Florida Southern District Court
Judge:Raag Singhal
Referred: Jared M Strauss
Case #: 0:24-cv-60834
Nature of Suit440 Civil Rights - Other Civil Rights
Cause28:1331 Fed. Question: Civil Rights Violation
Case Filed:May 17, 2024
Last checked: Monday Jul 01, 2024 4:42 AM EDT
Defendant
Citibank, N.A.
Represented By
Alexander V. Maugeri
Jones Day
contact info
Eliot Pedrosa
Jones Day
contact info
Defendant
Citigroup Inc.
Represented By
Alexander V. Maugeri
Jones Day
contact info
Eliot Pedrosa
Jones Day
contact info
Plaintiff
Werner Jack Becker
Represented By
Brandon M. Haase
Consovoy Mccarthy PLLC
contact info
Bryan Weir
Consovoy Mccarthy PLLC
contact info
Daniel Joseph Shapiro
contact info
Plaintiff
Dana Guida
Represented By
Brandon M. Haase
Consovoy Mccarthy PLLC
contact info
Bryan Weir
Consovoy Mccarthy PLLC
contact info
Daniel Joseph Shapiro
contact info


Docket last updated: 09/06/2024 11:59 PM EDT
Monday, August 26, 2024
45 45 1 pgs order Order on Motion for Extension of Time to File Response/Reply/Answer Tue 08/27 10:35 AM
ORDER GRANTING IN PART44 PLAINTIFFS' MOTION for Extension of Time to File Response/Reply to Motion. Memorandum in Opposition due by 9/27/2024. Signed by Judge Raag Singhal on 8/26/2024. See attached document for full details. (caw)
Related: [-]
Friday, August 23, 2024
44 44 motion Extension of Time to File Response/Reply/Answer Fri 08/23 3:12 PM
MOTION for Extension of Time to File Response/Reply/Answer by Werner Jack Becker, Dana Guida.(Shapiro, Daniel)
Related: [-]
Att: 1 Text of Proposed Order
Monday, August 19, 2024
43 43 2 pgs order Order on Motion to Stay Mon 08/19 3:58 PM
ORDER: Defendants' Motion to Stay Discovery (DE42 ) is GRANTED. Discovery shall be stayed pending resolution of Defendants' Motion to Dismiss and until the Court enters a Scheduling Order Setting Case for Trial. Signed by Judge Raag Singhal on 8/19/2024. See attached document for full details. (wce)
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Wednesday, August 14, 2024
42 42 motion Stay Wed 08/14 8:49 PM
MOTION to Stay re41 MOTION to Dismiss for Lack of Jurisdiction36 Amended Complaint/Amended Notice of Removal by Citibank, N.A., Citigroup Inc.. Responses due by 8/28/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Exhibit 1 - Plaintiffs' Requests for Production,
Att: 2 Exhibit 2 - Plaintiffs' Interrogatories
41 41 motion Dismiss/Lack of Jurisdiction Wed 08/14 8:41 PM
MOTION to Dismiss for Lack of Jurisdiction36 Amended Complaint/Amended Notice of Removal by Citibank, N.A., Citigroup Inc.. Responses due by 8/28/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Exhibit 1 - Declaration of Marco Chavarin with Exhibits
Monday, August 05, 2024
40 40 order Order on Motion for Leave to File Excess Pages Mon 08/05 3:37 PM
PAPERLESS ORDER granting39 Motion for Leave to File Excess Pages. Defendant may file a Motion to Dismiss not exceeding 35 pages, double-spaced, no excessive footnotes. The same page limitation will apply to Plaintiffs' response to the Motion to Dismiss. Signed by Judge Raag Singhal on 8/5/2024. (pb00)
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39 39 motion File Excess Pages Mon 08/05 3:13 PM
Unopposed MOTION for Leave to File Excess Pages by Citibank, N.A., Citigroup Inc..(Pedrosa, Eliot)
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Att: 1 Text of Proposed Order Granting Defendants' Unopposed Motion to Enlarge Page Limit
Wednesday, July 31, 2024
38 38 order Order on Motion to Dismiss/Lack of Jurisdiction Order on Motion to Stay Wed 07/31 8:47 PM
PAPERLESS ORDER denying as moot29 Motion to Dismiss for Lack of Jurisdiction and33 Motion to Stay in light of Plaintiff's filing of a First Amended Complaint36 . Signed by Judge Raag Singhal on 7/31/2024. (jgr)
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37 37 respm Response in Opposition to Motion Wed 07/31 6:25 PM
RESPONSE in Opposition re33 Defendant's MOTION to Stay re29 MOTION to Dismiss for Lack of Jurisdiction1 Complaint Motion to Stay Discovery Pending Ruling on Motion to Dismiss filed by Werner Jack Becker, Dana Guida. Replies due by 8/7/2024. (Shapiro, Daniel)
