Docket Entries Since Last Update
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Court Dockets
U.S. District Court
District of Columbia (Washington, DC)
CIVIL DOCKET FOR CASE #: 1:19-cv-02443-RDM-ZMF
District of Columbia (Washington, DC)
CIVIL DOCKET FOR CASE #: 1:19-cv-02443-RDM-ZMF
SAVIGNAC et al v. JONES DAY et al
DOCKET INFORMATION
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| Plaintiff |
MARK C. SAVIGNAC
Plaintiff
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| Representation | |||
| MARK C. SAVIGNAC 2207 Combes Street Urbana, IL 61801 (217) 714-3803 marksavignac@gmail.com PRO SE | |||
| Plaintiff |
JULIA SHEKETOFF
Plaintiff
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| Representation | |||
| JULIA SHEKETOFF 2207 Combes Street Urbana, IL 61801 (617) 470-5284 sheketoff@gmail.com PRO SE | |||
| Defendant |
JONES DAY
Defendant
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| Representation | |||
| MaryEllen Powers JONES DAY 51 Louisiana Avenue, NW Washington, DC 20001-2113 (202) 879-3870 Fax: (202) 737-2832 mepowers@jonesday.com LEAD ATTORNEY ATTORNEY TO BE NOTICED | Anderson T. Bailey JONES DAY One Mellon Bank Center 500 Grant Street Suite 4500 Pittsburgh, PA 15219 (412) 391-3939 atbailey@jonesday.com PRO HAC VICE ATTORNEY TO BE NOTICED | Christopher DiPompeo JONES DAY 51 Louisiana Avenue, NW Washington, DC 20001 (202) 879-7686 cdipompeo@jonesday.com ATTORNEY TO BE NOTICED | |
| Terri L. Chase JONES DAY 600 Brickell Avenue Suite 3300 Miami, FL 33131 (305) 714-9722 Fax: (305) 714-9799 tlchase@jonesday.com PRO HAC VICE ATTORNEY TO BE NOTICED | Traci L. Lovitt JONES DAY 250 Vesey Street New York, NY 10281 (212) 326-3939 Fax: (212) 755-7306 tlovitt@jonesday.com PRO HAC VICE ATTORNEY TO BE NOTICED | ||
| Defendant |
JOHN DOES 1-10 TERMINATED: 05/12/2021Defendant
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| Defendant |
MICHAEL SHUMAKER
Defendant
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| Representation | |||
| Terri L. Chase (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED | |||
| Defendant |
TRACI LOVITT
Defendant
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| Representation | |||
| Terri L. Chase (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED | |||
Numbers shown are court assigned numbers.
| Entry | Filed | Description | |
|---|---|---|---|
| 1 | Aug 13, 2019 | View | COMPLAINT against STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY ( Filing fee $ 400, receipt number 4616100178) with Jury Demand filed by MARC C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Addendum, # 2 Civil Cover Sheet)(ztd) (Entered: 08/14/2019) |
| Aug 13, 2019 | Summons (3) Issued as to STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (ztd) (Entered: 08/14/2019) | ||
| 2 | Aug 13, 2019 | Request | MOTION for CM/ECF Password by JULIA SHEKETOFF (Attachments: # 1 Text of Proposed Order)(ztd) (Entered: 08/14/2019) |
| 3 | Aug 13, 2019 | Request | MOTION for CM/ECF Password by MARC C. SAVIGNAC (Attachments: # 1 Text of Proposed Order)(ztd) (Entered: 08/14/2019) |
| 4 | Aug 13, 2019 | View | NOTICE OF RELATED CASE by MARC C. SAVIGNAC, JULIA SHEKETOFF. Case related to Case No. 19-cv-00945-RDM. (ztd) (Entered: 08/14/2019) |
| 5 | Aug 14, 2019 | Request | STANDING ORDER: The parties are hereby ORDERED to comply with the directives set forth in the attached Standing Order. See document for details. Signed by Judge Randolph D. Moss on 8/14/19. (lcrdm1, ) (Entered: 08/14/2019) |
| Aug 14, 2019 | MINUTE ORDER: Upon consideration of Plaintiffs' motions for leave to file through CM/ECF, Dkt. 2 , 3 , it is hereby ORDERED that Plaintiffs' motions are GRANTED. Plaintiffs, Julia Sheketoff and Marc C. Savignac, may file and receive service of other parties' filings through the Court's CM/ECF system. Signed by Judge Randolph D. Moss on 08/14/2019. (lcrdm2, ) (Entered: 08/14/2019) | ||
| 6 | Aug 16, 2019 | Request | RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. JONES DAY served on 8/14/2019, answer due 9/4/2019 (Savignac, Mark) (Entered: 08/16/2019) |
| 7 | Aug 16, 2019 | View | RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. STEPHEN J. BROGAN served on 8/14/2019, answer due 9/4/2019 (Savignac, Mark) (Entered: 08/16/2019) |
| 8 | Aug 16, 2019 | View | RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. BETH HEIFETZ served on 8/14/2019, answer due 9/4/2019 (Savignac, Mark) (Entered: 08/16/2019) |
| 9 | Aug 19, 2019 | View | NOTICE of Appearance by MaryEllen Powers on behalf of All Defendants (Powers, MaryEllen) (Main Document 9 replaced on 8/20/2019) (ztd). (Entered: 08/19/2019) |
| 10 | Aug 19, 2019 | View | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Traci L. Lovitt, :Firm- Jones Day, :Address- 250 Vesey Street, New York, NY 10281. Phone No. - 212-326-7830. Fax No. - 212-326-6999 Filing fee $ 100, receipt number 0090-6330522. Fee Status: Fee Paid. by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Powers, MaryEllen) (Entered: 08/19/2019) |
| 11 | Aug 19, 2019 | View | MOTION for Extension of Time to File Answer re 1 Complaint by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Text of Proposed Order)(Powers, MaryEllen) (Attachment 1 replaced fillable document on 8/20/2019) (ztd). Modified on 8/20/2019 (ztd). (Entered: 08/19/2019) |
| 12 | Aug 19, 2019 | View | RESPONSE re 11 MOTION for Extension of Time to File Answer re 1 Complaint filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Text of Proposed Order)(Savignac, Mark) (Entered: 08/19/2019) |
| Aug 20, 2019 | MINUTE ORDER: Upon consideration of Defendants' motion for pro hac vice admission, Dkt. 10 , it is hereby ORDERED that the motion is GRANTED. Traci L. Lovitt is hereby granted leave to appear pro hac vice in this case. Signed by Judge Randolph D. Moss on 08/20/2019. (lcrdm2, ) (Entered: 08/20/2019) | ||
| Aug 21, 2019 | MINUTE ORDER: Upon consideration of Defendants' motion for extension, Dkt. 11 , and Plaintiffs' opposition, Dkt. 12, it is hereby ORDERED that Defendants' motion is GRANTED. Defendant shall file a responsive pleading or dispositive motion on or before October 4, 2019. Signed by Judge Randolph D. Moss on 08/21/2019. (lcrdm2, ) (Entered: 08/21/2019) | ||
| Aug 21, 2019 | Set/Reset Deadlines: Defendant shall file a responsive pleading or dispositive motion on or before 10/4/2019. (kt) (Entered: 08/21/2019) | ||
| 13 | Sep 25, 2019 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Terri L. Chase, :Firm- Jones Day, :Address- 250 Vesey Street New York, NY 10281. Phone No. - (212) 326-3939. Fax No. - (212) 755-7306 Filing fee $ 100, receipt number 0090-6398059. Fee Status: Fee Paid. by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Declaration of Terri L. Chase, # 2 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/25/2019) |
| Sep 25, 2019 | MINUTE ORDER: Upon consideration of Defendants' Motion for Admission Pro Hac Vice, Dkt. 13 , it is hereby ORDERED that the motion is GRANTED. Terri L. Chase is hereby granted leave to appear pro hac vice in this case. Signed by Judge Randolph D. Moss on 9/25/19. (lcrdm1, ) (Entered: 09/25/2019) | ||
| 14 | Sep 26, 2019 | View | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Anderson T. Bailey, :Firm- Jones Day, :Address- 500 Grant Street, Suite 4500 Pittsburgh, PA 15219-4500. Phone No. - (412) 391-3939. Fax No. - (412) 394-7959 Filing fee $ 100, receipt number 0090-6400818. Fee Status: Fee Paid. by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Declaration of Anderson T. Bailey, # 2 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/26/2019) |
| Sep 26, 2019 | MINUTE ORDER: Upon consideration of Defendants' Motion for Leave to Appear Pro Hac Vice, Dkt. 14, it is hereby ORDERED that the motion is GRANTED. Anderson T. Bailey is hereby granted leave to appear pro hac vice in this case. Signed by Judge Randolph D. Moss on 09/26/2019. (lcrdm2, ) (Entered: 09/26/2019) | ||
| 15 | Sep 27, 2019 | View | MOTION to Dismiss by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Exhibit A - HR Email, # 2 Exhibit B - Email Exchange, # 3 Exhibit C - Review, # 4 Exhibit D - Assessment Statement, # 5 Exhibit E - EEOC Guidance, # 6 Text of Proposed Order)(Lovitt, Traci) (Entered: 09/27/2019) |
| 16 | Oct 1, 2019 | View | Consent MOTION for Leave to File Under Seal by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Errata Exhibit B to Motion to Dismiss, # 2 Text of Proposed Order)(Chase, Terri) (Entered: 10/01/2019) |
