Neal v. Sports Stats IQ LLC et al
| EDDIE NEAL |
| SPORTS STATS IQ LLC, CHRISTOPHER J. VAN DAM, P.A., CHRISTOPHER JAMES VAN DAM and Sylvester Butler |
| Thomas Stanton |
| 1:2025cv21947 |
| April 29, 2025 |
| U.S. District Court for the Southern District of Florida |
| Enjolique A Lett |
| Kathleen M Williams |
| Patent |
| 29 U.S.C. § 1109 Breach of Fiduciary Duties |
| None |
Docket Report
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This docket was last retrieved on October 24, 2025. A more recent docket listing may be available from PACER.
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| Filing 85 Joint MOTION TO DISMISS 81 Order on Motion for Leave to File,,,,,, Order on Motion to Dismiss,,,,,, Order on Motion to Dismiss for Failure to State a Claim,,,,,, Order on Motion to Stay,,,,, #1 Complaint,,, FOR FAILURE TO STATE A CLAIM by Sylvester Butler, Christopher J. Van Dam, P.A., Sports Stats IQ LLC, Christopher James Van Dam. Responses due by 11/7/2025. (Getz, Jessica) |
| Filing 84 Clerk's Notice to Filer re #80 Response to Motion,. Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#83]. It is not necessary to refile this document. (ls) |
| Filing 83 RESPONSE TO ORDER TO SHOW CAUSE re 74 Order to Show Cause,, by Christopher J. Van Dam, P.A., Christopher James Van Dam. (ls)(See Image at DE #80) |
| Filing 82 NOTICE of Mediator Selection. Selected/Added Mark Stein as Mediator. (Attachments: #1 Exhibit Exhibit A. Proposed Order)(Drolet, Robert) |
Filing 81
PAPERLESS ORDER. THIS MATTER is before the Court on Defendants Sylvester Butler and Sports Stats IQ LLC's Motion for Leave to File Amended Motion to Dismiss ("Motion") (DE #79 ). In the Motion, Defendants seek leave to file an amended Motion to Dismiss in light of Defendants' prior lack of representation. The Court's Order of Referral (DE #6 ) states that "[w]here there are multiple Plaintiffs or Defendants, the Parties shall file joint motions and consolidated responses and replies unless there are clear conflicts of position." Accordingly, Defendant Sylvester Butler's Motion to Dismiss (DE #18 ) and Defendants Christopher J. Van Dam, P.A. and Christopher James Van Dam's Motion to Dismiss (DE #27 ) are DENIED. Defendants are instructed to file a joint Motion to Dismiss that comports with the Court's Order of Referral (DE #6 ) that shall not exceed fifty (50) pages. Defendants shall file this joint Motion to Dismiss on or before October 24, 2025. If there are any conflicts of interest that prevent Defendants from filing a joint motion, they shall indicate that to this court with a notice and then file separate motions to dismiss that shall not exceed twenty (20) pages on or before October 24, 2025.In light of the foregoing, it is ORDERED AND ADJUDGED that the Motion is DENIED AS MOOT. Signed by Judge Kathleen M. Williams on 10/3/2025. (ymd)
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| Filing 80 RESPONSE to Motion re #79 MOTION for Leave to File Amended Motion to Dismiss Motion to Show Cause for failing to select a mediator timely filed by Christopher J. Van Dam, P.A., Christopher James Van Dam. Replies due by 10/10/2025. (Van Dam, Christopher) |
| Filing 79 MOTION for Leave to File Amended Motion to Dismiss by Sylvester Butler, Sports Stats IQ LLC. (Attachments: #1 Proposed Amended Motion to Dismiss)(Getz, Jessica) |
| Filing 78 RESPONSE TO ORDER TO SHOW CAUSE re 74 Order,,, Order to Show Cause,, by Sylvester Butler, Sports Stats IQ LLC. (Getz, Jessica) |
| Filing 77 CLERK'S NOTICE - Attorney Admissions has accepted the email information change request just submitted through attorneys PACER account for attorney Jessica Delaney Getz re #66 Notice of Change of Address, Email or Law Firm Name (pt) |
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Filing 76
PAPERLESS ORDER. THIS MATTER is before the Court sua sponte. The Parties shall file their Mediation Notice on or before October 10, 2025. Separately, the responsibility to comply with the Scheduling Order was not solely Plaintiff's. Accordingly, the Court expects responses from the Defendants as well as to why the mediation notice was not filed timely. Signed by Judge Kathleen M. Williams on 10/1/2025. (ymd)