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36 36 cmp Amended Complaint/Amended Notice of Removal Wed 07/31 3:15 PM
First AMENDED COMPLAINT against All Defendants, filed by Werner Jack Becker, Dana Guida.(Shapiro, Daniel)
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Monday, July 29, 2024
35 35 order Order Scheduling Mediation Mon 07/29 1:25 PM
PAPERLESS ORDER Scheduling Mediation before Michael Hanzman. Mediation Hearing set for 4/16/2025 at 09:00 AM. All parties and counsel must attend. Mediation report is due by 4/21/2025. Signed by Judge Raag Singhal on 7/29/2024. (jgr)
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Friday, July 26, 2024
34 34 adr Notice of Mediator Selection and/or Hearing Fri 07/26 2:41 PM
Joint NOTICE of Mediator Selection. Selected/Added Michael Hanzman as Mediator.(Pedrosa, Eliot)
Related: [-]
Att: 1 Text of Proposed Order
Thursday, July 18, 2024
33 33 motion Stay Thu 07/18 4:20 PM
Defendant's MOTION to Stay re29 MOTION to Dismiss for Lack of Jurisdiction1 Complaint Motion to Stay Discovery Pending Ruling on Motion to Dismiss by Citibank, N.A., Citigroup Inc.. Responses due by 8/1/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Exhibit Exhibit 1 - Plaintiffs' Request for Production,
Att: 2 Exhibit Exhibit 2 - Plaintiffs' Interrogatories
Monday, July 15, 2024
31 31 1 pgs order Order on Motion to Seal Mon 07/15 11:44 AM
ORDER GRANTING DEFENDANTS'30 UNOPPOSED MOTION TO FILE DOCUMENT UNDER SEAL. The document shall remain sealed until the Court enters an order unsealing it. Signed by Judge Raag Singhal on 7/12/2024. See attached document for full details. (scn)
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Wednesday, July 10, 2024
30 30 motion Motion to Seal (Public) Wed 07/10 5:39 PM
Unopposed MOTION to Seal per Local Rule 5.4 by Citibank, N.A., Citigroup Inc.. (Pedrosa, Eliot)
Related: [-]
Att: 1 Exhibit 1 - Agreement,
Att: 2 Text of Proposed Order
29 29 motion Dismiss/Lack of Jurisdiction Wed 07/10 5:32 PM
MOTION to Dismiss for Lack of Jurisdiction1 Complaint by Citibank, N.A., Citigroup Inc.. Responses due by 7/24/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Exhibit 1 - Declaration of Marco Chavarin with Exhibits
28 28 order Order on Motion to Appear Pro Hac Vice Wed 07/10 3:09 PM
PAPERLESS ORDER granting25 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Jayant W. Tambe. Jayant W. Tambe may appear and participate in this action on behalf of Defendants, Citigroup Inc. and Citibank, N.A. Signed by Judge Raag Singhal on 7/10/2024. (jgr)
Related: [-]
27 27 order Order on Motion to Appear Pro Hac Vice Wed 07/10 3:08 PM
PAPERLESS ORDER granting24 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Christopher C. Pagliarella. Christopher C. Pagliarella may appear and participate in this action on behalf of Defendants, Citigroup Inc. and Citibank, N.A. Signed by Judge Raag Singhal on 7/10/2024. (jgr)
Related: [-]
Monday, July 08, 2024
26 26 order Order on Motion for Leave to File Excess Pages Mon 07/08 6:38 PM
PAPERLESS ORDER granting23 Motion for Leave to File Excess Pages. Defendants Rule 12 motion in response to Plaintiffs' Complaint may not exceed 35 pages, doublespaced. Signed by Judge Raag Singhal on 7/8/2024. (jgr)
Related: [-]
Wednesday, July 03, 2024
25 25 motion Appear Pro Hac Vice - aty Wed 07/03 2:52 PM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Jayant W. Tambe. Filing Fee $ 200.00 Receipt # AFLSDC-17654449 by Citibank, N.A., Citigroup Inc.. Responses due by 7/17/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Certification Exhibit A - Certification,
Att: 2 Text of Proposed Order Exhibit B - Proposed Order
24 24 motion Appear Pro Hac Vice - aty Wed 07/03 2:44 PM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Christopher C. Pagliarella. Filing Fee $ 200.00 Receipt # AFLSDC-17654374 by Citibank, N.A., Citigroup Inc.. Responses due by 7/17/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Certification Exhibit A - Certification,
Att: 2 Text of Proposed Order Exhibit B - Proposed Order
Monday, July 01, 2024
23 23 motion File Excess Pages Mon 07/01 5:29 PM
