LOTT & FISCHER, PL • 255 Aragon Avenue • Third Floor • Coral Gables, FL 33134

Telephone: (305) 448-7089 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-22885-WILLIAMS/TORRES

PAYCARGO, LLC,

 Plaintiff,

vs

PAVEL GALBREATH, WALE UP LLC, 

AND CARGOSPRINT LLC

Defendants.

_____________________________________/

DEFENDANT CARGOSPRINT LLC’S NOTICE OF COMPLIANCE WITH STANDING

ORDER ON DISCOVERY PROCEDURES

Defendants CargoSprint LLC (“CargoSprint), by and through its undersigned counsel, hereby 

gives notice of compliance with this Court’s Standing Order on Discovery Procedures and states

as follows:

1) CargoSprint served its First Set of Requests for Production (“Requests for Production”) 

and First Set of Interrogatories (“First Set of Interrogatories” or “Interrogatories”) on 

Plaintiff on April 16, 2021.

2) On May 17, 2021, both parties agreed to extend the deadline for responses and objections 

to the Requests for Production and First Set of Interrogatories from May 17, 2021 to May 

27, 2021. 

3) Plaintiff submitted its objections on May 28, 2021 after the agreed-upon deadline had 

passed.

4) In attempt to comply with S.D. Fla. L.R. 7.1(a)(3) and 26.1(g), CargoSprint provided 

Case 1:20-cv-22885-KMW Document 134 Entered on FLSD Docket 07/13/2021 Page 1 of 3
CASE NO. 1:20-CV-22885-WILLIAMS/TORRES

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LOTT & FISCHER, PL • 255 Aragon Avenue • Third Floor • Coral Gables, FL 33134

Telephone: (305) 448-7089 • Facsimile: (305) 446-6191 

Plaintiff with a detailed letter regarding the deficiencies in Plaintiff’s responses to the First 

Set of Interrogatories and Requests for Production on June 28, 2021.

5) Since that date, CargoSprint has made multiple attempts to discuss the issues disclosed in 

CargoSprint’s letter, but have not been able to schedule due to a close call with Covid-19 

by Plaintiff’s Counsel as well as scheduling issues with Plaintiff. 

6) At present, all responses from Plaintiff to both the First Set of Interrogatories and Requests 

for Production are considered insufficient due to the failure of Plaintiff to timely respond.

7) Additionally, CargoSprint has specific objections to Plaintiff’s responses to Interrogatories 

1-4 and Requests for Production 3, 5-18, 20-30, 32-36, and 42. 

8) Both Parties will continue to make efforts to narrow, and hopefully eliminate, all disputes 

before the date of the hearing and will update this Court appropriately. 

CERTIFICATE OF CONFERRAL

 The undersigned counsel hereby certifies that, as required by Local Rule 7.1(a)(3), he has 

conferred with Plaintiff and made a good-faith effort to resolve by agreement the issues raised 

herein, but was not able to agree on a resolution. He has provided a detailed letter regarding the 

issues on June 28, 2021 and attempted to schedule a time to resolve the issues on July 6, July 8, 

and July 13, 2021, but opposing counsel has yet to agree to a time to discuss the issues and attempt 

a resolution. We continue with our conferral efforts. 

[signature on following page]

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CASE NO. 1:20-CV-22885-WILLIAMS/TORRES

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LOTT & FISCHER, PL • 255 Aragon Avenue • Third Floor • Coral Gables, FL 33134

Telephone: (305) 448-7089 • Facsimile: (305) 446-6191 

Date: July 13, 2021 Respectfully submitted,

LOTT & FISCHER PL

Dylan H. Smith

Ury Fischer

Florida Bar No. 048534

E-mail: ufischer@lottfischer.com

Noah H. Rashkind

Florida Bar No. 021945

E-mail: nrashkind@lottfischer.com

Giulia C. Farrior

Florida Bar No. 1011300

E-mail: gfarrior@lottfischer.com

Dylan H. Smith

Florida Bar No. 113122

E-mail: dsmith@lottfischer.com 

255 Aragon Avenue, Third Floor

Coral Gables, FL 33134

Telephone: (305) 448-7089

Attorneys for Defendant CargoSprint LLC 

Case 1:20-cv-22885-KMW Document 134 Entered on FLSD Docket 07/13/2021 Page 3 of 3