135 San Lorenzo Avenue, Suite 770, Coral Gables, Florida 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-22787-SCOLA/GOODMAN

LIORA SAMANDAROVA,

Plaintiff,

vs.

HOOKAH EXOTIX LLC,

JEAN-CHRISTOPHE PITTMAN, 

AND ALEXANDRE ARKHIPOV,

Defendants.

______________________________/

PLAINTIFF’S INTERIM STATUS REPORT

Plaintiff, Liora Samandarova, files her Interim Status Report pursuant to the Court’s 

Scheduling Order and Order of Referral to Mediation [ECF No. 13], as follows:

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

No. Plaintiff served Defendant, Alexandre Arkhipov, but was unable to serve Defendants, 

Hookah Exotix, LLC or Jean-Christophe Pittman. Mr. Pittman has been concealing his 

whereabouts, and Hookah Exotix, LLC, failed to have a registered agent available for service.

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

No. Only Defendant, Alexander Arkhipov, responded to the Complaint. The other 

Defendants were not served and so have not responded to it.

Case 1:22-cv-22787-RNS Document 23 Entered on FLSD Docket 01/19/2023 Page 1 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, Florida 33146

TEL 305.230.4884 FAX 305.230.4844

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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?

N/A.

d) Have the parties agreed on and selected a mediator? Have the parties agreed 

upon a place, date, and time for mediation?

Plaintiff emailed to propose a mediator but did not receive a response from Mr. Arkhipov.

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.

No.

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.

Plaintiff has not yet served discovery due to Mr. Arkhipov’s failure to comply with the 

Court’s Orders. Plaintiff intends to serve discovery, if necessary and intends to complete discovery 

prior to Court’s deadline so long as Mr. Arkhipov timely responds and cooperates.

Case 1:22-cv-22787-RNS Document 23 Entered on FLSD Docket 01/19/2023 Page 2 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, Florida 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

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.

The Court should be aware that Mr. Arkhipov has not complied with several of the Court’s 

Orders, most recently ECF No. 20, and so Plaintiff anticipates that the progression of this case may 

be difficult based on the pro se defense and failure to comply with deadlines.

Dated this 19th day of January 2023.

s/Brian H. Pollock, Esq.

Brian H. Pollock, Esq.

Fla. Bar No. 174742

brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Counsel for Plaintiff

Case 1:22-cv-22787-RNS Document 23 Entered on FLSD Docket 01/19/2023 Page 3 of 3