Litigation Lawyers, Professional Association v. Harbison et al
| Litigation Lawyers, Professional Association |
| Christopher Harbison and Regina Harbison |
| 4:2024cv00793 |
| June 6, 2024 |
| US District Court for the Eastern District of Missouri |
| Rodney H Holmes |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity-Breach of Contract |
| None |
Docket Report
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This docket was last retrieved on June 6, 2024. A more recent docket listing may be available from PACER.
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| Filing 50 Pursuant to Local Rule 2.08, the assigned/referred magistrate judge is designated and authorized by the court to exercise full authority in this assigned/referred action or matter under 28 U.S.C. Sec. 636 and 18 U.S.C Sec. 3401, including any case budgeting matters. (auto) |
| Filing 49 Petition (Removal/Transfer) Received From: Circuit of Broward County Florida, filed by Litigation Lawyers, Professional Association. (Attachments: #1 Exhibit A, #2 Exhibit B)(JBH) |
| Filing 48 Case transferred in from District of Florida Southern; Case Number 0:24-cv-60305. Original file certified copy of transfer order and docket sheet received. Case transferred in electronically. |
Filing 47
ORDER: Because six factors weigh in favor of transfer, three factors are neutral, and no factors weight in favor of retaining the case, it is hereby ORDERED AND ADJUDGED that the Clerk of Court SHALL transfer this case tothe United States District Court for the Eastern District of Missouri. Closing Case. Signed by Judge Raag Singhal on 6/6/2024. See attached document for full details. (scn)
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| Filing 46 Consent MOTION for Extension of Time to serve Defendants and re #44 Plaintiff's MOTION for Extension of Time to serve Defendants and Motion to Determine that the Defendants Have Waived the Objection of Failure to Serve Process by Not Raising It In Their Motion To Dismiss and Seeking to Transfer Venue For Conven by Christopher Harbison, Regina Harbison. Responses due by 6/20/2024. (McCoy, Kevin) |
| Case Opening Notification. Judge Assigned: Honorable Rodney H. Holmes. All parties must file the Notice Regarding Magistrate Judge Jurisdiction Form consenting to or opting out of the Magistrate Judge jurisdiction. Click #here for the instructions. Pursuant to Local Rule 2.09, every nongovernmental corporate party or nongovernmental corporation that seeks to intervene in any case, and every party or intervenor in an action in which jurisdiction is based upon diversity, must file a Disclosure Statement immediately upon entering its appearance in the case. Please complete and file the certificate as soon as possible. # (moed-0001.pdf). Per Local Rule 12.01, attorneys who are not admitted to the Eastern District of Missouri do not need to apply for admission pro hac vice in order to practice on a case if they had already filed an entry of appearance before the case was transferred from another United States District Court. For more information, visit #attorney applications. (JBH) |
| Filing 45 MOTION to Quash or Alternatively to Strike Summons by Christopher Harbison, Regina Harbison. (Attachments: #1 Affidavit Christerpher Harbison, #2 Affidavit Regina Harbison)(McCoy, Kevin) |
| Filing 44 Plaintiff's MOTION for Extension of Time to serve Defendants and Motion to Determine that the Defendants Have Waived the Objection of Failure to Serve Process by Not Raising It In Their Motion To Dismiss and Seeking to Transfer Venue For Convenience by Litigation Lawyers, Professional Association. Responses due by 6/6/2024. (Attachments: #1 Affidavit Affidavit of Dylan Stricklin, #2 Affidavit Affidavit of Angela Heath, #3 Affidavit Affidavit of Stephen Rakusin)(Amir, Ofer) |
| Filing 43 Plaintiff's NOTICE Of Service of Secretary of State Letter of Acceptance of Substituted Service of Process, Complaint, Summonses and Requests to Produce by Litigation Lawyers, Professional Association (Attachments: #1 Exhibit Acceptance letter from Secretary of State for Christerphor Harbison, #2 Exhibit Acceptance letter from Secretary of State for Regina Harbison, #3 Exhibit Complaint (With Exhibits), #4 Exhibit State Court Summons, Dated October 4, 2024, for Christerphor Harbison, #5 Exhibit State Court Summons, Dated October 4, 2024, for Regina Harbison, #6 Exhibit Federal Court Summons, Dated February 24, 2024, for Christerphor Harbison, #7 Exhibit Federal Court Summons, Dated February 24, 2024, for Regina Harbison, #8 Exhibit Secretary of State (in care of) Summons, Dated May 16, 2024, for Christerphor Harbison, #9 Exhibit Secretary of State (in care of) Summons, Dated May 16, 2024, for Regina Harbison, #10 Exhibit Request to Produce to Christerphor Harbison, #11 Exhibit Request to Produce to Regina Harbison) (Amir, Ofer) |
