La Dolfina S.A. LLC et al v. Meeker et al
Plaintiff: Adolfo Cambiaso and La Dolfina S.A. LLC
Defendant: Crestview Genetics LLC, D. Alan Meeker, Crestview Farm LLC, David Alan Meeker, Alan Meeker, Park Place Polo Team Corporation, Park Place Polo Fields Corporation and La Dolfina S.A.
Case Number: 9:2020cv82231
Filed: December 8, 2020
Court: US District Court for the Southern District of Florida
Presiding Judge: Aileen M Cannon
Referring Judge: Bruce E Reinhart
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1330 Breach of Contract
Jury Demanded By: Defendant
Docket Report

This docket was last retrieved on March 20, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 20, 2023 Deadline(s)/Hearing(s) terminated per Court's Order Staying Deadlines 344 . (sj00)
March 6, 2023 Opinion or Order Filing 344 PAPERLESS ORDER STAYING DEADLINES: All remaining pretrial and trial deadlines contained in the Court's Order Resetting Trial Deadlines #311 are STAYED pending the Court's ruling on the parties' Cross Motions for Summary Judgment #317 #321 . In light of this Order, the parties' Joint Motion Requesting a Pre-Trial Conference #343 is DENIED AS MOOT. Signed by Judge Aileen M. Cannon on 3/6/2023. (sj00)
March 3, 2023 Filing 343 Joint MOTION for Hearing re #311 Scheduling Order,,,, Set/Reset Hearings,,, For Pre-Trial Conference by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
February 22, 2023 Filing 342 SUPPLEMENT to #340 Order, Supplemental Brief on Motion for Summary Judgment by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC (Chapman, Avery)
February 22, 2023 Filing 341 SUPPLEMENT to #340 Order, Supplemental Briefing on Summary Judgment by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker (Sevilla-Sharon, Maia)
February 10, 2023 Opinion or Order Filing 340 ORDER REQUIRING SUPPLEMENTAL BRIEFING ON SUMMARY JUDGMENT: re #317 Plaintiff's MOTION for Summary Judgment filed by La Dolfina S.A. LLC, Adolfo Cambiaso, #321 Defendant's MOTION for Summary Judgment filed by Crestview Genetics LLC, D. Alan Meeker, Crestview Farm LLC. Signed by Judge Aileen M. Cannon on 2/10/2023. See attached document for full details. (pc)
December 16, 2022 Filing 339 Defendant's REPLY to Response re #321 Defendant's MOTION for Summary Judgment (Statement of Material Facts) filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Exhibit A - Meeker Reply Declaration)(Sevilla-Sharon, Maia) Modified Document Link on 12/19/2022 (pcs).
December 16, 2022 Filing 338 Defendant's REPLY to Response to Motion re #321 Defendant's MOTION for Summary Judgment filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Exhibit A - Meeker Reply Declaration)(Sevilla-Sharon, Maia)
December 16, 2022 Filing 337 REPLY in Support re #316 Defendant's MOTION to Exclude Testimony of Plaintiffs' Retained and Non-Retained Experts filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Exhibit A - Transcript Excerpt)(Sevilla-Sharon, Maia) Modified Text on 12/19/2022 (cds).
December 16, 2022 Filing 336 NOTICE by Adolfo Cambiaso, La Dolfina S.A. LLC re #318 Statement,,,,,,, Replacement to ECF 318-17 to Provide More Legible Copy of Previously Filed Exhibit (Attachments: #1 Exhibit Replacement Exhibit to ECF No. 318-17 to Correct Legibility) (Chapman, Avery)
December 16, 2022 Filing 335 Statement of: Reply Facts by Adolfo Cambiaso, La Dolfina S.A. LLC re #332 Response in Opposition to Motion, (Attachments: #1 Exhibit Fifth Affidavit of Adolfo Cambiaso, #2 Exhibit Meeker-Zedda WhatsApp - Crestview_0005525, #3 Exhibit Cambiaso Dep.Tr. excerpt, #4 Exhibit Meeker re:Storm Cat - Crestview_0005252, #5 Exhibit Meeker re: embryo center - Crestview_0005273)(Chapman, Avery)
December 16, 2022 Filing 334 Plaintiff's REPLY to Response to Motion re #317 Plaintiff's MOTION for Summary Judgment filed by Adolfo Cambiaso(individually), La Dolfina S.A. LLC. (Chapman, Avery)
December 16, 2022 Filing 333 Plaintiff's REPLY to Response to Motion re #320 Plaintiff's MOTION in Limine to exclude Brandon and Bayley filed by Adolfo Cambiaso(individually), La Dolfina S.A. LLC. (Chapman, Avery)
December 9, 2022 Filing 332 RESPONSE in Opposition re #318 Plaintiff's Statement of Material Facts filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 12/16/2022. (Attachments: #1 Exhibit A - Bookhout Declaration, #2 Exhibit B - Meeker Declaration)(Sevilla-Sharon, Maia) Modified document link on 12/15/2022 (pcs).
December 9, 2022 Filing 331 RESPONSE to Motion re #317 Plaintiff's MOTION for Summary Judgment filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 12/16/2022. (Attachments: #1 Exhibit A - Bookhout Declaration, #2 Exhibit B - Meeker Declaration)(Sevilla-Sharon, Maia)
December 9, 2022 Filing 330 Plaintiff's RESPONSE to #321 Defendant's MOTION for Summary Judgment , #329 Statement,,,,, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
December 9, 2022 Filing 329 Statement of: Counter Statement and Additional Facts by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC re #321 Defendant's MOTION for Summary Judgment , #322 Statement, (Attachments: #1 Exhibit 1- Crestview Genetics Objections and Resp to First RFP, #2 Exhibit 2- Dan Meeker Depo Trans Excertps, #3 Exhibit CV762-765, #4 Exhibit 4- 4th Affidavit of A. Cambiaso, #5 Exhibit Plaintiff's Third Request for Production to Alan Meeker - #11, #6 Exhibit Crestview's Responses and Objections to Plaintiff's 3d & 4th Reequests for Production, #7 Exhibit Defendants 06-06-22 Response, #8 Exhibit Crestview 0005427, #9 Exhibit LD 000074-075, #10 Exhibit Crestview 0005581-582, #11 Exhibit Crestview 0005585, #12 Exhibit Crestview 0003059, #13 Exhibit Crestview 0003451-452, #14 Exhibit DAM00120-162, #15 Exhibit Crestview 0005874-876, #16 Exhibit Crestview 0005877, #17 Exhibit FB000005-148, #18 Exhibit LD 000110-112, #19 Exhibit Crestview 0000526, #20 Exhibit Crestview 0000545, #21 Exhibit Crestview 000382-385, #22 Exhibit Crestview 0005796, #23 Exhibit LD 003867-870, #24 Exhibit LD 000138-151, #25 Exhibit LD 003872-873)(Chapman, Avery)
December 9, 2022 Filing 328 Plaintiff's RESPONSE to #316 Defendant's MOTION to Exclude Testimony of Plaintiffs' Retained and Non-Retained Experts by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC. (Attachments: #1 Exhibit Ex 3- Jornayvaz Depo Excerpts, #2 Exhibit Ex 2- Ballester Depo Excerpts, #3 Exhibit Ex 3- Novillo Astrada Depo Excerpts)(Chapman, Avery)
December 9, 2022 Filing 327 RESPONSE in Opposition re #320 Plaintiff's MOTION in Limine to exclude Brandon and Bayley filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 12/16/2022. (Attachments: #1 Exhibit Exhibit A - Brandon Expert Report, #2 Exhibit Exhibit B - Bayley Expert Report, #3 Exhibit Exhibit C - Excerpt of Brandon Transcript, #4 Exhibit Exhibit D - Excerpt of Bayley Transcript, #5 Exhibit Exhibit E - Rebuttal Expert Report to Rizzo, #6 Exhibit Exhibit F - Rebuttal Expert Report to Swerdlin)(Sevilla-Sharon, Maia)
November 30, 2022 Opinion or Order Filing 326 PAPERLESS ORDER granting #325 Joint Motion to Enlarge Page Limitations. The parties' page limitations for the parties' response briefs are hereby enlarged as follows: (1) Defendants may file a Response Brief to Plaintiffs' Motion for Summary Judgment of no more than 28 pages; (2) Plaintiffs may file a Response Brief to Defendants' Motion for Summary Judgment of no more than 40 pages; (3) Defendants may file a Response Brief to Plaintiffs' Daubert motion of no more than 22 pages; (4) Plaintiffs may file a Response Brief to Defendants' Daubert motion of no more than 35 pages. The parties are reminded that each filing must be double spaced, fully justified, using Times New Roman 12-point font. Signed by Judge Aileen M. Cannon on 11/30/2022. (sj00)
November 28, 2022 Filing 325 Joint MOTION for Leave to File Excess Pages in Response to MSJ Motions by La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
November 23, 2022 Filing 324 Restricted/filed in wrong case in error re: TRANSCRIPT of Motion Hearing held on 11/17/22 before Judge Aileen M. Cannon, (dmr) Modified text and restriction on 11/23/2022 (mf).
November 23, 2022 Filing 323 TRANSCRIPT of Motions Hearing held on 10/15/21 before Judge Aileen M. Cannon, 1-60 pages, Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/14/2022. Redacted Transcript Deadline set for 12/27/2022. Release of Transcript Restriction set for 2/21/2023. (dmr)
November 18, 2022 Filing 322 Statement of: of Material Facts by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker re #111 Scheduling Order,,, #311 Scheduling Order,,,, Set/Reset Hearings,,, (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B)(Sevilla-Sharon, Maia)
November 18, 2022 Filing 321 Defendant's MOTION for Summary Judgment by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker. Responses due by 12/2/2022 (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C)(Sevilla-Sharon, Maia)
November 18, 2022 Filing 320 Plaintiff's MOTION in Limine to exclude Brandon and Bayley by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. Bridget Brandon Expert Report, #2 Exhibit 2. Brandon Rebuttal to Rizzo Report, #3 Exhibit 3. Brandon Rebuttal to Swerdlin Expert Report, #4 Exhibit 4. Bayley Expert Report, #5 Exhibit 5. Brandon Depo Trans Excerpts, #6 Exhibit 6. Bayley Depo Trans Excerpts, #7 Exhibit 7. Comparison of Bayley report and Meeker Dec. Lang., #8 Exhibit 8. Index of Brandon Opinions Regarding Intent, #9 Exhibit 9. 60 Min Transcript)(Chapman, Avery)
November 18, 2022 Filing 319 Statement of: Joint Statement of Undisputed Facts in Suppof Plaintiffs' Motion for Summary Judgment by Adolfo Cambiaso, Crestview Farm LLC, Crestview Genetics LLC, La Dolfina S.A., La Dolfina S.A. LLC, D. Alan Meeker re #317 Plaintiff's MOTION for Summary Judgment (Attachments: #1 Exhibit 1. Depo Excerpts of R. Zedda, #2 Exhibit 2. Depo Excerpts of Cambiaso, #3 Exhibit 3. Depo Excerpts of R. Jornayvaz, #4 Exhibit 4. Plaintiffs' Resp to f/u 30(b)(6) questions, #5 Exhibit 5. Crestview Farm Cert of Org, #6 Exhibit 6. Crestview Farm Art of Org, #7 Exhibit 7. Plaintiff's Resp to Park Place req. for Admin, #8 Exhibit 8. Farm resp to Plaintiffs' 1st RFA, #9 Exhibit 9. Gutierrez Depo Excerpts, #10 Exhibit 10. Crestview Resp to Plaintiffs' RFA's, #11 Exhibit 11. 3rd Amendment to Horse Purchase and Sale Agreement, #12 Exhibit 12. Stankee Depo Excerpts)(Chapman, Avery)
November 18, 2022 Filing 318 Statement of: Plaintiffs' Statement of Facts in Support of Motion for Summary Judgment by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC re #317 Plaintiff's MOTION for Summary Judgment (Attachments: #1 Exhibit 1- 3rd Affidavit of Adolfo Cambiaso, #2 Exhibit 2- Frost Bank Wire Advice, #3 Exhibit 3- Meeker- Bucking WhatsApp, #4 Exhibit 4- SRA Registration for B02, #5 Exhibit 5- Meeker email to Cambiaso, #6 Exhibit 6- Borodin- Meeker WhatsApp Message, #7 Exhibit 7- Simmonds- Meeker WhatsApp Message, #8 Exhibit 8- Park Place Polo-Crestview Farm LTD NDA, #9 Exhibit 9- Simmonds depo transcript Excertps, #10 Exhibit 10- Simmonds email to Meeker, #11 Exhibit 11. Meeker email to Simmonds, #12 Exhibit 12- Meeker email to Thirsk, #13 Exhibit 13- Stankee Depo Excerpts, #14 Exhibit 14 Viagen Equine Cloning Agreement CF Symphony, #15 Exhibit 15- Meeker depo excerpts, #16 Exhibit 16. Viagen Equine Cloning Agreement CF Pantera 2, #17 Exhibit 17. Hurlingham Polo Mag article, #18 Exhibit 18. Economist article, #19 Exhibit 19. Vanity Fair Article, #20 Exhibit 20. 60 Minutes Transcript, #21 Exhibit 21. Fort Worth Business Article, #22 Exhibit 22. Cambiaso Depo Trans Excerpts, #23 Exhibit 23. SRA Storm Cat Registration, #24 Exhibit 24. Chart listing semen doses, #25 Exhibit 25. Los Pingos Del Taita Fresh Semen List, #26 Exhibit 26. Cambiaso-Meeker WhatsApp, #27 Exhibit 27. Meeker email to DiCaro, #28 Exhibit 28. Nov 14, 2022 letter from Defendants, #29 Exhibit 29. Bayley Expert Report, #30 Exhibit 30. Cert of Inc of Pegasus Rider Ltd, #31 Exhibit 31. Declaration of Mandate by Redfield Ltd, #32 Exhibit 32. Park Place Polo Ltd Art of Inc., #33 Exhibit 33. Register of Members of Park Place Polo Ltd.)(Chapman, Avery)
November 18, 2022 Filing 317 Plaintiff's MOTION for Summary Judgment by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 12/2/2022 (Chapman, Avery)
November 18, 2022 Filing 316 Defendant's MOTION to Exclude Testimony of Plaintiffs' Retained and Non-Retained Experts by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker. (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2, #3 Exhibit Exhibit 3, #4 Exhibit Exhibit 4, #5 Exhibit Exhibit 5, #6 Exhibit Exhibit 6, #7 Exhibit Exhibit 7, #8 Exhibit Exhibit 8, #9 Exhibit Exhibit 9)(Sevilla-Sharon, Maia)
November 9, 2022 Opinion or Order Filing 315 PAPERLESS ORDER granting in part #313 Joint Motion to Enlarge Page Limitations. The parties' page limitations for the parties' forthcoming pre-trial motions are hereby enlarged as follows: (1) Defendants may file a motion for summary judgment of no more than 40 pages; (2) Plaintiffs may file a motion for summary judgment of no more than 30 pages; (3) Plaintiffs may file a Daubert motion of no more than 25 pages; and (4) Defendants may file a Daubert motion of no more than 35 pages. The parties are reminded that each filing must be double spaced, fully justified, using Times New Roman 12-point font. Signed by Judge Aileen M. Cannon on 11/9/2022. (kts)
November 9, 2022 Opinion or Order Filing 314 PAPERLESS ORDER granting #312 Joint Motion for Enlargement of Time to File Pre-Trial Motions. The parties shall file any pre-trial motions, including motions for summary judgment and Daubert motions, on or before November 18, 2022. Responses to the pre-trial motions shall be filed on or before December 9, 2022. Any replies in support of the pre-trial motions shall be filed on or before December 16, 2022. All other deadlines in the Court's Order Resetting Trial Deadlines #311 remain in place except as amended by this Order. Signed by Judge Aileen M. Cannon on 11/9/2022. (kts)
November 9, 2022 Set/Reset Deadlines/Hearings per order DE#314. Dispositive Motions due by 11/18/2022. Motions due by 11/18/2022. (drz)
November 8, 2022 Filing 313 Joint MOTION for Leave to File Excess Pages to Enlarge Page Limitations by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker. (Attachments: #1 Text of Proposed Order Proposed Order)(Sevilla-Sharon, Maia)
November 8, 2022 Filing 312 Joint MOTION for Extension of Time to File Pre-Trial Motions re #311 Scheduling Order,,,, Set/Reset Hearings,,, by Crestview Farm LLC, Crestview Genetics LLC(a Nevada limited liability company), D. Alan Meeker. Attorney Maia Sevilla-Sharon added to party Crestview Genetics LLC(pty:cc), Attorney Maia Sevilla-Sharon added to party Crestview Genetics LLC(pty:cc), Attorney Maia Sevilla-Sharon added to party Crestview Genetics LLC(pty:3pd), Attorney Maia Sevilla-Sharon added to party D. Alan Meeker(pty:3pd). Responses due by 11/22/2022 (Attachments: #1 Text of Proposed Order Proposed Order)(Sevilla-Sharon, Maia)
October 12, 2022 Opinion or Order Filing 311 ORDER RESETTING TRIAL DEADLINES: SCHEDULING ORDER: ( In Limine Motions due by 3/13/2023., Dispositive Motions due by 11/12/2022., Motions due by 11/12/2022., Pretrial Stipulation due by 3/13/2023.), Jury Trial set for 4/10/2023 09:00 AM in Fort Pierce Division before Judge Aileen M. Cannon. Calendar Call set for 4/4/2023 01:45 PM in Fort Pierce Division before Judge Aileen M. Cannon. Signed by Judge Aileen M. Cannon on 10/12/2022. See attached document for full details. (nan) #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.
