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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Civil Case No.: 1:22-cv-22972-RNS/GOODMAN 

CURTIS J. JACKSON, III p/k/a 50 CENT, 

Plaintiff, 

 v. 

ANGELA KOGAN, PERFECTION PLASTIC 

SURGERY, INC. d/b/a PERFECTION PLASTIC 

SURGERY & MEDSPA, and THE SHADE 

ROOM, LLC d/b/a THE SHADE ROOM, 

Defendants. 

________________________________________/ 

INTERIM JOINT STATUS REPORT 

Pursuant to the Court's Scheduling Order and Order of Referral to Mediation (Dkt. 24), 

Plaintiff Curtis J. Jackson, III p/k/a 50 Cent ("Jackson") and Defendants Angela Kogan ("Kogan") 

and Perfection Plastic Surgery, Inc. d/b/a Perfection Plastic Surgery & MedSpa ("MedSpa") 

hereby submit the following Interim Joint Status Report: 

A. Have all defendants been served? If not, state the reasons. 

Jackson filed the Complaint against Kogan and MedSpa on September 16, 2022 (Dkt. 1), 

and Kogan was served on September 22, 2022 (Dkt. 14) and MedSpa was served on September 

21, 2022 (Dkt. 15). Jackson subsequently filed the First Amended Complaint on January 16, 2023 

(Dkt. 29), and added The Shade Room, LLC d/b/a The Shade Room ("TSR") as an additional 

defendant. TSR was served today, January 19, 2023. 

B. Have all defendants responded to the complaint? If not, state the reasons. 

No defendants have responded to the First Amended Complaint because Kogan and 

MedSpa's response is due on January 30, 2023 and TSR's response is due on February 9, 2023. 

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C. If this is a class action, has a motion for class certification been filed? If so, 

what is its status? 

This case is not a class action. 

D. Have the parties agreed on and selected a mediator? Have the parties agreed 

upon a place, date, and time for mediation? 

Before the First Amended Complaint was filed and TSR was added as a defendant, 

Jackson, Kogan, and MedSpa agreed to mediation before Mark E. Stein, Esq. on February 28, 

2023 at 10:00 a.m. by video conference. Because TSR was served today, TSR has not been 

consulted as to its availability for the mediation conference. Jackson's counsel, however, will 

promptly reach out to TSR's counsel regarding the mediation conference. 

E. Have the parties engaged in informal settlement negotiations? If not, explain 

the reasons for the failure to do so. If yes, state the status of such negotiations 

(e.g., ongoing, impasse, etc.) and the relative prospects for resolution through 

informal means. 

The parties have engaged in informal settlement negotiations, but the negotiations remain 

at an impasse and resolution through informal means is unlikely. 

F. Describe the status of discovery conducted to date, and identify whether the 

parties reasonably believe that they will be able to complete discovery by the 

Court's deadline. If not, explain the reasons. 

To date, the following discovery has been conducted: (i) Jackson, Kogan, and MedSpa 

exchanged initial disclosures on November 15, 2022; (ii) Jackson served requests for production 

and interrogatories on Kogan and MedSpa on November 28, 2022, and Kogan and MedSpa 

responded to those discovery requests on January 9, 2023; (iii) MedSpa served requests for 

production and interrogatories on Jackson on January 12, 2023, and Jackson's responses are 

currently due on February 13, 2023; (iv) Jackson's deposition is scheduled for February 21, 2023; 

and (v) Jackson is waiting for Kogan's counsel to confirm Kogan's availability to be deposed. 

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Additionally, before TSR was added as a defendant, Jackson served a document subpoena 

on TSR on December 2, 2022 and a deposition subpoena on TSR on December 15, 2022. TSR 

served written objections and responses to the document subpoena, stating that it would produce 

documents, but to date, TSR has not produced any documents. TSR, however, failed to serve 

written objections and responses or produce a witness in response to the deposition subpoena. 

Jackson, Kogan, and MedSpa have been diligent in conducting discovery, but the filing of 

the First Amended Complaint and addition of TSR as a defendant means that the parties may not 

be able to complete fact discovery by the Court's current deadline—February 23, 2023. 

G. Identify any other issues that the Court should be aware of that may affect the 

resolution of this matter or the schedule as currently set. 

As addressed in Section F, the filing of the First Amended Complaint and addition of TSR 

as a defendant may affect the schedule as currently set. 

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Dated: January 19, 2023 

Respectfully submitted, 

AKERMAN LLP 

 /s/ Eamon O’Kelly 

Joseph Rebak, Esq. 

Florida Bar No. 308668 

Alejandro J. Paz, Esq. 

Florida Bar No. 1011728 

Three Brickell City Centre 

98 Southeast Seventh Street, Suite 1100 

Miami, Florida 33131 

Tel.: (305) 374-5600 

Fax: (305) 374-5095 

joseph.rebak@akerman.com 

alejandro.paz@akerman.com 

Craig Weiner, Esq. (pro hac vice) 

Eamon O'Kelly, Esq. (pro hac vice) 

Reena Jain, Esq. (pro hac vice) 

1251 Avenue of the Americas, 37th Floor 

New York, New York 10020 

Tel.: (212) 880-3800 

Fax: (212) 880-8965 

craig.weiner@akerman.com 

eamon.okelly@akerman.com 

reena.jain@akerman.com 

Attorneys for Plaintiff Curtis Jackson, III p/k/a 

50 Cent

HEITNER LEGAL, P.L.L.C. 

 /s/ Darren A. Heitner 

Darren A. Heitner, Esq. 

Florida Bar No. 85956 

215 Hendricks Isle 

Fort Lauderdale, FL 33301 

Tel.: (954) 558-6999 

Fax: (954) 927-3333 

darren@heitnerlegal.com 

Attorneys for Defendants Angela Kogan and 

Perfection Plastic Surgery, Inc. d/b/a 

Perfection Plastic Surgery & MedSpa 

CERTIFICATE OF SERVICE 

I hereby certify that on this 19th day of January 2023, a true and correct copy of the 

foregoing motion was served via the Court's CM/ECF System upon all counsel of record. 

/s/ Alejandro J. Paz

Alejandro J. Paz 

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