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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

MATTHEW BUCKLEY and

TOP GUN OPTIONS, LLC,

Plaintiffs,

v.

EMMETT MOORE and 

TRADINGSCHOOLS.ORG,

 Defendants.

 /

DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ EMERGENCY MOTION FOR STATUS 

CONFERENCE

Defendants Emmett Moore and Tradingschools.org (“Defendants”), by and through their 

counsel of record submit the following opposition to Plaintiffs’ Emergency Motion for a Status 

Conference. (“Plaintiffs’ Motion”)

The genesis of Plaintiffs’ Motion is due to the fact that Susanne Arani, Esq., counsel for 

Defendants submitted a proposed draft of a motion that seeks to file a subsequent motion under 

seal. Plaintiffs and Defendants are currently meeting and conferring on the language, objected to 

by Plaintiffs, and the motion to file under seal will not occur unless and until there is an impasse 

between the parties on its contents.

Regardless, the proposed draft motion under seal seeks court intervention in to the 

following 1) the relationship between the Mudd Law Office and Plaintiff Mr. Buckley for potential 

abuse of process, and 2) a similar inquiry into the Mudd Law Offices handling of key witnesses in 

this case that may or may not arise to “witness tampering.” Again, no motion to file under seal 

will take place, given Plaintiffs’ concerns regarding the language in the draft that was sent to them.

Counsel for Plaintiffs have stated they will depose Ms. Susanne Arani, Esq. (counsel for 

Defendants) by way of email on or about May 13, 2021, prior to the service of the draft motion for 

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seal. This, in almost any regard, would be improper, privileged and a form of harassment due to

Defendants filing their Bond Motion. More so, this threat of deposition against defense counsel 

occurred after Defendants amended their Rule 26 disclosure to include two arresting officers who 

have recently arrested Plaintiff Mr. Buckley on serious charge.

Plaintiffs have sought sanctions, without any authority that can be discerned in their 

opposition to Defendants’ Bond Motion, filed on or about April 25, 2021 in this case. It seems as 

though they seek sanctions against counsel for defendants for publishing either 1) previously filed 

transcripts in the public realm, 2) Plaintiffs’ online statements on social media, and/or 3) transcript 

testimony from open court. Defendants will address these arguments in its reply brief, but states 

here, no impropriety has taken place. 

Plaintiffs’ Motion alleges that Defendants have served irrelevant discovery. Prior to or at 

any hearing, Defendants will submit a declaration that at no time have Plaintiffs met and conferred 

with counsel about any discovery that is allegedly not relevant. If they had, counsel would 

immediately respond in kind, as the parties have been doing throughout the discovery process.

Plaintiffs’ Motion states the Bond Motion currently on file is frivolous. For the reasons set 

forth in Defendants’ Bond Motion and anticipated reply, Defendants assert that its motion is far 

from frivolous, and looks forward to the ruling in the near future.

Defendants have never filed a motion for sanctions against Plaintiffs, unlike Plaintiffs’ 

counsel. Counsel did serve a Rule 11 motion based on statements made in the complaint that the 

Defense had proof were not true. Presumably realizing their error, it was Plaintiffs’ counsel who 

agreed to amend their complaint to remove the disputed statements.

For these reasons, Defendants object to the characterizations in Plaintiffs’ Motion, and do 

not see the need at this time to consume this Court’s resources with Plaintiffs’ imaginary claims 

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and future claims against Defendant or their counsel, prior to even a motion to file under seal being 

submitted to this Court.

Dated: May 15, 2021 __/s/ Susanne Arani_____

Susanne Arani, Esq.

Admitted Pro Hac Vice

California Bar No.: 238891

Arani Law

1028 Rosario Lane

Vista, California 92084

Tel.: (760) 331-8426

Email: susarani@gmail.com

Attorneys for Defendants Emmett Moore and 

Tradingschools.org

_/s/Matthew Fornaro_______________

Matthew Fornaro, Esq.

Matthew Fornaro, P.A.

Florida Bar No.: 0650641

mfornaro@fornarolegal.com

11555 Heron Bay Blvd., Ste. 200

Coral Springs, FL 33076

Tel.: (924) 324-3651

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CERTIFICATE OF SERVICE

I hereby certify that on May 15, 2021, I served Plaintiffs’ counsel of record on the below 

service list by electronic mail or e-mail service the document described as Defendants 

Opposition to Plaintiffs’ Motion for an Emergency Order. 

Service List

Graham Deurance graham@muddlaw.com

Katherine Sunstrom ksunstrom@muddlawoffices.com

Charles Mudd clm@muddlaw.com

Mallory Cooney Mallory.cooney@klgates.com

Elisa D’Amico elisa.damico@klgates.com

By: _/s/Matthew Fornaro___

Matthew Fornaro

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