Williams v. Able Business Services, Inc. et al
| Derek Williams |
| Able Business Services, Inc. and Mr. William Berry |
| 1:2025cv24711 |
| October 13, 2025 |
| U.S. District Court for the Southern District of Florida |
| Marty Fulgueira Elfenbein |
| K Michael Moore |
| Labor: Fair Standards |
| 28 U.S.C. § 1441 Notice of Removal |
| Both |
Docket Report
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This docket was last retrieved on March 31, 2026. A more recent docket listing may be available from PACER.
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| Filing 42 MOTION to Strike #41 Response/Reply (Other) by Able Business Services, Inc., William Berry. Responses due by 4/14/2026. (Schneider, Stuart) |
| Filing 41 REPLY in Further Support of #39 Response in Opposition to Motion by Derek Williams. (ls) |
| Filing 40 REPLY to Response to Motion re #38 Defendant's MOTION for Protective Order to Stay Discovery Pending Motion to Dismiss. filed by Able Business Services, Inc., William Berry. (Schneider, Stuart) |
| Filing 39 Plaintiff's Response in Opposition to #38 Defendant's MOTION to Stay Discovery filed by Derek Williams. Replies due by 3/27/2026. (wce) |
| Filing 38 Defendant's MOTION for Protective Order to Stay Discovery Pending Motion to Dismiss by Able Business Services, Inc., William Berry. Responses due by 4/3/2026. (Schneider, Stuart) |
Filing 37
PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants' Motion for Claims Professional to Appear Remotely by Zoom at Mediation. #36 . Therein, Defendants seek leave for their insurance carrier's claims professional to appear remotely at the mediation scheduled for April 8, 2026, as he is located in Hartford, Connecticut and seeks to save "time, expense, and resources," while the rest of the participants reside locally and will be appearing in person. Id. at 1-2. No Parties object to the relief requested. Id. at 2. In its Paperless Order of Referral to Mediation, the Court emphasized that the "physical presence of counsel and each party with full authority to enter in a full and complete compromise and settlement is mandatory," and that the "mediation shall take place in person absent good cause shown by the parties." (ECF No. 30). Nevertheless, here the Court finds good cause to grant the relief requested. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #36 is GRANTED. Mr. Ajay Patel, Defendants' insurance carrier's claims professional, may appear remotely at the mediation. All other participants shall appear in person. During the mediation conference, any remote participants shall have their web cameras on and positioned such that they are visible to one another unless excused by the mediator. Signed by Judge K. Michael Moore on 2/26/2026. (ss01)
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| Filing 36 Defendant's MOTION for Claims Professional to Appear By Zoom at Mediation Unopposed by Plaintiff by Able Business Services, Inc., William Berry. Responses due by 3/11/2026. (Singer, Dustin) . |
| Filing 35 Plaintiff's NOTICE of Parties Agreed Scheduled Mediation (In-Person) for April 8, 2026 by Derek Williams (nan) |
| Filing 34 Plaintiff's NOTICE of Serving Rule 26(a)(1) Initial Disclosures and Request for Production of Documents by Derek Williams (nan) |
| Filing 33 Defendant's NOTICE of Mediator Selection. Selected/Added Pamela Perry as Mediator. (Singer, Dustin) |
| Filing 32 Notice of Ninety Days Expiring by Able Business Services, Inc., William Berry re #5 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by William Berry, Able Business Services, Inc. (Schneider, Stuart) |
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Filing 31
ORDER Setting Discovery Status Conference:, ( Status Report due by 5/29/2026.) Status Conference Re: Discovery Matters set for 6/5/2026 11:00 AM via Zoom before Magistrate Judge Marty Fulgueira Elfenbein. Signed by Magistrate Judge Marty Fulgueira Elfenbein on 1/30/2026. See attached document for full details. (drz)
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Filing 30
