Case: Alianza Americas v. DeSantis

MEMORANDUM of Law in Support re 80 State Defendants' Motion to Dismiss Plaintiffs' First Amended Complaint filed by Ronald DeSantis, Florida Department of Transportation, Florida, State of, Lawrence A. Keefe, Jared W. Perdue, James Uthmeier. (McManus, Caetlin) (Entered: 02/28/2023)

Notice of correction to docket made by Court staff. Correction: 80, 86 corrected because: Memorandum in Support of Motion to Dismiss filed in error as attachment at 80-1 entered separately on the docket at 86 Pursuant to the CM/ECF Administrative Procedures Section (G) Number (4)). (McManus, Caetlin) (Entered: 02/28/2023)

Assented to MOTION for Extension of Time to April 26, 2023 to respond to Defendants' motions to dismiss and motion to transfer by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Attachments: # 1 Text of Proposed Order)(Leonetti, Kenneth) (Entered: 03/07/2023)

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Order on Motion for Extension of Time

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 88 Motion for Extension of Time to April 26, 2023 to respond to Defendants' motions to dismiss and motion to transfer. (Folan, Karen) (Entered: 03/07/2023)

NOTICE of Appearance by Matthew Casassa on behalf of Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe (Casassa, Matthew) (Entered: 04/19/2023)

Assented to MOTION for Extension of Time to May 10, 2023 to File Response/Reply as to 84 MOTION to Dismiss for Lack of Jurisdiction (Personal), Lack of Subject-Matter Jurisdiction, Improper Venue, and Failure to State a Claim, 81 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida., 80 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction, 82 MOTION to Dismiss Amended Complaint, Assented to MOTION for Leave to File Consolidated Opposition to Motions to Dismiss ( Responses due by 5/4/2023) by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Leonetti, Kenneth) (Entered: 04/20/2023)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 91 Motion for Extension of Time to May 10, 2023 to File Response to Motions to Dismiss and Transfer and to file consolidated respones. (Folan, Karen) (Entered: 04/21/2023)

Order on Motion for Extension of Time to File Response/Reply AND Order on Motion for Leave to File Document

MOTION to Participate as Amicus Curiae by National Latino Evangelical Coalition.(Pirozzolo, Lisa) (Entered: 04/24/2023)

Opposition re 93 MOTION to Participate as Amicus Curiae filed by James Montgomerie, Vertol Systems Company, Inc.. (Kelly, Brian) (Entered: 04/26/2023)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered. National Latino Evangelical Coalition (“NaLEC”)’s motion for leave to participate in this matter as amicus curiae, [ECF No. 93 ], is DENIED without prejudice.NaLEC seeks leave to: (1) file a brief related to the pending motions to dismiss and transfer the case, [ECF Nos. 80–82, and 84 ]; and if the case proceeds beyond the disposition of these motions, (2) “submit a brief or memorandum of law... on any dispositive motion in this case”; and (3) “submit declarations or affidavits in support of its memorandum of law, which may be accorded evidentiary weight if otherwise proper.” [ECF No. 93 at 3–4].The Federal Rules of Civil Procedure do not contain provisions concerning amici appearances, but it is well accepted that a district court has “inherent authority to appoint amici to assist it in a proceeding.” Portland Pipe Line Corp. v. City of S. Portland, No. 15-cv-00054, 2017 WL 79948, at *4 (D. Me. Jan. 9, 2017) (citation omitted); see also Borges v. Our Lady of the Sea Corp., 935 F.2d 436, 442 (1st Cir. 1991) (“A trial judge has wide latitude to regulate the conduct of trial.”). Further, "the acceptance of amicus briefs is within the sound discretion of the court[.]” Strasser v. Doorley, 432 F.2d 567, 569 (1st Cir. 1970).That said, the First Circuit has noted that “by the nature of things an amicus is not normally impartial[,]” and “an amicus who argues facts should rarely be welcomed.” Strasser, 432 F.2d at 569. It does seem that NaLEC intends to argue facts. In addition to requesting leave to file declarations or affidavits, to be accorded “evidentiary weight,” see [ECF No. 93 at 4], NaLEC states that it will “inform the Court of perspectives other than those represented by the parties; expound on the history and importance of the individual constitutional rights at issue in this case and the impact that different rulings may have on the community; and focus the Court’s attention on the broader implications of the case,” id. These appear to the Court to be factual issues likely to be contested by the parties.Additionally, “a district court lacking joint consent of the parties should go slow in accepting... an amicus brief unless, as a party, although short of a right to intervene, the amicus has a special interest that justifies [] having a say, or unless the court feels that existing counsel may need supplementing assistance[.]” Strasser, 432 F.2d at 569. Here, Defendants Vertol Systems Corp. and James Montgomerie oppose the motion. See [ECF No. 94 ]. Further, although NaLEC asserts that its participation will advance “special interests of faith-based and faith-affiliated organizations that have historically assumed a central role in supporting migrants,” [ECF No. 93 at 2], NaLEC has failed to articulate what those specific interests are, and why NaLEC’s participation at this stage of litigation would be required to advance them. Relatedly, the Court does not believe, and the parties have not indicated, that parties’ counsel require assistance, nor does the Court believe that additional advocacy is necessary or will be helpful.Given these considerations, the Court will, in its discretion, deny NaLEC’s motion at this early stage. NaLEC may renew its request if the case proceeds towards trial.(McManus, Caetlin) (Entered: 05/03/2023)

