Constance Jones v. James Trading Company Limited et al
| Constance Jones |
| James Trading Company Limited, Every Industry LLC, Li Shuang Qi, James Industry Group Co., Ltd., James Bond and Does 1 through 50, inclusive |
| 2:2019cv02674 |
| April 8, 2019 |
| US District Court for the Central District of California |
| Michael W Fitzgerald |
| John E McDermott |
| Labor: Other |
| 28 U.S.C. § 1441 |
| Plaintiff |
Docket Report
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Filing 138
MINUTES (IN CHAMBERS) ORDER GRANTING DEFENDANTS' MOTION TO WITHDRAW AS COUNSEL #131 by Judge Michael W. Fitzgerald. The Motion is GRANTED. The docket shall reflect that Defendants' counsel are permitted to withdraw once they have filed the required proof. Obviously, this Order has no effect on the pending appeal. (iv)
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| Filing 137 MINUTES OF TELEPHONIC - DEFENDANTS MOTION TO WITHDRAW AS COUNSEL #131 held before Judge Michael W. Fitzgerald. Case called, and counsel make their appearance. For the reasons stated on the record, the matter is taken under submission. Court Reporter: Amy Diaz. (iv) |
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Filing 136
SCHEDULING NOTICE AND ORDER by Judge Michael W. Fitzgerald. Pursuant to General Order 21-08, DEFENDANTS' MOTION TO WITHDRAW AS COUNSEL #131 set for September 13, 2021 will be held telephonically at 10:30 a.m. Counsel shall use the following conference call information: Number: (888) 363-4734; Access Code: 5200572. Counsel are ordered to remain available from 10:30 a.m. - 11:30 a.m. Any tentative ruling the Court may prepare, will be emailed to counsel prior to the hearing. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (rs) TEXT ONLY ENTRY
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| Filing 135 Opposition re: NOTICE OF MOTION AND MOTION of David T. Ching and Paul P. Cheng to Withdraw as Attorney #131 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration, #2 Declaration, #3 Proposed Order)(McMillan, Heather) |
| Filing 134 NOTIFICATION from Ninth Circuit Court of Appeals of case number assigned and briefing schedule. Appeal Docket No. 21-55896 assigned to Notice of Appeal to 9th Circuit Court of Appeals, #132 as to Defendant Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (iv) |
| Filing 133 REPRESENTATION STATEMENT re Notice of Appeal to 9th Circuit Court of Appeals, #132 . (Lin, David) |
| Filing 132 NOTICE OF APPEAL to the 9th Circuit Court of Appeals filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Appeal of Order on Motion to Set Aside Judgment, #125 . (Appeal Fee - $505 Fee Paid, Receipt No. ACACDC-31823067.) (Attachments: #1 Notice of Appeal, #2 Notice of Appeal, #3 Notice of Appeal)(Lin, David) |
| Filing 131 NOTICE OF MOTION AND MOTION of David T. Ching and Paul P. Cheng to Withdraw as Attorney filed by Attorney, David T. Ching and Paul P. Cheng Does, Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Motion set for hearing on 9/13/2021 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Proposed Order) (Attorney Paul Po-Ren Cheng added to party Does(pty:dft)) (Cheng, Paul) |
| Filing 130 NOTICE regarding Meet and Confer Ordered by the Court filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 129 MANDATE of Ninth Circuit Court of Appeals filed re: Notice of Appeal to 9th Circuit Court of Appeals, #98 , CCA # 21-55529. The judgment of this Court, entered July 14, 2021, takes effect this date. This constitutes the formal mandate of this Court issued pursuant to Rule 41(a) of the Federal Rules of Appellate Procedure. [See USCA Order, #117 DISMISSED.](mat) |
| Filing 128 APPLICATION for Judgment Debtor Exam as to Li Shuang Qi filed by Plaintiff Constance Jones. Application set for hearing on 8/24/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
| Filing 127 MINUTES OF JUDGMENT DEBTOR EXAMINATIONS OF: PERSON MOST KNOWLEDGEABLE OF JAMES TRADING COMPANY LIMITED AND PERSON MOST KNOWLEDGEABLE OF JAMES INDUSTRY GROUP CO LTD Judgment Debtor Exam held before Magistrate Judge John E. McDermott: Counsel stated their appearances. Judgment debtors did not appear. The Court ORDERED the parties to meet and confer within three days and thereafter file a stipulation for dates for the judgment debtors to appear. Court Reporter: ZOOM. (es) |
| Filing 126 NOTICE Regarding Bankruptcy Filing of Defendant Scheduled for Debtor's Examination filed by Plaintiff Constance Jones. (McMillan, Heather) |
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Filing 125
MINUTES (IN CHAMBERS) ORDER DENYING MOTION TO SET ASIDE DEFAULT JUDGMENT #96 by Judge Michael W. Fitzgerald. For the reasons discussed below, the Motion is DENIED. Defendants willfully failed to defend this action and therefore engaged in culpable conduct that led to the entry of default judgment. [see document for details.) (et)
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| Filing 124 NOTICE OF FILING BANKRUPTCY filed by Defendant Every Industry LLC. as to Every Industry, LLC, Bankruptcy Court case number 2:21-bk-16198-NB. (Selth, James) |
| Filing 123 Mail Returned addressed to Li Shuang Qi re Default Judgment #92 . (iv) |
| Filing 122 Mail Returned addressed to Li Shuang Qi re Order on Motion to Compel Answers to Interrogatories #91 . (iv) |
| Filing 121 PROOF OF SERVICE filed by Plaintiff Constance Jones, re Order on Motion for Judgment Debtor Exam #113 , Order on Motion for Judgment Debtor Exam #114 on Debtors James Trading Company Limited and James Industry Group Co., Ltd. served on July 23, 2021. (McMillan, Heather) |