PAPERLESS ORDER OF REFERRAL TO MEDIATION. Trial having been set in this matter for the two-week trial period beginning November 2, 2026, at 9:00 a.m. pursuant to Rule 16 of the Federal Rule of Civil Procedure and Rule 16.2 of the Local Rules of the United States District Court for the Southern District of Florida, it is hereby ORDERED AND ADJUDGED as follows: 1. All parties are required to participate in mediation. The mediation shall be completed no later than eighty (80) days before the scheduled trial date. 2. Plaintiff's counsel, or another attorney agreed upon by all counsel of record and any unrepresented parties, shall be responsible for scheduling the mediation conference. The parties are encouraged to avail themselves of the services of any mediator on the List of Certified Mediators, maintained in the office of the Clerk of this Court, but may select any other mediator. The parties shall agree upon a mediator and file a Notice of Mediator Selection within fifteen (15) days from the date of this Order. If there is no agreement, lead counsel shall file a request for the Clerk of Court to appoint a mediator in writing within fifteen (15) days from the date of this Order, and the Clerk shall designate a mediator from the List of Certified Mediators. Designation shall be made on a blind rotation basis. 3. The parties shall agree upon a place, date, and time for mediation convenient to the mediator, counsel of record, and unrepresented parties and file a Notice of Scheduling Mediation no later than one hundred and ten (110) days prior to the scheduled trial date. If the parties cannot agree to a place, date, and time for the mediation, they may motion the Court for an order dictating the place, date, and time. 4. The physical presence of counsel and each party with full authority to enter in a full and complete compromise and settlement is mandatory. If any party is not an individual (e.g., a corporation), a representative of that party with full authority to enter in a full and complete compromise and settlement is mandatory. The mediation shall take place in person absent good cause shown by the parties. No party shall be excused from attendance without express authorization from the Court. If insurance is involved, an adjuster with authority up to the policy limits or the most recent demand, whichever is lower, shall attend. 5. All discussions, representations and statements made at the mediation conference shall be confidential and privileged. 6. At least ten (10) days prior to the mediation date, all parties shall present to the mediator a brief written summary of the case identifying issues to be resolved. Copies of those summaries shall be served on all other parties. 7. The Court may impose sanctions against parties and/or counsel who do not comply with the attendance or settlement authority requirements herein, or who otherwise violate the terms of this Order. The mediator shall report non-attendance and may recommend imposition of sanctions by the Court for non-attendance. 8. The mediator shall be compensated in accordance with the standing order of the Court entered pursuant to Rule 16.2.B.6, or on such basis as may be agreed to in writing by the parties and the mediator selected by the parties. The cost of mediation shall be shared equally by the parties unless otherwise ordered by the Court. All payments shall be remitted to the mediator within 30 days of the date of the bill. Notice to the mediator of cancellation or settlement prior to the scheduled mediation conference must be given at least two (2) full business days in advance. Failure to do so will result in imposition of a fee for one hour. 9. If a full or partial settlement is reached in this case, counsel shall promptly notify the Court of the settlement in accordance with Local Rule 16.2.F, by filing a notice of settlement signed by the counsel of record within ten (10) days of the mediation conference. Thereafter, the parties shall forthwith submit an appropriate pleading concluding the case. 10. Within five (5) days following the mediation conference, the mediator shall file a Mediation Report indicating whether all required parties were present. The report shall also indicate whether the case settled (in full or in part), was continued with the consent of the parties, or whether the mediator declared an impasse. 11. If mediation is not conducted, the case may be stricken from the trial calendar, and other sanctions may be imposed. Signed by Judge K. Michael Moore on 1/26/2026. (ss01)
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Filing 29
