A.M. Cross Trade Logistics Network, Inc. et al v. McWilliams Collective, LLC et al
| A.M. CROSS TRADE LOGISTICS NETWORK, INC. and JEMARA INTERNATIONAL FREIGHT SERVICES INC. |
| McWilliams Collective, LLC, Eric L. McWilliams, Cargo Link International Inc., Global Ocean Agency Lines, L.L.C., Cosco Shipping Lines, Co. Ltd. and Airboss Defense Group, LLC |
| 1:2024cv01021 |
| April 3, 2024 |
| US District Court for the District of Maryland |
| Lydia Kay Griggsby |
| Negotiable Instrument |
| 28 U.S.C. § 1331 Fed. Question: Breach of Contract |
| Both |
Docket Report
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This docket was last retrieved on April 10, 2024. A more recent docket listing may be available from PACER.
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| Filing 116 Case transferred in from District of Florida Middle; Case Number 3:23-cv-00838. Original file certified copy of transfer order and docket sheet received. |
Filing 115
ORDERED: The Report and Recommendation (Doc. #113 ) is ADOPTED and CONFIRMED and made a part of this Order; Counts I through VI of the First Amended Complaint (Doc. #47 ) and the Crossclaims against Defendant Airboss Defense Group, LLC (Doc. #54 at 85-99) are SEVERED from the remaining claims in this case and TRANSFERRED to United States District Court for the District of Maryland; the Case Management and Scheduling Order and Referral to Mediation (Doc. #91 ) is VACATED; the Clerk shall TRANSFER such claims to the District of Maryland for all further proceedings. The Clerk is directed to terminate all pending motions and administratively close this case. See Order for details. Signed by Judge Wendy W. Berger on 3/28/2024. (CKS)
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| Filing 114 THIRD NOTICE TO COUNSEL Miguel A. Manrara of Local Rule 2.01(a), which requires membership or special admission in the Middle District bar to practice in the Middle District, except for the limited exceptions identified in the Rule. To apply for membership in the Middle District, visit www.flmd.uscourts.gov/for-lawyers. (Signed by Deputy Clerk). (CTR) |
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Filing 113
REPORT AND RECOMMENDATION re #110 , #111 , and #112 the parties' responses to this Court's #109 Order to Show Cause. Signed by Magistrate Judge Joel B. Toomey on 3/11/2024. (KLA)
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| Filing 112 RESPONSE TO ORDER TO SHOW CAUSE re #109 Order filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 111 RESPONSE TO ORDER TO SHOW CAUSE re #109 Order filed by Airboss Defense Group, LLC, Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) |
| Filing 110 RESPONSE TO ORDER TO SHOW CAUSE re #109 Order filed by Cargo Link International Inc., Cosco Shipping Lines, Co. Ltd., Global Ocean Agency Lines, L.L.C.. (Borak, Robert) |
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Filing 109
ORDER. On or before February 16, 2024, all Parties shall show cause why this case should not be transferred or stayed. Ruling on all pending motions (Docs. 52, 53, 55, 56, 60, 61, 65, and 92) is deferred until a determination regarding transfer or stay has been made. See Order for details. Signed by Magistrate Judge Joel B. Toomey on 1/26/2024. (KLA)
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Filing 108
ENDORSED ORDER accepting #106 Plaintiffs' Reply as timely filed and denying as moot #103 Plaintiffs' Motion for Clarification Regarding Order Granting Leave to File Reply (Doc. 102). Signed by Magistrate Judge Joel B. Toomey on 1/25/2024. (KLA)
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Filing 107
ENDORSED ORDER denying as moot #48 Motion to Dismiss Cross-Claim. Signed by Judge Wendy W. Berger on 1/24/2024. (MDJ)
