UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated,

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al.,

Defendants.

/

PLAINTIFFS’ RESPONSE TO ORDER TO SHOW CAUSE [ECF NO. 90]

Plaintiffs respectfully file this response to the Court’s Order to Show Cause why Naomi 

Osaka and Shaquille O’Neal should not be dismissed for failure to serve. ECF No. 90. 

It is hard to plausibly state that any of the Defendants sued in this action have not had actual 

knowledge of the allegations against them since it was filed. News of this lawsuit, filed closely on 

the heels of the collapse of FTX—the largest financial debacle in history—has been disseminated 

through nearly every conceivable source of news, be it on television, the internet, or otherwise. 

Dozens of articles published globally and nationwide specifically call out Defendants O’Neal and 

Osaka by name.

1 Defendant O’Neal, as set forth below, publicly acknowledged his actual notice 

1 See, e.g., “Shaq, Naomi Osaka, Steph Curry named as defendants in class-action suit against 

embattled crypto company FTX,” published November 17, 2022, at 

https://www.yahoo.com/video/shaq-naomi-osaka-steph-curry-164000087.html (accessed March 

10, 2023); “Naomi Osaka among those being sued as company she endorsed collapses,” published 

November 17, 2022, at https://www.express.co.uk/sport/tennis/1697980/Naomi-Osaka-suedcompany-endorsed-collapses-tennis-news (accessed March 10, 2023); “FTX Investors Sue 

Shaquille O’Neal, Naomi Osaka, Steph Curry,” published November 28, 2022, at 

https://peopleofcolorintech.com/articles/ftx-investors-sue-shaquille-oneal-naomi-osaka-stephcurry/ (accessed March 10, 2023); “Brady, Curry, Shaq Among Athletes Facing Lawsuit in FTX 

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of this suit shortly after it was filed. Many Defendants chose to have their counsel proactively 

reach out to participate in this litigation, such as counsel for Defendants Bankman-Fried, Brady, 

Bundchen, Ortiz, David, the Golden State Warriors, and Lawrence. Others have, unfortunately, 

not come forward.

Despite Plaintiffs’ diligent efforts to effect service on all 18 Defendants within the deadline 

mandated through Rule 4 of the Federal Rules of Civil Procedure, which, as explained below, 

appears to run at different times between different parties in this action, Plaintiffs respectfully 

submit that more time is needed to complete service on Defendants. Plaintiffs respectfully request 

that, rather than dismiss Defendants Osaka and O’Neal, that this Court grant an extension of time 

for them to effect service on them. 

A. Naomi Osaka

The process server initially followed the results of a skip trace to locate the most recent 

personal address of Naomi Osaka in order to attempt to effect timely service of process, but after 

seven failed service attempts at this address, the process server was informed on the eighth attempt 

that Defendant Osaka had sold the property. See Exhibit A. The process server researched different 

avenues to attempt to reach Defendant Osaka or to otherwise locate her whereabouts, including 

reaching out to agents who may have Defendant Osaka as a client. See Exhibit B. The process 

server spoke with Cary at Ground Control Business Management, who confirmed that Defendant 

Osaka is their client, but they are not lawyers, and advised they would have her counsel or agent 

contact her. Id. Later that day, the process server received a call from Defendant Osaka’s attorney, 

David E. Fink of Venable LLP. Id. He informed the process server that Osaka had moved, that her 

Debacle,” published November 16, 2022, at https://www.si.com/nfl/2022/11/16/brady-curry-shaqamong-athletes-facing-lawsuit-in-ftx-debacle (accessed March 10, 2023). 

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new property is gated and they would be unable to access it or otherwise get to her to serve her, 

and told her to stop trying to serve Defendant Osaka because he was authorized to accept service 

for her. Id. Plaintiffs’ Counsel then contacted Mr. Fink in this regard, who confirmed 

telephonically that “Yeah, you’ll never find her,” but that his firm represents her in this matter and 

he agreed to accept service; Plaintiffs’ counsel therefore sent the same day the Notice of 

Commencement of Action form, the Request for Waiver of Service form, and the operative 

Consolidated Amended Complaint, to avoid the necessity of sending formal service of process.

