Liberty Ford Lincoln Mercury, Inc. et al v. Ford Motor Company
| Liberty Ford Lincoln Mercury, Inc., Liberty Lincoln Mercury, Independence, LLC, Liberty Ford Lincoln Canton, LLC, Liberty Ford Solon, Inc., Liberty Ford, Inc. and Liberty Ford Southwest, Inc. |
| Ford Motor Company and Ford Motor Credit Company, LLC |
| James D. Thomas |
| 1:2021cv02085 |
| November 4, 2021 |
| US District Court for the Northern District of Ohio |
| J Philip Calabrese |
| Solomon Oliver |
| Contract: Other |
| 28 U.S.C. § 1441 Petition for Removal |
| Plaintiff |
Docket Report
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This docket was last retrieved on April 3, 2024. A more recent docket listing may be available from PACER.
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Filing 73
Opinion and Order: Regarding three objections to the Special Master's Order (ECF No. #63 ), the Court OVERRULES Plaintiffs' objection concerning Issue Two and Defendant's objection concerning Issue One and SUSTAINS Defendant's objection concerning Issue Five. Judge J. Philip Calabrese on August 4, 2023. (Y,A)
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Filing 72
Memorandum in Opposition to Plaintiffs' Objection to Special Master Discovery Order #1 filed by Ford Motor Company. Related document(s) #64 . (Attachments: #1 Exhibit 1 - Declaration of Eric Rice) (McNellie, Elizabeth)
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Filing 71
Response to Ford Motor Company's Objection to Special Master Discovery Order #1 filed by All Plaintiffs. (Related document(s) #66 , #67 ). (Attachments: #1 Exhibit 1 - Table of Contents for Special Master Binder, #2 Exhibit 2 - Michael Herrick Declaration, #3 Exhibit 2(A) - Liberty Ford's CGRs for 03-2019, #4 Exhibit 2(B) - Liberty Ford's Dealer Order Commitment Form for 03-2019, #5 Exhibit 2(C) - Liberty Ford's ASOBRs for 03-2019, #6 Exhibit 2(D) - FMC Vehicle Locator, #7 Exhibit 2(E) - FMC Sales Update Reports) (Panza, Richard)
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Filing 70
SEALED Document: Exhibits 1p & 1r, 1s & 1t, and 5i to Transcript of June 12, 2023 Meeting of the Parties with Special Master Thomas filed by All Plaintiffs. (Related document(s) #20 , #69 ) (Panza, Richard)
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Filing 69
Notice of Filing of the Transcript of the June 12, 2023, Meeting of the Parties with Special Master James D. Thomas filed by All Plaintiffs. (Attachments: #1 Transcript of Meeting with Special Master 6/12/23, #2 Exhibits to Transcript)(Panza, Richard)
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Filing 68
Order: The Court sets July 20, 2023 as the deadline for any responses to objections. No replies unless otherwise ordered. Judge J. Philip Calabrese on July 13, 2023. (Y,A)
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Filing 67
Supplement to Objection - Memorandum In Support of Objection to Special Master Discovery Report #1, filed by Ford Motor Company. (Related document(s) #66 ) (McNellie, Elizabeth)
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Filing 66
Objection to Special Master Discovery Order #1 filed by Ford Motor Company. Related document(s) #63 . (Attachments: #1 Memorandum in Support) (McNellie, Elizabeth) Modified on 7/12/2023. Filer notified the Court that attachment #1 Memorandum in Support was the incorrect document and they will be filing a supplement to the replace the attachment. (R,AP).
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Filing 65
SEALED Document: Exhibits B-6 through B-13 to Objection to Special Master Discovery Order #1 filed by All Plaintiffs. (Related document(s) #20 , #64 ) (Panza, Richard). Modified on 7/17/2023, filer notified of lack of cover page, with case caption, case number and signature block (H,SP).
