Shane Kisman v. United Parcel Service, Inc.
| Shane Kisman |
| United Parcel Service, Inc. |
| Daniel Turner |
| 2:2021cv03164 |
| April 13, 2021 |
| US District Court for the Central District of California |
| Andre Birotte |
| Charles F Eick |
| James V Selna |
| Civil Rights: Jobs |
| 42 U.S.C. § 2000 e Job Discrimination (Employment) |
| Plaintiff |
Docket Report
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Filing 120
ORDER GRANTING JOINT STIPULATION TO SET TRIAL-RELATED DEADLINES by Judge Andre Birotte Jr.: The Court GRANTS the parties' Stipulation #119 and SETS Final Pretrial Conference and Hearing on Daubert Motions #104 , #105 on 12/8/2023 11:00 AM before Judge Andre Birotte Jr. Trial and Hearing on Motions in Limine TBD at FPTC. Trial Filings (first round) due by 11/17/2023. Trial Filings (second round) due by 11/29/2023. (gk)
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| Filing 119 Joint STIPULATION to Continue Trial final Pretrial Conference and Trial-Related Deadlines from currently vacated to to be set at FPTC Re: Order,,,, Terminate Deadlines and Hearings,,,, Set/Reset Deadlines/Hearings,,,, Set/Reset Motion Hearing and R&R Deadlines,,, #117 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
| Filing 118 NOTICE of Appearance filed by attorney Phillip James Ebsworth on behalf of Defendant United Parcel Service, Inc. (Attorney Phillip James Ebsworth added to party United Parcel Service, Inc.(pty:dft))(Ebsworth, Phillip) |
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Filing 117
ORDER REGARDING TRIAL AND TRIAL-RELATED DEADLINES by Judge Andre Birotte Jr.: Upon Stipulation #113 , IT IS SO ORDERED that the Trial date, currently set for 11/7/2023, is hereby VACATED, pending the Court's ruling on Defendant's Motion for Summary Judgement. A new trial date will be set at the Final Pretrial Conference. The Final Pretrial Conference and the hearing on Defendant's Motion to Exclude Expert Report, Opinion, and Testimoy of Tim Huegel #104 and Defendant's Motion to Exclude Expert Report, Opinion, and Testimony of Vida Thomas #105 is CONTINUED to 12/8/2023 at 11:00 AM before Judge Andre Birotte Jr. The parties are ORDERED to file within ten days of this order a Stipulation and Proposed Order setting new deadlines for the Parties to file their Witness Lists, pursuant to L.R. 16-5, and a Joint Exhibit List, pursuant to L.R. 16-6.1. Parties must also include the new deadline to file the remaining first round and second round of trial filings. (gk)
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Filing 116
ORDER by Judge Andre Birotte Jr. Granting Request for Approval of Substitution of Attorney Jon Meer for Defendant United Parcel Service, Inc. in place of Attorney David W. Ammons #112 . (gk)
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| Filing 115 OPPOSITION re: MOTION to Exclude #104 EXPERT REPORT, OPINION, AND TESTIMONY OF TIM HUEGEL filed by Plaintiff Shane Kisman. (Shegerian, Carney) |
| Filing 114 OPPOSITION re: MOTION to Exclude #105 EXPERT REPORT, OPINION, AND TESTIMONY OF VIDA THOMAS filed by Plaintiff Shane Kisman. (Shegerian, Carney) |
| Filing 113 Joint STIPULATION to Continue Trial Setting and Trial-Related Deadlines from November 7, 2023 to TBD Re: Order on Motion to Continue,, #103 , Joint STIPULATION for Jury Trial on TBD filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
| Filing 112 REQUEST TO SUBSTITUTE ATTORNEY Jon Meer in place of attorney David W. Ammons filed by defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order on Request for Approval of Substitution (G-01)) (Attorney Jonathan D Meer added to party United Parcel Service, Inc.(pty:dft)) (Meer, Jonathan) |
| Filing 111 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice (Other) #107 . The following error(s) was/were found: Incorrect event selected. Correct event to be used is: Notice of Association of Counsel.. 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. (ak) |
| Filing 110 MEDIATION REPORT Filed by Defendant United Parcel Service, Inc.: Mediation held on June 16, 2023. The parties are unable to reach an agreement at this time.Counsel: Please evaluate the effectiveness of the ADR Program by completing a survey on your mediation experience. To access the survey, click on the following link: #MediationParticipantSurvey(Farmer, Dylan) |
| Filing 109 Notice of Appearance or Withdrawal of Counsel: for attorney Carney R Shegerian counsel for Plaintiff Shane Kisman. Adding Carney R. Shegerian as counsel of record for Plaintiff Shane Kisman for the reason indicated in the G-123 Notice. Filed by Plaintiff Shane Kisman. (Shegerian, Carney) |