| Filing 120 PROOF OF SERVICE filed by Plaintiff Constance Jones, re Order on Motion for Judgment Debtor Exam #115 of Every Industry LLC served on July 21,2021. (McMillan, Heather) |
| Filing 119 PROOF OF SERVICE filed by Plaintiff Constance Jones, re Order on Motion for Judgment Debtor Exam #113 , Order on Motion for Judgment Debtor Exam #114 , Order on Motion for Judgment Debtor Exam #115 served on July 21, 2021. (McMillan, Heather) |
| Filing 118 MINUTES [IN CHAMBERS] JUDGMENT DEBTOR EXAMINATION OF LI SHUANG QI AKA JAMES BOND by Magistrate Judge John E. McDermott: The Court hereby takes this matter set for July 20, 2021 off calendar. As of this date, proof of personal service has not been filed. CCP 708.110. Counsel shall submit a new application and proposed order once the debtor is located and able to be properly served. (es) |
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Filing 117
ORDER from Ninth Circuit Court of Appeals filed re: Notice of Appeal to 9th Circuit Court of Appeals, #98 filed by Li Shuang Qi, James Industry Group Co., Ltd. Every Industry LLC, James Trading Company Limited. CCA # 21-55529. A review of the record and the parties responses to the June 1, 2021, order to show cause demonstrates that this court lacks jurisdiction over this appeal because the May 20, 2021, notice of appeal was not filed within 30 days after the district courts default judgment entered on March 25, 2021. DISMISSED.(mat)
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Filing 116
ORDER by Judge Michael W. Fitzgerald. The Court's Order Directing the Parties to File Supplemental Briefing #112 is hereby AMENDED as follows: Plaintiff is permitted to file a supplemental brief in support of this argument, not exceeding five pages in length, on or before 7/12/2021. If Plaintiff files a supplemental brief by 7/12/2021, Defendants may respond by filing a supplemental opposition brief, not to exceed five pages, on or before 7/19/2021. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (smom) TEXT ONLY ENTRY
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Filing 115
ORDER by Magistrate Judge John E. McDermott: Granting #108 APPLICATION for Judgment Debtor Exam. Judgment Debtor Exam set for 8/5/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (es)
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Filing 114
ORDER by Magistrate Judge John E. McDermott: Granting #109 APPLICATION for Judgment Debtor Exam. Judgment Debtor Exam set for 8/5/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (es)
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Filing 113
ORDER by Magistrate Judge John E. McDermott: Granting #110 APPLICATION for Judgment Debtor Exam. Judgment Debtor Exam set for 8/5/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (es)
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Filing 112
MINUTES (IN CHAMBERS) ORDER DIRECTING PARTIES TO FILE SUPPLEMENTAL BRIEFING RE: MOTION TO SET ASIDE DEFAULT JUDGMENT #96 by Judge Michael W. Fitzgerald. Plaintiff is permitted to file a supplemental brief in support of this argument, not exceeding five pages in length, on or before July 12, 2021. If Plaintiff files a supplemental brief by June 15, 2021, Defendants may respond by filing a supplemental opposition brief, not to exceed five pages, on or before July 19, 2021. (iv)
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| Filing 111 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: APPLICATION for Judgment Debtor Exam as to James Industry Group Co., Ltd. #109 . The following error(s) was/were found: Case number is incorrect or missing. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (es) |
| Filing 110 APPLICATION for Judgment Debtor Exam as to James Trading Company Limited filed by Plaintiff Constance Jones. Application set for hearing on 7/27/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
| Filing 109 APPLICATION for Judgment Debtor Exam as to James Industry Group Co., Ltd. filed by Plaintiff Constance Jones. Application set for hearing on 7/27/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
| Filing 108 APPLICATION for Judgment Debtor Exam as to Every Industry LLC filed by Plaintiff Constance Jones. Application set for hearing on 7/20/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
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Filing 107
ORDER by Magistrate Judge John E. McDermott: Granting #106 APPLICATION for Judgment Debtor Exam. Judgment Debtor Exam set for 7/20/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (es)
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| Filing 106 APPLICATION for Judgment Debtor Exam as to Li Shuang Qi filed by Plaintiff Constance Jones. Application set for hearing on 7/20/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
| Filing 105 NOTICE of Withdrawal of Application for Appearance and Examination Set for July 6, 2021 filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 104 MINUTES OF TELEPHONIC - DEFENDANTS MOTION TO SET ASIDE DEFAULT JUDGMENT #96 held before Judge Michael W. Fitzgerald. Case called, and counsel make their appearance. For the reasons stated on the record and in light of the appeal, the Court does not rule on the motion. Court Reporter: Amy Diaz. (iv) |
| Filing 103 APPLICATION for Judgment Debtor Exam as to All Defendants filed by Plaintiff Constance Jones. Application set for hearing on 7/6/2021 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Proposed Order) (McMillan, Heather) |
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Filing 102
