Mary v. Professional Parking Management Corporation

Florida Southern District Court
Judge:Raag Singhal
Referred: Jared M Strauss
Case #: 0:24-cv-61213
Nature of Suit890 Other Statutes - Other Statutory Actions
Cause28:1446 Notice of Removal
Case Filed:Jul 10, 2024
Last checked: Saturday Aug 24, 2024 8:24 AM EDT
Defendant
Professional Parking Management Corporation
Registered Agent 1314 East Las Olas Blvd. Suite 405
Ft. Lauderdale, FL 33301
Represented By
Hayley Harrison Ryan
Cozen O'Connor
contact info
Jason Ryan Domark
Cozen O'Connor
contact info
Plaintiff
Richard Jean Mary
Individually and on behalf of all similarly situated 10881 NW 29th Court
Sunrise, FL 33322
Represented By
Manuel Santiago Hiraldo
Hiraldo P.A.
contact info
Rachel N. Dapeer
Dapeer Law, P.A.
contact info


Docket last updated: 12 hours ago
Friday, December 27, 2024
44 44 motion Withdraw as Attorney Fri 12/27 4:56 PM
MOTION to Withdraw as Attorney by Jennifer Thelusma for / by Richard Jean Mary. Responses due by 1/10/2025. (Dapeer, Rachel)
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Friday, December 06, 2024
43 43 order Order on Motion for Extension of Time Fri 12/06 1:56 AM
PAPERLESS ORDER granting42 Unopposed Motion for Extension of Time to Respond to Second Amended Complaint. Responses due by 1/3/2025. Signed by Judge Raag Singhal on 12/6/2024. (nni)
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Thursday, December 05, 2024
42 42 motion Extension of Time Thu 12/05 4:56 PM
Unopposed MOTION for Extension of Time to Respond to Second Amended Complaint re41 Amended Complaint/Amended Notice of Removal by Professional Parking Management Corporation. Responses due by 12/19/2024.(Ryan, Hayley)
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Att: 1 Text of Proposed Order
Tuesday, December 03, 2024
41 41 cmp Amended Complaint/Amended Notice of Removal Tue 12/03 11:26 AM
Second AMENDED COMPLAINT against Professional Parking Management Corporation filed in response to Order Granting Motion for Leave, filed by Richard Jean Mary.(Hiraldo, Manuel)
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40 40 2 pgs order Order on Motion to Amend/Correct Order on Motion to Dismiss for Failure to State a Claim Order on Motion for Leave to File Tue 12/03 11:10 AM
ORDER granting39 Motion to Amend/Correct. Clerks Notice: Filer must separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge ; denying as moot18 Motion to Dismiss for Failure to State a Claim( Amended Complaint due by 12/10/2024.); denying as moot31 Motion to Dismiss for Failure to State a Claim( Amended Complaint due by 12/10/2024.); granting34 Motion for Leave to File. Clerks Notice: Filer must separately re-file the amended pleading pursuant to Local Rule 15.1, unless otherwise ordered by the Judge . Signed by Judge Raag Singhal on 12/3/2024. See attached document for full details. (drz)
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Monday, October 21, 2024
39 39 motion Amend/Correct Mon 10/21 10:09 AM
MOTION to Amend/Correct21 Amended Complaint/Amended Notice of Removal by Richard Jean Mary. Responses due by 11/4/2024.(Hiraldo, Manuel)
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Att: 1 Text of Proposed Order,
Att: 2 Exhibit A - Proposed Corrected First Amended Class Action Complaint
Friday, October 18, 2024
38 38 respm Reply to Response to Motion Fri 10/18 4:07 PM
Defendant's REPLY to Response to Motion re31 MOTION TO DISMISS21 Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM filed by Professional Parking Management Corporation. (Ryan, Hayley)
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Wednesday, October 16, 2024
37 37 2 pgs order Order on Motion to Stay Thu 10/17 8:47 AM
ORDER granting19 Motion to Stay Discovery Pending Disposition of its Dispositive Motion to Dismiss. Signed by Judge Raag Singhal on 10/16/2024. See attached document for full details. (drz)
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Friday, October 11, 2024
36 36 respm Response in Opposition to Motion Fri 10/11 5:07 PM
RESPONSE in Opposition re31 MOTION TO DISMISS21 Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM filed by Richard Jean Mary. Replies due by 10/18/2024. (Hiraldo, Manuel)
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Wednesday, October 09, 2024
35 35 notice Notice (Other) Wed 10/09 12:02 PM
NOTICE of Filing Defendants Responses to Plaintiff's Discovery by Richard Jean Mary re33 Notice (Other) (Dapeer, Rachel)
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Tuesday, October 08, 2024
34 34 motion Leave to File Document Tue 10/08 8:52 AM
MOTION for Leave to File Second Amended Complaint by Richard Jean Mary.(Hiraldo, Manuel)
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Att: 1 Exhibit A - Proposed Second Amended Complaint (redline),
Att: 2 Text of Proposed Order
Monday, October 07, 2024
33 33 notice Notice (Other) Mon 10/07 5:26 PM
NOTICE of Discovery Dispute by Richard Jean Mary (Dapeer, Rachel)
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32 32 notice Notice of Attorney Appearance Mon 10/07 4:17 PM
