Case: Jackson v. City of Fort Lauderdale

Complaint pursuant to 42 USC 1983 against ZACHARY BARO, CAMERON BURDICK, JAMIE CHATMAN, CITY OF FORT LAUDERDALE, A Florida Municipality,, paul CRISTAFARO, ROBERT DEITRICH, KEVIN DUPREE, Jesus Fernandez, ANDREW GOTTSTEIN, Steve GREENLAW, RYAN IJAMES, Jeffrey Jenkins, Raymond Ketchmark, Douglas MacDoughall, Ronald Magno, ELIEZER Ramos, Aryo Rezaie, Remy Rodriguez, FRANCO SMITH, ROBERT SMITH, DAVID SOIKA, Steven Smith, SEAN WALTERS, Rick maglione. Filing fee $ 405.00 receipt number AFLSDC-17574055, filed by JAYANNA JACKSON, Scott Ross, MIKE GABELUS. (Attachments: # 1 Civil Cover Sheet)(Davis, Michael) (Entered: 05/31/2024)

1 Civil Cover Sheet

View on PACER

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt 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. (wce) (Entered: 06/03/2024)

Clerk's Notice to Filer re: Electronic Case. Parties Not Added. The Filer failed to add all parties associated with the case. The Clerk has added all parties associated with the case. It is not necessary to re-file this document. (wce) (Entered: 06/03/2024)

Clerk's Notice of Docket Correction - ELECTRONIC CASE

Clerk's Notice of Judge Assignment and Optional Consent

NOTICE of Filing Proposed Summons(es) Notice of Summons by Jayanna Jackson (Attachments: # 1 Exhibit Summons in Civil Action) (Davis, Michael) (Entered: 06/06/2024)

Summons Issued as to Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Paul Cristafaro, Robert Deitrich, Kevin Dupree, Jesus Fernandez, Avery Figueras, Andrew Gottstein, Steven Greenlaw, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Douglas Macdoughall, Rick Maglione, Ronald Magno, Eliezer Ramos, Aryo Rezaie, Remy Rodriguez, Franco Smith, Robert Smith, Steven Smith, David Soika, Sean Walters. (scn) (Entered: 06/07/2024)

NOTICE of Filing Proposed Summons(es) City of Fort Lauderdale by Mike Gabelus, Jayanna Jackson, Scott Ross (Attachments: # 1 Summon(s)) (Davis, Michael) (Entered: 08/27/2024)

Summons Issued as to City of Fort Lauderdale, Florida. (cqs) (Entered: 08/28/2024)

Summons Issued as to City of Fort Lauderdale, Florida.(Corrected). (cqs) (Entered: 08/28/2024)

Plaintiff's MOTION for Extension of Time extension for service of summonses With Incorporated Memorandum of Law re 1 Complaint 42 USC 1983 or Bivens,, 4 Notice of Filing Proposed Summons(es), 5 Summons Issued, 6 Notice of Filing Proposed Summons(es) by Jayanna Jackson. Responses due by 9/11/2024. (Attachments: # 1 Text of Proposed Order Order Granting Plaintiffs' Motion For Extension of Time To Serve Process)(Davis, Michael) (Entered: 08/28/2024)

PAPERLESS ORDER granting 9 Plaintiffs' Motion for Extension of Time to Serve Process. Plaintiffs shall serve the Complaint and summons on all Defendants by October 13, 2024. Signed by Judge Rodney Smith on 8/28/2024. (kv00) (Entered: 08/28/2024)