| Oct 1, 2019 | MINUTE ORDER: Upon consideration of Defendants' Consent Motion for Leave to File Under Seal, Dkt. 16, it is hereby ORDERED that the motion is GRANTED. The Clerk's office shall place the document originally filed at Dkt. No. 15-2 under seal, and the errata attached to the Consent Motion for Leave is accepted for filing as a substitute Exhibit B to Defendants' Motion to Dismiss, Dkt. 15. Signed by Judge Randolph D. Moss on 10/1/2019. (lcrdm2, ) Modified on 10/1/2019 to correct typo (kt). (Entered: 10/01/2019) | ||
| 17 | Oct 1, 2019 | Request | SEALED DOCUMENT filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.)(ztd) (Entered: 10/02/2019) |
| 18 | Oct 10, 2019 | View | Memorandum in opposition to re 15 MOTION to Dismiss filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(Savignac, Mark) (Entered: 10/10/2019) |
| 19 | Oct 17, 2019 | View | REPLY to opposition to motion re 15 MOTION to Dismiss filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Lovitt, Traci) (Entered: 10/17/2019) |
| 20 | Oct 18, 2019 | View | NOTICE of Appearance by Christopher DiPompeo on behalf of STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (DiPompeo, Christopher) (Entered: 10/18/2019) |
| 21 | Oct 28, 2019 | View | MOTION for Leave to File Surreply in Opposition to Motion to Dismiss by MARK C. SAVIGNAC, JULIA SHEKETOFF (Attachments: # 1 Exhibit Proposed Surreply in Opposition to Motion to Dismiss, # 2 Text of Proposed Order)(Sheketoff, Julia) (Entered: 10/28/2019) |
| 22 | Nov 1, 2019 | View | WITHDRAWN AT THE HEARING ON 8/4/2020.....Memorandum in opposition to re 21 MOTION for Leave to File Surreply in Opposition to Motion to Dismiss filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Lovitt, Traci) Modified on 8/4/2020 (kt). (Entered: 11/01/2019) |
| 23 | Nov 8, 2019 | View | REPLY to opposition to motion re 21 MOTION for Leave to File Surreply in Opposition to Motion to Dismiss filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Savignac, Mark) (Entered: 11/08/2019) |
| 24 | Jun 20, 2020 | View | NOTICE of Change of Address by Mark Christopher Savignac (Savignac, Mark) (Entered: 06/20/2020) |
| 25 | Jun 30, 2020 | View | MOTION for Leave to File Supplemental Complaint by MARK C. SAVIGNAC, JULIA SHEKETOFF (Attachments: # 1 Exhibit Proposed Supplemental Complaint, # 2 Text of Proposed Order)(Savignac, Mark) Modified event on 7/2/2020 (znmw). (Entered: 06/30/2020) |
| Jul 1, 2020 | MINUTE ORDER: In light of Plaintiffs' motion for leave to file supplemental complaint, Dkt. 25 , it is hereby ORDERED that Defendants shall respond to the motion on or before July 8, 2020. Signed by Judge Randolph D. Moss on 7/1/2020. (lcrdm1) (Entered: 07/01/2020) | ||
| Jul 1, 2020 | MINUTE ORDER: In light of Defendants' motion to dismiss, Dkt. 15 , and the subsequent briefing, the Court concludes that oral argument would be beneficial in deciding the pending motion. It is therefore ORDERED that the parties shall appear telephonically for oral argument on August 4, 2020 at 10:00 a.m. Signed by Judge Randolph D. Moss on 7/1/2020. (lcrdm1) (Entered: 07/01/2020) | ||
| 26 | Jul 8, 2020 | View | Memorandum in opposition to re 25 MOTION for Leave to File Supplemental Complaint filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit)(DiPompeo, Christopher) (Entered: 07/08/2020) |
| 27 | Jul 15, 2020 | View | REPLY to opposition to motion re 25 MOTION for Leave to File Supplemental Complaint filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Savignac, Mark) (Entered: 07/15/2020) |
| Aug 4, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Motion Hearing held on 8/4/2020 re: 15 MOTION to Dismiss filed by JONES DAY, STEPHEN J. BROGAN, BETH HEIFETZ. Matter TAKEN UNDER ADVISEMENT. Defendants' oral motion to withdraw their 22 Memorandum in opposition to Plaintiffs' Motion for Leave to File Surreply is GRANTED, and DEEMED WITHDRAWN; Plaintiffs' 21 Motion for Leave to File Surreply is GRANTED. By 8/11/2020, Plaintiffs shall file the work sharing agreement and any other materials that they believe should be considered, if the Court considers Defendants' motion as a motion for summary judgment on Sheketoff's exhaustion of her Title VII claim; By 8/11/2020, Defendants shall file anything else that they wish the Court to consider if it treats their motion on that subject as one for summary judgment. (Court Reporter: Jeff Hook.) (kt) (Entered: 08/04/2020) | ||
| 28 | Aug 4, 2020 | View | SURREPLY to re 15 MOTION to Dismiss filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (ztd) (Entered: 08/07/2020) |
| 29 | Aug 7, 2020 | View | TRANSCRIPT OF TELEPHONIC MOTION HEARING before Judge Randolph D. Moss held on August 4, 2020. Page Numbers: 1 - 82. Date of Issuance: August 7, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/28/2020. Redacted Transcript Deadline set for 9/7/2020. Release of Transcript Restriction set for 11/5/2020.(Hook, Jeff) (Entered: 08/07/2020) |
| 30 | Aug 11, 2020 | View | SUPPLEMENTAL MEMORANDUM to re 15 MOTION to Dismiss Regarding Title VII Exhaustion, filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit 1 - Charge, # 2 Exhibit 2 - Notice)(Bailey, Anderson) (Entered: 08/11/2020) |
| 31 | Aug 11, 2020 | View | SUPPLEMENTAL MEMORANDUM to re 15 MOTION to Dismiss Opposition to Motion to Dismiss filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Declaration of Julia Sheketoff, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I)(SHEKETOFF, JULIA) Modified to add link on 8/13/2020 (znmw). (Entered: 08/11/2020) |
| 32 | Sep 4, 2020 | View | MEMORANDUM OPINION AND ORDER: For the reasons stated in the accompanying Memorandum Opinion and Order, Dkt. 32 , it is hereby ORDERED that Defendants' motion to dismiss, Dkt. 15 , is GRANTED in part and DENIED in part. Signed by Judge Randolph D. Moss on 09/04/2020. (lcrdm1) Modified on 9/4/2020 to add "Memorandum Opinion" in front of entry (kt). (Entered: 09/04/2020) |
| 33 | Sep 9, 2020 | View | MOTION for Reconsideration re 32 Order on Motion to Dismiss, by JULIA SHEKETOFF (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 09/09/2020) |
| Sep 10, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for reconsideration, Dkt. 33 , it is hereby ORDERED that Defendants shall file a response, if any, on or before September 18, 2020, and Plaintiffs shall file a reply, if any, on or before September 22, 2020. Signed by Judge Randolph D. Moss on 09/10/2020. (lcrdm1) (Entered: 09/10/2020) | ||
| 34 | Sep 16, 2020 | View | Consent MOTION for Extension of Time to File Response/Reply as to 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Attachments: # 1 Text of Proposed Order)(Bailey, Anderson) (Entered: 09/16/2020) |
| Sep 17, 2020 | MINUTE ORDER: Upon consideration of Defendant's Consent Motion for Extension of Time, Dkt. 34 , to respond to Plaintiffs' Motion for Reconsideration 33 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant shall respond to Plaintiff's Motion for Reconsideration on or before September 28, 2020, and Plaintiffs shall file a reply, if any, on or before October 5, 2020. Signed by Judge Randolph D. Moss on 09/17/2020. (lcrdm1) (Entered: 09/17/2020) | ||
| 35 | Sep 18, 2020 | View | ANSWER to 1 Complaint with Jury Demand by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY.(Lovitt, Traci) (Entered: 09/18/2020) |
| 36 | Sep 28, 2020 | View | Memorandum in opposition to re 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit - Response to Amica Brief)(Lovitt, Traci) (Entered: 09/28/2020) |
| 37 | Sep 30, 2020 | View | MOTION for Extension of Time to File Response/Reply as to 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, by JULIA SHEKETOFF (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 09/30/2020) |
| Sep 30, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for extension of time to file a reply as to the motion to reconsider, Dkt. 37 , it is hereby ORDERED that Defendants shall file their partial opposition to this motion on or before October 2, 2020, at 5:00 p.m. Signed by Judge Randolph D. Moss on 09/30/2020. (lcrdm1) (Entered: 09/30/2020) | ||
| 38 | Sep 30, 2020 | View | RESPONSE re 37 MOTION for Extension of Time to File Response/Reply as to 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit)(Lovitt, Traci) (Entered: 09/30/2020) |
| Oct 1, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for an extension of time to file a reply for motion to reconsider, Dkt. 37 , and Defendants' response agreeing to the extension, Dkt. 38 , the motion is hereby GRANTED. Plaintiffs are ORDERED to file a reply on or before October 19, 2020. Signed by Judge Randolph D. Moss on 10/01/2020. (lcrdm1) (Entered: 10/01/2020) | ||
| 39 | Oct 1, 2020 | View | REPLY to opposition to motion re 37 MOTION for Extension of Time to File Response/Reply as to 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, filed by JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 10/01/2020) |