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Filing 64
Objection to Special Master Discovery Order #1 filed by All Plaintiffs. (Related document(s) #63 ). (Attachments: #1 Exhibit A - Defendants counsel's 6-6-23 letter to Plaintiffs' counsel, #2 Exhibit B - Plaintiffs counsel's 6-14-23 letter to SM Thomas) (Panza, Richard)
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Filing 63
Special Master Discovery Order #1. Judge J. Philip Calabrese on July 5, 2023. (Attachments: #1 Appendix I, #2 Appendix II)(Y,A)
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Filing 62
Order: The Court finds that Special Master James D. Thomas has complied with Sections II.F.1 and 2 of the Order Appointing Special Master (ECF No. #61 ). Judge J. Philip Calabrese on 5/31/2023. (Attachments: #1 Acknowledgement and Agreement to be Bound)(Y,A)
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Filing 61
Order Appointing Special Master: Pursuant to Rule 53, the Court appoints James D. Thomas as Special Master and Orders him to proceed with all reasonable diligence in the performance of his duties as set out in the Appointing Order accompanying this entry. The Court Orders that attorney James D. Thomas be given access to file electronically and view any and all sealed filings in this matter. Judge J. Philip Calabrese on 5/3/2023. (Y,A)
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Filing 60
Order: The Court OVERRULES Defendant's objections to the appointment of a Special Master and ADOPTS IN PART one of Plaintiffs' proposals. Judge J. Philip Calabrese on 5/3/2023. (Y,A)
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Filing 59
Order: By email, the Court will supply counsel with the name of its candidate for consideration to serve as a Special Master. The Court takes under advisement Plaintiffs' nominees and Defendant's objection to appointing a Special Master. Judge J. Philip Calabrese on 4/19/2023. (Y,A)
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Filing 58
Notice of Filing of the Deposition Transcript of Defendant's Civil Rule 30(B)(6) Designee, Brian Finnerty filed by All Plaintiffs. (Attachments: #1 Deposition Transcript of Brian Finnerty)(Panza, Richard)
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Filing 57
Response to Proposed Appointment of a Special Master filed by Ford Motor Company. Related document(s) #54 . (McNellie, Elizabeth)
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Filing 56
Submission Regarding The Court's Appointment of a Special Master filed by All Plaintiffs. Related document(s) #54 .(Panza, Richard)
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Filing 55
Notice of Filing Deposition Transcript filed by Ford Motor Company. (Attachments: #1 Exhibit A - Deposition Transcript - Michael James Herrick)(McNellie, Elizabeth)
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Filing 54
Order: Notice pursuant to Rule 53 and Order for parties to make submissions regarding the appointment of a special master. Judge J. Philip Calabrese on 4/3/2023. (Attachments: #1 Draft Order Appointing)(Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference in Chambers on March 29, 2023. Richard D. Panza, Matthew W. Nakon, Rachelle K. Zidar, and Thomas R. Theado appeared for Plaintiffs. Jeremiah J. Wood and Elizabeth A. McNellie appeared for Defendant. Counsel provided additional background information on the case and updated the Court on the status of discovery. Based on the current procedural posture, the Court discussed the need for appointment of a special master and proposed a process for selecting one. By separate order, the Court will provide formal notice of potential appointment under Rule 53(b)(1). Time: 55 minutes. (Y,A)
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Order [non-document]: Previously, the Court scheduled a status conference by Zoom on March 29, 2023 at 4:30.m. The Court will now conduct that conference in person. Judge J. Philip Calabrese on 3/20/2023. (Y,A)
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Filing 53
Order: The Court DENIES Plaintiffs' motion for clarification (ECF No. #52 ). Judge J. Philip Calabrese on 3/17/2023.(Y,A)
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Filing 52
Motion for Combined Relief for Clarification of the Courts February 14 2023 Discovery Ruling ECF No 48 and Either for Inclusion of Rule 54 b Language into the Courts December 5 2022 Opinion and Order ECF No 42 or for Certification of ECF No 42 for Interlocutory Appeal Under 28 USC 1292 b filed by Liberty Ford Lincoln Canton, LLC, Liberty Ford Lincoln Mercury, Inc., Liberty Ford Solon, Inc., Liberty Ford Southwest, Inc., Liberty Ford, Inc., Liberty Lincoln Mercury, Independence, LLC. Related document(s) #47 , #42 , #48 . (Panza, Richard)
