Florida Middle District Court
Judge:Timothy J Corrigan
Referred: Samuel J Horovitz
Case #: 3:24-cv-01082
Nature of Suit442 Civil Rights - Employment
Cause28:1332 Diversity-Notice of Removal
Case Filed:Oct 18, 2024
Last checked: Wednesday Apr 16, 2025 4:30 AM EDT
Defendant
Adlib Software
Represented By
Alex Brandon Claude Ershock
Lewis Brisbois Bisgaard & Smith LLP
contact info
Jonathan A. Beckerman
Lewis Brisbois Bisgaard & Smith LLP
contact info
Defendant
Diversis Capital Management, LP
Represented By
Alex Brandon Claude Ershock
Lewis Brisbois Bisgaard & Smith LLP
contact info
Jonathan A. Beckerman
Lewis Brisbois Bisgaard & Smith LLP
contact info
Defendant
Remote Technology Services, Inc.
Represented By
Miguel Morel
Littler Mendelson
contact info
Mediator
Robyn S. Hankins
4600 Military Trail, Ste. 217
Jupiter, FL 33458
Represented By
Robyn S. Hankins
Robyn S. Hankins, Pl
contact info
Plaintiff
Don Dama
Represented By
Steven Greg Wenzel
Wenzel Fenton Cabassa, PA
contact info
Hannah E. Horr
Wenzel Fenton Cabassa, P.A.
contact info
Luis A. Cabassa
Wenzel Fenton Cabassa, PA
contact info


Docket last updated: 04/22/2025 11:59 PM EDT
Friday, February 21, 2025
29 29 2 pgs order Order Appointing Mediator/Scheduling Mediation Fri 02/21 12:02 PM
ORDER appointing Robyn Hankins, Esq. as mediator in this action. Conduct mediation hearing by 11/1/2025. Lead counsel to coordinate dates. Signed by Senior Judge Timothy J. Corrigan on 2/21/2025.(TPL)
Related: [-]
Att: 1 Docket Sheet,
Att: 2 Mediation Report
Tuesday, February 11, 2025
28 28 adr Notice of selection of mediator Tue 02/11 11:36 AM
NOTICE OF SELECTION of Robyn S. Hankins as mediator by Don Dama.(Cabassa, Luis)
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Friday, December 20, 2024
27 27 answer Answer to amended complaint Fri 12/20 7:35 PM
ANSWER and affirmative defenses to 16 Amended Complaint, by Remote Technology Services, Inc..(Morel, Miguel)
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26 26 answer Answer to amended complaint Fri 12/20 4:21 PM
ANSWER and affirmative defenses with Jury Demand to 16 Amended Complaint, by Adlib Software, Diversis Capital Management, LP.(Ershock, Alex)
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Monday, December 09, 2024
25 25 misc Disclosure Statement - LR 3.03 and FRCP 7.1 Mon 12/09 7:10 AM
DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Remote Technology Services, Inc. identifying Corporate Parent Remote Technology, Inc. for Remote Technology Services, Inc... (Morel, Miguel)
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Friday, December 06, 2024
24 24 misc Disclosure Statement - LR 3.03 and FRCP 7.1 Fri 12/06 5:31 PM
DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Remote Technology Services, Inc.. (Morel, Miguel)
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Thursday, December 05, 2024
23 23 misc Certificate of Interested Persons and Corporate Disclosure Statement Thu 12/05 10:13 AM
CERTIFICATE of interested persons and corporate disclosure statement re18 Order by Don Dama. (Cabassa, Luis)
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22 22 notice Notice of a Related Action Thu 12/05 10:10 AM
NOTICE of a related action per Local Rule 1.07(c) by Don Dama. Related case(s): Yes (Cabassa, Luis)
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21 21 order Case Management Scheduling Order Thu 12/05 9:49 AM
CASE MANAGEMENT AND SCHEDULING ORDER: Selection of mediator due by 2/7/2025; Amended Pleadings due by 2/7/2025; Joinder of Parties due by 2/7/2025; Plaintiff disclosure of expert report due by 7/3/2025; Defendant disclosure of expert report due by 7/17/2025; Discovery due by 9/2/2025; Dispositive motions due by 10/1/2025; Pretrial statement due by 2/12/2026; All other motions due by 2/12/2026; Final Pretrial Conference set for 2/19/2026 at 11:00 AM in Jacksonville Courtroom 10 D before Senior Judge Timothy J. Corrigan; Jury Trial set for trial term commencing 3/2/2026 at 9:00 AM in Jacksonville Courtroom 10 D before Senior Judge Timothy J. Corrigan. Signed by Deputy Clerk on 12/5/2024. (TPL)