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| Filing 106 REPLY to Response to Motion re #61 MOTION for Miscellaneous Relief, specifically MOTION FOR LEAVE TO SERVE JURISDICTIONAL DISCOVERY AND FOR EXTENSION OF TIME , #60 MOTION for Miscellaneous Relief, specifically MOTION FOR LEAVE TO SERVE LIMITED JURISDICTIONAL DISCOVERY, AND FOR EXTENSION OF TIME filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 105 SECOND NOTICE TO COUNSEL Miguel A. Manrara TO COMPLY with Local Rule 2.01(a), which requires membership or special admission in the Middle District bar to practice in the Middle District, except for the limited exceptions identified in the Rule. To apply for membership in the Middle District, visit www.flmd.uscourts.gov/for-lawyers. (Signed by Deputy Clerk). (LSS) |
| Filing 104 Case Reassigned to Judge Wendy W. Berger. New case number: 3:23-cv-838-WWB-JBT. Senior Judge Brian J. Davis no longer assigned to the case. (ELM) |
| Filing 103 MOTION for Clarification re 102 Order on Motion for Miscellaneous Relief by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) Modified on 12/26/2023 to edit the docket text (RPB). |
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Filing 102
ENDORSED ORDER: Docs. #95 , #96 and #97 Plaintiffs' Motions for Leave to File Replies are GRANTED to the extent that Plaintiffs may file a single consolidated reply of no more than ten (10) substantive pages. Signed by Judge Brian J. Davis on 12/22/2023. (AMP)
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Filing 101
ENDORSED ORDER granting #99 Motion to Withdraw as Counsel. Gaspard Rappoport, Esq., is hereby permitted to withdraw as counsel for Defendants/Crossclaim Plaintiffs McWilliams Collective, LLC and Eric L. Williams. The Clerk is directed to terminate Mr. Rappoport as counsel of record. Signed by Magistrate Judge Joel B. Toomey on 12/13/2023. (TSP)
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| Filing 100 RESPONSE in Opposition re #92 MOTION to Dismiss First Amended Complaint filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Attachments: #1 Exhibit Declaration Of MA. Teresa C. Buensuceso)(Liang, Shanshan) Modified text on 12/13/2023 (KME). |
| Filing 99 MOTION for Gaspard Rappoport to Withdraw as Attorney by Eric L. McWilliams, McWilliams Collective, LLC. (Rappoport, Gaspard) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 98 RESPONSE in Opposition re #97 MOTION for Leave to Reply and MOTION for Extension of Time to Respond filed by Airboss Defense Group, LLC. (Roberts, Cameron) |
| Filing 97 MOTION for Leave to Reply to Defendant Airboss Defense Group, LLC's Reply in Opposition to Plaintiff's (1) #60 Motion for Leave to Serve Limited Jurisdictional Discovery and (2) for Extension of Time to Respond to Defendant Airboss Defense Group, LLC's Motion to Dismiss for Lack of Personal Jurisdiction by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) Modified text on 11/27/2023 (BD). |
| Filing 96 MOTION for Leave to Reply to Defendant Cargo Link International Inc.'s Response in Opposition to Plaintiffs' #61 Motion for Leave to Serve Jurisdictional Discovery and MOTION for Extension of Time to Respond to Cargo Link International Inc's Motion to Dismiss Plaintiff's Amended Complaint by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) Modified text on 11/27/2023 (BD). |
| Filing 95 MOTION for Leave to Reply Defendants McWilliams Collective, LLC, and Eric L. McWilliams' Response to Plaintiffs' #61 Motions for Leave to Serve Jurisdictional Discovery by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) Modified text on 11/27/2023 (BD). |
| Filing 94 DECLARATION of Eric L. McWilliams re #93 Response in Opposition to Motion by Eric L. McWilliams(an individual ), McWilliams Collective, LLC(a Florida Limited Liability Company). (Attachments: #1 Exhibit 1 - Transportation Management Agreement (May 7, 2021), #2 Exhibit 2 - Daily Graph Email and attached report (Mar. 29, 2022), #3 Exhibit 3 - ATL MIA Warehouse WhatsApp Chat (Mar. 2022), #4 Exhibit 4 - Email chain re MIA Warehouse (Mar. 2022), #5 Exhibit 5 - Invoice 20220720ADG001, #6 Exhibit 6 - Invoice 20220720ADG005, #7 Exhibit 7 - Invoice 20220720ADG006)(Phillips, J.) |
| Filing 93 RESPONSE in Opposition re #65 MOTION to Dismiss for Lack of Jurisdiction filed by Eric L. McWilliams(an individual ), McWilliams Collective, LLC(a Florida Limited Liability Company). (Phillips, J.) |
