America's Business Capital, LLC v. International Professional Services
| America's Business Capital, LLC |
| International Professional Services, Joel Nazareno, Thomas Plamenco and International Professional Services doing business as PSC Inc. |
| Michael Cardello, III |
| 1:2018cv01819 |
| March 26, 2018 |
| US District Court for the Eastern District of New York |
| Brooklyn Office |
| Lois Bloom |
| Roslynn R Mauskopf |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity-Contract Dispute |
| Plaintiff |
Docket Report
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Filing 129
ORDER: As per the parties #127 STIPULATION of Dismissal, this case is hereby dismissed with prejudice and with each party to bear its own costs and fees. The Clerk of Court is directed to close this case. So Ordered by Judge Roslynn R. Mauskopf on 3/26/2019. (Almonte, Giselle)
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| Filing 127 STIPULATION of Dismissal by America's Business Capital, LLC (Abrams, Louis) |
| Filing 128 Minute Entry for proceedings held before Magistrate Judge Lois Bloom: Telephone Conference held on 3/20/2019. Recorded. Tick #(s) 11:32 - 12:04. Appearance for Plaintiff: Louis Abrams, Esq. Appearances for Defendants: Thomas Plamenco, pro se and Paul Stuart Haberman, Esq. (Latka-Mucha, Wieslawa) |
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Filing 126
ORDER: As stated in the attached Order, the Court held a telephone conference in this case on March 20, 2019. All parties agreed on the record to voluntarily dismiss this case with prejudice pursuant to Fed. R. Civ. P. 41(a). Plaintiff's counsel shall file the stipulation discontinuing this action by March 28, 2019, and shall send a copy of this Order to Mr. Plamenco. The Clerk of Court is directed to terminate as moot both defendant Plamenco's motion to compel, ECF No. 118, and plaintiff's request for a pre-motion conference, ECF No. 120. The Court stays all deadlines in this case pending the filing of the stipulation of dismissal. See attached Order. Ordered by Magistrate Judge Lois Bloom on 3/20/2019. (Downs, Abigail)
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| Filing 125 RESPONSE to Motion re #120 MOTION for pre motion conference re: Voluntary Dismissal filed by Joel Nazareno. (Haberman, Paul) |
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Filing 124
ORDER granting #123 Motion to Continue: As stated in the attached Order, because not all the parties are available for the conference on March 7, 2019, the Court shall adjourn the conference. The Court shall hold the telephonic status conference in this case on March 20, 2019, at 11:30 a.m. Plaintiff's counsel shall send a copy of this Order to pro se defendant, Mr. Plamenco, by whatever means available that will ensure that he gets immediate notice. The Court stays all deadlines pending the March 20, 2019, telephone conference. See attached Order. Ordered by Magistrate Judge Lois Bloom on 3/5/2019. (Downs, Abigail)
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| Telephone Conference set for 3/20/2019 11:30 AM before Magistrate Judge Lois Bloom. (Downs, Abigail) |
| Filing 123 MOTION to Continue 3-7 Conference by America's Business Capital, LLC. (Abrams, Louis) |
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Filing 122
As stated in the attached Order, plaintiff's request for an extension of time (ECF No. 121) to respond to defendant's motion to compel (ECF No. 118) is granted. The Court stays the deadline to respond until the telephone conference on March 7, 2019. Plaintiff shall ensure that Mr. Plamenco receives a copy of this Order prior to the 3/7/19 Conference. See attached Order. C/mailed to pro se defendant via first class mail. Ordered by Magistrate Judge Lois Bloom on 3/4/2019. (Downs, Abigail)
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| Filing 121 MOTION for Extension of Time to File Response/Reply as to #118 MOTION to Compel Production of Documents, filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A - Motion for Voluntary Dismissal) (Abrams, Louis) |
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ORDER: By March 15, 2019, both defendant Nazareno and defendant Plamenco shall file letters with the Court, not to exceed three pages each, setting forth their positions on plaintiff's proposed motion to dismiss this action pursuant to Rule 41(a)(2). Plaintiff's request to stay discovery is denied without prejudice to renew after the upcoming telephonic conference before Judge Bloom. The Clerk of Court is respectfully directed to mail a copy of this Order to pro se defendant Plamenco and note the mailing on the docket. Ordered by Judge Roslynn R. Mauskopf on 3/1/2019. (Pettig, Bruce)
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| Filing 120 MOTION for pre motion conference re: Voluntary Dismissal by America's Business Capital, LLC. (Abrams, Louis) |
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Filing 119
ORDER: As stated in the attached Order, the Court shall hold a telephonic status conference in this action on March 7, 2019, at 10:00 a.m., and plaintiff shall respond to defendant's motion to compel, ECF No. #118 , by March 4, 2019. See attached Order. C/mailed to pro se defendant via FedEx. Ordered by Magistrate Judge Lois Bloom on 2/27/2019. (Downs, Abigail)
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| Filing 118 MOTION to Compel Production of Documents, filed by Thomas Plamenco. (Almonte, Giselle) |
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Filing 117
ORDER: The Court held a telephone conference in this matter on August 30, 2018. As discussed on the record, the Court sets the following schedule. The parties shall complete all fact discovery by February 25, 2019. The parties shall file a joint status letter before that date, if they will seek expert discovery, detailing what expert discovery is needed as well as how long they need to complete discovery. Upon the completion of discovery, any party who intends to file a motion for summary judgment shall write to Judge Mauskopf by March 15, 2019 to request a pre-motion conference in accordance with her individual rules. The parties are encouraged to discuss settlement. So Ordered by Magistrate Judge Lois Bloom on 8/30/2018. (Almonte, Giselle)
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| Filing 116 Minute Entry: Telephone Conference held on 8/30/2018 before Magistrate Judge Lois Bloom. Nicholas C. Harbist and Louis Abrams appeared on behalf of the plaintiff America's Business Capital, LLC. Paul Stuart Haberman appeared on behalf of defendant Joel Nazareno. Thomas Plamenco appeared as a pro se defendant. (FTR Log #2:06-2:29.) (Almonte, Giselle) |
| Filing 115 Letter Regarding Discovery Status by America's Business Capital, LLC (Harbist, Nicholas) |
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Filing 114
