Fortun Insurance, LLC v. Rouco et al
| Florida Southern District Court | |
| Judge: | Jacqueline Becerra |
| Case #: | 1:25-cv-20760 |
| Nature of Suit | 880 Civil Rights - Defend Trade Secrets Act of 2016 (DTSA) |
| Cause | 18:1836(b) Civil Action to Protect Trade Secrets |
| Case Filed: | Feb 18, 2025 |
| Last checked: Wednesday Feb 19, 2025 8:11 AM EST |
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Defendant
Lauren Falcon
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Defendant
Teresita Manso
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Defendant
Aymara Mencia-Barnes
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Defendant
Carolyn Parada
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Defendant
RRJ Insurance Services of Florida Corp.
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Defendant
Rolando Rouco
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Plaintiff
Fortun Insurance, LLC
a Florida limited liability company 365 Palermo Ave.
Coral Gables, FL 33134 |
Represented By
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| Docket last updated: 11 hours ago |
| Thursday, February 20, 2025 | ||
| 8 | 8
notice
Notice (Other)
Thu 02/20 6:17 PM
Plaintiff's NOTICE of Status of Service by Fortun Insurance, LLC re 7 Order,,,, Order Setting Hearing on Motion,,, (Carver, Christopher) |
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| Wednesday, February 19, 2025 | ||
| 7 | 7
order
- Order (PAPERLESS or pdf attached) Order Setting Hearing on Motion
Wed 02/19 3:47 PM
PAPERLESS ORDER. THIS CAUSE came before the Court on Plaintiff's Motion for a Temporary Restraining Order and Preliminary Injunction (the "Motion"), ECF No.5 . Upon due consideration of the Motion and the relevant portions of the record, it is hereby ORDERED AND ADJUDGED that: 1.Plaintiff shall serve a copy of this Order, in addition to the Complaint, on all Defendants, and notify the Court when service is completed; 2.Defendants shall file a response to the Motion within five (5) days of being served; 3.Plaintiff shall file a reply within two (2) days of the filing of Defendants' response; Further, a hearing on the Motion is SET for Friday, March 7, 2025, at 2:00 P.M. before the undersigned at the Wilkie D. Ferguson US Courthouse, 400 N. Miami Avenue, Courtroom 11-4, Miami, Florida 33128. Signed by Judge Jacqueline Becerra on 2/19/2025. (rs01) |
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| 6 | 6
order
- Order (PAPERLESS or pdf attached)
Wed 02/19 12:58 PM
PAPERLESS ORDER REGARDING PROCEDURES. The parties shall comply with the following procedures: 1. SERVICE : Federal Rule of Civil Procedure 4(m) requires service of summons and complaint to be perfected upon Defendants within 90 days after the filing of the complaint. Unless service is waived, proof of service must be made to the Court by filing the server's affidavit. If a Defendant waives service, notice of the same shall be filed immediately. Failure to file proof of service or show good cause within 90 days will result in a dismissal without prejudice and without further notice. 2. DEFAULTS : In the event a served Defendant does not appear in this action, the Plaintiff(s) shall file a Motion for Clerk's Default within seven days of the deadline for the Defendant to answer. Extensions of time to answer a pleading must take the form of a motion to the Court. Motions for Final Default Judgment, if applicable, shall be filed within seven days of the entry of a Clerk's Default. Any motions for default final judgment must comply with the Court's Standing Procedures Regarding Motions for Default Final Judgment found at: https://www.flsd.uscourts.gov/sites/flsd/files/JudgeBecerraStandingOrderMotionsforDefaultJudgment.pdf. 3. CERTIFICATE OF INTERESTED PARTIES : Within fifteen days from the date the last Defendant enters an appearance in this action, the parties, 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 must not include the undersigned or the assigned Magistrate Judge as interested parties 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. 4. JOINT SCHEDULING REPORTS : Within twenty days from the date the last Defendant enters an appearance in this action, the parties are directed to prepare and file a Joint Scheduling Report as required by Local Rule 16.1. Disclosures required under Fed. R. Civ. P. 26(a)(l) must be made at or before the time the parties confer to develop their case management and discovery plan. The parties must certify in the Joint Scheduling Report that such disclosures have been made unless a party files an objection to a required disclosure. Such filed objection must include a full explanation of the basis for the objection. The scheduling conference may be held via video conference or in person. It may not be held by telephone. In drafting their Joint Proposed Scheduling Order, the parties shall utilize the Court's Template Scheduling Order, found at https://www.flsd.uscourts.gov/sites/flsd/files/TemplateSchedulingOrder.pdf. Any deviation from the guidelines set forth in the Court's Template Scheduling Order or those proposed by the Local Rules must be noted in the Joint Scheduling Report along with an explanation for why any deviation is being proposed. Failure to articulate the reason(s) for any deviation from the guidelines set forth in the Court's Template Scheduling Order may result in the Court setting pre-trial deadlines and/or a trial date without regard to those proposed by the parties. 