| 40 | Oct 19, 2020 | View | REPLY to opposition to motion re 33 MOTION for Reconsideration re 32 Order on Motion to Dismiss, filed by JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 10/19/2020) |
| 41 | Jan 18, 2021 | View | MOTION for Hearing Request for Pre-Motion Conference on Plaintiffs' Motion for Partial Summary Judgment by MARK C. SAVIGNAC, JULIA SHEKETOFF (Savignac, Mark) Modified event on 1/21/2021 (znmw). (Entered: 01/18/2021) |
| Jan 19, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' notice of request for a pre-motion conference, Dkt. 41 , it is hereby ORDERED that the parties shall file pre-motion statements on or before February 23, 2021, and shall appear telephonically for a pre-motion conference on March 2, 2021 at 3:30 p.m. Parties may use the same teleconference number and access code previously used in this case. Signed by Judge Randolph D. Moss on 01/19/2021. (lcrdm1) (Entered: 01/19/2021) | ||
| 42 | Feb 11, 2021 | View | ORDER GRANTING LEAVE TO FILE: Upon consideration of Plaintiffs' motion for leave to file a supplemental complaint, Dkt. 25 , and for the reasons set forth in the attached order, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that the supplemental complaint, Dkt. 25-1, is deemed FILED. The Court further ORDERS Defendants Jones Day and Stephen Brogan to respond to the supplemental complaint on or before March 5, 2021. See attached document for details. Signed by Judge Randolph D. Moss on 02/11/2021. (lcrdm1) (Entered: 02/11/2021) |
| 43 | Feb 11, 2021 | View | AMENDED COMPLAINT against STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, JOHN DOES 1-10 with Jury Demand filed by MARK C. SAVIGNAC, JULIA SHEKETOFF.(ztd) (Entered: 02/12/2021) |
| 44 | Feb 23, 2021 | View | RESPONSE to Defendants' Pre-Motion Statement 41 , by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (Lovitt, Traci) Modified linkage and text on 2/25/2021 (ztd). (Entered: 02/23/2021) |
| Mar 2, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Pre-motion Conference held on 3/2/2021. Rule 16 report due by 4/22/2021. Telephonic Initial Scheduling Conference set for 5/7/2021, at 9:00 AM, before Judge Randolph D. Moss. The parties shall utilize the same teleconference number and access code. (Court Reporter Jeff Hook.) (kt) (Entered: 03/02/2021) | ||
| 45 | Mar 5, 2021 | View | ANSWER to 43 Amended Complaint by STEPHEN J. BROGAN, JONES DAY.(Lovitt, Traci) (Entered: 03/05/2021) |
| 46 | Apr 22, 2021 | View | MEET AND CONFER STATEMENT. (Attachments: # 1 Text of Proposed Order Proposed Order)(SHEKETOFF, JULIA) (Entered: 04/22/2021) |
| 47 | Apr 28, 2021 | View | MEMORANDUM OPINION AND ORDER granting in part and denying in part Plaintiffs' Motion for Reconsideration, Dkt. 33 . Plaintiffs may file an amended complaint addressing the deficiency in pleadings as to the EPA claim (Count V) on or before May 12, 2021. See attached document for details. Signed by Judge Randolph D. Moss on 04/28/2021. (lcrdm1) Modified on 4/29/2021 to change document type to "opinion". (kt). (Entered: 04/28/2021) |
| May 7, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Initial Scheduling Conference held on 5/7/2021. Document Discovery to close by 9/3/2021; Fact Discovery to close by 12/3/2021; Proponent's Expert Disclosures due by 1/7/2022; Opponent's Expert Disclosures due by 2/4/2022; Expert Discovery to close by 3/4/2022; Pre-Motion Statement, in advance of any motion for summary judgment, due by 3/11/2022; Opposition due by 3/18/2022. A Status Conference/Pre-motion Conference is set for 3/22/2022, at 10:30 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter Jeff Hook.) (kt) (Entered: 05/07/2021) | ||
| 48 | May 12, 2021 | View | AMENDED COMPLAINT against All Defendants with Jury Demand filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix Redline)(SHEKETOFF, JULIA) (Entered: 05/12/2021) |
| May 26, 2021 | NOTICE of Hearing: Telephone Conference set for 6/4/2021, at 3:00 PM, before Judge Randolph D. Moss. The parties shall utilize the same teleconference number and access code.(kt) (Entered: 05/26/2021) | ||
| 49 | May 26, 2021 | View | ANSWER to 48 Amended Complaint by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY.(Lovitt, Traci) (Entered: 05/26/2021) |
| 50 | Jun 1, 2021 | View | NOTICE re Conference on Draft Proposed Protective Order by MARK C. SAVIGNAC, JULIA SHEKETOFF (Attachments: # 1 Exhibit A - Proposed Protective Order, # 2 Exhibit B - Email Chain With Jones Day)(SHEKETOFF, JULIA) (Entered: 06/01/2021) |
| 51 | Jun 2, 2021 | View | RESPONSE re 50 Notice (Other) filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit 1 - Proposed Protective Order)(Bailey, Anderson) (Entered: 06/02/2021) |
| Jun 4, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 6/4/2021. Issues addressed. For the reasons stated on the record, by Monday Plaintiffs shall email documents for in camera review; Defendants' counsel are ordered not to disclose those documents. Joint Status report due one week from today. (Court Reporter: Jeff Hook.) (kt) (Entered: 06/04/2021) | ||
| 52 | Jun 7, 2021 | View | TRANSCRIPT OF TELEPHONIC MOTION HEARING before Judge Randolph D. Moss held on March 2, 2021. Page Numbers: 1 - 35. Date of Issuance: June 7, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court rep orter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 6/28/2021. Redacted Transcript Deadline set for 7/8/2021. Release of Transcript Restriction set for 9/5/2021.(Hook, Jeff) (Entered: 06/07/2021) |
| 53 | Jun 11, 2021 | View | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on June 4, 2021. Page Numbers: 1 - 80. Date of Issuance: June 11, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 7/2/2021. Redacted Transcript Deadline set for 7/12/2021. Release of Transcript Restriction set for 9/9/2021.(Hook, Jeff) (Entered: 06/11/2021) |
| 54 | Jun 11, 2021 | View | Joint STATUS REPORT re Disputes Over Protective Order by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 06/11/2021) |
| Jun 15, 2021 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 54 , it is hereby ORDERED that the parties shall adhere to the following schedule: Plaintiffs shall file a brief in support of their proposed protective order on or before June 18, 2021, and Defendants shall file an opposing brief on or before June 28, 2021. It is further ORDERED that the parties shall file their briefs on the public docket with any redactions necessary to maintain the confidentiality of the communications that Plaintiffs submitted for in camera review and that the parties shall submit unredacted versions for in camera review via email to the Court Deputy. Signed by Judge Randolph D. Moss on 06/15/2021. (lcrdm1) (Entered: 06/15/2021) | ||
| 55 | Jun 16, 2021 | View | RESPONSE to Minute Order to Protect Jones Day Employees by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix, # 2 Text of Proposed Order)(SHEKETOFF, JULIA) Modified text on 6/17/2021 (ztd). (Entered: 06/16/2021) |
| 56 | Jun 28, 2021 | View | RESPONSE re 55 MOTION for Protective Order to Protect Jones Day Employees filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Bailey, Anderson) (Entered: 06/28/2021) |
| Jul 2, 2021 | NOTICE of Hearing: Telephone Conference (discovery dispute) set for 7/20/2021, at 2:00 PM, before Judge Randolph D. Moss. The parties shall use the same teleconference number and access code previously provided.(kt) (Entered: 07/02/2021) | ||
| 57 | Jul 16, 2021 | View | Joint MOTION for Protective Order and Notice of ESI Stipulation by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Proposed Protective Order, # 2 ESI Stipulation)(Bailey, Anderson) (Entered: 07/16/2021) |