See Exhibit C.

On March 8, 2023, in response to Plaintiffs’ Counsel’s email scheduling the Joint 

Scheduling Conference, Mr. Fink—acknowledging that he and his firm do in fact represent 

Defendant Osaka in this Action—disclaimed the necessity for his appearance on her behalf at the 

Joint Scheduling Conference, stating “We have not yet accepted service, have not made any 

appearance in the case, and have not yet even determined who will be representing Ms. Osaka in 

this matter.”2 See Exhibit D. He continued that “[i]n light of the foregoing, please do not represent 

that you have ‘served’ our client until this has actually occurred.” Id. As a result, on March 10, 

2023, Plaintiffs formally served Attorney Fink with process as Defendant Osaka’s agent 

designated to accept service on her behalf. See Ex. B; see also Exhibit E.

2 This is contrary to the statement the Movant Defendants made in their motion, that Defendant 

Osaka has not selected counsel for this action. Rather, Attorney Fink communicated that he had 

not yet decided which attorneys from his firm would be staffing the defense of this case. 

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B. Shaquille O’Neal 

Shaquille O’Neal has demonstrably had actual notice of this action since at least December 

15, 2022, when CNBC published an article containing O’Neal’s comments during his interview 

with CNBC Make It that week regarding the allegations in this suit:3

“A lot of people think I’m involved, but I was just a paid spokesperson for a 

commercial,” O’Neal says.

. . . 

Today, O’Neal cites his friendship with Curry as a reason he consented to appear 

in the ad. A spokesperson for Curry declined to comment.

In the ad, O’Neal told viewers that he checked his FTX account daily. But when 

asked now if he’s bullish on crypto, he offers a simple response: “No.”

“People know I’m very, very honest,” O’Neal says. “I have nothing to hide. If I was 

heavily involved, I would be at the forefront saying, ‘Hey.’ But I was just a paid 

spokesperson.”

It’s unclear how much money O’Neal made from his FTX endorsement deal.

Despite O’Neal’s actual knowledge of this action for at least the last three months and his claim 

that he has “nothing to hide,” to date he has not allowed himself to be served with process, has not 

had counsel confirm that they will represent him in this action, or otherwise appeared in this action.

Shaquille O’Neal owns and has owned a large number of homes all across the country, 

from Florida and Georgia, to Texas, to Nevada and California.

4 Plaintiffs’ Counsel’s investigation

showed, however, that while Defendant O’Neal is regularly on the move between these locations

(making personal service of process more difficult than with an average American), he was likely 

3 See “Shaq distances himself from crypto and FTX collapse: ‘I was just a paid spokesperson,’” 

dated December 15, 2022, published at https://www.cnbc.com/2022/12/15/shaq-on-crypto-ftxpost-collapse-i-was-just-a-paid-spokesperson.html (accessed March 10, 2023).

4 https://www.realtor.com/news/celebrity-real-estate/every-home-shaquille-oneal-has-ownedpast-and-present/ (accessed March 10, 2023). 

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spending much of his time in Texas, based on reports that he “is expanding [his] Big Chicken 

franchise to Texas, and as a result, he has bought a house there to help facilitate the move.”5

The process servers made several service attempts at the most recent, last-known address 

listed for Defendant O’Neal in Texas. After learning that Defendant O’Neal sold his former 

Sugarland residence (apparently to his ex-wife, Arnetta Yardbourgh), Plaintiffs’ Counsel’s 

investigation showed that Defendant O’Neal recently purchased another home in Texas, but the 

address was not listed and did not show up in the process server’s skip trace. See Composite

Exhibit F. After combing through public records and reports of the purchase of the new home (all 

of which did not list the address of the property because (1) O’Neal did not purchase the home in 

his individual capacity and (2) the reports only stated his home was in “Carrollton, Texas” and 

gave the statistics for the home, such as the square footage and number of bedrooms or bathrooms), 

Plaintiffs’ Counsel finally located an article that gave away the full address of 4012 Sahara Court, 

Carrollton, Texas 75010.6 Since obtaining the address, the process server has made numerous 

attempts at effecting service on O’Neal at his Carrollton address and Plaintiffs’ Counsel have 

directed them to continue attempting service. See Comp. Ex. F.