Order on Motion for Miscellaneous Relief

Opposition re 81 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 05/10/2023)

Opposition re 84 MOTION to Dismiss for Lack of Jurisdiction (Personal), Lack of Subject-Matter Jurisdiction, Improper Venue, and Failure to State a Claim, 80 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction, 82 MOTION to Dismiss Amended Complaint filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 05/10/2023)

Opposition re 84 MOTION to Dismiss for Lack of Jurisdiction (Personal), Lack of Subject-Matter Jurisdiction, Improper Venue, and Failure to State a Claim, 80 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction, 82 MOTION to Dismiss Amended Complaint / Corrected Consolidated Opposition to Motions to Dismiss filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 05/11/2023)

MOTION for Leave to File Amicus Brief by National Association for the Advancement of Colored People Martha's Vineyard Branch. (Attachments: # 1 Amicus Brief)(Cole, David) (Entered: 05/17/2023)

MOTION for Leave to Appear Pro Hac Vice for admission of Roberto J. Gonzalez, Yahonnes Cleary, Jessica Finberg, Tianqi Lei, and Patrick Lim. Filing fee: $ 625, receipt number AMADC-9860934 by National Association for the Advancement of Colored People Martha's Vineyard Branch. (Attachments: # 1 Certification of Roberto J. Gonzalez, # 2 Certification of Yahonnes Cleary, # 3 Certification of Jessica Finberg, # 4 Certification of Tianqi Lei, # 5 Certification of Patrick Lim)(Cole, David) (Entered: 05/17/2023)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 100 Motion for Leave to Appear Pro Hac Vice of Roberto J. Gonzalez, Yahonnes Cleary, Jessica Finberg, Tianqi Lei, and Patrick Lim. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at https://pacer.uscourts.gov/register-account. You must put the docket number on your form when registering or it will be rejected.Pro Hac Vice Admission Request Instructions https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. Pursuant to Local Rule 83.5.3, local counsel shall also file an appearance in this matter. Further, local counsel shall review all filings and shall personally appear in Court for any hearings or conferences, unless expressly excused by the Court for good cause. (McManus, Caetlin) (Entered: 05/18/2023)

Order on Motion for Leave to Appear

Judge Allison D. Burroughs: ELECTRONIC ORDER entered. The National Association for the Advancement of Colored People (“NAACP”) Martha’s Vineyard Branch’s motion for leave to file brief as amicus curiae, [ECF No. 99 ], is DENIED without prejudice. As noted in the Court’s previous order, [ECF No. 95 ], "the acceptance of amicus briefs is within the sound discretion of the court,” but, “by the nature of things an amicus is not normally impartial[,]” and “an amicus who argues facts should rarely be welcomed.” Strasser v. Doorley, 432 F.2d 567, 569 (1st Cir. 1970). Additionally, “a district court lacking joint consent of the parties should go slow in accepting... an amicus brief unless, as a party, although short of a right to intervene, the amicus has a special interest that justifies [] having a say, or unless the court feels that existing counsel may need supplementing assistance.” Id.Defendants Vertol and Montgomerie seemingly oppose the motion. See [ECF No. 99 at 2]. Further, the NAACP Martha’s Vineyard Branch states that through its amicus brief it “seeks to assist the Court by putting” the events at issue “into historical context.” [Id. at 3]. The Court does not find, and the parties have not indicated, that such assistance is necessary at this stage of the litigation.The Court will therefore deny the motion with leave to renew if the case proceeds towards trial. (McManus, Caetlin) (Entered: 05/19/2023)