5. FILING OF MOTIONS : All filings must be in a 12-point font and double spaced. Single spacing is only permitted for footnotes. The required conferral under Local Rule 7.1 must be by telephone or in person. An e-mail conferral will only be permitted if counsel are in agreement as to the relief sought in the motion. 6. EXTENSIONS OF TIME : Requests for extensions of time, including unopposed motions, will only be granted by the Court upon an appropriate motion showing good cause why the deadline cannot be met. Absent an emergency, motions for extensions of time must be filed no later than three business days prior to the deadline from which relief is being sought. All requests for extensions of time must include: (1) the conferral statement required under Local Rule 7.1; (2) a list of any prior motions for extension of time; (3) a specific statement regarding the circumstances necessitating the requested relief; and (4) a statement as to whether the request impacts the deadline to file a dispositive motion or trial date. Signed by Judge Jacqueline Becerra on 2/19/2025. (rs01) |
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motion
Expedited Motion
Wed 02/19 7:44 AM
EXPEDITED MOTION Plaintiff Fortun for a Temporary Restraining Order and Preliminary Injunction by Fortun Insurance, LLC.(Carver, Christopher) |
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Att: 1
Exhibit 1 - Declaration of Michael Perelman,
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Att: 2
Exhibit 2 - Proposed order
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order
Clerk's Notice of Docket Correction - ELECTRONIC CASE
Wed 02/19 7:36 AM
Clerk's Notice to Filer re: Electronic Case. Venue on the Civil Cover Sheet does not match the initiating document. The Clerks Office confirmed Miami-Dade (Office - Miami) as the county with the filer. It is not necessary to re-file this document. (cwc) |
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service
Summons Issued
Wed 02/19 7:35 AM
Summons Issued as to Lauren Falcon, Teresita Manso, Aymara Mencia-Barnes, Carolyn Parada, RRJ Insurance Services of Florida Corp., Rolando Rouco. (cwc) |
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| Tuesday, February 18, 2025 | ||
| 2 | 2
order
Clerk's Notice of Judge Assignment and Optional Consent
Wed 02/19 7:30 AM
Clerks Notice of Judge Assignment to Judge Jacqueline Becerra. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Edwin G. Torres 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. (cwc) |
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| 1 | 1
97
pgs
COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18212824, filed by Fortun Insurance, LLC.(Carver, Christopher)
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Att: 1
Civil Cover Sheet,
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Att: 2
Summon(s) Rolando Rouco,
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Att: 3
Summon(s) RJR Insurance Services of Florida Corp.,
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Att: 4
Summon(s) Carolyn Parada,
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Att: 5
Summon(s) Aymara Mencia-Barnes,
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Att: 6
Summon(s) Teresita Manso,
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Att: 7
Summon(s) Lauren Falcon,
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Att: 8
Exhibit A - Rouco Producer Agreement,
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Att: 9
Exhibit B - Mencia Producer Agreement,
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Att: 10
Exhibit C - Parada Producer Agreement,
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Att: 11
Exhibit D - Manso Producer Agreement,
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Att: 12
Exhibit E - US Parking solicitation email 1-28-25,
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Att: 13
Exhibit F - Sunview solicitation email 1-30-25,
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Att: 14
Exhibit G - Sunview BOR change notification email 1-31-25,
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Att: 15
Exhibit H - Sunview Rouco file possession confirmation email 1-30-25,
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Att: 16
Exhibit I - GP Mobile solicitation email chain,
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Att: 17
Exhibit J - Victoria Roofing solicitation email 1-31-25,
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Att: 18
Exhibit K - Estate Operating Manager BOR change email 2-5-25,
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Att: 19
Exhibit L - Estate Operating Manager BOR change letter 2-3-25,
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Att: 20
Exhibit M - Coccoloba notification of BOR change email thread 2-3-25,
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Att: 21
Exhibit N - Coccoloba Signed Broker of Record Letter 2-3-25,
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Att: 22
Exhibit O - EZfill Holdings BOR change notification email 2-5-25,
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Att: 23
Exhibit P - EYM Group BOR change notification email 2-3-25,
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Att: 24
Exhibit Q - San Lorenzo Properties BOR change notification email chain,
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Att: 25
Exhibit R - San Lorenzo Properties BOR Letter 2-5-25
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