At the same time, Plaintiffs’ Counsel have worked to determine whether there are any 

attorneys who represent or have previously represented Defendant O’Neal who either (1) intend 

to represent him, (2) will accept service on his behalf, or (3) would provide information to facilitate 

his service.

5 https://thesportsrush.com/nba-news-shaquille-oneal-has-a-new-1-22-million-home-in-northtexas-amid-big-chicken-restaurant-expansion-plans/ (accessed March 10, 2023). 

6 https://www.housedigest.com/913481/take-a-tour-of-shaquille-oneals-stunning-new-texashome/ (accessed March 10, 2023). 

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Plaintiffs’ counsel first reached out to Benjamine Reid, Clifton R. Gruhn, and Jeffrey A. 

Cohen, shareholders at the Miami office of Carlton Fields who recently represented Mr. O’Neal 

in many different litigation,

7 with Notice of Commencement and Request for Waiver of Service 

forms and a copy of the operative Amended Complaint. See Composite Exhibit G. They

disclaimed knowledge of O’Neal’s representation and declined to forward the materials to Mr. 

O’Neal. Id.

Then, Plaintiffs’ Counsel contacted Peter W. Ross and Eric C. Lauritsen of Ross LLP, who 

represented O’Neal as recently as two months ago,

8 with Notice of Commencement and Request 

for Waiver of Service forms and a copy of the operative Amended Complaint. See Exhibit H. On 

a phone call, attorney Lauritsen similarly disclaimed any personal knowledge of O’Neal’s 

representation or whereabouts. Mr. Ross’s response to Plaintiffs’ Counsel’s email is outstanding.

Finally, Plaintiffs’ Counsel contacted attorney Dennis Roach, who has apparently 

represented and worked with O’Neal in various matters for years.9 On a phone call, Mr. Roach 

confirmed that O’Neal was his client. When asked whether he represented him in this action or if 

he knew who did, he said to send him the information and he would “speak to the powers that be” 

to confirm and would “get back” to Plaintiffs’ Counsel. Plaintiffs’ Counsel followed up with an 

email with Notice of Commencement and Request for Waiver of Service forms and a copy of the 

7 https://www.law.com/dailybusinessreview/2021/05/13/slam-dunk-carlton-fields-lawyers-score413k-in-attorney-fees-for-shaquille-oneal/ (accessed March 10, 2023); see also 

https://www.abajournal.com/news/article/biglaw_lawyers_sanctioned_for_advising_shaquille_o

neal_he_didnt_need_to_att (accessed March 10, 2023). 

8 https://www.law360.com/articles/1570921/shaq-settles-suit-against-pot-co-allegingmismanaged-funds (accessed March 10, 2023). 

9 https://abcnews.go.com/Sports/shaq-lawyer-calls-incident-horseplay/story?id=23045999

(accessed March 10, 2023); https://www.prnewswire.com/news-releases/shaquille-oneal-unveilsall-star-board-of-directors-for-the-shaquille-oneal-foundation-301273421.html (accessed March 

10, 2023). 

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operative Amended Complaint. See Exhibit I. Mr. Ross’s response to Plaintiffs’ Counsel’s email 

is outstanding. 

In the interim, Plaintiffs’ Counsel continue their attempts to have Mr. O’Neal located and 

personally served, and are in the process of enlisting professional private investigators to aid in the 

search, to the extent necessary. 

ARGUMENT

As the Court makes clear in its Order to Show Cause, Federal Rule of Civil Procedure 4(m) 

provides that “[i]f a defendant is not served within 90 days after the complaint is filed, the court—

on motion or on its own after notice to the plaintiff—must dismiss the action without prejudice

against that defendant or order that service be made within a specified time. But if the plaintiff 

shows good cause for the failure, the court must extend the time for service for an appropriate 

period.” ECF No. 90 (quoting Fed. R. Civ. P. 4(m)). 