September 30, 2022 Filing 310 Plaintiffs' ANSWER to Counterclaim by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1- 7/27/22 letter, #2 Exhibit 2- 7/29/22 letter, #3 Exhibit 3- 9/28/22 letter, #4 Exhibit 4- 7/12/22 letter, #5 Exhibit 5- 9/13/22 letter)(Chapman, Avery)
September 16, 2022 Filing 309 Defendants' ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand , COUNTERCLAIM against Adolfo Cambiaso, La Dolfina S.A. LLC by D. Alan Meeker, Crestview Farm LLC, Crestview Genetics LLC. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D)(Sevilla-Sharon, Maia)
September 9, 2022 Opinion or Order Filing 308 PAPERLESS ORDER granting #307 Motion to Withdraw as Counsel. Grace de la Gueronniere representing Plaintiffs La Dolfina S.A. LLC, Adolfo Cambiaso, and La Dolfina S.A. withdrawn from case. Plaintiffs will continue to be represented by Avery S. Chapman of Chapman Law Group, PLC and Habib Nasrullah, Harry H. Dorcy, and Miles D. Orton of Wheeler Trigg O'Donnell LLP. Signed by Magistrate Judge Bruce E. Reinhart on 9/9/2022. (kso)
September 8, 2022 Filing 307 Unopposed MOTION to Withdraw as Attorney for Plaintiffs by Grace de la Gueronniere for / by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). Responses due by 9/22/2022 (Chapman, Avery)
September 7, 2022 Opinion or Order Filing 306 PAPERLESS ORDER granting #304 Motion to Withdraw as Counsel. Ryan D. O'Quinn, formerly of the law firm DLA Piper LLP, representing Defendants Crestview Farm, LLC, D. Alan Meeker, and Crestview Genetics, LLC is hereby withdrawn and relieved of any further responsibility as counsel for Defendants. Defendants Crestview Farm, LLC, D. Alan Meeker, and Crestview Genetics, LLC will continue to be represented in this matter by Maia Sevilla-Sharon, Jason Lewis, and James C. Bookhout of DLA Piper LLP and Gary Woodfield of Nason Yeager Gerson Harris & Fumero, P.A. Maia Sevilla-Sharon shall be designated to act on behalf of the non-resident attorneys representing Defendants in this action, Jason Lewis and James C. Bookhout, that have been admitted pro hac vice pursuant to Local Rule 4(b). Signed by Magistrate Judge Bruce E. Reinhart on 9/7/2022. (kso)
September 6, 2022 Opinion or Order Filing 305 PAPERLESS ORDER: In light of #303 the Third Amended Complaint, the Clerk of the Court is directed to TERMINATE Park Place Polo Team Corporation and Park Place Polo Fields Corporation as Defendants in this action. Signed by Judge Aileen M. Cannon on 9/6/2022. (dsy)
September 6, 2022 Filing 304 Unopposed MOTION to Withdraw as Attorney by Ryan Dwight O'Quinn for / by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 9/20/2022 (Attachments: #1 Text of Proposed Order Proposed Order)(Sevilla-Sharon, Maia)
September 6, 2022 Set/Reset Response/Answer Due Deadline: Crestview Farm LLC response/answer due 9/16/2022; Crestview Genetics LLC response/answer due 9/16/2022; D. Alan Meeker response/answer due 9/16/2022. Per Chambers - See ECF No. #302 ORDER Granting #300 Motion for Clarification. (sk)
September 2, 2022 Filing 303 Third AMENDED COMPLAINT against Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker, filed by La Dolfina S.A. LLC(a Florida limited liability company), Adolfo Cambiaso(individually), La Dolfina S.A.. (Attachments: #1 Exhibit 1. Operating Agreement of Crestview Genetics, #2 Exhibit 2. Crestview Genetics Purchase and Sale Agreement, #3 Exhibit 3. Crestview Genetics Assignment of Membership Interest, #4 Exhibit 2009 Horse Cloning Contract, #5 Exhibit 2011 Quota-Holders Agreement, #6 Exhibit 6. 2019 Settlement Agreement, #7 Exhibit 7. 2019 Side Letter Agreement, #8 Exhibit 8. Secret Cloning Agreement, #9 Exhibit 9. Amendment to Secret Cloning Agreement, #10 Exhibit 10. Second Amendment to Secret Cloning Agreement, #11 Exhibit 11. Third Amendment to Secret Cloning Agreement, #12 Exhibit 12. Fourth Amendment to Secret Cloning Agreement, #13 Exhibit 13. Email demonstrating Crestview entities are merely alter-egos of Mr. Meeker, #14 Exhibit 14. Certificate of Interested Persons filed by Crestview Genetics in May 2016, #15 Exhibit 15. Affidavit of Julio Ernesto Gutierrez Conte, #16 Exhibit 16. Vanity Fair Article, #17 Exhibit 17. 60 Minutes Article, #18 Exhibit 18. Additional Media Statements by Meeker - No Sales of Clones, #19 Exhibit 19. Crestview v Chris Young Counterclaim, #20 Exhibit 20. Storm Cat Settlement Agreement, #21 Exhibit 21. November 18, 2020 Correspondence, #22 Exhibit 22. Composite Exhibit Andrey Borodin's Park Place Polo Team Purchased the Clones, #23 Exhibit 23. Affidavit of Robert P. Jornayvaz III, #24 Exhibit 24. Andrey Borodin's Park Place Polo Removes the 3 Clones from this Jurisdiction in the Midst of Litigation, #25 Exhibit 25. Certified Transcript of Voice Message from Price to Arellano, #26 Exhibit 26. Akerman LLP Representation of Daren Tamplin, DVM, #27 Exhibit 27. Inconsistencies of Crestview, #28 Exhibit 28. Affidavit of Camila Castagnola, #29 Exhibit 29. Affidavit of Bartolome Castagnola, #30 Exhibit 30. Affidavit of Roberto Zedda, #31 Exhibit 31. Second Affidavit of Roberto Zedda, #32 Exhibit 32. Affidavit of Santiago Ballester President of the Argentine Association of Polo Pony Breeders)(Chapman, Avery)
August 31, 2022 Reset Deadline (Third) Amended Complaint due by 9/2/2022. (mf)
August 30, 2022 Opinion or Order Filing 302 ORDER Granting #300 Motion for Clarification. The Third Amended Complaint is due 9/2/2022. Answer(s) deadline for the Third Amended Complaint due by 9/16/2022. Signed by Judge Aileen M. Cannon on 8/30/2022. See attached document for full details. (nan) Corrected text per chambers on 8/31/2022 (mf).
August 30, 2022 Filing 301 RESPONSE in Opposition re #300 Defendant's MOTION for clarification #299 Order on Motion to Dismiss for Failure to State a Claim,,,,,,,,,,,, Order on Expedited Motion,,,,,,, filed by La Dolfina S.A. LLC and filed by Adolfo Cambiaso(individually). Replies due by 9/6/2022. (Chapman, Avery)
August 29, 2022 Filing 300 Defendant's MOTION for clarification #299 Order on Motion to Dismiss for Failure to State a Claim,,,,,,,,,,,, Order on Expedited Motion,,,,,,, by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Responses due by 9/12/2022 (Chaskes, Robert)
August 19, 2022 Opinion or Order Filing 299 OMNIBUS ORDER ON MOTIONS TO DISMISS [ECF Nos. 144, 167, 168, 234] AND MOTION FOR PRELIMINARY INJUNCTION [ECF No. 179] granting in part and denying in part #144 Motion to Dismiss for Failure to State a Claim( Amended Complaint due by 9/2/2022.); granting in part and denying in part #167 Motion to Dismiss for Failure to State a Claim( Amended Complaint due by 9/2/2022.); granting #168 Motion to Dismiss; denying #179 Expedited Motion ; granting in part and denying in part #234 Motion to Dismiss for Failure to State a Claim (Third Amended Complaint due by 9/2/2022.). [For purposes of efficiency, the parties shall proceed ONLY in the action styled 20-82231-CIV-CANNON/Reinhart]. Signed by Judge Aileen M. Cannon on 8/19/2022. See attached document for full details. (nan)
August 12, 2022 Filing 298 TRANSCRIPT of Discovery Hearing held on 7/13/2022 before Magistrate Judge Bruce E. Reinhart, 1-39 pages, Court Reporter: Bonnie Joy Lewis, 305-523-5635. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/2/2022. Redacted Transcript Deadline set for 9/12/2022. Release of Transcript Restriction set for 11/10/2022. (kpe) Modified text on 8/15/2022 (wc).
August 6, 2022 Opinion or Order Filing 297 ORDER STAYING DEADLINES and denying #296 Joint Motion to Enlarge Page Limitations. Signed by Judge Aileen M. Cannon on 8/6/2022. See attached document for full details. (dsy)
August 4, 2022 Filing 296 Joint MOTION for Leave to File Excess Pages by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Text of Proposed Order Proposed Order)(Sevilla-Sharon, Maia)
August 3, 2022 Filing 295 NOTICE of Attorney Appearance by Francis M. McDonald, Jr on behalf of Adolfo Cambiaso, La Dolfina S.A. LLC. Attorney Francis M. McDonald, Jr added to party Adolfo Cambiaso(pty:pla), Attorney Francis M. McDonald, Jr added to party La Dolfina S.A. LLC(pty:pla). (McDonald, Francis)
July 28, 2022 Opinion or Order Filing 294 PAPERLESS ORDER denying as moot #286 Motion to Compel and Motion for Sanctions. The parties have resolved their dispute. Signed by Magistrate Judge Bruce E. Reinhart on 7/28/2022. (hk02)
July 27, 2022 Filing 293 NOTICE by Crestview Farm LLC, Crestview Genetics LLC, La Dolfina S.A., La Dolfina S.A. LLC, David Lichter, D. Alan Meeker Joint Notice of Stipulation Resolving Crestview Parties' Motion to Compel and For Sanctions (Sevilla-Sharon, Maia)
July 26, 2022 Opinion or Order Filing 292 PAPERLESS ORDER granting #291 Plaintiffs' Unopposed Motion for Extension of Time to File a Response to the Crestview Parties' Motion for Sanctions and to Compel [ECF 286]. Plaintiffs' Response is due by 7/27/2022. Signed by Magistrate Judge Bruce E. Reinhart on 7/26/2022. (hk02)
July 25, 2022 Filing 291 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #290 Order, #286 Defendant's MOTION to Compel Depositions Defendant's MOTION for Sanctions by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). (Chapman, Avery)
July 13, 2022 Opinion or Order Filing 290 ORDER Memorializing Discovery Rulings made during the Discovery Hearing on 7/13/22 (DE 289). Signed by Magistrate Judge Bruce E. Reinhart on 7/13/2022. See attached document for full details. (jgy)
July 13, 2022 Filing 289 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Bruce E. Reinhart: Discovery Hearing held on 7/13/2022. Total time in court: 0 hour(s) : 50 minutes. Order Memorializing Discovery Rulings forthcoming. (Digital BER_1_7.13.2022) (jgy)
July 12, 2022 Filing 288 Plaintiff's RESPONSE to #286 Defendant's MOTION to Compel Depositions Defendant's MOTION for Sanctions by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Chapman, Avery)
July 12, 2022 Opinion or Order Filing 287 PAPERLESS Order taking under advisement #286 Defendant's Motion to Compel and setting a Telephonic Discovery Hearing for 7/13/2022 at 11:00 AM before Magistrate Judge Bruce E. Reinhart to address 1) whether to compel Plaintiffs 30(b)(6) deposition, and 2) whether to compel depositions of Mr and Mrs. Castagnola. Counsel shall appear telephonically using the following conference call instructions: Dial 1-888-557-8511; Enter access code 4098267#; and Enter security code 1234#. Signed by Magistrate Judge Bruce E. Reinhart on 7/12/2022. (jgy)
July 11, 2022 Filing 286 Defendant's MOTION to Compel Depositions ( Responses due by 7/25/2022), Defendant's MOTION for Sanctions by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Attorney Maia Sevilla-Sharon added to party Crestview Farm LLC(pty:dft), Attorney Maia Sevilla-Sharon added to party Crestview Genetics LLC(pty:dft), Attorney Maia Sevilla-Sharon added to party D. Alan Meeker(pty:dft). (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 Text of Proposed Order Proposed Order)(Sevilla-Sharon, Maia)
June 21, 2022 Opinion or Order Filing 285 ORDER Scheduling Mediation before Jay M. Cohen. Mediation Hearing set for 8/2/2022 10:00 AM. Signed by Judge Aileen M. Cannon on 6/21/2022. See attached document for full details. (drz)
June 20, 2022 Reset Deadlines per paperless order DE#284. Expert Discovery due by 6/30/2022. (drz)
June 20, 2022 Opinion or Order Filing 284 PAPERLESS ORDER granting in part and denying in part #283 Joint Motion to Enlarge Time to Complete Depositions of Certain Expert Witnesses. Back in July 2021, the Court entered a Scheduling Order which set a deadline of May 20, 2022 for the parties to complete all discovery #111 . Subsequently, the Court twice extended that deadline with respect to expert discovery pursuant to the parties' requests #257 #261 , most recently setting the expert discovery deadline for June 17, 2022 #261 . Now, the parties again ask that the Court extend the expert discovery deadline, requesting a new deadline of July 8, 2022 #283 . The parties submitted this request for extension on June 17, 2022--the deadline at issue. The parties shall complete expert discovery on or before June 30, 2022. No further extensions of this deadline will be granted. Moving forward, any requests for extension must be filed sufficiently in advance of the deadline at issue. Signed by Judge Aileen M. Cannon on 6/20/2022. (dsy)
June 17, 2022 Filing 283 Joint MOTION for Extension of Time of Discovery Cutoff Deadline for Completion of Depositions of Certain Expert Wtinesses, submitted on behalf of all Parties by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
June 17, 2022 Filing 282 Joint NOTICE of Mediator Selection and Hearing. Selected/Added Jay M Cohen as Mediator. Mediation Hearing set for 8/2/2022 at 10:00 am. (Attachments: #1 Text of Proposed Order)(Chapman, Avery)
June 16, 2022 Filing 281 TRANSCRIPT of Hearing from the audiotaped proceedings held on 06/10/2022 before Magistrate Judge Bruce E. Reinhart, Volume Number 1 of 1, 1-33 pages, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 7/7/2022. Redacted Transcript Deadline set for 7/18/2022. Release of Transcript Restriction set for 9/14/2022. (Rassie, Ellen)
June 16, 2022 Opinion or Order Filing 280 PAPERLESS ORDER striking #278 Joint Amended Notice Scheduling Mediation. Pursuant to the Court's Scheduling Order #261 , the parties are obligated to file a joint notice scheduling mediation that identifies the name of the selected mediator and the time, date, and physical location for mediation. The parties' Joint Amended Notice, however, does not specify the agreed location for mediation. Accordingly, on or before June 17, 2022, the parties shall file a renewed joint notice scheduling mediation that specifically identifies the place for mediation. Signed by Judge Aileen M. Cannon on 6/16/2022. (dsy)
June 16, 2022 Filing 279 Clerks Notice to Filer re #278 Notice (Other),. Mediator Not Added; ERROR - The Filer failed to the mediator. Filer is instructed to file a Notice of Entry of Parties Listed into CM/ECF and add the mediator. (drz)
June 15, 2022 Filing 278 STRICKEN PER DE# 280 -NOTICE by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company) re 277 Order on Motion to Compel,,, Order on Motion for Extension of Time to Mediate,, Filed on behalf of all parties (Attachments: #1 Text of Proposed Order) (Chapman, Avery) Modified on 6/16/2022 (drz).
June 10, 2022 Opinion or Order Filing 277 PAPERLESS ORDER denying #275 the Park Place Defendants' Motion to Compel Mediation, and granting in part and denying in part #276 Plaintiffs' Motion to Enlarge Time to Complete Mediation. On or before August 3, 2022, the parties shall complete mediation and file a mediation report as required by the Court's Scheduling Order #261 . Pursuant to that Order, mediation must take place in person #261 . On or before June 15, 2022, the parties shall select a mediator and jointly file a proposed notice scheduling mediation #261 . No further extensions of these deadlines will be granted. Signed by Judge Aileen M. Cannon on 6/10/2022. (dsy)
June 10, 2022 Filing 276 Plaintiff's MOTION for Extension of Time to Mediate and provide Report, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
June 10, 2022 Filing 275 MOTION to Compel Mediation by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Responses due by 6/24/2022 (Chaskes, Robert)
June 10, 2022 Opinion or Order Filing 274 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Bruce E. Reinhart: Discovery Hearing held on 6/10/2022. Total time in court: 0 hour(s) : 30 minutes.MINUTE ORDER: For the reasons stated on the record, Ms. Maria Vazquez shall, in her individual capacity, make herself available for a deposition via Zoom on June 17, 2022. On before Monday, June 13, 2022 at 5:00 PM, the Crestview Defendants are ordered to provide Plaintiffs' counsel with the list of topics to which they believe Plaintiffs' original 30(b)(6) witness did not adequately respond. Plaintiffs may then designate an additional 30(b)(6) witness. If Plaintiffs chose to designate Ms. Vazquez as the additional 30(b)(6) witness, that deposition shall also take place via Zoom on June 17, 2022. If Plaintiffs chose to designate a different individual as the additional 30(b)(6) witness, that deposition shall take place IN PERSON in Palm Beach County on or before July 1, 2022. Signed by Magistrate Judge Bruce E. Reinhart on 6/10/2022. (Digital BER_1_6.10.2022). (jgy)
June 8, 2022 Filing 273 NOTICE by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker of Filing Correspondence in Compliance with Court Order (Attachments: #1 Exhibit Email Correspondence, #2 Exhibit Exhibits to Email) (O'Quinn, Ryan)
June 8, 2022 Filing 272 NOTICE of Striking #268 Notice (Other) filed by Crestview Genetics LLC, D. Alan Meeker, Crestview Farm LLC by Crestview Farm LLC, Crestview Genetics LLC, Crestview Genetics LLC, Crestview Genetics LLC, Crestview Genetics LLC, D. Alan Meeker, D. Alan Meeker (O'Quinn, Ryan)
June 8, 2022 Filing 271 Clerks Notice to Filer re #268 Notice (Other). Document Not Captioned; CORRECTIVE ACTION REQUIRED - The Filer must File a Notice of Striking, then refile the document with the proper caption pursuant to Local Rules. (drz)
June 8, 2022 Filing 270 Clerks Notice of Docket Correction re 269 Clerks Notice of Docket Correction and Instruction to Filer - Attorney,,. Correction Other. Incorrect Notice of Correction to Attorney Filed. (drz)
June 8, 2022 Filing 269 Clerks Notice to Filer re #268 Notice (Other). Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED - 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 the typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and Local Rule 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (drz)
June 7, 2022 Filing 268 STRICKEN PER DE#268 -NOTICE by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker Re Discovery Dispute (Attachments: #1 Exhibit 1-12) (O'Quinn, Ryan) Modified on 6/8/2022 (drz).