SCHEDULING NOTICE AND ORDER by Judge Michael W. Fitzgerald. Pursuant to General Order 21-07, DEFENDANTS MOTION TO SET ASIDE DEFAULT JUDGMENT #96 set for June 7, 2021 will be held telephonically at 9:00 a.m. Counsel shall use the following conference call information: Number: (877) 411-9748; Access Code: 6448503. Counsel are ordered to remain available from 9:00 a.m. - 10:00 a.m. Any tentative ruling the Court may prepare, will be emailed to counsel prior to the hearing. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (rs) TEXT ONLY ENTRY
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| Filing 101 REPLY TO PLAINTIFFS OPPOSITION TO NOTICE OF MOTION AND MOTION to Set Aside Judgment RE: Default Judgment,, #92 #96 filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (Cheng, Paul) |
| Filing 100 NOTIFICATION from Ninth Circuit Court of Appeals of case number assigned and briefing schedule. Appeal Docket No. 21-55529 assigned to Notice of Appeal to 9th Circuit Court of Appeals, #98 as to Defendant Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (iv) |
| Filing 99 REPRESENTATION STATEMENT re Notice of Appeal to 9th Circuit Court of Appeals, #98 . (Lin, David) |
| Filing 98 NOTICE OF APPEAL to the 9th Circuit Court of Appeals filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Appeal of Default Judgment,, #92 . (Appeal Fee - $505 Fee Paid, Receipt No. ACACDC-31333964.) (Attachments: #1 Notice of Appeal, #2 Notice of Appeal-, #3 Notice of Appeal)(Lin, David) |
| Filing 97 Opposition re: NOTICE OF MOTION AND MOTION to Set Aside Judgment RE: Default Judgment,, #92 #96 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration, #2 Supplement)(McMillan, Heather) |
| Filing 96 NOTICE OF MOTION AND MOTION to Set Aside Judgment RE: Default Judgment,, #92 filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Motion set for hearing on 6/7/2021 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration of George Wu In Support of Motion, #2 Declaration of David T. Ching In Support of Motion, #3 Proposed Order) (Cheng, Paul) |
| Filing 95 Notice of Appearance or Withdrawal of Counsel: for attorney Paul Po-Ren Cheng counsel for Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Adding David T. Ching as counsel of record for JAMES TRADING COMPANY LIMITED; JAMES INDUSTRY GROUP CO, LTD.; EVERY INDUSTRY, LLC; LI SHUANG QI aka JAMES BOND for the reason indicated in the G-123 Notice. Filed by Attorney for Defendants David T. Ching. (Cheng, Paul) |
| Filing 94 Notice of Appearance or Withdrawal of Counsel: for attorney Paul Po-Ren Cheng counsel for Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Adding Paul P. Cheng as counsel of record for JAMES TRADING COMPANY LIMITED; JAMES INDUSTRY GROUP CO, LTD.; EVERY INDUSTRY, LLC; LI SHUANG QI aka JAMES BOND for the reason indicated in the G-123 Notice. Filed by Attorney for Defendants Paul P. Cheng. (Attorney Paul Po-Ren Cheng added to party Every Industry LLC(pty:dft), Attorney Paul Po-Ren Cheng added to party James Industry Group Co., Ltd.(pty:dft), Attorney Paul Po-Ren Cheng added to party James Trading Company Limited(pty:dft), Attorney Paul Po-Ren Cheng added to party Li Shuang Qi(pty:dft))(Cheng, Paul) |
| Filing 92 DEFAULT JUDGMENT by Judge Michael W. Fitzgerald. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that judgment be entered in favor of Plaintiff and against Defendants as follows: Corporate Defendants and Defendant Li Shuang Qi are jointly and severally liable for the sum of $6,520,953.24. Corporate Defendants are jointly and severally liable for an additional $753,337.04 for past lost income damages and $700,248.00 for three years of front pay, totaling $1,453,585.04. Defendant Li Shuang Qi is solely liable for an additional $2,800 in attorneys' fees. ( MD JS-6. Case Terminated ) (iv) |
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Filing 91
MINUTES (IN CHAMBERS) ORDER GRANTING MOTION FOR DEFAULT JUDGMENT AGAINST DEFENDANTS JAMES TRADING COMPANY LIMITED, JAMES INDUSTRY GROUP CO. LTD., AND EVERY INDUSTRY LLC #80 ; MOTION FOR DEFAULT JUDGMENT AGAINST DEFENDANT LI SHUANG QI AKA JAMES BOND #87 by Judge Michael W. Fitzgerald. For the foregoing reasons, the Motion is GRANTED. Plaintiffs discovery motions (Docket Nos. #45 , #47 , #49 , #51 , and #62 ) are DENIED as moot. A separate judgment shall issue. (iv)
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| Filing 93 Mail Returned addressed to Li Shuang Qi re Text Only Scheduling Notice 88 . (iv) |
| Filing 90 STATUS REPORT of DISCOVERY MOTIONS AGAINST EVERY INDUSTRY LLC filed by Plaintiff Constance Jones. (McMillan, Heather) |
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Filing 89
MINUTES (IN CHAMBERS) ORDER RE PLAINTIFFS DISCOVERY MOTIONS (Docket Nos. 45, 47, 49, 51 and 62) by Magistrate Judge John E. McDermott: In regard to Plaintiff's still pending discovery motions (Dkt. 45, 47, 49, 51 and 62), the entry of default against Defendant Every Industry LLC (Dkt. 77, 78) appears to have mooted the aforementioned discovery motions. The Court ORDERS Plaintiff Constance Jones to file a Status Report by February 24, 2021 confirming these motions are moot. (es)
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| Filing 88 SCHEDULING NOTICE by Judge Michael W. Fitzgerald. Pursuant to General Order 20-09, Rule 78 of the Federal Rules of Civil Procedure and Local Rule 7-15, the Court finds the MOTION FOR DEFAULT JUDGMENT BY COURT AGAINST LI SHUANG QI aka JAMES BOND #87 is appropriate for submission on the papers without oral argument. Accordingly, the hearing set on this motion for February 22, 2021 is vacated and taken off calendar. If the Court determines that a hearing is necessary, one will be reset at a later date. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY |
| Filing 87 APPLICATION for Default Judgment against Defendant Li Shuang Qi aka James Bond filed by Plaintiff Constance Jones. Application set for hearing on 2/22/2021 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration, #2 Proposed Order) (McMillan, Heather) |
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Filing 86
SCHEDULING NOTICE and ORDER by Judge Michael W. Fitzgerald. Pursuant to General Order 20-09 and Rule 78 of the Federal Rules of Civil Procedure and Local Rule 7-15, the Court finds the MOTION FOR DEFAULT JUDGMENT #80 appropriate for submission on the papers without oral argument. Accordingly, the hearing set on this motion for January 25, 2021 is vacated and taken off calendar. If the Court determines that a hearing is necessary, one will be reset at a later date. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (rs) TEXT ONLY ENTRY
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Filing 85
ORDER GRANTING EXTENSION OF TRIAL AND RELATED PRETRIAL DEADLINES #83 by Judge Michael W. Fitzgerald. Final Pretrial Conference and Hearing on Motions in Limine: August 23, 2021, at 11:00 a.m. Trial Date (Est. 7-10 Days): September 14, 2021, at 8:30 a.m. SEE ORDER FOR DETAILS. (iv)
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| Filing 84 DEFAULT BY CLERK F.R.Civ.P.55(a) as to Li Shuang Qi aka James Bond. (iv) |
| Filing 83 Second REQUEST to Set Trial Date on 09/14/2021 and Extending Related Pretrial Deadlines filed by Plaintiff Constance Jones. (Attachments: #1 Declaration, #2 Proposed Order) (McMillan, Heather) |
| Filing 82 First REQUEST for Entry of Default against Defendant Li Shuang Qi filed by Plaintiff Constance Jones. (Attachments: #1 Declaration) (McMillan, Heather) |
| Filing 81 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting APPLICATION for Default Judgment against Plaintiff Constance Jones #80 (McMillan, Heather) |
| Filing 80 APPLICATION for Default Judgment against Defendants James Trading Company Limited, James Industry Group Co., Ltd., and Every Industry LLC filed by Plaintiff Constance Jones. Application set for hearing on 1/25/2021 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration of Constance Jones in Support, #2 Declaration of Heather K. McMillan in Support, #3 Proposed Order) (McMillan, Heather) Modified on 12/28/2020 per Notice of Errata #81 (smom). |
| Filing 78 DEFAULT BY CLERK F.R.Civ.P.55(a) as to James Trading Company Limited, James Industry Group Co., Ltd, Every Industry LLC. (iv) |
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Filing 79
SELF-REPRESENTATION ORDER by Judge Michael W. Fitzgerald. (iv)
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Filing 77
MINUTES (IN CHAMBERS) ORDER AUTHORIZING THE CLERK TO ENTER DEFAULT AGAINST DEFENDANT by Judge Michael W. Fitzgerald. Because the Court is satisfied that Corporate Defendants were given actual notice of the Prior Order, the Clerk is ORDERED to enter default against Corporate Defendants. (iv)
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| Filing 76 DECLARATION of Heather K. McMillan re Deficiency - Default /Default Judgment (CV-52b) - optional html form, #75 filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 75 NOTICE OF DEFICIENCY Re: Request for Clerk to Enter Default #70 , #71 , #72 . The Clerk cannot enter the requested relief as: Clerk is not authorized to process Default, due to the complexities in the service of summons and complaint of corporation in foreign country. Request for Entry of Default has been forwarded to the assigned Judge. (iv) |
| Filing 74 Amendment to REQUEST for Clerk to Enter Default against Defendant Every Industry LLC #72 Declaration of Heather K. McMillan filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 73 Amendment to REQUEST for Clerk to Enter Default against Defendant James Industry Group Co., Ltd. #71 Declaration of Heather K. McMillan filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 72 REQUEST for Clerk to Enter Default against Defendant Every Industry LLC filed by Plaintiff Constance Jones. Request set for hearing on 12/7/2020 at 09:00 AM before Judge Michael W. Fitzgerald. (McMillan, Heather) |
| Filing 71 REQUEST for Clerk to Enter Default against Defendant James Industry Group Co., Ltd. filed by Plaintiff Constance Jones. Request set for hearing on 12/7/2020 at 09:00 AM before Judge Michael W. Fitzgerald. (McMillan, Heather) |
| Filing 70 REQUEST for Clerk to Enter Default against Defendant James Trading Company Limited filed by Plaintiff Constance Jones. Request set for hearing on 12/7/2020 at 09:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration) (McMillan, Heather) |
| Filing 69 Proof of Service filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi re: Order on Motion to Withdraw as Attorney,,,,,,, #68 (Kulkarni, Radha) |