| Filing 108 Notice of Appearance or Withdrawal of Counsel: for attorney Carney R Shegerian counsel for Plaintiff Shane Kisman. Adding Mark Lim as counsel of record for Plaintiff Shane Kisman for the reason indicated in the G-123 Notice. Filed by Plaintiff Shane Kisman. (Attorney Carney R Shegerian added to party Shane Kisman(pty:pla))(Shegerian, Carney) |
| Filing 107 Notice NOTICE OF ASSOCIATION filed by plaintiff Shane Kisman. (Shegerian, Carney) |
| Filing 106 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice (Other), #104 , Notice (Other) #105 . The following error(s) was/were found: Hearing information is missing, incorrect, or untimely. Incorrect event selected. Correct event to be used is: Applications/Ex Parte Applications/Motions/Petitions/Requests > Exclude. As only a motion-type event will prompt the filer to place the motion on calendar, for this one-time only, the clerk shall convert the docketing event. However, rather than the noticed date of 10/6/2023 at 10:00 AM, the matter shall be placed on calendar for the same date as the Pretrial Conference, 10/20/2023 at 11:00 AM. 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. (gk) |
| Filing 105 Notice of Motion & Motion to Exclude Expert Report, Opinion, and Testimony of Vida Thomas filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Memorandum, #2 Exhibit 1, #3 Proposed Order)(Farmer, Dylan) Modified on 9/8/2023 (gk). |
| Filing 104 Notice of Motion & Motion to Exclude Expert Report, Opinion, and Testimony of Tim Huegel filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Memorandum, #2 Exhibit 1, #3 Exhibit 2, #4 Proposed Order)(Farmer, Dylan) Modified on 9/8/2023 (gk). |
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Filing 103
ORDER GRANTING JOINT STIPULATION TO CONTINUE TRIAL SETTING AND TRIAL-RELATED DEADLINES by Judge Andre Birotte Jr.: The Court GRANTS the Stipulation #101 . The relevant dates are CONTINUED. Jury Trial set for 11/7/2023 08:30 AM before Judge Andre Birotte Jr. Final Pretrial Conference set for 10/20/2023 11:00 AM before Judge Andre Birotte Jr. Last Date to Hear Daubert Motions 10/20/2023. Trial Filings (first round) due by 9/29/2023. Trial Filings (second round) due by 10/6/2023. The Court further ORDERS that Defendant United Parcel Service, Inc.'s Motion to Continue Trial Setting and Trial-Related Deadlines #93 is DENIED AS MOOT. The hearing scheduled for 7/14/2023 is vacated. See document for further details. (gk)
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| Filing 102 MINUTES OF Motion Hearing (Video Conference - Zoom) held before Judge Andre Birotte Jr. RE: Motion to Continue Trial Setting and Trial Related Deadlines #93 . Court and counsel confer. For the reasons stated on the record, the Court continues the matter to 7/14/2023 at 10:00 AM before Judge Andre Birotte Jr. Court Reporter: Katie Thibodeaux. (gk) |
| Filing 101 Joint STIPULATION to Continue Trial Setting and Trial Related Deadlines from 8/15/2023 to 11/7/2023 Re: Order,,,, Set/Reset Deadlines/Hearings,,, #58 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
| Filing 100 MEMORANDUM in Support of NOTICE OF MOTION AND MOTION to Continue Trial Setting and Trial Related Deadlines from 8/15/2023 to 10/17/2023 #93 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Declaration of Dylan Farmer)(Farmer, Dylan) |
| Filing 99 PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION TO CONTINUE TRIAL AND TRIALRELATED DEADLINES in opposition re: NOTICE OF MOTION AND MOTION to Continue Trial Setting and Trial Related Deadlines from 8/15/2023 to 10/17/2023 #93 filed by Plaintiff Shane Kisman. (Attachments: #1 Declaration DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION TO CONTINUE TRIAL AND TRIALRELATED DEADLINES)(Cantor, Zachary) |
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Filing 98
ORDER RE STIPULATION TO EXPEDITE HEARING ON DEFENDANT'S MOTION TO CONTINUE TRIAL SETTING AND TO EXTEND PLAINTIFF'S RESPONSE DEADLINE by Judge Andre Birotte Jr.: It is hereby ordered that, pursuant to the Stipulation #97 , the hearing on UPS's Motion to Continue Trial Setting #93 is set for 6/30/2023 at 10:00 AM before Judge Andre Birotte Jr. It is further ordered that Kisman's deadline to file a response in opposition to UPSs Motion is 6/28/2023. (gk)
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| Filing 97 Joint STIPULATION to Expedite Hearing on Motion to Continue Trial Setting [Dkt. 93] to 6/30/2023 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
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Filing 96
MINUTES (IN CHAMBERS) ORDER DENYING Defendant's Motion to Expedite Without Prejudice by Judge Andre Birotte Jr.: UPS can file an ex parte application, consistent with our Local Rules. Or it can file a regularly noticed motion, consistent with our Local Rules. But it cannot file a hybrid, accelerated motion that ducks L.R. 7-3. Accordingly, Defendant's Motion to Expedite #94 is DENIED WITHOUT PREJUDICE. The Court encourages the parties to resolve disputes regarding the timing of Defendant's Motion to Continue on their own. Court Reporter: N/A. (gk)