| Filing 42 Summons Issued as to REGINA HARBISON. (scn) |
| Filing 41 Summons Issued as to CHRISTOPHER HARBISON. (scn) |
| Filing 40 NOTICE of Filing Proposed Summons(es) for Defendants in care of the Secretary of State by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer) |
| Filing 39 NOTICE of Filing Proposed Summons(es) for Defendant in care of the Secretary of State by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer) |
| Filing 38 NOTICE of Supplementing Exhibit by CHRISTOPHER HARBISON, REGINA HARBISON re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), (McCoy, Kevin) |
| Filing 37 First STIPULATED MOTION for Substitution of Counsel. Substituting Ofer M. Amir, Esq. for Ofer M. Amir, Esq. of the Amir Law Firm, P.A. by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 5/28/2024. (Attachments: #1 Text of Proposed Order Proposed Order)(Amir, Ofer) |
| Filing 36 Plaintiff's REPLY to #34 Response in Opposition to Motion,, motion to strike by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Amir, Ofer) |
| Filing 35 Plaintiff's REPLY to #33 Response in Opposition to Motion,, motion to strike by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Amir, Ofer) |
| Filing 34 RESPONSE in Opposition re #31 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #32 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/30/2024. (McCoy, Kevin) |
| Filing 33 RESPONSE in Opposition re #31 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #32 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), , #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/30/2024. (McCoy, Kevin) |
| Filing 32 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 5/1/2024. (Amir, Ofer) |
| Filing 31 Amended MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 5/1/2024. (Amir, Ofer) |
| Filing 30 NOTICE OF WITHDRAWAL OF MOTION by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION re #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION, #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer) |
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Filing 29
PAPERLESS ORDER granting #28 Motion for Extension of Time to File Reply to Motion. Reply is due by 4/18/2024. Signed by Judge Raag Singhal on 4/15/2024. (jgr)
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| Filing 28 First MOTION for Extension of Time to File Response/Reply/Answer as to #26 Response in Opposition to Motion, #27 Response in Opposition to Motion, For Plaintiff by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Amir, Ofer) |
| Filing 27 RESPONSE in Opposition re #21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), Opposition to Plaintiff's Motion to Strike Portions of Defendants' Motion to Dismiss and Supporting Memorandum of Law filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/12/2024. (McCoy, Kevin) |
| Filing 26 RESPONSE in Opposition re #22 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by CHRISTOPHER HARBISON, REGINA HARBISON. Replies due by 4/12/2024. (McCoy, Kevin) |
| Filing 25 REPLY to #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), Defendants' Reply in Support of their Motion to Dismiss for Lack of Personal Jurisdiction or in the Alternative, to Transfer, and Memorandum of Law by CHRISTOPHER HARBISON, REGINA HARBISON. (McCoy, Kevin) |
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Filing 24
PAPERLESS ORDER granting #23 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney R. Thomas Avery. Mr. Avery may appear and participate in this action onbehalf of Defendants Christopher Harbison and Regina Harbison. Signed by Judge Raag Singhal on 3/26/2024. (jgr)
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| Filing 23 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for R. Thomas Avery. Filing Fee $ 200.00 Receipt # AFLSDC-17395025 by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 4/8/2024. (Attachments: #1 Exhibit A, #2 Exhibit B)(McCoy, Kevin) |
| Filing 22 (WITHDRAWN PER DE#30) First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 4/5/2024. (Amir, Ofer) Modified text on 4/18/2024 (scn). |