ORDER: As set forth in the attached Order, by letter dated August 20, 2018 (ECF No. 113), plaintiff's counsel seeks an adjournment of the August 22, 2018 telephone conference. Defendants consent to this request. The request is granted. The Court shall hold the telephone conference on August 30, 2018 at 2:00 p.m. By August 27, 2018, the parties shall file a joint status letter regarding electronic discovery. Plaintiff's counsel shall notify defendants of this adjournment as expeditiously as possible, by telephone and/or email. See attached Order. c/ mailed to defendant Plamenco. Ordered by Magistrate Judge Lois Bloom on 8/21/2018. (Smith, Roberta)
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| Filing 113 First MOTION to Continue the August 22nd Teleconference by America's Business Capital, LLC. (Harbist, Nicholas) |
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Filing 112
SCHEDULING ORDER: The Court shall hold another telephone conference on 8/22/2018 at 9:30 a.m. By 8/20/2018, the parties shall file a joint status letter regarding electronic discovery. After establishing contact with defendants, plaintiff's counsel shall telephone the Court at 718-613-2170. The parties are encouraged to discuss settlement. SO ORDERED by Magistrate Judge Lois Bloom, on 7/19/2018. C/mailed. (Latka-Mucha, Wieslawa)
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| Filing 111 Minute Entry for proceedings held before Magistrate Judge Lois Bloom: Telephone Conference held on 7/19/2018. Recorded. Tick #(s) 2:11 - 2:31. Appearances for Plaintiff: Nicholas Harbist, Esq. & Louis Abrams, Esq. Appearances for Defendants: Paul Stuart Haberman, Esq. and Thomas Plamenco, pro se. (Latka-Mucha, Wieslawa) |
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Filing 110
PROTECTIVE ORDER, endorsed on doc.#109 : SO ORDERED by Magistrate Judge Lois Bloom, on 7/17/2018. C/mailed. (See page # 11.) (Latka-Mucha, Wieslawa)
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| Filing 109 NOTICE by America's Business Capital, LLC of Proposed Protective Order (Harbist, Nicholas) |
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ORDER: On June 29, 2018, the parties filed a proposed mutual protective order. (ECF No. 107.) However, the agreement was not signed. The parties are directed to refile signed copies of the proposed order by July 16, 2018. Ordered by Magistrate Judge Lois Bloom on 7/9/2018. (Smith, Roberta)
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| Filing 108 Letter Re: Joint Discovery Status Report by America's Business Capital, LLC (Harbist, Nicholas) |
| Filing 107 NOTICE by America's Business Capital, LLC FOR JOINT PROPOSED PROTECTIVE ORDER (Harbist, Nicholas) |
| Filing 106 TRANSCRIPT re: the 3/16/2018 Oral Argument before The Honorable Valerie E. Caproni in America's Business Capital, LLC v. International Professional Services, et al., Case No. 1:17-CV-1308 (VEC). (Latka-Mucha, Wieslawa) |
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Filing 105
ORDER, endorsed on Louis D. Abrams, Esq.'s 6/22/2018 letter: The Clerk of Court is directed to file the attached transcript on the docket. SO ORDERED by Magistrate Judge Lois Bloom, on 6/26/2018. C/mailed w/Attachments: #1 Transcript of the March 16, 2018 Oral Argument before The Honorable Valerie E. Caproni, Case No. 1: 17-cv-1308-VEC. (Latka-Mucha, Wieslawa)
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| Filing 104 ANSWER to #72 Amended Complaint, by Joel Nazareno. (Haberman, Paul) |
| Filing 103 ANSWER to #72 Amended Complaint, filed by Thomas Plamenco. (Almonte, Giselle) (Modified) |
| Filing 102 Letter Dated June 1, 2018 from pro se defendant Thomas Plamenco re: having no attorney and all correspondence to be sent to 30 Delphine Terrace Staten Island, NY 10305. (Almonte, Giselle) |
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Filing 101
ORDER, granting #100 Motion to Substitute Attorney. Defendant Thomas Plamenco shall proceed pro se. The application is granted. SO ORDERED by Magistrate Judge Lois Bloom, on 6/1/2018. C/mailed. (Attorneys: Bradley Siegel; Bradley Ross Siegel; Janet Nina Eshaghoff and Michael Eric Kupferberg terminated.) (Latka-Mucha, Wieslawa)
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| Filing 100 First MOTION to Substitute Attorney Bradley R. Siegel by Thomas Plamenco. (Attachments: #1 Affidavit in Support Affirmation of Bradley R. Siegel in Support of Request to be Relieved as Counsel, #2 Exhibit Exhibit A, #3 Exhibit Exhibit B, #4 Exhibit Exhibit C, #5 Exhibit Exhibit D, #6 Affidavit Affidavit of Service) (Siegel, Bradley) |
| Minute Entry for proceedings held before Magistrate Judge Lois Bloom: Initial Conference held on 6/1/2018. (FTR Log #11:11-11:44.) (Smith, Roberta) |
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SCHEDULING ORDER: The Court held a conference in this matter on June 1, 2018. As discussed on the record, plaintiff shall order the transcript of the proceedings before Judge Caproni on March 16, 2018. Defendants shall answer the complaint by June 15, 2018. By June 29, 2018, the parties shall file a mutual protective order and a joint status letter regarding electronic discovery. Any request to amend the pleadings or to join other parties shall be filed by July 2, 2018. Fed. R. Civ. P. 16(b)(3)(A). The Court shall hold a telephone conference in this matter on July 19, 2018 at 2:00 p.m. After establishing contact with defendants' counsel, plaintiff's counsel shall telephone the Court at 718-613-2170. Parties are advised that they must contact each other before making any request for an adjournment to the Court. Any request for an adjournment must be received in writing at least forty-eight (48) hours before the scheduled conference. Ordered by Magistrate Judge Lois Bloom on 6/1/2018. (Smith, Roberta)
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| Filing 99 REPORT of Rule 26(f) Planning Meeting (Harbist, Nicholas) |
| Filing 98 NOTICE of Consent to Change Attorney by Bradley Siegel (Siegel, Bradley) |
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Filing 97
ORDER, granting #96 Notice of Motion to Admit Counsel Pro Hac Vice. The admitted attorney Louis D. Abrams, an associate of the firm of Blank Rome LLP and a member in good standing of the bars of the State of New Jersey and the Commonwealth of Pennsylvania, is permitted, as attorney pro hac vice, to argue or try this case in whole or in part as counsel for Plaintiff America's Business Capital, LLC. SO ORDERED by Magistrate Judge Lois Bloom, on 4/30/2018. (The attorney shall register for ECF, registration is available online at the NYEDs homepage. Once registered, the attorney shall file a notice of appearance and ensure that s/he receives electronic notification of activity in this case.) (Latka-Mucha, Wieslawa)
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| Filing 96 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0207-10390332. by America's Business Capital, LLC. (Attachments: #1 Affidavit in Support) (Abrams, Louis) |