“Good cause exists ‘only when some outside factor[,] such as reliance on faulty advice,

rather than inadvertence or negligence, prevented service.” Id. (quoting Lepone-Dempsey v.

Carroll Cnty. Comm’rs, 476 F.3d 1277, 1281 (11th Cir. 2007) (alterations in original)). However, 

“[e]ven in the absence of good cause, a district court has the discretion to extend the time for 

service of process.” Id. (citing id.). Extensions based on a finding of good cause are mandatory, 

whereas the Court may exercise its discretion to extend the deadline under Rule 4(m) based on the 

factors listed in the advisory committee notes accompanying that rule. Id. (citing Hong-Diep Vu v. 

Phong Ho, 756 F. App’x 881, 882 (11th Cir. 2018)). These factors include whether the statute of 

limitations would bar a refiled action, if the applicable statute of limitations would bar the refiled 

action, or if the defendant is evading service or conceals a defect in attempted service. See 

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Horenkamp v. Van Winkle & Co., 402 F.3d 1129, 1132–33 (11th Cir. 2005) (quoting Fed. R. Civ. 

P. 4(m), Advisory Comm. Note, 1993 Amendments).

On the facts at issue here, Plaintiffs believe that good cause exists for a first extension of 

time to complete service of process on Defendants. For both Defendants O’Neal and Osaka, 

despite numerous service attempts, Plaintiffs’ process servers relied on faulty data, in large part 

because the new homes that both Defendants purchased were done so through LLCs in order to 

maintain their anonymity, and therefore did not initially show up when searched. Watts v. City of 

Miami, CV 15-21271-CIV, 2016 WL 8939143, at *2 (S.D. Fla. Feb. 22, 2016) (Scola, J.) (finding 

good cause to extend the deadline a second time for plaintiff to serve defendant where process 

server relied on faulty information regarding defendant’s work schedule and ultimately served 

defendant 20 days after the expiration of the first extension, and explaining that “[e]ven if the 

[p]laintiff’s documentation was insufficient to establish good cause, the Court would exercise its 

discretion to extend the deadline”) (citing Horenkamp, 402 F.3d at 1132–3; Fed. R. Civ. P. 4(m) 

advisory committee's notes to 1993 amendment (“Relief may be justified, for example ... if the 

defendant is evading service....”)). 

Once Plaintiffs and their process servers discovered the addresses were outdated, service 

was attempted at the new addresses. See In re Cutuli, 13 F.4th 1342, 1348 (11th Cir. 2021) (finding 

the “court acted within its considerable discretion to grant an extension of time regardless of 

whether there was good cause for [the] failure to serve on time” where the plaintiff was not “sitting 

on his hands between the initial service attempt and the grant of the extension”); see also AutoOwners Ins. Co. v. Traster, No. 616CV2051ORL41DCI, 2017 WL 10080181, at *2 (M.D. Fla. 

Apr. 5, 2017) (granting the plaintiff an extension of time to serve the defendant upon finding that 

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“Plaintiff has diligently attempted to serve Defendant” after searching for alternate addresses and 

means of service when first results were discovered to be erroneous).

Moreover, Defendant Osaka has now been served through personal service on her counsel,

who instructed the process server to cease attempts to personally serve Defendant Osaka because

her property is gated and who represented to the process server that he was designated to accept 

service on her behalf. See Fed. R. Civ. P. 4(e)(2)(c); See also Durbin Paper Stock Co. v. Hossain, 

97 F.R.D. 639, 639 (S.D. Fla. 1982) (explaining that “a party must have appointed his attorney as 

his agent for service of process before personal jurisdiction is obtained over the party by service 

on his attorney.”) (citing Ransom v. Brennan, 437 F.2d 513 (5th Cir. 1971); Miree v. United States,

490 F. Supp. 768 (N.D. Ga. 1980)).

To the extent that that there is any issue with how this service was effectuated, good cause 

further exists for an extension to continue attempts to serve Defendant Osaka. See First Sw. Fin. 