NOTICE of Attorney Appearance by Jennifer Thelusma on behalf of Richard Jean Mary. Attorney Jennifer Thelusma added to party Richard Jean Mary(pty:pla). (Thelusma, Jennifer)
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Monday, September 30, 2024
31 31 motion Dismiss for Failure to State a Claim Mon 09/30 3:58 PM
MOTION TO DISMISS21 Amended Complaint/Amended Notice of Removal FOR FAILURE TO STATE A CLAIM by Professional Parking Management Corporation. Responses due by 10/15/2024.(Domark, Jason)
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Att: 1 Exhibit A
Thursday, September 26, 2024
30 30 misc Response to Order to Show Cause Thu 09/26 9:53 AM
RESPONSE TO ORDER TO SHOW CAUSE re28 Order to Show Cause by Professional Parking Management Corporation. (Ryan, Hayley)
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Tuesday, September 17, 2024
29 29 respm Reply to Response to Motion Tue 09/17 4:02 PM
REPLY to Response to Motion re19 Defendant's MOTION to Stay Discovery Pending Disposition of its Dispositive Motion to Dismiss filed by Professional Parking Management Corporation.(Ryan, Hayley)
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Att: 1 Exhibit Exhibit A
Monday, September 16, 2024
28 28 2 pgs order Order to Show Cause Mon 09/16 4:09 PM
ORDER TO SHOW CAUSE. Show Cause Response due by 9/26/2024. Signed by Judge Raag Singhal on 9/12/2024. See attached document for full details. (kpe)
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27 27 2 pgs order Order on Motion to Appear Pro Hac Vice Mon 09/16 4:07 PM
ORDER granting26 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Melissa Siebert, Esq. Signed by Judge Raag Singhal on 9/12/2024. See attached document for full details. (kpe)
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Wednesday, September 11, 2024
26 26 motion Appear Pro Hac Vice - aty Wed 09/11 12:28 PM
MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Melissa Siebert. Filing Fee $ 200.00 Receipt # AFLSDC-17826192 by Professional Parking Management Corporation. Responses due by 9/25/2024.(Ryan, Hayley)
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Att: 1 Text of Proposed Order Proposed Order
Tuesday, September 10, 2024
25 25 respm Response in Opposition to Motion Tue 09/10 11:40 AM
RESPONSE in Opposition re19 Defendant's MOTION to Stay Discovery Pending Disposition of its Dispositive Motion to Dismiss filed by Richard Jean Mary. Replies due by 9/17/2024. (Hiraldo, Manuel)
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Saturday, September 07, 2024
24 24 order Order on Motion for Extension of Time Sat 09/07 12:25 AM
PAPERLESS ORDER granting Defendant's Unopposed Motion (DE23 ) for Extension of Time to Respond to the Amended Complaint (DE21 ). Defendant PPM shall have up to and including September 30, 2024 to answer or otherwise respond to Plaintiff's First Amended Class Action Complaint. Signed by Judge Raag Singhal on 9/6/2024. (nni)
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Thursday, September 05, 2024
23 23 motion Extension of Time Thu 09/05 2:14 PM
Unopposed MOTION for Extension of Time to Respond to the Amended Complaint re21 Amended Complaint/Amended Notice of Removal by Professional Parking Management Corporation. Responses due by 9/19/2024.(Ryan, Hayley)
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Att: 1 Text of Proposed Order Proposed Order
Wednesday, September 04, 2024
22 22 1 pgs order Order Scheduling Mediation Wed 09/04 4:10 PM
ORDER Scheduling Mediation before Howard Tescher, Esq. Mediation Hearing set for 1/30/2025 09:30 AM. Signed by Judge Raag Singhal on 9/4/2024. See attached document for full details. (drz)
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21 21 cmp Amended Complaint/Amended Notice of Removal Wed 09/04 12:19 PM
First AMENDED COMPLAINT against Professional Parking Management Corporation, filed by Richard Jean Mary.(Hiraldo, Manuel)
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Tuesday, September 03, 2024
20 20 adr Notice of Mediator Selection and/or Hearing Tue 09/03 12:26 PM
Joint NOTICE of Mediator Selection and Hearing. Selected/Added Howard Tescher as Mediator. Mediation Hearing set for 1/30/2025 at 9:30 a.m..(Hiraldo, Manuel)
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Att: 1 Text of Proposed Order
Wednesday, August 28, 2024
19 19 motion Stay Wed 08/28 5:54 PM
Defendant's MOTION to Stay Discovery Pending Disposition of its Dispositive Motion to Dismiss by Professional Parking Management Corporation. Responses due by 9/11/2024.(Ryan, Hayley)
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Att: 1 Exhibit Exhibit A
Monday, August 26, 2024
18 18 motion Dismiss for Failure to State a Claim Mon 08/26 6:27 PM
MOTION TO DISMISS1 Notice of Removal (State Court Complaint), FOR FAILURE TO STATE A CLAIM by Professional Parking Management Corporation. Responses due by 9/9/2024.(Domark, Jason)
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Att: 1 Exhibit A-Non-Payment Notice
Tuesday, August 13, 2024
17 17 order Order on Motion for Extension of Time Tue 08/13 11:20 AM
