Prezerv Technologies, Inc. v. Morari et al
Prezerv Technologies, Inc. |
Alessandro Morari, Giacomo Domeniconi, Solidium AI, Inc. and Bartolomeo Garafolo |
1:2021cv11918 |
November 29, 2021 |
US District Court for the District of Massachusetts |
F Dennis Saylor |
Contract: Other |
28 U.S.C. § 1441 |
Plaintiff |
Docket Report
This docket was last retrieved on January 26, 2022. A more recent docket listing may be available from PACER.
Document Text |
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Filing 40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM the Second Amended Complaint, MOTION to Dismiss for Lack of Jurisdiction the Second Amended Complaint ( Responses due by 2/9/2022) by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Attachments: #1 Memorandum of Law, #2 Cert of Defendant Morari, #3 Cert Defendant of Domeniconi, #4 Text of Proposed Order)(Brinen, Joshua) |
Filing 39 NOTICE OF ATTORNEY PAYMENT OF FEES as to #28 Notice of Interlocutory Appeal,,,, 30 USCA Case Number, #29 Abbreviated Electronic Record on Appeal Sent to USCA by Defendants Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. Filing fee $ 505, receipt number AMADC-9140302. Payment Type : APPEAL. (Badway, Ernest) |
Filing 38 Chief Judge F. Dennis Saylor, IV: ORDER entered. Order for the Production and Exchange of Discovery Material. (Attachments: #1 Exhibit A)(McKillop, Matthew) |
Filing 37 Electronic Clerk's Notes for proceedings held before Chief Judge F. Dennis Saylor, IV: Status Conference held by video on 1/12/2022. Case called; Status discussed; Protective Order to issue. NOTICE OF HEARING: Status Conference set for 2/2/2022 11:00 AM in Remote Proceeding : Boston before Chief Judge F. Dennis Saylor IV. This hearing will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the session's courtroom deputy as soon as possible.Access to the hearing will be made available to the media and public. In order to gain access to the hearing, you must sign up at the following address: #https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on #www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Court Reporter: Valerie OHara at vaohara@gmail.com.)(Attorneys present: William F. McGonigle, III and Raymond P. Ausrotas for the plaintiff. Mark Eamon White for the defendants.) (McKillop, Matthew) |
Filing 36 NOTICE by Prezerv Technologies, Inc. Re: Proposed Protective Orders (Attachments: #1 Exhibit Ex. 1 - Defs' Initial Proposed Order, #2 Exhibit Ex. 2 - Pl's Redlines, #3 Exhibit Ex. 3 - Defs' New Terms, #4 Text of Proposed Order Ex. 4 - Proposed Order)(McGonigle, William) |
Filing 33 AMENDED COMPLAINT against All Defendants, filed by Prezerv Technologies, Inc.. (Attachments: #1 Exhibit Ex. 1 - Bylaws, #2 Exhibit Ex. 2 - Board Consent, #3 Exhibit Ex. 3 - Board Action, #4 Exhibit Ex. 4 - Morari NDA, #5 Exhibit Ex. 5 - Domeniconi NDA, #6 Exhibit Ex. 6 - Stock Agreement, #7 Exhibit Ex. 7 - Garofalo NDA, #8 Exhibit Ex. 8 - Spencer Aff., #9 Exhibit Ex. 9 - Solidium, #10 Supplement Redline Comparison)(McGonigle, William) |
Filing 35 NOTICE is hereby given that an official transcript of a proceeding has been filed by the court reporter in the above-captioned matter. Counsel are referred to the Court's Transcript Redaction Policy, available on the court website at #http://www.mad.uscourts.gov/attorneys/general-info.htm (Coppola, Katelyn) |
Filing 34 Transcript of Motion Hearing held on December 7, 2021, before Chief Judge F. Dennis Saylor IV. The Transcript may be purchased through the Court Reporter, viewed at the public terminal, or viewed through PACER after it is released. Court Reporter Name and Contact Information: Valerie OHara at vaohara@gmail.com. Redaction Request due 1/25/2022. Redacted Transcript Deadline set for 2/4/2022. Release of Transcript Restriction set for 4/4/2022. (Coppola, Katelyn) |