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ORDER granting #95 Motion to Adjourn Conference: With consent of all counsel, Defendant Plamenco's counsel writes to request that the May 1, 2018 initial conference be adjourned for at least thirty days. (ECF No. 95.) The request is granted. The Court shall hold the initial conference on June 1, 2018 at 10:30 a.m. in Courtroom 11A South, 225 Cadman Plaza East, Brooklyn, New York, 11201. The parties shall exchange their Rule 26(a)(1) initial disclosures and file their Rule 26(f) Meeting Report with the Court by May 25, 2018. Parties are advised that they must contact each other before making any request for an adjournment to the Court. Any request for an adjournment must be electronically filed with the Court at least forty-eight (48) hours before the scheduled conference. Ordered by Magistrate Judge Lois Bloom on 4/26/2018. (Smith, Roberta)
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| Filing 95 Letter MOTION to Adjourn Conference by Thomas Plamenco. (Siegel, Bradley) |
| Filing 94 NOTICE of Appearance by Nicholas C. Harbist on behalf of America's Business Capital, LLC (notification declined or already on case) (Harbist, Nicholas) |
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Filing 93
ORDER, granting #92 Notice of Motion to Admit Counsel Pro Hac Vice: The admitted attorney Nicholas C. Harbist is permitted to argue or try this case in whole or in part as counsel for Plaintiff America's Business Capital, LLC. SO ORDERED by Magistrate Judge Lois Bloom, on 4/16/2018. (The attorney shall register for ECF, registration is available online at the NYEDs homepage. Once registered, the attorney shall file a notice of appearance and ensure that s/he receives electronic notification of activity in this case.) (Latka-Mucha, Wieslawa)
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| Filing 92 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0207-10347296. by America's Business Capital, LLC. (Attachments: #1 Affidavit of Nicholas C. Harbist, Esquire) (Harbist, Nicholas) |
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SCHEDULING ORDER: Plaintiff's diversity action was transferred to this Court from the Southern District of New York on March 26, 2018. The Court shall hold an initial conference on May 1, 2018 at 2:30 p.m. in Courtroom 11A South of the United States Courthouse, 225 Cadman Plaza East in Brooklyn, New York. The parties shall exchange their Rule 26(a)(1) initial disclosures and file their Rule 26(f) Meeting Report with the Court by April 24, 2018. Parties are advised that they must contact each other before making any request for an adjournment to the Court. Any request for an adjournment must be received in writing at least forty-eight (48) hours before the scheduled conference. Ordered by Magistrate Judge Lois Bloom on 3/27/2018. (Doody, Sara)
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| Filing 91 In accordance with Rule 73 of the Federal Rules of Civil Procedure and Local Rule 73.1, the parties are notified that if all parties consent a United States magistrate judge of this court is available to conduct all proceedings in this civil action including a (jury or nonjury) trial and to order the entry of a final judgment. Attached to the Notice is a blank copy of the consent form that should be filled out, signed and filed electronically only if all parties wish to consent. The form may also be accessed at the following link: #http://www.uscourts.gov/uscourts/FormsAndFees/Forms/AO085.pdf. You may withhold your consent without adverse substantive consequences. Do NOT return or file the consent unless all parties have signed the consent. (Bowens, Priscilla) |
| Filing 90 Case transferred in from District of New York Southern; Case Number 1:17-cv-01308. Original file certified copy of transfer order and docket sheet received. |
| The case of America's Business Capital, LLC v. International Professional Services, has been transferred from Southern District of New York to the Eastern District of New York. The new case number is 18cv1819. PLEASE NOTE: if you plan to continue representing your client(s), you must be admitted to practice before this court. You must do so by applying for Pro Hac Vice or permanent admission. To apply for Pro Hac Vice admission, you must first register for an ECF login and password. Please visit the Court's website at www.nyed.uscourts.gov/attorney-admissions for guidance. Once registered, you must electronically file a Motion to Appear Pro Hac Vice. You must pay the required pro hac vice fee online. (Bowens, Priscilla) |
| CASE TRANSFERRED OUT ELECTRONICALLY from the U.S.D.C. Southern District of New York to the United States District Court - District of Eastern District of New York (mro) [Transferred from New York Southern on 3/26/2018.] |
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Filing 89
ORDER terminating #75 Motion to Dismiss; terminating #78 Motion to Dismiss. WHEREAS on November 1, 2017 (Dkts. 75, 78), Defendants Nazareno and Plamenco filed motions to dismiss the Second Amended Complaint; and WHEREAS on March 16, 2018, the parties appeared for oral argument on the motions to dismiss; IT IS HEREBY ORDERED that, for the reasons stated on the record on March 16, 2018, Defendants' motions to dismiss are DENIED. IT IS FURTHER ORDERED that, for the reasons stated on the record on March 16, 2018, this case shall be TRANSFERRED to the Eastern District of New York pursuant to 28 U.S.C. 1406(a). The Clerk is respectfully directed to close the open motions at Dkts. 75 and 78. The Clerk is also asked to transfer this case to the Eastern District of New York and to note the transfer on the docket. (Signed by Judge Valerie E. Caproni on 3/16/2018) (mro) [Transferred from New York Southern on 3/26/2018.]
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| Minute Entry for proceedings held before Judge Valerie E. Caproni: Oral Argument held on 3/16/2018 re: #78 MOTION to Dismiss filed by Thomas Plamenco. Order to follow. (Court Reporter Tom Murray) (Brantley, Michael) [Transferred from New York Southern on 3/26/2018.] |
| Filing 88 NOTICE OF APPEARANCE by Michael Eric Kupferberg on behalf of Thomas Plamenco. (Kupferberg, Michael) [Transferred from New York Southern on 3/26/2018.] |
| Filing 87 NOTICE OF APPEARANCE by Bradley Ross Siegel on behalf of Thomas Plamenco. (Siegel, Bradley) [Transferred from New York Southern on 3/26/2018.] |
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Filing 86
ORDER: IT IS HEREBY ORDERED that the February 23, 2018 argument is ADJOURNED to March 16, 2018 at 2:00 p.m., Courtroom 443, Thurgood Marshall U.S. Courthouse. Oral Argument set for 3/16/2018 at 02:00 PM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni. (Signed by Judge Valerie E. Caproni on 2/22/2018) (kgo) [Transferred from New York Southern on 3/26/2018.]