PAPERLESS ORDER SCHEDULING TRIAL IN MIAMI. This case is now set for trial commencing the two-week trial period of November 2, 2026, at 9 a.m. in Courtroom 13-1, (thirteenth floor) United States Courthouse, 400 North Miami Avenue, Miami, Florida. All parties are directed to report to the calendar call on October 29, 2026, at 2 p.m., at which time all matters relating to the scheduled trial date may be brought to the attention of the Court. A final pretrial conference as provided for by Rule 16, Fed. R. Civ. P., and Rule 16.1(C), S.D. Fla. L.R., is scheduled for October 20, 2026, at 11 a.m. A bilateral pretrial stipulation and all other pretrial preparations shall be completed NO LATER THAN FIVE DAYS PRIOR TO THE PRETRIAL CONFERENCE. All motions to amend the pleadings or to join additional parties must be filed by the later of forty-five (45) days after the date of entry of this Order, or forty-five (45) days after the first responsive pleading by the last responding defendant. Any and all pretrial motions, including motions for summary judgment, Daubert motions, and motions in limine must be filed no later than eighty (80) days prior to the trial date. Responses to summary judgment motions must be filed no later than fourteen (14) days after service of the motion, and replies in support of the motion must be filed no later than seven (7) days after service of the response, with both deadlines computed as specified in Rule 6, Fed. R. Civ. P. The Parties are hereby notified that this Court requires strict compliance with Local Rule 56.1 regarding the filing of any motion for summary judgment and corresponding statements of material facts. For evidence not previously filed on the docket, and to the extent practicable, evidentiary support for a Party's statement of material facts shall be filed as separate exhibits within the Court's electronic case filing system; the first citation to any evidence in support of a motion for summary judgment or statement of material facts shall provide the docket entry for that evidence using the form "ECF No." In all circumstances, citations to any composite exhibit shall provide both the page number assigned by the Court's electronic case filing system (i.e., the page number of the PDF) and the page number of the document. Each party is limited to one Daubert motion. If all evidentiary issues cannot be addressed in a 20-page memorandum, the parties must file for leave to exceed the page limit. Each party is also limited to one motion in limine (other than Daubert motions). If all evidentiary issues cannot be addressed in a 20-page memorandum, the parties must file for leave to exceed the page limit. Rule 26(a)(2) expert disclosures shall be completed one hundred thirty (130) days prior to the date of trial. All discovery, including expert discovery, shall be completed one hundred (100) days prior to the date of trial. The failure to engage in discovery pending settlement negotiations shall not be grounds for continuance of the trial date. All exhibits must be pre-marked, and a typewritten exhibit list setting forth the number and description of each exhibit must be submitted at the time of trial. Plaintiff's exhibits shall be marked numerically with the letter "P" as a prefix. Defendant's exhibits shall be marked numerically with the letter "D" as a prefix. For a jury trial, counsel shall prepare and submit proposed jury instructions to the Court. The Parties shall submit their proposed jury instructions and verdict form jointly, although they do not need to agree on each proposed instruction. Where the parties do not agree on a proposed instruction, that instruction shall be set forth in bold type. Instructions proposed only by a plaintiff should be underlined. Instructions proposed only by a defendant should be italicized. Every instruction must be supported by citation to authority. The parties should use the Eleventh Circuit Pattern Jury Instructions for Civil Cases as a guide, including the directions to counsel contained therein. The parties shall jointly file their proposed jury instructions via CM/ECF, and shall also submit their proposed jury instructions to the Court via e-mail at [email protected] in WordPerfect or Word format. For a non-jury trial, the parties shall prepare and submit to the Court proposed findings of fact and conclusions of law fully supported by the evidence, which counsel expects the trial to develop, and fully supported by citations to law. The proposed jury instructions or the proposed findings of fact and conclusions of law shall be submitted to the Court no later than five (5) business days prior to the scheduled trial date. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuit's Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court. THE FILING BY COUNSEL OF A "NOTICE OF UNAVAILABILITY" BY MOTION OR OTHERWISE IS NOT PROVIDED FOR UNDER THE LOCAL RULES AND SHALL NOT BE PRESUMED TO ALTER OR MODIFY THE COURT'S SCHEDULING ORDER. Signed by Judge K. Michael Moore on 1/26/2026. (ss01) #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 28 Joint SCHEDULING REPORT - Rule 16.1 by Able Business Services, Inc., William Berry (Singer, Dustin) |
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Filing 27
PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants' Motion for Enlargement of Time to Submit Joint Scheduling Report. #26 . Therein, Defendants seek a second extension of time to prepare the required Joint Scheduling Report because while the Parties conducted their Joint Scheduling Conference on January 9, 2026, they "have not been able to confer with respect to their Joint Scheduling Report." Id. at 1-2. However, Defendants also indicate that the Parties have failed to confer on the instant Motion because Plaintiff's counsel did not respond to Defendants' counsel's conferral email. Id. at 2. Local Rule 7.1(a) provides that counsel for the movant must confer with all parties in a good faith effort to resolve the issues in the motion and equally requires the non-moving party's cooperation. Accordingly, it is hereby ORDERED AND ADJUDGED that the Motion #26 is DENIED WITHOUT PREJUDICE. Plaintiff's counsel is DIRECTED to respond to Defendants' counsel's conferral efforts before the end of the day today, January 20, 2026, and Defendants shall be allowed to refile the Motion on or after January 21, 2026, regardless of whether conferral has occurred. Plaintiff's continued failure to confer may result in dismissal or the imposition of other sanctions. However, if the Parties have been able to confer regarding the Joint Scheduling Report in the time since the Motion was filed, they may file that report on or before the current deadline of January 23, 2026. Signed by Judge K. Michael Moore on 1/20/2026. (ss01)
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| Filing 26 Defendant's MOTION for Extension of Time to Submit Joint Scheduling Report re 25 Order on Motion for Extension of Time,,,,,,,,, by Able Business Services, Inc., William Berry. Responses due by 1/30/2026. (Attachments: #1 Text of Proposed Order)(Schneider, Stuart) |
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Filing 25
PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants' Motion for Enlargement of Time to Hold Joint Scheduling Conference and Submit Joint Scheduling Report. #24 . Therein, Defendants seek an extension of time to hold the required Joint Scheduling Conference and to file the Joint Scheduling Report because they "have not received any request or correspondence from Plaintiff to hold a joint scheduling conference and Plaintiff has failed to respond to three separate requests from Defendants to hold the same." Id. at 1. Plaintiff previously filed a Unilateral Joint Scheduling Report on the basis that he "has awaited to confer with Defendants' counsel regarding preparation of the Joint Scheduling Report and has not been contacted by email to have any form of communication (it's been approximately 2 weeks)," and that "Defendants have failed to acknowledge this Court's Order and respond and have not participated in the required conference." (ECF No. 23) at 1 (emphasis in original). However, the exhibits attached to Defendants' Motion are emails showing repeated outreach efforts from Defendants regarding the Joint Scheduling Conference, apparently to which Plaintiff did not respond. (ECF No. 24-1). Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #24 is GRANTED. The Parties shall hold a Joint Scheduling Conference within fourteen (14) days of this Order, and a Joint Scheduling Report within seven (7) days of the Joint Scheduling Conference. Plaintiff's Unilateral Joint Scheduling Report #23 is STRICKEN. The Court cannot discern why Plaintiff has represented that Defendants refused to confer in the face of evidence to the contrary, and he is cautioned that all litigants have a continuing obligation of truthful and complete disclosure in all filings with the Court. If the Parties continue to have disagreements on any of the substance of the Joint Scheduling Report, they may indicate such disagreements in their combined filing (rather than filing unilateral reports). Signed by Judge K. Michael Moore on 1/5/2026. (ss01)
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| Filing 24 MOTION for Extension of Time to Hold Joint Scheduling Conference and Submit Joint Scheduling Report re 21 Pretrial Order,,,,,,,,,,,,,,,,,, by Able Business Services, Inc., William Berry. Responses due by 1/16/2026. (Attachments: #1 Exhibit Composite Exhibit A - Emails, #2 Text of Proposed Order)(Schneider, Stuart) |
| Filing 23 (STRICKEN) NOTICE of Filing Plaintiff's Unilateral Joint Scheduling Report by Derek Williams (nan) Modified per DE 25 on 1/5/2026 (amb). |
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Filing 22
ORDER SETTING DISCOVERY PROCEDURES. Signed by Magistrate Judge Marty Fulgueira Elfenbein on 12/22/2025. See attached document for full details. (drz)
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Filing 21
