Bob Goodlatte: “I include in the Record the affidavit that I cited in my earlier remarks. United States District Court Southern District…”

“I include in the Record the affidavit that I cited in my earlier remarks. United States District Court Southern District of Florida Case No. 1:17-cv-24116-KMM Enrique Madrinan, Plaintiff, v. Harbour Shopping Center, Inc. and Luza Corp. d/b/a Donut Gallery Diner, Defendants. DEFENDANT LUZA CORP.'S NOTICE OF FILING AFFIDAVIT IN RELATION TO DOCKET ENTRY THIRTY-THREE, PLAINTIFF'S REPLY TO DEFENDANTS RESPONSE TO PLAINTIFF'S MOTION TO DISQUALIFY COUNSEL AND LAW FIRM REPRESENTING DEFENDANT LUZA CORP., D/B/A DONUT GALLERY DINER 7. Notably, the alleged time entries at issue in this case, include authoring discovery six months in advance of the case being filed. Because most cases settled upon filing, and Federal Disability Advocates wanted to bill hours before they settled, they had their off-site team who handled the pre- filing, filing, and service, serve discovery with the Complaint. I repetitively told Mr. Lopez, the real person in charge of Federal Disability Advocates, this practice was useless because a party cannot propound discovery until after the scheduling conference. I even argued that it was counter- productive because it led to a debate over when, and if, discovery was served, which unnecessarily increased legal fees. Mr. Lopez's response was that increasing legal fees was what I was supposed to do, and that serving discovery with the complaint was part of how to get to ten hours pre-filing.”