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Filing 85
ORDER granting #84 Letter Motion to Adjourn Conference. Oral argument is adjourned to February 23, 2018 at 2:00 p.m., Courtroom 443, Thurgood Marshall U.S. Courthouse. No further adjournments will be granted. Oral Argument set for 2/23/2018 at 02:00 PM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni. (Signed by Judge Valerie E. Caproni on 1/24/2018) (mro) [Transferred from New York Southern on 3/26/2018.]
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| Filing 84 FIRST LETTER MOTION to Adjourn Conference Scheduled for 2/2/18 addressed to Judge Valerie E. Caproni from Paul Stuart Haberman dated January 22, 2018. Document filed by Joel Nazareno.(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
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Filing 83
ORDER: IT IS HEREBY ORDERED that Plaintiff, Defendant Nazareno, and Defendant Plamenco must appear for oral argument on these motions on February 2, 2018 at 3:00 p.m. in Courtroom 443, Thurgood Marshall U.S. Courthouse, 40 Foley Square, New York, NY. (Oral Argument set for 2/2/2018 at 3:00 PM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 1/10/2018) (js) [Transferred from New York Southern on 3/26/2018.]
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| Filing 82 REPLY MEMORANDUM OF LAW in Support re: #75 FIRST MOTION to Dismiss the Second Amended Complaint (Notice of Motion). . Document filed by Joel Nazareno. (Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 81 REPLY MEMORANDUM OF LAW in Support re: #78 MOTION to Dismiss . . Document filed by Thomas Plamenco. (Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 80 MEMORANDUM OF LAW in Opposition re: #78 MOTION to Dismiss . . Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 79 MEMORANDUM OF LAW in Opposition re: #75 FIRST MOTION to Dismiss the Second Amended Complaint (Notice of Motion). . Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 78 MOTION to Dismiss . Document filed by Thomas Plamenco. Responses due by 11/15/2017 (Attachments: #1 Affirmation in Support, #2 Memorandum of Law In Support, #3 Exhibit A, #4 Exhibit B, #5 Exhibit C)(Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 77 FIRST MEMORANDUM OF LAW in Support re: #75 FIRST MOTION to Dismiss the Second Amended Complaint (Notice of Motion). . Document filed by Joel Nazareno. (Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 76 DECLARATION of Paul Stuart Haberman in Support re: #75 FIRST MOTION to Dismiss the Second Amended Complaint (Notice of Motion).. Document filed by Joel Nazareno. (Attachments: #1 Exhibit A)(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 75 FIRST MOTION to Dismiss the Second Amended Complaint (Notice of Motion). Document filed by Joel Nazareno.(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
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Filing 74
STIPULATION TO EXTEND TIME TO RESPOND AND ANSWER: IT IS STIPULATED AND AGREED, by and between THE SIEGEL LAW FIRM, P.C. attorneys for defendant THOMAS PLAMENCO (the "Defendant") and attorneys for the plaintiff AMERICA'S BUSINESS CAPITAL, LLC (the "Plaintiff") in the above-entitled action, that the time for Defendant to answer, respond, or otherwise move with respect to the Second Amended Complaint is hereby extended to November 1, 2017. IT IS FURTHER STIPULATED AND AGREED, that Plaintiff's time to file Opposition papers, if any, is hereby extended to November 15, 2017, and Defendant's time to file Reply papers, if any, is hereby extended to November 25, 2017. IT IS FURTHER STIPULATED AND AGREED, that facsimile or electronic signatures shall be deemed as originals and this Stipulation may be filed without further notice. SO ORDERED. These extensions are granted as to Plaintiff and as to both Defendants Thomas Plamenco and Joel Nazareno. The parties are advised that they must request extensions of time from the Court, and must do so by ECF letter filed at least 48 hours prior to a deadline, pursuant to the Court's Individual Practices, Rule 1(C). Motions terminated: #73 MOTION for Extension of Time, filed by Thomas Plamenco. International Professional Services answer due 11/1/2017; Joel Nazareno answer due 11/1/2017; Thomas Plamenco answer due 11/1/2017. (Responses due by 11/15/2017. Replies due by 11/25/2017.) (Signed by Judge Valerie E. Caproni on 10/18/2017) (ap) [Transferred from New York Southern on 3/26/2018.]
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| Filing 73 MOTION for Extension of Time . Document filed by Thomas Plamenco.(Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 72 SECOND AMENDED COMPLAINT amending #25 Amended Complaint, against Joel Nazareno, Thomas Plamenco with JURY DEMAND.Document filed by America's Business Capital, LLC. Related document: #25 Amended Complaint,. (Attachments: #1 Exhibit Redline)(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
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Filing 71
ORDER: IT IS HEREBY ORDERED that Plaintiff's claims against International Professional Services shall be dismissed. The Clerk of Court is respectfully requested to terminate International Professional Services and Receiver Michael Cardello, III as parties to this action. Michael Cardello, III (Michael Cardello III, Receiver for International Professional Services, Inc.) and International Professional Services terminated. (Signed by Judge Valerie E. Caproni on 9/20/2017) (kgo) [Transferred from New York Southern on 3/26/2018.]
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| Filing 70 Minute Entry for proceedings held before Judge Valerie E. Caproni: Telephone Conference held on 9/13/2017. Call with counsel for plaintiff and defendant Planenco re: Order to amend the complaint. (Todd, Nicole) [Transferred from New York Southern on 3/26/2018.] |
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Filing 69
ORDER: IT IS HEREBY ORDERED that no later than September 20, 2017, Plaintiff must file a Second Amended Complaint, and Plaintiff must in addition file a redlined copy of the Second Amended Complaint reflecting the changes made to the First Amended Complaint. Defendant Nazareno and Plamenco's motions to dismiss are denied as moot in light of Plaintiff's anticipated Second Amended Complaint. Defendant Nazareno and Plamenco's deadline to move or answer in response to the Second Amended Complaint is October 18, 2017. Plaintiff's opposition is due no later than November 1, 2017, and Defendants' replies are due no later than November 15, 2017. Amended Pleadings due by 9/20/2017. Motions due by 10/18/2017. Responses due by 11/1/2017. Replies due by 11/15/2017. (Signed by Judge Valerie E. Caproni on 9/6/2017) (ap) [Transferred from New York Southern on 3/26/2018.]
