Alternative Global Two LLC et al v. Blackstream Development LLC
| Alternative Global Two, LLC, Alternative Global Four, LLC and Alternative Global Five, LLC |
| Blackstream Development LLC |
| 1:2024cv21147 |
| March 27, 2024 |
| US District Court for the Southern District of Florida |
| Miami Office |
| Rodolfo A Ruiz |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity-Breach of Fiduciary Duty |
| Defendant |
Docket Report
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This docket was last retrieved on March 27, 2024. A more recent docket listing may be available from PACER.
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Filing 68
Bar Letter re: Admissions sent to attorneys Laura McDonald, William Stevens Brown, William Logan Lewis, Carter R. Massingill, Ioannis George Conits, John T. Lay, Lindsay Anne Joyner, Ross B. Plyler, mailing date March 27, 2024. (cw)
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Filing 67
Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (bb)
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Filing 66
Case transferred in from South Carolina; Case Number 6:22-cv-04501. Electronic file including transfer order and docket sheet received. .(bb).
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Filing 64
ORDER AND OPINION granting #49 Motion to Transfer Case, including all remaining pending motions, to the Southern District of Florida. Signed by Honorable Jacquelyn D Austin on 3/26/24.(jtho, ) Modified on 3/27/2024 to edit text (jtho, ).
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Filing 63
TEXT ORDER granting #61 Motion for Jon L. Swergold to Appear Pro Hac Vice for plaintiffs. Signed by Honorable Jacquelyn D Austin on 3/26/24.(jtho, )
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Filing 62
TEXT ORDER granting #60 Motion for Avi Benayoun to Appear Pro Hac Vice for plaintiffs. Signed by Honorable Jacquelyn D Austin on 3/26/24.(jtho, )
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Filing 61
MOTION to Appear Pro Hac Vice by Jon L. Swergold ( Filing fee $ 350 receipt number ASCDC-11669589) by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Response to Motion due by 4/8/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Application/Affidavit for Pro Hac Vice Admission for Swergold)No proposed order.(Brown, William)
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Filing 60
MOTION to Appear Pro Hac Vice by Avi Benayoun ( Filing fee $ 350 receipt number ASCDC-11669577) by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Response to Motion due by 4/8/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Application/Affidavit for Pro Hac Vice Admission for Benayoun)No proposed order.(Brown, William)
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Filing 59
RESPONSE in Opposition re #50 MOTION to Compel Subpoena Response by Southern First Response filed by Southern First Bancshares, Inc. d/b/a Southern First Bank.Reply to Response to Motion due by 3/29/2024 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit 1: Affidavit of Carl Francois)(Plyler, Ross) Modified on 3/22/2024 to add document description (jtho, ).
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Filing 58
MOTION to Compel Production Responsive to Second Request for Production by Alternative Global Two LLC. Response to Motion due by 4/4/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Memo in Support, #2 Exhibit 1 - Plf's Second Request for Production to Defendant, #3 Exhibit 2 - Def's Responses to Plf's Second Request for Production, #4 Exhibit 3 - Def's First Set of Discovery to Plfs, #5 Exhibit 4 - Plfs' Responses to Defs First Set of Discovery, #6 Exhibit 5 - Order from Florida matter, #7 Exhibit 6 - Plfs' Initial Disclosures, #8 Exhibit 7 - Rule 26f Report, #9 Exhibit 8 - 12/6/2023 McManus email, #10 Exhibit 9 - 1/31/2024 Massingill email, #11 Exhibit 10 - 2/1/2024 Brown email, #12 Exhibit 11 - 3/15/2024 Brown email, #13 Joint Certification)No proposed order.(Brown, William)
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Filing 57
