LASSOFF v. HARD ROCK CAFE INTERNATIONAL (USA) INC et al
| SAMUEL J. LASSOFF |
| HARD ROCK CAFE INTERNATIONAL (USA) INC, HARD ROCK HOTEL AND CASINO ATLANTIC CITY, SEMINOLE HARD ROCK SUPPORT SERVICES, LLC, HARD ROCK INTERNATIONAL INC., BOARDWALK 1000, LLC d/b/a HARD ROCK HOTEL & CASINO ATLANTIC CITY; and BOARDWALK 1000, LLC doing business as HARD ROCK HOTEL & CASINO ATLANTIC CITY |
| 1:2023cv12407 |
| August 29, 2023 |
| US District Court for the District of New Jersey |
| Renee Marie Bumb |
| Elizabeth A Pascal |
| Other Fraud |
| 28 U.S.C. § 1332 Diversity-Fraud |
| Plaintiff |
Docket Report
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Filing 28
TEXT ORDER This matter comes before the Court upon the pre-motion letters from Plaintiff Samuel Lassoff and Defendants Seminole Hard Rock Support Services, LLC, Hard Rock International, Inc., Hard Rock Cafe International (USA), Inc. and Boardwalk 1000 LLC d/b/a Hard Rock Hotel & Casino Atlantic City (collectively, "Defendants") [Docket Nos. 17, 27], concerning a proposed motion to dismiss by Defendants. Given the Court's concerns, including the adequacy of Plaintiff's responses to the merits of Defendants' pre-motion letter, the Court will hold an in-person pre-motion conference on Thursday November 9, 2023, at 1:30 p.m., in Courtroom 3D in of the Mitchell H. Cohen Courthouse, 4th and Cooper Streets, Camden, New Jersey 08101. So Ordered by Chief Judge Renee Marie Bumb on 10/17/2023. (Costigan, Roberta)
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| Filing 27 Letter from PLAINTIFF(S) COUNSEL TO HONORABLE CHIEF JUDGE RENEE MARIE BUMB re 25 Order,,,,,,, 21 Order,,,. (LASSOFF, SAMUEL) |
| Filing 26 Letter from PLAINTIFF(S) RE AMENDED COMPLAINT. (LASSOFF, SAMUEL) |
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Filing 25
TEXT ORDER This matter comes before the Court upon the two identical pre-motion letters filed by Plaintiff Samuel Lassoff ("Plaintiff") on October 14, 2023, [Docket Nos. 2324] in response to this Court's October 11, 2023, Text Order [Docket No. 21] directing Plaintiff to show cause as to why he failed to timely respond to the pre-motion letter filed by Defendants Seminole Hard Rock Support Services, LLC, Hard Rock International, Inc., Hard Rock Cafe International (USA), Inc. (collectively, "Defendants") as required by Rule I.A of this Court's Individual Rules and Procedures [Docket No. 16]. This Court's Individual Rules and Procedures, linked in the prior Text Order, specifies that any response to a pre-motion letter seeking leave to file a motion to dismiss shall not exceed three (3) single-spaced pages and that affidavits and exhibits are not permitted unless directed by the Court. Instead of complying with the Court's prior order and its Individual Rules and Procedures, Plaintiff filed a twelve-page single-spaced letter as well as a seemingly irrelevant exhibit in support of his argument that counsel for Defendants is conflicted in this case. The Court will not sift through Plaintiff's unacceptable filings. It is hereby ORDERED that Plaintiff shall show cause by no later than October 20, 2023, in a letter of no more than three (3) pages setting forth why (i) Plaintiff failed to timely respond to Defendants' pre-motion letter; (ii) the specific relief Defendants' seek should not be grantedthat is, why Plaintiff named the proper Defendants and why the New Jersey Casino Control Act and its regulations do not prevent relief; and (iii) Plaintiff failed to comply with this Court's October 11, 2023, Text Order. So Ordered by Chief Judge Renee Marie Bumb on 10/16/2023. (Costigan, Roberta)
