UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 20-23230-CIV-CANNON/Otazo-Reyes

ANGELA MILNER, et al.,

Plaintiffs,

vs.

TERI GALARDI,

Defendant.

______________________________________/

DEFENDANT’S SECOND MOTION FOR SANCTIONS AND INCORPORATED 

MEMORANDUM OF LAW

The Defendant, TERI GALRDI, by and through undersigned counsel files this her 

Second Motion For Sanctions and Incorporated Memorandum of Law and states as 

follows:

1. At the request of the Plaintiffs’, the mediation in this case was reset for 

May 20th, 2021 at 10:30 am before Neil Flaxman, Esq. (DE 54).

2. On May 20th, 2021 none of the Plaintiffs’ attended the mediation in 

violation of the Court’s Order and the Court’s rules. (DE 56).1

3. The Court then entered an Order on June 26th, 2021 rescheduling the 

mediation in front of Bruce Blitman, Esq. to take place on August 19th, 

2021 via zoom. (DE 91).

4. On August 19th, 2021, Plaintiffs’ Jocelyn Johnson, Shakir Williams and

Jammie Parker did not appear for mediation. (DE 101,102). 

5. Simultaneously herewith the Defendant has filed a Motion For An 

Extension of Time to Extend the Discovery Deadline Out of Time and to 

Extend the Dispositive Motion Deadline. (DE 105).

 1 See also Defendant’s Supplement To Her Motion for Sanctions and Incorporated 

Memorandum of Law, which has yet to be ruled on by the Court. (DE 58)

Case 1:20-cv-23230-AMC Document 106 Entered on FLSD Docket 09/02/2021 Page 1 of 3
6. The Plaintiffs’ Jocelyn Johnson, Shakir Williams, Tiffany Thompson and 

Angela Milner failed to appear at their duly noticed and agreed to 

depositions.

7. The history of these four Plaintiffs’ depositions being rescheduled at the 

request of the Plaintiffs’ leading up to their recent non-appearance at the 

depositions is codified in the Defendant’s Motion To Extend the 

Discovery Deadline Out of Time And To Extend The Dispositive Motion 

Deadline at paragraphs # 1 through 17. (DE 105).

8. Plaintiffs’ Tiffany Thompson, Angela Milner, Shakir Williams and 

Jocelyn Johnson have offered to make themselves available for deposition 

regardless of whether the Court extends the deadlines pursuant to the 

Defendant’s Unopposed Motion To Extend The Discovery Deadline Out 

of Time (DE 105) as opposed to the request of the Defendant to dismiss 

these Plaintiffs’ cases. 

9. Based upon the foregoing, the Defendant is seeking sanctions as follows:2

a. Dismissing the cases of Plaintiffs’ Jocelyn Johnson, Shakir 

Williams and Jammie Parker for their failure to attend the duly 

scheduled and noticed mediation pursuant to this Court’s Order 

which mediation took place on Thursday August 19th, 2021 at 

10:00 am.

b. The Defendant is also seeking the dismissal of the Plaintiffs’ 

Jocelyn Johnson, Shakir Williams, Tiffany Thompson and Angela 

Milner’s cases for their failure to appear at their duly noticed and 

agreed to depositions. 

WHEREFORE, and for all of the foregoing reasons the Defendant seeks the dismissal of 

the Plaintiffs’ cases as alleged herein along with an award of attorney’s fees for having to 

prepare, file and attend a hearing on the instant motion along with any other relief that the 

Court deems just and proper. 

 2 It should also be pointed out here that Plaintiffs’ Jocelyn Johnson and Shakir Williams 

did not appear for mediation or deposition. 

Case 1:20-cv-23230-AMC Document 106 Entered on FLSD Docket 09/02/2021 Page 2 of 3
CERTIFICATE OF GOOD FAITH CONFERENCE; CONFERRED BUT 

UNABLE TO RESOLVE ISSUES PRESENTED IN THE MOTION 

Pursuant to Local Rule 7.1(a)(3)(A), I hereby certify 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 but has been unable to resolve the 

issues.

_/s/ Gerald J. Tobin

Attorney Name 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 2nd day of September, 2021, I electronically 

filed the foregoing document via CM/ECF. I also certify that the foregoing document is 

being served this day on all counsel of record listed in the Service List below via 

transmission of Notice of Electronic Filing generated by CM/ECF.

GERALD J. TOBIN, ESQ.

4551 Ponce de Leon Blvd. 

Coral Gables, Florida 33146

305-858-9020 Tel

305-858-6097 Fax

geraldtobinpa@aol.com

/s/ GERALD J. TOBIN

GERALD J. TOBIN, ESQ. 

F.B.N 81536

Counsel for the Defendant

SERVICE LIST

Astrid E. Gabbe, Esq.

The Law Office of Astrid E. Gabbe, P.A. 

P.O. Box 4216

Hollywood, FL, 33083

954-303-9882

Fax: 954-983-1427

Email: astridgabbe@gmail.com

Email: astridgabbe@aol.com 

Counsel for the Plaintiffs 

Ainsworth Dudley, Esq.

4200 Northside Parkway

Building 1, Suite 200

Atlanta, GA 30327

404-687-8205 Tel

Email:adudleylaw@gmail.com

Counsel for The Plaintiffs

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