| Filing 92 MOTION to Dismiss First Amended Complaint by Cosco Shipping Lines, Co. Ltd. (Attachments: #1 Exhibit "A")(Buhler, Phillip) |
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Filing 91
CASE MANAGEMENT AND SCHEDULING ORDER: Mediator selection due by 7/31/2024; Fact Discovery due by 8/30/2024; Expert Discovery due by 12/30/2024; Dispositive motions due by 1/30/2025; Conduct mediation hearing by 1/31/2025; Pretrial statement due by 6/18/2025; Final Pretrial Conference set for 6/25/2025 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 7/7/2025 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 11/16/2023. (Attachments: #1 Mediation Report Form, #2 Docket Sheets)(AMP)
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Filing 90
ENDORSED ORDER DISCHARGING #69 Order to Show Cause in light of #83 Case Management Report and #84 Joint Response to Order to Show Cause. Signed by Judge Brian J. Davis on 11/16/2023. (AMP)
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| Filing 89 RESPONSE in Opposition re #60 Motion for Leave to Serve Limited Jurisdictional Discovery and for Extension of Time filed by Airboss Defense Group, LLC. (Roberts, Cameron) (Modified on 11/17/2023, to edit text) (BGR). |
| Filing 88 RESPONSE in Opposition re #61 Motion for Leave to Serve Jurisdictional Discovery and for Extension of Time filed by Cargo Link International Inc. (Marcotte, Daniel) (Modified on 11/17/2023, to edit text) (BGR). |
| Filing 87 RESPONSE to Motion re #61 Motion for Leave to Serve Jurisdictional Discovery and for Extension of Time, #60 Motion for Leave to Serve Limited Jurisdictional Discovery and for Extension of Time filed by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) (Modified on 11/17/2023, to edit text) (BGR). |
| Filing 86 CERTIFICATE of interested persons and corporate disclosure statement Pursuant to Federal Rule of Civil Procedure 7.1 and Local Rule 3.03 by Cosco Shipping Lines, Co. Ltd. (Buhler, Phillip) |
| Filing 85 CERTIFICATE of interested persons and corporate disclosure statement by Airboss Defense Group, LLC. (Brew, George) |
| Filing 84 RESPONSE TO ORDER TO SHOW CAUSE re #69 Order to show cause filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) Modified text on 11/15/2023 (MCB). |
| Filing 83 CASE MANAGEMENT REPORT. (Liang, Shanshan) |
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Filing 82
ENDORSED ORDER granting #79 Defendants' Unopposed Motion for Admission Pro Hac Vice, Written Designation and Consent to Act. If Nicole Marie Kozlowski, Esq., has not already done so, she shall expeditiously register for a login and password for electronic filing at the Court's website at www.flmd.uscourts.gov. Signed by Magistrate Judge Joel B. Toomey on 11/14/2023. (TSP)
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| Filing 81 CERTIFICATE of interested persons and corporate disclosure statement re #80 Order by Global Ocean Agency Lines, L.L.C.. (Spector, Andrew) |
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Filing 80
ORDER striking #72 #73 #77 disclosure statements. Proper disclosure statements due by November 20, 2023. Signed by Magistrate Judge Joel B. Toomey on 11/13/2023. (TSP)
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| Filing 79 Unopposed MOTION for Nicole Marie Kozlowski to appear pro hac vice Special Admission fee paid, Receipt No. AFLMDC-21454457 for $150 by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 78 NOTICE of a related action per Local Rule 1.07(c) by Airboss Defense Group, LLC. Related case(s): Yes (Roberts, Cameron) |
| Filing 77 **STRICKEN per #80 Order** CERTIFICATE of interested persons and corporate disclosure statement by Airboss Defense Group, LLC. (Roberts, Cameron) Modified on 11/14/2023 (SPM). |
| Filing 76 CERTIFICATE of interested persons and corporate disclosure statement by Jemara International Freight Services Inc. identifying Other Affiliate A.M. CROSS TRADE LOGISTICS NETWORK, INC. for Jemara International Freight Services Inc. (Liang, Shanshan) Modified text on 11/13/2023 (JK). |
