1:25-cv-20405
01/27/2025
Open
Fraud - Personal Property Fraud
took place in this District, and because Defendant has engaged in substantial and not isolated activity in this District.
6. This Court has personal long arm jurisdiction over Defendant pursuant to Florida Statute 48.193(1)(a)(1) because Defendant —itself and through its agent(s) —operated, conducted, engaged in, and carried on a business or business venture in this State.
7. This Court has personal long arm jurisdiction over Defendant pursuant to Florida Statute 48.193(1)(a)(1) because Defendant owns, manages, and operates businesses in the State of Florida (e.g., without limitation, BOCA BRIDGES LOT 0255 , LLC and CH STORAGE, LLC), through an entity owns real property in the State of Florida ( Brulee Breeze Way Boca Raton, Florida ), has retained local counsel in the State of Florida, and has thereby submitted himself to the jurisdiction of the courts of this State.
8. This Court has personal long arm jurisdiction over Defendant pursuant to Florida Statute 48.193(1)(a)(2) because Defendant committed tortious acts within the State of Florida (as more particularly described herein)
9. Personal jurisdiction over Defendant meets the minimum contacts or due process requirements such that the exercise of jurisdiction would not offend traditional notions of fair play and substantial justice because (i) Defendant has operated and conducted significant business in Florida, including purchasing, operating, ; (ii) Defendant travels to and from Florida as part of his normal business operations; (iv) modern methods of transportation and communication (e.g., Zoom and other video conferencing platforms) reduce significantly any burden on Defendant to litigate in the State of Florida; and (iii) The State of Florida has a strong interest in seeing this matter resolved in Florida.
10. Any conditions precedent to bringing this action have been performed, have occurred, have been waived, or have otherwise been excused by Defendant’s course of conduct.
11. Plaintiff Jonny Lopez is an entrepreneur who, among other things, holds cryptocurrency, including Ethereum (“ETH”).
12. The term “cryptocurrency” or “crypto asset” generally refers to an asset issued and/or transferred using distributed ledger or blockchain technology.
13. A blockchain or distributed ledger is a peer-to-peer database spread across a network of computers that records all transactions in theoretically unchangeable, digitally recorded data packages, referred to as “blocks.” The system relies on cryptographic techniques for secure recording of transactions.
14. A blockchain “protocol” is a code, software, or algorithm that governs how a blockchain, or a feature of a blockchain, operates.
15. A “wallet” is a piece of hardware or software on which crypto asset owners typically store the cryptographic key information providing them control over their crypto assets. Crypto wallets offer a method to store and manage critical information about crypto assets, i.e., cryptographic information necessary to identify and transfer those assets.
16. A “smart contract” is a software or code that, based on programmable conditions, is deployed and run on a blockchain.
