AEG Holdco, LLC v. Kellie Vazquez et al
| AEG Holdco, LLC |
| LAD (Aviation), Inc., Nadiezhda Hernandez, Kyle Gamez, Charles Taylor Insurance General Agency, A Charles Taylor Company, Kellie Vazquez, Charles Taylor Insurance General Agency, Inc. doing business as Charles Taylor Environmental Technical Services and LAD Aviation, Inc. doing business as Premier Environmental Assessments, a Charles Taylor Company |
| 2:2021cv05290 |
| June 29, 2021 |
| US District Court for the Central District of California |
| Virginia A Phillips |
| Alicia G Rosenberg |
| Defend Trade Secrets Act (of 2016) |
| Plaintiff |
Docket Report
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Filing 168
ORDER GRANTING PLAINTIFF'S UNOPPOSED APPLICATION TO EXTEND THE DECEMBER 5, 2023SETTLEMENT ENFORCEMENT DEADLINE TO FEBRUARY 29 2024 #166 by Judge Virginia A. Phillips. (lc)
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| Filing 167 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: REQUEST to Continue Settlement Enforcement Deadline from December 5, 2023 to February 29, 2024 #166 . The following error(s) was/were found: Hearing information is missing, incorrect, or untimely. Filer Erroneously set Request on Judge's Motion calendar for hearing on 12/11/2023 at 11:00 AM. No such hearing appears on the filing, nor is one required for request format. Note clerk has TERMED ONLY this erroneous hearing. Request Remains pending Judge's Ruling. 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. (lc) Modified on 11/8/2023 (lc). |
| Filing 166 REQUEST to Continue Settlement Enforcement Deadline from December 5, 2023 to February 29, 2024 Re: Order,, Terminate Deadlines and Hearings,, Terminated Case, #165 filed by Plaintiff AEG Holdco, LLC. Request set for hearing on 12/11/2023 at 11:00 AM before Judge Virginia A. Phillips. (Attachments: #1 Declaration of Cheryl A. Sabnis In Support of Plaintiff's Unopposed Application to Extend Settlement Enforcement Deadline, #2 Proposed Order Granting Plaintiff's Unopposed Application to Extend Settlement Enforcement Deadline) (Sabnis, Cheryl) |
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Filing 165
ORDER by Judge Virginia A. Phillips: The Court, having been advised by a Notice of Settlement #164 that the case has settled, ORDERS that this action be dismissed in its entirety without prejudice and that all pending deadlines and hearings be vacated. Further, the Court retains jurisdiction for a period of 60 days to enforce the terms of the settlement.(Made JS-6. Case Terminated.) (lc)
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| Filing 164 NOTICE of Settlement filed by Plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 163 Notice of Appearance or Withdrawal of Counsel: for attorney Nicole Bartz Metral counsel for Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Nicole Metral 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 Charles Taylor Insurance General Agency, Inc. and LAD (Aviation), Inc.. (Metral, Nicole) |
| Filing 162 Notice of Appearance or Withdrawal of Counsel: for attorney Rachael Gray Weatherly counsel for Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Adding Rachael Weatherly as counsel of record for Defendants Charles Taylor Insurance General Agency, Inc. and LAD (Aviation), Inc. for the reason indicated in the G-123 Notice. Filed by defendants Charles Taylor Insurance General Agency, Inc. and LAD (Aviation), Inc.. (Attorney Rachael Gray Weatherly added to party Charles Taylor Insurance General Agency, Inc.(pty:dft), Attorney Rachael Gray Weatherly added to party LAD Aviation, Inc.(pty:dft))(Weatherly, Rachael) |
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Filing 161
ORDER GRANTING FIFTH APPLICATION TO CONTINUE TRIAL AND PRETRIAL DEADLINES #158 by Judge Virginia A. Phillips: Pre-trial Conference and Hearing on Motions in Limine: 3/18/2024 at 2:30 PM; Jury Trial: 3/25/2024 at 9:00 AM (SEE DOCUMENT FOR ALL SPECIFIED DEADLINES). (lc)
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| Filing 160 Notice of Appearance or Withdrawal of Counsel: for attorney Christopher Cody Wilcoxson counsel for Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Blair Gerold 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 LAD (Aviation), Inc. and Charles Taylor Insurance General Agency, Inc.. (Wilcoxson, Christopher) |
| Filing 159 NOTICE OF NON-OPPOSITION to Fifth APPLICATION to Extend Discovery Cut-Off Date to 8/29/2023 #158 and Request for July 19, 2023, Joint Report Deadline filed by Plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 158 Fifth APPLICATION to Extend Discovery Cut-Off Date to 8/29/2023 filed by Defendant LAD Aviation, Inc.. (Attachments: #1 Declaration, #2 Proposed Order) (Wilcoxson, Christopher) |
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Filing 157
CORRECTED ORDER GRANTING THIRD STIPULATED APPLICATION TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES (NOTE CHANGES MADE BY THE COURT) #151 by Judge Virginia A. Phillip: FINAL PRETRIAL CONFERENCE set for 1/8/2024 at 02:30 PM ; MOTION IN LIMINE set for hearing on 1/8/2024 at 02:30 PM; Jury Trial set for 1/23/2024 08:30 AM (SEE DOCUMENT FOR ALL SPECIFIED DEADLINES). (lc) Modified on 5/2/2023 (lc).