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Filing 51
Non-Appeal Transcript Order Form for proceedings held on 11/15/2022 before Judge Calabrese, Court Reporter: Greg Mizanin. Requested completion date: As soon as possible without incurring additional charge. filed by Ford Motor Company, Ford Motor Credit Company, LLC. (McNellie, Elizabeth)
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Filing 50
Transcript of Motion Hearing held on 11-15-2022 before Judge Calabrese. To obtain a bound copy of this transcript please contact court reporter Greg Mizanin at gregory_mizanin@ohnd.uscourts.gov. [35 pages] Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties requesting that privacy information be redacted must file a notice of intent to redact with the court by 3/1/2023. Redaction Request due 3/15/2023. Redacted Transcript Deadline set for 3/25/2023. Release of Transcript Restriction set for 5/23/2023. Related document(s) #49 . (M,Gr)
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Filing 49
7-day Non-Appeal Transcript Order Form for proceedings held on 11/15/2022 before Judge Calabrese, Court Reporter: Greg Mizanin. Requested completion date: 2/27/2023 filed by All Plaintiffs. (Panza, Richard)
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Filing 48
Order Ruling on Discovery Disputes. Judge J. Philip Calabrese on 2/14/2023. (Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference by Zoom on February 7, 2023. Richard D. Panza, Matthew W. Nakon, Rachelle K. Zidar, and Thomas R. Theado appeared for Plaintiffs. Jeremiah J. Wood and Elizabeth A. McNellie appeared for Defendant. The Court addressed various discovery disputes that Plaintiffs raised. Following argument by counsel, the Court took the matter under advisement and indicated it would issue a ruling promptly. Further, the Court provided notice to counsel that concluding discovery and preparing the case for dispositive motions may require the appointment of a special master. The deadline to serve written discovery requests (excluding limited follow-up) is February 15, 2023. The Court sets the next status conference for March 29, 2023, at 4:30 p.m., which will be held by Zoom. Time: 55 minutes. (Y,A)
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Filing 47
Opinion and Order: The Court DENIES Plaintiffs' motion for inclusion of Rule 54(b) language or, in the alternative, to certify an interlocutory appeal. (ECF No. #43 ). Judge J. Philip Calabrese on 2/1/2023. (Y,A)
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IMPORTANT: Notice [non-document]: The Court schedules a Status Conference for February 7, 2023 at 4:00 p.m., which will be held via Zoom before Judge J. Philip Calabrese. (Y,A)
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Filing 46
Supplemental Authority in Support of Motion for Inclusion of Rule 54(b) language or, in the alternative, Motion to Certify the Court's December 5, 2022 Opinion and Order for Interlocutory Appeal filed by All Plaintiffs. (Related document(s) #43 ) (Panza, Richard)
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Filing 45
Reply to Ford Motor Company's Brief in Opposition to Plaintiffs' Motion for Inclusion of Rule 54(b) Language, or in the Alternative, to Certify the Court's December 5, 2022, Opinion and Order for Interlocutory Appeal Under 28 U.S.C. Section 1292(b) filed by All Plaintiffs. (Related document(s) #43 , #44 ) (Panza, Richard)
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Filing 44
Opposition to #43 Motion for Inclusion of Rule 54(b) language or, in the alternative, Motion to Certify the Court's December 5, 2022 Opinion and Order for Interlocutory Appeal filed by All Defendants. (Attachments: #1 Exhibit A - Carpenter v. Liberty Ins. Corp., 850 Fed. Appx. 351,356) (Wood, Jeremiah)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference via Zoom on December 16, 2022. Richard D. Panza, Matthew W. Nakon, Rachelle K. Zidar, and Thomas R. Theado appeared for Plaintiffs. Jeremiah J. Wood and Elizabeth A. McNellie appeared for Defendant. The Court sets the following briefing schedule on Plaintiffs motion for certificate of appealability: Opposition: January 11, 2023; Reply: January 25, 2023. Time: 5 minutes. (Court Reporter: None) (S,KM)
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Filing 43
Motion for certificate of appealability (Plaintiffs' Motion for Inclusion of Rule 54(b) Language or, in the Alternative, to Certify the Court's December 5, 2022 Opinion and Order for Interlocutory Appeal) filed by Liberty Ford Lincoln Canton, LLC, Liberty Ford Lincoln Mercury, Inc., Liberty Ford Solon, Inc., Liberty Ford Southwest, Inc., Liberty Ford, Inc., Liberty Lincoln Mercury, Independence, LLC. Related document(s) #42 . (Nakon, Matthew)