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| Filing 24 Letter from PLAINTIFF(S) RE JUDGE RENEE BUMBS 10/11/23 TEXT ORDER re #18 Request for Clerk's Entry of Default, #16 Letter, #20 Order, #11 Summons Returned Executed, #17 Letter, #22 Notice of Voluntary Dismissal (aty), 21 Order,,,. (LASSOFF, SAMUEL) |
| Filing 23 Letter from Plaintiff(s) re Judge Renee Bumbs 10/11/23 TEXT ORDER re #18 Request for Clerk's Entry of Default, #19 Response (NOT Motion), #16 Letter, #20 Order, #11 Summons Returned Executed, #17 Letter, #22 Notice of Voluntary Dismissal (aty), 21 Order,,, #15 Application for Clerk's Order to Ext Answer/Proposed Order,. (Attachments: #1 Exhibit Additional Proof of Conflict of Interest & Disqualification of Defendants counsel Fox Rothchild LLP)(LASSOFF, SAMUEL)NOTICE TO COUNSEL: Counsel is advised that pursuant to Local Civil Rule 5.3(c)(2), a single, consolidated motion to seal shall be filed within 14 days following the completed briefing of the materials sought to be sealed, or within 14 days following the date on which the last of such materials was filed under temporary seal if the motion is resolved, unless otherwise directed by the Court. |
| Filing 22 NOTICE of Voluntary Dismissal of DEFENDANT HARD ROCK CAFE INTERNATIONAL (USA) INC. ONLY without prejudice by SAMUEL J. LASSOFF (LASSOFF, SAMUEL) |
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Filing 21
TEXT ORDER This matter comes before the Court upon the pre-motion letter filed by Defendants Seminole Hard Rock Support Services, LLC, Hard Rock International, Inc., Hard Rock Cafe International (USA), Inc. (collectively, "Defendants") on October 2, 2023. [Docket No. 16.] Plaintiff Samuel Lassoff ("Plaintiff") has failed to address Defendants' letter within seven (7) days as required by Rule I.A of this Court's Individual Rules and Procedures, available at https://www.njd.uscourts.gov/sites/njd/files/ProceduresJudgeReneeMarieBumb.pdf. It is hereby ORDERED that Plaintiff shall show cause by no later than October 16, 2023, why he has failed to timely respond AND why the relief Defendants seek in their pre-motion letter should not be granted. If no response is filed, the Court will likely grant Defendants the relief their motion seeks. So Ordered by Chief Judge Renee Marie Bumb on 10/11/2023. (Costigan, Roberta)
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Filing 20
ORDER Extending Defendants' time to answer, move, or otherwise reply to the Complaint until October 12, 2023. Signed by Magistrate Judge Elizabeth A. Pascal on 10/3/2023. (amv)
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| Filing 19 RESPONSE re #18 Request for Clerk's Entry of Default, #16 Letter, #17 Letter, #15 Application for Clerk's Order to Ext Answer/Proposed Order,. (MUSKETT, EILEEN) |
| Filing 18 Request for Clerk's Entry of Default by SAMUEL J. LASSOFF against Hard Rock International Inc. and Seminole Hard Rock Support Services, LLC. (LASSOFF, SAMUEL) |
| Filing 17 Letter from Eileen Oakes Muskett re #16 Letter, #15 Application for Clerk's Order to Ext Answer/Proposed Order,. (MUSKETT, EILEEN) |
| Filing 16 Letter from Eileen Oakes Muskett. (MUSKETT, EILEEN) |
| Filing 15 Application and Proposed Order for Clerk's Order to extend time to answer Attorney EILEEN O. MUSKETT for BOARDWALK 1000, LLC,EILEEN O. MUSKETT for HARD ROCK CAFE INTERNATIONAL (USA) INC,EILEEN O. MUSKETT for HARD ROCK INTERNATIONAL INC.,EILEEN O. MUSKETT for SEMINOLE HARD ROCK SUPPORT SERVICES, LLC added. (MUSKETT, EILEEN) |
