129192422 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-cv-22307-BLOOM/Otazo-Reyes

MARIA FERNANDA SOTO LEIGUE, 

individually and on behalf of all others similarly 

situated, 

Plaintiff, 

v.

EVERGLADES COLLEGE, INC. d/b/a 

KEISER UNIVERSITY, 

Defendant. 

__________________________________/

DEFENDANT EVERGLADES COLLEGE, INC. D/B/A KEISER UNIVERSITY’S

NOTICE OF PENDING, REFILED, RELATED OR SIMILAR ACTIONS 

Defendant Everglades College, Inc. d/b/a Keiser University (“Defendant”), by and through 

its undersigned counsel, and pursuant to Rule 3.8 of the Local Rules of the United States District 

Court for the Southern District of Florida, hereby provides notice of a similar action in this District 

styled Maria Fernanda Soto Leigue, individually and on behalf of all others similarly situated v. 

Everglades College, Inc. d/b/a Keiser University, Case No. 1:21-cv-24267-KMW that was pending 

before the Honorable Kathleen M. Williams, and which Plaintiff Maria Fernanda Soto Leigue 

(“Plaintiff”) voluntarily dismissed on April 27, 2022 (the “Prior Action”). 

The Instant Action and the Prior Action are similar for the following reasons: 

1. The Instant Action and the Prior Action involve the identical parties and the same

counsel; 

2. In both actions, Plaintiff asserts claims pursuant to the Florida Telephone Solicitation 

Act, Fla. Stat. § 501.059; 

Case 1:22-cv-22307-BB Document 4 Entered on FLSD Docket 07/25/2022 Page 1 of 3
2 

129192422 

3. Count II of the Complaint in the Instant Action (Instant Action, ECF No. 1) is identical 

to Count I of the First Amended Complaint in the Prior Action (Prior Action, ECF No. 

13); and

4. Defendant’s Motion to Dismiss Plaintiff’s First Amended Class Action Complaint 

(Prior Action, ECF No. 17) was pending and fully briefed at the time of Plaintiff’s 

voluntary dismissal of the Prior Action. 

The Instant Action therefore involves subject matter that is identical to the Prior Action. 

Pursuant to Rule IOP 2.15.00 of the Internal Operating Procedures of the United States District 

Court for the Southern District of Florida, Defendant respectfully submits that transferring the 

instant action to the Honorable Kathleen M. Williams, who presided over the Prior Action, would 

avoid “the unnecessary duplication of judicial labor.” 

Respectfully submitted,

DATED: July 25, 2022

By: /s/ Maria K. Vigilante

 Maria K. Vigilante (Florida Bar No. 98822)

 Maria.Vigilante@blankrome.com

 BLANK ROME LLP

Broward Financial Centre

500 East Broward Boulevard, Suite 2100 

Fort Lauderdale, FL 33394 

Tel.: 954.512.1800 

Fax: 813.433.5564 

Justin C. Sorel (Florida Bar No. 0016256) 

 Justin.Sorel@csklegal.com 

 COLE, SCOTT & KISSANE, P.A. 

 Esperante Building 

222 Lakeview Avenue, Suite 120 

West Palm Beach, FL 33401

Tel.: 561.383.9200 

Fax: 561.683.8977

Attorneys for Defendant

EVERGLADES COLLEGE, INC.

Case 1:22-cv-22307-BB Document 4 Entered on FLSD Docket 07/25/2022 Page 2 of 3
3 

129192422 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically filed 

on July 25, 2022, with the Clerk of the Court by using the CM/ECF System. I also certify that the 

foregoing document is being served this day on all counsel of record via transmission of the Notice 

of Electronic Filing generated by CM/ECF. 

/s/ Maria K. Vigilante 

Maria K. Vigilante

Case 1:22-cv-22307-BB Document 4 Entered on FLSD Docket 07/25/2022 Page 3 of 3