Services, LLC v. Best Light, LLC, 13-20049-CIV, 2015 WL 12781193, at *2 (S.D. Fla. Apr. 15, 

2015) (“Courts have extended the time for service when a plaintiff, in attempting to serve process, 

relied on a statement by an individual that he or she was authorized to accept service on the 

defendant's behalf, even though that individual was not in fact authorized.”) (collecting cases).10

Even regardless of whether there is good cause for a mandatory extension of time to serve 

Defendants, Plaintiffs have made a sufficient showing that the Court should extend the deadline to 

serve them, anyway. In deciding whether to exercise discretion to extend the time for service, 

Courts consider a variety of other factors, including the possibility of prejudice to the defendant, 

10 Further, Defendant Osaka’s counsel is in possession of a Notice of Commencement of Action 

and Request for Waiver of Service form, for which the deadline to respond is Wednesday, April 

5, 2023. To obviate any further concerns with service, Defendant Osaka and her counsel would 

ostensibly fulfill Osaka’s “duty to avoid unnecessary expenses of serving the summons.” Fed. R. 

Civ. P. 4(d)(1).

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the impact on the judicial proceedings, the reason for the delay, whether the defendant had actual 

notice, and whether the complaint was eventually served properly. First Sw. Fin. Services, LLC, 

2015 WL 12781193, at *1 (collecting cases).

Here, there is no conceivable prejudice to Defendants in granting the extension for 

Plaintiffs to serve them. Filed concurrently with this Response is also Plaintiffs’ unopposed motion 

to extend the deadline to hold the joint conference, seeking an unopposed extension of time to hold 

the conference after these Defendants have been served. ECF No. 98. No discovery has yet 

occurred, and the current deadline for all served Defendants to file their response to the operative 

Consolidated Amended Complaint is April 14, 2023. ECF No. 49. Similarly, the extension to serve 

Defendants would have little impact on the judicial proceedings, as a scheduling order is not yet 

in place and not all served Defendants have yet entered their appearances to participate in this 

litigation. See Todd v. City of LaFayette, 3:12CV589-MHT, 2013 WL 6050855, at *4 (M.D. Ala. 

Sept. 23, 2013) (finding no prejudice to defendant served 41 days after the deadline to do so, “a 

week and a half longer than the delay the Eleventh Circuit approved in Horenkamp. Id. at 1130,” 

because defendant “would have had to move to extend the time for discovery even if he was served 

at the tail end of the 120–day window” where co-defendants went forward in the case without him, 

“a common occurrence in multi-party litigation”).

Moreover, as shown above, Defendants certainly have actual notice of these proceedings, 

with O’Neal acknowledging and publicly responding to the allegations in this action in nationwide 

press on December 15, 2023. The fact that O’Neal has not yet entered an appearance through 

counsel, 6 of whom are in receipt of Notices of Commencement of Action and Requests for Waiver 

of Service forms, tends to illustrate that the failure to participate in these proceedings has thus far 

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been intentional. By comparison, many of the Defendants who have appeared in this action have 

done so through voluntarily appearing and executing waiver of service forms. ECF No. 87 at 3–4. 

Finally, Plaintiffs have diligently attempted to effect service on Defendants, having served 

17 of the 18 Defendants and continuing their attempts to complete service as soon as practicable. 

Moreover, it appears there are a number of different service deadlines currently in effect such that 

Plaintiffs submit any extension should render the new deadline consistent. 

Although the case was consolidated for all purposes, the two cases still retain their own 

status and the consolidation does not affect issues such as the deadline for service of process. As 

one district court recently explained:

Cases consolidated under Rule 42(a) ... retain their separate identity. Patton v. 

Aerojet Ordnance Co., 765 F.2d 604, 606 (6th Cir. 1985). And although 

“consolidation is permitted as a matter of convenience and economy in 

administration, [it] does not merge the suits into a single cause, or change the rights 

of the parties, or make those who are parties in one suit parties in another.” 