| Filing 75 CERTIFICATE of interested persons and corporate disclosure statement by A.M. Cross Trade Logistics Network, Inc. identifying Other Affiliate JEMARA INTERNATIONAL FREIGHT SERVICES INC. for A.M. Cross Trade Logistics Network, Inc. (Liang, Shanshan) Modified text on 11/13/2023 (JK). |
| Filing 74 CERTIFICATE of interested persons and corporate disclosure statement by Cargo Link International Inc. (Marcotte, Daniel) |
| Filing 73 **STRICKEN per #80 Order** CERTIFICATE of interested persons and corporate disclosure statement by Global Ocean Agency Lines, L.L.C. (Borak, Robert) Modified on 11/14/2023 (SPM). |
| Filing 72 **STRICKEN per #80 Order** CORPORATE Disclosure Statement by Cosco Shipping Lines, Co. Ltd.(Buhler, Phillip) Modified on 11/14/2023 (SPM). |
| Filing 71 NOTICE of a related action per Local Rule 1.07(c) by Eric L. McWilliams, McWilliams Collective, LLC. Related case(s): Yes (Phillips, J.) |
| Filing 70 NOTICE TO COUNSEL Cameron W. Roberts to comply with Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - Submit a Pro Hac Vice E-File Registration through PACER. Visit www.flmd.uscourts.gov/for-lawyers for details (Signed by Deputy Clerk). (LSS) |
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Filing 69
ORDER directing the parties to SHOW CAUSE on or before November 14, 2023, why sanctions should not be imposed for their failure to file a Case Management Report within the time prescribed by Local Rule 3.02(b)(1). Signed by Judge Brian J. Davis on 11/6/2023. (AMP)
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Filing 68
ENDORSED ORDER granting #64 Consent Motion of Defendant Cosco Shipping Lines Company Ltd. for Extension of Time to Respond to Amended Complaint. Defendant Cosco Shipping Lines Company Ltd., shall have up to and including November 24, 2023 to respond to the First Amended Complaint #47 . Signed by Magistrate Judge Joel B. Toomey on 11/6/2023. (TSP)
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| Filing 67 NOTICE to the Courts to take judicial notice regarding #65 MOTION to Dismiss for Lack of Jurisdiction by Airboss Defense Group, LLC(a Maryland Limited Liability Company ). (Attachments: #1 Exhibit 1 - Order Regarding Defendant's Motion to Transfer)(Brew, George) |
| Filing 66 DEFENDANT Airboss Defense Group, LLC'S Notice of Joinder to Defendant, Global Ocean Agency Lines, LLC's, Motion to Dismiss for Lack of Subject Matter Jurisdiction [D.E. 56]. (Brew, George) Motions referred to Magistrate Judge Joel B. Toomey. Modified on 11/7/2023 to edit docket text and event type (MDC). |
| Filing 65 MOTION to Dismiss for Lack of Jurisdiction by Airboss Defense Group, LLC(a Maryland Limited Liability Company ). (Attachments: #1 Exhibit A - Affidavit of Carlos Motta)(Brew, George) |
| Filing 64 Consent MOTION for Extension of Time to File Response/Reply as to #47 Amended Complaint by Cosco Shipping Lines, Co. Ltd. (Buhler, Phillip) Motions referred to Magistrate Judge Joel B. Toomey. Modified text on 11/6/2023 (KME). |
| Filing 63 NOTICE to the Courts to take judicial notice regarding #61 MOTION for Miscellaneous Relief, specifically Motion for Leave to Serve Jurisdictional Discovery and for Extension of Time, #56 MOTION to Dismiss for Lack of Jurisdiction, #55 MOTION to Dismiss for Failure to State a Claim by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) |
| Filing 62 RESPONSE in Opposition re #56 MOTION to Dismiss for Lack of Jurisdiction, #55 MOTION to Dismiss for Failure to State a Claim filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Attachments: #1 Exhibit A)(Liang, Shanshan) |
| Filing 61 MOTION for Miscellaneous Relief, specifically Motion for Leave to Serve Jurisdictional Discovery and for Extension of Time by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Liang, Shanshan) |
| Filing 60 MOTION for Miscellaneous Relief, specifically Motion for Leave to Serve Limited Jurisdictional Discovery and for Extension of Time by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Attachments: #1 Exhibit A, #2 Exhibit B)(Liang, Shanshan) |