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| Minute Entry for proceedings held before Judge Valerie E. Caproni: In Chambers Conference held on 9/6/2017. Re: Plaintiff's Proposed motion to strike. Counsel for Plaintiff. Counsel for Defendant Nazareno only. Order to follow. (Todd, Nicole)[Transferred from New York Southern on 3/26/2018.] |
| Filing 68 REPLY AFFIRMATION of Paul Stuart Haberman in Support re: #55 FIRST MOTION to Dismiss (Notice of Motion).. Document filed by Joel Nazareno. (Attachments: #1 Letter to Court in Eastern District Matter, #2 Memorandum of Law from Motion Made in Eastern District Matter, #3 August 8, 2017 Order in Eastern District Matter, #4 August 17, 2017 Order in This Matter)(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
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Filing 67
ORDER: it is hereby ORDERED that Plaintiff's claims against Defendant International Professional Services will be dismissed without costs (including attorneys' fees) to either party on September 18, 2017, unless before that date one or more of the parties files a letter with the Court requesting that the action not be dismissed and stating the reasons why the Court should retain jurisdiction over this action in light of the parties' settlement. To be clear, any request that the action not be dismissed must be filed on or before September 18, 2017; any request filed thereafter may be denied solely on that basis. If the parties wish for the Court to retain jurisdiction over their settlement agreement, not later than September 13, 2017, they must submit the settlement agreement to the Court in accordance with Rule 5.A of the Court's Individual Practices, along with a request that the Court issue an order expressly retaining jurisdiction to enforce their settlement agreement. See Hendrickson v. United States, 791 F.3d 354 (2d Cir. 2015). All deadlines and court conferences previously scheduled with respect to Defendant International Professional Services are cancelled. (Signed by Judge Valerie E. Caproni on 8/18/2017) (kgo) [Transferred from New York Southern on 3/26/2018.]
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| Filing 66 LETTER addressed to Judge Valerie E. Caproni from Louis D. Abrams dated 8-17-2017 re: Settlement in Principle Between Plaintiff ABC and Defendant PSC. Document filed by America's Business Capital, LLC.(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 65 REPLY MEMORANDUM OF LAW in Support re: #64 MOTION to Dismiss . . Document filed by Thomas Plamenco. (Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 64 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MOTION to Dismiss . Document filed by Thomas Plamenco. Responses due by 8/16/2017(Eshaghoff, Janet) Modified on 8/17/2017 (db). [Transferred from New York Southern on 3/26/2018.] |
| ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney Louis Abrams to RE-FILE Document #63 Memorandum of Law in Opposition to Motion. ERROR(S): Document(s) linked to filing error. (db) [Transferred from New York Southern on 3/26/2018.] |
| ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Notice to Attorney Janet Nina Eshaghoff to RE-FILE Document #64 MOTION to Dismiss . Use the event type Memorandum in Opposition to Motion found under the event list Replies, Opposition and Supporting Documents. (db) [Transferred from New York Southern on 3/26/2018.] |
| ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney Janet Nina Eshaghoff to RE-FILE Document #61 MOTION to Dismiss . ERROR(S): Supporting Documents are filed separately, each receiving their own document #'s. (db) [Transferred from New York Southern on 3/26/2018.] |
| Filing 63 FILING ERROR - DEFICIENT DOCKET ENTRY - MEMORANDUM OF LAW in Opposition re: #61 MOTION to Dismiss . of Thomas Plamenco. Document filed by America's Business Capital, LLC. (Abrams, Louis) Modified on 8/17/2017 (db). [Transferred from New York Southern on 3/26/2018.] |
| Filing 62 MEMORANDUM OF LAW in Opposition re: #55 FIRST MOTION to Dismiss (Notice of Motion). of Joel Nazareno. Document filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 61 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Dismiss . Document filed by Thomas Plamenco.(Eshaghoff, Janet) Modified on 8/17/2017 (db). [Transferred from New York Southern on 3/26/2018.] |
| Filing 60 MEMO ENDORSEMENT: on re: #54 Letter filed by Joel Nazareno. ENDORSEMENT: Given that Mr. Nazareno filed his motion to dismiss the Amended Complaint over the weekend, his request to extend his time to answer or move in response to the Amended Complaint is denied as moot. (Signed by Judge Valerie E. Caproni on 7/31/2017) (ap) [Transferred from New York Southern on 3/26/2018.] |
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Filing 59
STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO AMENDED COMPLAINT AND FOR RELATED RELIEF: IT IS HEREBY STIPULATED AND AGREED that on April 26, 2017, the Honorable Arthur D. Spatt for the United States District Court for the Eastern District of New York entered an order (the "Order") appointing Michael Cardello III, Esq., as the receiver (the "Receiver") for International Professional Services Inc. ("PSC") in a case captioned GWG MCA Capital, Inc. v. NuLook Capital, LLC, International Professional Services Inc. dba PSC, PSC Financial, a division of PSC, Anthony Mannino, Joel Nazareno and Robert Aurigema, Civil Action No. 17-CV-1724 (ADS)(GRB); and IT IS FURTHER STIPULATED AND AGREED that the Receiver requires additional time to investigating the allegations asserted by the Plaintiff, America's Business Capital LLC (the "Plaintiff") and determine an appropriate response; and IT IS FURTHER STIPULATED AND AGREED that the Receiver's time to Answer and/or Respond the Amended Complaint is extended through and including August 31, 2017; and IT IS FURTHER STIPULATED AND AGREED that nothing contained herein shall be construed as a waiver of any rights or defenses that the Receiver may be entitled to assert on behalf of PSC. Because the Court previously denied Defendant's motion to dismiss and compel arbitration as moot in light of Plaintiff's amended complaint, there is no motion for which Defendant must submit a reply at this time. Michael Cardello, III answer due 8/31/2017., Motions terminated: #53 LETTER MOTION for Extension of Time to File Response/Reply as to #25 Amended Complaint, and for Related Relief addressed to Judge Valerie E. Caproni from Stephen E. Turman, Esq. dated July 28, 2017. filed by Michael Cardello, III. (Signed by Judge Valerie E. Caproni on 7/31/2017) (rj) [Transferred from New York Southern on 3/26/2018.]