Order on Motion for Leave to File Document

Assented to MOTION for Leave to File by All Defendants to File Reply Briefs in Support of Motions to Dismiss and Transfer by Ronald DeSantis, Florida Department of Transportation, Florida, State of, Jared W. Perdue.(Weir, Bryan) (Entered: 05/23/2023)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 103 Motion for Leave to File Reply Briefs in Support of Motions to Dismiss and Transfer ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Folan, Karen) (Entered: 05/24/2023)

Order on Motion for Leave to File Document

REPLY to Response to 80 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction and Venue filed by Ronald DeSantis, Florida Department of Transportation, Florida, State of, Lawrence A. Keefe, Jared W. Perdue, James Uthmeier. (Weir, Bryan) (Entered: 06/16/2023)

Joint REPLY to Response to 81 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. filed by Ronald DeSantis, Florida Department of Transportation, Florida, State of, Perla Huerta, Lawrence A. Keefe, James Montgomerie, Jared W. Perdue, James Uthmeier, Vertol Systems Company, Inc.. (Weir, Bryan) (Entered: 06/16/2023)

REPLY to Response to 82 MOTION to Dismiss Amended Complaint filed by James Montgomerie, Vertol Systems Company, Inc.. (Kelly, Brian) (Entered: 06/16/2023)

REPLY to Response to 84 MOTION to Dismiss for Lack of Jurisdiction (Personal), Lack of Subject-Matter Jurisdiction, Improper Venue, and Failure to State a Claim filed by Perla Huerta. (Ramacher, Nicholas) (Entered: 06/16/2023)

Assented to MOTION for Leave to File Sur-Reply by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Leonetti, Kenneth) (Entered: 06/30/2023)

Order on Motion for Leave to File Document

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 109 Motion for Leave to File Document ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Folan, Karen) (Entered: 06/30/2023)

SUR-REPLY to Motion re 84 MOTION to Dismiss for Lack of Jurisdiction (Personal), Lack of Subject-Matter Jurisdiction, Improper Venue, and Failure to State a Claim, 80 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss MOTION to Dismiss for Lack of Jurisdiction, 82 MOTION to Dismiss Amended Complaint filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 07/14/2023)

Judge Allison D. Burroughs: MEMORANDUM AND ORDER entered....Accordingly, for the reasons stated above, the motions to dismiss at ECF Nos. 80 and 84 are GRANTED and the Amended Complaint is dismissed, without prejudice, as to Huerta, DeSan tis, Perdue, Keefe, Uthmeier, the State of Florida, and the Florida DOT. The motion to dismiss at ECF No. 82 is GRANTED in part and DENIED in part. It is granted insofar as the Amended Complaint is dismissed in its entirety, without prejudice, as to Montgomerie. With respect to Vertol, it is granted insofar as Counts II, V, and IX are dismissed without prejudice, and denied as to Counts I, VI, VII, VIII, X, XI, XII, and XIII. SO ORDERED.(McManus, Caetlin)

Judge Allison D. Burroughs: MEMORANDUM AND ORDER entered. Having considered the relevant factors for transfer and finding that they all weigh against transfer or are neutral, the Court DENIES Vertol's request to transfer, [ECF No. 81 ].SO ORDERED. (McManus, Caetlin)

Assented to MOTION for Extension of Time to April 19, 2024 to File Answer to Plaintiff's First Amended Complaint by Vertol Systems Company, Inc..(Kelly, Brian) (Entered: 04/12/2024)

Order on Motion for Extension of Time to Answer

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 114 Assented to MOTION for Extension of Time to April 19, 2024 to File Answer to 21 Amended Complaint. Vertol Systems Company, Inc. answer due 4/19/2024. (McManus, Caetlin) (Entered: 04/12/2024)

ANSWER to 21 Amended Complaint by Vertol Systems Company, Inc..(Kelly, Brian) (Entered: 04/19/2024)

CORPORATE DISCLOSURE STATEMENT by Vertol Systems Company, Inc.. (Kelly, Brian) (Entered: 04/19/2024)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered. The parties shall submit a joint proposed schedule by 5/7/2024 and indicate whether they object to the court setting a schedule on the written submission. (McManus, Caetlin) (Entered: 04/23/2024)