| Filing 59 DECLARATION of Eric L. McWilliams re #58 Response in Opposition to Motion by Eric L. McWilliams(an individual ), McWilliams Collective, LLC(a Florida Limited Liability Company). (Attachments: #1 Exhibit 1 - Transportation Management Agreement (May 7, 2021), #2 Exhibit 2 - Daily Graph Email and attached report (Mar. 29, 2022), #3 Exhibit 3 - ATL MIA Warehouse WhatsApp Chat (Mar. 2022), #4 Exhibit 4 - Email chain re MIA Warehouse (Mar. 2022), #5 Exhibit 5 - Invoice 20220720ADG001, #6 Exhibit 6 - Invoice 20220720ADG005, #7 Exhibit 7 - Invoice 20220720ADG006)(Phillips, J.) |
| Filing 58 RESPONSE in Opposition re #48 MOTION to Dismiss for Lack of Jurisdiction filed by Eric L. McWilliams(an individual ), McWilliams Collective, LLC(a Florida Limited Liability Company). (Phillips, J.) |
| Filing 57 NOTICE by Global Ocean Agency Lines, L.L.C. re #52 MOTION to Dismiss Plaintiffs' Amended Complaint for Lack of Personal Jurisdiction and Lack of Subject Matter Jurisdiction ; Alternatively MOTION to Compel Alternative Dispute Resolution Notice of Joinder (Borak, Robert) |
| Filing 56 MOTION to Dismiss for Lack of Jurisdiction by Global Ocean Agency Lines, L.L.C. (Borak, Robert) Modified on 10/13/2023 to edit text (ABC). |
| Filing 55 MOTION to Dismiss for Failure to State a Claim by Global Ocean Agency Lines, L.L.C. (Borak, Robert) Modified on 10/13/2023 to edit text (ABC). |
| Filing 54 ANSWER and affirmative defenses with Jury Demand to #47 Amended Complaint , CROSSCLAIM against Airboss Defense Group, LLC by McWilliams Collective, LLC, Eric L. McWilliams.(Phillips, J.) |
| Filing 53 MOTION to Dismiss for Lack of Jurisdiction by Airboss Defense Group, LLC. (Attachments: #1 Exhibit A - Affidavit of Carlos Motta)(Brew, George) |
| Filing 52 MOTION to Dismiss Plaintiffs' Amended Complaint for Lack of Personal Jurisdiction and Lack of Subject Matter Jurisdiction ; Alternatively, MOTION to Compel Alternative Dispute Resolution by Cargo Link International Inc. (Attachments: #1 Exhibit 1 - Declaration of Scott Ogden, #2 Exhibit 2 - Agency Agreement between CLI & GOAL, #3 Exhibit 3 - Agency Agreement between JEMARA & GOAL, #4 Exhibit 4 - GOAL's Regulations for the Conduct of Business)(Marcotte, Daniel) Motions referred to Magistrate Judge Joel B. Toomey. Modified on 10/13/2023 to edit text (ABC). |
| Filing 51 SUMMONS issued as to Cosco Shipping Lines, Co. Ltd. (JK) |
| Filing 50 PROPOSED summons to be issued by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Liang, Shanshan) |
| Filing 49 REQUEST for Judicial Notice in Support; re #48 MOTION to Dismiss Cross-Claim for Lack of Jurisdiction by Airboss Defense Group, LLC. (Attachments: #1 Exhibit Order regarding Defendant's Motion to Transfer Venue)(Brew, George) (Modified on 9/25/2023, to edit text) (BGR). |
| Filing 48 MOTION to Dismiss Cross-Claim of McWilliams Collective, LLC and Eric L. McWilliams Pursuant to FRCP 12(B)(2) for Lack of Jurisdiction; Memorandum of Law; Declaration and Request for Judicial Notice in Support by Airboss Defense Group, LLC. (Attachments: #1 Exhibit Affidavit Carlos Motta)(Brew, George) (Modified on 9/25/2023, to edit text) (BGR). |
| Filing 47 First AMENDED COMPLAINT against Airboss Defense Group, LLC, Cargo Link International Inc., Cosco Shipping Lines, Co. Ltd., Global Ocean Agency Lines, L.L.C., Eric L. McWilliams, McWilliams Collective, LLC with Jury Demand. filed by Jemara International Freight Services Inc., A.M. Cross Trade Logistics Network, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L)(AJS) |
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Filing 46
ORDER granting #43 Plaintiffs' Motion for Leave to File Amended Complaint with directions to the Clerk of Court. All other motions directed to the original complaint (Docs. #12 , #13 , #28 , #32 , #34 , #35 , & #38 ) are DENIED without prejudice as procedurally moot. See Order for details. Signed by Magistrate Judge Joel B. Toomey on 9/21/2023. (KLA) Modified on 9/21/2023 to edit docket text to add links (MDC).