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| Filing 57 FIRST MEMORANDUM OF LAW in Support re: #55 FIRST MOTION to Dismiss (Notice of Motion). . Document filed by Joel Nazareno. (Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 56 DECLARATION of Paul Stuart Haberman in Support re: #55 FIRST MOTION to Dismiss (Notice of Motion).. Document filed by Joel Nazareno. (Attachments: #1 Exhibit A, #2 Exhibit B)(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 55 FIRST MOTION to Dismiss (Notice of Motion). Document filed by Joel Nazareno.(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
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Filing 58
ORDER granting #52 Letter Motion for Extension of Time to Answer re #52 LETTER MOTION for Extension of Time to File Answer. Request Granted. So Ordered. (Signed by Judge Valerie E. Caproni on 7/28/2017) (js) [Transferred from New York Southern on 3/26/2018.]
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| Filing 54 SECOND LETTER addressed to Judge Valerie E. Caproni from Stephen Ghee, Esq dated July 28, 2017 re: Extension of time to answer or appear (consented to by opposing atty). Document filed by Joel Nazareno.(Ghee, Stephen) [Transferred from New York Southern on 3/26/2018.] |
| Filing 53 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - LETTER MOTION for Extension of Time to File Response/Reply as to #25 Amended Complaint, and for Related Relief addressed to Judge Valerie E. Caproni from Stephen E. Turman, Esq. dated July 28, 2017. Document filed by Michael Cardello, III.(Turman, Stephen) Modified on 9/14/2017 (ldi). [Transferred from New York Southern on 3/26/2018.] |
| Filing 52 LETTER MOTION for Extension of Time to File Answer addressed to Judge Valerie E. Caproni from Janet Nina Esagoff dated July 28, 2017. Document filed by Thomas Plamenco.(Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 51 NOTICE OF CHANGE OF ADDRESS by Paul Stuart Haberman on behalf of Joel Nazareno. New Address: Law Offices of Paul S. Haberman LLC, P.O. Box 167, Norwood, New Jersey, USA 07648, (201) 564-0590. (Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 50 NOTICE OF APPEARANCE by Stephen Ghee on behalf of Joel Nazareno. (Ghee, Stephen) [Transferred from New York Southern on 3/26/2018.] |
| Filing 49 STIPULATION EXTENDING TIME TO RESPOND AND ANSWER: IT IS STIPULATED AND AGREED, by and between THE SIEGEL LAW FIRM, P.C. attorneys for defendant THOMAS PLAMENCO (the "Defendant") and attorneys for the plaintiff AMERICA'S BUSINESS CAPITAL, LLC in the above-entitled action, that the time for Defendant to answer, respond, or otherwise move with respect to the Complaint is hereby extended to July 31, 2017. Thomas Plamenco answer due 7/31/2017. (Signed by Judge Valerie E. Caproni on 7/18/2017) (mro) [Transferred from New York Southern on 3/26/2018.] |
| Filing 48 FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - MOTION for Extension of Time to File Answer re: #47 LETTER MOTION for Extension of Time Stipulation Extending Time to Answer addressed to Judge Valerie E. Caproni from The Siegel Law Firm dated July 17, 2017. Stipulation Extending Time to Answer. Document filed by Thomas Plamenco.(Eshaghoff, Janet) Modified on 7/19/2017 (db). [Transferred from New York Southern on 3/26/2018.] |
| Filing 47 FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - LETTER MOTION for Extension of Time Stipulation Extending Time to Answer addressed to Judge Valerie E. Caproni from The Siegel Law Firm dated July 17, 2017. Document filed by Thomas Plamenco.(Eshaghoff, Janet) Modified on 7/19/2017 (db). [Transferred from New York Southern on 3/26/2018.] |
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Filing 46
STIPULATION EXTENDING TIME TO RESPOND AND ANSWER, IT IS STIPULATED AND AGREED, by and between THE SIEGEL LAW FIRM, P.C. attorneys for defendant THOMAS PLAMENCO (the "Defendant") and attorneys for the plaintiff AMERICA'S BUSINESS CAPITAL, LLC in the above-entitled action, that the time for Defendant to answer, respond, or otherwise move with respect to the Complaint is hereby extended to July 17, 2017. IT IS FURTHER STIPULATED AND AGREED, that facsimile or electronic signatures shall be deemed as originals and this Stipulation may be filed without further notice. SO ORDERED. (Thomas Plamenco answer due 7/17/2017.) (Signed by Judge Valerie E. Caproni on 7/6/17) (yv) [Transferred from New York Southern on 3/26/2018.]
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| Filing 45 NOTICE of Stipulation Extending Time to Respond and Answer. Document filed by Thomas Plamenco. (Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
| Filing 44 NOTICE OF APPEARANCE by Janet Nina Eshaghoff on behalf of Thomas Plamenco. (Eshaghoff, Janet) [Transferred from New York Southern on 3/26/2018.] |
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Filing 43
ORDER denying as moot #20 Motion to Compel Arbitration; denying as moot #20 Motion to Dismiss. IT IS HEREBY ORDERED that the motion to dismiss and compel arbitration is denied as moot in light of Plaintiff's amended complaint. The Receiver's time to answer or otherwise respond to the amended complaint is adjourned to July 28, 2017. The Clerk of Court is respectfully directed to close the open motion at docket entry twenty. (Signed by Judge Valerie E. Caproni on 6/30/2017) (kgo) [Transferred from New York Southern on 3/26/2018.]