MOTION to Compel Production Responsive to First Request for Production by Alternative Global Two LLC. Response to Motion due by 4/4/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Memo in Support, #2 Exhibit 1 - Plf's First Request for Production to Defendant, #3 Exhibit 2 - Def's Responses to Plf's First Request for Production, #4 Exhibit 3 - Def's First Set of Discovery to Plfs, #5 Exhibit 4 - Plfs' Responses to Defs First Set of Discovery, #6 Exhibit 5 - Order from Florida matter, #7 Exhibit 6 - Plfs' Initial Disclosures, #8 Exhibit 7 - Rule 26f Report, #9 Exhibit 8 - 12/6/2023 McManus email, #10 Exhibit 9 - 1/31/2024 Massingill email, #11 Exhibit 10 - 2/1/2024 Brown email, #12 Exhibit 11 - 3/15/2024 Brown email, #13 Joint Certification)No proposed order.(Brown, William)
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Filing 56
MOTION to Compel Complete Answers to First Set of Interrogatories by Alternative Global Two LLC. Response to Motion due by 4/4/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Memo in Support, #2 Exhibit 1 - Plf's First Interrogatories to Defendant, #3 Exhibit 2 - Def's Responses to Plf's First Interrogatories, #4 Exhibit 3 - Def's First Set of Discovery to Plfs, #5 Exhibit 4 - Plfs' Responses to Defs First Set of Discovery, #6 Exhibit 5 - Order from Florida matter, #7 Exhibit 6 - 12/06/2023 McManus email, #8 Exhibit 7 - 1/31/2024 Massingill email, #9 Exhibit 8 - 2/1/2024 Brown email, #10 Exhibit 9 - 3/15/2024 Brown email, #11 Joint Certification)No proposed order.(Brown, William)
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Filing 54
REPLY to Response to Motion re #48 MOTION to Quash and for Protective Order MOTION for Protective Order Response filed by Blackstream Development LLC. (Attachments: #1 Exhibit Subpoena to Blackstream, #2 Exhibit Judge Reid's Order, #3 Exhibit Plaintiffs' Objections and Responses to Blackstream's Written Discovery, #4 Exhibit 09/12/2022 Declaration of Josh Howard)(Massingill, Carter)
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Filing 53
REPLY to Response to Motion re #49 MOTION to Transfer Case Response filed by Blackstream Development LLC. (Attachments: #1 Exhibit Subpoena to Blackstream, #2 Exhibit King Case, #3 Exhibit Plaintiffs' discovery responses)(Conits, Ioannis)
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Filing 52
RESPONSE in Opposition re #48 MOTION to Quash and for Protective Order MOTION for Protective Order Response filed by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC.Reply to Response to Motion due by 3/18/2024 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit 1 - Defendants Rule 26(a)(1) Disclosures, #2 Exhibit 2 - Blackstreams Responses and Objections to Plaintiffs First Set of Requests for Production, #3 Exhibit 3 - Affidavit of Service, #4 Exhibit 4 - 11.16.2023 Order Denying Blackstreams Motion to Dismiss, #5 Exhibit 5 - 12.21.2023 Rule 26(f) Report, #6 Exhibit 6 - 12.21.2023 Plaintiffs Rule 26(a)(1) Initial Disclosures, #7 Exhibit 7 - Wire Transfer for other real estate deals, #8 Exhibit 8 - Wire Transfers information, #9 Exhibit 9 - McManus email, #10 Exhibit 10 - Massingill email, #11 Exhibit 11 - Brown email)(Brown, William) (Attachment 11 replaced on 3/12/2024 to add exhibit # page per request of filer) (jtho, ). M
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Filing 51
RESPONSE in Opposition re #49 MOTION to Transfer Case Response filed by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC.Reply to Response to Motion due by 3/18/2024 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit 1 - Declaration of Richard Cardinale, #2 Exhibit 2 - Opinion of Vice Chancellor Lori W. Will, Court of Chancery of the State of Delaware, #3 Exhibit 3 - Order regarding Stay from Florida, #4 Exhibit 4 - Plaintiffs Rule 26a1 Initial Disclosures, #5 Exhibit 5 - Broadstreet Inc. website, #6 Exhibit 6 - Broadstreet People, #7 Exhibit 7 - Defendants Rule 26(a)(1) Initial Disclosures, #8 Exhibit 8 - Blackstreams Objections to First Request for Production and Second Request for Production, #9 Exhibit 9 - Blackstreams Objections to First Set of Interrogatories, #10 Exhibit 10 - Contender Development projects, #11 Exhibit 11 - Table C-3, USDCCivil Federal Judicial Caseload Statistics, #12 Exhibit 12 - Table X-1A, USDC-Weighted and Unweighted Filings per Authorized Judgeship During the 12-Month Period Ending Mar. 31, 2023, #13 Exhibit 13 - Table C-5, USDC Civil Federal Judicial Caseload Statistics (March 31, 2023))(Brown, William) (Attachments 1 and 10 replaced on 3/12/2024 for page orientation) (jtho, ).