| 58 | Jul 16, 2021 | View | PROTECTIVE ORDER: Upon consideration of the parties' joint motion for the Court to enter a protective order, Dkt. 57 , it is hereby ORDERED that the motion is GRANTED. See attached document for details. The parties' submission appears to moot any remaining dispute regarding the protective order. But to the extent that the parties continue to dispute whether the protective order should contain a separate provision allowing an "attorney's eyes only" designation, Dkt. 55 ; Dkt. 56 , the Court concludes that Plaintiffs have failed to demonstrate that such a provision is appropriate pursuant to Doe v. District of Columbia, 697 F.2d 1115 (D.C. Cir. 1983). As the D.C. Circuit explained in that case, "every litigant has a powerful interest in being able to retain and consult freely with an attorney." Id. at 1119. Nonetheless, a court may restrain that exchange of information by entering an attorney's-eyes-only protective order "when serious harm to a party or to the community cannot be avoided without either forbidding discovery altogether or curtailing communication between one of the litigants and his attorney regarding discovered materials." Id. at 1120. But "the [C]ourt must be confident that the potential injury is substantial and cannot be prevented through the use of any device less restrictive of a party's access to his lawyer." Id. In other words, the Court may only enter a protective order that satisfies "three criteria: 1 the harm posed by disclosure must be substantial and serious; 2 the restraining order must be narrowly drawn and precise; and 3 there must be no alternative means of protecting the public interest which intrudes less directly on attorney-client relations." Id. (quoting In re Halkin, 598 F.2d 176, 191 (D.C. Cir. 1979)). Here, the Court is unpersuaded that providing the named defendants and their designated representatives with sensitive discovery materials pursuant to the agreed-upon protective order, including all limitations contained therein, poses a risk of serious harm sufficient to justify the limitations that Plaintiffs sought in the parties' Joint Status Report Regarding Dispute Over Protective Order, Dkt. 54 . The concerns that Plaintiffs raise are unduly speculative to overcome the "powerful interest in being able to... consult freely with an attorney." Doe, 697 F.2d at 1119. Signed by Judge Randolph D. Moss on 07/16/2021. (lcrdm1) (Main Document 58 replaced on 7/19/2021 to remove the word "Proposed" at the top of the order) (kt). (Entered: 07/16/2021) |
| 62 | Jul 16, 2021 | View | NOTICE by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (ztd); (See docket entry no. 57 to view.) (Entered: 07/20/2021) |
| 59 | Jul 19, 2021 | View | NOTICE Regarding Mootness of Motion for Protective Order by MARK C. SAVIGNAC, JULIA SHEKETOFF re 58 Order on Motion for Protective Order,,,,,,,,,, (SHEKETOFF, JULIA) (Entered: 07/19/2021) |
| 60 | Jul 19, 2021 | Request | REDACTED NOTICE Regarding July 20 Conference on Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF (SHEKETOFF, JULIA) Modified text on 7/20/2021 (ztd). (Entered: 07/19/2021) |
| 61 | Jul 19, 2021 | Request | SEALED DOCUMENT filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Notice)(ztd) (Entered: 07/19/2021) |
| Jul 20, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 7/20/2021. For the reasons stated on the record, Defendants shall supplement the discovery response. Defendants' brief due by 7/30/2021; Plaintiffs' opposition due by 8/17/2021; Defendants' final reply due by 8/27/2021. (Court Reporter: Jeff Hook.) (kt) (Entered: 07/20/2021) | ||
| 63 | Jul 23, 2021 | View | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on July 20, 2021. Page Numbers: 1 - 74. Date of Issuance: July 23, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporte r referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/13/2021. Redacted Transcript Deadline set for 8/23/2021. Release of Transcript Restriction set for 10/21/2021.(Hook, Jeff) (Entered: 07/23/2021) |
| Jul 27, 2021 | NOTICE of Hearing: Telephone Conference set for 7/29/2021, at 2:00 PM, by telephone, before Judge Randolph D. Moss. The parties shall utilize the same teleconference number and access code.(kt) (Entered: 07/27/2021) | ||
| 64 | Jul 28, 2021 | View | NOTICE Regarding July 29 Conference on Julia's Text Messages by MARK C. SAVIGNAC, JULIA SHEKETOFF (SHEKETOFF, JULIA) (Entered: 07/28/2021) |
| 65 | Jul 28, 2021 | Request | Consent MOTION for Extension of Time to Brief Discovery Disputes by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Text of Proposed Order)(Bailey, Anderson) (Entered: 07/28/2021) |
| Jul 28, 2021 | MINUTE ORDER: Upon consideration of Defendants' consent motion for extension of time, Dkt. 65 , it is hereby ORDERED that the motion is GRANTED. The parties shall adhere to the following schedule: Defendants' opening brief on the discovery issues ripe for briefing shall be due on or before August 3, 2021; Plaintiffs' response brief shall be due on or before August 21, 2021; and Defendants' reply brief shall be due on or before August 27, 2021. Signed by Judge Randolph D. Moss on 07/28/2021. (lcrdm1) (Entered: 07/28/2021) | ||
| Jul 29, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 7/29/2021. For the reasons stated on the record, the parties are to meet and confer. (Court Reporter: Jeff Hook.) (kt) (Entered: 07/29/2021) | ||
| 66 | Aug 3, 2021 | View | MEMORANDUM by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Chase, Terri) (Entered: 08/03/2021) |
| 67 | Aug 16, 2021 | Request | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on July 29, 2021. Page Numbers: 1 - 46. Date of Issuance: August 16, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court report er referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 9/6/2021. Redacted Transcript Deadline set for 9/16/2021. Release of Transcript Restriction set for 11/14/2021.(Hook, Jeff) (Entered: 08/16/2021) |
| 68 | Aug 21, 2021 | View | REDACTED DOCUMENT- Brief in Support of Discovery on Lost Wages and Punitive Damages by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix)(Savignac, Mark) (Entered: 08/21/2021) |
| 69 | Aug 21, 2021 | Request | SEALED MOTION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Appendix, # 2 Brief)(ztd) (Entered: 08/27/2021) |
| 70 | Aug 27, 2021 | View | REDACTED DOCUMENT- Reply Regarding Plaintiffs' Requests for Discovery on Partnership Information and Punitive Damages by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Chase, Terri) (Entered: 08/27/2021) |
| 71 | Aug 27, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Reply Regarding Plaintiffs' Requests for Discovery on Partnership Information and Punitive Damages, # 2 Exhibit A, # 3 Exhibit B)(Chase, Terri) (Entered: 08/27/2021) |
| Aug 30, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 69 , it is hereby ORDERED that the motion is GRANTED. Plaintiffs' brief in support of discovery and appendix thereto is hereby deemed FILED UNDER SEAL. Signed by Judge Randolph D. Moss on 08/30/2021. (lcrdm1) (Entered: 08/30/2021) | ||
| Aug 30, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion to file under seal, Dkt. 71 , it is hereby ORDERED that the motion is GRANTED. Defendants' reply and Exhibits A and B thereto are hereby deemed FILED UNDER SEAL. Signed by Judge Randolph D. Moss on 08/30/2021. (lcrdm1) (Entered: 08/30/2021) | ||
| 72 | Aug 30, 2021 | Request | SEALED DOCUMENT filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Appendix)(ztd) (Entered: 08/31/2021) |
| 73 | Aug 30, 2021 | Request | SEALED DOCUMENT (REPLY) filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit A)(ztd) (Entered: 08/31/2021) |
| 74 | Sep 1, 2021 | View | Joint MOTION for Extension of Time to Complete Document Discovery by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 09/01/2021) |
| 75 | Sep 1, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Motion for Leave to File Surreply, # 2 Exhibit Sealed Proposed Surreply, # 3 Text of Proposed Order)(Savignac, Mark) (Entered: 09/01/2021) |
| 76 | Sep 1, 2021 | View | MOTION for Leave to File Surreply in Support of Discovery on Lost Wages by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Exhibit Proposed Surreply, # 2 Text of Proposed Order)(Savignac, Mark) (Entered: 09/01/2021) |
| Sep 2, 2021 | NOTICE of Hearing: Telephone Conference (as to discovery dispute) set for 9/9/2021, at 3:00 PM, before Judge Randolph D. Moss. The parties shall utilize the teleconference number and access code previously used for telephonic hearings (kt) Modified on 9/2/2021 to add teleconference number instruction (kt). (Entered: 09/02/2021) | ||
| Sep 2, 2021 | MINUTE ORDER: Upon consideration of the parties' joint motion for an extension of time to complete discovery, Dkt. 74 , it is hereby ORDERED that the motion is GRANTED. The parties shall complete document discovery on or before October 15, 2021. Signed by Judge Randolph D. Moss on 09/02/2021. (lcrdm1) (Entered: 09/02/2021) | ||
| Sep 2, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file, Dkt. 75 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs' sealed motion for leave to file a surreply is hereby deemed FILED UNDER SEAL. Signed by Judge Randolph D. Moss on 09/02/2021. (lcrdm1) (Entered: 09/02/2021) | ||
| 80 | Sep 2, 2021 | View | SEALED MOTION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Surreply)(ztd) (Entered: 09/09/2021) |
| 77 | Sep 7, 2021 | Request | REDACTED DOCUMENT- Memorandum in Opposition to 76 MOTION for Leave to File Surreply in Support of Discovery on Lost Wages by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Chase, Terri) (Entered: 09/07/2021) |