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| Filing 42 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - LETTER MOTION for Extension of Time to File Answer re: #25 Amended Complaint, and for Related Relief addressed to Judge Valerie E. Caproni from Stephen E. Turman, Esq. dated June 30, 2017. Document filed by Michael Cardello, III.(Turman, Stephen) Modified on 8/25/2017 (ldi). [Transferred from New York Southern on 3/26/2018.] |
| Set/Reset Deadlines: Michael Cardello, III answer due 7/28/2017. (kgo) [Transferred from New York Southern on 3/26/2018.] |
| Filing 41 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Joel Nazareno served on 5/22/2017, answer due 7/29/2017. Service was accepted by Madelyn Nazareno. Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 40 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Thomas Plamenco served on 5/26/2017, answer due 6/16/2017. Service was accepted by Thomas Plamenco. Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 39 MEMO ENDORSEMENT on re: #38 Letter filed by Joel Nazareno, Joel Nazareno answer due 7/29/2017. ENDORSEMENT: Request GRANTED. Nazareno's deadline to answer or otherwise respond to the complaint is adjourned to July 29, 2017. No later than July 6, 2017, Plaintiff must file on the docket all affidavits of service for Defendants previously served. Moving forward, Plaintiff must promptly file an affidavit of service for any newly served Defendants. (Signed by Judge Valerie E. Caproni on 6/29/2017) (ras) [Transferred from New York Southern on 3/26/2018.] |
| Filing 38 FIRST LETTER addressed to Judge Valerie E. Caproni from Paul Stuart Haberman dated June 29, 2017 re: Extension of Time to Answer or Otherwise Appear. Document filed by Joel Nazareno.(Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
| Filing 37 NOTICE OF APPEARANCE by Paul Stuart Haberman on behalf of Joel Nazareno. (Haberman, Paul) [Transferred from New York Southern on 3/26/2018.] |
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Filing 36
STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO AMENDED COMPLAINT AND FOR RELATED RELIEF, Motions terminated: #35 LETTER MOTION for Extension of Time to File Answer re: #25 Amended Complaint, and time to file a Reply in connection with PSC's Motion to Dismiss and Compel Arbitration addressed to Judge Valerie E. Caproni from Stephen E. Turman d filed by Michael Cardello, III. IT IS HEREBY STIPULATED AND AGREED, that the Receiver's time to Answer and/or Respond the Amended Complaint is extended through and including June 30, 2017; and IT IS FURTHER STIPULATED AND AGREED that the Receiver's time to file a Reply in connection to that certain motion filed by PSC seeking to dismiss the Complaint and compel arbitration is also extended through and including June 30, 2017. So Ordered. (Michael Cardello, III answer due 6/30/2017.(Responses due by 6/30/2017) (Signed by Judge Valerie E. Caproni on 6/5/17) (yv) Modified on 6/22/2017 (yv). [Transferred from New York Southern on 3/26/2018.]
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| Filing 35 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - LETTER MOTION for Extension of Time to File Answer re: #25 Amended Complaint, and time to file a Reply in connection with PSC's Motion to Dismiss and Compel Arbitration addressed to Judge Valerie E. Caproni from Stephen E. Turman dated 06/05/2017. Document filed by Michael Cardello, III.(Turman, Stephen) Modified on 8/7/2017 (ldi). [Transferred from New York Southern on 3/26/2018.] |
| Filing 34 NOTICE OF APPEARANCE by Stephen Eric Turman on behalf of Michael Cardello, III. (Turman, Stephen) [Transferred from New York Southern on 3/26/2018.] |
| Filing 33 NOTICE OF APPEARANCE by Michael Cardello, III on behalf of Michael Cardello, III. (Cardello, Michael) [Transferred from New York Southern on 3/26/2018.] |
| Filing 32 MEMO ENDORSEMENT on re: #31 Letter filed by International Professional Services. ENDORSEMENT: Requests GRANTED. International Professional Services answer due 6/12/2017. ( Replies due by 6/5/2017.) (Signed by Judge Valerie E. Caproni on 5/18/2017) (mro) [Transferred from New York Southern on 3/26/2018.] |
| Filing 31 LETTER addressed to Judge Valerie E. Caproni from Sarah Y. Khurana dated May 18, 2017 re: Extension of time to file (i) reply to motion; and (ii) response to Amended Complaint. Document filed by International Professional Services.(Khurana, Sarah)[Transferred from New York Southern on 3/26/2018.] |
| Filing 30 ELECTRONIC SUMMONS ISSUED as to Thomas Plamenco. (pc) [Transferred from New York Southern on 3/26/2018.] |
| Filing 29 ELECTRONIC SUMMONS ISSUED as to Joel Nazareno. (pc) [Transferred from New York Southern on 3/26/2018.] |
| Filing 28 MEMORANDUM OF LAW in Opposition re: #20 MOTION to Compel Arbitration . MOTION to Dismiss . . Document filed by America's Business Capital, LLC. (Attachments: #1 M. Sciore Decl., #2 Ex. A - 2014 ARMS General Agreement, #3 Ex. B - 2015 PSCF Agreement, #4 Ex. C - 2016 Alleged Agreement, #5 Exhibit 1 - ACH Authorization Form No. 1, #6 Exhibit 2 - ACH Authorization Form No. 2)(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 27 REQUEST FOR ISSUANCE OF SUMMONS as to Thomas Plamenco, re: #25 Amended Complaint,. Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 26 REQUEST FOR ISSUANCE OF SUMMONS as to Joel Nazareno, re: #25 Amended Complaint,. Document filed by America's Business Capital, LLC. (Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 25 AMENDED COMPLAINT amending #1 Complaint against International Professional Services, Joel Nazareno, Thomas Plamenco with JURY DEMAND.Document filed by America's Business Capital, LLC. Related document: #1 Complaint filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A)(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 24 MEMO ENDORSEMENT on re: #23 Letter, filed by America's Business Capital, LLC. ENDORSEMENT: Requests GRANTED. The initial pretrial conference is adjourned sine die pending resolution of the motions to compel arbitration and dismiss. Plaintiff's deadline to respond to Defendant's motions to compel arbitration and dismiss is adjourned to May 8, 2017, and Defendant's deadline to reply is adjourned to May 22, 2017. Defendant is encouraged to consult the undersigned's individual rules (Section 3(E)) in the event Plaintiff amends its complaint in response to Defendant's motion to dismiss. ( Responses due by 5/8/2017, Replies due by 5/22/2017.) (Signed by Judge Valerie E. Caproni on 4/26/2017) (kgo) [Transferred from New York Southern on 3/26/2018.] |
| Filing 23 LETTER addressed to Judge Valerie E. Caproni from LOUIS D. ABRAMS dated 4/26/2017 re: EXTENSION OF TIME TO FILE OPPOSITION TO MOTION TO COMPEL ARBITRATION AND REQUEST TO ADJOURN STATUS CONFERENCE. Document filed by America's Business Capital, LLC.(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 22 DECLARATION of Sarah Y. Khurana in Support re: #20 MOTION to Compel Arbitration . MOTION to Dismiss .. Document filed by International Professional Services. (Attachments: #1 Exhibit A - 2015 Agreement, #2 Exhibit B - 2016 Agreement, #3 Exhibit C - Correspondence, #4 Exhibit D - Correspondence)(Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
| Filing 21 MEMORANDUM OF LAW in Support re: #20 MOTION to Compel Arbitration . MOTION to Dismiss . . Document filed by International Professional Services. (Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
| Filing 20 MOTION to Compel Arbitration ., MOTION to Dismiss . Document filed by International Professional Services.(Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
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Filing 19
ORDER FOR ADMISSION PRO HAC VICE granting #18 Motion for Louis D. Abrams to Appear Pro Hac Vice. (Signed by Judge Valerie E. Caproni on 4/17/2017) (jwh) [Transferred from New York Southern on 3/26/2018.]