Filing 32 Electronic Clerk's Notes for proceedings held before Chief Judge F. Dennis Saylor, IV: Status Conference held by video on 1/4/2022. Case called; Court Denied without prejudice as moot #21 Motion to Dismiss for Failure to State a Claim/Motion to Dismiss for Lack of Jurisdiction. New Amended Complaint to be filed by the close of business on 1/7/22. Counsel to negotiate Proposed Protective Order before next hearing. NOTICE OF HEARING: Status Conference set for 1/12/2022 11:00 AM in Remote Proceeding : Boston before Chief Judge F. Dennis Saylor IV. This hearing will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the session's courtroom deputy as soon as possible.Access to the hearing will be made available to the media and public. In order to gain access to the hearing, you must sign up at the following address: #https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on #www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Court Reporter: Valerie OHara at vaohara@gmail.com.)(Attorneys present: William F. McGonigle, III and Raymond P. Ausrotas for the plaintiff. Mark Eamon White for the defendants.) (McKillop, Matthew) |
Filing 31 AMENDED COMPLAINT against All Defendants, filed by Prezerv Technologies, Inc.. (Attachments: #1 Exhibit Ex. 1 - Morari NDA, #2 Exhibit Ex. 2 - Domeniconi NDA, #3 Exhibit Ex. 3 - Morari Stock Agreement, #4 Exhibit Ex. 4 - Garofalo NDA, #5 Exhibit Ex. 5 - Spencer Aff., #6 Exhibit Ex. 6 - Solidium Cert.)(McGonigle, William) |
Filing 30 USCA Case Number 22-1013 for #28 Notice of Interlocutory Appeal, filed by Giacomo Domeniconi, Solidium AI, Inc., Alessandro Morari. (Paine, Matthew) |
Filing 29 Certified and Transmitted Abbreviated Electronic Record on Appeal to US Court of Appeals re #28 Notice of Interlocutory Appeal. (Paine, Matthew) |
Filing 28 NOTICE OF INTERLOCUTORY APPEAL as to #15 Preliminary Injunction by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. ( (Fee Status: Filing Fee - NOT PAID)) NOTICE TO COUNSEL: A Transcript Report/Order Form, which can be downloaded from the First Circuit Court of Appeals web site at #http://www.ca1.uscourts.gov MUST be completed and submitted to the Court of Appeals. Counsel shall register for a First Circuit CM/ECF Appellate Filer Account at #http://pacer.psc.uscourts.gov/cmecf. Counsel shall also review the First Circuit requirements for electronic filing by visiting the CM/ECF Information section at #http://www.ca1.uscourts.gov/efiling.htm. US District Court Clerk to deliver official record to Court of Appeals by 1/19/2022. (Badway, Ernest) Modified on 12/31/2021 to Correct Filing Fee Status. Filing Fee Was NOT PAID. (Paine, Matthew). |
Filing 27 STATUS REPORT by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Brinen, Joshua) |
Filing 26 STATUS REPORT by Prezerv Technologies, Inc.. (McGonigle, William) |
Filing 25 Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #24 Assented to MOTION for Extension of Time to Jan. 14, 2022 to Oppose Motion to Dismiss (McKillop, Matthew) |
Filing 24 Assented to MOTION for Extension of Time to Jan. 14, 2022 to Oppose Motion to Dismiss by Prezerv Technologies, Inc..(McGonigle, William) |
Filing 23 Chief Judge F. Dennis Saylor, IV: ORDER entered. MODIFIED PRELIMINARY INJUNCTION. (McKillop, Matthew) |
Filing 22 MEMORANDUM in Support re #21 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction filed by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Attachments: #1 Exhibit A Certification of Morari, #2 Exhibit B Certification of Domeniconi)(McManus, Caetlin) |
Filing 21 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction ( Responses due by 12/29/2021) by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Attachment #1 Proposed Order)(Brinen, Joshua) (Attachment 1 replaced on 12/15/2021) (McManus, Caetlin). Modified on 12/15/2021 to separate Memo in Support and Exhibits from Motion (McManus, Caetlin). |
Filing 20 Electronic Clerk's Notes for proceedings held before Chief Judge F. Dennis Saylor, IV: Status Conference held by video on 12/13/2021. Case called; Status discussed. Modified Preliminary Injunction Order to issue. Counsel to notify clerk if they would like to set a Status Conference. ORDERED DEADLINES:Report regarding status of authorizations due by 12/21/21. Production of documents to be exchanged by 12/23/21. Final Production and initial disclosures to be completed 1/5/22. Depositions to begin after 1/24/22. Discovery cut off 3/1/22. Motions for Summary Judgment deadline 3/21/22. NOTICE OF HEARING: Status Conference set for 1/4/2022 10:00 AM by video before Chief Judge F. Dennis Saylor IV. This hearing will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the session's courtroom deputy as soon as possible.Access to the hearing will be made available to the media and public. In order to gain access to the hearing, you must sign up at the following address: #https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on #www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Court Reporter: Valerie OHara at vaohara@gmail.com.)