−−

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 20-cv-21984-DPG

AARON SILBERMAN, an individual, and

AMJ MISIL AB LLC, a Florida limited liability

company,

Plaintiffs,

vs. 

PREMIER BEAUTY AND HEALTH LLC, a

Florida limited liability company, JORGE HANE,

an individual, and FLORENCIA HANE, an

individual, jointly and severally,

Defendants.

 /

DEFENDANTS’ NOTICE OF RESPONSE WITH RESPECT TO PLAINTIFFS’ NOTICE 

[DE 338) RE: ORDER [DE 315]

Defendants, PREMIER BEAUTY AND HEALTH LLC, JORGE HANE AND 

FLORENCIA HANE, by and through undersigned counsel, file this Notice of Response to 

Plaintiffs’ Notice [DE 338] Re: Order [DE 315], as follows:

1. Plaintiffs have filed yet another motion, wasting this Court’s time, complaining that 

Defendants failed to file its witness and exhibit lists on or before May 11, 2023 (before the Daubert 

hearing) (when the Plaintiffs filed their exhibit and witness list just 11 minutes prior to the 

aforesaid hearing). 

2. Plaintiffs fail to acknowledge that (based upon Plaintiffs’ request), the trial in this 

matter is now set for October 10, 2023 (see DE 332). That order mandates that the due date for the 

Case 1:20-cv-21984-DPG Document 339 Entered on FLSD Docket 05/12/2023 Page 1 of 3
−−

filing of the pretrial stipulation is to be on September 1, 2023.

3. While Plaintiffs cite to the Order [DE 315], it is ultimately unclear how that portion 

of the Order is effected by the subsequent rescheduling of the trial and certainly the exhibit list is 

part of the pretrial stipulation.

4. Further, Plaintiffs claim without any support that somehow it is prejudiced by 

Defendants’ failure to provide an exhibit and witness list, when Defendants filed a witness list on 

December 2, 2021. [DE 132]. 

5. Finally, Plaintiffs’ motion should be denied simply because Plaintiffs’ motion does 

not contain a meet and confer certificate as mandated by LR 7.1(c). 

WHEREFORE for the reasons set froth herein, Defendants ask this Court to deny 

Plaintiffs’ motion. 

CERTIFICATE OF SERVICE

I hereby certify that on May 12, 2023, I electronically filed the foregoing document with 

the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served 

this day on all counsel of record identified on the attached Service List in the manner specified, 

either via transmission of Notice of Electronic Filing generated by CM/ECF or in some other 

authorized manner for those counsel or parties who are not authorized to receive electronically 

Notice of Electronic Filing.

WOLFE LAW MIAMI PA

 175 SW 7th Street, Suite 2410

Miami, Florida 33130

P: 305.384.7370

F: 305.384.7371

Case 1:20-cv-21984-DPG Document 339 Entered on FLSD Docket 05/12/2023 Page 2 of 3
−−

Email: rwolfe@wolfelawmiami.com 

By: /s/ Richard C. Wolfe __

 Richard C. Wolfe, Esq.

 Florida Bar No.: 355607

Kozyak Tropin &Throckmorton

2525 Ponce De Leon Blvd, Suite 900

Coral Gables, FL 33134 

Email: jal@kttlaw.com

By: s/Javier A. Lopez_____

Javier A. Lopez, Esq. 

Florida Bar No. 16727 

Attorneys for Defendants

SERVICE LIST

Alexander Flint, Esq.

G & F Law Group, LLP

221 W. Hallandale Beach Blvd.

Suite 209

Hallandale Beach, FL 33009

acf@gflawgroup.com

Ariel Rapaport, Esq.

15807 Biscayne Blvd.

Suite 217

North Miami Beach, FL 33160

arap@gflawgroup.com

Irain Alberto Gonzalez, Esq.

Gosz & Gonzalez, PL

2250 SW 3rd Avenue

Suite 500

Miami, FL 33129

iag@gflawgroup.com

Case 1:20-cv-21984-DPG Document 339 Entered on FLSD Docket 05/12/2023 Page 3 of 3