MOTION for Leave to File Excess Pages by Citibank, N.A., Citigroup Inc..(Pedrosa, Eliot)
Related: [-]
Att: 1 Text of Proposed Order
Wednesday, June 26, 2024
22 22 order - Order (PAPERLESS or pdf attached) Wed 06/26 1:17 PM
DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jared M. Strauss on 6/26/2024. See attached document for full details. (emd)
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21 21 order Scheduling Order Order Referring Case to Mediation Order Referring Case to Magistrate Judge Wed 06/26 1:00 PM
ORDER SETTING TRIAL AND PRE-TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: (Jury Trial set for 8/25/2025 09:00 AM in Fort Lauderdale Division before Judge Raag Singhal., Calendar Call set for 8/20/2025 10:30 AM in Fort Lauderdale Division before Judge Raag Singhal., Amended Pleadings due by 8/12/2024., Discovery due by 5/7/2025., Expert Discovery due by 5/7/2025., Joinder of Parties due by 8/12/2024., In Limine Motions due by 6/25/2025., Dispositive Motions due by 5/21/2025., Pretrial Motions due by 5/21/2025., Joint Pretrial Stipulation due by 8/8/2025.), REFERRING CASE to Mediation. (Mediation Deadline 5/14/2025.), REFERRING CASE to Magistrate Judge Jared M. Strauss for all Discovery Matters. Signed by Judge Raag Singhal on 6/26/2024. See attached document for full details. (jas)
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Tuesday, June 25, 2024
20 20 misc Scheduling Report - Rule 26(f)/16.1 Tue 06/25 6:17 PM
Joint SCHEDULING REPORT - Rule 16.1 by Citibank, N.A., Citigroup Inc. (Pedrosa, Eliot)
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Tuesday, June 11, 2024
19 19 misc Certificate of Other Affiliates/Corporate Disclosure Statement Tue 06/11 4:02 PM
Corporate Disclosure Statement by Werner Jack Becker, Dana Guida identifying Other Affiliate Consovoy McCarthy PLLC, Other Affiliate Don Bivens, PLLC, Other Affiliate Lawfair LLC for Dana Guida, Werner Jack Becker (Shapiro, Daniel)
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Wednesday, June 05, 2024
18 18 4 pgs order Order Requiring Joint Scheduling Report Wed 06/05 4:13 PM
ORDER REQUIRING SCHEDULING REPORT. Signed by Judge Raag Singhal on 6/5/2024. See attached document for full details. (caw)
Related: [-]
17 17 order Order on Motion to Appear Pro Hac Vice Wed 06/05 10:42 AM
PAPERLESS ORDER granting10 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Alexander V. Maugeri. Alexander V. Maugeri may appear and participate in this action on behalf of Defendants Citigroup Inc. and Citibank, N.A. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
Related: [-]
16 16 order Order on Motion to Appear Pro Hac Vice Wed 06/05 10:41 AM
PAPERLESS ORDER granting8 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Brandon M. Haase. Brandon M. Haase, may appear and participate in this actionon behalf of Plaintiffs Werner Becker and Dana Guida. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
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15 15 order Order on Motion to Appear Pro Hac Vice Wed 06/05 10:40 AM
PAPERLESS ORDER granting7 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Bryan K. Weir. Bryan K. Weir, may appear and participate in this action on behalf of Plaintiffs Werner Becker and Dana Guida. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
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14 14 order - Order (PAPERLESS or pdf attached) Wed 06/05 10:28 AM
PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONS Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
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13 13 order Notice of Court Practice/to Appear/Other Wed 06/05 10:28 AM
NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions (and responses to motions) with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions (and responses). Motions for Extension of Time Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC , 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Labeling Exhibits on CM/ECF Exhibits to pleadings and motions shall be docketed in accordance with the Court's CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley ) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Notices of Settlement Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
