Kiyani v. Fundora et al
| Sohail Kiyani |
| Thomas Grob, Jason Guevara, Robert Carpenter, Ricardo Safford, Andrew Richter, David Fundora, Alexander Perez, Jerry Obray and Ric L. Bradshaw |
| 9:2024cv81098 |
| September 10, 2024 |
| U.S. District Court for the Southern District of Florida |
| Raag Singhal |
| Civil Rights: Other |
| 42 U.S.C. § 1983 Civil Rights Act |
| Plaintiff |
Docket Report
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This docket was last retrieved on November 8, 2024. A more recent docket listing may be available from PACER.
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Filing 47
PAPERLESS ORDER granting #46 Plaintiff's Unopposed Motion for Extension of Time to File Opposition to Defendants' Motion to Dismiss. Plaintiff shall file his response to Defendants' Motion to Dismiss on or by 11/15/2024. Signed by Judge Raag Singhal on 11/8/2024. (lp00)
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| Filing 46 Unopposed MOTION for Extension of Time to Respond to Motion to Dismiss re #34 Defendant's MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Sohail Kiyani. Responses due by 11/22/2024. (Attachments: #1 Text of Proposed Order)(Criscione, Galen) |
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Filing 45
PAPERLESS ORDER granting #44 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) M. Salman Ravala, Esq. Signed by Judge Raag Singhal on 11/6/2024. (lp00)
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| Filing 44 Amended MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for M. Salman Ravala. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See #39 Motion to Appear Pro Hac Vice, by Sohail Kiyani. Responses due by 11/19/2024. (Criscione, Galen) |
| Filing 43 MEMORANDUM in Support , Defendant's REPLY Memorandum In Further Support of Amended Motion for Permission to Conventionally File Video by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. (Fereg, Mark) |
| Filing 42 CLERK'S NOTICE - Attorney Admissions has updated the email information as submitted through attorneys PACER account for attorney Galen J Criscione re #41 Notice of Change of Address, Email or Law Firm Name (pt) |
| Filing 41 NOTICE of Change of Email; by Galen J Criscione (Criscione, Galen) |
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Filing 40
PAPERLESS ORDER denying #39 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) M. Salman Ravala. The email address for movant, Galen J. Criscione, Esq., is inactive, meaning that the movant cannot receive Notices of Electronic Filings, which is required pursuant to Local Rule 4(b). Signed by Judge Raag Singhal on 11/1/2024. (lp00)
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| Filing 39 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for M. Salman Ravala. Filing Fee $ 200.00 Receipt # AFLSDC-17949282 by Sohail Kiyani. Responses due by 11/14/2024. (Criscione, Galen) |
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Filing 38
PAPERLESS ORDER re #36 Defendants' Amended Motion for Permission to Conventionally File Video (the "Motion"). Defendants, David Fundora, Jason Guevara, Robert Carpenter, Jerry Obray, Alexander Perez, Thomas Grob, Ricardo Safford, Andrew Richter and Ric L. Bradshaw, shall file an expedited reply in further support of their Motion on or by 11/4/2024. Signed by Judge Raag Singhal on 10/30/2024. (lp00)
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| Filing 37 RESPONSE in Opposition re #36 Amended MOTION for Permission to Conventionally File Video filed by Sohail Kiyani. Replies due by 11/5/2024. (Attachments: #1 Exhibit Exhibit A - Expungment Order)(Criscione, Galen) |
| Filing 36 Amended MOTION for Permission to Conventionally File Video by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. (Attachments: #1 Text of Proposed Order Granting Defendants Amended Motion for Permission to Conventionally File Flash Drive Video)(Fereg, Mark) |
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Filing 35
PAPERLESS ORDER denying without prejudice #33 Defendants David Fundora, Jason Guevara, Robert Carpenter, Jerry Obray, Alexander Perez, Thomas Grob, Ricardo Safford, Andrew Richter and Ric. L. Bradshaw's ("Defendants") Motion for Permission to Conventionally File Video based upon Defendants' failure to include a sufficiently specific Local Rule 7.1(a)(3) certification. Pursuant to Local Rule 7.1(a)(3), when counsel for the movant has been unable to confer with all parties or non-parties who may be affected by the relief sought, counsel for the movant must certify that counsel "has made reasonable efforts to confer with all parties or non-parties who may be affected by the relief sought in the motion, which efforts shall be identified with specificity in the statement (including the date, time, and manner of each effort)." (emphasis added). Defendants' certification states only that the movant "attempted to confer with all parties who may be affected by the relief sought in good faith; however, Counsel for the Plaintiff has not confirmed whether he opposes the relief sought." (DE #33 at 2). The Court requires more specific information regarding the conferral efforts in order to determine whether the movant's efforts have been "reasonable." Signed by Judge Raag Singhal on 10/28/2024. (lp00)
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| Filing 34 Defendant's MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. Responses due by 11/8/2024. (Attachments: #1 Exhibit A, #2 Exhibit B)(Fereg, Mark) |
| Filing 33 Defendant's MOTION for Permission to Conventionally File Video by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. (Attachments: #1 Text of Proposed Order)(Fereg, Mark) |
| Filing 32 Defendant's Certificate of Other Affiliates/Corporate Disclosure Statement by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford identifying Corporate Parent Palm Beach County Sheriff's Office for Alexander Perez, Andrew Richter, David Fundora, Jason Guevara, Jerry Obray, Ric L. Bradshaw, Ricardo Safford, Robert Carpenter, Thomas Grob (Fereg, Mark) |
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Filing 31
PAPERLESS ORDER granting #30 Defendants' Unopposed Motion for Extension of Time to File Response to Plaintiff's Complaint. Defendants, Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, and Ricardo Safford, shall file their response(s) to Plaintiff's Complaint on or by 10/25/2024. The Court notes that it is granting Defendants, excluding Defendant Alexander Perez, one additional day beyond the 21-day request for consistency purposes. Signed by Judge Raag Singhal on 10/1/2024. (lp00)