June 3, 2022 Opinion or Order Filing 267 PAPERLESS Order setting telephonic Discovery Hearing for 6/10/2022 at 01:30 PM before Magistrate Judge Bruce E. Reinhart. Counsel shall appear telephonically using the following conference call instructions: Dial 1-888-557-8511; Enter access code 4098267#; and Enter security code 1234#. Signed by Magistrate Judge Bruce E. Reinhart on 6/3/2022. (jgy)
May 31, 2022 Opinion or Order Filing 266 PAPERLESS ORDER denying without prejudice #264 Plaintiffs' Motion for Protective Order for failure to comply with the discovery dispute procedures outlined in Section III of the Court's Standing Discovery Order at #114 . See the Court's Order at 265 . If the dispute is not resolved after a discovery hearing, the Court will consider authorizing the filing of an appropriate discovery motion. Signed by Magistrate Judge Bruce E. Reinhart on 5/31/2022. (jgy)
May 31, 2022 Opinion or Order Filing 265 PAPERLESS ORDER regarding discovery dispute. The Court is in receipt of the Crestview Defendants' e-mail outlining a pending discovery dispute related to the deposition of a witness. The e-mail does not comply with Section III of the Court's Standing Discovery Order at #114 . In compliance with Section III of the SDO , the parties are ordered to confer and if, after conferring, the parties are unable to resolve their dispute without the Court's intervention, they shall e-mail the Court with two afternoons in the following seven business days when all parties are available for a discovery hearing. Signed by Magistrate Judge Bruce E. Reinhart on 5/31/2022. (jgy)
May 30, 2022 Filing 264 Plaintiff's MOTION for Protective Order re: location of deposition of Maria Vazquez by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Chapman, Avery)
May 26, 2022 Opinion or Order Filing 263 PAPERLESS ORDER granting #262 Joint Motion to Enlarge Time to Complete Depositions of Certain Fact Witnesses. The parties may complete the depositions of Santiago Ballester, Juan Carlos Di Caro, Ernesto Gutierrez, Maria Vazquez, Camilla Castagnola, and Bartolome Castagnola on or before June 17, 2022. No further extensions of this deadline will be granted. Signed by Judge Aileen M. Cannon on 5/26/2022. (dsy)
May 26, 2022 Filing 262 Joint MOTION for Extension of Time to Complete Depositions of Certain Fact Witnesses re #261 Order on Motion for Extension of Time to Mediate, Order on Motion to Take Deposition by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). Responses due by 6/9/2022 (Chapman, Avery)
May 23, 2022 Set Deadlines/Hearings ( Pretrial Stipulation due by 12/19/2022.), Deadline(s)/Hearing(s) terminated. Per Order DE#261 . (drz)
May 23, 2022 Opinion or Order Filing 261 ORDER granting #258 JOINT MOTION AND RESETTING PRETRIAL AND TRIAL DEADLINES. Signed by Judge Aileen M. Cannon on 5/23/2022. See attached document for full details. (drz)
May 23, 2022 Set Deadlines/Hearings PER ORDER de#261 . Expert Discovery due by 6/17/2022. Fact Discovery due by 5/27/2022. Mediation Deadline 7/15/2022. Dispositive Motions due by 8/8/2022. In Limine Motions due by 12/19/2022. Motions due by 8/8/2022. Pretrial Order due by 12/19/2022. Calendar Call set for 1/10/2023 01:45 PM before Judge Aileen M. Cannon. Jury Trial set for 1/17/2023 09:00 AM before Judge Aileen M. Cannon. (drz)
May 22, 2022 Opinion or Order Filing 260 PAPERLESS ORDER: In light of #232 the Crestview Defendants' Amended Counterclaim, Plaintiffs' Amended Motion to Dismiss the Counterclaim #228 is DENIED AS MOOT. Signed by Judge Aileen M. Cannon on 5/22/2022. (dsy)
May 17, 2022 Filing 259 Clerks Notice to Filer re #258 Joint MOTION for Extension of Time to Complete Scheduled Mediation and to Complete International and Out of State Depositions re #111 Scheduling Order,,,. 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. AND Wrong Motion Relief(s) Selected; ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs. (ls)
May 16, 2022 Filing 258 Joint Motion for Extension of Time to Mediate/Complete Scheduled Mediation ,,, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 5/31/2022 (Chapman, Avery) Modified Relief on 5/17/2022 (ls). Added MOTION to Complete International and Out of State Depositions after Discovery Cutoff on 5/17/2022 (ls).
April 20, 2022 Opinion or Order Filing 257 ORDER GRANTING JOINT MOTION AND RESETTING PRE-TRIAL DEADLINES. Granting #254 Motion for Extension of Time; striking #255 Motion for Extension of Time of Discovery Cutoff Deadline; granting #256 Motion to Strike #254 Joint MOTION for Extension of Time for Expert Disclosure re #111 Scheduling Order ( Expert Discovery due by 6/10/2022., Fact Discovery due by 5/20/2022.). Signed by Judge Aileen M. Cannon on 4/18/2022. See attached document for full details. (ail)
April 18, 2022 Filing 256 Joint MOTION to Strike #255 Joint MOTION for Extension of Time of Discovery Cutoff Deadline of Expert Disclosures Duplicate Filing by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). Responses due by 5/2/2022 (Chapman, Avery)
April 13, 2022 Filing 255 Joint MOTION for Extension of Time of Discovery Cutoff Deadline of Expert Disclosures by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
April 13, 2022 Filing 254 Joint MOTION for Extension of Time for Expert Disclosure re #111 Scheduling Order,,, by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 4/27/2022 (Chapman, Avery)
April 8, 2022 Opinion or Order Filing 253 PAPERLESS Order Cancelling the Status Conference Re: Discovery Matters set for 4/14/2022 at 01:00 PM,, in light of counsel's representation to the Court that the status conference is not needed. Cancellation of the Discovery Status Conference is without prejudice to the parties requesting a hearing should a discovery dispute later arise. Signed by Magistrate Judge Bruce E. Reinhart on 4/8/2022. (jgy)
April 7, 2022 Filing 252 STATUS REPORT Joint Discovery Status Report by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
March 16, 2022 Opinion or Order Filing 251 PAPERLESS ORDER granting #250 the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Miles D. Orton. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsel's pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on 3/16/2022. (dsy)
March 15, 2022 Filing 250 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Miles D. Orton. Filing Fee $ 200.00 Receipt # AFLSDC-15478945 by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company). Responses due by 3/29/2022 (Attachments: #1 Certification, #2 Text of Proposed Order)(Chapman, Avery)
March 8, 2022 Filing 249 TRANSCRIPT of Discovery Hearing held on 3/3/2022 before Magistrate Judge Bruce E. Reinhart, 1-32 pages, Court Reporter: Joanne Mancari, 305-523-5635. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/29/2022. Redacted Transcript Deadline set for 4/8/2022. Release of Transcript Restriction set for 6/6/2022. (apz)
March 3, 2022 Opinion or Order Filing 248 ORDER MEMORIALIZING DISCOVERY RULINGS. Signed by Magistrate Judge Bruce E. Reinhart on 3/3/2022. See attached document for full details. (jgy)
March 3, 2022 Filing 247 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Bruce E. Reinhart: Discovery Hearing held on 3/3/2022. Total time in court: 0 hour(s) : 45 minutes. Order forthcoming. (Digital BER_1_3.3.2022) (jgy)
March 2, 2022 Filing 246 STATUS REPORT Joint Discovery Memorandum by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Chapman, Avery)
March 1, 2022 Opinion or Order Filing 245 PAPERLESS Order setting Telephonic Discovery Hearing at the request of the parties for 3/3/2022 at 01:00 PM before Magistrate Judge Bruce E. Reinhart. Counsel shall appear telephonically using the following conference call instructions: Dial 1-888-557-8511; Enter access code 4098267#; and Enter security code 1234#. Signed by Magistrate Judge Bruce E. Reinhart on 3/1/2022. (jgy)
February 25, 2022 Filing 244 Plaintiff's REPLY to Response to Motion re #234 Amended MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
February 17, 2022 Opinion or Order Filing 243 PAPERLESS ORDER granting #242 Plaintiffs' Unopposed Motion for Extension of Time to File a Reply in Support of #234 Amended Motion to Dismiss Crestview Genetics' #232 Amended Counterclaim. Plaintiffs may file a reply in support of their amended motion to dismiss #234 on or before February 25, 2022. Signed by Judge Aileen M. Cannon on 2/17/2022. (dsy)
February 16, 2022 Filing 242 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #240 Response in Opposition to Motion, #234 Amended MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Text of Proposed Order Exhibit A)(Chapman, Avery)
February 15, 2022 Opinion or Order Filing 241 PAPERLESS ORDER denying #235 the Park Place Defendants' Motion to Stay Discovery Pending a Ruling on their Motion to Dismiss the Second Amended Complaint. The parties shall proceed in accordance with the Court's Scheduling Order #111 and Magistrate Judge Reinhart's Standing Discovery Order #114 . Signed by Judge Aileen M. Cannon on 2/15/2022. (dsy)
February 11, 2022 Filing 240 RESPONSE in Opposition re #234 Amended MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM filed by Crestview Genetics LLC(a Nevada limited liability company). Replies due by 2/18/2022. (O'Quinn, Ryan)
February 11, 2022 Filing 239 Defendant's REPLY to Response to Motion re #235 Defendant's MOTION to Stay DISCOVERY PENDING A RULING ON THEIR #168 MOTION TO DISMISS SECOND AMENDED COMPLAINT filed by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. (Chaskes, Robert)
February 4, 2022 Filing 238 RESPONSE in Opposition re #235 Defendant's MOTION to Stay DISCOVERY PENDING A RULING ON THEIR #168 MOTION TO DISMISS SECOND AMENDED COMPLAINT filed by Adolfo Cambiaso, La Dolfina S.A. LLC. Replies due by 2/11/2022. (Chapman, Avery)
February 4, 2022 Filing 237 NOTICE by Adolfo Cambiaso(individually), La Dolfina S.A., La Dolfina S.A. LLC(a Florida limited liability company) re #234 Amended MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM of Scriveners Error (Chapman, Avery)
February 3, 2022 Filing 236 Notice of Ninety Days Expiring by Park Place Polo Fields Corporation, Park Place Polo Team Corporation re #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law filed by Park Place Polo Team Corporation, Park Place Polo Fields Corporation (Chaskes, Robert)
February 1, 2022 Filing 235 Defendant's MOTION to Stay DISCOVERY PENDING A RULING ON THEIR #168 MOTION TO DISMISS SECOND AMENDED COMPLAINT by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Responses due by 2/15/2022 (Chaskes, Robert)
January 28, 2022 Filing 234 Amended MOTION TO DISMISS #232 Amended COUNTERCLAIM against Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC, filed by Crestview Genetics LLC. Responses due by 2/11/2022 (Chapman, Avery) Modified to link to DE #232 per filing attorney on 2/4/2022 (pes).
January 21, 2022 Filing 233 RESPONSE in Opposition re #228 Amended MOTION to Dismiss for Lack of Jurisdiction #223 Counterclaim MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM filed by Crestview Genetics LLC. Replies due by 1/28/2022. (O'Quinn, Ryan)
January 14, 2022 Filing 232 Amended COUNTERCLAIM against Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC, filed by Crestview Genetics LLC. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C)(O'Quinn, Ryan)
January 6, 2022 Opinion or Order Filing 231 PAPERLESS ORDER: In light of the filing of an Amended Motion to Dismiss the Counterclaim #228 , Plaintiffs' Motion to Dismiss the Counterclaim #227 is DENIED AS MOOT. Signed by Judge Aileen M. Cannon on 1/6/2022. (dsy)
January 6, 2022 Opinion or Order Filing 230 PAPERLESS ORDER granting #229 Crestview Genetics, LLC's Motion for Enlargement of Time to Respond to #228 Plaintiffs' Amended Motion to Dismiss #223 Crestview Genetics, LLC's Counterclaim. Crestview Genetics, LLC shall respond to the motion to dismiss #228 on or before January 21, 2022. Signed by Judge Aileen M. Cannon on 1/6/2022. (dsy)
January 3, 2022 Filing 229 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #228 Amended MOTION to Dismiss for Lack of Jurisdiction #223 Counterclaim MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM by Crestview Genetics LLC. (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
December 24, 2021 Filing 228 Amended MOTION to Dismiss for Lack of Jurisdiction #223 Counterclaim , MOTION TO DISMISS #223 Counterclaim FOR FAILURE TO STATE A CLAIM ( Responses due by 1/7/2022) by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
December 24, 2021 Filing 227 Plaintiff's MOTION to Dismiss #223 Counterclaim by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 1/7/2022 (Chapman, Avery)
December 20, 2021 Opinion or Order Filing 226 PAPERLESS ORDER granting #225 Plaintiffs' Motion for Enlargement of Time to Respond to Crestview Genetics' Counterclaim. Plaintiffs shall respond to the Counterclaim #223 on or before December 24, 2021. Signed by Judge Aileen M. Cannon on 12/20/2021. (dsy)
December 19, 2021 Filing 225 MOTION for Extension of Time to File Response/Reply/Answer as to #223 Counterclaim by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
December 1, 2021 Opinion or Order Filing 224 PAPERLESS ORDER denying #222 Plaintiffs' Motion to Enlarge Time to Amend Pleadings and Join Parties. Signed by Judge Aileen M. Cannon on 12/01/2021. (dsy)
November 30, 2021 Filing 223 COUNTERCLAIM against Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC, filed by Crestview Genetics LLC.(O'Quinn, Ryan)
November 30, 2021 Filing 222 Plaintiff's MOTION for Extension of Time to Amend 217 Order on Motion for Extension of Time to Amend, or Join Additional Parties by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 12/14/2021 (Chapman, Avery)
November 23, 2021 Opinion or Order Filing 221 PAPERLESS ORDER granting #220 Plaintiff's Motion for Extension of Time to Serve Discovery Responses on Crestview Defendants. Plaintiff shall have until November 29, 2021 to respond to the discovery requests from the Crestview Defendants. However, the deadline for Plaintiff to respond to Crestview Defendants' discovery requests was 11/22/21 (see DE 207) and the Court notes that Plaintiff filed the instant Motion at 5:28pm on 11/22/21. The Court warns all parties in this action that it will not countenance a repeated practice of asking for extensions at the very last minute. Furthermore, the Court is granting this Motion in part because the deadline has already passed. However, since Crestview Defendants were not given sufficient time to confer with Plaintiff's counsel regarding the relief requested in the motion before it was filed, this Order is without prejudice to Crestview Defendants filing a motion seeking the relief they believe is required. Signed by Magistrate Judge Bruce E. Reinhart on 11/23/2021. (jgy)
November 22, 2021 Filing 220 Plaintiff's MOTION for Extension of Time to Serve Discovery Responses re 207 Order on Motion for Extension of Time,, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 12/6/2021 (Chapman, Avery)
November 19, 2021 Opinion or Order Filing 219 ORDER Granting re #216 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Harry Dorcy. Filing Fee $ 200.00 Receipt # AFLSDC-15184019 filed by La Dolfina S.A. LLC, La Dolfina S.A., Adolfo Cambiaso Signed by Magistrate Judge Bruce E. Reinhart on 11/18/2021. See attached document for full details. (ail)
November 18, 2021 Opinion or Order Filing 218 PAPERLESS ORDER granting #216 the Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Harry Dorcy. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsel's pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on 11/18/2021. (dsy)
November 18, 2021 Opinion or Order Filing 217 PAPERLESS ORDER granting in part and denying in part #215 Plaintiffs' Motion to Enlarge Time to Amend Pleadings and Join Parties. The parties may amend pleadings and join parties on or before November 30, 2021. Signed by Judge Aileen M. Cannon on 11/18/2021. (dsy)
November 18, 2021 Filing 216 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Harry Dorcy. Filing Fee $ 200.00 Receipt # AFLSDC-15184019 by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 12/2/2021 (Attachments: #1 Certification of Harry Dorcy, #2 Text of Proposed Order)(Chapman, Avery)
November 16, 2021 Filing 215 Unopposed MOTION for Extension of Time to Amend 186 Order on Motion to Expedite, Enlarging Time to Amend Pleadings and/or Join Additional Parties Until Ten (10) Days After Ruling on Motions to Dismiss [144, 168] Second Amended Complaint #122 , by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 11/30/2021 (Chapman, Avery)
November 10, 2021 Opinion or Order Filing 214 PAPERLESS ORDER denying as moot #213 Plaintiff's Unopposed Motion for Extension of Time to Respond to the First Request for Production of Documents. The Motion seeks a 30-day extension to respond to Defendant Park Place Polo Corp.'s First Request for Production and the Motion represents that the request is unopposed. Pursuant to Section II, paragraph E of the Standing Discovery Order, "the parties may agree to a longer period for production, without leave of Court." #114 . Because the parties agree to the extension of time, the Motion is denied as moot. Signed by Magistrate Judge Bruce E. Reinhart on 11/10/2021. (jgy)