PAPERLESS PRETRIAL ORDER. THIS ORDER has been entered upon the reassignment of this case to the undersigned Judge. It is ORDERED that S.D. Fla. L.R. 16.1 shall apply to this case and the parties shall hold a scheduling conference within fourteen (14) days of the date of this Order. Within seven (7) days of the scheduling conference, counsel shall file a Joint Scheduling Report. The report shall indicate the proposed month and year for the trial and the estimated number of days required for trial. The scheduling conference may be held via telephone. At the conference, the parties shall comply with the following agenda that the Court adopts from S.D. Fla. L.R. 16.1: (1) Documents (S.D. Fla. L.R. 16.1.B.1 and 2) The parties shall determine the procedure for exchanging a copy of, or a description by category and location of, all documents and other evidence that is reasonably available and that a party expects to offer, or may offer, if the need arises. Fed. R. Civ. P. 26(a)(1)(B). (A) Documents include computations of the nature and extent of any category of damages claimed by the disclosing party unless the computations are privileged or otherwise protected from disclosure. Fed. R. Civ. P. 26(a)(1)(C). (B) Documents include insurance agreements which may be at issue with the satisfaction of the judgment. Fed. R. Civ. P. 26(a)(1)(D). (2) List of Witnesses - The parties shall exchange the name, address, and telephone number of each individual known to have knowledge of the facts supporting the material allegations of the pleading filed by the party. Fed. R. Civ. P. 26(a)(1)(A). The parties have a continuing obligation to disclose this information. (3) Discussions and Deadlines (S.D. Fla. L.R. 16.1.B.2) - The parties shall discuss the nature and basis of their claims and defenses and the possibility of a prompt settlement or resolution of the case. Failure to comply with this Order or to exchange the information listed above may result in sanctions and/or the exclusion of documents or witnesses at the time of trial. S.D. Fla. L.R. 16.1.I. Failure of counsel to file a joint scheduling report may result in remand or dismissal, default, and the imposition of other sanctions including attorney's fees and costs. The filing of a motion to dismiss, or other motion, does not toll the time for filing a joint scheduling report. The parties are hereby on notice that this Court requires all filings to be formatted in 12 point Times New Roman font and double spaced, including any footnotes, with one inch margins on all sides. Failure to follow these formatting guidelines may result in the filing being stricken, any opposing filing being granted by default, and the imposition of other sanctions, including attorney's fees and costs. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Failure to comply with ANY of these procedures may result in the imposition of appropriate sanctions, including but not limited to, the striking of the motion or dismissal of this action. The parties shall seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing.... Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuit's Local Rules and Internal Operating Procedures, within three (3) days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court. Telephonic appearances are not permitted for any purpose. Upon reaching a settlement in this matter the parties are instructed to notify the Court by telephone and to file a Notice of Settlement within twenty-four (24) hours. Signed by Judge K. Michael Moore on 12/19/2025. (ss01)
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Filing 20
PAPERLESS ORDER REFERRING PRETRIAL DISCOVERY MATTERS TO MAGISTRATE JUDGE MARTY FULGUEIRA ELFENBEIN. PURSUANT to 28 U.S.C. 636 and the Magistrate Judge Rules of the Local Rules of the Southern District of Florida, the above-captioned Cause is referred to United States Magistrate Judge Marty Fulgueira Elfenbein to take all necessary and proper action as required by law with respect to any and all pretrial discovery matters. Any motion affecting deadlines set by the Court's Scheduling Order is excluded from this referral, unless specifically referred by separate Order. It is FURTHER ORDERED that the parties shall comply with Magistrate Judge Elfenbein's discovery procedures. Signed by Judge K. Michael Moore on 12/19/2025. (ss01)
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Filing 19
ORDER OF RECUSAL. Judge Rodolfo A. Ruiz, II recused. Case reassigned to Judge K. Michael Moore for all further proceedings. Signed by Judge Rodolfo A. Ruiz, II on 12/17/2025. See attached document for full details. (vjk)