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| Filing 95 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: NOTICE OF MOTION AND MOTION to Expedite Hearing on Motion to Continue Trial Setting #94 . The following error(s) was/were found: Hearing information is missing, incorrect, or untimely. The filer set this motion for hearing on 6/30/2023 at 10:00 AM. 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. (gk) |
| Filing 94 NOTICE OF MOTION AND MOTION to Expedite Hearing on Motion to Continue Trial Setting filed by Defendant United Parcel Service, Inc.. Motion set for hearing on 6/30/2023 at 10:00 AM before Judge Andre Birotte Jr. (Attachments: #1 Proposed Order) (Farmer, Dylan) |
| Filing 93 NOTICE OF MOTION AND MOTION to Continue Trial Setting and Trial Related Deadlines from 8/15/2023 to 10/17/2023 filed by Defendant United Parcel Service, Inc.. Motion set for hearing on 7/14/2023 at 10:00 AM before Judge Andre Birotte Jr. (Attachments: #1 Exhibit A, #2 Proposed Order) (Farmer, Dylan) |
| Filing 92 MINUTES OF Motion Hearing held before Judge Andre Birotte Jr. RE: Defendant's Motion for Summary Judgment #66 . The Court having carefully considered the papers and the evidence submitted by the parties, and having heard the oral argument of counsel, hereby takes the motion under submission. Court Reporter: Katherine Stride. (gk) |
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Filing 91
ORDER RE: CONTINUANCE OF MEDIATION DEADLINE AND LOCAL RULE 16-2 MEET AND CONFER DEADLIEN by Judge Andre Birotte Jr, Re: Stipulation #90 . It is hereby ordered that, the deadline for the parties to mediate this matter is continued to 6/16/2023. The deadline for the parties to meet and confer pursuant to Local Rule 16-2 is continued to 6/23/2023. The other deadlines in the Courts prevailing scheduling order remain in effect. (vdr)
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| Filing 90 Joint STIPULATION to Continue Mediation Deadline and Rule 16-2 Meet-and-Confer Deadline from May 19, 2023 to June 16, 2023 Re: Order on Motion to Extend Time to File 28:2241/2254, #63 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
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Filing 89
(IN CHAMBERS) ORDER CONTINUING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT #66 by Judge Andre Birotte Jr. This Court, on its own motion, hereby continues the hearing date regarding this motion from May 5, 2023, to May 26, 2023, at 10:00 AM before Judge Andre Birotte Jr. SO ORDERED.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cb) TEXT ONLY ENTRY
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| Filing 88 REPLY Support NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit Reply ISO UPS SUF, #2 Memorandum Objections to Plaintiff's MSJ Evidence, #3 Exhibit Exhibit G - Farmer Declaration and Exhibits, #4 Exhibit Response to Plaintiff's Stmt of AMF)(Farmer, Dylan) |
| Filing 87 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 68-81 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 68-71, #2 Exhibit EXHIBITS 72-75, #3 Exhibit EXHIBITS 76-81)(Cantor, Zachary) |
| Filing 86 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 55B-67 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 55B-65, #2 Exhibit EXHIBIT 66, #3 Exhibit EXHIBIT 67)(Cantor, Zachary) |
| Filing 85 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 46-55A IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 46-51A, #2 Exhibit EXHIBITS 51B-55A)(Cantor, Zachary) |
| Filing 84 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 42A-45B IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 42A-43, #2 Exhibit EXHIBITS 43A-45B)(Cantor, Zachary) |
| Filing 83 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 38B-42 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBIT 38B PART 1, #2 Exhibit EXHIBIT 38B PART 2, #3 Exhibit EXHIBITS 39-42)(Cantor, Zachary) |
| Filing 82 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 32B-38A IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 32B-37G, #2 Exhibit EXHIBITS 38-38A)(Cantor, Zachary) |
| Filing 81 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 28-32A IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 28-32A)(Cantor, Zachary) |
| Filing 80 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 25-27 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 25-27)(Cantor, Zachary) |
| Filing 79 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 11-24 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 11-22, #2 Exhibit EXHIBITS 23-24)(Cantor, Zachary) |