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IMPORTANT: Notice [non-document]: The Court schedules a Status Conference for December 16, 2022 at 2:30 p.m. via Zoom before Judge J. Philip Calabrese. (Y,A)
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Filing 42
Opinion and Order: The Court DENIES Plaintiffs' motion for a partial summary judgment. (ECF No. #37 .) Judge J. Philip Calabrese on 12/5/2022.(Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held oral argument on Plaintiffs' partial motion for summary judgment on Counts 1 and 2 (ECF No. #37 ) on the record on November 15, 2022. Richard D. Panza appeared for Plaintiffs, and Rachelle K. Zidar argued for Plaintiffs. Elizabeth A. McNellie argued for Defendant. The Court took the matter under advisement. (Court Reporter: Gregory Mizanin.) Time: 55 minutes. (Y,A)
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Order [non-document]: Pursuant to Local Rule 7.2(b), the Court GRANTS Defendants request for oral argument, which will be held on the record on November 15, 2022 at 10:30 a.m. in Courtroom 16B, Carl B. Stokes U.S. Courthouse, 801 West Superior Avenue, Cleveland, Ohio. Judge J. Philip Calabrese on 10/20/2022. (Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference by telephone on October 20, 2022. Richard D. Panza and Thomas R. Theado appeared for Plaintiffs. Jeremiah J. Wood and Elizabeth A. McNellie appeared for Defendant. Counsel updated the Court on the status of discovery and discussed possible dates for oral argument on Plaintiffs' pending motion for a partial summary judgment. The Court will schedule oral argument by separate order. Time: 15 minutes. (Y,A)
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Telphone Status Conference set for 10/20/2022 at 2:00 p.m. before Judge J. Philip Calabrese. (Y,A)
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IMPORTANT: Notice [non-document]: Notwithstanding the prior order vacating the case schedule, the status conference set for October 20, 2022 at 2:00 p.m. will proceed as previously scheduled at that time. The Courtroom Deputy will email counsel with instructions to participate in the conference. (Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference by telephone on September 21, 2022. Richard D. Panza, Matthew W. Nakon, Rachelle K. Zidar, and Thomas R. Theado appeared for Plaintiffs. Jeremiah J. Wood and Elizabeth A. McNellie appeared for Defendant. Counsel updated the Court on the status of discovery and document production and orally requested that the Court vacate the current schedule and set a new one, though they disagree on the schedule going forward. For good cause shown, the Court GRANTS the joint motion to vacate the current schedule (ECF No. #24 ). After a ruling on the pending motion for partial summary judgment, the Court will set a new schedule. Time: 20 minutes. (Y,A)
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Order [non-document]: The Court STRIKES the motion to quash the subpoena for failure to comply with Section 4.A. of the Court's Civil Standing Order and Local Rule 37.1. Related document(s) #41 . Judge J. Philip Calabrese on 9/12/2022. (R,AP)
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Filing 41
Motion to quash plaintiffs' subpoena, filed by Ford Motor Credit Company, LLC. (Attachments: #1 Brief in Support, #2 Subpoena to Ford Motor Credit Company, #3 Declaration of Ken Scherer). (Murnane, Colleen)
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Filing 40
Reply to response to #37 Motion for summary judgment on Counts 1 and 2 of the Second Amended Complaint filed by All Plaintiffs. (Nakon, Matthew)
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Filing 39
Response to #37 Motion for summary judgment on Counts 1 and 2 of the Second Amended Complaint, filed by Ford Motor Company. (McNellie, Elizabeth)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference by telephone on July 19, 2022. Richard Panza, Matthew Nakon, and Thomas Theado appeared for Plaintiffs. Jeremiah Wood and Elizabeth McNellie appeared for Defendant. The parties agreed to follow the briefing schedule for Plaintiffs motion for partial summary judgment (ECF No. #37 ) set forth in the Rules. The Court schedules a telephone status conference for September 21, 2022 at 4:00 p.m. The Courtroom Deputy will provide dial-in information beforehand. Time: 15 minutes. (Y,A)
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Filing 38
Order: Resolving Discovery Dispute. Judge J. Philip Calabrese on 7/15/2022. (Y,A)
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Order [non-document]: The Court notes that following two disclosures no party has objected or raised concern should Judge Calabrese decide to move forward with purchasing a Ford. Judge J. Philip Calabrese on 7/15/2022. (Y,A)