Order on Motion for Extension of Time

(STRICKEN PER DE 12 ) NOTICE of Attorney Appearance by Scott David Alexander on behalf of Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Kevin Dupree, Jesus Fernandez, Andrew Gottstein, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Aryo Rezaie, Franco Smith, Robert Smith, David Soika, Sean Walters. Attorney Scott David Alexander added to party Zachary Baro(pty:dft), Attorney Scott David Alexander added to party Cameron Burdick(pty:dft), Attorney Scott David Alexander added to party Jan Caldera(pty:dft), Attorney Scott David Alexander added to party Jamie Chatman(pty:dft), Attorney Scott David Alexander added to party Kevin Dupree(pty:dft), Attorney Scott David Alexander added to party Jesus Fernandez(pty:dft), Attorney Scott David Alexander added to party Andrew Gottstein(pty:dft), Attorney Scott David Alexander added to party Ryan Ijames(pty:dft), Attorney Scott David Alexander added to party Jeffrey Jenkins(pty:dft), Attorney Scott David Alexander added to party Raymond Ketchmark(pty:dft), Attorney Scott David Alexander added to party Ronald Magno(pty:dft), Attorney Scott David Alexander added to party Eliezer Ramos(pty:dft), Attorney Scott David Alexander added to party Aryo Rezaie(pty:dft), Attorney Scott David Alexander added to party Franco Smith(pty:dft), Attorney Scott David Alexander added to party Robert Smith(pty:dft), Attorney Scott David Alexander added to party David Soika(pty:dft), Attorney Scott David Alexander added to party Sean Walters(pty:dft). (Alexander, Scott) Modified Text on 9/10/2024 (wce). (Entered: 08/29/2024)

NOTICE of Striking 11 Notice of Attorney Appearance,,,,,, filed by Ryan Ijames, Jamie Chatman, Jan Caldera, Cameron Burdick, Jeffrey Jenkins, Zachary Baro, Raymond Ketchmark, Aryo Rezaie, Franco Smith, Robert Smith, Ronald Magno, Andrew Gottstein, Jesus Fernandez, David Soika, Sean Walters, Eliezer Ramos, Kevin Dupree by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Kevin Dupree, Jesus Fernandez, Andrew Gottstein, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Remy Rodriguez, Franco Smith, Robert Smith, David Soika, Sean Walters (Alexander, Scott) (Entered: 09/10/2024)

ORDER REQUIRING JOINT SCHEDULING REPORT, CERTIFICATES OF INTERESTED PARTIES AND CORPORATE DISCLOSURE STATEMENTS: By November 1, 2024, the parties shall: Prepare and file a Joint Scheduling Report and File Certificates of Interested Parties and Corporate Disclosure Statements. Signed by Judge Rodney Smith on 9/27/2024. See attached document for full details. (wce) (Entered: 09/27/2024)

WAIVER OF SERVICE Returned Executed by Jayanna Jackson, Scott Ross, Mike Gabelus. City of Fort Lauderdale, Florida waiver sent on 8/29/2024, response/answer due 10/28/2024; Paul Cristafaro waiver sent on 8/29/2024, response/answer due 10/28/2024; Robert Deitrich waiver sent on 8/29/2024, response/answer due 10/28/2024; Avery Figueras waiver sent on 8/29/2024, response/answer due 10/28/2024; Steven Greenlaw waiver sent on 8/29/2024, response/answer due 10/28/2024; Douglas Macdoughall waiver sent on 8/29/2024, response/answer due 10/28/2024; Steven Smith waiver sent on 8/29/2024, response/answer due 10/28/2024. (Davis, Michael) (Entered: 10/04/2024)

WAIVER OF SERVICE Returned Executed by Jayanna Jackson, Scott Ross, Mike Gabelus. Zachary Baro waiver sent on 8/29/2024, response/answer due 10/28/2024; Cameron Burdick waiver sent on 8/29/2024, response/answer due 10/28/2024; Jan Caldera waiver sent on 8/29/2024, response/answer due 10/28/2024; Jamie Chatman waiver sent on 8/29/2024, response/answer due 10/28/2024; Kevin Dupree waiver sent on 8/29/2024, response/answer due 10/28/2024; Jesus Fernandez waiver sent on 8/29/2024, response/answer due 10/28/2024; Andrew Gottstein waiver sent on 8/29/2024, response/answer due 10/28/2024; Ryan Ijames waiver sent on 8/29/2024, response/answer due 10/28/2024; Jeffrey Jenkins waiver sent on 8/29/2024, response/answer due 10/28/2024; Raymond Ketchmark waiver sent on 8/29/2024, response/answer due 10/28/2024; Ronald Magno waiver sent on 8/29/2024, response/answer due 10/28/2024; Eliezer Ramos waiver sent on 8/29/2024, response/answer due 10/28/2024; Aryo Rezaie waiver sent on 8/29/2024, response/answer due 10/28/2024; Remy Rodriguez waiver sent on 8/29/2024, response/answer due 10/28/2024; Franco Smith waiver sent on 8/29/2024, response/answer due 10/28/2024; Robert Smith waiver sent on 8/29/2024, response/answer due 10/28/2024; David Soika waiver sent on 8/29/2024, response/answer due 10/28/2024; Sean Walters waiver sent on 8/29/2024, response/answer due 10/28/2024. (Davis, Michael) (Entered: 10/04/2024)