| Filing 78 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 EXHIBITS 3-10 IN SUPPORT OF DECLARATION OF ZACHARY CANTOR IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT #77 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 3-3B, #2 Exhibit EXHIBITS 4-6, #3 Exhibit EXHIBITS 7-10)(Cantor, Zachary) |
| Filing 77 DECLARATION of ZACHARY CANTOR in support of opposition to Motion for Summary Judgement NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit EXHIBITS 1-2)(Cantor, Zachary) |
| Filing 76 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 filed by Plaintiff Shane Kisman. (Attachments: #1 Memorandum PLAINTIFFS STATEMENT OF GENUINE ISSUES OF ADDITIONAL MATERIAL FACT IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT, #2 Memorandum PLAINTIFFS OPPOSITION TO DEFENDANTS STATEMENT OF GENUINE ISSUES OF MATERIAL FACT, #3 Exhibit NOTICE OF MANUEL FILING EXHIBIT 32A, #4 Exhibit NOTICE OF MANUEL FILING EXHIBIT 32B, #5 Exhibit NOTICE OF MANUEL FILING EXHIBIT 55B, #6 Affidavit CERTIFICATE OF SERVICE)(Cantor, Zachary) |
| Filing 75 Notice of Withdrawal of Motion for Relief of Discovery Matter #73 , Motion for Relief of Discovery Matter, #72 filed by Defendant United Parcel Service, Inc.. (Farmer, Dylan) |
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Filing 74
ORDER RE CONTINUANCE OF DAUBERT/RULE 702 MOTION HEARING DEADLINE by Judge Andre Birotte Jr.: Pursuant to the Stipulation #69 , the deadline for the Court to hear Daubert/Rule 702 motions to exclude or limit expert testimony is continued to 7/28/2023. (gk)
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| Filing 73 NOTICE OF MOTION AND MOTION for Relief from Exclusion of Expert Thomas' Report and Testimony filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Memorandum, #2 Exhibit 1, #3 Proposed Order)(Farmer, Dylan) |
| Filing 72 NOTICE OF MOTION AND MOTION for Relief from Exclusion of Expert Huegel's Report and Testimony filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Memorandum, #2 Exhibit 1, #3 Exhibit 2, #4 Proposed Order)(Farmer, Dylan) |
| Filing 71 NOTICE OF ASSIGNMENT of Panel Mediator. Mediator (ADR Panel) Daniel Turner has been assigned to serve as Panel Mediator. (lst) |
| Filing 70 STIPULATION REGARDING SELECTION of Panel Mediator filed. Parties stipulate that Daniel J. Turner may serve as Panel Mediator. Plaintiff obtained the Panel Mediators consent to serve. All parties and the Panel Mediator have agreed that the mediation will be held on 5/19/2023 and counsel will submit mediation statements seven (7) calendar days before the session. Filed by Defendant United Parcel Service, Inc.(Farmer, Dylan) |
| Filing 69 Joint STIPULATION to Continue Deadline to Hear Daubert / Rule 702 Motions from May 5, 2023 to July 28, 2023 Re: Order on Motion to Extend Time to File 28:2241/2254, #63 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
| Filing 68 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Exhibit to Motion, #67 . The following error(s) was/were found: Local Rule 11-3.8 title page is missing, incomplete, or incorrect. 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. (gk) |
| Filing 67 EXHIBIT C-F In Support of Motion for Summary Judgment to NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action #66 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit Declaration of Bruce McRae, #2 Exhibit Declaration of Darren Moore, #3 Exhibit Declaration of Robert McCrea, #4 Proposed Order)(Farmer, Dylan) |
| Filing 66 NOTICE OF MOTION AND MOTION for Summary Judgment as to All Causes of Action filed by Defendant United Parcel Service, Inc.. Motion set for hearing on 5/5/2023 at 10:00 AM before Judge Andre Birotte Jr. (Attachments: #1 Memorandum Statement of Undisputed Facts, #2 Memorandum Memorandum of Points and Authorities, #3 Exhibit Declaration of Dylan Farmer, #4 Exhibit Declaration of Philip Cote) (Farmer, Dylan) |
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Filing 65
ORDER GRANTING STIPULATION OF DISMISSAL WITH PREJUDICE OF AGE DISCRIMINATION CLAIM #64 by Judge Andre Birotte Jr. It is hereby ordered that, pursuant to the stipulation between Shane Kisman (Plaintiff) and United Parcel Service, Inc. (Defendant), Plaintiffs First Cause of Actionfor age discrimination under California state law and the Age Discrimination in Employment Act is hereby DISMISSED WITH PREJUDICE. Plaintiff's remaining causes of action (2-12) remain pending. IT IS SO ORDERED. (rolm)
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| Filing 64 Joint STIPULATION to Dismiss Case pursuant to Age Discrimination Claim filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
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Filing 63
