Quotestorm Holdings, LLC v. Cook et al
Plaintiff: Quotestorm Holdings, LLC
Defendant: Patrick Cook and Affluent Ads, LLC doing business as Leadnomics
Case Number: 1:2024cv20690
Filed: February 22, 2024
Court: US District Court for the Southern District of Florida
Presiding Judge: Jacqueline Becerra
Referring Judge: Jonathan Goodman
2 Judge: Kathleen M Williams
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332 Diversity-Notice of Removal
Jury Demanded By: None
Docket Report

This docket was last retrieved on April 17, 2024. A more recent docket listing may be available from PACER.

Date Filed Document Text
April 17, 2024 Filing 32 ANSWER and Affirmative Defenses to Amended Complaint by Affluent Ads, LLC. (Socarras, Ruben)
April 17, 2024 Filing 31 MOTION to Adopt/Join #20 Defendant's MOTION to Dismiss #1 Notice of Removal (State Court Complaint), by Affluent Ads, LLC. (Socarras, Ruben)
April 17, 2024 Opinion or Order Filing 30 PAPERLESS ORDER granting #29 Defendant Patrick Cook's Motion for Extension of Time to File Response/Answer to a Plaintiff's Amended Complaint. Defendant Cook's Response/Answer is due 5/7/2024. However, the Undersigned notes that Defendant's motion improperly cites to the instant case again. Earlier today, the Undersigned entered an Order [ECF No. #28 ] granting Defendant Cook's Motion for Substitution of Counsel. In that Order, the Undersigned highlighted and informed Defendant Cook that his filings must include the proper case citation. All parties (especially Defendant Cook) must be mindful of the citation and make sure that the proper citation is included on all future filings. Signed by Magistrate Judge Jonathan Goodman on 4/17/2024. (cpa)
April 17, 2024 Filing 29 Unopposed MOTION for Extension of Time to File Response/Reply/Answer or Otherwise Respond to Plaintiff's Amended Complaint by Patrick Cook. (Trigo, Capri)
April 17, 2024 Opinion or Order Filing 28 ORDER granting #27 Motion for Substitution of Counsel. Attorney added: Ana Maria Perez for Patrick Cook. Attorneys Brittany Lee Hynes and Paul Lopez representing Defendant Patrick Cook are terminated from this case. Signed by Magistrate Judge Jonathan Goodman on 4/17/2024. See attached document for full details. (cpa)
April 16, 2024 Filing 27 STIPULATED MOTION for Substitution of Counsel. Substituting Capri Trigo, Ana M. Perez for Brittany L. Hynes, Paul O. Lopez by Patrick Cook. Attorney Capri Trigo added to party Patrick Cook(pty:dft). Responses due by 4/30/2024. (Attachments: #1 Exhibit Exhibit A Order)(Trigo, Capri)
April 5, 2024 Opinion or Order Filing 26 PAPERLESS ORDER SETTING HEARING. Pending motions in this case are hereby SET for hearing before the undersigned on Monday, April 29, 2024, at 10:00 a.m. in Courtroom 6 on the 10th Floor of the James Lawrence King Federal Courthouse, 99 N.E. 4th Street, Miami, Florida, 33132. Signed by Judge Jacqueline Becerra on 4/5/2024. (ad02)
April 3, 2024 Filing 25 First AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Quotestorm Holdings, LLC. (Attachments: #1 Exhibit Master Service Agreement dated 1.5.2023, #2 Exhibit Employment Agreement btwn. Quotestorm and Cook dated 12.19.2022)(Klein, Jason)
March 27, 2024 Opinion or Order Filing 24 REVISED ORDER OF REASSIGNMENT to Judge Jacqueline Becerra for all further proceedings, Judge Kathleen M. Williams no longer assigned to case. Signed by Judge Kathleen M. Williams on 3/27/2024. See attached document for full details. (vjk)
March 15, 2024 Filing 23 Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Quotestorm Holdings, LLC (Klein, Jason)
March 15, 2024 Filing 22 First Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Affluent Ads, LLC (Socarras, Ruben)
March 14, 2024 Filing 21 Defendant, Affluent Ads, LLC's ANSWER and Affirmative Defenses to Complaint re the Notice of Removal (State Court Complaint) by Affluent Ads, LLC. (Socarras, Ruben)
March 14, 2024 Filing 20 Defendant's MOTION to Dismiss #1 Notice of Removal (State Court Complaint), by Patrick Cook. Responses due by 3/28/2024. (Lopez, Paul)
March 6, 2024 Opinion or Order Filing 19 MAGISTRATE JUDGE GOODMAN'S DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jonathan Goodman on 3/6/2024. See attached document for full details. (fbn)
March 6, 2024 Filing 18 Plaintiff's NOTICE Filing by Quotestorm Holdings, LLC re #5 Order Referring Case to Magistrate Judge,, Notice of Court Practice/to Appear/Other, (Attachments: #1 Exhibit Declaration of Juan Carlos Redero) (Klein, Jason)
March 6, 2024 Filing 17 Joint SCHEDULING REPORT - Rule 16.1 by Quotestorm Holdings, LLC (Attachments: #1 Exhibit JOINT PROPOSED SCHEDULING ORDER)(Klein, Jason)
March 1, 2024 Filing 16 NOTICE of Attorney Appearance by Richard M. Bales, Jr on behalf of Quotestorm Holdings, LLC. Attorney Richard M. Bales, Jr added to party Quotestorm Holdings, LLC(pty:pla). (Bales, Richard)