WAIVER OF SERVICE Returned Executed by Jayanna Jackson, Scott Ross, Mike Gabelus. Rick Maglione waiver sent on 8/29/2024, response/answer due 10/28/2024. (Davis, Michael) (Entered: 10/04/2024)

MOTION TO DISMISS 1 Complaint 42 USC 1983 or Bivens,, FOR FAILURE TO STATE A CLAIM by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Kevin Dupree, Jesus Fernandez, Andrew Gottstein, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Aryo Rezaie, Franco Smith, Robert Smith, David Soika, Sean Walters. Responses due by 11/5/2024. (Alexander, Scott) (Entered: 10/22/2024)

Defendant's MOTION TO DISMISS 1 Complaint 42 USC 1983 or Bivens,, FOR FAILURE TO STATE A CLAIM by Avery Figueras, Rick Maglione, Steven Greenlaw, Douglas MacDoughall, Steven Smith and by City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich. Attorney Jeffery Rodman Lawley added to party City of Fort Lauderdale, Florida(pty:dft), Attorney Jeffery Rodman Lawley added to party Paul Cristafaro(pty:dft), Attorney Jeffery Rodman Lawley added to party Robert Deitrich(pty:dft). Responses due by 11/12/2024. (Lawley, Jeffery) (Entered: 10/28/2024)

NOTICE of Attorney Appearance by Jeffery Rodman Lawley on behalf of City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich (Lawley, Jeffery) (Entered: 10/28/2024)

Certificate of Other Affiliates/Corporate Disclosure Statement by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Kevin Dupree, Jesus Fernandez, Andrew Gottstein, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Aryo Rezaie, Franco Smith, Robert Smith, David Soika, Sean Walters (Alexander, Scott) (Entered: 10/29/2024)

Joint SCHEDULING REPORT - Rule 16.1 by Jayanna Jackson (Attachments: # 1 Text of Proposed Order Proposed Scheduling Order)(Davis, Michael) (Entered: 11/05/2024)

Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich, Avery Figueras, Steven Greenlaw, Douglas Macdoughall, Rick Maglione, Steven Smith (Lawley, Jeffery) (Entered: 11/08/2024)

First AMENDED COMPLAINT against Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich, Jesus Fernandez, Avery Figueras, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Rick Maglione, Ronald Magno, Eliezer Ramos, Remy Rodriguez, Robert Smith, Steven Smith, David Soika, Sean Walters, filed by Jayanna Jackson, Scott Ross, Mike Gabelus.(Davis, Michael) (Entered: 11/12/2024)

MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM (Count VI) by Zachary Baro, Cameron Burdick, Jamie Chatman, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno. Responses due by 12/9/2024. (Alexander, Scott) (Entered: 11/25/2024)

ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, Kevin Dupree, Jesus Fernandez, Andrew Gottstein, Ryan Ijames, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco Smith, Robert Smith, David Soika, Sean Walters. (Alexander, Scott) (Entered: 11/25/2024)

Defendant's MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Avery Figueras, Rick Maglione, Steven Smith by City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich. Responses due by 12/10/2024. (Lawley, Jeffery) (Entered: 11/26/2024)

RESPONSE in Opposition re 24 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM (Count VI) filed by Mike Gabelus, Jayanna Jackson, Scott Ross. Replies due by 12/16/2024. (Davis, Michael) (Entered: 12/09/2024)

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 26 Defendant's MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Avery Figueras, Rick Maglione, Steven Smith by Mike Gabelus, Jayanna Jackson, Scott Ross. (Davis, Michael) (Entered: 12/10/2024)

REPLY to Response to Motion re 24 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM (Count VI) filed by Zachary Baro, Cameron Burdick, Jamie Chatman, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno. (Alexander, Scott) (Entered: 12/14/2024)

PAPERLESS ORDER granting 28 Motion for Extension of Time to File Response. Plaintiffs shall respond to the Motions to Dismiss by December 17, 2024. Signed by Judge Rodney Smith on 12/16/2024. (kv00) (Entered: 12/16/2024)