November 9, 2021 Filing 213 Unopposed MOTION for Extension of Time to Respond to the First Request for Production of Documents from Defendant Park Place Polo Corporation by Adolfo Cambiaso. Responses due by 11/23/2021 (Chapman, Avery)
November 5, 2021 Filing 212 REPLY to Response to Motion re #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law filed by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. (Pankey, Noelle)
November 2, 2021 Opinion or Order Filing 211 PAPERLESS ORDER granting #210 Defendants Park Place Polo Team Corporation and Park Place Polo Fields Corporation's Motion to Enlarge Page Limitation for Their Reply in Support of Their Motion to Dismiss the Second Amended Complaint. The Park Place Defendants are permitted to file a Reply that does not exceed fifteen (15) pages (double spaced and fully justified). Signed by Judge Aileen M. Cannon on 11/2/2021. (dsy)
November 1, 2021 Filing 210 Defendant's MOTION for Leave to File Excess Pages DEFENDANTS PARK PLACE POLO TEAM CORPORATION AND PARK PLACE POLO FIELDS CORPORATIONS MOTION TO ENLARGE PAGE LIMITATION FOR THEIR REPLY IN SUPPORT OF THEIR MOTION TO DISMISS THE SECOND AMENDED COMPLAINT by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. (Attachments: #1 Exhibit Proposed Order)(Pankey, Noelle)
October 25, 2021 Reset Deadlines Per DE#209. Replies due by 11/5/2021. (cqs)
October 23, 2021 Opinion or Order Filing 209 PAPERLESS ORDER granting #208 Defendants Park Place Polo Fields Corporation and Park Place Polo Team Corporation's Unopposed Motion for Extension of Time to File Reply in Support of #168 Motion to Dismiss the Second Amended Complaint. The Park Place Defendants shall file their Reply in Support of their Motion to Dismiss the Second Amended Complaint on or before November 5, 2021. Signed by Judge Aileen M. Cannon on 10/23/2021. (dsy)
October 22, 2021 Filing 208 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law DEFENDANTS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE A REPLY IN SUPPORT OF THEIR MOTION TO DISMISS THE SECOND AMENDED COMPLAINT by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. (Attachments: #1 Exhibit Proposed Order)(Pankey, Noelle)
October 21, 2021 Opinion or Order Filing 207 PAPERLESS ORDER granting in part and denying in part #203 Plaintiff's Motion for Extension of Time to Respond to the first Discovery Requests from the Crestview Defendants. Having reviewed Plaintiff's Motion and Defendants' Opposition (DE #205 ), the Court finds that Plaintiff's Motion, in accordance with Section II(E) of the Court's Standing Discovery Order (DE #114 ) includes a good cause explanation for why production cannot be completed by the deadline and an extension should be granted. Thus, Plaintiff shall have until November 22, 2021 to respond to the discovery requests from the Crestview Defendants. Signed by Magistrate Judge Bruce E. Reinhart on 10/21/2021. (jgy)
October 20, 2021 Filing 206 RESPONSE in Opposition re #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law filed by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Replies due by 10/27/2021. (Chapman, Avery)
October 20, 2021 Filing 205 RESPONSE in Opposition re #203 Plaintiff's MOTION for Extension of Time to Respond to the first Discovery Requests from the Crestview Defendants re #114 Order filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 10/27/2021. (O'Quinn, Ryan)
October 19, 2021 Opinion or Order Filing 204 PAPERLESS ORDER requiring Crestview Defendants to file an EXPEDITED Response to #203 Plaintiff's Motion for Extension of Time to Respond to the first Discovery Requests from the Crestview Defendants. Defendants shall file their Response by no later than Wednesday, October 20, 2021 at 5:00 PM. Signed by Magistrate Judge Bruce E. Reinhart on 10/19/2021. (jgy)
October 19, 2021 Filing 203 Plaintiff's MOTION for Extension of Time to Respond to the first Discovery Requests from the Crestview Defendants re #114 Order by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 11/2/2021 (Chapman, Avery)
October 15, 2021 Filing 202 NOTICE by Adolfo Cambiaso, La Dolfina S.A. LLC re 201 Motion Hearing,,,,, Notice of Filing Exhibits Displayed to the Court During the October 15, 2021 Hearing (de la Gueronniere, Grace)
October 15, 2021 Filing 201 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Motion Hearing held on 10/15/2021 re #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law filed by Park Place Polo Team Corporation, Park Place Polo Fields Corporation, #167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Crestview Genetics LLC, D. Alan Meeker, Crestview Farm LLC, #144 MOTION TO DISMISS #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Crestview Genetics LLC, D. Alan Meeker, Crestview Farm LLC, #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, filed by La Dolfina S.A. LLC, Adolfo Cambiaso. The Court heard arguments from the parties on the pending motions. Orders to follow. Total time in court: 1 hour(s) : 30 minutes. Attorney Appearance(s): Grace Rockefeller de la Gueronniere, Habib Nasrullah, Avery Spencer Chapman, Gary A. Woodfield, Jason S. Lewis, James C. Bookhout, Robert Iddings Chaskes, Noelle Page Pankey, Diego Andres Bucking Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. (dsy)
October 14, 2021 Filing 200 Plaintiff's REPLY to Response to Motion re #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, Reply to Response by Park Place Polo Defendants to Plaintiffs' Renewed Motion for Issuance of a Preliminary Injunction filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. Andrey Borodin Polo Players' Edition Magazine Cover Article, #2 Exhibit 2. Draft 2020 Secret Purchase Agreement (Akerman000248), #3 Exhibit 3. Crestview_0001992, #4 Exhibit 4. Crestview_0003141, #5 Exhibit 5. Akerman000001_image, #6 Exhibit 6. Crestview_0002649, #7 Exhibit 7. PPPT000540, #8 Exhibit 8. Tamplin000136)(Chapman, Avery)
October 14, 2021 Filing 199 REPLY to Response to Motion re #167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (O'Quinn, Ryan)
October 14, 2021 Filing 198 Notice of Supplemental Authority re #158 Reply to Response to Motion, 195 Order on Motion for Leave to File, by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
October 14, 2021 Filing 197 Plaintiff's REPLY to Response to Motion re #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, Reply by Plaintiffs to Response of Crestview Defendants to Expedited Motion for Issuance of a Preliminary Injunction filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. Andrey Borodin Polo Players' Edition Magazine Cover Article)(Chapman, Avery)
October 11, 2021 Filing 196 RESPONSE in Opposition re #167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Replies due by 10/18/2021. (Chapman, Avery)
October 11, 2021 Opinion or Order Filing 195 PAPERLESS ORDER denying #191 Renewed Motion for Leave to File Sur-Reply in Opposition to Motion to Dismiss. If Plaintiffs wish, on or before October 14, 2021, they may file a Notice of Supplemental Authority limited to a maximum of 250 words. Plaintiffs shall include a Certificate of Word Count. No further briefing will be permitted on #144 Motion to Dismiss. Signed by Judge Aileen M. Cannon on 10/11/2021. (dsy)
October 11, 2021 Opinion or Order Filing 194 PAPERLESS ORDER granting #192 Defendants' Unopposed Motion to File Overlength Response in Opposition to Plaintiffs' Renewed Expedited Motion for Entry of Preliminary Injunction. The Court already reminded the parties per ECF No. 176 that they may not file documents that require prior Court approval without first obtaining leave of Court. Parties may attach the proposed document as an attachment to any motion seeking leave, but the proposed document may not be filed as an independent docket entry without prior Court approval. Any future filings that fail to comply with this directive will be stricken without further notice. Furthermore, motions to file overlength briefs must be filed sufficiently before the Court deadline to permit Court review of the motion. Signed by Judge Aileen M. Cannon on 10/11/2021. (dsy) Modified text/status per Chambers on 10/12/2021 (sk).
October 8, 2021 Filing 193 RESPONSE in Opposition re #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 10/15/2021. (Attachments: #1 Exhibit Exhibit A)(O'Quinn, Ryan)
October 8, 2021 Filing 192 Unopposed MOTION for Leave to File Excess Pages to Enlarge Page Limitation by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
October 8, 2021 Filing 191 Renewed MOTION for Leave to File proposed SUR-REPLY in Opposition to [DE 158] by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. proposed SUR-REPLY)(Chapman, Avery)
October 8, 2021 Filing 190 RESPONSE in Opposition re #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, filed by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Replies due by 10/15/2021. (Attachments: #1 Exhibit Ex. 1 - Executed Simmons Declaration)(Pankey, Noelle)
October 7, 2021 Opinion or Order Filing 189 PAPERLESS ORDER granting #188 Motion to Withdraw as Attorney. Molly Kokesh from the law firm of Davis Graham & Stubbs LLP representing Plaintiffs La Dolfina S.A. LLC, La Dolfina S.A., and Adolfo Cambiaso is hereby withdrawn and relieved of any further responsibility as counsel for Plaintiffs. The Clerk is directed to remove Ms. Kokesh from the CM/ECF electronic list of counsel to be served in this action. Plaintiffs La Dolfina S.A. LLC, La Dolfina S.A., and Adolfo Cambiaso will continue to be represented in this matter by Avery S. Chapman and Grace De la Gueronniere of Chapman Law Group, PLC, and Habib Nasrullah of Wheeler Trigg ODonnell LLP. Signed by Magistrate Judge Bruce E. Reinhart on 10/7/2021. (jgy)
October 6, 2021 Filing 188 MOTION to Withdraw as Attorney as counsel of record for Plaintiffs La Dolfina S.A. LLC and Adolfo Cambiaso and Defendant and Counterclaim/Third Party Complaint Plaintiff La Dolfina S.A. by Molly Kokesh for / by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 10/20/2021 (de la Gueronniere, Grace)
October 6, 2021 Filing 187 NOTICE by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC re 47 Order on Motion to Appear Pro Hac Vice,, of Change of Address, Email or Law Firm Name as to Habib Nasrullah. Attorney Grace Rockefeller de la Gueronniere added to party La Dolfina S.A.(pty:3pp). (de la Gueronniere, Grace)
October 5, 2021 Opinion or Order Filing 186 PAPERLESS ORDER granting in part and denying in part #182 Expedited Motion by Plaintiffs to Amend the Scheduling Order Regarding Date for Amendment of Pleadings and Joinder of Parties. Parties shall amend their pleadings and join parties on or before November 16, 2021. Signed by Judge Aileen M. Cannon on 10/5/2021. (dsy)
October 5, 2021 Filing 185 PAPERLESS NOTICE of Hearing: re #167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM , #144 MOTION TO DISMISS #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, FOR FAILURE TO STATE A CLAIM , #179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,,, #182 Renewed MOTION to Expedite tp Amend Scheduling Order re Date for Amendement of Pleadings, #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law Motion Hearing set for 10/15/2021 08:30 AM in Fort Pierce Division before Judge Aileen M. Cannon via the Zoom platform. The Zoom link and information will be emailed to the parties of record. (tgs)
October 5, 2021 Filing 184 RESPONSE in Opposition re #182 Renewed MOTION to Expedite tp Amend Scheduling Order re Date for Amendement of Pleadings filed by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Replies due by 10/12/2021. (Pankey, Noelle)
October 4, 2021 Filing 183 RESPONSE in Opposition re #182 Renewed MOTION to Expedite tp Amend Scheduling Order re Date for Amendement of Pleadings filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 10/12/2021. (O'Quinn, Ryan)
September 30, 2021 Filing 182 Renewed MOTION to Expedite tp Amend Scheduling Order re Date for Amendement of Pleadings by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
September 29, 2021 Filing 181 Corporate Disclosure Statement by Park Place Polo Team Corporation identifying Corporate Parent Park Place Polo, Ltd. for Park Place Polo Team Corporation (Pankey, Noelle)
September 29, 2021 Filing 180 Corporate Disclosure Statement by Park Place Polo Fields Corporation identifying Corporate Parent Wonderland Services, Ltd for Park Place Polo Fields Corporation (Pankey, Noelle)
September 27, 2021 Set/Reset Deadline as to #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal, with Incorporated Memorandum of Law. Responses due by 10/20/2021. SEE DE 178 ORDER (ail)
September 27, 2021 Set/Reset Deadline as to #167 MOTION TO DISMISS #134 Counterclaim,Third Party Complaint,FOR FAILURE TO STATE A CLAIM . Responses due by 10/11/2021.SEE DE 177 ORDER (ail)
September 24, 2021 Filing 179 Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re 172 Order on Expedited Motion,,,,, Order on Motion for Leave to File,,,,,,,,, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. Transcript from 1.29.2021 TRO Hearing, #2 Exhibit 2. Composite of Secret Cloning Agreement and Two Amendments Thereto, #3 Exhibit 3. Sworn Statements by Meeker Know Known to be False, #4 Exhibit 4. Operating Agreement of Crestview Genetics, LLC, #5 Exhibit 5. December 31, 2017 Assignment of all Ownership Interest in Genetics to Farm, #6 Exhibit 6. Email re No Cuartetera Clone Embryo Sale, #7 Exhibit 7. Crestview Genetics, LLC Articles of Organization, #8 Exhibit 8. October 8, 2020 Email re Drafting Secret Cloning Agreement, #9 Exhibit 9. Technical Consulting and Services Agreement, #10 Exhibit 10. Viagen Equine Cloning Contract, #11 Exhibit 11. March 23, 2011 Email re Quota Holder Agreement, #12 Exhibit 12. September 18, 2020 Email from Mr. Juan Carlo Di Caro, #13 Exhibit 13. June 11, 2020 Email from Mr. Di Caro, #14 Exhibit 14. March 11, 2020 Email from Mr. Meeker Showing Known Disagreement over Interpretations of Agreements, #15 Exhibit 15. September 18, 2009 Letter from Viagen re Viable Cuartetera Cells, #16 Exhibit 16. Park Place Polo Manager Voice Mail Transcript, #17 Exhibit 17. Park Place Polo Manager Writes of Concealing Cuartetera Clone Whereabouts, #18 Exhibit 18. 2009 Horse Cloning Contract, #19 Exhibit 19. 2011 Quota-Holders Agreement, #20 Exhibit 20. Affidavit of Julio Ernesto Gutierrez Conte, #21 Exhibit 21. Media Reports, #22 Exhibit 22. 2019 Side Letter Agreement, #23 Exhibit 23. Affidavit of Camila Castagnola, #24 Exhibit 24. Affidavit of Bartolome Castagnola, #25 Exhibit 25. Affidavit of Mr. Astrada, #26 Exhibit 26. Affidavit of Santiago Ballester President of the Argentine Association of Polo Pony Breeders, #27 Exhibit 27. Clone Injured, Receives Over 1 Month Emergency Care, #28 Exhibit 28. Another Clone Injured, #29 Exhibit 29. Second Affidavit of Roberto Zedda, #30 Exhibit 30. Non-Disclosure Agreement with Park Place Polo, #31 Exhibit 31. Affidavit of Roberto Zedda, #32 Exhibit 32. Very Large December 2020 Payment from Crestview Defendants to ViaGen, #33 Exhibit 33. Composite Exhibit of Park Place Polo Florida Corporate Records, #34 Exhibit 34. November 2019 Email Crestview Defendants State Cuarteteras Produced per 2019 Side Letter Agreement, #35 Exhibit 35. Email Demonstrating Crestview Entities are Alter-Egos of Mr. Meeker, #36 Text of Proposed Order)(Chapman, Avery)
September 24, 2021 Opinion or Order Filing 178 PAPERLESS ORDER granting #174 Plaintiffs Adolfo Cambiaso and La Dolfina S.A., LLC's Unopposed Motion for Enlargement of Time to File Response in Opposition to Defendants Park Place Polo Team Corporation and Park Place Polo Fields Corporation's Motion to Dismiss the Second Amended Complaint. Plaintiffs shall file their Response in Opposition to Defendants Park Place Polo Team Corporation and Park Place Polo Fields Corporation's Motion to Dismiss the Second Amended Complaint on or before October 20, 2021. Signed by Judge Aileen M. Cannon on September 24, 2021. (ahz)
September 24, 2021 Opinion or Order Filing 177 PAPERLESS ORDER granting #173 Counter-Claim and Third-Party Plaintiffs' Unopposed Motion for Enlargement of Time to File Response in Opposition to Motion to Dismiss Counterclaim. Counter-Claim and Third-Party Plaintiffs shall file their Response in Opposition to the Motion to Dismiss Counterclaim on or before October 11, 2021. Signed by Judge Aileen M. Cannon on September 24, 2021. (ahz)
September 24, 2021 Opinion or Order Filing 176 PAPERLESS ORDER DENYING #170 Plaintiffs' Motion to File Sur-Reply to Defendants' Motion to Dismiss Second Amended Complaint; and striking #171 Plaintiffs' Sur-Reply to Defendants' Motion to Dismiss Second Amended Complaint. Parties may not file a document that requires prior Court approval without first obtaining leave of Court. They may attach the proposed document as an attachment to any motion seeking leave, but the proposed document may not be filed as an independent docket entry without prior Court approval. Signed by Judge Aileen M. Cannon on September 24, 2021. (ahz)
September 23, 2021 Filing 175 RESPONSE in Opposition re #170 Plaintiff's MOTION For Leave to File Sur-Reply re #158 Reply to Response to Motion, to Dismiss Second Amended Complaint MOTION for Leave to File filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 9/30/2021. (O'Quinn, Ryan)