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| Filing 45 NOTICE of Appearance by Alvaro L. Mejer on behalf of A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc. (Mejer, Alvaro) |
| Filing 44 RESPONSE in Opposition re #32 MOTION Limited Jurisdictional Discovery filed by Airboss Defense Group, LLC. (Brew, George) |
| Filing 43 MOTION to Amend #1 Complaint by All Plaintiffs. (Attachments: #1 Exhibit 1 - Proposed Amended Complaint, #2 Complaint Exhibit A, #3 Complaint Exhibit B, #4 Complaint Exhibit C, #5 Complaint Exhibit D, #6 Complaint Exhibit E, #7 Complaint Exhibit F, #8 Complaint Exhibit G, #9 Complaint Exhibit H, #10Complaint Exhibit I, #11 Complaint Exhibit J, #12 Complaint Exhibit K, #13 Complaint Exhibit L)(Liang, Shanshan) Motions referred to Magistrate Judge Joel B. Toomey. Modified to edit docket text on 9/13/2023 (RLK). |
| Filing 42 RESPONSE re #31 Notice to take judicial notice filed by Airboss Defense Group, LLC. (Brew, George) |
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Filing 41
ENDORSED ORDER granting #23 Opposed Motion for Special Admission. Although the Motion indicated it is opposed, the deadline to file a memorandum in opposition has now expired. Therefore, the motion is considered unopposed. If Cameron W. Roberts has not already done so, he shall expeditiously register for a login and password for electronic filing at the Court's website at www.flmd.uscourts.gov. Signed by Magistrate Judge Joel B. Toomey on 9/7/2023. (KLA)
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| Filing 40 ANSWER and affirmative defenses to #1 Complaint with Jury Demand , CROSSCLAIM and Demand for Jury Trial against Airboss Defense Group, LLC by McWilliams Collective, LLC, Eric L. McWilliams.(Phillips, J.) |
| Filing 39 NOTICE of Joinder by Cargo Link International Inc. re #35 MOTION to Dismiss for Lack of Jurisdiction filed by Global Ocean Agency Lines, L.L.C., #34 MOTION to Dismiss for Failure to State a Claim filed by Global Ocean Agency Lines, L.L.C. . (Marcotte, Daniel) (Modified on 8/31/2023, to edit text) (BGR). |
| Filing 38 Amended MOTION to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction, Motion to Dismiss Based on Forum Non Conveniens; Alternatively, Motion to Compel Alternative Dispute Resolution by Cargo Link International Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Marcotte, Daniel) |
| Filing 37 NOTICE of Lead Counsel Designation by J. Trumon Phillips on behalf of Eric L. McWilliams, McWilliams Collective, LLC. Lead Counsel: Brett Ingerman. (Phillips, J.) |
| Filing 36 DEFENDANT, Global Ocean Agency Lines Notice of Joinder to Defendant Cargo Link International Inc's #28 Motion to Compel Alternative Dispute Resolution Agreement (Borak, Robert) Modified on 9/21/2023 to edit docket text(MDC). |
| Filing 35 MOTION to Dismiss for Lack of Jurisdiction Lack of Subject Matter Jurisdiction by Global Ocean Agency Lines, L.L.C.. (Borak, Robert) |
| Filing 34 MOTION to Dismiss for Failure to State a Claim by Global Ocean Agency Lines, L.L.C.. (Borak, Robert) |
| Filing 33 NOTICE of Lead Counsel Designation by Andrew Robert Spector on behalf of Global Ocean Agency Lines, L.L.C.. Lead Counsel: Andrew Spector. (Spector, Andrew) |
| Filing 32 MOTION Limited Jurisdictional Discovery by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) Motions referred to Magistrate Judge Joel B. Toomey. Modified text on 8/29/2023 (BD). |
| Filing 31 NOTICE to the Courts to take judicial notice regarding #28 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss Complaint Based on Forum Non Conveniens; Alternatively MOTION to Compel Alternative Dispute Resolution by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Liang, Shanshan) |