ORDER GRANTING JOINT STIPULATION TO EXTEND NON-TRIAL-RELATED CASE DEADLINES by Judge Andre Birotte Jr.: Upon the parties' Joint Stipulation #62 , IT IS HEREBY ORDERED that the following are CONTINUED: (1) Expert Disclosure (Rebuttal) deadline 1/20/2023, (2) Expert Discovery Cut-Off 3/31/2023, (3) Last Date to Hear Motions 5/5/2023, and (4) Deadline to Complete Settlement Conference 5/19/2023. See document for further details. (gk)
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| Filing 62 Joint REQUEST to Extend Time to file Joint Stipulation to Extend Non-Trial-Related Case Deadlines and Motion to Amend Scheduling Order petition to 5/5/2023 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B) (Farmer, Dylan) |
| Filing 61 NOTICE of Change of address by David Wesley Ammons attorney for Defendant United Parcel Service, Inc.. Changing attorneys address to 300 S. Grand Ave., Suite 3950, Los Angeles, CA 90071. Filed by Defendant United Parcel Service, Inc.. (Ammons, David) |
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Filing 60
ORDER RE CONTINUANCE OF EXPERT DISCLOSURE DUE DATES [F.R.C.P. 26(a)(2)(B)] by Judge Andre Birotte Jr.: It is hereby ordered that, pursuant to the Stipulation #59 , the dates for full compliance with FRCP 26(a)(2)(B) regarding providing expert reports with initial disclosures is continued to 11/3/2022 (initial reports), and expert reports with rebuttal disclosures is continued to 12/9/2022. (gk)
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| Filing 59 Second STIPULATION to Continue Expert Disclosure Deadlines from October 12, 2022 to November 3, 2022 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order)(Farmer, Dylan) |
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Filing 58
ORDER GRANTING JOINT STIPULATION TO EXTEND CASE DEADLINES AND TRIAL DATE by Judge Andre Birotte Jr.: Upon Stipulation #56 , IT IS HEREBY ORDERED that the pre-trial and trial dates are CONTINUED: Jury Trial set for 8/15/2023 08:30 AM before Judge Andre Birotte Jr. Final Pretrial Conference set for 7/28/2023 11:00 AM before Judge Andre Birotte Jr. Last Date to Hear Motion to Amend Pleadings/Add Parties 2/4/2022. Non-Expert Discovery cut-off 1/24/2023. Last Date to Hear Motions 3/14/2023. Deadline to Complete Settlement Conference 3/28/2023. Trial Filings (first round) due by 7/7/2023. Trial Filings (second round) due by 7/14/2023. Furthermore, the Court's prior ADR Referral Order (see ECF No. 29) is REVISED and the case is referred to the Court Medial Panel. See document for further details. (gk)
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| Filing 57 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS by Clerk RE: Stipulation filed 5/19/2022 #54 . Counsel shall immediately file a Proposed Order and email a Microsoft Word version of the Proposed Order to the chambers email address. (gk) |
| Filing 56 Amended Joint Stipulation to Extend Case Deadlines and Trial Date and Motion to Amend order Regarding Jury//Court Trial and Order/Referral to ADR (Attachments: #1 Exhibit A (Schedule of Pre-Trial and Trial Dates Worksheet), #2 Proposed Order)(Farmer, Dylan) |
| Filing 55 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Miscellaneous Document #54 . The following error(s) was/were found: Proposed order not submitted pursuant to Local Rule 52-4.1. 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. (gk) |
| Filing 54 Joint Stipulation to Extend Case Deadlines and Trial Date and Motion to Amend Order Regarding Jury/Court Trial (Attachments: #1 Exhibit Schedule of Pretrial and Trial Dates Worksheet)(Farmer, Dylan) |
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Filing 53
ORDER by Judge Andre Birotte Jr: granting #52 Non-Resident Attorney William R. Liles APPLICATION to Appear Pro Hac Vice on behalf of United Parcel Service, Inc., designating David Wesley Ammons as local counsel. (lom)
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| Filing 52 APPLICATION of Non-Resident Attorney William R. Liles to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33127280) filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order) (Ammons, David) |
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Filing 51
ORDER RE CONTINUANCE OF EXPERT DISCLOSURE DUE DATES [F.R.C.P. 26(a)(2)(B)] by Judge Andre Birotte Jr.: Upon Stipulation #50 , IT IS HEREBY ORDERED that the parties' deadline to provide initial expert disclosures is continued to 6/15/2022 and the parties' deadline to provide rebuttal expert disclosures is continued to 7/22/2022. (gk)
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| Filing 50 STIPULATION for Extension of Time to File Expert Disclosures filed by Plaintiff Shane Kisman. (Attachments: #1 Proposed Order [PROPOSED] ORDER RE CONTINUANCE OF EXPERT DISCLOSURE DUE DATES)(Cantor, Zachary) |
| Filing 49 INITIAL DISCLOSURE of Expert Witnesses filed by Plaintiff Shane Kisman (Cantor, Zachary) |
