Moskowitz v. Target Corporation et al
Plaintiff: BRIANNE MOSKOWITZ
Defendant: JAIMIE DONOVAN, TARGET CORPORATION, Meggan Manns and Jaime Donovan
Case Number: 2:2021cv14186
Filed: April 29, 2021
Court: US District Court for the Southern District of Florida
Presiding Judge: Donald M Middlebrooks
Nature of Suit: P.I.: Other
Cause of Action: 28 U.S.C. § 1441
Jury Demanded By: Both
Docket Report

This docket was last retrieved on June 14, 2021. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 14, 2021 Filing 20 REPLY to Response to Motion re #16 MOTION to Dismiss #10 Summons Issued, #3 Amended Complaint/Amended Notice of Removal or insufficient process, insufficient service of process, lack of personal jurisdiction, and pursuant to the Colorado River Abstention Doctrine filed by Meggan Manns. (Derrevere, Jon)
June 14, 2021 Filing 19 NOTICE by Meggan Manns re #17 Response in Opposition to Motion, Notice of Intent Not to File a Reply (Derrevere, Jon)
June 8, 2021 Filing 18 RESPONSE in Opposition re #16 MOTION to Dismiss #10 Summons Issued, #3 Amended Complaint/Amended Notice of Removal or insufficient process, insufficient service of process, lack of personal jurisdiction, and pursuant to the Colorado River Abstention Doctrine AMENDED RESPONSE filed by Brianne Moskowitz. Replies due by 6/15/2021. (Attachments: #1 Exhibit A, #2 Exhibit B)(Odom, Jason)
June 7, 2021 Filing 17 RESPONSE in Opposition re #16 MOTION to Dismiss #10 Summons Issued, #3 Amended Complaint/Amended Notice of Removal or insufficient process, insufficient service of process, lack of personal jurisdiction, and pursuant to the Colorado River Abstention Doctrine filed by Brianne Moskowitz. Replies due by 6/14/2021. (Attachments: #1 Exhibit A, #2 Exhibit B)(Odom, Jason)
June 2, 2021 Filing 16 MOTION to Dismiss #10 Summons Issued, #3 Amended Complaint/Amended Notice of Removal or insufficient process, insufficient service of process, lack of personal jurisdiction, and pursuant to the Colorado River Abstention Doctrine by Meggan Manns. Responses due by 6/16/2021 (Attachments: #1 Exhibit 1 - (State Court) Docketing, Affid Process Server, Summons, Complaint, Ans., #2 Exhibit 2 - (Federal) Affidavit Process Server, Summons, Amended Complaint)(Derrevere, Jon)
May 27, 2021 Filing 15 Plaintiff's REPLY to #13 Response in Opposition to Motion, to Amend Complaint and for Remand by Brianne Moskowitz. (Attachments: #1 Exhibit A, #2 Exhibit B)(Odom, Jason)
May 26, 2021 Filing 14 REPLY to Response to Motion re #11 Defendant's MOTION to Quash Summons [DE 10]Defendant's MOTION to Strike #7 Notice of Entry of Parties Listed into CM/ECF Meggan Manns filed by Target Corporation. (Derrevere, Jon)
May 25, 2021 Filing 13 RESPONSE in Opposition re #9 Plaintiff's MOTION to Amend/Correct Complaint MOTION to Remand to State Court and Incorporated Memorandum of Law filed by Target Corporation. Replies due by 6/1/2021. (Attachments: #1 Exhibit 1 - Price v. Walmart - Feb 24, 2001 Order Denial Remand, #2 Exhibit 2 - Manns' Affidavit, #3 Exhibit 3 - Taklani v. Target Order -Granting Lawrence's MFSJ)(Derrevere, Jon)
May 19, 2021 Filing 12 RESPONSE in Opposition re #11 Defendant's MOTION to Quash Summons [DE 10]Defendant's MOTION to Strike #7 Notice of Entry of Parties Listed into CM/ECF Meggan Manns filed by Brianne Moskowitz. Replies due by 5/26/2021. (Attachments: #1 Exhibit 1 - Email dated 05.09.21, #2 Exhibit 2 - Clerk's email dated 05.11.21)(Odom, Jason)
