`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
`(Miami Division)
`
`
`
`
`
`
`
`ACTION No. 1:23-CV-22933-ALTMAN
`WORLD MEDIA ALLIANCE LABEL
`
`INC.
`
` (Florida corporation)
`PLAINTIFF’S EMERGENCY MOTION TO
`
`AMEND PARAGRAPH 1 OF THE ORDER
` Plaintiffs,
`OF THIS DATE
`
` v.
`
`ELLO ENTERTAINMENT GROUP,
`LLC.,
` (Wyoming company);
`
`VAL SEGAL,
` et al.
`
`
` Defendants.
`
`
`Plaintiffs World Media Alliance Label Inc. (“WMA”), a Florida corporation, respectfully
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`files an Emergency Motion to amend the Order entered in this case, Dkt 62, on March 21, 2024,
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`earlier on this date.
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`The amendment that WMA seeks concerns Paragraph 1, where the Order states that the
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`parties must meet again in person.
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`The undersigned is currently in Germany (Munich) in connection with an extradition
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`matter of one U.S. citizen. The undersigned is a criminal defense counsel of record in his client’s
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`two criminal cases in the U.S. District Courts. The undersigned interacts with German attorneys
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`and German authorities; at present the client is hospitalized and is awaited to be returned to an
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`institution of preliminary detention. The obligation of the undersigned to be in Munich arose well
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`before the status conference and today’s Order. The German Court made a ruling, authorizing the
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`1
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`Case 1:23-cv-22933-RKA Document 63 Entered on FLSD Docket 03/21/2024 Page 2 of 3
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`undersigned to undertake legal representation of the U.S. citizen and be allowed work visitation
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`rights on a daily basis and other representation privileges.
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`For that reason, the plaintiffs and their counsel move, on an emergency basis, this honorable
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`Court to allow the undersigned to be present at the joint meeting of the parties via Zoom or a
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`comparable video connection. If the clients’ presence in person is desirable and allowed, given
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`the technical nature of many issues, the plaintiffs’ executives will also attend the joint meeting in
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`Miami Dade in person, while the undersigned attorney would have a parallel separate confidential
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`communication line from Germany with them.
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`Prior to this filing, the undersigned had advised all other attorneys in this case about the
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`undersigned’s being on a legal work assignment in Germany and advised all other attorneys that
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`the Motion was being filed today.
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`The present Motion is diligently filed on the same day under Eastern Standard Time as the
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`Order was issued.
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`Dated: March 21, 2024.
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`Respectfully submitted,
`
` ____________________/George Lambert/
` George Lambert, Esq.
`
`
`
`
`
`The Lambert Law Firm
`FL bar 1022697
`421 Poinciana Drive, #1422,
`Sunny Isles Beach, FL 33160;
`Email: office.law.323@gmail.com
`Tel. (305) 938 0600
`Attorney for Plaintiff World Media Alliance Label Inc.
`
`
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`
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`
`2
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`Case 1:23-cv-22933-RKA Document 63 Entered on FLSD Docket 03/21/2024 Page 3 of 3
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`
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`CERTIFICATE OF SERVICE.
`
`
`The undersigned certifies that the foregoing was served by MC/ECF on the attorneys of
`Defendants as follows:
`
`Jay Brian Shapiro jshapiro@stearnsweaver.com, mrt@stearnsweaver.com
`Stearns Weaver Miller - Miami
`Museum Tower
`150 West Flagler Street
`Suite 2200
`Miami, Florida 33130
`
`Richard Kinney Edward Middagh richard@middaghlaw.com
`Middagh Law, PLLC
`Attorney in Coral Gables, Florida
`Located in: Red Sunset Building
`Address: 6915 Red Rd #206, Coral Gables, FL 33146
`
`Brian M. Willen bwillen@wsgr.com
`Wilson Sonsini
`1301 Avenue of the Americas
`40th Floor New York
`NY10019-6022
`
`Veronica Louise De Zayas vdezayas@stearnsweaver.com, egraham@stearnsweaver.com
`Stearns Weaver Miller - Miami
`Museum Tower
`150 West Flagler Street
`Suite 2200
`Miami, Florida 33130
`
`Jeremy Auster jauster@wsgr.com
`Wilson Sonsini
`1301 Avenue of the Americas
`40th Floor New York
`NY10019-6022
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`
`
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`
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`Dated: March 21, 2024
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`
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`
`
`/signed George Lambert/
`
`
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`3
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