September 22, 2021 Filing 174 Unopposed MOTION for Extension of Time to file a Response to the Park Place Polo Defendants' Motion to Dismiss Plaintiffs' Second Amended Complaint re #168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 10/6/2021 (Chapman, Avery)
September 22, 2021 Filing 173 Unopposed MOTION for Extension of Time to Respond to the Crestview Defendants' Motion to Dismiss Counterclaim re #167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Responses due by 10/6/2021 (Chapman, Avery)
September 21, 2021 Opinion or Order Filing 172 PAPERLESS ORDER granting in part and denying in part #162 Plaintiffs' Motion for Leave to File Overlength Renewed Motion for Preliminary Injunction; striking #163 Plaintiffs' Renewed Motion for Preliminary Injunction; and denying without prejudice #164 Plaintiffs' Motion for Leave to File Under Seal Confidential Exhibits due to lack of conferral. Plaintiffs are permitted to file a Renewed Motion for Preliminary Injunctive Relief that does not exceed thirty (30) pages (double spaced and fully justified). Accordingly, Plaintiffs' overlength Renewed Motion for Preliminary Injunction #163 is STRICKEN from the Court record. Any future motion to seal must specify compelling reasons overcoming the presumption of openness in judicial proceedings and explain why redaction of any sensitive information is not an appropriate alternative to sealing. Furthermore, that one party chooses to label a document protected pursuant to a Protective Order #88 is not alone a reason to shield a document from public view. Signed by Judge Aileen M. Cannon on September 21, 2021. (ahz)
September 21, 2021 Filing 171 STRICKEN SUR REPLY to Response to Motion re #170 Plaintiff's MOTION For Leave to File Sur-Reply re #158 Reply to Response to Motion, to Dismiss Second Amended Complaint MOTION for Leave to File filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery) Modified text on 9/24/2021 (mno). SEE (176)
September 21, 2021 Filing 170 Plaintiff's MOTION For Leave to File Sur-Reply re #158 Reply to Response to Motion, to Dismiss Second Amended Complaint, MOTION for Leave to File by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
September 21, 2021 Filing 169 RESPONSE in Opposition re #162 Plaintiff's MOTION for Leave to File an Overlength Renewed Expedited Motion for Issuance of a Preliminary Injunction filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 9/28/2021. (O'Quinn, Ryan)
September 21, 2021 Filing 168 Defendant's MOTION to Dismiss #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with Incorporated Memorandum of Law by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Responses due by 10/5/2021 (Chaskes, Robert)
September 20, 2021 Filing 167 MOTION TO DISMISS #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, FOR FAILURE TO STATE A CLAIM by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 10/4/2021 (O'Quinn, Ryan)
September 17, 2021 Filing 166 Plaintiff's REPLY to Response to Motion re #164 Plaintiff's MOTION for Leave to File Under Seal Confidential Exhibits to Plaintiffs Renewed Expedited Motion for Issuance of a Preliminary Injunction filed by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. (Chapman, Avery)
September 17, 2021 Filing 165 RESPONSE in Opposition re #162 Plaintiff's MOTION for Leave to File an Overlength Renewed Expedited Motion for Issuance of a Preliminary Injunction filed by Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Attorney Noelle Page Pankey added to party Park Place Polo Team Corporation(pty:dft). Replies due by 9/24/2021. (Pankey, Noelle)
September 17, 2021 Filing 164 Plaintiff's MOTION for Leave to File Under Seal Confidential Exhibits to Plaintiffs Renewed Expedited Motion for Issuance of a Preliminary Injunction by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
September 17, 2021 Filing 163 **STRICKEN**Plaintiff's EXPEDITED MOTION For Issuance of a Preliminary Injunction re #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1. Transcript of January 29, 2021 Hearing, #2 Exhibit 2. Composite of Secret Cloning Agreement, Amendment, and Second Amendment thereto, #3 Exhibit 3. Sworn Statements by Meeker Know Known to be False, #4 Exhibit 4. Operating Agreement of Crestview Genetics, LLC, #5 Exhibit 5. December 31, 2017 Assignment of all Ownership Interest in Genetics to Farm, #6 Exhibit 6. Email re No Cuartetera Clone Embryo Sale, #7 Exhibit 7. Crestview Genetics, LLC Articles of Organization, #8 Exhibit 8. October 8, 2020 Email re Drafting Secret Cloning Agreement, #9 Exhibit 9. Technical Consulting and Services Agreement, #10 Exhibit 10. Viagen Equine Cloning Contract, #11 Exhibit 11. March 23, 2011 Email re Quota Holder Agreement, #12 Exhibit 12. September 18, 2020 Email from Mr. Juan Carlo Di Caro, #13 Exhibit 13. June 11, 2020 Email from Mr. Di Caro, #14 Exhibit 14. March 11, 2020 Email from Mr. Meeker Showing Known Disagreement over Interpretations of Agreements, #15 Exhibit 15. September 18, 2009 Letter from Viagen re Viable Cuartetera Cells, #16 Exhibit 16. Park Place Polo Manager Voice Mail Transcript, #17 Exhibit 17. Park Place Polo Manager Writes of Concealing Cuartetera Clone Whereabouts, #18 Exhibit 18. 2009 Horse Cloning Contract, #19 Exhibit 19. 2011 Quota-Holders Agreement, #20 Exhibit 20. Affidavit of Julio Ernesto Gutierrez Conte, #21 Exhibit 21. Media Reports, #22 Exhibit 22. 2019 Side Letter Agreement, #23 Exhibit 23. Affidavit of Camila Castagnola, #24 Exhibit 24. Affidavit of Bartolome Castagnola, #25 Exhibit 25. Affidavit of Mr. Astrada, #26 Exhibit 26. Affidavit of Santiago Ballester President of the Argentine Association of Polo Pony Breeders, #27 Exhibit 27. Clone Injured, Receives Over 1 Month Emergency Care, #28 Exhibit 28. Another Clone Injured, #29 Exhibit 29. Second Affidavit of Roberto Zedda, #30 Exhibit 30. Non-Disclosure Agreement with Park Place Polo, #31 Exhibit 31. Affidavit of Roberto Zedda, #32 Exhibit 32. Very Large December 2020 Payment from Crestview Defendants to ViaGen, #33 Exhibit 33. Composite Exhibit of Park Place Polo Florida Corporate Records, #34 Exhibit 34. November 2019 Email Crestview Defendants State Cuarteteras Produced per 2019 Side Letter Agreement, #35 Exhibit 35. Email Demonstrating Crestview Entities are Alter-Egos of Mr. Meeker)(Chapman, Avery) Text Modified on 9/23/2021 per DE 172 ORDER (ail).
September 17, 2021 Filing 162 Plaintiff's MOTION for Leave to File an Overlength Renewed Expedited Motion for Issuance of a Preliminary Injunction by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
September 17, 2021 Opinion or Order Filing 161 PAPERLESS ORDER granting in part and denying in part #159 Defendants' Motion for Extension of Time to Produce Documents. Defendants shall have until September 24, 2021 to complete the production of documents responsive to Plaintiffs' discovery requests and to provide a privilege log. Signed by Magistrate Judge Bruce E. Reinhart on 9/17/2021. (jgy)
September 16, 2021 Filing 160 RESPONSE in Opposition re #159 Defendant's MOTION for Extension of Time to Produce Documents re #114 Order and re 141 Paperless Order granting Defendants First Motion for Enlargement of Time to Produce filed by Adolfo Cambiaso, La Dolfina S.A. LLC. Replies due by 9/23/2021. (Chapman, Avery)
September 15, 2021 Filing 159 Defendant's MOTION for Extension of Time to Produce Documents re #114 Order by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 9/29/2021 (O'Quinn, Ryan)
September 15, 2021 Filing 158 REPLY to Response to Motion re #144 MOTION TO DISMISS #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (O'Quinn, Ryan)
September 13, 2021 Set/Reset Answer Due Deadline: Park Place Polo Fields Corporation response due 10/1/2021; Park Place Polo Team Corporation response due 10/1/2021. SEE DE 157 ORDER (ail)
September 12, 2021 Opinion or Order Filing 157 PAPERLESS ORDER granting #155 Defendants Park Place Polo Team Corporation and Park Place Polo Fields Corporation's Motion for Enlargement of Time to Respond to Complaint. Defendants Park Place Polo Team Corporation and Park Place Polo Fields Corporation shall file a combined response or separate answers to the Second Amended Complaint on or before October 1, 2021. Signed by Judge Aileen M. Cannon September 12, 2021. (ahz)
September 9, 2021 Filing 156 Plaintiff's RESPONSE to Park Place Polo Defendants Motion to Enlarge Time, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
September 9, 2021 Filing 155 Defendant's MOTION for Extension of Time to File Response/Reply/Answer as to #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, DEFENDANTS PARK PLACE POLO TEAM CORPORATION AND PARK PLACE POLO FIELDS CORPORATIONS MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO THE SECOND AMENDED COMPLAINT AND TO SERVE INITIAL DISCLOSURES by Park Place Polo Fields Corporation. (Attachments: #1 Text of Proposed Order Proposed Order)(Pankey, Noelle)
September 9, 2021 Filing 154 NOTICE of Attorney Appearance by Noelle Page Pankey on behalf of Park Place Polo Fields Corporation. Attorney Noelle Page Pankey added to party Park Place Polo Fields Corporation(pty:dft). (Pankey, Noelle)
September 9, 2021 Filing 153 NOTICE of Attorney Appearance by Robert Iddings Chaskes on behalf of Park Place Polo Fields Corporation, Park Place Polo Team Corporation. Attorney Robert Iddings Chaskes added to party Park Place Polo Fields Corporation(pty:dft), Attorney Robert Iddings Chaskes added to party Park Place Polo Team Corporation(pty:dft). (Chaskes, Robert)
September 8, 2021 Filing 152 RESPONSE in Opposition re #144 MOTION TO DISMISS #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, FOR FAILURE TO STATE A CLAIM filed by Adolfo Cambiaso, La Dolfina S.A. LLC. Replies due by 9/15/2021. (Chapman, Avery)
September 2, 2021 Opinion or Order Filing 151 PAPERLESS ORDER granting #149 Plaintiffs' Unopposed Motion to Enlarge Page Limitation. Plaintiffs shall file a Response in Opposition to Defendants' Motion to Dismiss not to exceed thirty-five (35) pages, double-spaced, in 12-point Times New Roman font. Signed by Judge Aileen M. Cannon on September 2, 2021. (ahz)
September 2, 2021 Opinion or Order Filing 150 PAPERLESS ORDER granting #148 Counterclaim Defendant and Third-Party Defendants' Unopposed Motion for Enlargement of Time to Respond to Counterclaim and Third-Party Complaint. Counterclaim Defendant and Third-Party Defendants shall file an answer or responsive motion to the Counterclaim and Third-Party Complaint on or before September 20, 2021. Signed by Judge Aileen M. Cannon on September 2, 2021. (ahz)
September 2, 2021 Filing 149 Unopposed MOTION for Leave to File Excess Pages to Enlarge Page Limitation by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
September 2, 2021 Filing 148 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #134 Counterclaim,,,,,,,, Third Party Complaint,,,,,,, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Exhibit Exhibit A)(O'Quinn, Ryan)
September 1, 2021 Filing 147 SUMMONS (Affidavit) Returned Executed on #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Adolfo Cambiaso, La Dolfina S.A. LLC. Park Place Polo Fields Corporation served on 8/23/2021, answer due 9/13/2021. (Chapman, Avery) Modified to QC on 9/1/2021 (amb).
September 1, 2021 Filing 146 SUMMONS (Affidavit) Returned Executed on #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Adolfo Cambiaso, La Dolfina S.A. LLC. Park Place Polo Team Corporation served on 8/23/2021, answer due 9/13/2021. (Chapman, Avery)
August 30, 2021 Opinion or Order Filing 145 ORDER Scheduling Mediation before David Lichter. Mediation Hearing set for 5/16/2022 10:00 AM. Signed by Judge Aileen M. Cannon on 8/30/2021. See attached document for full details. (jas)
August 25, 2021 Filing 144 MOTION TO DISMISS #122 Amended Complaint/Amended Notice of Removal,,,,,,,,, FOR FAILURE TO STATE A CLAIM by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 9/8/2021 (O'Quinn, Ryan)
August 24, 2021 Opinion or Order Filing 143 PAPERLESS ORDER granting in part and denying in part Plaintiffs' #136 Motion to Amend Scheduling Order. The parties shall file all motions to amend pleadings or to join parties on or before October 8, 2021. Signed by Judge Aileen M. Cannon on 8/24/2021. (ad00)
August 24, 2021 Opinion or Order Filing 142 PAPERLESS ORDER granting #139 Defendants' Unopposed Motion to Enlarge Page Limitation. Defendants shall file a response to the Second Amended Complaint not to exceed 35 pages, double-spaced, in 12-point Times New Roman font. Signed by Judge Aileen M. Cannon on 8/24/2021. (jrt)
August 23, 2021 Opinion or Order Filing 141 PAPERLESS ORDER GRANTING #130 Defendants' Motion for Extension of Time to Produce Documents. Having reviewed Defendants' Motion and Plaintiffs' Response (DE #138 ), the Court finds that Defendants' Motion, in accordance with Section II(E) of the Court's Standing Discovery Order (DE #114 ) includes a good cause explanation for why production cannot be completed by the deadline and an extension should be granted. Thus, Defendants shall have until September 17, 2021 to produce any documents responsive to the Plaintiffs' discovery requests and to provide a privilege log. Signed by Magistrate Judge Bruce E. Reinhart on 8/23/2021. (jgy)
August 23, 2021 Filing 140 NOTICE by La Dolfina S.A., La Dolfina S.A. LLC re 135 Order, 126 Order on Emergency Motion with Certification of Emergency,,,, Reflecting Agreement of the Parties (Attachments: #1 Exhibit Agreed redactions) (Chapman, Avery)
August 23, 2021 Filing 139 Unopposed MOTION for Leave to File Excess Pages to Enlarge Page Limitation by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
August 23, 2021 Filing 138 RESPONSE in Opposition re #130 MOTION for Extension of Time to Produce Documents Expedited Response filed by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Replies due by 8/30/2021. (Attachments: #1 Exhibit (Responses and Objections by Defendants))(Chapman, Avery)
August 23, 2021 Filing 137 NOTICE by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC and by D. Alan Meeker, Crestview Genetics, LLC and Crestview Farm, LLC, selecting Mediator and setting Mediation (JOINT NOTICE OF ALL PARTIES) for all consolidated cases Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC (Chapman, Avery)
August 20, 2021 Filing 136 Plaintiff's EXPEDITED MOTION to Amend Scheduling Order as to August 30, 2021 Deadline to Amend Pleadings/Add New Parties in Both Consolidated Cases re (111 in 9:20-cv-82231-AMC) Scheduling Order,,, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina S.A. LLC. Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(Chapman, Avery)
August 20, 2021 Set/Reset Deadline as to #130 MOTION for Extension of Time to Produce Documents . Responses due by 8/23/2021.SEE DE 135 ORDER (ail)
August 19, 2021 Opinion or Order Filing 135 PAPERLESS ORDER requiring Plaintiffs to file EXPEDITED Response to #130 Defendants' Motion for Extension of Time to Produce Documents. Plaintiffs shall file a Response by no later than Monday, August 23rd, 2021 at 5:00 PM. Signed by Magistrate Judge Bruce E. Reinhart on 8/19/2021. (jgy)
August 18, 2021 Filing 134 COUNTERCLAIM against Crestview Farm LLC, THIRD PARTY COMPLAINT against D. Alan Meeker, Crestview Genetics LLC, filed by Adolfo Cambiaso, La Dolfina S.A. LLC, La Dolfina S.A.. (Attachments: #1 Exhibit 1. Crestview Genetics Operating Agreement, #2 Exhibit 2. Purchase and Sale Agreement Crestview Genetics, #3 Exhibit 3. Assignment of Interest Crestview Genetics, #4 Exhibit 4. 2009 Horse Cloning Contract, #5 Exhibit 5. 2011 Quota-Holders Agreement, #6 Exhibit 6. 2019 Settlement Agreement, #7 Exhibit 7. 2019 Side Letter Agreement, #8 Exhibit 8. Description of Secret Cloning Agreement, #9 Exhibit 9. Amendment to Secret Cloning Agreement, #10 Exhibit 10. 2nd amendment to Secret Cloning Agreement, #11 Exhibit 11. Affidavit of Robert P. Jornayvaz III, #12 Exhibit 12. Affidavit of Roberto Zedda, #13 Exhibit 13. Second Affidavit of Roberto Zedda, #14 Exhibit 14. Certificate of Interested Persons filed by Crestview Genetics in May 2016, #15 Exhibit 15. November 18, 2020 Correspondence, #16 Exhibit 16. Andrey Borodin's Park Place Polo Removes the 3 Clones from this Jurisdiction in the Midst of Litigation, #17 Exhibit 17. Affidavit of Craig T. Bernard, #18 Exhibit 18. Affidavit of Bartolome Castagnola, #19 Exhibit 19. Affidavit of Camila Castagnola, #20 Exhibit 20. Affidavit of Santiago Ballester President of the Argentine Association of Polo Pony Breeders, #21 Exhibit 21. Additional Media Statements by Meeker - No Sales of Clones, #22 Exhibit 22. 4th Affidavit of Roberto Zedda, #23 Exhibit 23. Sworn Statements of Meeker now known to be false, #24 Exhibit 24. Inconsistencies of Crestview, #25 Exhibit 25. Certified transcript of voicemessage from Ash Price to J. Arellano)(Chapman, Avery)
August 18, 2021 Filing 133 ANSWER and Affirmative Defenses to Complaint with Jury Demand by La Dolfina S.A.. Attorney Avery Spencer Chapman added to party La Dolfina S.A.(pty:dft). (Chapman, Avery)
August 18, 2021 Filing 132 ANSWER and Affirmative Defenses to Complaint with Jury Demand by La Dolfina S.A. LLC. (Chapman, Avery)
August 18, 2021 Filing 131 ANSWER and Affirmative Defenses to Complaint with Jury Demand by Adolfo Cambiaso. Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(Chapman, Avery)