Order on Motion for Extension of Time to File Response/Reply/Answer

RESPONSE in Opposition re 26 Defendant's MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Avery Figueras, Rick Maglione, Steven Smith filed by Mike Gabelus, Jayanna Jackson, Scott Ross. Replies due by 12/26/2024. (Davis, Michael) (Entered: 12/17/2024)

REPLY to Response to Motion re 26 Defendant's MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Avery Figueras, Rick Maglione, Steven Smith filed by City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich. (Lawley, Jeffery) (Entered: 12/26/2024)

NOTICE OF UNAVAILABILITY by City of Fort Lauderdale, Florida for dates of 4/17/25-4/18/25 and 5/29/25-6/13/25 (Lawley, Jeffery) (Entered: 02/05/2025)

PAPERLESS ORDER denying as moot 17 Motion to Dismiss for Failure to State a Claim; denying as moot 18 Motion to Dismiss for Failure to State a Claim in light of 23 First Amended Complaint. Signed by Judge Rodney Smith on 3/18/2025. (kv00) (Entered: 03/18/2025)

Order on Motion to Dismiss for Failure to State a Claim AND Order on Motion to Dismiss for Failure to State a Claim

ORDER SETTING CIVIL TRIAL DATE, PRETRIAL DEADLINES, AND REFERRAL TO MAGISTRATE JUDGE. ( Jury Trial set for 12/14/2026 09:00 AM in Fort Lauderdale Division before Judge Rodney Smith., Calendar Call set for 12/8/2026 09:00 AM in Fort Lauderdale Division before Judge Rodney Smith., Amended Pleadings due by 4/9/2025., Expert Discovery due by 3/27/2026., Fact Discovery due by 3/27/2026., Joinder of Parties due by 4/9/2025., Mediation Deadline 4/3/2026., In Limine Motions due by 8/31/2026., Dispositive Motions due by 5/29/2026., Motions due by 8/31/2026., Pretrial Stipulation due by 10/30/2026.) Signed by Judge Rodney Smith on 3/19/2025. See attached document for full details. (kpe) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here. (Entered: 03/19/2025)

ORDER OF REFERRAL TO MEDIATION. Signed by Judge Rodney Smith on 3/19/2025. See attached document for full details. (kpe) (Entered: 03/19/2025)

GENERAL ORDER ON DISCOVERY OBJECTIONS AND PROCEDURES. Signed by Magistrate Judge Patrick M. Hunt on 3/24/2025. See attached document for full details. (mhr) (Entered: 03/24/2025)

NOTICE of Change of Address/Contact Information; Change of Email; by Kimberly Lynn Boldt (Boldt, Kimberly) (Entered: 03/31/2025)

CLERK'S NOTICE - Attorney Admissions has updated the address and email information as submitted through attorneys PACER account for attorney Kimberly Lynn Boldt (pt) (Entered: 04/01/2025)

Clerk's Notice - Attorney Admissions

NOTICE of Attorney Appearance by Lori Brooke Lewellen on behalf of City of Fort Lauderdale, Florida, Rick Maglione, Avery Figueras, Steven Greenlaw, Douglas Macdoughall, Robert Deitrich, Paul Cristafaro, Steven Smith. Attorney Lori Brooke Lewellen added to party City of Fort Lauderdale, Florida(pty:dft), Attorney Lori Brooke Lewellen added to party Rick Maglione(pty:dft), Attorney Lori Brooke Lewellen added to party Avery Figueras(pty:dft), Attorney Lori Brooke Lewellen added to party Steven Greenlaw(pty:dft), Attorney Lori Brooke Lewellen added to party Douglas Macdoughall(pty:dft), Attorney Lori Brooke Lewellen added to party Robert Deitrich(pty:dft), Attorney Lori Brooke Lewellen added to party Paul Cristafaro(pty:dft), Attorney Lori Brooke Lewellen added to party Steven Smith(pty:dft). (Lewellen, Lori) (Entered: 04/03/2025)

NOTICE of Attorney Appearance by Lori Brooke Lewellen on behalf of City of Fort Lauderdale, Florida, Rick Maglione, Avery Figueras, Robert Deitrich, Paul Cristafaro, Steven Smith (Lewellen, Lori) (Entered: 04/07/2025)