| Filing 68 MINUTES (IN CHAMBERS) by Judge Michael W. Fitzgerald re #52 MOTION to Withdraw as Attorney. The Motion is GRANTED, #52 . Counsel shall serve a copy of this Order on Defendants by mail, e-mail, or any other practical means of service calculated to give actual notice of the withdrawal, and then file a proof ofservice within five court days of the filing of this Order. After filing the proof of service, Counsel are GRANTED LEAVE to withdraw and will be deemed withdrawn as counsel of record. The docket shall reflect the withdrawal.The action is STAYED until November 30, 2020, or until all Defendants filenotice with the Court that they have retained new counsel, whichever comes first. As for Defendants James Trading Company Limited, James Industry Group Co., Ltd, and Every Industry LLC (Corporate Defendants), they shall file notice with the Court by no later than November 30, 2020 that they have retained new counsel. The basic rule is that an entity must appear in federal court through counsel. Accordingly, Corporate Defendants cannot proceed pro se in this action. Should Defendants fail to file the above notice, Plaintiff shall apply for entry of default against Corporate Defendants by no later than December 7, 2020, and shall move for default judgment within ten (10) days of entry of default by the Clerk. Defendant Li Shuang Qu aka James Bond shall file notice with the Court by no later than November 30, 2020, that he has retained new counsel or that he has elected to proceed pro se. When an attorney of record ceases to represent individuals, as here, the individuals must appoint another attorney by a signed substitution of attorney form or appear pro se. L.R. 83-2.3.3. If Defendant Li Shuang Qu aka James Bond does not retain new counsel by November 30, 2020, he should be prepared to represent himself. IT IS SO ORDERED. See order for further details. (shb) |
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Filing 67
SCHEDULING NOTICE and ORDER by Judge Michael W. Fitzgerald. Pursuant to General Order 20-09 and Rule 78 of the Federal Rules of Civil Procedure and Local Rule 7-15, the Court finds the MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANTS #52 appropriate for submission on the papers without oral argument. Accordingly, the hearing set on this motion for October 19, 2020 is vacated and taken off calendar. If the Court determines that a hearing is necessary, one will be reset at a later date. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY
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| Filing 66 Notice of Appearance or Withdrawal of Counsel: for attorney Jeffrey K Joyner counsel for Defendants Does, Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. Jeffrey K. Joyner is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendants James Trading Company Limited, et. al.. (Attorney Jeffrey K Joyner added to party Does(pty:dft))(Joyner, Jeffrey) |
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Filing 65
MINUTE ORDER(IN CHAMBERS) ORDER RE PLAINTIFF'S DISCOVERY MOTIONS (Docket Nos. 45, 47, 49, 51 and 62) by Magistrate Judge John E. McDermott: The Court will defer rulings for now on Plaintiff Constance Jones' discovery motions (Dkt. 45, 47, 49, 51 and 62) until the issue of legal representation of Defendant Every Industry, LLC is resolved. The parties need not file additional pleadings on the pending discovery motions for now and the November 3, 2020 Motion to Compel Deposition hearing date (Dkt. 62) is hereby vacated. The Court will review the pending motions after the District Court rules on defense counsels Motion to Withdraw set for hearing on October 19, 2020. (Dkt. 52.) The non-expert discovery cutoff has been extended to February 9, 2021. (Dkt. 64.) The extension should provide sufficient time to resolve the discovery issues not possible now in view of the counsel situation. (es)
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Filing 64
ORDER GRANTING EXTENSION OF TRIAL AND RELATED PRETRIAL DEADLINES #63 by Judge Michael W. Fitzgerald. IT IS HEREBY ORDERED that the trial date and pretrial deadlines in the Courts Order re Jury Trial Dates (Dkt. 41) be extended as follows: Final Pretrial Conference and Hearing on Motions in Limine May 24, 2021, at 11:00 a.m. Trial Date (Est. 7-10 Days) June 15, 2021, at 8:30 a.m. SEE ORDER FOR DETAILS. (iv)
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| Filing 63 Plaintiff's Unopposed Request for Entry of Order Extending Trial and Pretrial Deadlines (Attachments: #1 Declaration, #2 Proposed Order)(McMillan, Heather) |
| Filing 62 NOTICE OF MOTION AND MOTION for Discovery regarding to Compel Deposition of Defendant Every Industry LLC's Person Most Qualified filed by Plaintiff Constance Jones. Motion set for hearing on 11/3/2020 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Memorandum, #2 Declaration, #3 Proposed Order)(McMillan, Heather) |
| Filing 61 REPLY In Support of NOTICE OF MOTION AND MOTION of Jeff K. Joyner to Withdraw as Attorney for Defendants #52 filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (Attachments: #1 Declaration of Jordan Grotzinger)(Kulkarni, Radha) |
| Filing 60 SCHEDULING NOTICE by Magistrate Judge John E. McDermott re Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC #51 , Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One #49 . Hearing is hereby off calendar. A ruling will follow. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (san) TEXT ONLY ENTRY |
| Filing 59 Opposition Opposition re: NOTICE OF MOTION AND MOTION of Jeff K. Joyner to Withdraw as Attorney for Defendants #52 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration, #2 Supplement Plaintiff's Objection to the Declaration of Jeff Joyner, #3 Proposed Order)(McMillan, Heather) |
| Filing 58 REPLY in support Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC #51 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration)(McMillan, Heather) |
| Filing 57 REPLY in support Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One #49 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration)(McMillan, Heather) |
| Filing 56 MEMORANDUM in Opposition to Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One #49 filed by Defendant Every Industry LLC. (Attachments: #1 Declaration of Radha D.S. Kulkarni in Support of Opposition to Motion to Compel Responses to Request for Production, #2 Exhibit A through E of Kulkarni Declaration in Support of Opposition to Motion to Compel Responses to Request for Production)(Joyner, Jeffrey) |