Order

NOTICE of Appearance by Ross N. MacPherson on behalf of Vertol Systems Company, Inc. (MacPherson, Ross) (Entered: 04/23/2024)

JOINT SUBMISSION pursuant to Local Rule 16.1 by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Leonetti, Kenneth) (Main Document 120 replaced on 5/14/2024) (McManus, Caetlin). (Additional attachment(s) added on 5/14/2024: # 1 Annex A: Tet of Porposed Order) (McManus, Caetlin). (Entered: 05/07/2024)

1 Annex A: Tet of Porposed Order

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NOTICE of Withdrawal of Appearance by Christopher John Stevens (Stevens, Christopher) (Entered: 05/16/2024)

MOTION for Leave to Appear Pro Hac Vice for admission of Christopher M. Mason Filing fee: $ 125, receipt number AMADC-10428287 by James Montgomerie, Vertol Systems Company, Inc.. (Attachments: # 1 Certification by Christopher M. Mason)(Kelly, Brian) (Entered: 05/22/2024)

Order on Motion for Leave to Appear

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 122 Motion for Leave to Appear Pro Hac Vice Added Christopher M. Mason. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Instructions on how to link CM/ECF accounts to upgraded pacer account can be found at https://www.mad.uscourts.gov/caseinfo/nextgen-current-pacer-accounts.htm#link-account. Pursuant to Local Rule 83.5.3, local counsel shall also file an appearance in this matter. Further, local counsel shall review all filings and shall personally appear in Court for any hearings or conferences, unless expressly excused by the Court for good cause. (McManus, Caetlin) (Entered: 05/22/2024)

NOTICE of Appearance by Christopher M. Mason on behalf of James Montgomerie, Vertol Systems Company, Inc. (Mason, Christopher) (Entered: 05/28/2024)

Assented to MOTION for Leave to File Excess Pages by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Casassa, Matthew) (Entered: 07/02/2024)

Order on Motion for Leave to File Excess Pages

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 125 Assented-to Motion for Leave to File Excess Pages ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (McManus, Caetlin) (Entered: 07/02/2024)

MOTION for Leave to File Second Amended Complaint by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Leonetti, Kenneth) (Entered: 07/04/2024)

MEMORANDUM in Support re 127 MOTION for Leave to File Second Amended Complaint (Leave to file granted July 2, 2024) filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 07/04/2024)

DECLARATION of Kenneth S. Leonetti by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 19, # 18 Exhibit 20, # 19 Exhibit 21, # 20 Exhibit 22, # 21 Exhibit 23, # 22 Exhibit 24, # 23 Exhibit 25, # 24 Exhibit 26, # 25 Exhibit 27, # 26 Exhibit 28, # 27 Exhibit 29, # 28 Exhibit 30, # 29 Exhibit 31, # 30 Exhibit 32, # 31 Exhibit 33, # 32 Exhibit 34, # 33 Exhibit 35, # 34 Exhibit 36, # 35 Exhibit 37, # 36 Exhibit 38, # 37 Exhibit 39, # 38 Exhibit 40, # 39 Exhibit 41, # 40 Exhibit 42, # 41 Exhibit 43, # 42 Exhibit 44, # 43 Exhibit 45, # 44 Exhibit 46, # 45 Exhibit 47, # 46 Exhibit 48, # 47 Exhibit 49, # 48 Exhibit 50, # 49 Exhibit 51, # 50 Exhibit 52, # 51 Exhibit 53, # 52 Exhibit 54, # 53 Exhibit 55, # 54 Exhibit 56, # 55 Exhibit 57, # 56 Exhibit 58, # 57 Exhibit 59, # 58 Exhibit 60, # 59 Exhibit 61, # 60 Exhibit 62, # 61 Exhibit 63, # 62 Exhibit 64, # 63 Exhibit 65, # 64 Exhibit 66, # 65 Exhibit 67, # 66 Exhibit 68, # 67 Exhibit 69, # 68 Exhibit 70, # 69 Exhibit 71, # 70 Exhibit 72, # 71 Exhibit 73, # 72 Exhibit 74, # 73 Exhibit 75, # 74 Exhibit 76, # 75 Exhibit 77, # 76 Exhibit 78, # 77 Exhibit 79, # 78 Exhibit 80, # 79 Exhibit 81, # 80 Exhibit 82, # 81 Exhibit 83, # 82 Exhibit 84, # 83 Exhibit 85, # 84 Exhibit 86, # 85 Exhibit 87)(Leonetti, Kenneth) (Entered: 07/04/2024)

