Massey & Duffy filed this MOTION FOR SANCTIONS in Court: Plaintiffs, Christopher Howard and Jeffrey Greenstone, move for sanctions for Defendant, Second Chance Jai Alia, LLC’s, refusal to provide a full response to Question #2 of Plaintiffs’ Second Set of Interrogatories as follows: PROCEDURAL BACKGROUND Plaintiffs brought this claim against Defendant claiming that its tip […]
federal court
Sample Federal Court Verdict Form, Fair Credit Reporting Act
PLAINTIFF’S PROPOSED SPECIAL JURY INTERROGATORIES/JURY VERDICT FORM PART A. FCRA CLAIMS (1)(a) In preparing the background report about Richard Alexander Williams (“Richard Williams”) for Rent-A-Center dated February 28, 2012, did First Advantage LNS Screening Solutions, Inc. (“First Advantage”) negligently fail to follow reasonable procedures to assure maximum possible accuracy of the information […]
Federal Court Jury Instructions, Fair Credit Reporting Act
JURY INSTRUCTION NO. 1 – RELIMINARY INSTRUCITONS Members of the Jury: Now that you’ve been sworn, I need to explain some basic principles about a civil trial and your duty as jurors. [These are preliminary instructions. I’ll give you more detailed instructions at the end of the trial.][1] The jury’s duty: It’s your duty to […]
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS THE COMPLAINT
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS THE COMPLAINT Plaintiff, Willie Jones, responds to Defendant, Gainesville Hotel Management, LLC, D/B/A Paramount Plaza Hotel& Suites’ Second Motion to Dismiss [Doc. 10] as follows: INTRODUCTION “[T]he Eleventh Circuit has held that the requirements to state a claim of a FLSA violation are straightforward.” Vestey v. […]
