Terra Towers Corp. et al v. Gelber Schachter & Greenberg, P.A. et al
| Terra Towers Corp. and TBS Management, S.A. |
| GELBER SCHACHTER & GREENBERG, P.A., CONTINENTAL TOWERS LATAM HOLDINGS LIMITED, Telecom Business Solution, LLC, Latam Towers, LLC, AMLQ HOLDINGS (CAY) LTD., DT HOLDINGS, INC. and ADAM MICHAEL SCHACHTER |
| 1:2022cv06150 |
| July 19, 2022 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| Valerie E Caproni |
| Lewis A Kaplan |
| Other Statutes: Arbitration |
| 28 U.S.C. § 1441 nr Notice of Removal |
| None |
Docket Report
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This docket was last retrieved on August 26, 2022. A more recent docket listing may be available from PACER.
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| Filing 87 NOTICE OF APPEARANCE by Katherine Michelle Poldneff on behalf of Latam Towers, LLC, Telecom Business Solution, LLC..(Poldneff, Katherine) |
| Filing 86 NOTICE OF APPEARANCE by David A Landman on behalf of Latam Towers, LLC, Telecom Business Solution, LLC..(Landman, David) |
Filing 85
MEMO ENDORSED ORDER granting #82 Motion to Seal. ENDORSEMENT: Granted. SO ORDERED. (Signed by Judge Lewis A. Kaplan on 8/23/22) (yv)
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| Filing 84 ***SELECTED PARTIES*** LETTER addressed to Judge Lewis A. Kaplan from Gregg L. Weiner, Stephanie A. Casey, and Michael N. Ungar dated August 22, 2022 re: seeking leave to file, under seal, a copy of the Second Partial Final Award. Document filed by Latam Towers, LLC, GELBER SCHACHTER & GREENBERG, P.A., AMLQ HOLDINGS (CAY) LTD., ADAM MICHAEL SCHACHTER, TBS Management, S.A., DT HOLDINGS, INC., CONTINENTAL TOWERS LATAM HOLDINGS LIMITED, Terra Towers Corp., Telecom Business Solution, LLC.Motion or Order to File Under Seal: #82 .(Weiner, Gregg) |
| Filing 83 MEMORANDUM OF LAW in Support re: #82 MOTION to Seal August 22, 2022 Letter to the Court. . Document filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., Latam Towers, LLC, ADAM MICHAEL SCHACHTER, Telecom Business Solution, LLC..(Weiner, Gregg) |
| Filing 82 MOTION to Seal August 22, 2022 Letter to the Court. Document filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., Latam Towers, LLC, ADAM MICHAEL SCHACHTER, Telecom Business Solution, LLC..(Weiner, Gregg) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #81 MOTION for Roberto Martinez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26555565. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| Filing 81 MOTION for Roberto Martinez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26555565. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER. (Attachments: #1 Exhibit Exh A Affidavit in Support of Mtn to Appear Pro Hac Vice Roberto Martinez-, #2 Exhibit Exhibit B - Certificate of Good Standing, #3 Text of Proposed Order Proposed Order for Admission Pro Hac Vice Roberto Martinez).(Martinez, Roberto) |
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Filing 80
ORDER GRANTING MOTION TO ADMIT COUNSEL PRO HAC VICE granting #78 Motion for Katherine M. McDonald to Appear Pro Hac Vice. The motion of Katherine M. McDonald ("Applicant") for admission to practice pro hac vice in the above-captioned action is GRANTED. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned action in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. So ORDERED. (Signed by Judge Lewis A. Kaplan on 8/11/22) (yv)
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Filing 79
ORDER GRANTING MOTION TO ADMIT COUNSEL PRO HAC VICE granting #77 Motion for Daniel V. Ward to Appear Pro Hac Vice. The motion of Daniel V. Ward ("Applicant") for admission to practice pro hac vice in the above-captioned action is GRANTED. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned action in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. So ORDERED. (Signed by Judge Lewis A. Kaplan on 8/11/22) (yv) Modified on 8/11/2022 (yv).