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| Filing 75 RESPONSE TO ORDER TO SHOW CAUSE re 74 Order,,, Order to Show Cause,, by Eddie Neal. (Drolet, Robert) |
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Filing 74
PAPERLESS ORDER TO SHOW CAUSE. THIS MATTER is before the Court sua sponte. On August 13, 2025, the Court issued the Scheduling Order (DE #55 ) in this matter, requiring that the Parties file a joint notice of mediation "[w]ithin thirty (30) days of the date of this Order." To date, the Parties have failed to file a joint notice of mediation or a motion for extension of time to do so. Accordingly, it is ORDERED AND ADJUDGED that the Parties shall SHOW CAUSE on or before October 3, 2025 at 4:00 p.m. as to why sanctions should not be imposed for failure to comply with a Court Order. Signed by Judge Kathleen M. Williams on 10/1/2025. (ymd)
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Filing 73
PAPERLESS ORDER. THIS MATTER is before the Court on Defendant's Notice and Motion Pursuant to Court Order ("Motion") (DE #54 ). No motion was required to provide the Court with the required notice. Accordingly, it is ORDERED AND ADJUDGED that the Motion is DENIED AS MOOT. Signed by Judge Kathleen M. Williams on 10/1/2025. (ymd)
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| Filing 72 Corporate Disclosure Statement - NONE disclosed by Sports Stats IQ LLC (Lomnitzer, Lorri) Modified Filer on 9/19/2025 (ls). |
| Filing 71 CLERK'S NOTICE - Attorney Admissions has accepted the address information change request as submitted through attorneys PACER account for attorney Jessica Delaney Getz re #66 Notice of Change of Address, Email or Law Firm Name (pt) |
| Filing 70 NOTICE of Striking #67 Certificate of Other Affiliates/Corporate Disclosure Statement filed by Sports Stats IQ LLC by Sylvester Butler, Sports Stats IQ LLC (Lomnitzer, Lorri) |
| Filing 69 CLERK'S NOTICE - Attorney Admissions has not updated address and/or email information for attorney Jessica Delaney Getz re #66 Notice of Change of Address, Email or Law Firm Name. Attorney Jessica Delaney Getz has not completed the required procedures for updating their information with the Court. After filing something in any pending cases, Attorney is instructed to go to their PACER account, Manage My Account, to complete the process of updating their information. The Court is NOT responsible for updating secondary email addresses. See the Courts website for detailed instructions. #www.flsd.uscourts.gov/updating-your-information (pt) |
| Filing 68 Clerk's Notice to Filer re #67 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) |
| Filing 67 "STRICKEN" Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Sports Stats IQ LLC (Lomnitzer, Lorri) Modified Filer on 9/17/2025 (ls). Modified on 9/18/2025 (ls). (per DE #70) |
| Filing 66 NOTICE of Change of Address/Contact Information; Change of Email; Change of Law Firm Name; by Jessica Delaney Getz (Getz, Jessica) |
| Filing 65 NOTICE of Attorney Appearance by Lorri Lomnitzer on behalf of Sylvester Butler, Sports Stats IQ LLC (Lomnitzer, Lorri) |
| Filing 64 NOTICE of Striking #62 Notice of Attorney Appearance, filed by Sports Stats IQ LLC, Sylvester Butler by Sylvester Butler, Sports Stats IQ LLC. Attorney Lorri Lomnitzer added to party Sylvester Butler(pty:dft), Attorney Lorri Lomnitzer added to party Sports Stats IQ LLC(pty:dft). (Lomnitzer, Lorri) |
| Filing 63 Clerk's Notice to Filer re #62 Notice of Attorney Appearance,. 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) |
| Filing 62 "STRICKEN" NOTICE of Attorney Appearance by Lorri Lomnitzer on behalf of Sylvester Butler, Sports Stats IQ LLC. Attorney Lorri Lomnitzer added to party Sylvester Butler(pty:dft), Attorney Lorri Lomnitzer added to party Sports Stats IQ LLC(pty:dft). (Lomnitzer, Lorri) Modified on 9/17/2025 (ls). (per DE #64) |