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Tuesday, December 03, 2024
20 20 misc Disclosure Statement - LR 3.03 and FRCP 7.1 Tue 12/03 1:36 PM
DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Adlib Software, Diversis Capital Management, LP identifying Other Affiliate Adlib Publishing System Inc. for Adlib Software; Corporate Parent Diversis Capital Management GP, LLC for Diversis Capital Management, LP.. (Ershock, Alex)
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Wednesday, November 27, 2024
19 19 misc Case Management Report Wed 11/27 8:59 PM
CASE MANAGEMENT REPORT. (Ershock, Alex)
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Monday, November 25, 2024
18 18 2 pgs order Order Mon 11/25 1:16 PM
ORDER: Upon review of the record, the parties have failed to file their respective disclosure statements pursuant to Local Rule 3.03. Accordingly, the parties shall file their respective disclosure statements, using the standard form available on the Court's website, www.flmd.uscourts.gov, by December 6, 2024. See Order for further details. Signed by Magistrate Judge Samuel J. Horovitz on 11/25/2024. (JLW)
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17 17 order Order on Motion for Extension of Time to Answer Mon 11/25 11:41 AM
ENDORSED ORDER denying as moot 14 Defendants' Motion for Extension of Time to Respond to Plaintiff's Complaint ("Motion") based on the filing of 16 Plaintiff's Amended Complaint. However, given the unopposed relief requested in the Motion, pursuant to Federal Rule of Civil Procedure 15, Defendants shall have up to and including December 20, 2024 to respond to 16 Plaintiff's Amended Complaint. Signed by Magistrate Judge Samuel J. Horovitz on 11/25/2024. (JLW)
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Saturday, November 23, 2024
16 16 cmp Amended Complaint Sat 11/23 11:02 AM
AMENDED COMPLAINT and DEMAND FOR JURY TRIAL against Adlib Software, Diversis Capital Management, LP, Remote Technology Services, Inc. with Jury Demand. filed by Don Dama. Related document: 7 Complaint filed by Don Dama.(Cabassa, Luis)
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Att: 1 Exhibit A - Employment Agreement
15 15 notice Notice of appearance Sat 11/23 10:54 AM
NOTICE of Appearance by Steven Greg Wenzel on behalf of Don Dama (Wenzel, Steven)
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Friday, November 22, 2024
14 14 motion Extension of Time to File Answer / Respond to Complaint Fri 11/22 11:59 PM
MOTION for Extension of Time to File Answer re1 Notice of Removal by Remote Technology Services, Inc.. (Morel, Miguel)
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Monday, November 04, 2024
13 13 order Order on Motion for Extension of Time to File Mon 11/04 12:45 PM
ENDORSED ORDER granting 12 Stipulation Regarding Defendants' Responses to Complaint. Each Defendant shall file its response to the 7 Complaint on or before November 22, 2024. The Court cautions the parties that all future requests for relief must be made by motion in compliance with the Federal Rules of Civil Procedure and this Court's Local Rules. See Fed. R. Civ. P. 7(b)(1); Local Rule 3.01. Signed by Magistrate Judge Samuel J. Horovitz on 11/4/2024. (JLW)
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Friday, November 01, 2024
12 12 misc Stipulation Fri 11/01 3:23 PM
STIPULATION re7 Complaint regarding extension of time to respond for all Defendants (joint) by Adlib Software, Diversis Capital Management, LP. (Ershock, Alex)
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11 11 notice Notice (Other) Fri 11/01 12:54 PM