(Attorneys present: William F. McGonigle, III and Raymond P. Ausrotas for the plaintiff. Mark White for the defendants.) (McKillop, Matthew) |
Filing 19 Objection to #17 Proposed Document(s) submitted by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. with Respect to Proposed Preliminary Injunction. (Attachments: #1 Exhibit electronically stored discovery Consultant)(Brinen, Joshua) |
Filing 18 NOTICE of Appearance by Mark Eamon White on behalf of Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. (White, Mark) |
Filing 17 Proposed Document(s) submitted by Prezerv Technologies, Inc.. Document received: Proposed Preliminary Injunction Order. (McGonigle, William) |
Filing 16 NOTICE of Appearance by Joshua Brinen on behalf of Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. (Brinen, Joshua) |
Filing 15 Chief Judge F. Dennis Saylor, IV: ORDER entered. PRELIMINARY INJUNCTION. (McKillop, Matthew) |
Filing 14 Electronic Clerk's Notes for proceedings held before Chief Judge F. Dennis Saylor, IV: Hearing re Preliminary Injunction held by video on 12/7/2021. Case called; arguments heard. Preliminary Injunction Order to follow. Plaintiff to submit revised proposed order by the close of business on 12/8/21. Defendants to file objections or alternate proposal by 12:00 PM on 12/10/21. NOTICE OF HEARING: Status Conference set for 12/13/2021 05:30 PM in Remote Proceeding : Boston before Chief Judge F. Dennis Saylor IV. This hearing will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the session's courtroom deputy as soon as possible.Access to the hearing will be made available to the media and public. In order to gain access to the hearing, you must sign up at the following address: #https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on #www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Court Reporter: Valerie OHara at vaohara@gmail.com.)(Attorneys present: William F. McGonigle, III and Raymond P. Ausrotas for the plaintiff. Mark White for the defendants.) (McKillop, Matthew) |
Filing 13 NOTICE of Appearance by Ernest E. Badway on behalf of Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. (Badway, Ernest) |
Filing 12 NOTICE of Appearance by Ernest E. Badway on behalf of Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. (Badway, Ernest) |
Filing 11 Reply in Support of its Motion for Preliminary Injunction by Prezerv Technologies, Inc. (Attachments: #1 Affidavit Ex. 1 - Raufi Aff., #2 Exhibit Ex. 2, #3 Exhibit Ex. 3, #4 Exhibit Ex. 4, #5 Exhibit Ex. 5, #6 Exhibit Ex. 6, #7 Exhibit Ex. 7, #8 Exhibit Ex. 8)(McGonigle, William) Modified on 12/6/2021 to correct docket text (McManus, Caetlin). |
Filing 10 Response by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. to #1 Notice of Removal, MEMORANDUM OF LAW IN OPPOSITION TO PLAINTIFFS MOTIONS FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION. (Attachments: #1 Affidavit of Solidium AI, Inc., #2 Exhibit A - Formation Documents, #3 Affidavit of Giacomo Domeniconi, #4 Exhibit A - Board Consent, #5 Exhibit B - NDA, #6 Exhibit C - Termination Letter, #7 Exhibit D - Bank Statement, #8 Affidavit of Alessandro Morari, #9 Exhibit A - NDA, #10 Exhibit B - Screenshot, #11 Exhibit C - Termination Letter, #12 Exhibit D - Bylaws, #13 Exhibit E - Restricted Stock Agreement, #14 Exhibit F - Forfeiture Notice, #15 Exhibit G - Proof of Investment)(Badway, Ernest) |
Filing 9 Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #7 Motion for Leave to Appear Pro Hac Vice Added Joshua D. Brinen. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at # https://pacer.uscourts.gov/register-account.Pro Hac Vice Admission Request Instructions # https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) |