| Filing 48 Expert Designations filed by Defendant United Parcel Service, Inc. (Farmer, Dylan) |
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Filing 47
ORDER DENYING DEFENDANT'S MOTION TO AMEND ORDER DENYING MOTION TO DISMISS AND TRANSFER VENUE TO CERTIFY ORDER FOR PERMISSIVE INTERLOCUTORY APPEAL by Judge Andre Birotte Jr.: The Court DENIES Defendant United Parcel Service, Inc.'s Motion for Permissive Interlocutory Appeal #41 and reaffirms its 8/13/2021 Order finding venue is proper in this district. (gk)
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| Filing 46 Notice of Appearance or Withdrawal of Counsel: for attorney David Wesley Ammons counsel for Defendant United Parcel Service, Inc.. Julia Levitskaia is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendant United Parcel Service, Inc. (Ohio). (Ammons, David) |
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Filing 45
(IN CHAMBERS) ORDER TAKING DEFENDANT'S MOTION TO AMEND ORDER DENYING MOTIONS TO DISMISS AND TRANSFER VENUE TO CERTIFY ORDER FOR PERMISSIVE INTERLOCUTORY APPEAL #41 UNDER SUBMISSION by Judge Andre Birotte Jr.: The Court has considered the matters raised with respect to the Motion and has concluded that pursuant to Local Rule 7.15, the matter can be decided without oral argument. The Court advises counsel that the Motion, noticed for hearing on January 21, 2022, has been taken under submission and off its motion calendar. No appearance by counsel is necessary. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cb) TEXT ONLY ENTRY
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Filing 44
(IN CHAMBERS) ORDER by Judge Andre Birotte Jr.: The hearing date regarding the NOTICE OF MOTION AND MOTION for Leave to Appeal (ECF No. #41 ) is hereby CONTINUED to January 21, 2022 at 10:00 AM before Judge Andre Birotte Jr. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (jgr) TEXT ONLY ENTRY
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| Filing 43 REPLY in opposition to Motion to Amend Order Denying Motions to Dismiss and Transfer Venue to Certify Order for Permissive Interlocutory Appeal filed by Defendant United Parcel Service, Inc.. (Farmer, Dylan) |
| Filing 42 OPPOSITION to NOTICE OF MOTION AND MOTION for Leave to Appeal #41 filed by Plaintiff Shane Kisman. (Cantor, Zachary) |
| Filing 41 NOTICE OF MOTION AND MOTION for Leave to Appeal filed by Defendant United Parcel Service, Inc.. Motion set for hearing on 1/7/2022 at 10:00 AM before Judge Andre Birotte Jr. (Attachments: #1 Proposed Order) (Farmer, Dylan) |
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Filing 40
ORDER by Judge Andre Birotte Jr. Granting Application of Non-Resident Attorney Christine E. Reinhard to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc., designating Julia Levitskaia as local counsel #39 . (gk)
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| Filing 39 APPLICATION of Non-Resident Attorney Christine E. Reinhard to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 9/9/2021, Receipt No. 31954507) filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order) (Levitskaia, Julia) |
| Filing 38 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS by Clerk RE: Pro Hac Vice Application filed 9/9/2021 #35 . The document is stricken. (gk) |
| Filing 37 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Christine E. Reinhard to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31954507) #35 . The following error(s) was/were found: Local Rule 5-4.3.4 Application not hand-signed. Local Rule 83-2.1.3.3(a) Application not complete: state and/or federal courts to which the applicant has been admitted are not listed. Other error(s) with document(s): The attorney seeking to appear pro hac vice must complete Section 1 of this Application, personally sign, in ink, the certification in Section II, and have the designated Local Counsel sign in Section III. ELECTRONIC SIGNATURES ARE NOT ACCEPTED. See Instructions for Applicants (1) (G-64). (lt) |
| Filing 36 AMENDED ANSWER & Defenses to Complaint (Attorney Civil Case Opening) #1 filed by Defendant United Parcel Service, Inc.. (Farmer, Dylan) |
| Filing 35 [DOCUMENT STRICKEN PER RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS ON 9/13/2021, SEE DOCKET NO. 38] APPLICATION of Non-Resident Attorney Christine E. Reinhard to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31954507) filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order) (Levitskaia, Julia) Modified on 9/13/2021 (gk). |
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Filing 34
ORDER GRANTING STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT BY NO MORE THAN 30 DAYS by Judge Andre Birotte Jr.: IT IS HEREBY ORDERED that the parties' Stipulation #31 is GRANTED. It is further ORDERED that Defendant's deadline to respond to Plaintiff's Complaint is extended until 9/10/2021. (gk)