August 18, 2021 Filing 130 MOTION for Extension of Time to Produce Documents by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 9/1/2021 (Attachments: #1 Text of Proposed Order Proposed Order)Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(O'Quinn, Ryan)
August 16, 2021 Filing 129 Summons Issued as to Park Place Polo Fields Corporation, Park Place Polo Team Corporation. (Attachments: #1 Summons)(ail)
August 15, 2021 Opinion or Order Filing 128 PAPERLESS ORDER denying as moot #87 Defendants' Refiled Motion to Dismiss in light of #122 Plaintiffs' Second Amended Complaint. Signed by Judge Aileen M. Cannon on August 15, 2021. (ahz)
August 15, 2021 Opinion or Order Filing 127 PAPERLESS ORDER denying #125 Defendants' Motion for Stay of Discovery. The Court does not see a basis to stay discovery in this action. The parties shall follow Judge Reinhart's discovery procedures. Signed by Judge Aileen M. Cannon on August 15, 2021. (ahz)
August 15, 2021 Opinion or Order Filing 126 PAPERLESS ORDER granting in part and denying in part #124 Defendants' Emergency Motion for Contempt and for Sanctions and to Enforce Agreed Protective Order. Defendants' Motion is DENIED to the extent it seeks an order of contempt against Plaintiffs and an order striking Plaintiffs' Second Amended Complaint. Defendants' Motion is GRANTED to the extent it seeks an order striking Exhibits 5, 6, and 7 [122-5], [122-6], [122-7], from the Second Amended Complaint #122 . The Clerk is directed to strike those exhibits from the docket. On or before August 23, 2021, Plaintiffs are directed to confer with Defendants with respect to Exhibits 5, 6 and 7. Following such conferral, Plaintiffs shall file a notice with the Court explaining the need, if any, to attach such exhibits to their Second Amended Complaint, and explaining what redactions may be warranted to comply with Federal Rule of Civil Procedure 5.2. See Fed. R. Civ. P. 5.2. Signed by Judge Aileen M. Cannon on August 15, 2021. (ahz)
August 13, 2021 Filing 125 MOTION to Stay of Discovery and Supporting Memorandum of Law by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 8/27/2021 (Attachments: #1 Text of Proposed Order Proposed Order)Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(O'Quinn, Ryan)
August 12, 2021 Filing 124 EMERGENCY MOTION with Certification of Emergency included for Contempt and for Sanctions and to Enforce Agreed Protective Order by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 8/26/2021 (Attachments: #1 Exhibit Exhibit A, #2 Text of Proposed Order Proposed Order)Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(O'Quinn, Ryan)
August 12, 2021 Opinion or Order Filing 123 PAPERLESS ORDER GRANTING #116 Defendants Adolfo Cambiaso, La Dolfina S.A., and La Dolfina S.A., LLC's Unopposed Motion for Enlargement of Time to file Responsive Pleading. The Defendants specified in this Order shall file a combined response or separate answers to Plaintiff's Amended Complaint on or before August 18, 2021. Signed by Judge Aileen M. Cannon on August 12, 2021. (ahz)
August 12, 2021 Set/Reset Answer Due Deadline: Adolfo Cambiaso response due 8/18/2021; La Dolfina S.A. LLC response due 8/18/2021. SEE DE 123 ORDER (ail)
August 11, 2021 Filing 122 Second AMENDED COMPLAINT against Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker, Park Place Polo Team Corporation, Park Place Polo Fields Corporation filed in response to Order Granting Motion for Leave, filed by La Dolfina S.A. LLC, Adolfo Cambiaso. (Attachments: #1 Exhibit 1. 2009 Horse Cloning Contract, #2 Exhibit 2. 2011 Quota-Holders Agreement, #3 Exhibit 3. 2019 Settlement Agreement, #4 Exhibit 4. 2019 Side Letter Agreement, #5**STRICKEN** Exhibit 5. Secret Cloning Agreement, #6**STRICKEN** Exhibit 6. Amendment to the Secret Cloning Agreement, #7 **STRICKEN**Exhibit 7. Second Amendment to the Secret Clone Sale Agreement, #8 Exhibit 8. Affidavit of Robert P. Jornayvaz III, #9 Exhibit 9. Akerman LLP Representation of Daren Tamplin, DVM, #10 Exhibit 10. Affidavit of Roberto Zedda, #11 Exhibit 11. Second Affidavit of Roberto Zedda, #12 Exhibit 12. Email demonstrating Crestview entities are merely alter-egos of Mr. Meeker, #13 Exhibit 13. Certificate of Interested Persons filed by Crestview Genetics in May 2016, #14 Exhibit 14. Affidavit of Julio Ernesto Gutierrez Conte, #15 Exhibit 15. Genetics Answer to Overbrook Farm Counterclaim, #16 Exhibit 16. Storm Cat Settlement Agreement, #17 Exhibit 17. November 18, 2020 Correspondence, #18 Exhibit 18. Composite Exhibit 18, Andrey Borodin's Park Place Polo Team Purchased the Clones, #19 Exhibit 19. Andrey Borodin's Park Place Polo Removes the 3 Clones from this Jurisdiction in the Midst of Litigation, #20 Exhibit 20. Affidavit of Craig T. Bernard, #21 Exhibit 21. Affidavit of Bartolome Castagnola, #22 Exhibit 22. Affidavit of Camila Castagnola, #23 Exhibit 23. Affidavit of Santiago Ballester, #24 Exhibit 24. March 13, 2020 Email from Meeker re Cuartetera, #25 Exhibit 25. Vanity Fair Article, #26 Exhibit 26. 60 Minutes Article, #27 Exhibit 27. Additional Media Statements by Meeker - No Sales of Clones, #28 Exhibit 28. Fourth Affidavit of Roberto Zedda, #29 Exhibit 29. Inconsistencies of Crestview Defendants Legal Team Averments, #30 Exhibit 30. Sworn Statements by Meeker Know Known to be False, #31 Summon(s) Park Place Polo Fields Corporation, #32 Summon(s) Park Place Polo Team Corporation)(Chapman, Avery)Text Modified on 8/16/2021 per DE 126 ORDER(ail).
August 11, 2021 Opinion or Order Filing 121 PAPERLESS ORDER granting #117 Plaintiffs' Opposed Motion for Leave to File Second Amended Complaint and denying #118 Plaintiffs' Opposed Motion for Leave to file Under Seal Confidential Document Exhibits to Proposed Second Amended Complaint. Plaintiffs shall file their proposed Second Amended Complaint [117-1] as an independent docket entry on or before August 13, 2021. No sealing of documents is permitted. Plaintiffs' Proposed Exhibits 5, 6, and 7 to the Second Amended Complaint filed under seal 119 are STRICKEN from the Court record. Signed by Judge Aileen M. Cannon on August 11, 2021. (ahz)
August 9, 2021 Filing 120 Clerks Notice to Filer re 119 Sealed Document. Document Not Captioned; In the future the Filer must File a Notice of Filing with the attached Exhibit, with the proper caption pursuant to Local Rules. It is not necessary to refile this document. (nc)
August 7, 2021 Filing 118 Plaintiff's MOTION for Leave to File Under Seal Confidential Document Exhibits to Plaintiffs Proposed Second Amended Complaint by Adolfo Cambiaso, La Dolfina S.A. LLC. Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(Chapman, Avery)
August 7, 2021 Filing 117 Plaintiff's MOTION for Leave to File Second Amended Complaint by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit Exhibit A - Plaintiffs' Proposed Second Amended Complaint)Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(Chapman, Avery)
August 7, 2021 SYSTEM ENTRY - Docket Entry 119 [misc] restricted/sealed until further notice. (1038418)
August 6, 2021 Filing 116 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to (90 in 9:21-cv-81066-AMC) Order on Motion for Miscellaneous Relief, (7 in 9:21-cv-81066-AMC) Amended Complaint/Amended Notice of Removal,, by Adolfo Cambiaso, La Dolfina S.A., La Dolfina, S.A., LLC. Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC(de la Gueronniere, Grace)
August 2, 2021 Opinion or Order Filing 115 ORDER CONSOLIDATING CASES: The Clerk of the Court is instructed to CLOSE Case No. 21-81066-CIV-CANNON for administrative purposes only. All future pre-trial filings in this case shall be made under Case No. 20-82231-CIV-CANNON/Reinhart only. Signed by Judge Aileen M. Cannon on 8/2/2021. See attached document for full details. Associated Cases: 9:20-cv-82231-AMC, 9:21-cv-81066-AMC (scn)
July 26, 2021 Opinion or Order Filing 114 STANDING DISCOVERY ORDER for Magistrate Judge Bruce Reinhart. Signed by Magistrate Judge Bruce E. Reinhart on 7/26/2021. See attached document for full details. (ls)
July 26, 2021 Opinion or Order Filing 113 ORDER Setting Discovery Status Conference. ( Status Conference Re: Discovery Matters set for 4/14/2022 01:00 PM in West Palm Beach Division before Magistrate Judge Bruce E. Reinhart.) Signed by Magistrate Judge Bruce E. Reinhart on 7/26/2021. See attached document for full details. (ls)
July 23, 2021 Filing 112 CASE REFERRED to Magistrate Judge Bruce E. Reinhart per DE #111 . (vjk)
July 23, 2021 Opinion or Order Filing 111 ORDER SETTING TRIAL, SETTING PRE-TRIAL DEADLINES, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: Jury Trial set for 10/11/2022 09:00 AM in Fort Pierce Division before Judge Aileen M. Cannon. Calendar Call set for 10/4/2022 01:45 PM in Fort Pierce Division before Judge Aileen M. Cannon. Amended Pleadings due by 8/30/2021. Discovery due by 5/20/2022. Expert Discovery due by 5/20/2022. Joinder of Parties due by 8/30/2021. Mediation Deadline 6/17/2022. In Limine Motions due by 9/2/2022. Dispositive Motions due by 6/24/2022. Motions due by 6/24/2022. Pretrial Stipulation due by 9/2/2022. Signed by Judge Aileen M. Cannon on 7/23/2021. See attached document for full details. (tgs) #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.
July 15, 2021 Opinion or Order Filing 110 PAPERLESS ORDER granting #108 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Molly Kokesh. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsel's pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on July 15, 2021. (ahz)
July 14, 2021 Filing 109 Joint SCHEDULING REPORT - Rule 16.1 by Adolfo Cambiaso, La Dolfina S.A. LLC (Attachments: #1 Text of Proposed Order)(de la Gueronniere, Grace)
July 14, 2021 Filing 108 Plaintiff's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Molly Kokesh. Filing Fee $ 200.00 Receipt # AFLSDC-14845732 by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 7/28/2021 (Attachments: #1 Text of Proposed Order, #2 Certification)(de la Gueronniere, Grace)
July 9, 2021 Filing 107 CLERK'S NOTICE - Attorney Admissions has updated the email for PHV attorney Jason S. Lewis re #106 Notice for PHV Attorney to Receive Electronic Notification. (pt)
July 9, 2021 Filing 106 Notice to the Court for Pro Hac Vice Attorney to Receive Electronic Notification by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker (O'Quinn, Ryan)
July 8, 2021 Opinion or Order Filing 105 PAPERLESS ORDER STRIKING #95 Plaintiffs' Scheduling Report; #96 Defendants' Initial Scheduling Report; and #99 Defendants' Corrected Scheduling Report. Pursuant to the Court's Omnibus Order #81 , the parties are required to file a scheduling report jointly. Accordingly, the parties are directed to prepare and file a joint scheduling report, as required by Local Rule 16.1, by no later than July 16, 2021. Signed by Judge Aileen M. Cannon on July 8, 2021. (ahz)
July 8, 2021 Opinion or Order Filing 104 PAPERLESS ORDER denying #94 Plaintiffs' Opposed Motion for Leave to file Under Seal Motion to Amend First Amended Complaint. Under Local Rule 5.4(b)(1), a party seeking to file a document under seal must set forth the factual and legal basis for departing from the default premise of public access, and it must do so with as much particularity as possible. See S.D. Fla. L.R. 5.4(b)(1). Plaintiffs' Motion does not satisfy that standard. Further, the Court will seal only such limited information that truly warrants shielding from public view. If Plaintiffs wish to file a motion to amend the operative pleading, they must do so publicly. Signed by Judge Aileen M. Cannon on July 8, 2021. (ahz)
July 7, 2021 Filing 103 Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Adolfo Cambiaso, La Dolfina S.A. LLC identifying Corporate Parent La Dolfina S.A. for La Dolfina S.A. LLC (de la Gueronniere, Grace)
July 7, 2021 Opinion or Order Filing 102 PAPERLESS ORDER granting #100 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney James C. Bookhout; and granting #101 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Jason S. Lewis. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsels' pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on July 7, 2021. (ahz)
July 6, 2021 Filing 101 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jason S. Lewis. Filing Fee $ 200.00 Receipt # AFLSDC-14821987 by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 7/20/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(O'Quinn, Ryan)
July 6, 2021 Filing 100 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for James C. Bookhout. Filing Fee $ 200.00 Receipt # AFLSDC-14821762 by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 7/20/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(O'Quinn, Ryan)
July 2, 2021 Filing 99 Corrected SCHEDULING REPORT - Rule 26(f) by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
July 2, 2021 Filing 98 NOTICE by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker re #96 SCHEDULING REPORT - Rule 26(f)/16.1 of Withdrawal of Joint Scheduling and Conference Report (O'Quinn, Ryan)
July 2, 2021 Filing 97 Certificate of Other Affiliates/Corporate Disclosure Statement Certificate of Interested Persons by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker identifying Other Affiliate The David Alan Meeker Family Irrevocable Trust for Crestview Farm LLC (O'Quinn, Ryan)
July 2, 2021 Filing 96 Joint SCHEDULING REPORT - Rule 26(f) by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
July 2, 2021 Filing 95 **STRICKEN**Plaintiff's SCHEDULING REPORT - Rule 26(f) by Adolfo Cambiaso, La Dolfina S.A. LLC (Attachments: #1 Text of Proposed Order)(Chapman, Avery) Text Modified on 7/9/2021 per 105 ORDER (ail).
June 29, 2021 Filing 94 Plaintiff's MOTION for Leave to File Under Seal Plaintiffs' Motion to Amend Complaint with Document Exhibits by La Dolfina S.A. LLC. (Chapman, Avery)
June 25, 2021 Opinion or Order Filing 93 PAPERLESS ORDER granting #90 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney William N. Warren; and granting #91 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Caitlyn E. Hubbard. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsels' pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on June 25, 2021. (ahz)
June 24, 2021 Filing 92 NOTICE of Change of Address, Email or Law Firm Name by Gary A. Woodfield (Woodfield, Gary)
June 24, 2021 Filing 91 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Caitlyn E. Hubbard. Filing Fee $ 200.00 Receipt # AFLSDC-14793624 by Crestview Farm LLC, D. Alan Meeker. Responses due by 7/8/2021 (Attachments: #1 Text of Proposed Order)(Woodfield, Gary)
June 24, 2021 Filing 90 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for William N. Warren. Filing Fee $ 200.00 Receipt # AFLSDC-14793591 by Crestview Farm LLC, D. Alan Meeker. Responses due by 7/8/2021 (Attachments: #1 Text of Proposed Order)(Woodfield, Gary)
June 22, 2021 Opinion or Order Filing 89 PAPERLESS ORDER: In light of #87 Defendants' Refiled Motion to Dismiss Plaintiffs' First Amended Complaint, #37 Defendants' Motion to Dismiss Plaintiffs' First Amended Complaint is DENIED AS MOOT. Defendants' challenge to personal jurisdiction is noted as stated in the Court's Omnibus Order #81 and Order Following Status Conference #85 . Signed by Judge Aileen M. Cannon on June 22, 2021. (ahz)
June 22, 2021 Opinion or Order Filing 88 ORDER GRANTING JOINT MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER. Granting #86 Motion for Protective Order. Signed by Judge Aileen M. Cannon on 6/22/2021. See attached document for full details. (ail)
June 18, 2021 Filing 87 MOTION TO DISMISS #81 Order on Expedited Motion,,,,,,,, Order on Motion to Expedite,,,,,,,, Order on Motion to Strike,,,,,,,,,,,,,,,, Order on Motion for Miscellaneous Relief,,,,,,,, Order on Motion for Sanctions,,,,,,,, Order on Motion for Leave to File,,,,,,,,,,,,,,,,,,,,,,, #85 Order, #22 Amended Complaint/Amended Notice of Removal,, FOR FAILURE TO STATE A CLAIM Refiled Motion to Dismiss Plaintiff's First Amended Complaint by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 7/2/2021 (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C)(O'Quinn, Ryan)
June 18, 2021 Filing 86 Joint MOTION for Protective Order AGREED by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Text of Proposed Order Agreed Protective Order)(Woodfield, Gary)
June 17, 2021 Opinion or Order Filing 85 ORDER FOLLOWING STATUS CONFERENCE re 82 Status Conference. Signed by Judge Aileen M. Cannon on 6/16/2021. See attached document for full details. (ail)
June 16, 2021 Opinion or Order Filing 84 PAPERLESS ORDER STRIKING #83 Notice of Unavailability by attorney Avery Chapman. Notices of unavailability are not proper filings in federal court. If there is a scheduling conflict, counsel must confer with opposing counsel and submit a motion for a continuance that sets forth good cause for the enlargement sought. Signed by Judge Aileen M. Cannon on June 16, 2021. (ahz)
June 16, 2021 Filing 83 **STRICKEN** NOTICE OF UNAVAILABILITY by Adolfo Cambiaso, La Dolfina S.A. LLC for dates of July 6-9, 2021; July 12-24, 2021; August 6, 2021; August 11-16, 2021; September 23- 27, 2021; October 20, 2021; October 25- November 5, 2021; November 24 - 26, 2021; December 6 17, 2021; February 24, 2022 March 21, 2022; May 4, 2022- May 13, 2022; and July 21, 2022 August 3, 2022. (Chapman, Avery) Text Modified on 6/17/2021 per DE 84 ORDER (ail).