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| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #77 MOTION for Daniel V. Ward to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26531108. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #78 MOTION for Katherine M. McDonald to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26531144. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| Filing 78 MOTION for Katherine M. McDonald to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26531144. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by AMLQ HOLDINGS (CAY) LTD...(McDonald, Katherine) |
| Filing 77 MOTION for Daniel V. Ward to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26531108. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by AMLQ HOLDINGS (CAY) LTD...(Ward, Daniel) |
| >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE re: Document No. #76 MOTION for Roberto Martinez to Appear Pro Hac Vice . Filing fee $ 200.00. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Florida; the filing fee was not paid; Ink Signature Needed When Not Using Own Pacer Account; Re-file the motion as a 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. Pay the filing fee using the event Pro Hac Vice Fee Payment found under the event list Other Documents. (sgz) |
| Filing 76 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Roberto Martinez to Appear Pro Hac Vice . Filing fee $ 200.00. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER. (Attachments: #1 Affidavit Exh A Affidavit in Support of Mtn to Appear Pro Hac Vice Roberto Martinez, #2 Exhibit Exhibit B - Certificate of Good Standing, #3 Text of Proposed Order Proposed Order for Admission Pro Hac Vice Roberto Martinez).(Casey, Stephanie) Modified on 8/9/2022 (sgz). |
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Filing 75
ORDER FOR ADMISSION PRO HAC VICE granting #70 Motion for Andy Hernandez to Appear Pro Hac Vice. The motion of Andy Hernandez for admission pro hac vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing the discipline of attorneys. (Signed by Judge Lewis A. Kaplan on 8/8/22) (yv)
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| Filing 74 LETTER addressed to Judge Lewis A. Kaplan from Michael N. Ungar, Gregg L. Weiner, and Stephanie A. Casey dated August 5, 2022 re: the Moving Parties' pending motions in Case II. Document filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., Latam Towers, LLC, ADAM MICHAEL SCHACHTER, Telecom Business Solution, LLC..(Weiner, Gregg) |
| Filing 73 NOTICE OF APPEARANCE by Gregg L Weiner on behalf of AMLQ HOLDINGS (CAY) LTD...(Weiner, Gregg) |
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Filing 72
ORDER FOR ADMISSION PRO HAC VICE granting #69 Motion for Luke Thomas Jacobs to Appear Pro Hac Vice. The motion of Luke T. Jacobs for admission pro hac vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing the discipline of attorneys. (Signed by Judge Lewis A. Kaplan on 8/4/22) (yv)
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Filing 71
ORDER FOR ADMISSION PRO HAC VICE granting #68 Motion for Juan Jose Rodriguez to Appear Pro Hac Vice. The motion of Juan J. Rodriguez for admission pro hac vice in the above-captioned actionis granted. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing the discipline of attorneys. (Signed by Judge Lewis A. Kaplan on 8/4/22) (yv)
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| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #70 MOTION for Andy Hernandez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26497792. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| Filing 70 MOTION for Andy Hernandez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26497792. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by TBS Management, S.A., Terra Towers Corp.. (Attachments: #1 Exhibit A - Affidavit, #2 Exhibit B - Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Hernandez, Andy) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #69 MOTION for Luke Thomas Jacobs to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26492648. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #68 MOTION for Juan Jose Rodriguez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26492476. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) |
| Filing 69 MOTION for Luke Thomas Jacobs to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26492648. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by TBS Management, S.A., Terra Towers Corp.. (Attachments: #1 Exhibit A - Affidavit, #2 Exhibit B - Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Jacobs, Luke) |