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Filing 37
Motion for partial summary judgment on Counts 1 and 2 of the Second Amended Complaint, filed by Liberty Ford Lincoln Canton, LLC, Liberty Ford Lincoln Mercury, Inc., Liberty Ford Solon, Inc., Liberty Ford Southwest, Inc., Liberty Ford, Inc., Liberty Lincoln Mercury, Independence, LLC. Related document(s) #29 . (Nakon, Matthew)
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Filing 36
Joint Status Report of the Parties Regarding Discovery Dispute filed by Ford Motor Company. (McNellie, Elizabeth)
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Filing 35
Notice of Filing Ford Motor Company's Responses to Plaintiffs' Second Set of Discovery, and Ford's Verification filed by All Plaintiffs. (Attachments: #1 Ford Motor Company's Responses to Second Set of Discovery Requests, #2 Ford's Verification of Discovery Responses)(Panza, Richard)
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Filing 34
Minutes and Order on Discovery Dispute: The Court held a status conference to address certain discovery disputes raised by Plaintiffs. The Court directs the parties to make a single joint submission by July 13, 2022 addressing the costs and burdens of transforming the data at issue into a reasonably usable format. Time: 30 minutes. (Y,A)
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Filing 33
Order: The Court reschedules the conference to June 27, 2022 at 11:00 a.m., which will be held over Zoom. The Court will not reschedule the conference again absent good cause. The Court directs each side's technical representative to attend. Judge J. Philip Calabrese on 6/21/2022. (Y,A)
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Filing 32
Minutes and Ruling on Discovery Dispute The Court held a status conference to address certain discovery disputes raised by Plaintiffs. The Court overrules certain objections Plaintiffs raise and continues the conference to June 21, 2022 at noon, which will be held over Zoom. Further, the Court directs each sides technical representative to attend. Time: 30 minutes. (Y,A)
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Filing 31
Rule 37 Order. Judge J. Philip Calabrese on 6/7/2022. (Y,A)
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Random Reassignment of Magistrate Judge pursuant to General Order 2022-03. In the event of a referral, case will be assigned to Magistrate Judge Jonathan D. Greenberg. (H,Ch)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a discovery dispute conference by telephone on June 7, 2022. Matthew Nakon, Richard Panza, Rachelle Zidar, and Thomas Theado appeared for Plaintiffs. Jeremiah Wood and Elizabeth McNellie appeared for Defendant. For a second time, Judge Calabrese disclosed that he is considering purchasing a Ford and requested any objections no later than July 1, 2022. With respect to the discovery disputes, the Court heard from counsel on two discovery issues. First, Plaintiff objected to the PDF format in which Defendant exported and produced data. Second, Plaintiff objected to Defendant's anonymization of the dealers in connection with the data. Based on this discussion, the Court ORDERS the parties to submit by email to the Court by June 8, 2022: (1) the governing ESI protocol; and (2) one example each from Plaintiffs and Defendant of a report with the anonymized data. The Court continued the conference to June 17, 2022 at 2:30 p.m. Time: 40 minutes. (Y,A)
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Filing 30
Answer to #29 Second Amended complaint for Declaratory and Injunctive Relief, a Preliminary and Permanent Injunction, and Money Damages, filed by Ford Motor Company. (McNellie, Elizabeth)
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Filing 29
Second Amended complaint for Declaratory and Injunctive Relief, a Preliminary and Permanent Injunction, and Money Damages against Ford Motor Company. Filed by Liberty Ford Southwest, Inc., Liberty Ford Solon, Inc., Liberty Ford Lincoln Mercury, Inc., Liberty Ford Lincoln Canton, LLC, Liberty Lincoln Mercury, Independence, LLC, Liberty Ford, Inc. (Panza, Richard)
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Filing 28