STRICKEN. Joint NOTICE of Non-Agreement on Mediator by Plaintiffs and Defendants by City of Fort Lauderdale, Florida re 36 Order Referring Case to Mediation (Lawley, Jeffery) Modified per DE 44 Notice of Striking on 4/11/2025 (ebz). (Entered: 04/09/2025)

Clerk's Notice to Filer re 42 Notice (Other). Wrong Event Selected - Document is a Motion to Appoint Mediator; CORRECTIVE ACTION REQUIRED - The Filer must File a Notice of Striking, then refile the document using the Motion to Appoint Mediator event and ensure all applicable parties are added. (ebz) (Entered: 04/10/2025)

NOTICE of Striking 42 Notice (Other) filed by City of Fort Lauderdale, Florida by Plaintiffs and Defendants by City of Fort Lauderdale, Florida (Lawley, Jeffery) (Entered: 04/10/2025)

Joint MOTION to Appoint Mediator by Plaintiffs, Jayanna Jackson, Scott Ross, Mike Gabelus, and Defendants, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco Smith, Robert Smith, Steven Smith, David Soika, Sean Walters, Rick Maglione, by Cameron Burdick, Jamie Chatman, Kevin Dupree, Jesus Fernandez, City of Fort Lauderdale, Florida, Avery Figueras, Jan Caldera, Robert Deitrich, Paul Cristafaro, Zachary Baro. Responses due by 4/24/2025. (Lawley, Jeffery) (Entered: 04/10/2025)

Clerk's Notice of Docket Correction and Instruction to Filer - Attorney

ORDER GRANTING JOINT MOTION TO APPOINT MEDIATOR, granting 45 Motion to Appoint Mediator, filed by City of Fort Lauderdale, Florida, Paul Cristafaro, Jamie Chatman, Jan Caldera, Jesus Fernandez, Robert Deitrich, Avery Figueras, Kevin Dupree, Zachary Baro, Cameron Burdick. The Clerk of Court is hereby directed to designate a mediator in this matter. Signed by Judge Rodney Smith on 4/11/2025. See attached document for full details. (pcs) (Entered: 04/14/2025)

Clerk's Appointment of Mediator: Neil Flaxman added (pt) (Entered: 04/14/2025)

PAPERLESS ORDER striking 24 Motion to Dismiss; and 26 Motion to Dismiss for failing to comply with the joint motion requirements specified in 13 ORDER REQUIRING JOINT SCHEDULING REPORT. By May 2, 2025, the Defendants shall file one joint motion to dismiss that complies with 13 ORDER REQUIRING JOINT SCHEDULING REPORT. Signed by Judge Rodney Smith on 4/23/2025. (kv00) (Entered: 04/23/2025)

Order on Motion to Dismiss for Failure to State a Claim AND Order on Motion to Dismiss for Failure to State a Claim

Joint NOTICE OF SCHEDULING MEDIATION by City of Fort Lauderdale, Florida (Lawley, Jeffery) (Entered: 04/29/2025)

Joint NOTICE RE-NOTICE OF SCHEDULING MEDIATION AS TO DATE ONLY by City of Fort Lauderdale, Florida (Lawley, Jeffery) (Entered: 04/30/2025)

MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco Smith, Robert Smith, David Soika, Sean Walters, and by Cameron Burdick, Jamie Chatman, Kevin Dupree, Jesus Fernandez, City of Fort Lauderdale, Florida, Avery Figueras, Jan Caldera, Robert Deitrich, Paul Cristafaro, Zachary Baro. Responses due by 5/16/2025. (Lawley, Jeffery) (Entered: 05/02/2025)

RESPONSE in Opposition re 51 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S With Request for Hearing filed by Jayanna Jackson, Scott Ross, Mike Gabelus. Replies due by 5/27/2025. (Kuehne, Benedict) (Entered: 05/17/2025)

REPLY in Support of Motion re 51 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S. filed by Cameron Burdick, Jamie Chatman, Kevin Dupree, Jesus Fernandez, City of Fort Lauderdale, Florida, Avery Figueras, Jan Caldera, Robert Deitrich, Paul Cristafaro, Zachary Baro. (Lawley, Jeffery) (Entered: 05/27/2025)