17. Defendant Chase Herro (who sometimes goes by Chase Hero) is also a serial ETH trader.
18. Among other things, Chase proudly broadcasts his ETH holdings to the public.
Page 3Presiding Judge
Jacqueline Becerra
Referral Judge
Edwin G. Torres
Plaintiff
JONATHAN LOPEZ
Defendants
CHASE HERRO
CHASE HERO
Plaintiff Attorneys
Derek Grant Silver
Melissa Lea Mackiewicz
Joseph Isaiah Pardo
Defendant Attorneys
Jeffrey Adam Neiman
Brandon Scott Floch
Exhibit Caselaw
(#34) RESPONSE in Opposition re #30 MOTION to Stay Discovery Pending Resolution of Motion to Compel Arbitration [ECF 10] filed by Jonathan Lopez. Replies due by 9/22/2025. (Attachments: #1 Exhibit Caselaw)(Pardo, Joseph) (Entered: 09/14/2025)
Text of Proposed Order
(#32) Unopposed MOTION to Continue September 19, 2025 Oral Argument re 31 Order,, Set/Reset Motion/R&R Deadlines and Hearings, by Chase Herro. Responses due by 9/22/2025. (Attachments: #1 Text of Proposed Order)(Floch, Brandon) (Entered: 09/08/2025)
Text of Proposed Order
(#30) MOTION to Stay Discovery Pending Resolution of Motion to Compel Arbitration [ECF 10] by Chase Herro. Responses due by 9/16/2025. (Attachments: #1 Text of Proposed Order)(Floch, Brandon) (Entered: 09/02/2025)
(#28) NOTICE of Change of Address/Contact Information; Change of Email; Change of Law Firm Name; by Jeffrey Adam Neiman (Neiman, Jeffrey) (Entered: 08/14/2025)
Affidavit Declaration of Bobo Zuljevic & Exhibit A
(#31) PAPERLESS ORDER SETTING ORAL ARGUMENT. Oral argument on Defendant's Motion to Compel Arbitration or in the alternative Motion to Dismiss, ECF No. #10 , is hereby SET for Friday, September 19, 2025 at 10:30 a.m. before the undersigned at the Wilkie D. Ferguson, Jr. Courthouse, Courtroom 11-4, 400 North Miami Avenue, Miami, Florida 33128. Signed by Judge Jacqueline Becerra on 9/5/2025. (cfz) (Entered: 09/05/2025)
(#9) NOTICE of Attorney Appearance by Brandon Scott Floch on behalf of CHASE HERRO. Attorney Brandon Scott Floch added to party CHASE HERRO(pty:dft). (Floch, Brandon) (Entered: 02/19/2025)
(#8) NOTICE of Attorney Appearance by Jeffrey Adam Neiman on behalf of CHASE HERRO. Attorney Jeffrey Adam Neiman added to party CHASE HERRO(pty:dft). (Neiman, Jeffrey) (Entered: 02/19/2025)
(#7) SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by JONATHAN LOPEZ. CHASE HERRO served on 1/29/2025, response/answer due 2/19/2025. (Pardo, Joseph) (Entered: 02/03/2025)
(#5) NOTICE Corrected Civil Cover Sheet by JONATHAN LOPEZ re #1 Complaint, (Pardo, Joseph) (Entered: 01/28/2025)
(#4) Summons Issued as to CHASE HERRO. (wce) (Entered: 01/28/2025)
Summon(s)
Civil Cover Sheet
Exhibit A
(#7) SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by JONATHAN LOPEZ. CHASE HERRO served on 1/29/2025, response/answer due 2/19/2025. (Pardo, Joseph) (Entered: 02/03/2025)
Docket(#35) PAPERLESS ORDER RESETTING HEARING. In light of a criminal trial beginning on Monday, September 22, 2025, the oral argument previously set for Monday, September 22, 2025, at 9:00AM is hereby RESET to Thursday, October 9, 2025, at 8:30AM before the undersigned at the Wilkie D. Ferguson, Jr. Courthouse, Courtroom 11-4, 400 North Miami Avenue, Miami, Florida 33128. In light of the Courts Order as stated herein, the Court's ruling on the Motion to Compel Arbitration or in the alternative Motion to Dismiss, ECF No. #10 , is hereby STAYED pending oral argument. Signed by Judge Jacqueline Becerra on 9/18/2025. (cfz) (Entered: 09/18/2025)
[-] Read LessDocket(#34) RESPONSE in Opposition re #30 MOTION to Stay Discovery Pending Resolution of Motion to Compel Arbitration [ECF 10] filed by Jonathan Lopez. Replies due by 9/22/2025. (Attachments: #1 Exhibit Caselaw)(Pardo, Joseph) (Entered: 09/14/2025)
[-] Read LessDocket(#33) PAPERLESS ORDER RESETTING ORAL ARGUMENT. THIS CAUSE comes before the Court on Defendant's Unopposed Motion to Continue September 19, 2025 Hearing, ECF No. #32 , (the "Motion"). Upon due consideration of the Motion, the pertinent portions of the record, and for good cause shown, it is hereby ORDERED AND ADJUDGED that the Motion is GRANTED. The oral argument previously set by ECF No. 31 is hereby RESET to Monday, September 22, 2025 at 9:00 a.m. before the undersigned at the Wilkie D. Ferguson, Jr. Courthouse, Courtroom 11-4, 400 N. Miami Avenue, Miami, Florida 33128. Signed by Judge Jacqueline Becerra on 9/8/2025. (cfz) (Entered: 09/08/2025)