| Filing 68 MOTION for Juan Jose Rodriguez to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26492476. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by TBS Management, S.A., Terra Towers Corp.. (Attachments: #1 Exhibit A - Affidavit, #2 Exhibit B - Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Rodriguez, Juan) |
| NOTICE OF CASE REASSIGNMENT to Judge Lewis A. Kaplan. Judge Valerie E. Caproni is no longer assigned to the case. (vba) |
| NOTICE OF REDESIGNATION TO ANOTHER MAGISTRATE JUDGE. The above entitled action has been redesignated to Magistrate Judge Robert W. Lehrburger. Please note that this is a reassignment of the designation only. (vba) |
| Filing 67 CASE TRANSFERRED IN from the United States District Court - District of Florida Southern; Case Number: 1:22-cv-21204. Original file certified copy of transfer order and docket entries received. |
| CASE OPENING INITIAL ASSIGNMENT NOTICE - TRANSFER CASE: This case is assigned to: Judge Valerie E. Caproni. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. 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 #https://nysd.uscourts.gov/rules/ecf-related-instructions..(vba) |
| Magistrate Judge Katharine H. Parker is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vba) |
| NOTE TO OUT OF STATE ATTORNEYS: Please visit the Court's website at https://nysd.uscourts.gov/ for information regarding admission to the S.D.N.Y. Bar and the CM/ECF Rules & Filing Instructions. (vba) |
| Case Designated ECF. (vba) |
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Filing 66
ORDER Transferring Case: denying #38 Motion to Remand to State Court; granting #14 Motion to Transfer Venue. Transferring this Action to the United States District Court for the Southern District of New York. Signed by Judge Robert N. Scola, Jr. on 7/18/2022. See attached document for full details. (ls) [Transferred from Florida Southern on 7/19/2022.]
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| Civil Case Terminated. Closing Case. (ls) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 65 REPLY to Response to Motion re #56 MOTION for Discovery limited to the issue of Personal Jurisdiction filed by TBS Management, S.A., Terra Towers Corp.. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 64
PAPERLESS ORDER: The Court grants #63 the Plaintiffs' unopposed motion for an extension of time to reply in support of their motion for jurisdictional discovery. The Plaintiffs must file their reply on or before July 8, 2022. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 63 MOTION for Extension of Time to File Response/Reply/Answer as to #56 MOTION for Discovery limited to the issue of Personal Jurisdiction by TBS Management, S.A.. (Attachments: #1 Text of Proposed Order)(Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 62 RESPONSE in Opposition re #56 MOTION for Discovery limited to the issue of Personal Jurisdiction filed by AMLQ Holdings (Cay) Ltd., Latam Towers, LLC, Telecom Business Solution, LLC. Replies due by 7/1/2022. (Jimenez, Marcos)[Transferred from Florida Southern on 7/19/2022.] |
| Filing 61 RESPONSE in Support re #17 Defendant's MOTION to Compel Arbitration or in the Alternative Stay the Proceedings Pending Arbitration filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 60 RESPONSE in Support re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM , #13 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, filed by AMLQ HOLDINGS (CAY) LTD., LATAM TOWERS, LLC, TELECOM BUSINESS SOLUTION, LLC. (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 59 RESPONSE in Support re #6 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM filed by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER. (Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 58
ORDER OF RECUSAL. Magistrate Judge Jonathan Goodman recused. Case reassigned to Magistrate Judge Melissa Damian for all further proceedings Signed by Magistrate Judge Jonathan Goodman on 6/14/2022. See attached document for full details. (jc) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 57 REPLY to Response to Motion re #38 Plaintiff's MOTION to Remand to State Court filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 56 MOTION for Discovery limited to the issue of Personal Jurisdiction by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 6/24/2022 (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 55 REPLY to Response to Motion re #14 MOTION to Change Venue filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 54