| Filing 61 NOTICE of Attorney Appearance by Jessica Delaney Getz on behalf of Sylvester Butler, Sports Stats IQ LLC. Attorney Jessica Delaney Getz added to party Sylvester Butler(pty:dft), Attorney Jessica Delaney Getz added to party Sports Stats IQ LLC(pty:dft). (Getz, Jessica) |
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Filing 60
PAPERLESS ORDER. THIS MATTER is before the Court on Defendant Butler's Unopposed Motion for Extension of Time (DE #59 ) ("Motion"). In the Motion, Defendant Butler requests an extension of time through September 16, 2025 to obtain counsel for Sports Stats IQ LLC. This Court previously sua sponte gave Defendant Butler an extension for this same deadline. Under this extended deadline, Defendant Butler was required to obtain counsel by August 27, 2025. Accordingly, Defendant Butler's Motion does not 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). Nonetheless, because the Motion is unopposed, it is ORDERED AND ADJUDGED that the Motion is GRANTED. Defendant Butler shall obtain counsel for Sports Stats IQ on or before September 16, 2025 and such counsel shall file their appearance into this matter accordingly. No further extensions shall be given. Signed by Judge Kathleen M. Williams on 8/27/2025. (ymd)
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| Filing 59 Defendant's MOTION for Extension of Time to obtain counsel by Sylvester Butler. Responses due by 9/10/2025. (Van Dam, Christopher) |
| Filing 58 NOTICE of Compliance by Thomas Stanton re 56 Order,,,,,, (Stanton, Thomas) |
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Filing 57
PAPERLESS ORDER. THIS MATTER is before the Court sua sponte. The Court instructs the Parties to refrain from sending any emails to the Court regarding communications between the Parties and non-parties, or copying the Court onto any existing email threads representing communications between the Parties and non-parties. Accordingly, going forward, all matters to be considered by the Court must be through pleadings filed to the docket. Signed by Judge Kathleen M. Williams on 8/26/2025. (ymd)
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Filing 56
PAPERLESS ORDER TO SHOW CAUSE. THIS MATTER is before the Court on Defendant Sylvester Butler's Notice and Motion Pursuant to Court Order Regarding Inability to Obtain Client File From Prior Counsel ("Motion") (DE #54 ). In the Motion, Defendant represents that he has been unable to obtain his client file from his prior counsel, Mr. Thomas H. Stanton.Florida Bar Rule 4-1.16(d) provides that, "[u]pon termination of representation, a lawyer shall take steps to the extent reasonably practicable to protect a client's interest, such as...surrendering papers and property to which the client is entitled.". A "lawyer may retain papers and other property as security for a fee only to the extent permitted by law." Defendant Butler has represented that Mr. Stanton has been unresponsive to his requests for his client file. As far as the Court is aware, Defendant Butler does not owe Mr. Stanton any outstanding legal fees that justifies the retention of the client file. Accordingly, it is ORDERED AND ADJUDGED that Mr. Stanton will file a notice with the Court by August 20, 2025, that details the reasons for his refusal to turn over Defendant Butler's client file. Defendant Butler is instructed to immediately serve a copy of this Order to Mr. Stanton and then send a confirmatory email to the Court with proof of such service. The Court further considers Defendant Butler's deadline for retaining counsel on behalf of Sports Stats IQ LLC and sua sponte gives Defendant Butler an extension until August 27, 2025 to find counsel. Signed by Judge Kathleen M. Williams on 8/14/2025. (ymd)
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Filing 55
SCHEDULING ORDER: ( Jury Trial set for 7/13/2026 in Miami Division before Judge Kathleen M. Williams., Calendar Call set for 7/7/2026 11:00 AM in Miami Division before Judge Kathleen M. Williams.) Signed by Judge Kathleen M. Williams on 8/13/2025. See attached document for full details. (ls) #Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here.
