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LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

STATUS REPORT

Plaintiffs Pamela Titus, Joseph Amodio, William Vilcina, Jacqueline Fontanez, Paul Jones,

Byron Hall, and Damien Day (collectively, the “Plaintiffs”) submit this Status Report and state:

1. On December 08, 2020, Plaintiffs and Defendants (collectively, the “Parties”) 

appeared before this Court to conduct status conference and, as per said status conference, the 

Parties were to confer regarding the matters discussed before this Court on December 08, 2020, 

and, thereafter, submit a status report regarding the outcome of said conferral no later than 

December 11, 2020. See D.E. 54 (PAPERLESS Minute Entry for proceedings held before Judge 

Roy K. Altman: Status Conference held on 12/8/2020). 

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LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

2. On December 10, 2020, at 2:00 pm, the Parties conferred telephonically and 

discussed possible ways to both resolve the discovery disputes had between the Parties, as well as 

foster or otherwise advance a resolution of this case. 

3. At the conclusion of the conferral, based on possible solutions offered by Plaintiffs 

and Defendants agreement therewith, Plaintiffs believed, in good faith, that the Parties had reached 

an understanding with respect underlying discovery dispute, whereby in order to simplify this 

consolidated action and attempt to resolve any outstanding discovery disputes had by Plaintiff, 

Plaintiffs were to conduct the depositions that Plaintiffs have been attempting to schedule since

August 27, 2020. 

4. As the Parties discussed on December 10, 2020, said depositions would allow 

Plaintiffs to verify facts and assertions that Defendants claim to be gospel – all without any formal 

affirmation or verification – despite the obvious concerns of assuming truth, especially in light of 

the fact that the FDCPA claims advanced by Plaintiffs are alleged to be result of Defendants 

filing false documents in Plaintiffs’ respective bankruptcy proceeding, whereby Defendants 

had signed such documents under penalty of perjury. 

5. Yet, now that it is time to report to this Court the collaborative breakthrough 

Plaintiffs believed the Parties secured as a result of the December 10th conferral, Defendants refuse

to join Plaintiffs in the submission of this Status Report, and instead, have asked that Plaintiffs 

falsely report to this Court that the Parties have resolved all discovery disputes at the December 

10th conferral. Given the extreme disparity between what the Parties actually discussed and how

Defendants would have a joint status report read, Plaintiffs submits this Status Report unilaterally. 

6. Nevertheless, despite what can only be described as a communication issue in the 

most generous light, the depositions set forth in the attached composite exhibit, of which Plaintiffs 

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LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

have been trying to schedule since August 27, 2020, will allow Plaintiffs to resolve most, if not 

all, factual disputes currently had by the Parties, or put differently, will allow this case to be 

resolved in the most expeditious, cost-effective, and otherwise proper way possible – an outcome 

which Defendants outright oppose for unspecified reasons. 

Dated: December 11, 2020

Respectfully Submitted,

 /s/ Thomas J. Patti . 

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on December 11, 2020, the foregoing was

electronically filed with the Clerk of the Court using the CM/ECF system which will send a

notice of electronic filing to all counsel of record.

 /s/ Thomas J. Patti 

.

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

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