June 16, 2021 Filing 82 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Status Conference Hearing held on June 16, 2021. The Court discussed the Court's Omnibus Order #81 and the initiation of discovery and possible consolidation of the case with a related case transferred from the Northern District of Texas (21-81066-CIV-CANNON (S.D. Fla.)). Written Order to follow. Total time in court: 30 minutes. Attorney Appearance(s): Grace Rockefeller de la Gueronniere, Habib Nasrullah, Avery Spencer Chapman, Gary A. Woodfield, Ryan Dwight O'Quinn. Court Reporter: Tammy Nestor, 305-523-5148 / Tammy_Nestor@flsd.uscourts.gov. (ahz)
June 16, 2021 Opinion or Order Filing 81 OMNIBUS ORDER ON PENDING MOTIONS: denying #26 Plaintiffs' Expedited Motion for a Preliminary Injunction; denying #28 Plaintiffs' Renewed Expedited Motion for Expedited Discovery in Aid of Motion for Preliminary Injunction; denying #31 Plaintiff's Motion For Clarification and for Leave to Promulgate Expedited Discovery in Advance of Evidentiary Hearing for Preliminary Injunction; denying #58 Plaintiff's Motion to Expedite Inspection of Clones; denying #59 Defendant's Motion to Strike Plaintiff's Motion to Expedite Inspection of Clones and for Sanctions; denying without prejudice #61 Plaintiffs' Expedited Motion for Preservation, to be refiled at a later date if necessary; granting #66 Plaintiffs' Motion for Judicial Notice of Jurisdictional Facts; denying #72 73 Defendants' Motion for Sanctions; and granting Plaintiffs' Motion for Leave to File Related Filings #76 . This leaves for resolution Defendants' Motion to Dismiss for Lack of Personal Jurisdiction and for Failure to State a Claim [ECF No. 37]. The Court herein DENIES Defendants' Motion to Dismiss for Lack of Personal Jurisdiction but RESERVES RULING on Defendants' Motion to Dismiss for Failure to State a Claim. Defendants are directed to refile their Rule 12(b)(6) motion with no alterations on or before June 19, 2021. No additional briefing on Defendants' Motion to Dismiss will be permitted by either party. The parties are directed to submit a Joint Scheduling Report on or before 7/2/2021. Signed by Judge Aileen M. Cannon on 6/16/2021. Signed by Judge Aileen M. Cannon on 6/16/2021. See attached document for full details. (mr1) Modified on 6/16/2021 (tgs). (fixed errors) Modified on 6/16/2021 (tgs).
June 15, 2021 Filing 80 Notice of Pending, Refiled, Related or Similar Actions by Adolfo Cambiaso, La Dolfina S.A. LLC (Attachments: #1 Exhibit Order Transferring the Case to the Southern District of Florida, #2 Exhibit Matrix of Ripe Motions Before the SDFL Court) (Chapman, Avery)
June 11, 2021 Filing 79 REPLY to Response to Motion re #76 Plaintiff's MOTION for Leave to File Related Filings filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
June 7, 2021 Filing 78 RESPONSE to Motion re #76 Plaintiff's MOTION for Leave to File Related Filings filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 6/14/2021. (O'Quinn, Ryan)
May 28, 2021 Filing 77 PAPERLESS NOTICE of Hearing: Status Conference set for 6/16/2021 11:00 AM in Fort Pierce Division before Judge Aileen M. Cannon via the Zoom platform. The Zoom link and information will be emailed to the parties of record. The parties are directed to sign into the hearing ten (10) minutes prior to the scheduled time. (tgs)
May 24, 2021 Filing 76 Plaintiff's MOTION for Leave to File Related Filings by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit [NDTX 20 DE 49] Motion to Reconsider Order Denying Motion to Transfer to SDFL, #2 Exhibit [NDTX 20 DE 50] Appendix in Support of Motion to Reconsider Transfer to SDFL)(Chapman, Avery)
May 7, 2021 Filing 75 Plaintiff's REPLY to #72 Response in Opposition to Motion, #66 Plaintiff's MOTION for Judicial Notice of Relevant Jurisdictional Facts re #55 Supplement,,,,,,, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1)(Chapman, Avery)
May 3, 2021 Filing 74 Clerks Notice to Filer re #72 Response in Opposition to Motion. Two or More Document Events Filed as One; ERROR - Only one event was selected by the Filer but more than one event was applicable to the document filed. The docket entry was corrected by the Clerk SEE 73 MOTION for Sanctions. It is not necessary to refile this document but in the future, the Filer must select all applicable events. (ail)
April 30, 2021 Filing 73 MOTION for Sanctions by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. SEE DE #72 IMAGE (ail)
April 30, 2021 Filing 72 RESPONSE in Opposition re #66 Plaintiff's MOTION for Judicial Notice of Relevant Jurisdictional Facts re #55 Supplement,,,,,,, and Defendants' Request for Sanctions filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 5/7/2021. (O'Quinn, Ryan)
April 20, 2021 Opinion or Order Filing 71 PAPERLESS ORDER DENYING #69 Defendants' Motion to Strike and for Sanctions as to #66 Plaintiffs' Motion for Judicial Notice. Federal Rule of Civil Procedure 12(f) provides that "[t]he court may strike from a pleading... any redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f). The submission that Defendants seek to strike is not a pleading. Signed by Judge Aileen M. Cannon on April 20, 2021. (ahz)
April 19, 2021 Filing 70 Plaintiff's RESPONSE to #69 MOTION to Strike #66 Plaintiff's MOTION for Judicial Notice of Relevant Jurisdictional Facts re #55 Supplement,,,,,,, and for Sanctions, 67 Notice of Pending, Refiled, Related or Similar Actions by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
April 19, 2021 Filing 69 MOTION to Strike #66 Plaintiff's MOTION for Judicial Notice of Relevant Jurisdictional Facts re #55 Supplement,,,,,,, and for Sanctions by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 5/3/2021 (Attachments: #1 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
April 16, 2021 Filing 68 Clerks Notice to Filer re #64 Notice (Other),. Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see 67 Notice of Pending, Refiled, Related or Similar Actions. It is not necessary to refile this document. (ail)
April 16, 2021 Filing 66 Plaintiff's MOTION for Judicial Notice of Relevant Jurisdictional Facts re #55 Supplement,,,,,,, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit Crestview Farm/Meeker Shipping Horses to and from Florida 2016 2020)(Chapman, Avery)
April 15, 2021 Filing 67 Notice of Pending, Refiled, Related or Similar Actions by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker SEE DE #64 IMAGE (ail)
April 15, 2021 Filing 65 Notice of Pending, Refiled, Related or Similar Actions by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
April 15, 2021 Filing 64 NOTICE by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker of Related or Similar Actions (Woodfield, Gary)
March 3, 2021 Filing 63 RESPONSE in Opposition re #59 Defendant's MOTION to Strike #58 Plaintiff's MOTION to Expedite Inspection of Clones and for Sanctions and Plaintiffs' Reply To Defendants Response [De 62] To Motion For Preservation of ESI Order [De 61] filed by Adolfo Cambiaso, La Dolfina S.A. LLC. Replies due by 3/10/2021. (Chapman, Avery)
February 26, 2021 Filing 62 RESPONSE to Motion re #61 Plaintiff's EXPEDITED MOTION For Preservation, Restoration and Holding of Relevant ESI re #22 Amended Complaint/Amended Notice of Removal,, filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 3/5/2021. (O'Quinn, Ryan)
February 24, 2021 Filing 61 Plaintiff's EXPEDITED MOTION For Preservation, Restoration and Holding of Relevant ESI re #22 Amended Complaint/Amended Notice of Removal,, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit Cover Email to Litigation Hold and Preserve Demand, #2 Exhibit Litigation Hold and Preserve Demand to Defendants, #3 Exhibit Fourth Affidavit of Roberto Zedda, #4 Exhibit Affidavit of Craig T. Bernard, #5 Exhibit Email String re ESI Preservation, #6 Text of Proposed Order Proposed Order)(Chapman, Avery)
February 19, 2021 Filing 60 NOTICE by Adolfo Cambiaso, La Dolfina S.A. LLC OF PROPOSED STIPULATED PROTECTIVE ORDER PROVIDING FOR CONFIDENTIALITY AND GOVERNING THE PRODUCTION AND EXCHANGE OF INFORMATION (Attachments: #1 Exhibit Proposed Confidentiality Order) (Chapman, Avery)
February 17, 2021 Filing 59 Defendant's MOTION to Strike #58 Plaintiff's MOTION to Expedite Inspection of Clones and for Sanctions by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 3/3/2021 (O'Quinn, Ryan)
February 16, 2021 Filing 58 Plaintiff's MOTION to Expedite Inspection of Clones by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
February 10, 2021 Filing 57 Plaintiff's RESPONSE to #56 Response/Reply (Other) Defendants' Objection by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
February 8, 2021 Filing 56 Defendant's Objection to Documents Filed by Plaintiffs to #55 Supplement,,,,,,, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (O'Quinn, Ryan)
February 5, 2021 Filing 55 SUPPLEMENT to 48 Motion Hearing,,,, #41 Response to Motion,,, #42 Reply to Response to Motion by Adolfo Cambiaso, La Dolfina S.A. LLC (Attachments: #1 Exhibit PowerPoint Presentation and PDF Hotlink thereto, #2 Exhibit Index of Affidavits and Exhibits filed as of the January 29, 2021 Hearing, #3 Exhibit Affidavit of Andrew Lott DVM, #4 Exhibit Second Affidavit of Taryn Hartnett, #5 Exhibit Second Affidavit of Ernesto Gutierrez, #6 Exhibit Prior Litigation of Meeker in Palm Beach County, Florida, #7 Exhibit Table of Inconsistencies of Meeker Averments, #8 Exhibit 2009 Cloning Agreement with Executive Summary, #9 Exhibit 2012 Quota Agreement with Executive Summary, #10 Exhibit 2019 Side Letter Agreement with Executive Summary, #11 Exhibit 2019 Settlement Agreement with Executive Summary, #12 Exhibit Link to 60 Minutes Featuring Adolfo Cambiaso and Alan Meeker, #13 Exhibit Link to National Geographic Piece Featuring Alan Meeker, #14 Exhibit Relevant Press and News Articles, #15 Exhibit Affidavit of Argentine Polo Association, #16 Exhibit TRO Hearing Summary of Cases Regarding Lanham Act Unfair Competition ( 43(a)/15 USC 1125(a)), #17 Exhibit Proposed Jurisdictional Requests for Production, #18 Exhibit Proposed Jurisdictional Interrogatory Requests, #19 Exhibit Proposed Spoliation Requests for Production, #20 Exhibit Proposed Third Party Subpoena to Daren Tamplin DVM, #21 Exhibit Proposed Thid Party Subpoena to Park Place Polo, #22 Exhibit Proposed Stipulation, #23 Exhibit Juan Carlo Di Caro Complete Email String with Alan Meeker and Counsel May 10, 2020 through December 2, 2020, #24 Exhibit NDTX 20 - Defendant's Objection to Plaintiff's Disclosure Statement and Certificate of Interested Persons, #25 Exhibit NDTX 21 - Defendant's Objection to Plaintiff's Disclosure Statement and Certificate of Interested Persons)(Chapman, Avery)
February 5, 2021 Filing 54 Defendant's Joint Composite Submission of Additonal Evidence to #37 MOTION to Dismiss for Lack of Jurisdiction #22 Amended Complaint/Amended Notice of Removal,, , #38 Response in Opposition to Motion, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Woodfield, Gary)
February 5, 2021 Filing 53 TRANSCRIPT of Motion Hearing held on 1/29/2021 before Judge Aileen M. Cannon, 1-182 pages, Court Reporter: Diane Miller,772-467-2337 / Diane_Miller@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/26/2021. Redacted Transcript Deadline set for 3/8/2021. Release of Transcript Restriction set for 5/6/2021. (dmr)
February 4, 2021 Filing 52 CLERK'S NOTICE - Attorney Admissions has updated the contact information for PHV attorney Habib Nasrullah re 50 Notice of Change of Address, Email or Law Firm Name, #49 Notice (Other). (pt)
February 4, 2021 Filing 51 Clerks Notice to Filer re #49 Notice (Other). Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see DE 50. 50 Notice of Change of Address, Email or Law Firm Name. It is not necessary to refile this document. (mc)
February 3, 2021 Filing 50 NOTICE of Change of Address, Email or Law Firm Name by Grace Rockefeller de la Gueronniere as to Habib Nasrullah re 47 Order on Motion to Appear Pro Hac Vice (See DE #49 for image) (mc)
February 3, 2021 Filing 49 NOTICE by Adolfo Cambiaso, La Dolfina S.A. LLC re 47 Order on Motion to Appear Pro Hac Vice,, Notice of Change of Firm Affiliation and Change of Address (de la Gueronniere, Grace)
January 29, 2021 Filing 48 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Motion Hearing held on January 29, 2021 regarding #26 Plaintiffs' Renewed Motion for Expedited Temporary Restraining Order, #28 Plaintiffs' Renewed Expedited Motion for Expedited Discovery, #31 Plaintiffs' Expedited Motion for Clarification regarding Expedited Discovery, and #37 Defendants' Motion to Dismiss for Lack of Jurisdiction and Failure to State a Claim. The Court heard argument from the parties on pending motions. For the reasons discussed in open court, the parties shall have until February, 5, 2021, to supplement the record with any additional factual materials they wish to submit. Any such record materials shall be filed in a single, composite entry with supporting attachments. No further briefing is authorized. Written order to follow. Attorney Appearance(s): Habib Nasrullah, Avery Spencer Chapman, Gary A. Woodfield, Ryan Dwight O'Quinn. Total time in court: 4 hour(s) : 15 minutes. Diane Miller, 561-514-3728 / Diane_Miller@flsd.uscourts.gov.