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| Filing 54 NOTICE and MOTION pursuant to Court Order Regarding Inability to Obtain Client File from Prior Counsel by Sylvester Butler. (ls) |
| Filing 53 Amended SCHEDULING REPORT - Rule 16.1 by Joel Borgella, Eddie Neal (Attachments: #1 Exhibit Proposed Order)(Drolet, Robert) |
| Filing 52 Joint SCHEDULING REPORT - Rule 16.1 by Joel Borgella, Eddie Neal (Attachments: #1 Exhibit Proposed Order)(Drolet, Robert) |
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Filing 51
ORDER SETTING DISCOVERY PROCEDURES Signed by Magistrate Judge Enjolique A. Lett on 8/1/2025. See attached document for full details. (mwn)
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| Filing 50 Case Reassignment of Paired Magistrate Judge pursuant to Administrative Order(s) - 2025-52A to Magistrate Judge Enjolique A. Lett. Ch. Magistrate Judge Jonathan Goodman no longer assigned to case. (mno) |
| Set Deadlines: Deadline to obtain new counsel 8/14/2025. Joint Scheduling Report due by 8/7/2025. Per DE 49 . (wce) |
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Filing 49
PAPERLESS ORDER. THIS MATTER is before the Court following the July 24, 2025 Status Conference (DE 48). It is ORDERED AND ADJUDGED as follows:1. The Parties shall confer and file a Joint Scheduling Order by August 7, 2025. 2. Defendant Butler must retain counsel on or before August 14, 2025, who must, by that date, enter an appearance on behalf of Sports Stats IQ LLC. 3. If Defendant Butler has issues obtaining his client file from his prior attorney, he is instructed to notify the Court immediately by email. Signed by Judge Kathleen M. Williams on 7/24/2025. (ymd)
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| Filing 48 PAPERLESS Minute Entry for proceedings held before Judge Kathleen M. Williams. Zoom Status Conference held on 7/24/2025. Counsel of record and Mr. Sylvester Butler present. Court Reporter: Jill Wells, 305-523-5158 / [email protected]. (mso) |
| Filing 47 PAPERLESS ORDER denying #40 MOTION to Authorize Pro Se Litigant to Utilize the CM/ECF Autosender System for Filing Motions and Attend Hearings via Zoom by Sylvester Butler ("Butler"). The Undersigned notes that Butler is already receiving copies of court filings, which are sent to his email address ([email protected]). To the extent Butler is seeking electronic filing privileges, the motion is denied because in the Southern District of Florida, a pro se party is not permitted to electronically file documents on CM/ECF. Section 2C of the Southern District of Florida CM/ECF Administrative Procedures states that pro se litigants are required to "file their documents in a conventional manner." Pouyeh v. Pub. Health Tr. of Jackson Health Sys., No. 16-23582-CIV, 2023 WL 6296008, at *2 (S.D. Fla. Aug. 29, 2023), report and recommendation adopted, No. 16-23582-CIV, 2023 WL 6296037 (S.D. Fla. Sept. 27, 2023).4 The term "conventional manner" is defined in Section 1A of the Administrative Procedures as "'hard copies containing an original, handwritten (wet) signature of the filing attorney or pro se party' filed 'in person or by U.S. mail.'" Davide v. Seterus, Inc., No. 18-24486-CIV, 2019 WL 13255684, at *1 (S.D. Fla. Mar. 18, 2019) (quoting S.D. Fla. CM/ECF Administrative Procedures, 1A, 2C (effective Dec. 2, 2024), available at https://www.flsd.uscourts.gov/policies-procedures). Butler also seeks blanket permission to attend all hearings via Zoom. Because the July 24, 2025 status conference will be conducted via videoconference, Butler's request is denied without prejudice at this time. He may timely renew his request (if appropriate) upon the setting of an in-person hearing. Signed by Ch. Magistrate Judge Jonathan Goodman on 7/23/2025. (mkr) |
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Filing 46
PAPERLESS ORDER. THIS MATTER is before the Court on Plaintiff's Motion for Leave to Appear via Zoom Platform (DE #42 ). Because this Court ordered the Status Conference to be conducted virtually, Plaintiff's Motion (DE #42 ) is DENIED AS MOOT. Signed by Judge Kathleen M. Williams on 7/22/2025. (ymd)