NOTICE of Correction of Scrivener's Error In Response To Motion To Dismiss And Motion For Leave To File Corrected Response In Opposition To Motion To Dismiss by Jayanna Jackson re 52 Response in Opposition to Motion, (Attachments: # 1 Exhibit Plaintiffs' Corrected Response In Opposition To Defendants' Combined Motion To Dismiss Plaintiffs' First Amended Class Action Complaint(DE51)) (Kuehne, Benedict) Modified on 6/9/2025 (pcs). (Entered: 06/06/2025)

Clerk's Notice to Filer re 54 Notice (Other),. Wrong Event Selected - Document is a Motion; ERROR - The Filer selected the wrong event. A motion event must always be selected when filing a motion. The correction was made by the Clerk. It is not necessary to refile this document. (pcs) (Entered: 06/09/2025)

Clerk's Notice of Docket Correction and Instruction to Filer - Attorney

PAPERLESS ORDER granting 54 Motion for Leave to File Corrected Response in Opposition to Motion to Dismiss. Plaintiffs shall file the amended response as a separate docket entry by July 3, 2025. Signed by Judge Rodney Smith on 6/27/2025. (hws) (Entered: 06/27/2025)

Order on Motion for Leave to File

RESPONSE in Opposition re 51 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S filed by Jayanna Jackson. Replies due by 7/9/2025. (Kuehne, Benedict) (Entered: 07/02/2025)

Defendant's REPLY in Support of Motion re 51 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S. filed by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich, Kevin Dupree, Jesus Fernandez. (Lawley, Jeffery) (Entered: 07/09/2025)

Unopposed MOTION for Extension of Time For Motion For Class Certification by Jayanna Jackson. Responses due by 8/13/2025. (Attachments: # 1 Text of Proposed Order Order Granting Plaintiffs' Unopposed Motion For Extension of Time For Motion For Class Certification. 7.30.25)(Davis, Michael) (Entered: 07/30/2025)

PAPERLESS ORDER granting 59 Plaintiffs' Unopposed Motion for Extension of Time for Motion for Class Certification. Plaintiffs' Motion for Class Certification is due by August 14, 2025. Signed by Judge Rodney Smith on 7/31/2025. (hws) (Entered: 07/31/2025)

Order on Motion for Extension of Time

Plaintiff's MOTION for Leave to File Excess Pages For Class Certification Motion by Mike Gabelus, Jayanna Jackson, Scott Ross. (Attachments: # 1 Text of Proposed Order Proposed Order)(Dos Santos, Johan) (Entered: 08/14/2025)

(STRIKEN) Plaintiff's MOTION to Certify Class by Mike Gabelus, Jayanna Jackson, Scott Ross. Responses due by 8/28/2025. (Attachments: # 1 Exhibit Ex. A Declaraction Toby Terpstra, # 2 Exhibit Ex. B Use Of Force Reports)(Dos Santos, Johan) per DE 63 . Modified text on 8/15/2025 (blc). (Entered: 08/14/2025)

ORDER denying Plaintiff's Unposed Motion for Leave to Exceed the Page Limit DE 61 and striking Plaintiff's Motion for Class Certification DE 62 . Plaintiff shall file a motion for class certification compliant with the Local Rules by August 22, 2025. Signed by Judge Rodney Smith on 8/15/2025. See attached document for full details. (blc) (Entered: 08/15/2025)

Plaintiff's MOTION to Certify Class by Mike Gabelus, Jayanna Jackson, Scott Ross. Responses due by 9/5/2025. (Attachments: # 1 Exhibit Ex. A - (CCM) Exhibit A Declaraction Toby Terpstra-Signed, # 2 Exhibit Ex. B - (CCM) UOF Reports, # 3 Exhibit Ex. C - City's Answers to PL Interrogatories (served 6-16-2025), # 4 Exhibit Ex. D - CITY's Response to PL RFA (served 6-16-2025))(Dos Santos, Johan) (Entered: 08/22/2025)

Consent MOTION for Extension of Time to File Response/Reply/Answer as to 64 Plaintiff's MOTION to Certify Class by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich, Kevin Dupree, Jesus Fernandez, Avery Figueras. (Lawley, Jeffery) (Entered: 09/04/2025)

PAPERLESS ORDER granting 65 Defendants' Consent Motion for Extension of Time to Respond to Plaintiffs' Corrected Motion for Class Certification. Defendants shall respond to Plaintiffs' Motion for Class Certification by September 19, 2025 . Signed by Judge Rodney Smith on 9/5/2025. (hws) (Entered: 09/05/2025)

