by August 1, 2023. Signed by Chief Judge Cecilia M. Altonaga on 7/18/2023. See attached document for full details. (ps1)
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Filing 37
PAPERLESS Minute Entry for proceedings held before Chief Judge Cecilia M. Altonaga: Motion Hearing held on 7/18/2023 re #13 Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint filed by The Downs Law Group, P.A. For the reasons stated in open court, the motion to dismiss is denied. Total time in court: 25 minutes. Attorney Appearance(s): Jason Daniel Berkowitz, Anisley Tarragona, Jeremy Daniel Friedman, and Paul Alexander Hankin. Court Reporter: Stephanie McCarn, 305-523-5518 / Stephanie_McCarn@flsd.uscourts.gov. (lfa)
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Set/Reset Response/Answer Due Deadline: The Downs Law Group, P.A., response/answer due 8/1/2023. (ps1)
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Filing 36
ORDER Following Discovery Hearing granting 35 Plaintiff's Motion to Compel Discovery Responses. Signed by Magistrate Judge Melissa Damian on 7/15/2023. See attached document for full details. (oco)
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Filing 35
ORE TENUS MOTION to Compel Discovery Responses by Sabrina Boukheir. (oco)
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Filing 34
PAPERLESS Minute Entry for proceedings held before Magistrate Judge Melissa Damian: Zoom Discovery Hearing held on 7/13/2023. Order to follow. Attorney Appearance(s): Jason Daniel Berkowitz, Jeremy Daniel Friedman, Paul Alexander Hankin, (Digital 15:08:06) Total time in court: 50 minutes. (dgj)
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Filing 33
ORDER Scheduling Mediation before Robyn Hankins; Mediation Hearing set for 11/8/2023 10:00 AM. The parties are reminded that a report of their mediation must be filed within seven (7) days thereafter. Signed by Chief Judge Cecilia M. Altonaga on 7/13/2023. See attached document for full details. (ps1)
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Filing 32
ORDER re #30 Notice of Mediator Selection and/or Hearing filed by Robyn Hankins and #10 Scheduling Order Referring Case to Mediation; on or before July 17, 2023, the parties shall email a Word version of their proposed order scheduling mediation [ECF No. 30-1] as required by the June 16 Order and the CM/ECF Administrative Procedures. Signed by Chief Judge Cecilia M. Altonaga on 7/12/2023. See attached document for full details. (ps1)
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Filing 31
Clerk's Notice to Filer re #30 Notice of Mediator Selection and/or Hearing,. Wrong Event Selected; ERROR - The Filer selected the wrong event. It is not necessary to refile this document. (ls)
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Filing 30
Joint NOTICE of Mediator Selection and Hearing. Selected/Added Robyn Hankins as Mediator. Mediation Hearing set for 11/8/2023 at 10:00 a.m.. (Attachments: #1 Text of Proposed Order) (Hankin, Paul)
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Filing 29
NOTICE of Striking #24 Notice of Mediator Selection and/or Hearing filed by Robyn Hankins by The Downs Law Group, P.A., (Hankin, Paul)
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Filing 28
ORDER denying #27 Motion for Leave to File a Surreply to Defendant's Motion to Dismiss the First Amended Complaint. Signed by Chief Judge Cecilia M. Altonaga on 7/11/2023. See attached document for full details. (ps1)
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Filing 27
Plaintiff's MOTION for Leave to File a Sur-Reply to Defendant's Motion to Dismiss the First Amended Complaint by Sabrina Boukheir. (Berkowitz, Jason)
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Filing 26
PAPERLESS NOTICE of Hearing on #13 Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint: Motion Hearing set for 7/18/2023 08:15 AM in Miami Division before Chief Judge Cecilia M. Altonaga. (ps1)
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Filing 25
Clerk's Notice to Filer re #24 Notice of Mediator Selection and/or Hearing. Proposed Order Docketed as Main Document; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - Filer must File a Notice of Striking, then resubmit the proposed order as instructed in the CM/ECF Administrative Procedures. AND Wrong Event Selected; ERROR - The Filer selected the wrong event. (ls)
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Filing 24
"STRICKEN" NOTICE of Mediator Selection and Hearing. Selected/Added Robyn Hankins as Mediator. Mediation Hearing set for 11/8/2023 at 10:00 a.m.. (Hankin, Paul) Modified Text on 7/7/2023 (ls). Modified on 7/12/2023 (ls). (per DE #29 )
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Filing 23
REPLY to Response to Motion re #13 Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint filed by The Downs Law Group, P.A.,. (Hankin, Paul)
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Filing 22
PAPERLESS ORDER Setting Discovery Hearing. Please take notice that the Court will hold a Discovery Hearing by Zoom on 7/13/2023 at 3:00 PM in the Miami Division before Magistrate Judge Melissa Damian on #15 Plaintiff's Discovery Memorandum. The Court will provide Zoom information to all counsel of record prior to the hearing. Signed by Magistrate Judge Melissa Damian on 6/29/2023. (oco)
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Filing 21
MEMORANDUM in Opposition Defendant's Responsive Memorandum in Opposition to Plaintiff's Discovery Memorandum by The Downs Law Group, P.A.,. (Friedman, Jeremy)
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Filing 20
RESPONSE in Opposition re #13 Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint filed by Sabrina Boukheir. Replies due by 7/5/2023. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Berkowitz, Jason)
