Some selected documents for this case are included below.
| Date Filed | # | Document Text |
|---|
| July 23, 2007 | 1 | COMPLAINT (verified) against CEMEX Puerto Rico, Inc., Canopy Ecoterra Corp, XYZ Insurance Company (Filing fee $ 350.), filed by American Waste Management and Recycling, LLC.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9# 10 Exhibit 10# 11 Exhibit 11# 12 Exhibit 12# 13 Exhibit 13# 14 Exhibit 14# 15 Exhibit 15)(Esteves, Ada) . |
| July 24, 2007 | 2 | MOTION for Leave to File Spanish language documents and for extension of time in which to file translations filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| August 2, 2007 | 4 | MOTION for Temporary Restraining Order filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- Statement of Abul Shah)(Esteves, Ada) |
| August 2, 2007 | 5 | MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- Insurance certificates# 2 Exhibit 2- email regarding trucking costs)(Esteves, Ada) |
| August 8, 2007 | 6 | MOTION for Hearing on TRO filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| August 13, 2007 | 9 | Motion In Compliance with Court Order filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| August 13, 2007 | 10 | Motion In Compliance Report Submittal by Canopy Ecoterra Corp. (Dkt. 7) filed byAntonio E. Valiente on behalf of Canopy Ecoterra Corp (Valiente, Antonio) |
| August 13, 2007 | 11 | INFORMATIVE Motion filed byJaime E. Toro-Monserrate on behalf of CEMEX Puerto Rico, Inc. (Toro-Monserrate, Jaime) |
| August 13, 2007 | 13 | NOTICE of Appearance by Joanne A. Tomasini-Muniz on behalf of CEMEX Puerto Rico, Inc. (Tomasini-Muniz, Joanne) |
| August 17, 2007 | 14 | MOTION requesting Order filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- Statement of Abul Shah)(Esteves, Ada) |
| August 22, 2007 | 15 | OBJECTION Motion Requesting Order (Dkt. 14) filed by Canopy Ecoterra Corp Re: 14 MOTION requesting Order filed by American Waste Management and Recycling, LLC., (Valiente, Antonio) |
| August 22, 2007 | 16 | MOTION Submitting certified translations filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 2- translation# 2 Exhibit 4- translation# 3 Exhibit 9- translation# 4 Exhibit 11- translation# 5 Exhibit 13- translation# 6 Exhibit 14- translation)(Esteves, Ada) |
| August 23, 2007 | 17 | MOTION to Dismiss/Lack of Jurisdiction as to American Waste Management and Recycling, LLC. filed byAntonio E. Valiente on behalf of Canopy Ecoterra Corp Suggestions in opposition/response due by 9/5/2007 (Attachments: # 1 Exhibit Exhibit I - Negative Certificate of Department of State)(Valiente, Antonio) |
| August 28, 2007 | 18 | MOTION for Extension of Time to File Answer to Complaint filed byJoanne A. Tomasini-Muniz on behalf of CEMEX Puerto Rico, Inc. Suggestions in opposition/response due by 9/10/2007 (Tomasini-Muniz, Joanne) |
| August 28, 2007 | 19 | RESPONSE in Opposition to Motion requesting Order filed by CEMEX Puerto Rico, Inc. Re: 14 MOTION requesting Order filed by American Waste Management and Recycling, LLC., (Attachments: # 1 Exhibit 1 Contract and Scope of Work# 2 Exhibit 2 Cement Plant layout)(Tomasini-Muniz, Joanne) |
| August 29, 2007 | 20 | MOTION for Leave to File Document Reply to CEMEX's Opposition to Motion Requesting Order filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. Suggestions in opposition/response due by 9/11/2007 (Esteves, Ada) |
| August 29, 2007 | 21 | RESPONSE in Opposition to Motion Requesting Extension of Time to Answer filed by American Waste Management and Recycling, LLC. Re: 18 MOTION for Extension of Time to File Answer to Complaint filed by CEMEX Puerto Rico, Inc., (Esteves, Ada) |
| September 6, 2007 | 22 | INFORMATIVE Motion regarding Motion to Dismiss Docket 17 filed byAntonio E. Valiente on behalf of Canopy Ecoterra Corp (Valiente, Antonio) |
| September 6, 2007 | 23 | RESPONSE in Opposition to Motion Requetsing Motion to Dismiss be Deemed Unopposed filed by American Waste Management and Recycling, LLC. Re: 22 INFORMATIVE Motion regarding Motion to Dismiss Docket 17 filed by Canopy Ecoterra Corp, (Esteves, Ada) |
| September 12, 2007 | 26 | RESPONSE in Opposition to Motion to Dismiss filed by American Waste Management and Recycling, LLC. Re: 17 MOTION to Dismiss/Lack of Jurisdiction as to American Waste Management and Recycling, LLC. filed by Canopy Ecoterra Corp, (Attachments: # 1 Exhibit 1- Certificate of Authorization to do Business# 2 Exhibit 2- Hacienda Registration)(Esteves, Ada) |
| September 12, 2007 | 27 | MOTION for Leave to File Spanish language documents and for extension of time in which to file them filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| September 13, 2007 | 28 | MOTION Requesting Preservation Order and Inspection at CEMEX site Pursuant to Docket No. 25 filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit Draft Order)(Esteves, Ada) |
| September 13, 2007 | 29 | MOTION for Leave to File Document Brief Reply filed byAntonio E. Valiente on behalf of Canopy Ecoterra Corp. Suggestions in opposition/response due by 9/26/2007 (Attachments: # 1)(Valiente, Antonio) Modified on 9/14/2007 correcting filer (np, ). |