Order on Motion for Extension of Time to File Response/Reply/Answer

~Util - Set/Reset Motion/R&R Deadlines and Hearings

Set/Reset Deadlines/Hearings per DE 66 as to 64 Plaintiff's MOTION to Certify Class . Responses due by 9/19/2025. (pcs)

RESPONSE in Opposition re 64 Plaintiff's MOTION to Certify Class by Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco Smith, Robert Smith, David Soika, Sean Walters, and filed by Zachary Baro, Cameron Burdick, Jan Caldera, Jamie Chatman, City of Fort Lauderdale, Florida, Paul Cristafaro, Robert Deitrich, Kevin Dupree, Jesus Fernandez, Avery Figueras. Replies due by 9/26/2025. (Lawley, Jeffery) (Entered: 09/19/2025)

Plaintiff's MOTION for Extension of Time to File Response/Reply/Answer by Mike Gabelus, Jayanna Jackson, Scott Ross. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Motion For EOT)(Dos Santos, Johan) (Entered: 09/25/2025)

PAPERLESS ORDER granting 68 Unopposed Motion for Extension of Time to File Reply to Response in Opposition to Motion for Class Certification. Plaintiffs' reply to the Response to Motion for Class Certification is due by October 9, 2025. Signed by Judge Rodney Smith on 9/26/2025. (hws) (Entered: 09/26/2025)

Order on Motion for Extension of Time to File Response/Reply/Answer

~Util - Set/Reset Motion/R&R Deadlines and Hearings

Set/Reset Deadlines/Hearings per DE 69 as to 64 Plaintiff's MOTION to Certify Class . Replies due by 10/9/2025. (pcs)

Plaintiff's REPLY in Support of Motion re 64 Plaintiff's MOTION to Certify Class . filed by Mike Gabelus, Jayanna Jackson, Scott Ross. (Kuehne, Benedict) (Entered: 10/09/2025)

Plaintiff's NOTICE Notice of Filing Exhibits in Support of DE70 by Mike Gabelus, Jayanna Jackson, Scott Ross (Attachments: # 1 Exhibit City's Answers to Plaintiffs Roggs, # 2 Exhibit Excerpt of Plaintiffs' Answer to Defendant Supervising Officers Roggs) (Dos Santos, Johan) (Entered: 10/10/2025)

Agreed MOTION to Amend/Correct 35 Scheduling Order,,,, Order Referring Case to Magistrate Judge,,, by Jayanna Jackson. Responses due by 11/24/2025. (Attachments: # 1 Text of Proposed Order Order Granting Motion To Modify Scheduling Order)(Dos Santos, Johan) (Entered: 11/10/2025)

ORDER RESETTING PRETRIAL DEADLINES-granting 72 Motion to Modify Scheduling Order. Amended Pleadings due by 4/9/2025. Expert Discovery due by 5/26/2026. Fact Discovery due by 5/26/2026. Mediation Deadline 5/4/2026. Dispositive Motions due by 7/28/2026. In Limine Motions due by 10/30/2026. Pretrial Stipulation due by 10/30/2026. Calendar Call set for 12/8/2025 09:00 AM in Fort Lauderdale Division before Judge Rodney Smith. Jury Trial set for 12/14/2026 in Fort Pierce Division before Judge Rodney Smith. Signed by Judge Rodney Smith on 11/17/2025. See attached document for full details. (mab) (Entered: 11/18/2025)

MOTION to Be Included in Docket Entries re 51 MOTION TO DISMISS, 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S, 67 Response in Opposition to Motion, 25 Answer to Amended Complaint, by Remy Rodriguez. Attorney Scott David Alexander added to party Remy Rodriguez(pty:dft). (Alexander, Scott) (Entered: 12/03/2025)

NOTICE of Joinder by Remy Rodriguez re 67 Response in Opposition to Motion, 51 MOTION TO DISMISS 23 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM by Rick Maglione, Steven Smith, Aryo Rezaie, Ryan Ijames, Andrew Gottstein, Jeffrey Jenkins, Raymond Ketchmark, Ronald Magno, Eliezer Ramos, Franco S (Alexander, Scott) (Entered: 12/03/2025)

ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by Remy Rodriguez. (Alexander, Scott) (Entered: 12/03/2025)

Extension of Time