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Filing 50
MOTION to Compel Subpoena Response by Southern First by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Response to Motion due by 3/25/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Joint Certification, #2 Memo in Support, #3 Exhibit 1 - Affidavit of Service, #4 Exhibit 2 - Subpoena to Southern First, #5 Exhibit 3 - 2.19.2024 Plyler letter in response to subpoena, #6 Exhibit 4 - Plaintiffs' Rule 26(a)(1) Initial Disclosures, #7 Exhibit 5 - 12.6.2023 Brown email, #8 Exhibit 6 - 1.31.2024 Massingill email, #9 Exhibit 7 - 2.1.2024 Brown email, #10 Exhibit 8 - Defendants Rule 26(a)(1) Disclosures, #11 Exhibit 9 - Blackstreams Objections to Plaintiffs First Set of Requests for Production, #12 Certificate of Service)No proposed order.(Brown, William)
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Filing 49
MOTION to Transfer Case by Blackstream Development LLC. Response to Motion due by 3/11/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Second Amended Complaint in the Florida Action, #2 Florida Order on Timing and Sequence, #3 9.27.22 Cardinale Declaration, #4 Cardinale Memorandum in Opposition to Blackstream's Motion to Quash, #5 11.14.23 Cardinale Declaration, #6 AG2, 4 and 5 Operating Agreements, #7 Cardinale Objection to Florida Order, #8 Portions of Transcript of Motions Hearing before Judge Cain, #9 Florida Order on Nonparty Motions to Quash Subpoenas, #10 Declaration of Joshua L. Howard, #11 Declaration of Ford S. Elliott, #12 Declaration of David Feingold, #13 Declaration of Michael Dazzo)No proposed order.(Conits, Ioannis)
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Filing 48
MOTION to Quash, Motion for Protective Order by Blackstream Development LLC. Response to Motion due by 3/11/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Exhibit Southern First Subpoena, #2 Exhibit Joint Certification of Consultation, #3 Exhibit Southern First's Objection)No proposed order.(Conits, Ioannis). Added MOTION for Protective Order on 2/26/2024 (jtho, ).
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Filing 47
NOTICE OF CHANGE OF CASE NUMBER: The new case number is 6:22-cv-04501-JDA. Please make a note of this for all future filings as well as Judge Austin's filing preferences. (jens)
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Filing 46
Case Reassigned to Judge Honorable Jacquelyn D Austin. Judge Honorable Timothy M Cain no longer assigned to the case. (cwil, )
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Filing 44
TEXT ORDER granting #43 Consent Motion to Substitute Attorney. The law firm of Gallivan, White & Boyd, P.A., is hereby substituted as counsel of record for the law firm of Wyche, P.A. for Defendant. Entered at the direction of the Honorable Timothy M Cain on 2/12/24.(kmca)
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Filing 43
Consent MOTION to Substitute Attorney by Blackstream Development LLC. Response to Motion due by 2/26/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Massingill, Carter)
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Filing 41
NOTICE of Appearance by Carter R Massingill on behalf of Blackstream Development LLC (Massingill, Carter)
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Filing 40
NOTICE of Appearance by Laura McDonald on behalf of Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC (McDonald, Laura)
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Filing 39
TEXT ORDER granting #38 Motion to Appear Pro Hac Vice. Attorney John L. McManus added for Plaintiffs. Entered at the direction of the Honorable Timothy M Cain on 1/10/24.(kmca)
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Filing 38
MOTION to Appear Pro Hac Vice by John L. McManus ( Filing fee $ 350 receipt number ASCDC-11518440) by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Response to Motion due by 1/23/2024. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Affidavit for Pro Hac Vice Admission)No proposed order.(Brown, William)
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Filing 37
AMENDED SCHEDULING ORDER: Motions to Amend Pleadings due by 6/18/2024, Plaintiffs ID of Expert Witness due by 7/19/2024, Defendants ID of Expert Witnesses Due by 9/19/2024, Records Custodian Affidavit due by 9/19/2024, Discovery due by 10/18/2024, Mediation Due by 10/25/2024, Motions due by 11/18/2024, Jury Selection Deadline 12/2/2024 or sixty (60) days after dispositive motions have been resolved. Signed by Honorable Timothy M Cain on 01/03/2024. (jens)
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Filing 36
ADR STATEMENT/CERTIFICATION by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC(Brown, William)
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Filing 35
ADR STATEMENT/CERTIFICATION by Blackstream Development LLC(English, Gregory)
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Filing 34
Joint Rule 26(f) Report and Joint LR 26.03 Answers, by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC, Blackstream Development LLC. (Attachments: #1 Exhibit Consent Amended Scheduling Order, #2 Exhibit Certification as to Mediation)(Brown, William) Modified on 12/21/2023: to add joint filer as listed, to add text (26.03s) (kmca).