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Filing 45
PAPERLESS ORDER. THIS MATTER is before the Court sua sponte. It is ORDERED AND ADJUDGED that the Status Conference set for July 24, 2025 at 4:30 p.m. will be conducted via videoconference. Videoconference details will be emailed to the Parties prior to the Status Conference. Signed by Judge Kathleen M. Williams on 7/21/2025. (ymd)
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| Filing 44 CLERK'S NOTICE - Attorney Admissions has updated the address and email information as submitted through attorneys PACER account for attorney Robert L Drolet (pt) |
| Filing 43 Amended NOTICE of Lead of Counsel Designation by Joel Borgella, Eddie Neal (Drolet, Robert) Modified Text on 7/21/2025 (ls). |
| Filing 42 MOTION for Leave to Appear via Zoom Platform by Joel Borgella, Eddie Neal. Responses due by 8/1/2025. (Attachments: #1 Exhibit Proposed Order)(Drolet, Robert) Modified Text on 7/21/2025 (ls). |
| Filing 41 CLERK'S NOTICE - Attorney Admissions has updated the address and email information as submitted through attorneys PACER account for attorney German Morales (pt) |
| Filing 40 MOTION to Authorize Pro Se Litigant to Utilize the CM/ECF Autosender System for Filing Motions and Attend Hearings via Zoom by Sylvester Butler. (ls) |
| Filing 39 Explanatory Statement Regarding Timeliness and Procedural Circumstances by Sylvester Butler re 33 Order. (ls) |
| Filing 38 NOTICE of Change of Address/Contact Information; Change of Email; Change of Law Firm Name; by German Morales (Morales, German) |
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Filing 37
PAPERLESS ORDER. THIS MATTER is before the Court sua sponte. On July 15, 2025, Plaintiff filed a Scheduling Report (DE #31 ) ("Report"). In the Report, Plaintiff represented that it was not possible to confer with Defendants Christopher James Van Dam and Sylvester Butler. Accordingly, a joint scheduling report was not filed as required by the Court's Order of Referral and Notice of Court Practice and Procedures (DE #6 ). This Court then issued a Paperless Order to Show Cause (DE 33) requiring the Defendants to explain the reasons for their lack of conferral and non-compliance with a Court Order. On July 17, 2025, Defendant Van Dam filed their Response to Order to Show Cause (DE #31 ) ("Response"). In the Response, Defendant Van Dam attached email communications directly refuting Plaintiff's representations about the lack of conferral. Specifically, Defendant Van Dam attached an email from July 15 that illustrates conferral about a joint scheduling order. This email, however, came in at 5:57 p.m. on the day that the joint scheduling report was due and there appeared to be some delays in communication between the parties. Shortly after this communication, Plaintiff filed their Report and represented that there were no further communications since July 11 that have led to any movement. Accordingly, it is ORDERED AND ADJUDGED that a Status Conference is SET for July 24, 2025 at 4:30 p.m. before the Honorable Kathleen M. Williams in Room 11-3 of the Wilkie D. Ferguson, Jr. United States Courthouse, located at 400 North Miami Avenue in Miami, Florida. The Parties should come prepared to discuss why their conduct does not warrant sanctions. Signed by Judge Kathleen M. Williams on 7/18/2025. (ymd)
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| Set Hearings: Status Conference set for 7/24/2025 04:30 PM in Miami Division before Judge Kathleen M. Williams per DE 37 . (wce) |
| Filing 36 Defendant's SCHEDULING REPORT - Rule 16.1 by Christopher J. Van Dam, P.A., Christopher James Van Dam (Van Dam, Christopher) |
| Filing 35 RESPONSE TO ORDER TO SHOW CAUSE by Christopher J. Van Dam, P.A., Christopher James Van Dam. (Attachments: #1 Exhibit supporting emails, #2 Exhibit supporting emails)(Van Dam, Christopher) |
| Filing 34 Amended MEMORANDUM in Support re #18 MOTION to Dismiss #1 Complaint,,, by Sylvester Butler. (ls) |
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Filing 33