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MOTION for Discovery by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Leonetti, Kenneth) (Entered: 07/04/2024)

MEMORANDUM in Support re 130 MOTION for Discovery filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Leonetti, Kenneth) (Entered: 07/04/2024)

DECLARATION of Kenneth S. Leonetti by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14)(Leonetti, Kenneth) (Entered: 07/04/2024)

NOTICE of Withdrawal of Appearance by Matthew Casassa (Casassa, Matthew) (Entered: 07/10/2024)

STIPULATION re 127 MOTION for Leave to File Second Amended Complaint and Joint Motion for Briefing Schedule on Plaintiffs' Second Amended Complaint and Motion for Jurisdictional Discovery by Ronald DeSantis, Perla Huerta, Lawrence A. Keefe, James Montgomerie, James Uthmeier, Vertol Systems Company, Inc.. (Weir, Bryan) (Entered: 07/18/2024)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 134 Stipulation re 127 MOTION for Leave to File Second Amended Complaint and Joint Motion for Briefing Schedule on Plaintiffs' Second Amended Complaint and Motion for Jurisdictional Discovery. (McManus, Caetlin) (Entered: 07/19/2024)

Order on Motion for Leave to File Document

Order

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 127 Motion for Leave to File Second Amended Complaint ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (McManus, Caetlin) (Entered: 07/19/2024)

AMENDED COMPLAINT / Second Amended Class Action Complaint against Lawrence A. Keefe, Perla Huerta, James Montgomerie, Vertol Systems Company, Inc., James Uthmeier, Ronald DeSantis, filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Leonetti, Kenneth) (Entered: 07/19/2024)

Assented to MOTION for Extension of Time to September 9, 2024 to File and to Modify Briefing Schedule by Ronald DeSantis, Perla Huerta, Lawrence A. Keefe, James Montgomerie, Jared W. Perdue, James Uthmeier, Vertol Systems Company, Inc..(Weir, Bryan) (Entered: 08/05/2024)

Order on Motion for Extension of Time to File

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 138 Assented to MOTION for Extension of Time to September 9, 2024 to File and to Modify Briefing Schedule. (McManus, Caetlin) (Entered: 08/05/2024)

Assented to MOTION for Leave to File Excess Pages and Consolidated Motion to Dismiss by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier.(Weir, Bryan) (Entered: 08/30/2024)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 140 Assented to MOTION for Leave to File Excess Pages and Consolidated Motion to Dismiss; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Cook, Savannah) (Entered: 09/03/2024)

Order on Motion for Leave to File Excess Pages

Assented to MOTION for Leave to File Excess Pages (1) in support of their forthcoming motion to dismiss Plaintiffs Second Amended Complaint and (2) in opposition to Plaintiffs Motion for Leave to Conduct Jurisdictional Discovery by James Montgomerie, Vertol Systems Company, Inc..(Kelly, Brian) (Entered: 09/05/2024)

Order on Motion for Leave to File Excess Pages

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 142 Motion for Leave to File Excess Pages (1) in support of their forthcoming motion to dismiss Plaintiffs Second Amended Complaint and (2) in opposition to Plaintiffs Motion for Leave to Conduct Jurisdictional Discovery ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Folan, Karen) (Entered: 09/05/2024)

MOTION for Leave to File Excess Pages Memorandum in Support of Her Motion to Dismiss (Unopposed) by Perla Huerta.(Ramacher, Nicholas) (Entered: 09/05/2024)

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 144 Motion for Leave to File Excess Pages in Memorandum in Support of Her Motion to Dismiss (Unopposed) ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Folan, Karen) (Entered: 09/05/2024)

MOTION to Dismiss for Lack of Jurisdiction, MOTION to Dismiss for improper venue, MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier.(Weir, Bryan) (Entered: 09/09/2024)

MEMORANDUM in Support re 146 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss for improper venue MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier. (Attachments: # 1 Weir Declaration, # 2 Exhibit A - Program Guidelines, # 3 Exhibit B - Terms and Conditions)(Weir, Bryan) (Entered: 09/09/2024)

1 Weir Declaration

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3 Exhibit B - Terms and Conditions