January 28, 2021 Opinion or Order Filing 47 PAPERLESS ORDER granting #44 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Habib Nasrullah. The Court reserves the power to withdraw permission for special appearance prior to and during the time of trial. Failure to abide by any Court order or failure to appear at any scheduled matter may result in immediate revocation of counsel's pro hac vice status. Local counsel must be ready to adequately represent the party at any time, including conducting the actual trial. Signed by Judge Aileen M. Cannon on January 28, 2021. (ahz)
January 28, 2021 Filing 46 AFFIDAVIT signed by: Santiago Ballester re #29 Order,, Set/Reset Deadlines/Hearings,, Terminate Motions, #28 Renewed EXPEDITED MOTION Renewed For Expedited Discovery ( re #21 Order,,,,, Set/Reset Deadlines/Hearings,,,, 15 Order,, #14 EXPEDITED MOTION Expedited Motion for Expedited Discovery In Aid of Ex Parte Expedited Motion for Preliminary, #42 Reply to Response to Motion, #41 Response to Motion,,, #26 Plaintiff's MOTION to Expedite Ex Parte Renewed Motion for Temporary Restraining Order by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
January 27, 2021 Filing 45 REPLY to Response to Motion re #37 MOTION to Dismiss for Lack of Jurisdiction #22 Amended Complaint/Amended Notice of Removal,, filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (O'Quinn, Ryan)
January 27, 2021 Filing 44 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Habib Nasrullah. Filing Fee $ 200.00 Receipt # AFLSDC-14293198 by Adolfo Cambiaso, La Dolfina S.A. LLC. Responses due by 2/10/2021 (Attachments: #1 Certification, #2 Text of Proposed Order)(Chapman, Avery)
January 27, 2021 Filing 43 PAPERLESS NOTICE of RE-SETTING ZOOM STATUS CONFERENCE Hearing: **TIME CHANGE ONLY** Status Conference is hereby re-set for Friday, 1/29/2021 at 09:30 AM in Fort Pierce Division before Judge Aileen M. Cannon via Zoom platform. Zoom link and information previously emailed to the parties remains the same. Status Conference will run from 9:30 am to 2:30 pm with a twenty (20) minute break at 12:00 pm. (mno)
January 21, 2021 Filing 42 REPLY to Response to Motion re #26 Plaintiff's MOTION to Expedite Ex Parte Renewed Motion for Temporary Restraining Order filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
January 21, 2021 Filing 41 RESPONSE to Motion re #37 MOTION to Dismiss for Lack of Jurisdiction #22 Amended Complaint/Amended Notice of Removal,, filed by Adolfo Cambiaso, La Dolfina S.A. LLC. Replies due by 1/28/2021. (Attachments: #1 Exhibit Affidavit of Ernesto Gutierrez Conte, #2 Exhibit Second Affidavit of Adolfo Cambiaso, #3 Exhibit Second Affidavit of Robert P. Jornayvaz III, #4 Exhibit Affidavit of Agustine Nero, #5 Exhibit Affidavit of David Paradice, #6 Exhibit Affidavit of Taryn Hartnett, #7 Exhibit Third Affidavit of Roberto Zedda, #8 Exhibit NDTX Motion to Dismiss for Lack of Personal Jurisdiction, #9 Exhibit Tarrant County Removal to NDTX, #10 Exhibit Removed Tarrant County Motion to Transfer or Dismiss, #11 Exhibit Affidavit of Juan Carlos DiCaro, #12 Exhibit Vanity Fair Article, #13 Exhibit Summary of Averments from Affidavits Establishing Personal Jurisdiction)(Chapman, Avery)
January 21, 2021 Opinion or Order Filing 40 PAPERLESS ORDER granting #39 Plaintiffs' Unopposed Motion to Enlarge Page Limitations. The page limitation for the Plaintiffs' Response in Opposition to the Defendants' Motion to Dismiss is hereby enlarged from twenty (20) pages to forty (40) pages. The page limitation for the Plaintiffs' Reply in Support of their Motion for a Temporary Restraining Order is hereby enlarged from five (5) pages to fifteen (15) pages. Signed by Judge Aileen M. Cannon on January 21, 2021. (ahz)
January 20, 2021 Filing 39 Unopposed MOTION for Leave to File Excess Pages in Response to [DE 37] and in Reply to [DE 38] by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
January 14, 2021 Filing 38 RESPONSE in Opposition re #26 Plaintiff's MOTION to Expedite Ex Parte Renewed Motion for Temporary Restraining Order filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 1/21/2021. (Attachments: #1 Exhibit Exhibit A)(O'Quinn, Ryan)
January 14, 2021 Filing 37 MOTION to Dismiss for Lack of Jurisdiction #22 Amended Complaint/Amended Notice of Removal,, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 1/28/2021 (Attachments: #1 Exhibit Exhibit A)(O'Quinn, Ryan)
January 14, 2021 Filing 36 NOTICE of Attorney Appearance by Grace Rockefeller de la Gueronniere on behalf of Adolfo Cambiaso, La Dolfina S.A. LLC. Attorney Grace Rockefeller de la Gueronniere added to party Adolfo Cambiaso(pty:pla), Attorney Grace Rockefeller de la Gueronniere added to party La Dolfina S.A. LLC(pty:pla). (de la Gueronniere, Grace)
January 8, 2021 Opinion or Order Filing 35 PAPERLESS ORDER granting #32 Defendants' Motion to Enlarge Page Limitation for combined Motion to Dismiss. The page limitation for the Defendants' combined Motion to Dismiss is hereby enlarged from twenty (20) pages to thirty-five (35) pages. Signed by Judge Aileen M. Cannon on 1/8/2021. (ahz)
January 8, 2021 Filing 34 REPLY to Response to Motion re #31 Plaintiff's EXPEDITED MOTION For Clarification of [DE 29] and Leave to promulgate very Limited and Narrowly Focused Expedited Discovery in Advance of Evidentiary Hearing for Preliminary Injunction re #29 Order,, Set/Reset Deadlines/Heari filed by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
January 8, 2021 Filing 33 RESPONSE in Opposition re #31 Plaintiff's EXPEDITED MOTION For Clarification of [DE 29] and Leave to promulgate very Limited and Narrowly Focused Expedited Discovery in Advance of Evidentiary Hearing for Preliminary Injunction re #29 Order,, Set/Reset Deadlines/Heari filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Replies due by 1/15/2021. (Attachments: #1 Transcripts Exhibit A, #2 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
January 8, 2021 Filing 32 Defendant's MOTION to Enlarge Page Limitations re #22 Amended Complaint/Amended Notice of Removal,, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (Attachments: #1 Text of Proposed Order)(Woodfield, Gary)
January 7, 2021 Filing 31 Plaintiff's EXPEDITED MOTION For Clarification of [DE 29] and Leave to promulgate very Limited and Narrowly Focused Expedited Discovery in Advance of Evidentiary Hearing for Preliminary Injunction re #29 Order,, Set/Reset Deadlines/Hearings,, Terminate Motions, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2)(Chapman, Avery)
January 6, 2021 Filing 30 Notice of Pending, Refiled, Related or Similar Actions by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
January 4, 2021 Misc/Status Conference Hearing(s)set for January 4, 2021 at 3:00 p.m. is cancelled and rescheduled to January 29, 2021 at 10:00 a.m. Zoom link and information will be emailed to all parties of record. (mno)
January 2, 2021 Opinion or Order Filing 29 OMNIBUS ORDER. The following motions are DENIED AS MOOT: #13 , #14 , #18 and #27 . Additionally, the Zoom Hearing previously scheduled for 1/4/2021 is hereby re-set for 1/29/2021 at 10:00 AM in Fort Pierce Division before Judge Aileen M. Cannon. Please see attached Omnibus Order for important deadlines and details . Zoom information will be emailed to all parties of record. Signed by Judge Aileen M. Cannon on 1/2/2021. See attached document for full details. (mno)
December 31, 2020 Filing 28 Renewed EXPEDITED MOTION Renewed For Expedited Discovery ( re #21 Order,,,,, Set/Reset Deadlines/Hearings,,,, 15 Order,, #14 EXPEDITED MOTION Expedited Motion for Expedited Discovery In Aid of Ex Parte Expedited Motion for Preliminary Injunction re #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
December 31, 2020 Filing 27 MOTION for Leave to File Sur-Reply by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Memorandum Sur-Reply (proposed) of Plaintiffs to Reply by Defendants [DE 25])(Chapman, Avery)
December 30, 2020 Filing 26 Plaintiff's MOTION to Expedite Ex Parte Renewed Motion for Temporary Restraining Order by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit 1- Affidavit of Bartolome Castagnola, #2 Exhibit 2- Affidavit of Camilla Castagnola, #3 Exhibit 3- 11/18/20 correspodance, #4 Exhibit 4- First Affidavit of Roberto Zedda, #5 Exhibit 5- Second Affidavit of Roberto Zedda)(Chapman, Avery)
December 29, 2020 Filing 25 REPLY to Response to Motion re #18 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, filed by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (O'Quinn, Ryan)
December 29, 2020 Filing 24 TRANSCRIPT of TRO Motion Hearing held on 12/21/20 before Judge Aileen M. Cannon, 1-23 pages, Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 1/19/2021. Redacted Transcript Deadline set for 1/29/2021. Release of Transcript Restriction set for 3/29/2021. (dmr)
December 24, 2020 Filing 23 Plaintiff's RESPONSE to #21 Order,,,,, Set/Reset Deadlines/Hearings,,,, #18 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
December 24, 2020 Filing 22 First AMENDED COMPLAINT against All Defendants, filed by La Dolfina S.A. LLC, Adolfo Cambiaso. (Attachments: #1 Exhibit Affidavit of Robert Jornayvaz, #2 Exhibit 11/18/20 Correspondance, #3 Exhibit Affidavit of Roberto Zedda, #4 Exhibit Second Affidavit of Roberto Zedda, #5 Exhibit 2009 Cloning Agreement, #6 Exhibit Storm Cat Counterclaim, #7 Exhibit Viagen Agreement, #8 Exhibit 2019 Side Letter, #9 Exhibit Storm Cat Settlement Agreement, #10 Exhibit Camila Castagnola, #11 Exhibit Bartolome Castagnola, #12 Exhibit Fort Worth Times Article, #13 Exhibit Vanity Fair Article, #14 Exhibit 60 Minutes Article)(Chapman, Avery)
December 21, 2020 Opinion or Order Filing 21 ORDER SETTING EXPEDITED Briefing Schedule RE: (1) Plaintiffs Expedited Motion for Issuance of Temporary Restraining Order #13 ; (2) Plaintiffs Motion for Expedited Discovery in Aid of Ex Parte Expedited Motion for Issuance of Temporary Restraining Order #14 ; (3) Defendants Motion to Dismiss for Lack of Jurisdiction #18 ; and (4) Affidavit in Support of Expedited Motion for Issuance of Temporary Restraining Order #19 . ( Plaintiffs shall file a Response to Defendants Motion to Dismiss for Lack of Subject Matter and Personal Jurisdiction on or before 12/24/2020. Defendants shall file a combined Reply to Defendants Response on or before 12/29/2020. Counsel for all parties shall appear for a Zoom hearing on 1/4/2021 03:00 PM, to discuss the parties positions with respect to federal subject matter jurisdiction and personal jurisdiction). Zoom information will be emailed to all counsel of record. Signed by Judge Aileen M. Cannon on 12/21/2020. See attached document for full details. (mno)
December 21, 2020 Filing 20 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Motion Hearing held on 12/21/2020. Court heard arguments from the parties, RE #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, ; RE: #14 EXPEDITED MOTION Expedited Motion for Expedited Discovery In Aid of Ex Parte Expedited Motion for Preliminary Injunction ; RE: #18 Motion to Dismiss for Lack of Jurisdiction; RE: #19 Affidavit of Robert P. Jornayvaz, III re : #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order. Order to follow. Attorney Appearance(s):Plaintiff counsel, Avery Spencer Chapman; Defense counsel, Gary A. Woodfield and Ryan Dwight O'Quinn. Court Reporter: Diane Miller, 561-514-3728 / Diane_Miller@flsd.uscourts.gov. (mno)
December 21, 2020 Filing 19 AFFIDAVIT signed by: Robert P. Jornayvaz III re #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC (Chapman, Avery)
December 21, 2020 Filing 18 MOTION to Dismiss for Lack of Jurisdiction #1 Complaint, by Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. Responses due by 1/4/2021 (Attachments: #1 Exhibit Exhibit A, #2 Text of Proposed Order Proposed Order)(O'Quinn, Ryan)
December 21, 2020 Filing 17 NOTICE of Attorney Appearance by Gary A. Woodfield on behalf of D. Alan Meeker. Attorney Gary A. Woodfield added to party D. Alan Meeker(pty:dft). (Woodfield, Gary)
December 21, 2020 Filing 16 PAPERLESS NOTICE of Hearing on Motion #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, : Zoom Motion Hearing set for 12/21/2020 02:00 PM in Fort Pierce Division before Judge Aileen M. Cannon. Zoom information email to parties on 12/19/2020 (mno)
December 19, 2020 Filing 15 PAPERLESS ORDER setting VTC Zoom Hearing on #13 Plaintiffs' Expedited Motion for Ex Parte Temporary Restraining Order and #14 Plaintiffs' Motion for Expedited Discovery in Aid of Expedited Motion for Preliminary Injunction. Motion Hearing set for 12/21/2020 at 2:00 PM in Fort Pierce Division before Judge Aileen M. Cannon. The Plaintiffs are ordered to attempt service of this Order on Individual Defendant Alan Meeker on or before 3:00 PM on December 20, 2020. Counsel for all parties are required to appear via Zoom. Zoom instructions will be provided to counsel via separate e-mail. Signed by Aileen M. Cannon on 12/19/2020.
December 18, 2020 Filing 14 EXPEDITED MOTION Expedited Motion for Expedited Discovery In Aid of Ex Parte Expedited Motion for Preliminary Injunction re #13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Chapman, Avery)
December 18, 2020 Filing 13 EXPEDITED MOTION Ex Parte Expedited Motion for Temporary Restraining Order re #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Exhibit Exhibit 1 - Affidavit of Bartolome Castagnola, #2 Exhibit Exhibit 2 - Affidavit of Camila Castagnola, #3 Exhibit Exhibit 3 - November 18, 2020 Letter, #4 Exhibit Exhibit 4 - Affidavit of Roberto Zedda, #5 Exhibit Exhibit 5 - Second Affidavit of Roberto Zedda)(Chapman, Avery)
December 18, 2020 Filing 12 Summons Issued as to D. Alan Meeker. (ail)
December 17, 2020 Filing 11 NOTICE of Filing Proposed Summons(es) by Adolfo Cambiaso, La Dolfina S.A. LLC re #1 Complaint, filed by La Dolfina S.A. LLC, Adolfo Cambiaso, #10 Summons Returned Unexecuted filed by La Dolfina S.A. LLC, Adolfo Cambiaso (Attachments: #1 Summon(s) Meeker c/o Secretary of State) (Chapman, Avery)
December 17, 2020 Filing 10 Summons (Affidavit) Returned Unexecuted by La Dolfina S.A. LLC, Adolfo Cambiaso as to D. Alan Meeker. (Chapman, Avery)
December 17, 2020 Filing 9 NOTICE of Attorney Appearance by Gary A. Woodfield on behalf of Crestview Farm LLC. Attorney Gary A. Woodfield added to party Crestview Farm LLC(pty:dft). (Woodfield, Gary)
December 16, 2020 Filing 8 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by La Dolfina S.A. LLC, Adolfo Cambiaso. Crestview Genetics LLC served on 12/10/2020, answer due 12/31/2020. (Chapman, Avery)
December 16, 2020 Filing 7 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by La Dolfina S.A. LLC, Adolfo Cambiaso. Crestview Farm LLC served on 12/14/2020, answer due 1/4/2021. (Chapman, Avery)
December 16, 2020 Filing 6 NOTICE of Attorney Appearance by Ryan Dwight O'Quinn on behalf of Crestview Genetics LLC. Attorney Ryan Dwight O'Quinn added to party Crestview Genetics LLC(pty:dft). (O'Quinn, Ryan)
December 15, 2020 Opinion or Order Filing 5 ORDER Denying without prejudice #4 Plaintiffs' Expedited Motion for Preliminary Injunction. Plaintiffs' may refile an Ex Parte Motion for a Temporary Restraining Order on or before December 18, 2020. Signed by Judge Aileen M. Cannon on 12/15/2020. See attached document for full details. (mno)
December 11, 2020 Filing 4 Plaintiff's EXPEDITED MOTION for Preliminary Injunction re #1 Complaint, by Adolfo Cambiaso, La Dolfina S.A. LLC. (Attachments: #1 Affidavit Affidavit of Roberto Zedda)(Chapman, Avery)
December 9, 2020 Filing 3 Summons Issued as to Crestview Farm LLC, Crestview Genetics LLC, D. Alan Meeker. (amb)
December 8, 2020 Filing 2 Clerks Notice of Judge Assignment to Judge Aileen M. Cannon. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Dave Lee Brannon 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. (amb)
December 8, 2020 Filing 1 COMPLAINT against All Defendants. Filing fees $ 402.00 receipt number BFLSDC-14001619, filed by La Dolfina S.A. LLC, Adolfo Cambiaso. (Attachments: #1 Civil Cover Sheet, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Summon(s), #9 Summon(s), #10 Summon(s))(Chapman, Avery)

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Search for this case: La Dolfina S.A. LLC et al v. Meeker et al
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Plaintiff: Adolfo Cambiaso
Represented By: Avery Spencer Chapman
Represented By: Grace Rockefeller de la Gueronniere
Represented By: Habib Nasrullah
Represented By: Francis M. McDonald, Jr.
Represented By: Harry Dorcy
Represented By: Miles D. Orton
Represented By: Molly Kokesh
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Plaintiff: La Dolfina S.A. LLC
Represented By: Avery Spencer Chapman
Represented By: Grace Rockefeller de la Gueronniere
Represented By: Habib Nasrullah
Represented By: Francis M. McDonald, Jr.
Represented By: Harry Dorcy
Represented By: Miles D. Orton
Represented By: Molly Kokesh
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Defendant: Crestview Genetics LLC
Represented By: Gary A. Woodfield
Represented By: Ryan Dwight O'Quinn
Represented By: James C. Bookhout
Represented By: Jason S. Lewis
Represented By: Maia Sevilla-Sharon
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Defendant: D. Alan Meeker
Represented By: Gary A. Woodfield
Represented By: Maia Sevilla-Sharon
Represented By: Ryan Dwight O'Quinn
Represented By: Caitlyn Elizabeth Hubbard
Represented By: James C. Bookhout
Represented By: Jason S. Lewis
Represented By: William N. Warren
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Defendant: Crestview Farm LLC
Represented By: Gary A. Woodfield
Represented By: David E. Keltner
Represented By: Ryan Dwight O'Quinn
Represented By: Susan Becker Yoffee
Represented By: Caitlyn Elizabeth Hubbard
Represented By: James C. Bookhout
Represented By: Jason S. Lewis
Represented By: Maia Sevilla-Sharon
Represented By: William N. Warren
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Defendant: David Alan Meeker
Represented By: Gary A. Woodfield
Represented By: Ryan Dwight O'Quinn
Represented By: Caitlyn Elizabeth Hubbard
Represented By: James C. Bookhout
Represented By: Jason S. Lewis
Represented By: Maia Sevilla-Sharon
Represented By: William N. Warren
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Defendant: Alan Meeker
Represented By: Gary A. Woodfield
Represented By: William N. Warren
Represented By: Ryan Dwight O'Quinn
Represented By: Caitlyn Elizabeth Hubbard
Represented By: James C. Bookhout
Represented By: Jason S. Lewis
Represented By: Maia Sevilla-Sharon
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Defendant: Park Place Polo Team Corporation
Represented By: Robert Iddings Chaskes
Represented By: Noelle Page Pankey
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Defendant: Park Place Polo Fields Corporation
Represented By: Robert Iddings Chaskes
Represented By: Noelle Page Pankey
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Defendant: La Dolfina S.A.
Represented By: Avery Spencer Chapman
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