| 78 | Sep 7, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Opposition to Plaintiffs' Motion for Leave to File a Surreply)(Chase, Terri) (Entered: 09/07/2021) |
| Sep 8, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 78 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendants' unredacted memorandum in opposition to Plaintiffs' motion for leave to file a surreply is hereby deemed FILED UNDER SEAL. Signed by Judge Randolph D. Moss on 09/08/2021. (lcrdm1) (Entered: 09/08/2021) | ||
| 79 | Sep 8, 2021 | Request | REPLY to opposition to motion re 76 MOTION for Leave to File Surreply in Support of Discovery on Lost Wages filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix)(SHEKETOFF, JULIA) (Entered: 09/08/2021) |
| 81 | Sep 8, 2021 | Request | SEALED OPPOSITION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY re 80 SEALED MOTION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (ztd) (Entered: 09/09/2021) |
| Sep 9, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 9/9/2021. Damages discovery is suspended. The Court's ruling on bifurcation is held in abeyance. The Court GRANTS Plaintiffs' 76 Motion for Leave to File Surreply in Support of Discovery on Lost Wages. (Court Reporter Jeff Hook.) (kt) Modified on 9/9/2021 to correct typos (kt). (Entered: 09/09/2021) | ||
| 82 | Sep 9, 2021 | View | SURREPLY filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (ztd) (Entered: 09/10/2021) |
| Sep 28, 2021 | NOTICE of Hearing: Telephone Conference re: discovery dispute set for 9/29/2021, at 11:00 AM, before Judge Randolph D. Moss. The parties shall use the same teleconference number and access code as before. (kt) (Entered: 09/28/2021) | ||
| Sep 29, 2021 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 9/29/2021. For the reasons stated on the record, the parties shall confer and file a joint status report by end of day today. (Court Reporter: Jeff Hook.) (kt) (Entered: 09/29/2021) | ||
| 83 | Sep 29, 2021 | View | Joint STATUS REPORT by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 09/29/2021) |
| Sep 30, 2021 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 83 , it is hereby ORDERED that the parties shall adhere to the following briefing schedule: Plaintiffs shall file their motion to compel on or before October 13, 2021. Defendants shall file their opposition on or before October 27, 2021. Plaintiffs shall file their reply by November 8, 2021. It is further ORDERED that Defendants shall file any motion to compel related to Plaintiffs' privilege and work product assertions on or before October 22, 2021. Plaintiffs shall file their opposition to any such motion on or before November 5, 2021. Defendants shall file their reply on or before November 15, 2021. Signed by Judge Randolph D. Moss on 09/30/2021. (lcrdm1) (Entered: 09/30/2021) | ||
| 84 | Oct 13, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Motion to Compel Production of Documents on Defendants' First Privilege Log, # 2 Appendix, # 3 Text of Proposed Order)(Savignac, Mark) (Entered: 10/13/2021) |
| 85 | Oct 13, 2021 | View | MOTION to Compel Production of Documents on Defendants' First Privilege Log by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix, # 2 Text of Proposed Order)(Savignac, Mark) (Entered: 10/13/2021) |
| 86 | Oct 14, 2021 | View | Joint MOTION for Extension of Time to Complete Document Discovery by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 10/14/2021) |
| Oct 15, 2021 | MINUTE ORDER: Upon consideration of the parties' joint motion for an extension of time, Dkt. 86 , it is hereby ORDERED that the motion is GRANTED. The parties are ORDERED to complete document discovery on or before October 22, 2021. Signed by Judge Randolph D. Moss on 10/15/2021. (lcrdm1) (Entered: 10/15/2021) | ||
| Oct 17, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 84 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 10/17/2021. (lcrdm1) (Entered: 10/17/2021) | ||
| 87 | Oct 18, 2021 | Request | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on September 9, 2021. Page Numbers: 1 - 52. Date of Issuance: October 18, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 11/8/2021. Redacted Transcript Deadline set for 11/18/2021. Release of Transcript Restriction set for 1/16/2022.(Hook, Jeff) (Entered: 10/18/2021) |
| 88 | Oct 18, 2021 | Request | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on September 29, 2021. Page Numbers: 1 - 15. Date of Issuance: October 18, 2021. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 11/8/2021. Redacted Transcript Deadline set for 11/18/2021. Release of Transcript Restriction set for 1/16/2022.(Hook, Jeff) (Entered: 10/18/2021) |
| Oct 22, 2021 | MINUTE ORDER: The parties have contacted the Courtroom Deputy Clerk to request a telephone conference with the Court concerning certain ongoing discovery disputes in this case. Upon consideration of the parties' request, it is hereby ORDERED that the parties shall promptly meet and confer regarding all outstanding discovery disputes and shall file a joint status report on or before November 15, 2021, describing any remaining, unresolved disputes and describing in detail the parties' efforts to resolve those disputes. After receiving the parties' report, the Court will, if necessary, set a telephone conference to provide guidance to the parties. The parties are ordered, however, to do their best amicably to resolve their discovery disputes without the need for ongoing judicial intervention. Signed by Judge Randolph D. Moss on 10/22/2021. (lcrdm1) (Entered: 10/22/2021) | ||
| 89 | Oct 22, 2021 | View | REDACTED DOCUMENT- Motion to Compel by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Exhibit A (Proposed Order), # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Chase, Terri) (Entered: 10/22/2021) |
| 90 | Oct 22, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Motion to Compel, # 2 Exhibit A (Proposed Order), # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F)(Chase, Terri) (Entered: 10/22/2021) |
| Oct 26, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 90 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 10/26/2021. (lcrdm1) (Entered: 10/26/2021) | ||
| 91 | Oct 26, 2021 | Request | SEALED MOTION to Compel filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit A (Proposed Order), # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(znmw) (Entered: 10/27/2021) |
| 92 | Oct 27, 2021 | View | REDACTED DOCUMENT- Opposition to 85 MOTION to Compel Production of Documents on Defendants' First Privilege Log by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Appendix)(Chase, Terri) (Entered: 10/27/2021) |
| 93 | Oct 27, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Opposition to Motion to Compel, # 2 Appendix)(Chase, Terri) (Entered: 10/27/2021) |
| Oct 29, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 93 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 10/29/2021. (lcrdm1) (Entered: 10/29/2021) | ||
| 94 | Oct 29, 2021 | Request | SEALED OPPOSITION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY re 85 MOTION to Compel Production of Documents on Defendants' First Privilege Log (Attachments: # 1 Appendix)(znmw) (Entered: 11/01/2021) |
| 95 | Nov 3, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Reply in Support of Motion to Compel, # 2 Appendix)(Savignac, Mark) (Entered: 11/03/2021) |
| 96 | Nov 3, 2021 | View | REPLY to opposition to motion re 85 MOTION to Compel Production of Documents on Defendants' First Privilege Log filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix)(Savignac, Mark) (Entered: 11/03/2021) |
| Nov 5, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 95 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 11/5/2021. (lcrdm1) (Entered: 11/05/2021) | ||
| 97 | Nov 5, 2021 | Request | SEALED REPLY TO OPPOSITION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF re 91 SEALED MOTION to Compel filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Appendix)(znmw) (Entered: 11/05/2021) |
| 98 | Nov 5, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Opposition to Motion to Compel, # 2 Text of Proposed Order)(Savignac, Mark) (Entered: 11/05/2021) |
| 99 | Nov 5, 2021 | View | Memorandum in opposition to re 91 SEALED MOTION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(Savignac, Mark) (Entered: 11/05/2021) |
| Nov 9, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 98 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 11/9/2021. (lcrdm1) (Entered: 11/09/2021) | ||
| 100 | Nov 9, 2021 | Request | SEALED OPPOSITION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF re 91 SEALED MOTION to Compel filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (znmw) Modified date filed on 11/9/2021 (znmw). (Entered: 11/09/2021) |