PAPERLESS ORDER: The Court grants #53 the Defendants' unopposed motion for extensions of time to reply in support of a number of pending motions in this case. The Defendants must file their various replies in support of #6 #12 #13 #17 these motions on or before June 22, 2022. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Reset Deadlines/Hearings per de# 54 as to #13 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, , #17 Defendant's MOTION to Compel Arbitration or in the Alternative Stay the Proceedings Pending Arbitration, #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM , #6 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM . Replies due by 6/22/2022. (drz) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 53 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM , #13 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, , #6 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM , #17 Defendant's MOTION to Compel Arbitration or in the Alternative Stay the Proceedings Pending Arbitration by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. (Attachments: #1 Text of Proposed Order A)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 52
PAPERLESS ORDER: The Court grants #51 the Plaintiffs' unopposed motion for extension of time to reply in support of their motion to remand. The Plaintiffs must file their reply on or before June 13, 2022. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 51 MOTION for Extension of Time to File Response/Reply/Answer by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 50 RESPONSE in Opposition re #17 Defendant's MOTION to Compel Arbitration or in the Alternative Stay the Proceedings Pending Arbitration filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Replies due by 6/13/2022. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 49 RESPONSE in Opposition re #13 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Replies due by 6/13/2022. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 48 RESPONSE in Opposition re #12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Replies due by 6/13/2022. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 47 RESPONSE in Opposition re #6 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Replies due by 6/13/2022. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 46
PAPERLESS ORDER: The Court grants #45 the Defendants' unopposed motion for an extension of time to reply in support of their motion to transfer venue. The Defendants must file their reply on or before June 10, 2022. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 45 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to #14 MOTION to Change Venue by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. (Attachments: #1 Text of Proposed Order A)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 44 RESPONSE in Opposition re #38 Plaintiff's MOTION to Remand to State Court filed by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. Replies due by 6/8/2022. (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 43 Joint SCHEDULING REPORT - Rule 26(f) by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER (Attachments: #1 Text of Proposed Order)(Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 42 RESPONSE in Opposition re #14 MOTION to Change Venue filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Replies due by 6/3/2022. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 41 REPLY to Response to Motion re #35 Amended MOTION to Amend/Correct Complaint filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 40
PAPERLESS ORDER: The Court grants in part and denies in part #39 the Plaintiffs' mostly opposed motion for extensions of time to respond to five motions filed by various Defendants in this case: three separate #6 #12 #13 motions to dismiss; and one #14 motion to transfer venue and one #17 motion to compel arbitration, both filed by Defendants Telecom Business Solution, LLC; LATAM Towers, LLC; AMLQ Holdings (Cay) Ltd.; Adam M. Schachter; and Gelber Schachter & Greenberg, P.A. The Court grants the Plaintiffs' motion as it relates to the three motions to dismiss and the motion to compel arbitration but denies it, in part, as it relates to the motion to transfer venue. Accordingly, the Plaintiffs must file their responses to #14 the motion to transfer venue on or before May 27, 2022 but have until on or before June 6, 2022 to respond to #6 #12 #13 the three motions to dismiss and #17 the motion to compel arbitration. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 39 MOTION for Extension of Time to File Response/Reply/Answer to ECF Nos. 6, 12, 13, 14 and 17 by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 38 Plaintiff's MOTION to Remand to State Court by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Rodriguez, Juan) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 37 NOTICE Of Filing May 9, 2022 Order In Support Of Their Opposition To Plaintiffs' Amended Renewed Motion For Leave To Amend Complaint by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER re #36 Response to Motion, (Attachments: #1 Exhibit Arbitral Tribunal's May 9, 2022 Order) (Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 36 Joint RESPONSE to Motion re #35 Amended MOTION to Amend/Correct Complaint Defendants' Joint Response to Plaintiffs' Amended Renewed Motion for Leave to Amend Complaint filed by GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. Replies due by 5/23/2022. (Attachments: #1 Exhibit 1: Email string dated May 11, 2022, #2 Exhibit 2: BVI Business Companies Act)(Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 35 Amended MOTION to Amend/Correct Complaint by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/27/2022 (Attachments: #1 Exhibit A)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 34 NOTICE of Striking #32 Renewed MOTION to Amend/Correct Complaint filed by TBS MANAGEMENT, S.A., TERRA TOWERS CORP by TBS MANAGEMENT, S.A., TERRA TOWERS CORP (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 33 Clerks Notice to Filer re #32 Renewed MOTION to Amend/Correct Complaint. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match the typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and Local Rule 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules. (kpe) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 32 STRICKEN Renewed MOTION to Amend/Correct Complaint by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/26/2022 (Attachments: #1 Exhibit A)(Jacobs, Luke) Modified on 5/13/2022 per DE #34 Notice (kpe). [Transferred from Florida Southern on 7/19/2022.] |
| Filing 31 AMENDED JOINT NOTICE OF REMOVAL by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC re #1 Notice of Removal (State Court Complaint),,,,, 30 Order on Motion for Extension of Time to File Response/Reply/Answer,,,,,,,,,,,,, Order on Motion for Reconsideration,,,,,,,,,,,,,,,,,,,,,,,,, Amended Joint Notice of Removal (Attachments: #1 Civil Cover Sheet, #2 Docket Sheet A-0 State Court Docket Sheet, #3 Exhibit A-1 State Court Civil Cover Sheet, #4 Exhibit A-2 Complaint, #5 Exhibit A-3 Notice of Filing Arising From International Commercial Arbitration, #6 Summon(s) A-4 Proposed Summons: Adam Michael Schachter, #7 Summon(s) A-5 Proposed Summons: AMLQ Holdings (Cay) Ltd., #8 Summon(s) A-6 Proposed Summons: Continental Towers Latam Holdings Limited, #9 Summon(s) A-7 Proposed Summons: DT Holdings, Inc., #10 Summon(s) A-8 Proposed Summons: Gelber Schachter & Greenberg, P.A.,, #11 Summon(s) A-9 Proposed Summons: Latam Towers, LLC, #12 Summon(s) A-10 Proposed Summons: Telecom Business Solution, LLC., #13 Exhibit A-11 George Kroup Verified Motion For Admission To Appear Pro Hac Vice Pursuant To Florida Rule Of General Practice And Judicial Administration 2.510, #14 Exhibit A-12 John Baughman Verified Motion For Admission To Appear Pro Hac Vice Pursuant To Florida Rule Of General Practice And Judicial Administration 2.510, #15 Summon(s) A-13 Summons: Adam Michael Schachter, #16 Summon(s) A-14 Summons: DT Holdings, Inc., #17 Summon(s) A-15 Summons: Gelber Schachter & Greenberg, P.A., #18 Exhibit A-16 Order Granting Verified Motions To Appear Pro Hac Vice Baughman and Kroup, #19 Exhibit A-17 George Kroup Verified Motion For Admission To Appear Pro Hac Vice Pursuant To Florida Rule Of General Practice And Judicial Administration 2.510, #20 Summon(s) A-18 Summons: AMLQ Holdings (Cay) Ltd., #21 Summon(s) A-19 Summons: Continental Towers Latam Holdings Limited, #22 Summon(s) A-20 Summons: Latam Towers, LLC, #23 Summon(s) A-21 Summons: Telecom Business Solution, LLC,, #24 Exhibit A-22 Return of Service Summons: Gelber Schachter & Greenberg, P.A., #25 Exhibit A-23 Return of Service Summons: Adam Michael Schachter, #26 Exhibit A-24 Answer To Complaint by DT Holdings, Inc., #27 Exhibit B Shareholders Agreement, #28 Exhibit C Development Agreement, #29 Exhibit D Peppertree_AMLQs Acceptance of Service) (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 30