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Filing 33
ANSWER to #1 Complaint, by Blackstream Development LLC.(English, Gregory)
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Filing 32
MEDIATION ORDER. Mediation Due by 5/8/2024. Signed by Honorable Timothy M Cain on 11/17/23. (kmca)
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Filing 31
SCHEDULING ORDER: Rule 26(f) Conference Deadline 12/7/2023, 26(a) Initial Disclosures due by 12/21/2023, ADR Statement/Certification due by 12/21/2023, Rule 26 Report due by 12/21/2023, Motions to Amend Pleadings due by 1/31/2024, Plaintiffs ID of Expert Witness due by 3/1/2024, Defendants ID of Expert Witnesses Due by 4/1/2024, Records Custodian Affidavit due by 4/1/2024, Discovery due by 5/1/2024, Motions due by 5/15/2024, Jury Selection Deadline 7/15/2024 or sixty (60) days after dispositive motions have been resolved. Signed by Honorable Timothy M Cain on 11/17/23. (kmca)
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Filing 30
TEXT ORDER denying #10 Motion to Dismiss or Motion for a More Definite Statement. Defendant filed a Motion to Dismiss, or, in the alternative, a Motion for a More Definite Statement. (ECF No. #10 ). In its motion, Defendant asserts that the Complaint is "so vague or ambiguous that the party cannot reasonably prepare a response." (ECF No. #10 -1 at 23) (quoting Fed. R. Civ. P. 12(e)). However, Defendant attached seventeen exhibits to its motion, totaling over 1,100 pages for the court to review. Plaintiff responded to the motion and attached twenty-four of its own exhibits, totaling over 130 pages for the court to review. (ECF No. #20 ). Defendant filed a response and attached yet another declaration as an exhibit thereto. (ECF Nos. #21 , #21 -1). As Defendant's motion has presented matters outside the pleadings, the court must treat the motion as one for summary judgment. Fed. R. Civ. P. 12(d). Accordingly, "[a]ll parties must be given a reasonable opportunity to present all the material that is pertinent to the motion." Id. In this case, no scheduling order has been entered, and no formalized discovery has taken place. Accordingly, the court finds it prudent to deny the motion as premature at this time to allow the parties to engage in formal discovery. In its request for a more definite statement, Defendant listed several questions that go to the merits of the underlying claims, and discovery will enable the parties to further develop the record as to those questions. However, the court also finds that based on the information before it at this time, including the 1,200+ pages filed by the parties as to the motion to dismiss, a more definite statement as to the asserted claims is not necessary, as Defendant was clearly able to form a response and provide ample documentation as it its preliminary position. Accordingly, the court finds the motion to dismiss is essentially a premature motion for summary judgment and finds that further discovery would be helpful to developing the claims and/or defenses in this case. At this juncture, the motion (ECF No. #10 ) is DENIED without prejudice and with leave to refile. IT IS SO ORDERED. Entered at the direction of the Honorable Timothy M Cain on 11/16/23.(kmca)
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Filing 27
Joint STATUS REPORT by Blackstream Development LLC, Alternative Global Two LLC, Alternative Global Four LLC, Alternative Global Five LLC. (English, Gregory) Modified on 8/7/2023: to add joint filers as listed (kmca).