NOTICE by Don Dama re7 Complaint of Filing(Cabassa, Luis)
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Att: 1 Exhibit Ex. A - Employment Agreement
Friday, October 25, 2024
10 10 service Waiver of service executed Fri 10/25 2:56 PM
WAIVER of service returned executed on October 21, 2024 by Don Dama as to Remote Technology Services, Inc.. (Cabassa, Luis)
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Wednesday, October 23, 2024
9 9 notice Notice of Lead Counsel Designation Wed 10/23 12:15 PM
NOTICE of Lead Counsel Designation by Jonathan A. Beckerman on behalf of Adlib Software, Diversis Capital Management, LP. Lead Counsel: Jonathan A. Beckerman. (Beckerman, Jonathan)
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8 8 notice Notice to Counsel of Local Rule Wed 10/23 10:25 AM
NOTICE TO COUNSEL Jonathan A. Beckerman, Alex Brandon Claude Ershock of Local Rule 2.02(a), which states, "The first paper filed on behalf of a party must designate only one lead counsel who - unless the party changes the designation - remains lead counsel throughout the action." Counsel must file a Notice of Lead Counsel Designation identifying lead counsel. (Signed by Deputy Clerk). (MLB)
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Tuesday, October 22, 2024
7 7 cmp Complaint Tue 10/22 3:21 PM
COMPLAINT against All Defendants with Jury Demand filed by Don Dama. Filed in State Court on 09/09/2024.(EVK)
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6 6 notice Notice to Counsel of Local Rule Tue 10/22 10:06 AM
NOTICE of Local Rule 3.02(a)(2), which requires the parties in every civil proceeding, except those described in subsection (d), to file a case management report (CMR) using the uniform form at www.flmd.uscourts.gov. The CMR must be filed (1) within forty days after any defendant appears in an action originating in this court, (2) within forty days after the docketing of an action removed or transferred to this court, or (3) within seventy days after service on the United States attorney in an action against the United States, its agencies or employees. Judges may have a special CMR form for certain types of cases. These forms can be found at www.flmd.uscourts.gov under the Forms tab for each judge. (Signed by Deputy Clerk). (TPL)
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Monday, October 21, 2024
5 5 notice Notice (Other) Mon 10/21 3:31 PM
NOTICE by Don Dama of Filing(Cabassa, Luis)
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Att: 1 Waiver of Service of Summons (Adlib Software),
Att: 2 Waiver of Service of Summons (Diversis Capital Management)
4 4 notice Notice of Lead Counsel Designation Mon 10/21 3:28 PM
NOTICE of Lead Counsel Designation by Luis A. Cabassa on behalf of Don Dama. Lead Counsel: Luis A. Cabassa. (Cabassa, Luis)
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3 3 utility Case Assigned/Reassigned Mon 10/21 3:12 PM
NEW CASE ASSIGNED to Judge Timothy J. Corrigan and Magistrate Judge Samuel J. Horovitz. New case number: 3:24-cv-1082-TJC-SJH. (RLK)
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2 2 notice Notice of appearance Mon 10/21 1:17 PM
NOTICE of Appearance by Miguel Morel on behalf of Remote Technology Services, Inc. (Morel, Miguel)
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Friday, October 18, 2024
1 1 notice Notice of Removal Fri 10/18 8:30 PM
COMPLAINT and NOTICE OF REMOVAL from Circuit Court in and for Nassau County, Florida, case number 2024-CA-000279 filed in State Court on 09/09/2024. Filing fee $405, receipt number AFLMDC-22629171 filed by Diversis Capital Management, LP, Adlib Software.(Ershock, Alex)
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Att: 1 State Court COMPLAINT,
Att: 2 State Court Docket Sheet,
Att: 3 State Court Other Documents,
Att: 4 Civil Cover Sheet