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| Filing 30 Unopposed MOTION for Extension of Time to File Response/Reply/Answer to Plaintiff's Complaint by Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. (Attachments: #1 Text of Proposed Order Proposed Order on Defendants Unopposed Motion for Extension of Time to File Response to Plaintiffs Complaint)(Fereg, Mark) |
| Filing 29 NOTICE of Attorney Appearance by Mark Fereg on behalf of Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. Attorney Mark Fereg added to party Ric L. Bradshaw(pty:dft), Attorney Mark Fereg added to party Robert Carpenter(pty:dft), Attorney Mark Fereg added to party David Fundora(pty:dft), Attorney Mark Fereg added to party Thomas Grob(pty:dft), Attorney Mark Fereg added to party Jason Guevara(pty:dft), Attorney Mark Fereg added to party Jerry Obray(pty:dft), Attorney Mark Fereg added to party Alexander Perez(pty:dft), Attorney Mark Fereg added to party Andrew Richter(pty:dft), Attorney Mark Fereg added to party Ricardo Safford(pty:dft). (Fereg, Mark) |
| Filing 28 NOTICE of Attorney Appearance by Joseph Gregory Santoro on behalf of Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. Attorney Joseph Gregory Santoro added to party Ric L. Bradshaw(pty:dft), Attorney Joseph Gregory Santoro added to party Robert Carpenter(pty:dft), Attorney Joseph Gregory Santoro added to party David Fundora(pty:dft), Attorney Joseph Gregory Santoro added to party Thomas Grob(pty:dft), Attorney Joseph Gregory Santoro added to party Jason Guevara(pty:dft), Attorney Joseph Gregory Santoro added to party Jerry Obray(pty:dft), Attorney Joseph Gregory Santoro added to party Alexander Perez(pty:dft), Attorney Joseph Gregory Santoro added to party Andrew Richter(pty:dft), Attorney Joseph Gregory Santoro added to party Ricardo Safford(pty:dft). (Santoro, Joseph) |
| Filing 27 NOTICE of Striking #22 Waiver of Service Executed,, Summons Returned Executed, filed by Sohail Kiyani by Sohail Kiyani (Criscione, Galen) |
| Filing 26 Certificate of Other Affiliates/Corporate Disclosure Statement by Sohail Kiyani (Criscione, Galen) |
| Filing 25 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Alexander Perez served on 9/13/2024, response/answer due 10/4/2024. (Criscione, Galen) |
| Filing 24 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Andrew Richter served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 23 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. David Fundora served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 22 (STRICKEN PER DE#27 ) WAIVER OF SERVICE Returned Executed by Sohail Kiyani. Jason Guevara waiver sent on 9/12/2024, response/answer due 11/12/2024., SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Jason Guevara served on 9/12/2024, response/answer due 11/12/2024. (Criscione, Galen) Modified Text on 9/18/2024 (cds). |
| Filing 21 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Jerry Obray served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 20 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Ric L. Bradshaw served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 19 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Ricardo Safford served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 18 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Robert Carpenter served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
| Filing 17 SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sohail Kiyani. Thomas Grob served on 9/12/2024, response/answer due 10/3/2024. (Criscione, Galen) |
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Filing 16
PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONSWithin SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 9/12/2024. (lp00)
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| Filing 15 NOTICE OF COURT PRACTICEUnless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes.Multiple Plaintiffs or Defendants shall file joint motions (and responses to motions) with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions (and responses). Motions for Extension of Time Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Labeling Exhibits on CM/ECF Exhibits to pleadings and motions shall be docketed in accordance with the Court's CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket EntryA party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Notices of Settlement Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings.Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 9/12/2024. (lp00) |
| Filing 14 Summons Issued as to Ric L. Bradshaw, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. (cds) |
| Filing 13 NOTICE of Filing Proposed Summons(es) Ric L. Bradshaw in his capacity as Sheriff of Palm Beach County, Florida by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 12 NOTICE of Filing Proposed Summons(es) Andrew Richter by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 11 NOTICE of Filing Proposed Summons(es) Ricardo Safford by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 10 NOTICE of Filing Proposed Summons(es) Thomas Grob by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 9 NOTICE of Filing Proposed Summons(es) Alexander Perez by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 8 NOTICE of Filing Proposed Summons(es) Jerry Obray by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 7 NOTICE of Filing Proposed Summons(es) Robert Carpenter by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 6 NOTICE of Filing Proposed Summons(es) David Fundora by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 5 NOTICE of Filing Proposed Summons(es) Jason Guevara by Sohail Kiyani re #1 Complaint, filed by Sohail Kiyani (Criscione, Galen) |
| Filing 4 NOTICE Civil Cover Sheet by Sohail Kiyani re #1 Complaint, (Criscione, Galen) |
| Filing 3 Clerk's Notice to Filer re: Electronic Case. No Civil Cover Sheet. Filer is instructed to file a Notice (Other) with the Civil Cover Sheet attached within 24 hours of the notice. (cds) |
| Filing 2 Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Shaniek M. Maynard is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (cds) |
| Filing 1 COMPLAINT against Ric L Bradshaw, in his capacity as Sheriff of Palm Beach County, Florida, Robert Carpenter, David Fundora, Thomas Grob, Jason Guevara, Jerry Obray, Alexander Perez, Andrew Richter, Ricardo Safford. Filing fees $ 405.00 receipt number AFLSDC-17824178, filed by Sohail Kiyani.(Criscione, Galen) |
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