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| Filing 18 MOTION for LOUIS D. ABRAMS to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-13550576. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A - Certificate of Good Standing, #2 Exhibit B - Affidavit of Louis D. Abrams, #3 Text of Proposed Order)(Abrams, Louis) [Transferred from New York Southern on 3/26/2018.] |
| Filing 17 NOTICE OF APPEARANCE by Sarah Yeang Khurana on behalf of International Professional Services. (Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
| Filing 16 NOTICE OF APPEARANCE by Martin Paul Russo on behalf of International Professional Services. (Russo, Martin) [Transferred from New York Southern on 3/26/2018.] |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #18 MOTION for LOUIS D. ABRAMS to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-13550576. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (jc) [Transferred from New York Southern on 3/26/2018.] |
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Filing 15
ORDER FOR ADMISSION PRO HAC VICE: granting #13 Motion for Nicholas C. Harbist to Appear Pro Hac Vice. (Signed by Judge Valerie E. Caproni on 4/5/2017) (ap) [Transferred from New York Southern on 3/26/2018.]
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| Filing 14 MEMO ENDORSEMENT on re: #11 Letter filed by International Professional Services. ENDORSEMENT: Request GRANTED. (International Professional Services answer due 4/17/2017.) (Signed by Judge Valerie E. Caproni on 4/5/2017) (ras) [Transferred from New York Southern on 3/26/2018.] |
| Filing 13 AMENDED MOTION for Nicholas C. Harbist to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by America's Business Capital, LLC. (Attachments: #1 Affidavit of Nicholas C. Harbist in Support, #2 Certificate of Good Standing, #3 Text of Proposed Order)(Harbist, Nicholas) [Transferred from New York Southern on 3/26/2018.] |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #13 AMENDED MOTION for Nicholas C. Harbist to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu) [Transferred from New York Southern on 3/26/2018.] |
| >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #12 MOTION for Nicholas C. Harbist to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-13498836. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): Missing Attorney Affidavit/Declaration. Please Read Local Rule 1.3;. Re-file the motion as a Corrected Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (bcu) [Transferred from New York Southern on 3/26/2018.] |
| Filing 12 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Nicholas C. Harbist to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-13498836. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A - Certificate of Good Standing, #2 Text of Proposed Order)(Harbist, Nicholas) Modified on 4/4/2017 (bcu). [Transferred from New York Southern on 3/26/2018.] |
| Filing 11 LETTER addressed to Judge Valerie E. Caproni from Sarah Y. Khurana, Esq. dated April 3, 2017 re: Extension of Time to Respond to Complaint. Document filed by International Professional Services.(Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
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Filing 10
MEMO ENDORSEMENT on re: #8 Letter filed by International Professional Services. ENDORSEMENT: Application GRANTED. The initial pretrial conference is adjourned to April 28, 2017, at 10:00 a.m. in courtroom 443 of the Thurgood Marshall Courthouse. The parties' joint letter and case management plan are due no later than April 20, 2017, in accordance with the Court's February 22, 2017 order (Dkt. 6). ( Initial Conference set for 4/28/2017 at 10:00 AM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 3/30/2017) (mro) [Transferred from New York Southern on 3/26/2018.]
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| Filing 9 JOINT PRE-CONFERENCE STATEMENT . Document filed by America's Business Capital, LLC. (Attachments: #1 Exhibit Joint Discovery Plan)(Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
| Filing 8 LETTER addressed to Judge Valerie E. Caproni from Sarah Y. Khurana, Esq. dated March 30, 2017 re: Request for adjournment of ICMC. Document filed by International Professional Services.(Khurana, Sarah) [Transferred from New York Southern on 3/26/2018.] |
| Filing 7 SUMMONS RETURNED EXECUTED Summons and Complaint served. International Professional Services served on 3/1/2017, answer due 3/22/2017. Service was accepted by Andrew Ragavanis, Vice President. Document filed by America's Business Capital, LLC. (Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
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Filing 6
NOTICE OF INITIAL PRETRIAL CONFERENCE: Initial Conference set for 4/7/2017 at 10:00 AM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni, and as further set forth in this order. (Signed by Judge Valerie E. Caproni on 02/22/2017) (ap) Modified on 2/22/2017 (ap). Modified on 2/24/2017 (ap). [Transferred from New York Southern on 3/26/2018.]
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| Filing 5 ELECTRONIC SUMMONS ISSUED as to International Professional Services. (kl) [Transferred from New York Southern on 3/26/2018.] |
| ***NOTICE TO ATTORNEY REGARDING CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Andrew T. Hambelton. The following case opening statistical information was erroneously selected/entered: County code New York. The following correction(s) have been made to your case entry: the County code has been modified to XX Out of State. (kl) [Transferred from New York Southern on 3/26/2018.] |
| ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Andrew T. Hambelton. The party information for the following party/parties has been modified: International Professional Services, d/b/a PSC, Inc.. The information for the party/parties has been modified for the following reason/reasons: party role was entered incorrectly; alias party name was omitted. (kl) [Transferred from New York Southern on 3/26/2018.] |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Valerie E. Caproni. Please download and review the Individual Practices of the assigned District Judge, located at #http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #http://nysd.uscourts.gov/ecf_filing.php. (kl) [Transferred from New York Southern on 3/26/2018.] |
| Magistrate Judge James L. Cott is so designated. (kl) [Transferred from New York Southern on 3/26/2018.] |
| Case Designated ECF. (kl) [Transferred from New York Southern on 3/26/2018.] |
| Filing 4 REQUEST FOR ISSUANCE OF SUMMONS as to International Professional Services, re: #1 Complaint. Document filed by America's Business Capital, LLC. (Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
| Filing 3 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by America's Business Capital, LLC.(Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
| Filing 2 CIVIL COVER SHEET filed. (Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
| Filing 1 COMPLAINT against International Professional Services, d/b/a PSC, Inc.. (Filing Fee $ 400.00, Receipt Number 0208-13339128)Document filed by America's Business Capital, LLC. (Attachments: #1 Exhibit A)(Hambelton, Andrew) [Transferred from New York Southern on 3/26/2018.] |
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