May 14, 2021 Filing 11 Defendant's MOTION to Quash Summons [DE 10], Defendant's MOTION to Strike #7 Notice of Entry of Parties Listed into CM/ECF Meggan Manns ( Responses due by 5/28/2021) by Target Corporation. (Attachments: #1 Exhibit 1 - May 10, 2021 Corresp., #2 Exhibit 2 - Docketing, Complaint - 2021 CA 000319 - MOSKOWITZ vs. MANNS, #3 Exhibit 3. - Plt Opposes Motion to Quash [DE10] and to Strike [DE7])(Derrevere, Jon)
May 12, 2021 Filing 10 Summons Issued as to Meggan Manns. (ls)
May 11, 2021 Filing 9 Plaintiff's MOTION to Amend/Correct Complaint ( Responses due by 5/25/2021), MOTION to Remand to State Court and Incorporated Memorandum of Law by Brianne Moskowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Errata G, #8 Exhibit H, #9 Exhibit I)(Odom, Jason)
May 11, 2021 Filing 8 NOTICE of Filing Proposed Summons(es) by Brianne Moskowitz (Odom, Jason)
May 11, 2021 Filing 7 Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Meggan Manns. (Odom, Jason)
May 11, 2021 Filing 6 Clerks Notice to Filer re: Summons(es) cannot be issued. Summons NOT issued for the following reason - Party Not Added to the Case. (ls)
May 11, 2021 Filing 5 Clerks Notice to Filer re #3 Amended Complaint/Amended Notice of Removal. Parties Not Added; ERROR - The Filer failed to add all parties from the amended complaint/petition/removal, etc.. Filer is instructed to file a Notice of Entry of Parties Listed into CM/ECF and add the additional parties. (ls)
May 10, 2021 Filing 4 NOTICE of Filing Proposed Summons(es) by BRIANNE MOSKOWITZ (Odom, Jason)
May 10, 2021 Filing 3 AMENDED COMPLAINT and Demand for Jury Trial against All Defendants, filed by BRIANNE MOSKOWITZ.(Odom, Jason)
April 29, 2021 Filing 2 Clerks Notice of Judge Assignment to Judge Donald M. Middlebrooks. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Shaniek M. Maynard 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. (scn)
April 29, 2021 Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Moskowitz, Brianne v. Target Corporation and Jaimie Donovan) Filing fee $ 402.00 receipt number AFLSDC-14647729, filed by TARGET CORPORATION. (Answer filed/No Motion to Dismiss filed) (Attachments: #1 Exhibit 1 - Civil Cover Sheet, #2 Exhibit 2 - Summons & Cmplt to Target, #3 Exhibit 3 - Target Answer and Affirmative Defenses, #4 Exhibit 4 - Summons & Cmplt to Donovan, #5 Exhibit 5 - Donovan's Answer and Affirmative Defenses, #6 Exhibit 6 - Donovan's Affidavit, #7 Exhibit 7 - Demand, #8 Exhibit 8 - Operative Reports Dec 2019 MRI Report, #9 Exhibit 9 - Recommendation for Total Knee Surgery, #10 Exhibit 10 - Lumbar MRI Report, #11 Exhibit 11 - Additional Billing, #12 Exhibit 12 - State Court Pleadings and Process, #13 Exhibit 13 - NOF Notice of Removal)(Derrevere, Jon) Text Modified on 4/29/2021 (scn).

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Defendant: JAIMIE DONOVAN
Represented By: Jon Dale Derrevere
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Defendant: TARGET CORPORATION
Represented By: Jon Dale Derrevere
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Defendant: Meggan Manns
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Defendant: Jaime Donovan
Represented By: Jon Dale Derrevere
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Plaintiff: BRIANNE MOSKOWITZ
Represented By: Jason Lowell Odom
Represented By: David Marshall Carter
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