| Filing 55 MEMORANDUM in Opposition to Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC #51 filed by Defendant Every Industry LLC. (Attachments: #1 Declaration of Radha D.S. Kulkarni in Support of Opposition to Motion to Compel Interrogatory Responses, #2 Exhibit A through E of Kulkarni Declaration In Support of Opposition to Motion to Compel Interrogatory Responses)(Joyner, Jeffrey) |
| Filing 54 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS RE: Motion for Leave to Withdrawal as Counsel #52 by Judge Michael W. Fitzgerald. The document is accepted as filed. The hearing date has been rescheduled to 10/19/2020 at 10:00 a.m. (iv) |
| Filing 53 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Motion to Withdraw #52 . The following error(s) was/were found: Hearing has been set for 10/19/2020 at 10:00 am, however, pleading shows a date of 10/12/2020 which is a holiday. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (iv) |
| Filing 52 NOTICE OF MOTION AND MOTION of Jeff K. Joyner to Withdraw as Attorney for Defendants filed by Defendant Every Industry LLC. Motion set for hearing on 10/19/2020 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration of Jeff K. Joyner in Support of Motion for Leave to Withdraw as Counsel for Defendants, #2 Exhibit A to Declaration of Jeff K. Joyner in Support of Motion to Leave to Withdraw as Counsel for Defendants, #3 Proposed Order Granting Greenberg Traurig, LLP's Motion for Leave to Withdraw as Counsel for Defendants) (Joyner, Jeffrey) |
| Filing 51 NOTICE OF MOTION AND Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC filed by Plaintiff Constance Jones. Motion set for hearing on 10/6/2020 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) |
| Filing 50 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC #45 (McMillan, Heather) |
| Filing 49 NOTICE OF MOTION AND Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One filed by Plaintiff Constance Jones. Motion set for hearing on 10/6/2020 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) |
| Filing 48 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One #47 (McMillan, Heather) |
| Filing 47 NOTICE OF MOTION AND Amended MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One filed by Plaintiff Constance Jones. Motion set for hearing on 9/22/2020 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) |
| Filing 46 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One #43 (McMillan, Heather) |
| Filing 45 NOTICE OF MOTION AND Amended MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC filed by Plaintiff Constance Jones. Motion set for hearing on 9/22/2020 at 10:00 AM before Magistrate Judge John E. McDermott. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) |
| Filing 44 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC #42 (McMillan, Heather) |
| Filing 43 NOTICE OF MOTION AND MOTION to Compel Responses to Plaintiff's Request for Production of Documents, Set One filed by Plaintiff Constance Jones. Motion set for hearing on 9/28/2020 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) Modified on 8/31/2020 (es). (Refiled as Dkt. No. 47) |
| Filing 42 NOTICE OF MOTION AND MOTION to Compel Answers to Interrogatories of Defendant Every Industry LLC filed by Plaintiff Constance Jones. Motion set for hearing on 9/28/2020 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Memorandum of Points and Authorities, #2 Declaration of Michael J. Berry, #3 Proposed Order)(McMillan, Heather) Modified on 8/31/2020 (es). (Refiled as Dkt. No. 45) |
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Filing 41
ORDER RE JURY TRIAL by Judge Michael W. Fitzgerald. Last Day to Add Parties/Amend Pleadings due by 2/3/2020. Non-expert Discovery Cut-off 11/9/2020. Last Day to Hear Motions by 12/7/2020. File Memorandum of Contentions of Fact and Law, Exhibit and Witness Lists, Status Report regarding settlement, and all Motions in Limine 2/1/2021. Final Pretrial Conference and Hearing on Motions in Limine set for 2/22/2021 at 11:00 AM. Trial Date (Est. 7-10 Days) set for 3/16/2021 at 8:30 AM. SEE ORDER FOR DETAILS. (iv)
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Filing 40
ORDER/REFERRAL to ADR Procedure No 3 by Judge Michael W. Fitzgerald. Case ordered to a private mediator based upon a stipulation of the parties or by the court order. ADR Proceeding to be held no later than 12/18/2020. (iv)
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| Filing 39 SCHEDULING NOTICE by Judge Michael W. Fitzgerald: The Court, on its own motion, VACATES the Scheduling Conference on October 7, 2019. No appearances shall be made. The Court will review the parties' Joint Rule 26(f) Report and issue pretrial and trial dates, and an Order/Referral to ADR. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (smom) TEXT ONLY ENTRY |
| Filing 38 JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 7-10 days, filed by Plaintiff Constance Jones.. (McMillan, Heather) |
| Filing 37 STATUS REPORT (Supplemental) filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 36 STATUS REPORT re Service of Process on Foreign Defendants filed by Plaintiff Constance Jones. (McMillan, Heather) |
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Filing 35
ORDER SETTING SCHEDULING CONFERENCE by Judge Michael W. Fitzgerald. Scheduling Conference set for October 7, 2019 at 11:00 a.m. READ THIS ORDER CAREFULLY. IT DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. (lom)
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| Filing 34 ANSWER to Amended Complaint/Petition #11 JURY DEMAND. filed by Defendant Every Industry LLC.(Joyner, Jeffrey) |