Filing 8 Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #6 Motion for Leave to Appear Pro Hac Vice Added Mark E. White. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at # https://pacer.uscourts.gov/register-account.Pro Hac Vice Admission Request Instructions # https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (McManus, Caetlin) |
Filing 7 MOTION for Leave to Appear Pro Hac Vice for admission of Joshua D. Brinen, Esq. Filing fee: $ 100, receipt number AMADC-9077382 by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Attachments: #1 Exhibit - Certificate of Good Standing)(Badway, Ernest) (Main Document 7 replaced after proposed order removed from PDF on 12/1/2021) (McManus, Caetlin). (Additional attachment(s) added on 12/1/2021: #3 Text of Proposed Order) (McManus, Caetlin). |
Filing 6 MOTION for Leave to Appear Pro Hac Vice for admission of Mark E. White, Esq. Filing fee: $ 100, receipt number AMADC-9077035 by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc.. (Attachments: #1 Exhibit Certificates of Good Standing)(Badway, Ernest) (Main Document 6 replaced after proposed order removed from PDF on 12/1/2021) (McManus, Caetlin). (Additional attachment(s) added on 12/1/2021: #2 Text of Proposed Order) (McManus, Caetlin). |
Filing 5 Electronic Clerk's Notes for proceedings held before Chief Judge F. Dennis Saylor, IV: Status Conference held by telephone on 11/30/2021. Case called; Status discussed; Opposition or further filings due by close of business on 12/3/21. If defendants file by close of business on 12/3/21. Plaintiff counsel to have until 12/6/21 to file response. NOTICE OF HEARING: Preliminary Injunction Hearing set for 12/7/2021 11:00 AM in Remote Proceeding : Boston before Chief Judge F. Dennis Saylor IV. This hearing will be conducted by video conference. Counsel of record will receive a video conference invite at the email registered in CM/ECF. If you have technical or compatibility issues with the technology, please notify the session's courtroom deputy as soon as possible.Access to the hearing will be made available to the media and public. In order to gain access to the hearing, you must sign up at the following address: #https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on #www.mad.uscourts.gov or contact media@mad.uscourts.gov. (Court Reporter: Valerie OHara at vaohara@gmail.com.)(Attorneys present: William F. McGonigle, III and Raymond P. Ausrotas for the plaintiff. Mark White for the defendants.) (McKillop, Matthew) |
Filing 4 ELECTRONIC NOTICE of Hearing: Status Conference set for 11/30/2021 03:45 PM in Remote Proceeding : Boston before Chief Judge F. Dennis Saylor IV. This hearing shall be conducted remotely, by telephone only. Counsel of record will receive dial-in instructions at the email registered in CM/ECF. Access to the hearing will be made available to the media and public by way of teleconference. In order to gain access to the hearing via teleconference you must sign up at the following address: #https://https://forms.mad.uscourts.gov/courtlist.html. For questions regarding access to hearings, you may refer to the Court's general orders and public notices available on www.mad.uscourts.gov or contact www.media@uscourts.gov. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violations of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, or denial of entry to future hearings, and such other sanctions, including for contempt of court, as may be deemed appropriate or necessary by the court.(McKillop, Matthew) |
Filing 3 Certified Copy of Notice of Removal Provided to Defense Counsel by Email (Warnock, Douglas) |
Filing 2 ELECTRONIC NOTICE of Case Assignment. Chief Judge F. Dennis Saylor, IV assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Jennifer C. Boal. (Finn, Mary) |
Filing 1 NOTICE OF REMOVAL by Giacomo Domeniconi, Alessandro Morari, Solidium AI, Inc. ( Filing fee: $ 402, receipt number AMADC-9073277 Fee Status: Filing Fee paid) (Attachments: #1 Civil Cover Sheet, #2 Category Form, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit)(Badway, Ernest) |
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