PAPERLESS ORDER TO SHOW CAUSE. THIS MATTER is before the Court sua sponte. On April 30, 2025, the Court issued an Order of Referral and Notice of Court Practice and Procedures (DE #6 ) requiring that "WITHIN TWENTY (20) DAYS from the date that the last Defendant responds to the Complaint through an answer or Rule 12 motion, the Parties shall file a joint conference report and a joint proposed scheduling order, as required by S.D. Fla. Local Rule 16.1(b)." The last non-defaulting defendant filed a Motion to Dismiss on June 25, 2025, making the joint proposed scheduling order due on July 15, 2025. On July 15, 2025, Plaintiff filed a Scheduling Report (DE #31 ) and represented that Defendants Sylvester Butler and Christopher James Van Dam have not engaged with Plaintiff for the purpose of filing a joint proposed scheduling order. Moreover, Defendants have not filed their own proposed scheduling order. Accordingly, it is ORDERED AND ADJUDGED that Defendants Butler and Van Dam will SHOW CAUSE by July 18, 2025 as to why sanctions should not be imposed for failure to comply with a Court Order. Signed by Judge Kathleen M. Williams on 7/16/2025. (ymd)
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| Set Deadlines: Show Cause Response due by 7/18/2025 per DE 33 . (wce) |
| Filing 32 Defendant's REPLY in Support of Motion re #27 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Stay these US District Court Proceedings. filed by Christopher J. Van Dam, P.A., Christopher James Van Dam. (Van Dam, Christopher) . |
| Filing 31 Plaintiff's SCHEDULING REPORT - Rule 26(f) by Joel Borgella, Eddie Neal (Attachments: #1 Exhibit Exhibit A- Proposed Order)(Drolet, Robert) |
| Filing 30 Clerk's Notice to Filer re #27 First MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . Motion with Multiple Reliefs Filed as One Relief; ERROR - The Filer selected only one relief event and failed to select the additional corresponding events for each relief requested in the motion. The docket entry was corrected 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. (ls) |
| Filing 29 RESPONSE in Opposition re #27 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, MOTION to Stay these US District Court Proceedings filed by Joel Borgella, Eddie Neal. Replies due by 7/15/2025. (Drolet, Robert) Modified Text on 7/8/2025 (ls). |
| Filing 28 NOTICE of Change of Address/Contact Information; Change of Email; Change of Law Firm Name; by Robert L Drolet (Drolet, Robert) |
| Filing 27 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Christopher J. Van Dam, P.A., Christopher James Van Dam. Responses due by 7/9/2025. (Attachments: #1 Exhibit Neal Assignment of Patent, #2 Exhibit Miami Dade Third Complaint)(Van Dam, Christopher). Added MOTION to Stay these US District Court Proceedings on 7/8/2025 (ls). |
| Filing 26 REPLY in Support of Motion re #18 MOTION to Dismiss #1 Complaint,,,. filed by Sylvester Butler. (ls) |
| Filing 25 Consent by Pro Se Litigant (Non-Prisoner) Sylvester Butler to receive Notices of Electronic Filing at email address: [email protected] (ls) |
| Filing 24 Plaintiff's Opposition to #18 MOTION to Dismiss #1 Complaint,,, by Joel Borgella, Eddie Neal. (Drolet, Robert) |
| Filing 23 PAPERLESS ORDER granting #22 First MOTION for Extension of Time to File Response to Complaint by Christopher J. Van Dam, P.A. and Christopher James Van Dam ("Defendants"). Defendants' response is 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). Nonetheless, because the instant motion is unopposed, the Undersigned will exercise my discretion and grant the relief requested. Defendants will have until June 25, 2025 to file on CM/ECF their response to Plaintiffs' #1 Complaint. Going forward, the Undersigned expects strict compliance with the rules, practices and procedures of this Court. Signed by Ch. Magistrate Judge Jonathan Goodman on 6/4/2025. (mkr) |
| Filing 22 First MOTION for Extension of Time to File Response/Reply/Answer to Complaint by Christopher J. Van Dam, P.A., Christopher James Van Dam. Attorney Christopher James Van Dam added to party Christopher J. Van Dam, P.A.(pty:dft), Attorney Christopher James Van Dam added to party Christopher James Van Dam(pty:dft). (Attachments: #1 Appendix Proposed order)(Van Dam, Christopher) |