| Filing 33 21 DAY Summons Issued re Amended Complaint/Petition #11 as to Defendant James Industry Group Co., Ltd. (iv) |
| Filing 32 21 DAY Summons Issued re Amended Complaint/Petition #11 as to Defendant Li Shuang Qi. (iv) |
| Filing 31 21 DAY Summons Issued re Amended Complaint/Petition #11 as to Defendant James Trading Company Limited. (iv) |
| Filing 30 Request for Clerk to Issue Summons on Amended Complaint/Petition #11 filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 29 Request for Clerk to Issue Summons on Amended Complaint/Petition #11 filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 28 Request for Clerk to Issue Summons on Amended Complaint/Petition #11 filed by Plaintiff Constance Jones. (McMillan, Heather) |
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Filing 27
MINUTES (IN CHAMBERS) ORDER RE: MOTION TO DISMISS FIRST AMENDED COMPLAINT PURSUANT TO F.R.C.P. 12(b)(5) FOR INSUFFICIENT SERVICE OF PROCESS #15 ; MOTION TO DISMISS FIRST AMENDED COMPLAINT PURSUANT TO F.R.C.P. 12(b)(6) AND 12(f) #16 by Judge Michael W. Fitzgerald. The Rule 12(b)(5) Motion is DENIED without prejudice for refiling as a renewed motion to dismiss after Defendants James Trading, James Industry, and Mr. Qi have been properly served. The Court QUASHES the service. Plaintiff shall file a status report with the Court on or before July 22, 2019, explaining her efforts at service. The Rule 12(b)(6) Motion is DENIED. Every Industry shall answer the FAC on or before July 15, 2019. (iv)
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| Filing 26 MINUTES OF MOTION TO DISMISS #15 #16 Hearing held before Judge Michael W. Fitzgerald. Case called, and counsel make their appearance. The Court invites counsel to present their oral arguments. Arguments by counsel are heard. For the reasons stated on the record, the Court takes the matter under submission. An order will issue. Court Reporter: Amy Diaz. (lom) |
| Filing 25 Notice of Appearance or Withdrawal of Counsel: for attorney Heather K McMillan counsel for Plaintiff Constance Jones. Adding Michael J. Berry as counsel of record for Constance Jones for the reason indicated in the G-123 Notice. Filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 24 Notice of Appearance or Withdrawal of Counsel: for attorney Heather K McMillan counsel for Plaintiff Constance Jones. Adding Keyan Sedehi as counsel of record for Constance Jones for the reason indicated in the G-123 Notice. Filed by Plaintiff Constance Jones. (McMillan, Heather) |
| Filing 23 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting Objection/Opposition (Motion related), #18 (Attachments: #1 Declaration Declaration of Keyan Sedehi)(McMillan, Heather) |
| Filing 22 NOTICE OF ERRATA filed by Plaintiff Constance Jones. correcting Objection/Opposition (Motion related), #17 (Attachments: #1 Declaration Declaration of Keyan Sedehi)(McMillan, Heather) |
| Filing 21 REPLY In Support of NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11)pursuant to F.R.C.P. 12(b)(6) and 12(f) #16 filed by Defendant Every Industry LLC. (Attachments: #1 Declaration ISO Motion to Dismiss)(Joyner, Jeffrey) |
| Filing 20 REPLY In Support of NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11) pursuant to F.R.C.P. 12(b)(5) for insufficient service of process #15 filed by Defendants James Industry Group Co., Ltd., James Trading Company Limited. (Attachments: #1 Declaration ISO Motion to Dismiss)(Joyner, Jeffrey) |
| Filing 19 NOTICE OF ERRATA filed by Defendant Every Industry LLC. correcting NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11)pursuant to F.R.C.P. 12(b)(6) and 12(f) #16 (Correcting Caption Page of ECF Dkt. No. 16) (Attachments: #1 Exhibit A: Corrected Caption Page for ECF Dkt. No. 16 (Defendant Every Industry LLC Motion to Dismiss and Strike First Amended Complaint))(Joyner, Jeffrey) |
| Filing 18 Opposition Opposition to re: NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11)pursuant to F.R.C.P. 12(b)(6) and 12(f) #16 filed by Plaintiff Constance Jones. (Attachments: #1 Declaration Declaration of Heather K. McMillan)(McMillan, Heather) |
| Filing 17 Opposition Opposition to re: NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11) pursuant to F.R.C.P. 12(b)(5) for insufficient service of process #15 filed by Plaintiff Constance Jones. (Attachments: #1 Supplement Opposition Part 2 of 3, #2 Supplement Opposition Part 3 of 3, #3 Declaration Declaration of Heather K. McMillan)(McMillan, Heather) |
| Filing 16 NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11)pursuant to F.R.C.P. 12(b)(6) and 12(f) filed by Defendant Every Industry LLC. Motion set for hearing on 6/24/2019 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Proposed Order) (Joyner, Jeffrey) |
| Filing 15 NOTICE OF MOTION AND MOTION to Dismiss Case (First Amended Complaint at ECF Dkt. #11) pursuant to F.R.C.P. 12(b)(5) for insufficient service of process filed by Defendant James Industry Group Co., Ltd., James Trading Company Limited. Motion set for hearing on 6/24/2019 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration of Winston Shi, #2 Declaration of Peter Du and Exhibits A and B, #3 Proposed Order) (Joyner, Jeffrey) |
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Filing 14
MINUTES (IN CHAMBERS) ORDER RE: MOTION TO DISMISS COMPLAINT #9 by Judge Michael W. Fitzgerald. The Motion is DENIED as moot and the hearing set for May 13, 2019, is VACATED. (iv)