| Filing 21 First MOTION to Strike #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 4/5/2024. (Amir, Ofer) |
| Filing 20 RESPONSE in Opposition re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Replies due by 3/29/2024. (Amir, Ofer) |
| Filing 19 AFFIDAVIT in Opposition re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. (Attachments: #1 Exhibit Contract, #2 Exhibit Billing, #3 Exhibit Additional Billing, #4 Exhibit Federal Court Chart, #5 Exhibit Federal Court Chart, #6 Exhibit Articles of Incorporation, #7 Exhibit Emails, #8 Exhibit Emails, #9 Exhibit Checks and Shipping)(Amir, Ofer) |
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Filing 18
PAPERLESS ORDER granting #17 Motion for Extension of Time. Plaintiff shall have until 3/22/2024 to file a response to Defendants' Motion to Dismiss. Signed by Judge Raag Singhal on 3/15/2024. (jgr)
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| Filing 17 First MOTION for Extension of Time Respond to Motion to Dismiss by Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. Responses due by 3/28/2024. (Amir, Ofer) |
| Filing 16 Civil Complaint Cover Sheet by United States Attorney (Amir, Ofer) |
| Filing 15 Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by CHRISTOPHER HARBISON, REGINA HARBISON (McCoy, Kevin) |
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Filing 14
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 3/4/2024. (jgr)
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| Filing 13 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).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).Exhibits to pleadings and motions shall be docketed in accordance with the Courts 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.) 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 3/4/2024. (jgr) |
| Filing 12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint), by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 3/15/2024. (Attachments: #1 Exhibit Ex. 1 Rakusin Ref Report, #2 Exhibit Ex. 2 Declaration of Schwartz, #3 Exhibit Ex. 3 Declaration of R. Harbison)(McCoy, Kevin) |
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Filing 11
PAPERLESS ORDER granting #9 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Aaron E. Schwartz. Signed by Judge Raag Singhal on 3/1/2024. (pb00)
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| Filing 10 NOTICE of Filing Proposed Order by CHRISTOPHER HARBISON, REGINA HARBISON re #9 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Aaron E. Schwartz. Filing Fee $ 200.00 Receipt # AFLSDC-17335093 (Attachments: #1 Text of Proposed Order Proposed Order) (McCoy, Kevin) |
| Filing 9 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Aaron E. Schwartz. Filing Fee $ 200.00 Receipt # AFLSDC-17335093 by CHRISTOPHER HARBISON, REGINA HARBISON. Responses due by 3/15/2024. (Attachments: #1 Exhibit Certification of Aaron E. Schwartz)(McCoy, Kevin) |
| Filing 8 NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. All Parties. (Attachments: #1 Summon(s) Summons, #2 Exhibit Complaint, #3 Exhibit Request to Produce, #4 Exhibit Request to Produce, #5 Exhibit Waiver of service)(Amir, Ofer) Modified text on 2/29/2024 (scn). |
| Filing 7 NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS filed by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION. All Parties. (Attachments: #1 Summon(s) Summons, #2 Exhibit Complaint, #3 Exhibit Request to Produce, #4 Exhibit Request to Produce, #5 Exhibit Waiver of Service)(Amir, Ofer) Modified text on 2/29/2024 (scn). |
| Filing 6 Summons Issued as to CHRISTOPHER HARBISON, REGINA HARBISON. (scn) |
| Filing 5 NOTICE of Filing Proposed Summons(es) for Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer) |
| Filing 4 NOTICE of Filing Proposed Summons(es) for Defendants by LITIGATION LAWYERS, PROFESSIONAL ASSOCIATION (Amir, Ofer) |
| Filing 3 Bar Letter re: Admissions sent to attorney R. Thomas Avery and Aaron E. Schwartz, mailing date February 23, 2024, (pt) |
| 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 Jared M. Strauss 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. (wce) |
| Filing 1 NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 405.00 receipt number AFLSDC-17316106, filed by REGINA HARBISON, CHRISTOPHER HARBISON. (No Answer/ Motion to Dismiss Filed)(Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B, #4 Docket Sheet Docket Sheet)(McCoy, Kevin) Modified Text on 2/23/2024 (wce). |
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