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Filing 19
NOTICE of Striking #16 Response in Opposition to Motion, filed by Sabrina Boukheir by Sabrina Boukheir (Berkowitz, Jason)
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Filing 18
ORDER denying #14 Motion to Stay Discovery. Signed by Chief Judge Cecilia M. Altonaga on 6/27/2023. See attached document for full details. (ps1)
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Filing 17
Clerk's Notice to Filer re #16 Response in Opposition to Motion,. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - 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 typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and LR 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (ls)
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Filing 16
"STRICKEN" RESPONSE in Opposition re #13 Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint filed by Sabrina Boukheir. Replies due by 7/3/2023. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Berkowitz, Jason) Modified on 6/27/2023 (ls). (per DE #19)
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Filing 15
NOTICE of Filing Discovery: Plaintiff's Discovery Memorandum by Sabrina Boukheir. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Berkowitz, Jason)
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Filing 14
Defendant's MOTION to Stay Discovery Pending the Court's Ruling on Defendant's Motion to Dismiss the First Amended Complaint by The Downs Law Group, P.A.,. Responses due by 7/10/2023 (Friedman, Jeremy)
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Filing 13
Defendant's MOTION to Dismiss with Prejudice #1 Notice of Removal (State Court Complaint), Plaintiff's First Amended Complaint by The Downs Law Group, P.A.,. Responses due by 7/5/2023 (Attachments: #1 Exhibit Exhibit 1)(Friedman, Jeremy)
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Filing 12
Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by The Downs Law Group, P.A., (Friedman, Jeremy)
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Filing 11
NOTICE of Striking #8 Certificate of Other Affiliates/Corporate Disclosure Statement filed by The Downs Law Group, P.A., by The Downs Law Group, P.A., (Friedman, Jeremy)
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Filing 10
ORDER Setting Trial and Pretrial Schedule, Requiring Mediation, and Referring Certain Matters to Magistrate Judge: Trial set for two-week period beginning 4/22/2024 in Miami Division before Chief Judge Cecilia M. Altonaga. Calendar Call set for 4/16/2024 09:00 AM in Miami Division before Chief Judge Cecilia M. Altonaga. Motions to amend pleadings or join parties due by 7/28/2023. All Discovery, including Expert Discovery, due by 12/26/2023. Mediation Deadline 1/2/2024., In Limine Motions due by 2/6/2024. Motions due by 1/9/2024. Pretrial Stipulation due by 2/6/2024. REFERRING CASE to Magistrate Judge Melissa Damian for Discovery Matters. Signed by Chief Judge Cecilia M. Altonaga on 6/16/2023. See attached document for full details. (ps1)
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Filing 9
Clerk's Notice to Filer re #8 Certificate of Other Affiliates/Corporate Disclosure Statement. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - 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 typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and LR 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (ls)
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Filing 8
"STRICKEN" Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by The Downs Law Group, P.A., (Friedman, Jeremy) Modified on 6/20/2023 (ls). (per DE #11 )
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Filing 7
Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Sabrina Boukheir (Tarragona, Anisley)
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Filing 6
STATUS REPORT Removal Status Report by The Downs Law Group, P.A., (Friedman, Jeremy)
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Filing 5
SCHEDULING REPORT - Rule 16.1 by The Downs Law Group, P.A., (Attachments: #1 Text of Proposed Order)(Friedman, Jeremy)
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Filing 4
Order Requiring Joint Scheduling Report and Certificates of Interested Parties by 6/16/2023. Signed by Chief Judge Cecilia M. Altonaga on 6/7/2023. See attached document for full details. (ps1)
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Filing 3
ORDER Requiring a Removal Status Report by 6/16/2023. Signed by Chief Judge Cecilia M. Altonaga on 6/7/2023. See attached document for full details. (ps1)
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Filing 2
Clerks Notice of Judge Assignment to Chief Judge Cecilia M. Altonaga. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Melissa Damian 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. (nan)
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Filing 1
NOTICE OF REMOVAL (STATE COURT COMPLAINT ) Filing fee $ 402.00 receipt number AFLSDC-16672390, filed by The Downs Law Group, P.A.,. (Attachments: #1 Exhibits- State Court Complaint, Defendant's State Court Answer and Other State Court Documents, #2 Civil Cover Sheet)(Friedman, Jeremy) Modified Attachment Descriptions on 6/7/2023 (nan).
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| Plaintiff: Sabrina Boukheir | |
| Represented By: | Anisley Tarragona |
| Represented By: | Jason Daniel Berkowitz |
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| Defendant: The Downs Law Group, P.A., | |
| Represented By: | Jeremy Daniel Friedman |
| Represented By: | Paul Alexander Hankin |
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