| 101 | Nov 15, 2021 | View | Joint STATUS REPORT Regarding Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 11/15/2021) |
| 102 | Nov 15, 2021 | View | REDACTED DOCUMENT- Reply to 91 SEALED MOTION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Chase, Terri) (Entered: 11/15/2021) |
| 103 | Nov 15, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Reply in Support of Motion to Compel)(Chase, Terri) (Entered: 11/15/2021) |
| 104 | Nov 15, 2021 | View | REDACTED DOCUMENT- Motion for Leave to File Surreply in Opposition to 85 MOTION to Compel Production of Documents on Defendants' First Privilege Log by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Attachments: # 1 Supplemental Appendix, # 2 Text of Proposed Order)(Chase, Terri) (Entered: 11/15/2021) |
| 105 | Nov 15, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Motion for Leave to File Surreply in Opposition to Plaintiffs' Motion to Compel, # 2 Supplemental Appendix, # 3 Text of Proposed Order)(Chase, Terri) (Entered: 11/15/2021) |
| Nov 17, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 103 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 11/17/2021. (lcrdm1) (Entered: 11/17/2021) | ||
| Nov 17, 2021 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 105 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 11/17/2021. (lcrdm1) (Entered: 11/17/2021) | ||
| 106 | Nov 17, 2021 | Request | SEALED REPLY TO OPPOSITION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY re 91 SEALED MOTION to Compel. (This document is SEALED and only available to authorized persons.) (znmw) (Entered: 11/18/2021) |
| 107 | Nov 17, 2021 | Request | SEALED MOTION for Leave to File Surreply filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Surreply, # 2 Supplemental Appendix, # 3 Text of Proposed Order)(znmw) (Attachment 1 replaced on 11/18/2021) (znmw). (Entered: 11/18/2021) |
| 108 | Nov 23, 2021 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Opposition to Defendants' Motion for Leave to File Surreply)(Savignac, Mark) (Entered: 11/23/2021) |
| 109 | Nov 23, 2021 | View | Memorandum in opposition to re 107 SEALED MOTION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Savignac, Mark) (Entered: 11/23/2021) |
| Nov 24, 2021 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 108 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 11/24/2021. (lcrdm1) (Entered: 11/24/2021) | ||
| 110 | Nov 24, 2021 | Request | SEALED OPPOSITION filed by MARK C. SAVIGNAC, JULIA SHEKETOFF re 107 SEALED MOTION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (znmw) (Entered: 12/02/2021) |
| 111 | Dec 2, 2021 | Request | Joint MOTION for Extension of Time to Complete Discovery by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 12/02/2021) |
| Dec 5, 2021 | MINUTE ORDER: Upon consideration of the parties' joint motion for an extension of time to complete discovery, Dkt. 111 , it is hereby ORDERED that the motion is GRANTED and that the parties shall adhere to the following revised schedule: Fact discovery shall close on April 4, 2022. Proponent's expert disclosures shall be due on May 2, 2022. Opponent's expert disclosures shall be due on May 31, 2022. Expert discovery shall close on June 27, 2022. The parties shall file any pre-motion statements in advance of motions for summary judgment on or before July 1, 2022, and any responses thereto on or before July 11, 2022. It is further ORDERED that the status and pre-motion conference set for March 22, 2022, is hereby VACATED and RESCHEDULED for July 22, 2022, at 10:00 a.m., in Courtroom 8. Signed by Judge Randolph D. Moss on 12/5/2021. (lcrdm1) (Entered: 12/05/2021) | ||
| Dec 6, 2021 | Set/Reset Hearings: Status Conference set for 7/22/2022 at 10:00 AM before Judge Randolph D. Moss. (kt) (Entered: 12/06/2021) | ||
| 112 | Dec 20, 2021 | View | MOTION for Remote Depositions in Light of Ongoing Pandemic by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix, # 2 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 12/20/2021) |
| 113 | Dec 20, 2021 | View | RESPONSE re 112 MOTION for Remote Depositions in Light of Ongoing Pandemic filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (Chase, Terri) (Entered: 12/20/2021) |
| 114 | Dec 21, 2021 | View | REPLY to opposition to motion re 112 MOTION for Remote Depositions in Light of Ongoing Pandemic filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 12/21/2021) |
| Dec 21, 2021 | MINUTE ORDER: In light of Defendant's motion for remote depositions, Dkt. 112 , it is hereby ORDERED that the parties shall meet and confer regarding whether depositions can be conducted remotely and file a joint status report informing the Court of their respective positions on or before 3:00 p.m. on December 23, 2021. Signed by Judge Randolph D. Moss on 12/21/2021. (lcrdm1) (Entered: 12/21/2021) | ||
| 115 | Dec 23, 2021 | View | Joint STATUS REPORT re Remote Depositions by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 12/23/2021) |
| Dec 23, 2021 | MINUTE ORDER: In light of the parties' joint status report, Dkt. 115 , it is hereby ORDERED that Plaintiffs' motion for remote depositions, Dkt. 112 , is DENIED as MOOT. Signed by Judge Randolph D. Moss on 12/23/2021. (lcrdm1) (Entered: 12/23/2021) | ||
| 116 | Jan 19, 2022 | View | AMENDED COMPLAINT (SECOND) (With Defendants' Consent) against STEPHEN J. BROGAN, JOHN DOES 1-10, BETH HEIFETZ, JONES DAY, Michael Shumaker with Jury Demand filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Exhibit Redline Against First Amended Complaint)(Savignac, Mark) (Entered: 01/19/2022) |
| 117 | Jan 19, 2022 | Request | WAIVER OF SERVICE. MICHAEL SHUMAKER waiver sent on 1/19/2022, answer due 3/20/2022. (Savignac, Mark) (Entered: 01/19/2022) |
| Jan 20, 2022 | MINUTE ORDER: In light of the pending motions to compel before the Court, Dkt. 85 and Dkt. 91 , the parties are hereby ORDERED to appear by video for a motions hearing before Judge Randolph D. Moss at 2:00 p.m. on January 31, 2022. The parties may obtain access information for the video teleconference from the Courtroom Deputy Clerk. Signed by Judge Randolph D. Moss on 1/20/2022. (lcrdm1) (Entered: 01/20/2022) | ||
| Jan 31, 2022 | Minute Entry for proceedings held before Judge Randolph D. Moss: Video (Zoom) Motion Hearing held on 1/31/2022 re: 85 MOTION to Compel Production of Documents on Defendants' First Privilege Log filed by MARK C. SAVIGNAC, JULIA SHEKETOFF, and 91 SEALED MOTION to Compel filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. Plaintiffs' 85 Motion to Compel Production of Documents on Defendants' First Privilege Log is GRANTED IN PART and DENIED IN PART; The Court will refer the issue to a Magistrate Judge for ex parte, in camera review of the documents discussed on the record; Order forthcoming. Defendants' 91 SEALED MOTION to Compel is GRANTED IN PART, DENIED IN PART, and DEFERRED IN PART, for the reasons stated on the record; Order forthcoming. Plaintiffs' shall file a notice with the Court on or before 2/7/2022, as to how many documents are at issue regarding spousal privilege. The parties shall continue to meet and confer, and file a Joint Status Report by 2/7/2022. (Court Reporter: Janice Dickman.) (kt) (Entered: 01/31/2022) | ||
| Feb 1, 2022 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file a surreply, Dkt. 107 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 2/1/2022. (lcrdm1) (Entered: 02/01/2022) | ||
| 118 | Feb 1, 2022 | Request | SEALED SURREPLY filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, MICHAEL SHUMAKER re 91 SEALED MOTION to Compel filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Supplemental Appendix)(znmw) (Entered: 02/01/2022) |
| Feb 1, 2022 | MINUTE ORDER: For the reasons stated on the record at the January 31, 2022 Motions Hearing, it is hereby ORDERED that Plaintiffs' motion to compel, Dkt. 85 , is REFERRED for random assignment to a magistrate judge to conduct ex parte, in camera review of documents JD_PRIV_0003 through JD_PRIV_0043 of Defendants' first privilege log and JD_PRIV_0117 of Defendants' second privilege log to determine whether those documents fall within the asserted privileges. The magistrate judge may consider the parties' briefing to facilitate his or her review, see Dkt. 84 ; Dkt. 94 ; Dkt. 97 , but shall not otherwise receive argument from the parties. If the magistrate judge determines in the course of review that additional factual context is needed to assess whether a given document is privileged, he or she may order that Jones Day's administrative partner, Michael Shumaker, appear for an ex parte hearing before the magistrate judge for the purpose of answering the magistrate judge's questions regarding the document. Although counsel for Defendants may attend such a hearing, they are not permitted to offer any ex parte argument to the magistrate judge or to question Mr. Shumaker. After reviewing the relevant documents, the magistrate judge shall file an ex parte report and recommendation with the Court setting forth his or her recommendations and reasons for those recommendations, but without disclosing the content of any of the communications at issue. Signed by Judge Randolph D. Moss on 2/1/2022. (lcrdm1) (Entered: 02/01/2022) | ||