[-] Read LessDocket(#32) Unopposed MOTION to Continue September 19, 2025 Oral Argument re 31 Order,, Set/Reset Motion/R&R Deadlines and Hearings, by Chase Herro. Responses due by 9/22/2025. (Attachments: #1 Text of Proposed Order)(Floch, Brandon) (Entered: 09/08/2025)
[-] Read LessDocket(#31) PAPERLESS ORDER SETTING ORAL ARGUMENT. Oral argument on Defendant's Motion to Compel Arbitration or in the alternative Motion to Dismiss, ECF No. #10 , is hereby SET for Friday, September 19, 2025 at 10:30 a.m. before the undersigned at the Wilkie D. Ferguson, Jr. Courthouse, Courtroom 11-4, 400 North Miami Avenue, Miami, Florida 33128. Signed by Judge Jacqueline Becerra on 9/5/2025. (cfz) (Entered: 09/05/2025)
[-] Read LessDocket(#30) MOTION to Stay Discovery Pending Resolution of Motion to Compel Arbitration [ECF 10] by Chase Herro. Responses due by 9/16/2025. (Attachments: #1 Text of Proposed Order)(Floch, Brandon) (Entered: 09/02/2025)
[-] Read LessDocket(#29) CLERK'S NOTICE - Attorney Admissions has accepted the address and email information change request(s) as submitted through attorneys PACER account for attorney Jeffrey Adam Neiman (nwn) (Entered: 08/15/2025)
[-] Read LessDocket(#28) NOTICE of Change of Address/Contact Information; Change of Email; Change of Law Firm Name; by Jeffrey Adam Neiman (Neiman, Jeffrey) (Entered: 08/14/2025)
[-] Read LessDocket(#27) CLERK'S NOTICE - Attorney Admissions has accepted the email information change request as submitted through attorneys PACER account for attorney Brandon Scott Floch (pt) (Entered: 08/14/2025)
[-] Read LessDocket(#26) CLERK'S NOTICE - Attorney Admissions has accepted the address information change request as submitted through attorneys PACER account for attorney Brandon Scott Floch (pt) (Entered: 08/12/2025)
[-] Read LessDocket(#10) MOTION to Compel Arbitration or in the alternative Motion to Dismiss by CHASE HERRO. Responses due by 3/5/2025. (Attachments: #1 Affidavit Declaration of Bobo Zuljevic & Exhibit A)(Floch, Brandon) (Entered: 02/19/2025)
[-] Read LessDocket(#9) NOTICE of Attorney Appearance by Brandon Scott Floch on behalf of CHASE HERRO. Attorney Brandon Scott Floch added to party CHASE HERRO(pty:dft). (Floch, Brandon) (Entered: 02/19/2025)
[-] Read LessDocket(#8) NOTICE of Attorney Appearance by Jeffrey Adam Neiman on behalf of CHASE HERRO. Attorney Jeffrey Adam Neiman added to party CHASE HERRO(pty:dft). (Neiman, Jeffrey) (Entered: 02/19/2025)
[-] Read LessDocket(#7) SUMMONS (Affidavit) Returned Executed on #1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by JONATHAN LOPEZ. CHASE HERRO served on 1/29/2025, response/answer due 2/19/2025. (Pardo, Joseph) (Entered: 02/03/2025)
[-] Read LessDocket(#6) PAPERLESS ORDER REGARDING PROCEDURES. The parties shall comply with the following procedures: 1. SERVICE: Federal Rule of Civil Procedure 4(m) requires service of summons and complaint to be perfected upon Defendants within 90 days after the filing of the complaint. Unless service is waived, proof of service must be made to the Court by filing the server's affidavit. If a Defendant waives service, notice of the same shall be filed immediately. Failure to file proof of service or show good cause within 90 days will result in a dismissal without prejudice and without further notice. 2. DEFAULTS: In the event a served Defendant does not appear in this action, the Plaintiff(s) shall file a Motion for Clerk's Default within seven days of the deadline for the Defendant to answer. Extensions of time to answer a pleading must take the form of a motion to the Court. Motions for Final Default Judgment, if applicable, shall be filed within seven days of the entry of a Clerk's Default. Any motions for default final judgment must comply with the Court's Standing Procedures Regarding Motions for Default Final Judgment found at: https://www.flsd.uscourts.gov/sites/flsd/files/JudgeBecerraStandingOrderMotionsforDefaultJudgment.pdf. 3. CERTIFICATE OF INTERESTED PARTIES: Within fifteen days from the date the last Defendant enters an appearance in this action, the parties, including governmental parties, must file Certificates of Interested Parties and Corporate Disclosure Statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties must not include the undersigned or the assigned Magistrate Judge as interested parties unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the Certificates. 