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| Filing 33 ANSWER to Complaint (Attorney Civil Case Opening) #1 filed by Defendant United Parcel Service, Inc..(Farmer, Dylan) |
| Filing 32 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Stipulation Extending Time to Answer (30 days or less) #31 . The following error(s) was/were found: Incorrect event selected. Correct event to be used is: Stipulations > Extending Time to Answer (More than 30 days). 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. (gk) |
| Filing 31 STIPULATION Extending Time to Answer the complaint as to United Parcel Service, Inc. answer now due 9/10/2021, filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit 1, #2 Proposed Order)(Farmer, Dylan) |
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Filing 30
ORDER RE: JURY/COURT TRIAL - I. SCHEDULE; II. TRIAL PREPARATION; III. CONDUCT OF ATTORNEYS AND PARTIES by Judge Andre Birotte Jr. The Scheduling Order governing this case is set forth in the Schedule of Pretrial and Trial Dates chart below. Please refer to the Court's Standing Order for requirements for specific motions, discovery, certain types of filings, courtesy copies, emailing signature items to chambers, alternative dispute resolution, and other matters pertaining to all cases. See attached order for SCHEDULE OF PRETRIAL AND TRIAL DATES and requirements. (lom)
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Filing 29
ORDER/REFERRAL to ADR Procedure No 3 by Judge Andre Birotte Jr. 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 10/2/2022. (cb)
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Filing 28
(IN CHAMBERS) ORDER by Judge Andre Birotte Jr.: The Court has reviewed the Joint Rule 26(f) Report submitted by the parties, and determines that an in-person Scheduling Conference is unnecessary. Accordingly, the Court VACATES the August 20, 2021, Scheduling Conference. Order re Jury/Court Trial to issue. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cb) TEXT ONLY ENTRY
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Filing 27
ORDER (1) DENYING DEFENDANT'S MOTION TO DISMISS FOR IMPROPER VENUE, AND (2) DENYING DEFENDANT'S MOTION TO TRANSFER VENUE by Judge Andre Birotte Jr.: The Court DENIES Defendant United Parcel Service, Inc.'s Motion to Dismiss the Complaint for improper venue, as well as Defendant's Alternative Motion to Transfer Venue to the District of Nevada #10 . Defendant is ordered to file a response to the Complaint within 21 days of this order. (gk)
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| Filing 26 STATUS REPORT JOINT RULE 26 filed by Plaintiff Shane Kisman. (Attachments: #1 Exhibit Joint 26 Report Dates Worksheet)(Cantor, Zachary) |
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Filing 25
(IN CHAMBERS) ORDER TAKING DEFENDANTS MOTION TO DISMISS FOR IMPROPER VENUE AND ALTERNATIVE MOTION TO TRANSFER VENUE #10 ) UNDER SUBMISSION by Judge Andre Birotte Jr.: The Court has considered the matters raised with respect to the Motion and has concluded that pursuant to Local Rule 7.15, the matter can be decided without oral argument. The Court advises counsel that the Motion, noticed for hearing on July 23, 2021, has been taken under submission and off its motion calendar. No appearance by counsel is necessary. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cb) TEXT ONLY ENTRY
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Filing 24
(IN CHAMBERS) ORDER CONTINUING DEFENDANT'S MOTION TO DISMISS FOR IMPROPER VENUE AND ALTERNATIVE MOTION TO TRANSFER VENUE #10 by Judge Andre Birotte Jr. The hearing date regarding this motion is CONTINUED from July 16, 2021 to July 23, 2021 at 10:00 AM before Judge Andre Birotte Jr. IT IS SO ORDERED.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cb) TEXT ONLY ENTRY
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| Filing 23 REPLY In Support of Motion NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction #10 Corrected filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit C - Supplemental Declaration of Phillip Cote)(Farmer, Dylan) |
| Filing 22 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS by Clerk RE: Defendant's Reply in Support of Rule 12(b)(3) Motion to Dismiss for Improper Venue and Alternative Motion to Transfer Venue filed 7/1/2021 #20 . The document is stricken and counsel is ordered to file an amended or corrected document by 7/8/2021. (gk) |
| Filing 21 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Reply (Motion related) #20 . The following error(s) was/were found: Local Rule 11-8 Memorandum/brief exceeding 10 pages shall contain table of contents. 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. (gk) |