| Filing 30 RESPONSE in Opposition re #13 MOTION to Amend #11 MOTION to Dismiss for Lack of Jurisdiction filed by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Attachments: #1 Exhibit 1, #2 Appendix 2)(Liang, Shanshan) |
| Filing 29 NOTICE of Lead Counsel Designation by Shanshan Liang on behalf of A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. Lead Counsel: Shanshan Liang. (Liang, Shanshan) |
| Filing 28 MOTION to Dismiss for Lack of Jurisdiction , MOTION to Dismiss Complaint Based on Forum Non Conveniens; Alternatively , MOTION to Compel Alternative Dispute Resolution by Cargo Link International Inc.. (Attachments: #1 Exhibit 1 - Declaration of Scott Ogden, #2 Exhibit 2 - Agency Agreement between CLI & GOAL, #3 Exhibit 3 - Agency Agreement between JEMARA & GOAL, #4 Exhibit 4 - GOAL's Regulations for the Conduct of Business)(Mcalpin, Richard) Motions referred to Magistrate Judge Joel B. Toomey. |
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Filing 27
ENDORSED ORDER granting #24 #25 #26 Defendants' Unopposed Motions for Admission Pro Hac Vice, Written Designation and Consent to Act. If Brett Ingerman, Esq., Gaspard Rappoport, Esq., and William W. Reichart, III, have not already done so, they each shall expeditiously register for a login and password for electronic filing at the Court's website at www.flmd.uscourts.gov. Signed by Magistrate Judge Joel B. Toomey on 8/25/2023. (TSP)
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| Filing 26 Unopposed MOTION for William W. Reichart III to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-21184446 for $150 by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 25 Unopposed MOTION for Gaspard Rappoport to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-21184410 for $150 by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 24 Unopposed MOTION for Brett Ingerman to appear pro hac vice $150 Fee Paid per Tracking Id: AFLMDC-21184317 by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 23 MOTION for Cameron W. Roberts to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-21178509 for $150 by Airboss Defense Group, LLC. (Attachments: #1 Exhibit CA Bar Certificate of Good Standing)(Brew, George) Motions referred to Magistrate Judge Joel B. Toomey. |
| Filing 22 NOTICE of Lead Counsel Designation by Richard J. Mcalpin on behalf of Cargo Link International Inc. Lead Counsel: Richard J. McAlpin. (Mcalpin, Richard) Modified on 8/22/2023 (CTR). |
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Filing 21
ENDORSED ORDER granting #19 Defendants McWilliams Collective, LLC and Eric L. McWilliams' Unopposed Motion for Extension of Time to Respond to Complaint. Defendants McWilliams Collective, LLC and Eric L. McWilliams shall have up to and including September 1, 2023 to respond to the Complaint #1 . Signed by Magistrate Judge Joel B. Toomey on 8/18/2023. (TSP)
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| Filing 20 CERTIFICATE of interested persons and corporate disclosure statement by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) |
| Filing 19 Unopposed MOTION for Extension of Time to File Response to Complaint by Eric L. McWilliams, McWilliams Collective, LLC. (Phillips, J.) Motions referred to Magistrate Judge Joel B. Toomey. |
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Filing 18
ENDORSED ORDER granting #15 Defendant, Cargo Link International Inc.'s, Unopposed Motion for Extension of Time to Respond to Plaintiffs' Complaint. The moving Defendant shall have up to and including August 25, 2023 to respond to the Complaint. Signed by Magistrate Judge Joel B. Toomey on 8/16/2023. (KLA)