PAPERLESS ORDER granting16 Motion for Extension of Time to Respond to Complaint and to Serve Initial Disclosures. Plaintiff's opposition to the latter is noted and overruled. Responses due by 8/26/2024. Initial Disclosures due by 9/27/2024. Signed by Judge Raag Singhal on 8/13/2024. (nni)
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Friday, August 09, 2024
16 16 motion Extension of Time Fri 08/09 4:12 PM
MOTION for Extension of Time to Respond to Complaint and serve initial disclosuresd by Professional Parking Management Corporation. Responses due by 8/23/2024.(Domark, Jason)
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Att: 1 Text of Proposed Order
Friday, August 02, 2024
15 15 order - Order (PAPERLESS or pdf attached) Fri 08/02 9:45 AM
DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jared M. Strauss on 8/2/2024. See attached document for full details. (cer)
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Thursday, August 01, 2024
14 14 order Scheduling Order Order Referring Case to Mediation Order Referring Case to Magistrate Judge Fri 08/02 8:58 AM
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 9/16/2024., Discovery due by 5/7/2025., Expert Discovery due by 5/7/2025., Joinder of Parties due by 9/16/2024., Mediation Deadline 5/14/2025., In Limine Motions due by 6/25/2025., Dispositive Motions due by 5/21/2025., Motions due by 5/21/2025., Pretrial Stipulation due by 8/8/2025.). Signed by Judge Raag Singhal on 8/1/2024. See attached document for full details. (drz)
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Monday, July 29, 2024
13 13 misc Scheduling Report - Rule 26(f)/16.1 Mon 07/29 9:51 AM
Joint SCHEDULING REPORT - Rule 26(f) by Richard Jean Mary(Hiraldo, Manuel)
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Att: 1 Text of Proposed Order
Wednesday, July 17, 2024
12 12 misc Certificate of Other Affiliates/Corporate Disclosure Statement Wed 07/17 9:57 AM
Certificate of Other Affiliates/Corporate Disclosure Statement by Professional Parking Management Corporation identifying Corporate Parent PAVE Mobility Holdings, Inc. for Professional Parking Management Corporation (Ryan, Hayley)
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Monday, July 15, 2024
11 11 order Order on Motion for Extension of Time to File Response/Reply/Answer Mon 07/15 10:35 AM
PAPERLESS ORDER granting10 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document by Professional Parking Management Corporation. Response/Answer due 8/16/2024. Signed by Judge Raag Singhal on 7/15/2024. (pb00)
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Friday, July 12, 2024
10 10 motion Extension of Time to File Response/Reply/Answer Fri 07/12 5:14 PM
Unopposed MOTION for Extension of Time to File Response/Reply/Answer to Complaint by Professional Parking Management Corporation. (Ryan, Hayley)
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9 9 4 pgs order Order Requiring Joint Scheduling Report Fri 07/12 11:40 AM
Order Requiring Scheduling Report. Signed by Judge Raag Singhal on 7/12/2024. See attached document for full details. (kpe)
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8 8 misc Certificate of Other Affiliates/Corporate Disclosure Statement Fri 07/12 10:17 AM
Certificate of Other Affiliates/Corporate Disclosure Statement by Richard Jean Mary (Hiraldo, Manuel)
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7 7 order - Order (PAPERLESS or pdf attached) Fri 07/12 10:06 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 7/12/2024. (jgr)
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6 6 order Notice of Court Practice/to Appear/Other Fri 07/12 10:06 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 7/12/2024. (jgr)
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Thursday, July 11, 2024
5 5 notice Notice of Attorney Appearance Thu 07/11 10:15 AM
NOTICE of Attorney Appearance by Hayley Harrison Ryan on behalf of Professional Parking Management Corporation (Ryan, Hayley)
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4 4 notice Notice (Other) Thu 07/11 9:58 AM
NOTICE of Filing Civil Cover Sheet by Professional Parking Management Corporation re 3 Clerk's Notice to Filer re: Electronic Case (Domark, Jason)
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Att: 1 Civil Cover Sheet
3 3 order Clerk's Notice of Docket Correction - ELECTRONIC CASE Thu 07/11 8:38 AM
Clerk's Notice to Filer re: Electronic Case. No Civil Cover Sheet. Filer is instructed to file a Notice (Other) with the Civil Cover Sheet attached within 24 hours of the notice. (ar24)
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Wednesday, July 10, 2024
2 2 order Clerk's Notice of Judge Assignment and Optional Consent Thu 07/11 8:31 AM
Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (ar24)
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1 1 cmp Notice of Removal (State Court Complaint) Wed 07/10 5:30 PM
NOTICE OF REMOVAL (STATE COURT COMPLAINT - Class Action Complaint) Filing fee $ 405.00 receipt number BFLSDC-17668217, filed by Professional Parking Management Corporation.(Domark, Jason)
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Att: 1 20 pgs Exhibit A