| Feb 1, 2022 | CASE RANDOMLY REFERRED to Magistrate Judge Zia M. Faruqui for Report & Recommendation. (znmg) (Entered: 02/03/2022) | ||
| 119 | Feb 2, 2022 | View | ANSWER to 116 Amended Complaint, by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY.(Chase, Terri) (Entered: 02/02/2022) |
| 120 | Feb 4, 2022 | View | Consent MOTION to Clarify re Order,,,,,,, Order Referring Case to Magistrate Judge,,,,,, by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, MICHAEL SHUMAKER. (Chase, Terri) (Entered: 02/04/2022) |
| Feb 4, 2022 | MINUTE ORDER: Upon consideration of the parties' consent motion to clarify the Court's order referring the case to a magistrate judge, Dkt. 120 , it is hereby ORDERED that the motion is GRANTED. The Court hereby clarifies its February 1, 2022 order to permit the magistrate judge to consider the parties' filings at Dkt. 84, Dkt. 94, Dkt, 95, and Dkt. 118 in reaching a decision on the matter submitted for in camera review, as well as a transcript of the January 31, 2022 hearing. The Court further clarifies that the matter has been referred to the magistrate judge for a decision subject to potential objections in accordance with Federal Rule of Civil Procedure 72(a), and that the magistrate judge is authorized to disclose his reasoning to the parties, so long as he does not disclose the content of any assertedly privileged communications. Signed by Judge Randolph D. Moss on 2/4/2022. (lcrdm1) (Entered: 02/04/2022) | ||
| 121 | Feb 7, 2022 | View | Joint STATUS REPORT Regarding Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 02/07/2022) |
| 122 | Feb 7, 2022 | View | NOTICE in Response to Order of January 31, 2022 by MARK C. SAVIGNAC, JULIA SHEKETOFF (SHEKETOFF, JULIA) (Entered: 02/07/2022) |
| Feb 7, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 121 , it is hereby ORDERED that the parties shall file a further joint status report on or before February 14, 2022, advising the Court whether they have resolved any of their outstanding disputes. Signed by Judge Randolph D. Moss on 2/7/2022. (lcrdm1) (Entered: 02/07/2022) | ||
| 123 | Feb 14, 2022 | View | Joint STATUS REPORT Regarding Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 02/14/2022) |
| Feb 15, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 123 , it is hereby ORDERED that the parties shall file a further joint status report on or before February 22, 2022. Signed by Judge Randolph D. Moss on 2/15/2022. (lcrdm1) (Entered: 02/15/2022) | ||
| 124 | Feb 20, 2022 | View | MEMORANDUM OPINION AND ORDER: For the reasons stated in the attached Memorandum Opinion and Order, it is hereby ORDERED that Defendants' motion to compel, Dkt. 91, is GRANTED in part with respect to Interrogatory No. 1, and Plaintiffs are hereby ORDERED to respond to Interrogatory No. 1 and to identify each person with whom Plaintiffs conferred or consulted regarding Jones Day's parental and/or disability leave policies at any time prior to Plaintiffs' January 16, 2019 email to Jones Day, including those individuals referenced in that email as "other competent attorneys." Signed by Judge Randolph D. Moss on 2/20/2022. (lcrdm1) (Entered: 02/20/2022) |
| 125 | Feb 22, 2022 | View | Joint STATUS REPORT Regarding Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 02/22/2022) |
| Feb 22, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 125 , it is hereby ORDERED that the parties shall file a further joint status report on or before February 28, 2022. Signed by Judge Randolph D. Moss on 2/22/2022. (lcrdm1) (Entered: 02/22/2022) | ||
| 126 | Feb 23, 2022 | View | STRICKEN PURSUANT TO MEMORANDUM OPINION AND ORDER FILED ON 5/12/2022.....AMENDED COMPLAINT (THIRD) against STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, MICHAEL SHUMAKER, Traci Lovitt with Jury Demand filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Exhibit Redline Against Prior Pleadings)(Savignac, Mark) Modified on 5/13/2022 (kt). (Entered: 02/23/2022) |
| 127 | Feb 28, 2022 | View | Joint STATUS REPORT Regarding Discovery Disputes by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 02/28/2022) |
| Feb 28, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 127 , it is hereby ORDERED that the parties' dispute with respect to items 3 and 5 of their November 15, 2021 Joint Status Report, Dkt. 101 , shall be referred to Magistrate Judge Zia M. Faruqui to issue a decision subject to potential objections in accordance with Federal Rule of Civil Procedure 72(a). Signed by Judge Randolph D. Moss on 2/28/2022. (lcrdm1) (Entered: 02/28/2022) | ||
| Feb 28, 2022 | CASE DIRECTLY REFERRED to Magistrate Judge Zia M. Faruqui for discovery. (znmg) (Entered: 03/15/2022) | ||
| 128 | Mar 9, 2022 | View | MOTION to Strike 126 Amended Complaint, by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, TRACI LOVITT, MICHAEL SHUMAKER. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Chase, Terri) (Entered: 03/09/2022) |
| 129 | Mar 14, 2022 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Alison Frick, Filing fee $ 100, receipt number ADCDC-9101770. Fee Status: Fee Paid. by JULIA SHEKETOFF. (Attachments: # 1 Exhibit Declaration of Alison Frick, # 2 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 03/14/2022) |
| Mar 15, 2022 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for admission pro hac vice, Dkt. 129 , it is hereby ORDERED that the motion is GRANTED. ALISON FRICK is hereby granted leave to appear pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for Instructions. Signed by Judge Randolph D. Moss on 3/15/2022. (lcrdm1) (Entered: 03/15/2022) | ||
| 130 | Mar 16, 2022 | Request | NOTICE of Appearance by Alison E. Frick on behalf of MARK C. SAVIGNAC, JULIA SHEKETOFF (Frick, Alison) (Entered: 03/16/2022) |
| Mar 17, 2022 | Set/Reset Hearings: Discovery Conference set for 3/23/2022 at 10:00 AM before Magistrate Judge Zia M. Faruqui. (lcam) (Entered: 03/17/2022) | ||
| 131 | Mar 18, 2022 | Request | Joint MOTION for Extension of Time to Complete Discovery by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 03/18/2022) |
| Mar 18, 2022 | MINUTE ORDER: Upon consideration of the parties' joint motion for an extension of time to complete discovery, Dkt. 131 , it is hereby ORDERED that the motion is GRANTED; that all discovery deadlines are HELD IN ABEYANCE; and that, within seven days of the resolution of the parties' two discovery disputes by Magistrate Judge Faruqui, the parties shall meet and confer and file a joint status report proposing a revised discovery schedule. Signed by Judge Randolph D. Moss on 3/18/2022. (lcrdm1) (Entered: 03/18/2022) | ||
| 132 | Mar 18, 2022 | View | Memorandum in opposition to re 128 MOTION to Strike 126 Amended Complaint, filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Appendix)(znmw) (Entered: 03/21/2022) |
| Mar 23, 2022 | Minute Entry for proceedings held before Magistrate Judge Zia M. Faruqui: VTCDiscovery Hearing held on 3/23/2022. (Court Reporter FTR GOLD.)(FTR Time Frame: Ctrm 4 [10:27:20-11:14:13];) (bb) (Entered: 03/24/2022) | ||
| 133 | Mar 25, 2022 | View | REPLY to opposition to motion re 132 Memorandum in Opposition filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, TRACI LOVITT, MICHAEL SHUMAKER. (Chase, Terri) (Entered: 03/25/2022) |
| 134 | Apr 5, 2022 | Request | NOTICE of Change of Address by Alison E. Frick (Frick, Alison) (Entered: 04/05/2022) |
| 135 | Apr 14, 2022 | View | ORDER granting in part and denying in part Plaintiff's motion to compel, Dkt. 85 . Signed by Magistrate Judge Zia M. Faruqui on 04/14/2022. (lcam) (Entered: 04/14/2022) |
| 136 | Apr 21, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 04/21/2022) |
| Apr 22, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 136 , it is hereby ORDERED that the parties shall file a further joint status report on or before April 28, 2022. Signed by Judge Randolph D. Moss on 4/22/2022. (lcrdm1) (Entered: 04/22/2022) | ||
