309745092.1 

1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61023-RAR

MATTHEW BUCKLEY and

TOP GUN OPTIONS, LLC,

Plaintiffs,

v.

EMMETT MOORE and

TRADINGSCHOOLS.ORG,

Defendants.

PLAINTIFFS’ EMERGENCY MOTION 

FOR STATUS CONFERENCE

Plaintiffs MATTHEW BUCKLEY (“Buckley”) and TOP GUN OPTIONS, LLC (“Top 

Gun” and together with Buckley “Plaintiffs”), by and through undersigned counsel, hereby file 

their Emergency Motion for Status Conference and hereby move the Court to schedule a status 

conference within the next seven days, stating as follows:

1. Defendants have engaged in unprofessional conduct, including threatening to file 

motions for sanctions, filing frivolous motions, and serving discovery unrelated to the claims at 

issue, solely for the purpose of embarrassment and harassment.

2. Defendants sent their latest communication regarding such matters late in the 

evening on May 13, 2021, hours after Plaintiffs responded to Defendants’ frivolous Motion for 

Bond Hearing [DE 73]. Counsel for the Defendants, Susanne Arani, then stated in writing her 

intent to file a motion seeking the Court’s intervention with the attorney-client relationship 

between Plaintiffs and their counsel, Mudd Law. Attorney Arani’s motion is without merit, and 

therein makes baseless, inflammatory claims against lead counsel, Mudd Law and makes 

Case 0:20-cv-61023-RAR Document 75 Entered on FLSD Docket 05/14/2021 Page 1 of 3
309745092.1 

2

disparaging, unfounded insinuations about Buckley’s mental health and personal life that are 

wholly irrelevant to the matter at hand.

3. Attorney Arani communicated with Plaintiff’s counsel, purportedly seeking to meet 

and confer to file her motion for intervention under seal. The draft motion to seal itself contains 

disparaging information and unfounded accusations against Plaintiffs and Mudd Law, specifically 

lead counsel, Charles Lee Mudd, Jr.

4. In the face of the onslaught of frivolous filings from Defendants and in an attempt 

to avoid unnecessary litigation and an abuse of court resources, Plaintiffs respectfully request an 

emergency status conference to take place within the next seven days. Additionally, Plaintiffs 

respectfully request that the Court schedule the conference in advance of any hearing on pending 

motions. Counsel will make themselves available at the Court’s convenience. 

Dated: May 14, 2021 Respectfully submitted,

/s/ Elisa D’Amico

Elisa J. D’Amico, Esq.

Florida Bar No. 76936

elisa.damico@klgates.com

Mallory Cooney, FL Bar No. 0125659 

mallory.cooney@klgates.com

K&L GATES LLP 

Southeast Financial Center 

200 S. Biscayne Boulevard, Suite 3900 

Miami, Florida 33131-2399 

Tel.: 305-539-3300 

Facsimile: 305-358-7095

/s/ Katherine L. Sunstrom

Charles Lee Mudd, Jr., Esq. 

Graham Deurance

Katherine L. Sunstrom

Pro Hac Vice

clm@muddlaw.com

katie@muddlaw.com

graham@muddlaw.com

MUDD LAW

Case 0:20-cv-61023-RAR Document 75 Entered on FLSD Docket 05/14/2021 Page 2 of 3
309745092.1 

3

411 S. Sangamon Street, Suite 1B 

Chicago, Illinois 60607 

Telephone: 312-964-5051

Counsel for Plaintiffs Matthew Buckley 

And Top Gun Options, LLC

CERTIFICATE OF GOOD FAITH CONFERRAL

Undersigned counsel hereby certifies that counsel for the movant has conferred with all 

parties or non-parties who may be affected by the relief sought in this motion in a good faith effort 

to resolve the issues raised in the motion and states that they have been unable to reach a resolution.

CERTIFICATION PURSUANT TO LOCAL RULE 7.1(d)

After reviewing the facts and researching applicable legal principles, I certify that this 

motion in fact presents a true emergency (as opposed to a matter that may need only expedited 

treatment) and requires an immediate ruling because the Court would not be able to provide 

meaningful relief to a critical, non-routine issue after the expiration of seven days. I understand 

that an unwarranted certification may lead to sanctions.

/s/ Katherine L. Sunstrom

Katherine L. Sunstrom 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 14, 2020, a true and complete copy of the foregoing 

was electronically filed via CM/ECF system which will send a notice of electronic filing to all 

Counsel of Record.

/s/Elisa D’Amico

Elisa J. D’Amico

Case 0:20-cv-61023-RAR Document 75 Entered on FLSD Docket 05/14/2021 Page 3 of 3