4. JOINT SCHEDULING REPORTS: Within twenty days from the date the last Defendant enters an appearance in this action, the parties are directed to prepare and file a Joint Scheduling Report as required by Local Rule 16.1. Disclosures required under Fed. R. Civ. P. 26(a)(l) must be made at or before the time the parties confer to develop their case management and discovery plan. The parties must certify in the Joint Scheduling Report that such disclosures have been made unless a party files an objection to a required disclosure. Such filed objection must include a full explanation of the basis for the objection. The scheduling conference may be held via video conference or in person. It may not be held by telephone. In drafting their Joint Proposed Scheduling Order, the parties shall utilize the Court's Template Scheduling Order, found at https://www.flsd.uscourts.gov/sites/flsd/files/TemplateSchedulingOrder.pdf. Any deviation from the guidelines set forth in the Court's Template Scheduling Order or those proposed by the Local Rules must be noted in the Joint Scheduling Report along with an explanation for why any deviation is being proposed. Failure to articulate the reason(s) for any deviation from the guidelines set forth in the Court's Template Scheduling Order may result in the Court setting pre-trial deadlines and/or a trial date without regard to those proposed by the parties. 5. FILING OF MOTIONS: All filings must be in a 12-point font and double spaced. Single spacing is only permitted for footnotes. The required conferral under Local Rule 7.1 must be by telephone or in person. An e-mail conferral will only be permitted if counsel are in agreement as to the relief sought in the motion. 6. EXTENSIONS OF TIME: Requests for extensions of time, including unopposed motions, will only be granted by the Court upon an appropriate motion showing good cause why the deadline cannot be met. Absent an emergency, motions for extensions of time must be filed no later than three business days prior to the deadline from which relief is being sought. All requests for extensions of time must include: (1) the conferral statement required under Local Rule 7.1; (2) a list of any prior motions for extension of time; (3) a specific statement regarding the circumstances necessitating the requested relief; and (4) a statement as to whether the request impacts the deadline to file a dispositive motion or trial date. Signed by Judge Jacqueline Becerra on 1/29/2025. (ymr) (Entered: 01/29/2025)
[-] Read LessDocket(#5) NOTICE Corrected Civil Cover Sheet by JONATHAN LOPEZ re #1 Complaint, (Pardo, Joseph) (Entered: 01/28/2025)
[-] Read LessDocket(#4) Summons Issued as to CHASE HERRO. (wce) (Entered: 01/28/2025)
[-] Read LessDocket(#3) Clerk's Notice to Filer re: Electronic Case. Venue on the Civil Cover Sheet does not match the initiating document. The Clerks Office confirmed Miami-Dade (Office - Miami) as the county with the filer. It is not necessary to re-file this document. (wce) (Entered: 01/28/2025)
[-] Read LessDocket(#2) Clerks Notice of Judge Assignment to Judge Jacqueline Becerra. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Edwin G. Torres is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (wce) (Entered: 01/28/2025)
[-] Read LessDocket(#1) COMPLAINT against CHASE HERRO. Filing fees $ 405.00. Pay.gov Agency Tracking ID FLSDC-18155511, payment transferred from : 25CV20404, filed by JONATHAN LOPEZ. (Attachments: #1 Exhibit A, #2 Civil Cover Sheet, #3 Summon(s))(Pardo, Joseph) (Entered: 01/27/2025)
[-] Read Less