Order: The Court GRANTS IN PART and DENIES IN PART Plaintiffs' motion for leave to file a second amended complaint (ECF No. #25 ). Judge J. Philip Calabrese on 5/9/2022.(Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a status conference by telephone on May 4, 2022. Richard Panza, Matthew Nakon, Rachelle Zidar, and Thomas Theado appeared for Plaintiffs. Jeremiah Wood appeared for Defendant. The parties provided the Court with an update on the status of discovery. Relating to Defendant's document production, counsel for Plaintiff raised the issues that the documents were all designated "Attorneys' Eyes Only" and that the documents were produced in PDF rather than native format. The parties are working together to resolve these issues. The next status conference is scheduled for July 19, 2022 at 2:00 p.m. and will be held by telephone. The Courtroom Deputy will email counsel with instructions to participate in the conference. Time: 15 minutes. (Y,A)
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Filing 27
Reply in support of #25 Motion for leave to File a Second Amended Complaint filed by All Plaintiffs. (Panza, Richard)
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Filing 26
Response to #25 Motion for leave to File a Second Amended Complaint filed by Ford Motor Company. (McNellie, Elizabeth)
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Filing 25
Motion for leave to File a Second Amended Complaint and Memorandum in Support filed by Liberty Ford Lincoln Canton, LLC, Liberty Ford Lincoln Mercury, Inc., Liberty Ford Solon, Inc., Liberty Ford Southwest, Inc., Liberty Ford, Inc., Liberty Lincoln Mercury, Independence, LLC. (Attachments: #1 Exhibit 1 - Redline of Second Amended Complaint, #2 Exhibit 2 - Clean version of Second Amended Complaint) (Panza, Richard)
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Filing 24
First Amended Case Management Plan and Scheduling Order: The schedule is as follows: Motions to amend pleadings or add additional parties: April 12, 2022; Motions directed to pleadings: April 26, 2022; Fact discovery deadline: October 30, 2022; Plaintiff Liability Expert: November 30, 2022; Defendant Liability Expert: December 20, 2022; Liability Expert Discovery: January 18, 2023. The next status conference is scheduled for May 4, 2022 at 2:00 p.m. and will be held by telephone. Further, the Court sets a second status conference for October 20, 2022 at 2:00 p.m. to be held by telephone. The Courtroom Deputy will email counsel with instructions to participate in the conference. Judge J. Philip Calabrese on 4/4/2022. (Y,A)
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Filing 23
Joint Motion for 90 days to Modify Case Management Plan and Scheduling Order and memorandum in support, filed by Defendant Ford Motor Company. Related document(s) #17 . (Attachments: #1 Proposed Order). (McNellie, Elizabeth)
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Filing 22
Acknowledgement Of Receipt Of Original State Court Record Revived on |
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Filing 21
State court documents received from Lorain County Court of Common Pleas, case number 20cv202417. Original record returned to Lorain County Court with acknowledgement of receipt enclosed. (Attachments: #1 State Court Record, #2 Letter to Lorain County) (S,HR)
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Filing 20
Stipulated Protective Order. Judge J. Philip Calabrese on 2/9/2022. (Attachments: #1 Acknowledgement and Agreement to be Bound)(Y,A)
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Filing 19
Stipulated Motion for protective order filed by Defendant Ford Motor Company. (McNellie, Elizabeth, s/ by Jeremiah J. Wood)
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Filing 18
Attorney Appearance by Rachelle K. Zidar filed by on behalf of All Plaintiffs. (Zidar, Rachelle)
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Filing 17
Case Management Plan and Scheduling Order: The Court enters the following Case Management Order: Complex track. Case not referred to ADR at this time. Parties do not consent to the jurisdiction of a Magistrate Judge. The parties agree to confer regarding a protocol to control ESI discovery. The parties also agree to confer regarding a protective order and to submit the protective order for the Court's review. The schedule is as follows: Initial disclosures: January 24, 2022; Motions to amend pleading or add additional parties: April 12, 2022; Motions directed to pleadings: April 26, 2022; Fact discovery deadline: July 30, 2022; Plaintiff Liability Expert: August 30, 2022; Defendant Liability Expert: September 20, 2022; Liability Expert Discovery: October 18, 2022. The next status conference is scheduled for May 4, 2022 at 2:00 p.m. and will be held by telephone. Further, the Court sets a second status conference for October 20, 2022 at 2:00 p.m. to be held by telephone. The Courtroom Deputy will email counsel with instructions to participate in the conference. Judge J. Philip Calabrese on 1/11/2022. (Y,A)