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| Filing 17 NOTICE TO COUNSEL Miguel A. Manrara of Local Rule 2.01(a), which requires membership or special admission in the Middle District bar to practice in the Middle District, except for the limited exceptions identified in the Rule. To apply for membership in the Middle District, visit www.flmd.uscourts.gov/for-lawyers. (Signed by Deputy Clerk). (AJS) |
| Filing 16 NOTICE TO COUNSEL Shanshan Liang of Local Rule 2.02(a), which states, "The first paper filed on behalf of a party must designate only one lead counsel who - unless the party changes the designation - remains lead counsel throughout the action." Counsel must file a Notice of Lead Counsel Designation identifying lead counsel. (Signed by Deputy Clerk). (AJS) |
| Filing 15 Unopposed MOTION for Extension of Time to File Answer re #1 Complaint by Cargo Link International Inc. (Marcotte, Daniel) Motions referred to Magistrate Judge Joel B. Toomey. Modified on 8/16/2023 to edit docket text(AJS). |
| Filing 14 NOTICE of Appearance by Daniel S. Marcotte on behalf of Cargo Link International Inc. (Marcotte, Daniel) |
| Filing 13 AMENDED MOTION to Dismiss for Lack of Personal Jurisdiction and Memorandum of Law in Support by Airboss Defense Group, LLC. (Brew, George) Motions referred to Magistrate Judge Joel B. Toomey. (Modified on 8/15/2023, to edit text) (BGR). |
| Filing 12 REQUEST for Oral Argument and Evidentiary Hearing re #11 MOTION to Dismiss by Airboss Defense Group, LLC. (Brew, George) Modified text on 8/15/2023 (BD). |
| Filing 11 MOTION to Dismiss for Lack of Jurisdiction by Airboss Defense Group, LLC. (Attachments: #1 Affidavit Affidavit of Carlos Motta)(Brew, George) (Modified on 8/15/2023, filed in error per counsel. See doc #13 for refiled motion. ) (BGR). |
| Filing 10 NOTICE of Appearance by George Kellen Brew on behalf of Airboss Defense Group, LLC (Brew, George) |
| Filing 9 NOTICE of Local Rule 3.02(a)(2), which requires the parties in every civil proceeding, except those described in subsection (d), to file a case management report (CMR) using the uniform form at www.flmd.uscourts.gov. The CMR must be filed (1) within forty days after any defendant appears in an action originating in this court, (2) within forty days after the docketing of an action removed or transferred to this court, or (3) within seventy days after service on the United States attorney in an action against the United States, its agencies or employees. Judges may have a special CMR form for certain types of cases. These forms can be found at www.flmd.uscourts.gov under the Forms tab for each judge. (Signed by Deputy Clerk). (CKS) |
| Filing 8 SUMMONS issued as to Airboss Defense Group, LLC, Cargo Link International Inc., Global Ocean Agency Lines, L.L.C., McWilliams Collective, LLC. (LD) |
| Filing 7 PROPOSED summons to be issued by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 6 PROPOSED summons to be issued by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 5 PROPOSED summons to be issued by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 4 PROPOSED summons to be issued by A.M. Cross Trade Logistics Network, Inc., Jemara International Freight Services Inc.. (Liang, Shanshan) |
| Filing 3 SUMMONS issued as to Eric L. McWilliams. (BGR) |
| Filing 2 NEW CASE ASSIGNED to Judge Brian J. Davis and Magistrate Judge Joel B. Toomey. New case number: 3:23-cv-838-BJD-JBT. (AM) |
| Filing 1 COMPLAINT against All Defendants (Filing fee $402 receipt number AFLMDC-21052124) filed by All Plaintiffs. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Civil Cover Sheet, #13 Proposed Summons, #14 Proposed Summons, #15 Proposed Summons, #16 Proposed Summons, #17 Proposed Summons)(Liang, Shanshan) (Modified on 7/19/2023, counsel notified to correct and refile summons in order to be issued) (BGR). |
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