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Filing 25
TEXT ORDER granting #23 Joint Motion to Stay. The parties have jointly moved to stay all deadlines in this matter for thirty (30) days to allow the parties to conduct settlement negotiations. (ECF No. #23 ). The court finds it appropriate in the interest of judicial economy to grant the parties' motion and stay all current deadlines in this action so the parties may work towards resolving the matters raised in this case. Accordingly, the parties' joint motion (ECF No. #23 ) is GRANTED and all further action in this case is STAYED until August 7, 2023. The parties shall file a joint status report on or before August 7, 2023, indicating whether a global settlement has been reached. IT IS SO ORDERED. Entered at the direction of the Honorable Timothy M Cain on 7/12/23.(kmca)
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Filing 23
Joint MOTION to Stay by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC, Blackstream Development LLC. Response to Motion due by 7/24/2023. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Brown, William) Modified on 7/11/2023: to add joint filer as listed (kmca).
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Filing 21
REPLY to Response to Motion re #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION for More Definite Statement Response filed by Blackstream Development LLC. (Attachments: #1 Exhibit Declaration of Joshua L. Howard)(English, Gregory)
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Filing 20
RESPONSE in Opposition re #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION for More Definite Statement Response filed by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Reply to Response to Motion due by 3/31/2023. (Attachments: #1 Exhibit A - Declaration of Richard Cardinale Blackstream, #2 Exhibit 1 2019-11-26 Email from Howard re Estimate Cash through 2020, #3 Exhibit 2 2020-01-09 Email from Howard re detailed report, #4 Exhibit 3 2021-01-22 Feingold to Dazzo re Finally have arranged that in Greenville, #5 Exhibit 4 2020-02-13 J. Howard to R. Cardinale re Project Status, #6 Exhibit 5 2020-06-09 Cardinale email to J. Howard re TPS Morrisville, #7 Exhibit 6 2020-06-11 D. Feingold to R. Cardinale re DR Horton, #8 Exhibit 7 2020-06-16 Feingold to Cardinale re updated brochure, #9 Exhibit 8 2020-09-25 Elliott Provides Update, #10 Exhibit 9 2020-09-25 Feingold to Michael Dazzo and Richard Cardinale with update, #11 Exhibit 10-01 Feingold text to Dazzo and Cardinale re Ford Elliott statement, #12 Exhibit 11 2020-10-08 Feingold ro Cardinale re Turner statement, #13 Exhibit 12 2020-10-10 Feingold to Cardinale with Maxine Turner Wilson Bridge Financials, #14 Exhibit 13 - 2020-10-10-Email from Feingold to R. Cardinale re. Consolidated real estate projects, #15 Exhibit 14 - 2020-11-23 Feingold email to Cardinale, #16 Exhibit 15 2020-12-15 F. Elliot to R. Cardinale re Project Status, #17 Exhibit 16 2021-01-19 D. Feingold to R. Cardinale re Blackstream, #18 Exhibit 17 2021-03-04 A. Mormile to F. Elliott, #19 Exhibit 18 2021-03-8 J. Howard to R. Cardinale re Update on Project, #20 Exhibit 19 2021-04-05 Text from Ryan to Rich, #21 Exhibit 20 2021-11-04 Ford Elliot Text Message, #22 Exhibit 21 December 2021 Quarterly Report for L3, #23 Exhibit 22 2022-02-05 Text Message to Ford Elliot, #24 Exhibit 23 2022-07-01 Text Message to Josh Howard)(Brown, William) Modified on 3/6/2023: to reset Reply deadline per 18 order (kmca). (Attachments 7, 10, 13, 14 and 15 replaced on 3/6/2023: to replace with corrected documents (legible) as provided by filing user) (kmca).
