ALTERS et al v. PEOPLE'S REPUBLIC OF CHINA et al

Filing 1

COMPLAINT against All Defendants. Filing fees $ 400.00 receipt number AFLSDC-12595677, filed by LAWRENCE WOOD, MARTA REYES, LOGAN ALTERS, STEPHEN CLYNE, THE PITCHING LAB LLC d/b/a TBT TRAINING. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Summon(s) Summons)(Moore, Matthew)

CIVIL COVER SHEET

JS 44 (Rev. 06/17) FLSD Revised 06/01/2017

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose
of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.

I. (a)

PLAINTIFFS LOGAN ALTERS, et al.

DEFENDANTS Premier Brokers International, Inc.

(b) County of Residence of First Listed Plaintiff Miami-Dade

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)
NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)
Matthew T. Moore, Esq., The Berman Law Group, 3351 NW
Boca Raton, FL 33431
(d) Check County Where Action Arose:

MIAMI- DADE

II. BASIS OF JURISDICTION

MONROE

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

BROWARD

PALM BEACH

MARTIN

ST. LUCIE

INDIAN RIVER

OKEECHOBEE

HIGHLANDS

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)

(Place an “X” in One Box Only)

(For Diversity Cases Only)
PTF
Citizen of This State
1

1

U.S. Government
Plaintiff

3

Federal Question
(U.S. Government Not a Party)

2

U.S. Government
Defendant

4

Diversity
(Indicate Citizenship of Parties in Item III)

DEF
1

and One Box for Defendant)
PTF DEF
Incorporated or Principal Place
4
4
of Business In This State

CONTRACT
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excl. Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

V. ORIGIN
1

Original
Proceeding

(Place an “X” in One Box Only)
TORTS
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers’
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Med. Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities -

(Place an “X” in One Box Only)
2 Removed
3 Re-filed
from State
(See VI
Court
below)

VI. RELATED/
RE-FILED CASE(S)

2

Incorporated and Principal Place
of Business In Another State

5

5

3

3

Foreign Nation

6

6

Click here for: Nature of Suit Code Descriptions
FORFEITURE/PENALTY
BANKRUPTCY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
Other:

Employment
446 Amer. w/Disabilities Other
448 Education

2

Citizen or Subject of a
Foreign Country

IV. NATURE OF SUIT

Citizen of Another State

530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee –
Conditions of
Confinement

4 Reinstated
or
Reopened

5

(See instructions): a) Re-filed Case
JUDGE:

625 Drug Related Seizure
of Property 21 USC 881
690 Other

375 False Claims Act
376 Qui Tam (31 USC
3729 (a))
400 State Reapportionment
410 Antitrust
PROPERTY RIGHTS
820 Copyrights
430 Banks and Banking
830 Patent
450 Commerce
835 Patent – Abbreviated
460 Deportation
New Drug Application
840 Trademark
470 Racketeer Influenced and
Corrupt Organizations
SOCIAL SECURITY
861 HIA (1395ff)
480 Consumer Credit
862 Black Lung (923)
490 Cable/Sat TV
863 DIWC/DIWW (405(g))
850 Securities/Commodities/
864 SSID Title XVI
Exchange
865 RSI (405(g))
$ 890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
896 Arbitration
or Defendant)
899 Administrative Procedure
871 IRS—Third Party 26
Act/Review or Appeal of
USC 7609

LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt. Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc.
Security Act

Agency Decision
950 Constitutionality of State
Statutes

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

Transferred from
another district
(specify)

YES

OTHER STATUTES

422 Appeal 28 USC 158
423 Withdrawal
28 USC 157

NO

6 Multidistrict
Litigation
Transfer

7 Appeal to
District Judge
from Magistrate
Judgment

b) Related Cases

YES

8 Multidistrict
Litigation
– Direct
File

from
9 RemandedCourt
Appellate

NO

DOCKET NUMBER:

Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):

VII. CAUSE OF ACTION 28 U.S.C. § 1332(d)
LENGTH OF TRIAL via

VIII. REQUESTED IN
COMPLAINT:

days estimated (for both sides to try entire case)

CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23

DEMAND $ 9,999,999,999.00

CHECK YES only if demanded in complaint:
JURY DEMAND:

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE

SIGNATURE OF ATTORNEY OF RECORD

March 12, 2020

FOR OFFICE USE ONLY
RECEIPT #

AMOUNT

IFP

Save As...

JUDGE

Print

MAG JUDGE

Reset

Yes

No

JS 44 (Rev. 06/17) FLSD Revised 06/01/2017

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.
(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the
official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the “defendant” is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment,
noting in this section “(see attachment)”.
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in
one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and
box 1 or 2 should be marked. Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4
is checked, the citizenship of the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature of Suit. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature
of suit code that is most applicable. Click here for: Nature of Suit Code Descriptions.
V.

Origin. Place an “X” in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the
petition for removal is granted, check this box.
Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this
box is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.
Remanded from Appellate Court. (8) Check this box if remanded from Appellate Court.
VI.
Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the
corresponding judges name for such cases.
VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
VIII. Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

Date and Attorney Signature. Date and sign the civil cover sheet.