| September 13, 2007 | 30 | MOTION to Clarify Order [25] and in Opposition to AWMR's Request 28 filed byJoanne A. Tomasini-Muniz on behalf of CEMEX Puerto Rico, Inc. (Tomasini-Muniz, Joanne) |
| September 24, 2007 | 37 |  PRESERVATION AND INSPECTION ORDER . Signed by Judge Jose A Fuste on 9/24/07. (mrj, ) |
| September 24, 2007 | 39 | REPLY to Response to Motion to Dismiss and Memorandum of Law filed by Canopy Ecoterra Corp Re: 17 MOTION to Dismiss/Lack of Jurisdiction as to American Waste Management and Recycling, LLC. filed by Canopy Ecoterra Corp, (Valiente, Antonio) |
| September 24, 2007 | 40 | MOTION for Leave to Appear filed byDavid C. Indiano-Vicic on behalf of all plaintiffs Suggestions in opposition/response due by 10/9/2007 (Indiano-Vicic, David) |
| September 25, 2007 | 41 | MOTION for Leave to File Document Sur-Reply filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. Suggestions in opposition/response due by 10/9/2007 (Attachments: # 1 tendered sur-reply# 2 Exhibit 1- to Sur-reply- State Department certificate)(Esteves, Ada) |
| September 27, 2007 | 42 | Second MOTION for Extension of Time to File Answer to Verified Complaint filed byJoanne A. Tomasini-Muniz on behalf of CEMEX Puerto Rico, Inc. Suggestions in opposition/response due by 10/10/2007 (Tomasini-Muniz, Joanne) |
| September 28, 2007 | 43 | MOTION regarding violation of Court order and requesting sanctions filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- emails from AMECO denying permission to retrieve equipment# 2 Exhibit 2- Letter from AMECO confirming inability to retrieve equipment# 3 Exhibit 3- Marine Asset Management letter)(Esteves, Ada) |
| September 28, 2007 | 44 | MOTION for Leave to File Spanish language documents and for extension of time in which to file them filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| October 2, 2007 | 48 | Emergency MOTION regarding court order and requesting sanctions and other relief filed byJeffrey M. Williams-English on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- Statement of Jose Quinones# 2 Exhibit 2- statement from Cemex security# 3 Exhibit 3- Statement of Arthur Mitchell# 4 Exhibit 4- site map)(Williams-English, Jeffrey) |
| October 2, 2007 | 49 | MOTION for Leave to File Spanish language documents and for extension of time in which to file them filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| October 2, 2007 | 51 | ]SURREPLY to Reply to Opposition to 17 Ecoterra's Motion to Dismiss/Lack of Jurisdiction filed by American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- State Department Authorization)(Esteves, Ada) Modified on 10/3/2007 creating link (np, ). |
| October 2, 2007 | 52 | RESPONSE in Opposition to Motion Regarding Urgent Court Order and Requesting Sanctions and Other Relief filed by Canopy Ecoterra Corp Re: 48 Emergency MOTION regarding court order and requesting sanctions and other relief filed by American Waste Management and Recycling, LLC., (Valiente, Antonio) |
| October 2, 2007 | 53 | RESPONSE in Opposition to Motion regarding violation filed by CEMEX Puerto Rico, Inc. Re: 43 MOTION regarding violation of Court order and requesting sanctions filed by American Waste Management and Recycling, LLC., (Tomasini-Muniz, Joanne) |
| October 2, 2007 | 54 | MOTION for Reconsideration re [46] Order on Motion for Miscellaneous Relief filed byJaime E. Toro-Monserrate on behalf of CEMEX Puerto Rico, Inc. Suggestions in opposition/response due by 10/15/2007 (Attachments: # 1 Exhibit 1 draft joint motion)(Related document(s)[46]) (Toro-Monserrate, Jaime) |
| October 2, 2007 | 55 | MOTION for Urgent Status Conference filed byJaime E. Toro-Monserrate on behalf of CEMEX Puerto Rico, Inc. (Attachments: # 1)(Toro-Monserrate, Jaime) |
| October 3, 2007 | 56 | Emergency INFORMATIVE Motion regarding Joining Urgent Motion for Status Conference filed byAntonio E. Valiente on behalf of Canopy Ecoterra Corp (Valiente, Antonio) |
| October 3, 2007 | 59 | MOTION for Reconsideration OF STAY AND OPPOSITIONS TO CEMEX'S MOTION FOR RECONSIDERATION AND URGENT MOTION FOR STATUS CONFERENCE AND FOR BRIEF STAY AND ECOTERRA'S MOTION JOINING CEMEX re [58] Order on Motion for Miscellaneous Relief, Order on Informative Motion,, filed byJeffrey M. Williams-English on behalf of all plaintiffs Suggestions in opposition/response due by 10/16/2007 (Attachments: # 1 Exhibit E-mail dated October 1, 2007)(Related document(s)[58]) (Williams-English, Jeffrey) |
| October 5, 2007 | 61 | ANSWER to Complaint by CEMEX, CROSSCLAIM against Canopy Ecoterra Corp, COUNTERCLAIM against American Waste Management and Recycling, LLC. filed by Joanne A. Tomasini-Muniz on behalf of Defendants CEMEX Puerto Rico, Inc. Tomasini-Muniz, Joanne) Modified on 10/9/2007 to correct filer. (ft). |
| October 8, 2007 | 62 | Motion In Compliance with Court Order at Docket No. 60 filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Esteves, Ada) |
| October 9, 2007 | 63 | First MOTION for Non Resident Bond Upon Plaintiff AWMR filed byAntonio E. Valiente on behalf of Canopy Ecoterra CorpSuggestions in opposition/response due by 10/22/2007 |
| October 15, 2007 | 64 | Motion In Compliance with Court Order filed byAda Sofia Esteves on behalf of American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- e-mail to counsel Valiente Oct 12,07)(Esteves, Ada) |