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Filing 18
TEXT ORDER granting #17 Joint Motion for Extension of Time to File Response/Reply as to #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, MOTION for More Definite Statement. Response to Motion due by 3/3/2023. Reply due by 3/31/2023. Entered at the direction of the Honorable Timothy M Cain on 2/23/23.(kmca)
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Filing 17
Joint MOTION for Extension of Time to File Response/Reply as to #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION for More Definite Statement by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC, Blackstream Development LLC. Response to Motion due by 3/9/2023. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Brown, William) Modified on 2/23/2023: to add joint filer as listed (kmca).
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Filing 16
TEXT ORDER granting #15 Consent Motion for Extension of Time to File Response as to #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM or MOTION for More Definite Statement. Response to Motion due by 2/23/2023. Entered at the direction of the Honorable Timothy M Cain on 2/9/23.(kmca)
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Filing 15
Consent MOTION for Extension of Time to File Response/Reply as to #10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION for More Definite Statement by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC. Response to Motion due by 2/23/2023. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Brown, William)
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Filing 13
Local Rule 26.01 Answers to Interrogatories by Blackstream Development LLC.(English, Gregory)
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Filing 10
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM or MOTION FOR MORE DEFINITE STATEMENT by Blackstream Development LLC. Response to Motion due by 2/9/2023. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Memo in Support, #2 Exhibit Declaration of Joshua L. Howard, #3 Exhibit A to Declaration - Complaint, #4 Exhibit B to Declaration - Declaration of Josh Howard dated 9/12/22, #5 Exhibit C to Declaration - Reply Declaration of Josh Howard dated 10/6/22, #6 Exhibit D to Declaration - Cardinale Declaration, #7 Exhibit E to Declaration - First Amended Complaint in FL action, #8 Exhibit F to Declaration - Order Quashing Subpoena to Davick Capital, #9 Exhibit G to Declaration - Order Quashing Subpoena to Titan Communications, #10 Exhibit H to Declaration - FTC Press Release, #11 Exhibit I to Declaration - NYAG Complaint, #12 Exhibit J to Declaration - Giardina's deposition and other Court decisions, #13 Exhibit K to Declaration - SDNY Judge Lewis J. Liman's decision dated 6/6/22, #14 Exhibit L to Declaration - Order of Judge Lisette M. Reid dated 9/23/22, #15 Exhibit M to Declaration - Vice Chancellor Lori W. Will's decision dated 1/10/23, #16 Exhibit N to Declaration - L3 PPM, #17 Exhibit O to Declaration - L3 Audited Financials)No proposed order.(English, Gregory). Added MOTION for More Definite Statement on 1/27/2023: to add additional relief listed (kmca). (Attachment 4, 5, 6, 8, 9, 10, 11, replaced on 1/27/2023: to replace with legible documents (headers) as provided by filing user) (Attachment 12 replaced on 1/27/2023: to replace with corrected document (LR 5.01) as provided by filing user) (kmca).
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Filing 8
LETTER EXTENDING TIME TO ANSWER Blackstream Development LLC answer due 1/26/2023. (Attachments: #1 Supporting Documents Extension letter)(English, Gregory)
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Filing 6
SUMMONS Returned Executed by Alternative Global Two LLC, Alternative Global Four LLC, Alternative Global Five LLC. Blackstream Development LLC served on 12/15/2022, answer due 1/5/2023. (Attachments: #1 Exhibit A - Affidavits of Service)(kmca) Re-filed by clerk as requested by filing user (kmca)
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Filing 4
Summons Issued as to Blackstream Development LLC. (kmca)
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Filing 3
Local Rule 26.01 Answers to Interrogatories by Alternative Global Five LLC, Alternative Global Four LLC, Alternative Global Two LLC.(kmca)
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Filing 1
COMPLAINT against Blackstream Development LLC (Filing fee $402 receipt number ASCDC-10845667), filed by Alternative Global Two LLC, Alternative Global Four LLC, Alternative Global Five LLC. Service due by 3/13/2023. (Attachments: #1 Exhibit 1 - 7.1.22 Cardinale Correspondence to Ford Elliott)(kmca)
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