PAPERLESS ORDER: The Court denies #28 the Plaintiffs' motion for reconsideration. The Court's order, denying the Plaintiffs' motion for leave to amend, was explicitly entered "without prejudice" which affords the Plaintiffs the opportunity, without further Court intervention, to simply refile their motion if they determine refiling is warranted. The motion cannot simply be "reinstated," as is, because the initial motion fails to set forth the actual procedural history of the case, which supports seeking amendment under Federal Rule of Civil Procedure 15(a)(2), as opposed to Rule 15(a)(1)(B). If the Plaintiffs wish to file an amended motion, they may do so, but without delay and without the Court's reconsidering its order. Further, the Court notes that, as indicated in the Plaintiffs' certificate of conferral, the Defendants have changed their position regarding the requested amendment: from taking "no position," initially, to now intending to oppose any further motion for leave to amend. To move this case along, then, and to the extent the Plaintiffs intend to file an amended motion for leave to amend their complaint, they must do so by noon on May 12, 2022, and the Defendants must file their joint response by noon on May 16. All counsel must immediately make themselves readily available for a fulsome, good-faith Local Rule 7.1(a)(3) conferral before the filing of the Plaintiffs' motion, which itself must include a detailed description of those efforts. In the meantime, the Court grants #22 and #29 the Plaintiffs' (now) unopposed motions for extensions of time to respond to the Defendants' various motions: to simplify, the Plaintiffs must file their responses to #6 , #12 . #13 . #14 , and #17 the Defendants' motions on or before May 23, 2022. Finally, the Court has independently reviewed the Defendants' notice of removal and its associated attachments. The attachments were filed in violation of the Court's CM/ECF Next Gen Administrative Procedure 3L(2). Under that rule, filers must, among other things, "descriptively name each attachment." By simply labeling an attachment as an "exhibit," as was done here with many of the attachments, the Court cannot readily locate, identify, or distinguish the documents associated with removal. Complying with this rule is particularly important here, where a large number of the Defendants' twenty-nine attachments were generically labeled, preventing the Court from easily divining their significance - especially when one of those attachments was actually a Defendant's answer to the complaint in the state court. Accordingly, the Court strikes #1 the Defendants' notice and orders them to file an amended notice, on or before May 11, in compliance with Rule 3L(2). Other than ministerial changes relating to complying with the attachment procedure, no other changes to the notice itself may be made. Signed by Judge Robert N. Scola, Jr. [Transferred from Florida Southern on 7/19/2022.]
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| Filing 29 Unopposed MOTION for Extension of Time to file Response Memorandums by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/23/2022 (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 28 MOTION for Reconsideration re 27 Order on Motion for Leave to File,,, by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 27
PAPERLESS ORDER: The Court denies, without prejudice, #25 the Plaintiffs' motion for leave to amend their complaint under Rule 15(a)(2). As set forth in Federal Rule of Civil Procedure Rule 15(a)(1)(B), a plaintiff may amend its pleading, as of right, within twenty-one days after either service of a responsive pleading or service of a motion under Rule 12(b), (e), or (f), whichever is earlier. It does not appear that, here, any responsive pleadings have been filed and the docket reflects that the earliest motion to dismiss, under Rule 12(b), was filed fewer than twenty-one days ago. Accordingly, it would seem, then, that Rule 15(a)(2), upon which the Plaintiffs rely, is not applicable and the Court, therefore, may not permit amendment on that basis. Instead, the Plaintiffs must look to Rule 15(a)(1)(B) and proceed accordingly. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 26 RESPONSE to Motion re #22 MOTION for Extension of Time to File Response/Reply/Answer GSG's Motion to Dismiss filed by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER. Replies due by 5/16/2022. (Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 25 MOTION for Leave to File First Amended Complaint by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Attachments: #1 Exhibit A)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 24
ORDER Requiring Requiring Discovery and Scheduling Conference andOrder Referring Discovery Matters to Magistrate Judge Jonathan Goodman. Signed by Judge Robert N. Scola, Jr on 5/6/2022. See attached document for full details. (pes) [Transferred from Florida Southern on 7/19/2022.]