| Filing 14 NOTICE of Appearance by KAREN A. CONFOY on behalf of BOARDWALK 1000, LLC, HARD ROCK CAFE INTERNATIONAL (USA) INC, HARD ROCK INTERNATIONAL INC., SEMINOLE HARD ROCK SUPPORT SERVICES, LLC (CONFOY, KAREN) |
| Filing 13 NOTICE of Appearance by EILEEN O. MUSKETT on behalf of BOARDWALK 1000, LLC, HARD ROCK CAFE INTERNATIONAL (USA) INC, HARD ROCK INTERNATIONAL INC., SEMINOLE HARD ROCK SUPPORT SERVICES, LLC (MUSKETT, EILEEN) |
| Filing 12 SUMMONS Returned Executed by SAMUEL J. LASSOFF. HARD ROCK CAFE INTERNATIONAL (USA) INC served on 9/27/2023, answer due 10/18/2023. (LASSOFF, SAMUEL) |
| Filing 11 SUMMONS Returned Executed by SAMUEL J. LASSOFF. BOARDWALK 1000, LLC served on 9/21/2023, answer due 10/12/2023. (LASSOFF, SAMUEL) |
| Filing 10 Letter from SAMUEL LASSOFF regarding letter sent to Defendant(s) and Defendant(s) notice to file a Rule 11 motion. (Attachments: #1 Letter)(amv) |
| Filing 9 SUMMONS Returned Executed by SAMUEL J. LASSOFF. SEMINOLE HARD ROCK SUPPORT SERVICES, LLC served on 9/6/2023, answer due 9/27/2023. (LASSOFF, SAMUEL) |
| Filing 8 SUMMONS Returned Executed by SAMUEL J. LASSOFF. HARD ROCK INTERNATIONAL INC. served on 9/6/2023, answer due 9/27/2023. (LASSOFF, SAMUEL) |
| Filing 7 SUMMONS Returned Executed by SAMUEL J. LASSOFF. HARD ROCK CAFE INTERNATIONAL (USA) INC served on 9/1/2023, answer due 9/22/2023. (LASSOFF, SAMUEL) |
| Filing 6 SUMMONS Returned Executed by SAMUEL J. LASSOFF. BOARDWALK 1000, LLC served on 9/1/2023, answer due 9/22/2023. (LASSOFF, SAMUEL) |
| Filing 5 AFFIDAVIT of Service for Summons and Class Action Complaint SERVED on Boardwalk 1000 LLC dba Hard Rock Hotel and Casino Atlantic City served on Jeremy Kopp, CT CORP SYS - REG AGENT for Boardwalk 1000 LLC dba Hard Rock Hotel and Casino Atlantic City on 9/1/23, filed by SAMUEL J. LASSOFF. (LASSOFF, SAMUEL) |
| Filing 4 AFFIDAVIT of Service for Class Action Complaint & Cover Sheet for case 1:23-cv-12407 served on Hard Rock Casino Executive Employee "Nick" on 8/29/2023, filed by SAMUEL J. LASSOFF. (LASSOFF, SAMUEL) |
| Filing 3 Diversity Disclosure Statement by SAMUEL J. LASSOFF. (LASSOFF, SAMUEL) |
| Filing 2 SUMMONS ISSUED as to BOARDWALK 1000, LLC, HARD ROCK CAFE INTERNATIONAL (USA) INC, HARD ROCK INTERNATIONAL INC., SEMINOLE HARD ROCK SUPPORT SERVICES, LLC. Attached is the official court Summons, please fill out Defendant and Plaintiffs attorney information and serve. (ssp, ) |
| Notice of Judicial Preferences. #Click here for the Judge's Individual Procedure Requirements. (ssp, ) |
| CLERK'S QUALITY CONTROL MESSAGE - Please be advised, pursuant to Fed. R. Civ. P. 7.1(a)(2), unless the Court orders otherwise, in any action filed or removed to this Court, in which jurisdiction is based upon diversity under 28 U.S.C. 1332(a), a party or intervenor must file a disclosure statement naming and identifying the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. A party, intervenor or proposed intervenor must file the disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the Court. #Click here to complete the Diversity Disclosure Statement, once complete, file it using the event Diversity Disclosure Statement. (ssp, ) |
| Filing 1 COMPLAINT against All Defendants ( Filing and Admin fee $ 402 receipt number ANJDC-14604388) with JURY DEMAND, filed by SAMUEL J. LASSOFF. (Attachments: #1 Civil Cover Sheet Lassoff et al v Hard Rock Cover Sheet case 1:23-cv-12407)(LASSOFF, SAMUEL) |
| Chief Judge Renee Marie Bumb and Magistrate Judge Elizabeth A. Pascal added. (tf, ) |
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