| Filing 20 [DOCUMENT STRICKEN PER RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS ON 7/7/2021, SEE DOCKET NO. 22] REPLY in support of a motion NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction #10 filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Exhibit C & C-1)(Farmer, Dylan) Modified on 7/7/2021 (gk). |
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Filing 19
ORDER by Judge Andre Birotte Jr. Granting Application of Non-Resident Attorney Dylan A. Farmer to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc., designating Julia Levitskaia as local counsel #17 . (gk)
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| Filing 18 RESPONSE filed by Pro Hac Vice attorney Christine E Reinhard on behalf of Defendant United Parcel Service, Inc., will not be appearing. RE: Notice of Filing Fee Due. PHV fee N/A. (sbou) |
| Filing 17 APPLICATION of Non-Resident Attorney Dylan A. Farmer to Appear Pro Hac Vice on behalf of Defendant United Parcel Service, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31450660) filed by Defendant United Parcel Service, Inc.. (Attachments: #1 Proposed Order) (Levitskaia, Julia) |
| Filing 16 OPPOSITION to NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction #10 filed by Plaintiff Shane Kisman. (Attachments: #1 Declaration Decl. of Shane Kisman in support of Plaintiff's opposition to Defendant's motion to dismiss or transfer venue)(Cantor, Zachary) |
| Filing 15 NOTICE of Interested Parties filed by Defendant United Parcel Service, Inc., identifying United Parcel Service, Inc. (Delaware). (Attorney Julia Levitskaia added to party United Parcel Service, Inc.(pty:dft))(Levitskaia, Julia) |
| Filing 14 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Dylan A. Farmer. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (gk) |
| Filing 13 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Christine E. Reinhard. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (gk) |
| Filing 12 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction #10 . The following error(s) was/were found: Local Rule 7.1-1 No Notice of Interested Parties and/or no copies. 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. (gk) |
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Filing 11
ORDER SETTING SCHEDULING CONFERENCE by Judge Andre Birotte Jr. Scheduling Conference set for 8/20/2021 at 10:00 AM before Judge Andre Birotte Jr. (tf)
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| Filing 10 NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction filed by Defendant United Parcel Service, Inc.. Motion set for hearing on 7/16/2021 at 10:00 AM before Judge Andre Birotte Jr. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Proposed Order) (Attorney David Wesley Ammons added to party United Parcel Service, Inc.(pty:dft)) (Ammons, David) |
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Filing 9
STANDING ORDER upon filing of the complaint by Judge Andre Birotte Jr. (cb)
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Filing 8
ORDER RETURNING CASE FOR REASSIGNMENT by Judge James V. Selna. ORDER case returned to the Clerk for random reassignment pursuant to General Order 21-01. Case randomly reassigned from Judge James V. Selna to Judge Andre Birotte Jr for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:21-cv-03164 AB (Ex). (esa)
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| Filing 7 INITIAL ORDER FOLLOWING FILING OF COMPLAINT ASSIGNED TO JUDGE SELNA (lb) |
| Filing 6 NOTICE of Interested Parties filed by Plaintiff Shane Kisman, (Cantor, Zachary) |
| Filing 5 CIVIL COVER SHEET filed by Plaintiff Shane Kisman. (Cantor, Zachary) |
| Filing 4 NOTICE OF DEFICIENCIES in Attorney Case Opening RE: Complaint (Attorney Civil Case Opening) #1 . The following error(s) was found: The Civil Cover Sheet (CV-71)is missing or incomplete. All civil actions presented for filing must be accompanied by a completed Civil Cover Sheet. See Local Rule 3-1. Counsel must file a completed Civil Cover Sheet immediately. Failure to do so may be addressed by judicial action, including sanctions. See Local Rule 83-7. No Notice of Interested Parties has been filed. A Notice of Interested Parties must be filed with every partys first appearance. See Local Rule 7.1-1. Counsel must file a Notice of Interested Parties immediately. Failure to do so may be addressed by judicial action, including sanctions. See Local Rule 83-7. (ghap) |
| Filing 3 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (ghap) |
| Filing 2 NOTICE OF ASSIGNMENT to District Judge James V. Selna and Magistrate Judge Charles F. Eick. (ghap) |
| Filing 1 COMPLAINT Receipt No: ACACDC-31103862 - Fee: $402, filed by Plaintiff Shane Kisman. (Attorney Zachary Michael Cantor added to party Shane Kisman(pty:pla))(Cantor, Zachary) |
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