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Filing 23
PAPERLESS ORDER: To expedite the briefing of #22 the Plaintiffs' opposed motion for an extension of time to respond to #6 Defendants Adam Michael Schachter and Gelber Schachter & Greenberg, P.A.'s motion to dismiss, the Court orders the Defendants to respond to the motion seeking an extension on or before May 9, 2022. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 22 MOTION for Extension of Time to File Response/Reply/Answer GSG's Motion to Dismiss by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 21
PAPERLESS ORDER: The Court denies #20 the Plaintiffs' amended motion to stay all proceedings pending the Court's determination of an, as yet, unfiled motion to remand. The Plaintiffs are essentially requesting, improperly, an open-ended extension based on a motion to remand that is, at this point, purely theoretical. Further, the filing of a motion to remand would not, in and of itself, necessarily obviate the need for the Plaintiffs to respond to the bulk of the Defendants pending motions. Finally, because the Plaintiffs have not actually filed a motion to remand, nor even hinted at its substance, the Court has no way of evaluating whether a stay in the case is warranted. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 20 Amended MOTION to Stay all Proceedings in this action pending the Courts determination on Plaintiffs forthcoming Motion to Remand by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/18/2022 (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 19 Unopposed MOTION to Stay all Proceedings in this action pending the Courts determination on Plaintiffs forthcoming Motion to Remand by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/18/2022 (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 18
ORDER Granting #15 , #16 Motions to Withdraw. Attorney John F. Baughman representing TERRA TOWERS CORP (Plaintiff) and TBS MANAGEMENT, S.A. (Plaintiff); Attorney George W. Kroup representing TERRA TOWERS CORP (Plaintiff) and TBS MANAGEMENT, S.A. (Plaintiff); terminated. Notice of Termination delivered by US Mail to John Baughman, George Kroup. Signed by Judge Robert N. Scola, Jr on 4/27/2022. See attached document for full details. (pes) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 17 Defendant's MOTION to Compel Arbitration or in the Alternative Stay the Proceedings Pending Arbitration by AMLQ HOLDINGS (CAY) LTD., CONTINENTAL TOWERS LATAM HOLDINGS LIMITED, DT HOLDINGS, INC., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. Attorney Marcos Daniel Jimenez added to party CONTINENTAL TOWERS LATAM HOLDINGS LIMITED(pty:dft), Attorney Marcos Daniel Jimenez added to party DT HOLDINGS, INC.(pty:dft), Attorney Marcos Daniel Jimenez added to party GELBER SCHACHTER & GREENBERG, P.A.(pty:dft), Attorney Marcos Daniel Jimenez added to party ADAM MICHAEL SCHACHTER(pty:dft). Responses due by 5/10/2022 (Attachments: #1 Exhibit Declaration of Gregg L. Weiner)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 16 MOTION to Withdraw as Attorney by John F. Baughman for / by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/10/2022 (Attachments: #1 Text of Proposed Order)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 15 MOTION to Withdraw as Attorney by George W. Kroup for / by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/10/2022 (Attachments: #1 Text of Proposed Order)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 14 MOTION to Change Venue by AMLQ HOLDINGS (CAY) LTD., GELBER SCHACHTER & GREENBERG, P.A., LATAM TOWERS, LLC, ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. Responses due by 5/9/2022 (Attachments: #1 Exhibit Exhibit A - Shareholders Agreement, #2 Exhibit Exhibit B - Development Agreement, #3 Exhibit Exhibit C - Order)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 13 MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM , MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, ( Responses due by 5/9/2022) by AMLQ HOLDINGS (CAY) LTD.. (Attachments: #1 Exhibit Declaration of Carey Ziegler)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 12 MOTION to Dismiss for Lack of Jurisdiction #1 Notice of Removal (State Court Complaint),,,,, , MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM ( Responses due by 5/9/2022) by LATAM TOWERS, LLC, TELECOM BUSINESS SOLUTION, LLC. (Attachments: #1 Exhibit Declaration of John J. Ranieri)(Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
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Filing 11
PAPERLESS ORDER: The Court denies #8 counsel's motion to appear pro hac vice. As explained by the Clerk's notice of noncompliance, counsel is a member of the Florida Bar and resides or practices within the district. He is, therefore, as provided by Local Rule 4(a) of the Rules Governing the Admission, Practice, Peer Review, and Discipline of Attorneys, expected to be a member of the bar of this Court. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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Filing 10
PAPERLESS ORDER: The Court grants #9 counsel's motion to withdraw from her representation of the Plaintiffs. The Plaintiffs will continue to be represented by other counsel of record. The Clerk is directed to terminate attorney of Jennifer M. Hernandez from this case. Signed by Judge Robert N. Scola, Jr. (kbe) [Transferred from Florida Southern on 7/19/2022.]