| Apr 22, 2022 | MINUTE ORDER. The Court conducted an in camera review of four additional documents produced by Defendants. Pursuant to the Court's Order, Dkt. 85 , the Court redacted privileged material and provided the redacted documents to Defendants. Defendants are ORDERED to produce the additional documents to Plaintiffs within 15 days. Signed by Magistrate Judge Zia M. Faruqui on 04/22/2022. (lcam) (Entered: 04/22/2022) | ||
| 137 | Apr 24, 2022 | View | Unopposed MOTION for Extension of Time to Object to Magistrate Judge Order by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Text of Proposed Order)(SHEKETOFF, JULIA) (Entered: 04/24/2022) |
| 138 | Apr 25, 2022 | Request | TRANSCRIPT OF PROCEEDINGS, before Magistrate Judge Zia M. Faruqui, held on 3-23-2022. Page Numbers: 1 - 35. Date of Issuance: 4-25-2022. Transcriber: Elizabeth SaintLoth, Telephone number: 202-354-3242. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced ab ove. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 5/16/2022. Redacted Transcript Deadline set for 5/26/2022. Release of Transcript Restriction set for 7/24/2022.(Saint-Loth, Elizabeth) (Entered: 04/25/2022) |
| Apr 26, 2022 | MINUTE ORDER: Upon consideration of Plaintiffs' unopposed motion to extend the time to object to the magistrate judge's order, Dkt. 137 , it is hereby ORDERED that the motion is GRANTED. Plaintiffs shall file any objections to the magistrate judge's April 14, 2022 order, Dkt. 135 , on or before May 4, 2022. Signed by Judge Randolph D. Moss on 4/26/2022. (lcrdm1) (Entered: 04/26/2022) | ||
| 139 | Apr 28, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 04/28/2022) |
| May 2, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 139 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 5, 2022. Signed by Judge Randolph D. Moss on 5/2/2022. (lcrdm1) (Entered: 05/02/2022) | ||
| 140 | May 4, 2022 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Objection to Magistrate Judge Order on In Camera Review)(Savignac, Mark) (Entered: 05/04/2022) |
| 141 | May 4, 2022 | View | Appeal of Magistrate Judge Decision to District Court by MARK C. SAVIGNAC, JULIA SHEKETOFF re 135 Order (Savignac, Mark) (Entered: 05/04/2022) |
| 142 | May 5, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 05/05/2022) |
| May 6, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 142 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 12, 2022. Signed by Judge Randolph D. Moss on 5/6/2022. (lcrdm1) (Entered: 05/06/2022) | ||
| 143 | May 12, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 05/12/2022) |
| May 12, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 143 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 19, 2022. Signed by Judge Randolph D. Moss on 5/12/2022. (lcrdm1) (Entered: 05/12/2022) | ||
| 144 | May 12, 2022 | View | MEMORANDUM OPINION AND ORDER: For the reasons set forth in the attached Memorandum Opinion and Order, Defendants' motion to strike, Dkt. 128 , is hereby GRANTED. The Clerk of Court is directed to STRIKE Plaintiffs' Third Amended Complaint, Dkt. 126 , from the docket. See document for details. Signed by Judge Randolph D. Moss on 5/12/2022. (lcrdm1) Modified on 5/13/2022 to change document type to "opinion" (kt). (Entered: 05/12/2022) |
| 145 | May 18, 2022 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, TRACI LOVITT, MICHAEL SHUMAKER (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Opposition to Objection to Magistrate Judge Faruqui Order on In Camera Review)(Chase, Terri) (Entered: 05/18/2022) |
| 146 | May 18, 2022 | View | Memorandum in opposition to re 140 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) REDACTED filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, TRACI LOVITT, MICHAEL SHUMAKER. (Chase, Terri) (Entered: 05/18/2022) |
| May 19, 2022 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 140 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 5/19/2022. (lcrdm1) (Entered: 05/19/2022) | ||
| 147 | May 19, 2022 | Request | SEALED DOCUMENT (Objection) filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 05/19/2022) |
| 148 | May 19, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 05/19/2022) |
| May 19, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 148 , it is hereby ORDERED that the parties shall file a further joint status report on or before May 26, 2022. Signed by Judge Randolph D. Moss on 5/19/2022. (lcrdm1) (Entered: 05/19/2022) | ||
| 153 | May 19, 2022 | Request | SEALED DOCUMENT (Objection to Magistrate Judge Order on In Camera Review) filed by JULIA SHEKETOFF, MARK C. SAVIGNAC re 135 Order. (This document is SEALED and only available to authorized persons.)(znmw) Modified filer on 5/25/2022 (znmw). (Entered: 05/25/2022) |
| 149 | May 20, 2022 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Motion for Leave to Amend Complaint, # 2 Exhibit Proposed Third Amended Complaint, # 3 Exhibit Redline)(Savignac, Mark) (Entered: 05/20/2022) |
| 150 | May 20, 2022 | Request | MOTION for Leave to File Third Amended Complaint by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Attachments: # 1 Exhibit Proposed Third Amended Complaint)(Savignac, Mark) (Entered: 05/20/2022) |
| 151 | May 20, 2022 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by MARK C. SAVIGNAC, JULIA SHEKETOFF (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Reply in Support of Objection to Magistrate Judge Order)(Savignac, Mark) (Entered: 05/20/2022) |
| 152 | May 20, 2022 | Request | REPLY to opposition to motion Objection to Magistrate Judge Order on In Camera Review filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (Savignac, Mark) (Entered: 05/20/2022) |
| May 24, 2022 | MINUTE ORDER: Upon consideration of Defendants' sealed motion for leave to file under seal, Dkt. 145 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 5/24/2022. (lcrdm1) (Entered: 05/24/2022) | ||
| May 24, 2022 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 149 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 5/24/2022. (lcrdm1) (Entered: 05/24/2022) | ||
| May 24, 2022 | MINUTE ORDER: Upon consideration of Plaintiffs' sealed motion for leave to file under seal, Dkt. 151 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 5/24/2022. (lcrdm1) (Entered: 05/24/2022) | ||
| 154 | May 24, 2022 | Request | SEALED OPPOSITION filed by STEPHEN J. BROGAN, BETH HEIFETZ, JONES DAY, TRACI LOVITT, MICHAEL SHUMAKER re 153 Sealed Objection to Order on In Camera Review filed by JULIA SHEKETOFF, MARK SAVIGNAC. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 05/25/2022) |
| 155 | May 24, 2022 | Request | SEALED REPLY filed by MARK C. SAVIGNAC, JULIA SHEKETOFF re 153 Sealed Objection to Order on In Camera Review filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 05/25/2022) |
| 156 | May 24, 2022 | Request | SEALED MOTION for Leave to File Third Amended Complaint filed by MARK C. SAVIGNAC, JULIA SHEKETOFF. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Third Amended Complaint, # 2 Redline)(znmw) (Entered: 05/25/2022) |
| May 25, 2022 | MINUTE ORDER: In light of Plaintiffs' objection to Magistrate Judge Faruqui's Rule 72(a) order, Dkt. 141 , it is hereby ORDERED that Defendants shall provide the Court, ex parte, (1) with an unredacted copy of JD_PRIV_0039, and (2) redacted copies (reflecting Judge Faruqui's redactions) of the documents that Judge Faruqui provided to Defendants and ordered Defendants to produce to Plaintiffs in connection with his April 14, 2022 Order, Dkt. 135 , and April 22, 2022 Minute Order. Signed by Judge Randolph D. Moss on 5/25/2022. (lcrdm1) (Entered: 05/25/2022) | ||
| 157 | May 26, 2022 | View | Joint STATUS REPORT Regarding Discovery Schedule by MARK C. SAVIGNAC, JULIA SHEKETOFF. (SHEKETOFF, JULIA) (Entered: 05/26/2022) |
| May 27, 2022 | MINUTE ORDER: The Court has completed its review of the unredacted copy of JD_PRIV_0039. The Court understands from Magistrate Judge Faruqui that he intended to leave unredacted any items that were produced to Plaintiffs but inadvertently redacted two sentences that had been previously produced. With that clarification, the Court affirms Judge Faruqui's decision with respect to JD_PRIV_0039, as the Court concludes that the relevant portions of the document contain privileged legal advice. Plaintiffs are hereby ORDERED, on or before June 1, 2022, to file a status report with the Court indicating whether they continue to object to the remainder of Judge Faruqui's decision. Signed by Judge Randolph D. Moss on 5/27/2022. (lcrdm1) (Entered: 05/27/2022) | ||
| May 27, 2022 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 157 , it is hereby ORDERED that the parties shall file a further joint status report on or before June 2, 2022. Signed by Judge Randolph D. Moss on 5/27/2022. (lcrdm1) (Entered: 05/27/2022) |