March 1, 2024 Filing 15 NOTICE OF FILING ALL RECORDS IN THE UNDERLYING STATE COURT ACTION by Affluent Ads, LLC (Attachments: #1 Exhibit Civil Cover Sheet, #2 Exhibit Complaint, #3 Exhibit Request for Production to Patrick Cook, #4 Exhibit Request for Production to Affluent Ads, LLC, #5 Exhibit Notice of Serving Interrogatories to Patrick Cook, #6 Exhibit Notice of Serving Interrogatories to Affluent Ads, LLC, #7 Exhibit 20 Day Summons to Patrick Cook, #8 Exhibit 20 Day Summons to Affluent Ads, LLC, #9 Exhibit ESummons Issued to Patrick Cook, #10 Exhibit ESummons Issued to Affluent Ads, LLC, #11 Exhibit Notice of Appearance for Affluent Ads, LLC, #12 Exhibit Notice of Appearance for Patrick Cook, #13 Exhibit Affluent Ads, LLC Notice of Removal, #14 Exhibit Defendant Patrick Cook's Notice of Joinder to Defendant, Affluent Ads, LLC's Notice of Removal) (Socarras, Ruben)
March 1, 2024 Filing 14 STATUS REPORT by Affluent Ads, LLC (Socarras, Ruben)
February 29, 2024 Opinion or Order Filing 13 PAPERLESS ORDER granting #12 Defendant Affluent Ads LLC's MOTION for Extension of Time to Respond to Plaintiff's Complaint. Plaintiff does not oppose the relief requested. The motion states that Defendant's response is currently due today. Therefore, the instant motion fails to comply with Judge Williams' 48-hour rule. See Judge Williams' Court Practices and Procedures (available at the Court's website: https://www.flsd.uscourts.gov/content/judge-kathleen-m-williams).The Undersigned will exercise my discretion and grant the requested extension. Nonetheless, the parties are directed to adhere to the rules of this Court going forward. Defendant Affluent Ads, LLC will have until March 14, 2024 to file on CM/ECF their response to the Amended Complaint. Signed by Magistrate Judge Jonathan Goodman on 2/29/2024. (cpa)
February 29, 2024 Filing 12 MOTION for Extension of Time to File Response/Reply/Answer to Complaint after Removal by Affluent Ads, LLC. (Socarras, Ruben)
February 27, 2024 Filing 11 Clerk's Notice to Filer re #8 Notice (Other). Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#10]. It is not necessary to refile this document. (ls)
February 26, 2024 Filing 10 Notice of Adoption/Joinder by Patrick Cook Related document: #1 Notice of Removal (State Court Complaint), filed by Affluent Ads, LLC (ls)(See Image at DE #8 )
February 26, 2024 Filing 9 NOTICE of Attorney Appearance by Jason Klein on behalf of Quotestorm Holdings, LLC (Klein, Jason)
February 26, 2024 Filing 8 Defendant's NOTICE of Joinder to Defendant Affluent Ads LLC's Notice of Removal by Patrick Cook (Lopez, Paul)
February 26, 2024 Filing 7 NOTICE of Attorney Appearance by Brittany Lee Hynes on behalf of Patrick Cook. Attorney Brittany Lee Hynes added to party Patrick Cook(pty:dft). (Hynes, Brittany)
February 26, 2024 Filing 6 NOTICE of Attorney Appearance by Paul Octavio Lopez on behalf of Patrick Cook. Attorney Paul Octavio Lopez added to party Patrick Cook(pty:dft). (Lopez, Paul)
February 22, 2024 Opinion or Order Filing 5 ORDER OF REFERRAL AND NOTICE OF COURT PRACTICE IN REMOVAL CASES REFERRING CASE to Magistrate Judge Jonathan Goodman for Pretrial Non-Dispositive Matters. Signed by Judge Kathleen M. Williams on 2/22/2024. See attached document for full details. (pc)
February 22, 2024 Filing 4 CLERK'S NOTICE - Attorney David Alan Yarema has not been added to this case re #1 Notice of Removal (State Court Complaint), due to his membership status in this Courts Bar #https://www.flsd.uscourts.gov/flsd-bar-admission-status-and-admission-date-look. (pt)
February 22, 2024 Filing 3 Clerk's Notice to Filer re: Electronic Case. Documents Improperly Arranged. The Filer did not properly attach the Exhibits. Future filings must comply with the CM/ECF Civil Case Opening Guide. It is not necessary to re-file this document. (pc)
February 22, 2024 Filing 2 Clerks Notice of Judge Assignment to Judge Kathleen M. Williams. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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. (pc)
February 22, 2024 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - DEFENDANT, AFFLUENT ADS, LLCS NOTICE OF REMOVAL) Filing fee $ 405.00 receipt number AFLSDC-17311439, filed by Affluent Ads, LLC.(Socarras, Ruben) (Complaint see pg. 2 of Exhibits, no Answer/Motion to Dismiss filed) (Main Document 1 replaced on 2/22/2024) (pc). (Additional attachment(s) added on 2/22/2024: #1 Exhibit, #2 Civil Cover Sheet) (pc). Modified text on 2/22/2024 (pc).

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Plaintiff: Quotestorm Holdings, LLC
Represented By: Jason Klein
Represented By: Richard M. Bales, Jr.
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Defendant: Patrick Cook
Represented By: Brittany Lee Hynes
Represented By: Capri Trigo
Represented By: Paul Octavio Lopez
Represented By: Ana Maria Perez
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Defendant: Affluent Ads, LLC doing business as Leadnomics
Represented By: Jafar M. Abuyounis
Represented By: Ruben E. Socarras, Jr.
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