Flynn v. Berkley Vacations Resorts, Inc.
| Florida Southern District Court | |
| Judge: | Raag Singhal |
| Case #: | 0:25-cv-60028 |
| Nature of Suit | 190 Contract - Other Contract |
| Cause | 28:1441 Notice of Removal |
| Case Filed: | Jan 06, 2025 |
| Last checked: Monday Jan 06, 2025 5:07 PM EST |
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Defendant
Berkley Vacations Resorts, Inc.
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Represented By
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Plaintiff
Jody Flynn
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| Docket last updated: 01/16/2025 11:59 PM EST |
| Monday, January 13, 2025 | ||
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notice
Notice (Other)
Mon 01/13 6:09 PM
NOTICE Request For Judicial Notice by Berkley Vacations Resorts, Inc. (Epstein, Richard) |
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Att: 1
Exhibit Exhibit 1 Trinidad Complaint,
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Att: 2
Exhibit Exhibit 2 Rishoi Complaint,
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Att: 3
Exhibit Exhibit 3 Cole Complaint,
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Att: 4
Exhibit Exhibit 4 Slater Romines Amended Complaint,
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Att: 5
Exhibit Exhibit 5 Ola Complaint,
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Att: 6
Exhibit Exhibit 6 Whatley Complaint,
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Att: 7
Exhibit Exhibit 7 Spencer Complaint,
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Att: 8
Exhibit Exhibit 8 Long Complaint,
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Att: 9
Exhibit Exhibit 9 Harklerode Complaint,
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Att: 10
Exhibit Exhibit 10 Cohen Complaint,
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Att: 11
Exhibit Exhibit 11 Ronda Complaint,
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Att: 12
Exhibit Exhibit 12 Seidler Complaint,
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Att: 13
Exhibit Exhibit 13 Eugster Complaint,
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Att: 14
Exhibit Exhibit 14 Shull Complaint,
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Att: 15
Exhibit Exhibit 15 Nelson Complaint,
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Att: 16
Exhibit Exhibit 16 Vest Complaint,
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Att: 17
Exhibit Exhibit 17 White Complaint,
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Att: 18
Exhibit Exhibit 18 Gurwah Complaint,
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Att: 19
Exhibit Exhibit 19 Douglas Complaint,
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Att: 20
Exhibit Exhibit 20 Dietl Complaint,
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Att: 21
Exhibit Exhibit 21 Johnson complaint,
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Att: 22
Exhibit Exhibit 22 Lapilio-Schulz Complaint,
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Att: 23
Exhibit Exhibit 23 Wahl Complaint,
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Att: 24
Exhibit Exhibit 24 Smith Complaint
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cmp
Counterclaim
Mon 01/13 4:26 PM
COUNTERCLAIM against Jody Flynn, filed by Berkley Vacations Resorts, Inc..(Epstein, Richard) |
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Att: 1
Exhibit Exhibit 1 Purchase Contract,
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Att: 2
Exhibit Exhibit 2 Promissory Note
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motion
Dismiss for Failure to State a Claim
Mon 01/13 3:50 PM
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Berkley Vacations Resorts, Inc.. Responses due by 1/27/2025.(Epstein, Richard) |
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Att: 1
Exhibit Exhibit 1 Purchase Agreement,
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Att: 2
Exhibit Exhibit 2 Purchaser's Acknowledgement,
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Att: 3
Exhibit Exhibit 3 Pre-closing Acknowledgement,
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Att: 4
Exhibit Exhibit 4 Receipt for Timeshare Documents,
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Att: 5
Exhibit Exhibit 5 Closing Disclosure,
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Att: 6
Exhibit Exhibit 6 Recorded Warranty Deed
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| Wednesday, January 08, 2025 | ||
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misc
Certificate of Other Affiliates/Corporate Disclosure Statement
Wed 01/08 3:01 PM
Corporate Disclosure Statement by Berkley Vacations Resorts, Inc. identifying Corporate Parent The Berkley Group, Inc., Corporate Parent Vacatia, Inc. for Berkley Vacations Resorts, Inc. (Backman, Jeffrey) |
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order
- Order (PAPERLESS or pdf attached)
Wed 01/08 10:55 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 1/8/2025. (lp00) |
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order
- Order (PAPERLESS or pdf attached)
Wed 01/08 10:54 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 1/8/2025. (lp00) |
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| Tuesday, January 07, 2025 | ||
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misc
Bar Letter
Tue 01/07 1:54 PM
Bar Letter re: Admissions sent to attorney Marilyn J. Hochman, mailing date January 7, 2025, (pt) |
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| Monday, January 06, 2025 | ||
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order
Clerk's Notice of Judge Assignment and Optional Consent
Tue 01/07 10:34 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. (kpe) |
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cmp
Notice of Removal (State Court Complaint)
Mon 01/06 4:25 PM
NOTICE OF REMOVAL (STATE COURT COMPLAINT - Complaint) Filing fee $405.00. Pay.gov Agency Tracking ID FLSDC-18094612, payment transferred from : 25CV60027 Jody Flynn v. Berkley Vacations Resorts, Inc., filed by Berkley Vacations Resorts, Inc..(Backman, Jeffrey) |
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Att: 1
Exhibit State Court Complaint,
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Att: 2
Affidavit Declaration of Lili Kent,
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Att: 3
Exhibit Other State Court Documents,
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Att: 4
Affidavit Declaration of Phillip Silvestri,
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Att: 5
Affidavit Declaration of Jeffrey Backman,
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Att: 6
Civil Cover Sheet Civil Cover Sheet,
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Att: 7
Certification Certificate of Interested Parties
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