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| Filing 9 MOTION to Withdraw as Attorney by Jennifer M. Hernandez for / by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/6/2022 (Attachments: #1 Text of Proposed Order)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 8 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Andy Hernandez. Filing Fee $ 200.00 Receipt # AFLSDC-15582778 by TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Responses due by 5/6/2022 (Attachments: #1 Exhibit Certification of Attorney, #2 Text of Proposed Order)(Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 7 NOTICE of Attorney Appearance by Luke Thomas Jacobs on behalf of TBS MANAGEMENT, S.A., TERRA TOWERS CORP. Attorney Luke Thomas Jacobs added to party TBS MANAGEMENT, S.A.(pty:pla), Attorney Luke Thomas Jacobs added to party TERRA TOWERS CORP(pty:pla). (Jacobs, Luke) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 6 Defendant's MOTION TO DISMISS #1 Notice of Removal (State Court Complaint),,,,, FOR FAILURE TO STATE A CLAIM by GELBER SCHACHTER & GREENBERG, P.A., ADAM MICHAEL SCHACHTER. Responses due by 5/5/2022 (Martinez, Roberto) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 5 CORRECTED Bar Letter re: Admissions sent to attorneys John F. Baughman and George W. Kroup, mailing date April 20, 2022. Correction to case number. (cw) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 4 Bar Letter re: Admissions sent to attorneys John F. Baughman and George W. Kroup, mailing date April 20, 2022. (cw) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 3 NOTICE by AMLQ HOLDINGS (CAY) LTD., LATAM TOWERS, LLC, TELECOM BUSINESS SOLUTION, LLC of Certification of Filing Notice of Removal (Attachments: #1 Exhibit A) (Jimenez, Marcos) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 2 Clerks Notice of Judge Assignment to Judge Robert N. Scola, Jr. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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. (kpe) [Transferred from Florida Southern on 7/19/2022.] |
| Filing 1 STRICKEN - NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $ 402.00 receipt number AFLSDC-15568688, filed by LATAM TOWERS, LLC, GELBER SCHACHTER & GREENBERG, P.A., AMLQ HOLDINGS (CAY) LTD., ADAM MICHAEL SCHACHTER, TELECOM BUSINESS SOLUTION, LLC. (Attachments: #1 Civil Cover Sheet, #2 Docket Sheet, #3 A-1 State Court Civil Sheet, #4 A-2 COMPLAINT, #5 Exhibit A-3, #6 Summon(s) A-4 Adam Michael Schachter, #7 Summon(s) A-5 AMLQ HOLDINGS (CAY) LTD., #8 Summon(s) A-6 CONTINENTAL TOWERS LATAM HOLDINGS LIMITED, #9 Summon(s) A-7 DT HOLDINGS, INC, #10 Summon(s) A-8 GELBER SCHACHTER & GREENBERG, P.A, #11 Summon(s) A-9 LATAM TOWERS, LLC., #12 Summon(s) A-10 TELECOM BUSINESS SOLUTION, LLC., #13 Exhibit A-11, #14 Exhibit A-12, #15 Summon(s) A-13 Adam Michael Schachter, #16 Summon(s) A-14 DT Holdings, Inc., #17 Summon(s) A-15 GELBER SCHACHTER & GREENBERG, P.A, #18 Exhibit A-16, #19 Exhibit A-17, #20 Exhibit A-18, #21 Summon(s) A-19 CONTINENTAL TOWERS LATAM HOLDINGS LIMITED, #22 Summon(s) A-20 LATAM TOWERS, LLC, #23 Summon(s) A-21 TELECOM BUSINESS SOLUTION, LLC, #24 Exhibit A-22, #25 Exhibit A-23, #26 Exhibit A-24, #27 Exhibit B, #28 Exhibit C, #29 Exhibit D)(Jimenez, Marcos)No answer/motion to dismiss filed by filers. Modified text on 4/19/2022 (kpe). Modified/Stricken per DE 30 on 5/11/2022 (pes). [Transferred from Florida Southern on 7/19/2022.] |
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