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Minutes of proceedings [non-document] before Judge J. Philip Calabrese. The Court held a Case Management Conference by Zoom on January 11, 2022. Richard D. Panza and Thomas R. Theado appeared for Plaintiffs. Elizabeth A. McNellie and Jeremiah J. Wood appeared for Defendant. Counsel provided the history and background of the case and discussed the schedule and other case management issues. In addition, the Court suggested that the parties give consideration to using a special master. Time: 20 minutes. (Y,A)
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Rule 502 Order [non-document]: The Court Orders that under Rule 502(d) of the Federal Rules of Evidence, an inadvertent disclosure of a communication or information covered by the attorney-client privilege or work-product protection made in connection with this litigation shall not constitute a waiver of that privilege or protection in this or any other federal or state proceeding. Judge J. Philip Calabrese on 1/11/2022. (Y,A)
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Filing 16
Report of Parties' Planning Meeting - parties do not consent to this case being assigned to the magistrate judge, filed by All Plaintiffs. (Panza, Richard)
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Filing 15
Corporate Disclosure Statement filed by Liberty Ford Lincoln Mercury, Inc.. (Panza, Richard)
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Filing 14
Corporate Disclosure Statement filed by Liberty Lincoln Mercury, Independence, LLC. (Panza, Richard)
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Filing 13
Corporate Disclosure Statement filed by Liberty Ford Solon, Inc.. (Panza, Richard)
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Filing 12
Corporate Disclosure Statement filed by Liberty Ford Lincoln Canton, LLC. (Panza, Richard)
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Filing 11
Corporate Disclosure Statement filed by Liberty Ford, Inc.. (Panza, Richard)
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Filing 10
Corporate Disclosure Statement filed by Liberty Ford Southwest, Inc.. (Panza, Richard)
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Filing 9
Joint Consent to Electronic Service filed by All Plaintiffs. (Panza, Richard)
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Filing 8
Joint Motion to continue Case Management Conference filed by Liberty Ford Lincoln Canton, LLC, Liberty Ford Lincoln Mercury, Inc., Liberty Ford Solon, Inc., Liberty Ford Southwest, Inc., Liberty Ford, Inc., Liberty Lincoln Mercury, Independence, LLC. Related document(s) #7 . (Panza, Richard)
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Order [non-document]: The parties' joint motion to continue the case management conference is GRANTED (ECF No. #8 ). The Court will now conduct the case management conference on January 11, 2022 at 1:00 pm by Zoom. Judge J. Philip Calabrese on 11/16/2021.(Y,A)
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Filing 7
Case Management Conference Scheduling Order with case management conference to be held on 12/15/2021 at 1:00 p.m. in Chambers 16B before Judge J. Philip Calabrese. Judge J. Philip Calabrese on 11/8/2021. (Y,A) (Additional attachment(s) added on 11/8/2021: #1 Rule 26 Report of Parties) (Y,A).
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Filing 6
Order of Recusal. This case is returned to the Clerk for reassignment to another judge. Signed by Judge Solomon Oliver, Jr. on 11/8/2021. (R,Sh)
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Judge J. Philip Calabrese assigned to case. Judge Solomon Oliver, Jr. terminated. (L,MI)
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Filing 5
Answer to Complaint (Related Doc #1 ) filed by Ford Motor Company. (McNellie, Elizabeth)
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Filing 4
Magistrate Consent Form issued. (L,MI)
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Filing 3
Corporate Disclosure Statement filed by Ford Motor Company. (McNellie, Elizabeth)
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Filing 2
Supplement to Notice of Removal, - Civil Cover sheet, filed by Ford Motor Company. Related document(s) #1 . (McNellie, Elizabeth)
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Filing 1
Notice of Removal from Lorain County Common Pleas, case number 20CV202417 Filing fee paid $ 402, receipt number AOHNDC-11117718. Filed by Ford Motor Company. (Attachments: #1 Exhibit A - State Court Complaint). (McNellie, Elizabeth)
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Judge Solomon Oliver, Jr assigned to case. (L,MI)
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Random Assignment of Magistrate Judge pursuant to Local Rule 3.1. In the event of a referral, case will be assigned to Magistrate Judge David A. Ruiz. (L,MI)
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