| Filing 21 RESPONSES to Questions by Sylvester Butler. (Attachments: #1 Exhibits 1, #2 Exhibits 2, #3 Exhibits 3)(ls) |
| Filing 20 AFFIDAVIT/DECLARATION in Support re #18 MOTION to Dismiss #1 Complaint,,, filed by Sylvester Butler. (ls) |
| Filing 19 MEMORANDUM in Support re #18 MOTION to Dismiss #1 Complaint,,, by Sylvester Butler. (ls) |
| Filing 18 MOTION to Dismiss #1 Complaint, for Failure to File within the Statute of Limitations, Bad Faith, Abandonment, Declaration of Ownership, and Invalidity of Plaintiffs' Claims; and for Consolidation of Liability Exposure, including the Unauthorized Copyrighted Property of Team Defensive Scoring by Design LLC, by Sylvester Butler. Responses due by 6/17/2025. (Attachments: #1 Text of Proposed Order)(ls) |
| Filing 17 Clerk's Notice to Filer re #15 Summons Returned Executed,. Wrong Filer Name(s) Selected; ERROR - The wrong filer name was selected. The correction was made by the Clerk. It is not necessary to refile this document. (ls) |
| Filing 16 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Eddie Neal. Sylvester Butler served on 5/13/2025, response/answer due 6/3/2025. (Drolet, Robert) |
| Filing 15 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Eddie Neal. Sports Stats IQ LLC served on 5/13/2025, response/answer due 6/3/2025. (Drolet, Robert) Modified Filer on 6/3/2025 (ls). |
| Filing 14 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Eddie Neal. Christopher James Van Dam served on 5/14/2025, response/answer due 6/4/2025. (Drolet, Robert) |
| 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 Eddie Neal. Christopher J. Van Dam, P.A. served on 5/14/2025, response/answer due 6/4/2025. (Drolet, Robert) |
| Filing 12 MAGISTRATE JUDGE GOODMAN'S DISCOVERY PROCEDURES ORDER. Signed by Ch. Magistrate Judge Jonathan Goodman on 5/2/2025. See attached document for full details. (fbn) |
| Filing 11 NOTICE of Lead Counsel Designation by Eddie Neal, Joel Borgella. Attorney Robert L Drolet added to party Joel Borgella(pty:ip). (Drolet, Robert) |
| Filing 10 Clerk's Notice to Filer re #8 Notice (Other). 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) |
| Filing 9 Summons Issued as to Sylvester Butler, Christopher J. Van Dam, P.A., Sports Stats IQ LLC, Christopher James Van Dam. (ls) |
| Filing 8 NOTICE of Lead Counsel by Eddie Neal (Morales, German) |
| Filing 7 NOTICE of Filing Proposed Summons(es) by Eddie Neal, JOEL BORGELLA re 5 Clerk's Notice to Filer re: Electronic Case, Summons(es),. Attorney German Morales added to party JOEL BORGELLA(pty:ip). (Attachments: #1 Summon(s) Summons Christopher James Van Dam, #2 Summon(s) Summons Sylvester Butler, #3 Summon(s) Summons Sports Stats IQ LC, #4 Summon(s) Christopher J. Van Dam, P.A.) (Morales, German) |
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Filing 6
ORDER REFERRING CASE to Ch. Magistrate Judge Jonathan Goodman for Discovery and Pretrial Non-Dispositive Matters, and Notice of Court Practices and Procedures. Signed by Judge Kathleen M. Williams on 4/30/2025. See attached document for full details. (ls)
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| Filing 5 Clerk's Notice to Filer re: Summonses will not be issued. DE 4 has been restricted due to error. REASON: Attorney's return address is not listed. Filer may file a Notice of Filing Proposed Summons(es) with the corrected summonses attached. (pes) |
| Filing 3 FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (Attachments: #1 Complaint) (blc) |
| 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. (blc) |
| Filing 1 COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18407151, filed by EDDIE NEAL, JOEL BORGELLA. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M, #14 Exhibit Exhibit N, #15 Exhibit Exhibit O, #16 Exhibit Exhibit P, #17 Civil Cover Sheet Civil Cover Sheet, #18 Summon(s) Summons Sports Stats, #19 Summon(s) Summons Van Dam, #20 Summon(s) Summons Van Dam P.A., #21 Summon(s) Summons Butler)(Drolet, Robert) |
| SYSTEM ENTRY - Docket Entry 4 [service] restricted/sealed until further notice. (pes) |
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