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| Filing 18 CLERK'S NOTICE OF REASSIGNMENT OF CASE. Case reassigned to Judge Rodolfo A. Ruiz, II for all further proceedings. Judge Jose E. Martinez no longer assigned to case as presider. (yar) |
| Filing 17 Plaintiff's REPLY to #16 Response in Opposition to Motion, by Derek Williams. (nan) |
| Filing 16 RESPONSE in Opposition re #12 MOTION for Leave to File MOTION to Amend/Correct #1 Notice of Removal (State Court Complaint),,,, #10 MOTION for Leave to File MOTION to Amend/Correct #1 Notice of Removal (State Court Complaint),,, filed by Able Business Services, Inc., William Berry. Replies due by 12/8/2025. (Schneider, Stuart) |
| Filing 15 Plaintiff's NOTICE of Filing E-mail Correspondence to Defendants (Plaintiff's Case Resolution-Proposed) Dated November 21, 2025 by Derek Williams (nan) |
| Filing 14 NOTICE of Filing "Clean Copy" of Exhibit #1 to Verified Third Amended Complaint by Derek Williams re #12 MOTION for Leave to File MOTION to Amend/Correct #1 Notice of Removal (State Court Complaint). (ebz) |
| Filing 13 Consent by Pro Se Litigant (Non-Prisoner) Derek Williams to receive Notices of Electronic Filing at email address: [email protected] (ebz) |
| Filing 12 Plaintiff's MOTION for Leave to File Verified Third Amended Complaint #1 Notice of Removal (State Court Complaint) by Derek Williams. Responses due by 12/1/2025. (Attachments: #1 Verified Third Amended Complaint)(nan) |
| Filing 11 Plaintiff's NOTICE of Filing State Court Case Management Order (Streamlined Pathway) by Derek Williams (nan) |
| Filing 10 Plaintiff's MOTION for Leave to File Verified Third Amended Complaint for Breach of Contract, Promissory Estoppel, Fraud/Misrepresentation, Unpaid Wages Under Florida Law, Civil Theft, Unjust Enrichment (In the Alternative), Fraudulent Transfer, Violation of 501.204, FLA. STAT., and Other Relief with Demand for Jury Trial #1 Notice of Removal (State Court Complaint),,, by Derek Williams. Responses due by 12/1/2025. (Attachments: #1 Verified Third Amended Complaint)(nan) |
| Filing 9 NOTICE of Attorney Appearance by Dustin Philip Singer on behalf of Able Business Services, Inc., William Berry (Singer, Dustin) |
| Filing 8 REPLY in Support of Motion re #5 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . filed by Able Business Services, Inc., William Berry. (Schneider, Stuart) |
| Filing 7 RESPONSE in Opposition re #4 MOTION to Remand to State Court filed by Able Business Services, Inc., William Berry. Replies due by 11/4/2025. (Schneider, Stuart) |
| Filing 6 RESPONSE to Defendant's Motion to Dismiss With Request to Deny With Prejudice as Motion is Legally Insufficient and/or Premature due to Plaintiff's Timely Filed Motion for Remand to State Court (All Counts) and/or Remand of Non-Federal Claims (Counts I, III, IV, V, VI, and VII), in Federal Question (Count II) with Request to Sever and Remand Severed Claims to State Court Pursuant to 28 U.S.C.. 1441, 1441 (c) re #5 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Derek Williams. Replies due by 10/28/2025. (jas) |
| Filing 5 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Able Business Services, Inc., William Berry. Responses due by 11/3/2025. (Schneider, Stuart) |
| Filing 4 Plaintiff's MOTION for Remand to State Court (All Counts) and /or Remand of Non-Federal Claims (Counts I, III, IV, V, VI, & VII) in Federal Question (Count II) with Request to Sever and Remand Severed Claims to State Court Pursuant to 28 U.S.C. 1441, 1441 (c) by Derek Williams. (nan) |
| Filing 3 Bar Letter re: Admissions sent to attorney Dustin P. Singer, mailing date October 14, 2025, (pt) |
| Filing 2 Clerks Notice of Judge Assignment to Judge Jose E. Martinez. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Eduardo I. Sanchez 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) |
| Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Verified Second Amended Complaint for Breach of Contract, Promissory Estoppel, Fraud/Misrepresentation, Unpaid Wages, Civil Theft, Unjust Enrichment (in the Alternative), Fraudulent Transfer and Other Relief with Demand for Jury Trial) Filing fee $ 405.00 receipt number AFLSDC-18866734, filed by William Berry, Able Business Services, Inc.. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A - Initial State Court Complaint, #3 Exhibit B - Amended State Court Complaint, #4 Exhibit C - Second Amended State Court Complaint, #5 Exhibit List of Removal Documents - Defendant's Motion for Extension of Time. No Answer/Motion to Dismiss filed.)(Schneider, Stuart) Modified Attachment Description on 10/14/2025 (nan). |
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