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MEMORANDUM in Opposition re 130 MOTION for Discovery filed by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier. (Attachments: # 1 Nennstiel Declaration, # 2 Ringers Declaration)(Weir, Bryan) (Entered: 09/09/2024)

Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. by Ronald DeSantis, Perla Huerta, Lawrence A. Keefe, James Montgomerie, James Uthmeier, Vertol Systems Company, Inc..(Weir, Bryan) (Entered: 09/09/2024)

Joint MEMORANDUM in Support re 149 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. filed by Ronald DeSantis, Perla Huerta, Lawrence A. Keefe, James Montgomerie, James Uthmeier, Vertol Systems Company, Inc.. (Attachments: # 1 Appendix A: Potential Witnesses)(Weir, Bryan) (Entered: 09/09/2024)

MOTION to Dismiss for Lack of Jurisdiction by Perla Huerta.(Ramacher, Nicholas) (Entered: 09/09/2024)

MEMORANDUM in Support re 151 MOTION to Dismiss for Lack of Jurisdiction filed by Perla Huerta. (Ramacher, Nicholas) (Entered: 09/09/2024)

Opposition re 130 MOTION for Discovery filed by Perla Huerta. (Ramacher, Nicholas) (Entered: 09/09/2024)

MOTION to Dismiss the Second Amended Complaint by James Montgomerie, Vertol Systems Company, Inc..(Kelly, Brian) (Entered: 09/09/2024)

MEMORANDUM in Support re 154 MOTION to Dismiss the Second Amended Complaint and in Opposition to Plaintiff's Motion for Leave to Conduct Jurisdictional Discovery filed by James Montgomerie, Vertol Systems Company, Inc.. (Kelly, Brian) (Entered: 09/09/2024)

AFFIDAVIT in Support re 154 MOTION to Dismiss the Second Amended Complaint, 155 Memorandum in Support of Motion, Affidavit of James Montgomerie. (Kelly, Brian) (Entered: 09/09/2024)

NOTICE of Appearance by Rachel Leigh Kerner on behalf of Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe (Kerner, Rachel) (Entered: 09/27/2024)

NOTICE of Change of Address or Firm Name by Jeff Aaron (Aaron, Jeff) (Entered: 10/04/2024)

Assented to MOTION for Leave to File Excess Pages Plaintiffs' Assented to Motion for Leave to File Consolidated Opposition to Defendants' Motions to Dismiss of 85 Pages by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe.(Kerner, Rachel) (Entered: 10/15/2024)

Order on Motion for Leave to File Excess Pages

Judge Allison D. Burroughs: ELECTRONIC ORDER entered GRANTING 159 Motion for Leave to File Excess Pages. Parties are encouraged to be as succinct as possible. ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (McManus, Caetlin) (Entered: 10/15/2024)

Opposition re 154 MOTION to Dismiss the Second Amended Complaint, 146 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss for improper venue MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 151 MOTION to Dismiss for Lack of Jurisdiction Consolidated Opposition to Defendants' Motions to Dismiss the Second Amended Complaint filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Kerner, Rachel) (Entered: 10/18/2024)

Opposition re 149 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. Consolidated Opposition to Defendants' Motion to Transfer to the Northern District of Florida filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Kerner, Rachel) (Entered: 10/18/2024)

REPLY to Response to 130 MOTION for Discovery Consolidated Reply in Support to Motion for Leave to Take Jurisdictional Discovery filed by Alianza Americas, Jesus Doe, Pablo Doe, Yanet Doe. (Kerner, Rachel) (Entered: 10/18/2024)

Assented to MOTION for Leave to File Excess Pages and for Consolidated Reply Brief by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier.(Weir, Bryan) (Entered: 11/05/2024)

Order on Motion for Leave to File Excess Pages

Judge Allison D. Burroughs: ELECTRONIC ORDER entered granting 164 Motion for Leave to File Excess Pages and for Consolidated Reply Brief ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (Folan, Karen) (Entered: 11/05/2024)

REPLY to Response to 146 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss for improper venue MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Ronald DeSantis, Lawrence A. Keefe, James Uthmeier. (Weir, Bryan) (Entered: 11/08/2024)

REPLY to Response to 149 Joint MOTION to Transfer Case to U.S. District Court for the Northern District of Florida. filed by Ronald DeSantis, Perla Huerta, Lawrence A. Keefe, James Montgomerie, James Uthmeier, Vertol Systems Company, Inc.. (Weir, Bryan) (Entered: 11/08/2024)