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| Filing 13 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: First Amended Complaint #11 . The following error(s) was/were found: Local Rule 19-1 Complaint/Petition includes more than 10 Does or fictitiously named parties. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (iv) |
| Filing 12 REPLY In Support Of NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction Pursuant to F.R.C.P. 12(b)(5) for Insufficient Service of Process #9 filed by Defendants James Industry Group Co., Ltd., James Trading Company Limited. (Attachments: #1 Declaration ISO Motion to Dismiss)(Joyner, Jeffrey) |
| Filing 11 First AMENDED COMPLAINT against Defendants All Defendants amending Complaint - (Discovery),, filed by Plaintiff Constance Jones(McMillan, Heather) |
| Filing 10 Opposition Opposition to re: NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction Pursuant to F.R.C.P. 12(b)(5) for Insufficient Service of Process #9 filed by Plaintiff Constance Jones. (Attachments: #1 Supplement Opposition Part 2 of 3, #2 Supplement Opposition Part 3 of 3, #3 Declaration of Keyan Sedehi, #4 Declaration of Winston Shi, #5 Declaration of Heather K. McMillan)(McMillan, Heather) |
| Filing 9 NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction Pursuant to F.R.C.P. 12(b)(5) for Insufficient Service of Process filed by Defendant James Industry Group Co., Ltd., James Trading Company Limited. Motion set for hearing on 5/13/2019 at 10:00 AM before Judge Michael W. Fitzgerald. (Attachments: #1 Declaration of Winston Shi, #2 Declaration of Peter Du and Exhibits A and B, #3 Proposed Order) (Joyner, Jeffrey) |
| Filing 8 STIPULATION Extending Time to Answer the complaint as to Every Industry LLC answer now due 4/29/2019; James Industry Group Co., Ltd. answer now due 4/29/2019; James Trading Company Limited answer now due 4/29/2019; Li Shuang Qi answer now due 4/29/2019, re Complaint - (Discovery), filed by Defendants Every Industry LLC; James Industry Group Co., Ltd.; James Trading Company Limited; Li Shuang Qi.(Kulkarni, Radha) |
| Filing 7 DEMAND for Jury Trial filed by Plaintiff Constance Jones.. (McMillan, Heather) |
| Filing 6 NOTICE of Interested Parties filed by Plaintiff Constance Jones, (McMillan, Heather) |
| Filing 5 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (ghap) |
| Filing 4 NOTICE OF ASSIGNMENT to District Judge Michael W. Fitzgerald and Magistrate Judge John E. McDermott. (ghap) |
| CONFORMED FILED COPY OF PROOF OF SERVICE Executed by Plaintiff Constance Jones, upon Plaintiff Every Industry LLC served on 10/18/2018, answer due 11/8/2018. Service of the Summons and Complaint were executed upon Yan Lin-Registered Agent for Service of Process in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy.Original Summons NOT returned. (FILED IN STATE COURT ON 11/7/2018 SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| CONFORMED FILED COPY OF COMPLAINT against Defendants Does 1 through 50, inclusive, Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi., filed by plaintiff Constance Jones. (FILED IN STATE COURT ON 9/28/2018 SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| CONFORMED FILED COPY OF PROOF OF SERVICE Executed by Plaintiff Constance Jones, upon Defendant James Industry Group Co., Ltd. served on 10/18/2018, answer due 11/8/2018. Service of the Summons and Complaint were executed upon Winston Shi-Engineer in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy.Original Summons NOT returned. (FILED IN STATE COURT ON 11/7/2018 SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| CONFORMED FILED COPY OF PROOF OF SERVICE Executed by Plaintiff Constance Jones, upon Defendant James Trading Company Limited served on 10/18/2018, answer due 11/8/2018. Service of the Summons and Complaint were executed upon James A. Woodahl-Registered Agent for Service of Process in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy.Original Summons NOT returned. (FILED IN STATE COURT ON 11/7/2018 SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| CONFORMED FILED COPY OF PROOF OF SERVICE Executed by Plaintiff Constance Jones, upon Defendant Li Shuang Qi served on 10/18/2018, answer due 11/8/2018. Service of the Summons and Complaint were executed upon Winston Shi-Engineer in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy.Original Summons NOT returned. (FILED IN STATE COURT ON 11/7/2018 SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| NON CONFORM COPY OF NOTICE AND ACKNOWLEDGMENT OF SERVICE of Summons and Complaint returned Executed filed by Plaintiff Constance Jones, upon Defendant Every Industry LLC acknowledgment sent by Plaintiff on 1/31/2019, answer due 2/21/2019. Acknowledgment of Service signed by Radha Kulkarni, Attorney for defendant Every Industry LLC. (SUBMITTED ATTACHED EXHIBIT A) (ghap) |
| Filing 3 Certification and NOTICE of Interested Parties filed by Defendant Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi, (Joyner, Jeffrey) |
| Filing 2 CIVIL COVER SHEET filed by Defendants Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (Joyner, Jeffrey) |
| Filing 1 NOTICE OF REMOVAL from Los Angeles Superior Court, case number BC723451 Receipt No: 0973-23517003 - Fee: $400, filed by Defendant Every Industry LLC, James Industry Group Co., Ltd., James Trading Company Limited, Li Shuang Qi. (Attachments: #1 Exhibit A: Summons and Complaint and Other State Court Materials) (Attorney Jeffrey K Joyner added to party Every Industry LLC(pty:dft), Attorney Jeffrey K Joyner added to party James Industry Group Co., Ltd.(pty:dft), Attorney Jeffrey K Joyner added to party James Trading Company Limited(pty:dft), Attorney Jeffrey K Joyner added to party Li Shuang Qi(pty:dft))(Joyner, Jeffrey) |
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