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12 12 order Order on Motion for Extension of Time to File Response/Reply/Answer Wed 06/05 10:24 AM
PAPERLESS ORDER granting9 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document. Defendants shall have up to and including 7/10/2024 to respond to Plaintiffs' Complaint. Should Defendants file a Federal Rule of Civil Procedure 12 motion in response, Plaintiffs shall have thirty (30) days to respond to such motion, and Defendants shall have twenty-eight (28) days to file a reply. Signed by Judge Raag Singhal on 6/5/2024. (jgr)
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Monday, June 03, 2024
11 11 misc Certificate of Other Affiliates/Corporate Disclosure Statement Mon 06/03 3:31 PM
Corporate Disclosure Statement by Citibank, N.A., Citigroup Inc. identifying Other Affiliate Citibank, N.A. for Citigroup Inc. (Pedrosa, Eliot)
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10 10 motion Appear Pro Hac Vice - aty Mon 06/03 3:26 PM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Alexander V. Maugeri. Filing Fee $ 200.00 Receipt # AFLSDC-17577033 by Citibank, N.A., Citigroup Inc.. Responses due by 6/17/2024.(Pedrosa, Eliot)
Related: [-]
Att: 1 Certification of Alexander V. Maugeri,
Att: 2 Text of Proposed Order Granting Motion to Appear PHV of Alexander V. Maugeri
9 9 motion Extension of Time to File Response/Reply/Answer Mon 06/03 3:21 PM
Agreed MOTION for Extension of Time to File Response/Reply/Answer as to1 Complaint And to Set Briefing Schedule by Citibank, N.A., Citigroup Inc.. Attorney Eliot Pedrosa added to party Citibank, N.A.(pty:dft), Attorney Eliot Pedrosa added to party Citigroup Inc.(pty:dft).(Pedrosa, Eliot)
Related: [-]
Att: 1 Text of Proposed Order Granting Agreed Motion for Extension of Time
Tuesday, May 21, 2024
8 8 motion Appear Pro Hac Vice - aty Tue 05/21 11:06 AM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Brandon Haase. Filing Fee $ 200.00 Receipt # AFLSDC-17545425 by Werner Jack Becker, Dana Guida. Responses due by 6/4/2024. (Shapiro, Daniel)
Related: [-]
7 7 motion Appear Pro Hac Vice - aty Tue 05/21 11:03 AM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Bryan Weir. Filing Fee $ 200.00 Receipt # AFLSDC-17545403 by Werner Jack Becker, Dana Guida. Responses due by 6/4/2024. (Shapiro, Daniel)
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6 6 service Summons (Affidavit) Returned Executed Tue 05/21 10:56 AM
SUMMONS (Affidavit) Returned Executed on1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Werner Jack Becker, Dana Guida. Citigroup Inc., d/b/a Citibank served on 5/20/2024, response/answer due 6/10/2024. (Shapiro, Daniel)
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5 5 service Summons (Affidavit) Returned Executed Tue 05/21 10:53 AM
SUMMONS (Affidavit) Returned Executed on1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Werner Jack Becker, Dana Guida. Citibank, N.A. served on 5/20/2024, response/answer due 6/10/2024. (Shapiro, Daniel)
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Friday, May 17, 2024
4 4 misc Bar Letter Fri 05/17 3:55 PM
Bar Letter re: Admissions sent to attorney Bryan Weir and Brandon M. Haase, mailing date May 17, 2024, (pt)
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3 3 service Summons Issued Fri 05/17 2:07 PM
Summons Issued as to Citibank, N.A., and Citigroup Inc., d/b/a Citibank. (caw)
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2 2 order Clerk's Notice of Judge Assignment and Optional Consent Fri 05/17 2:02 PM
Clerk's Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website. (caw)
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1 1 cmp Complaint Fri 05/17 11:25 AM
COMPLAINT against Citibank, N.A., Citigroup Inc., d/b/a Citibank. Filing fees $ 405.00 receipt number AFLSDC-17537880, filed by Werner Jack Becker, Dana Guida.(Shapiro, Daniel)
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Att: 1 Civil Cover Sheet,
Att: 2 Summon(s)