Johnson v. Manhattan Ry. Co., 289 U.S. 479... (1933). Therefore, it is the district 

court's responsibility to ensure that parties are not prejudiced by consolidation. See

9 Charles A. Wright and Arthur R. Miller, Federal Practice and Procedure § 2385 

(2d ed. 1994).

Johnson v. Barney, 1:21-CV-141, 2021 WL 7184242, at *2–3 (S.D. Ohio Dec. 16, 2021) (quoting 

Lewis v. ACB Bus. Servs., Inc., 135 F.3d 389, 412-13 (6th Cir. 1998)) (emphasis in original).

Further, the deadline for service of process begins to run for any new Defendants added to 

an Amended Complaint at the time the amended complaint is filed. See Charles v. Bradshaw, 2018 

WL 11309206, at *2 (S.D. Fla. Aug. 14, 2018) aff’d, 782 F. App’x 991 (11th Cir. 2019) (“Filing 

an amended complaint does not toll the Rule 4(m) service period and thereby provide an additional 

90 days for service unless the amended complaint adds a new defendant ... Plaintiff argues that he 

had ninety days from the filing of his Amended Complaint to serve Defendant ... However, since 

Plaintiff did not add new defendants in filing his Amended Complaint, the deadline for Plaintiff to 

serve process was ... ninety days from when his original Complaint was filed.”) (citing 4B Charles 

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Alan Wright & Arthur R. Miller, Federal Practice & Procedure, Time Limit for Service § 1137 

(4th ed.)) (emphasis added).

As the Podalsky action commenced on December 7, 2022, the deadline to serve Defendants 

was March 6, 2023, as to the Podalsky Plaintiffs (and March 7, 2023, as to Plaintiff Kavuri for all 

Defendants, and Garrison as to the FTX Insider Defendants—Ellison, Singh, Wang, Friedman, 

and Trabucco—as they joined the Podalsky action by amendment December 8th). 

Based on these facts, and as set forth in Plaintiffs’ Unopposed Motion for Extension of 

Time to hold the Joint Scheduling Conference, [ECF No. 98], not only does good cause exist to 

extend the deadline to serve Defendants, but an extension would help to bring all Parties in line 

with the same schedule, increasing the efficiency with which this action could then proceed.

CONCLUSION

Plaintiffs respectfully request that the Court either find good cause or exercise its discretion 

in extending the deadlines so that all Plaintiffs have an additional 60 days from the date of the 

Court’s order to complete service of process on Defendants, or such other length of time as the 

Court deems appropriate, together with such other and further relief the Court deems just, equitable 

and proper.

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Dated: March 10, 2023 Respectfully submitted,

By: /s/ Adam Moskowitz

Adam M. Moskowitz

Florida Bar No. 984280

adam@moskowitz-law.com 

Joseph M. Kaye

Florida Bar No. 117520

joseph@moskowitz-law.com

THE MOSKOWITZ LAW FIRM, PLLC

2 Alhambra Plaza, Suite 601

Coral Gables, FL 33134 

Telephone: (305) 740-1423

By: /s/ David Boies

David Boies

(Pro Hac Vice)

Alex Boies

(Pro Hac Vice)

BOIES SCHILLER FLEXNER LLP

333 Main Street

Armonk, NY 10504

Phone: (914) 749–8200

dboies@bsfllp.com

By: /s/ Stephen Neal Zack

Stephen Neal Zack

Florida Bar No. 145215

BOIES SCHILLER FLEXNER LLP

100 SE 2nd St., Suite 2800

Miami, FL 33131

Office: 305-539-8400

szack@bsfllp.com

Co-Counsel for Plaintiff and the Class

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the forgoing was filed on March 10, 2023, 

via the Court’s CM/ECF system, which will send notification of such filing to all attorneys of 

record. By: /s/ Adam M. Moskowitz______

ADAM M. MOSKOWITZ

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