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Filing 156
ORDER GRANTING FOURTH STIPULATED APPLICATION TO CONTINUE TRIAL AND PRE-TRIALDEADLINES #155 by Judge Virginia A. Phillips: Final Pretrial Conference set for 1/15/2024 02:30 PM ; Jury Trial set for 1/23/2024 09:00 AM ; Motion in Limine set for hearing on 1/15/2024 at 02:30 PM (SEE DOCUMENT FOR ALL SPECIFIED DEADLINES). (lc) Modified on 5/1/2023 (lc).
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| Filing 155 Fourth STIPULATION to Continue Trial from October 23, 2023 to January 22, 2024 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration of Cheryl A. Sabnis In Support Of Fourth Stipulated Application To Continue Trial And Pre-Trial Deadlines, #2 Declaration of Michael A. Iannucci In Support Of The Parties' Fourth Stipulated Application To Continue Trial And Pre-Trial Deadlines, #3 Proposed Order Granting Fourth Stipulated Application To Continue Trial And Pre-Trial Deadlines)(Sabnis, Cheryl) |
| Filing 154 Notice of Withdrawal of Ex Parte Application to Compel,, #139 , Ex Parte Application to Compel,, #138 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Iannucci, Michael) |
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Filing 153
ORDER GRANTING THIRD STIPULATED APPLICATION TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES #151 by Judge Virginia A. Phillip: Final Pretrial Conference set for 10/16/2023 02:30 PM ; Jury Trial set for 10/23/2023 08:30 AM ; Motion in Limine set for hearing on 10/16/2023 at 02:30 PM (SEE DOCUMENT FOR ALL SPECIFIED DEADLINES). (lc) Modified on 2/10/2023 (lc).
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| Filing 152 Notice of Appearance or Withdrawal of Counsel: for attorney Christopher Cody Wilcoxson counsel for Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Filed by Defendants Charles Taylor Insurance General Agency, Inc. and LAD Aviation, Inc.. (Wilcoxson, Christopher) |
| Filing 151 Third STIPULATION to Continue Trial from 05/09/2023 to 11/06/2023 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Cheryl A. Sabnis ISO Stipulation, #2 Declaration of Michael A. Iannucci ISO Stipulation, #3 Declaration of Chris Humphreys ISO Stipulation, #4 Proposed Order)(Wilcoxson, Christopher) |
| Filing 150 NOTICE OF ERRATA filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. correcting Stipulation to Continue,, #148 (Wilcoxson, Christopher) |
| Filing 149 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Third Stipulation to Continue trial and Pretrial deadlines #148 . The following error(s) was/were found: Proposed document was not submitted or was not submitted as a separate attachment. Missing proposed order. Other error(s) with document(s): As an alternative, prepare and e-file a formal Notice of Lodging, to be docketed only under its specific event: Notice of Lodging, to which the formal proposed order is submitted as a Separate Attachment thereto. 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. (lc) |
| Filing 148 Third STIPULATION to Continue Trial and Pre-Trial Deadlines from 5/9/23 to 11/6/23 filed by Defendants Charles Taylor Insurance General Agency, Inc., Kyle Gamez, Nadiezhda Hernandez, LAD Aviation, Inc., Kellie Vazquez. (Attachments: #1 Declaration Declaration of Cheryl A. Sabnis, #2 Declaration Declaration of Michael A. Iannucci, #3 Declaration Declaration of Chris Humphries)(Attorney Christopher Cody Wilcoxson added to party Kyle Gamez(pty:dft), Attorney Christopher Cody Wilcoxson added to party Nadiezhda Hernandez(pty:dft), Attorney Christopher Cody Wilcoxson added to party Kellie Vazquez(pty:dft))(Wilcoxson, Christopher) |
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Filing 147
MINUTE (IN CHAMBERS) ORDER RE: DEFENDANTS' EX PARTE APPLICATION FOR AN ORDER COMPELLING DISCOVERY FROM NON-PARTIES by Magistrate Judge Alicia G. Rosenberg, re: EX PARTE APPLICATION to Compel Discovery from Non-Parties Robert Jay Barkley and RJB Company #139 , EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #138 . IT IS ORDERED that, by February 13, 2023, Defendants shall file a Notice after completing the scheduled depositions of these third parties. The Notice shall advise the court whether the ex parte applications directed to these third parties are withdrawn or moot. (see document for further details) (hr)
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| Filing 146 DECLARATION of Michael A. Iannucci in further support of EX PARTE APPLICATION to Compel Discovery from Non-Parties Robert Jay Barkley and RJB Company #139 , EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #138 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Iannucci, Michael) |
| Filing 145 PROOF OF SERVICE filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc., re Minutes of In Chambers Order/Directive - no proceeding held,, #143 to Non-Parties Robert Jay Barkley and RJB Company served on 01/25/2023. (Iannucci, Michael) |
| Filing 144 PROOF OF SERVICE filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc., re Minutes of In Chambers Order/Directive - no proceeding held,, #142 to Non-Party Kerriann Barkley-Sau served on 01/25/2023. (Iannucci, Michael) |
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Filing 143
MINUTE (IN CHAMBERS) ORDER RE: BRIEFING SCHEDULE ON DEFENDANTS' EX PARTE APPLICATION FOR AN ORDER COMPELLING DISCOVERY FROM NON-PARTIES ROBERT JAY BARKLEY AND RJB COMPANY by Magistrate Judge Alicia G. Rosenberg, re: EX PARTE APPLICATION to Compel Discovery from Non-Parties Robert Jay Barkley and RJB Company #139 . IT IS ORDERED that Jay Barkley and RJB Company may file and serve on Defendants oppositions to the ex parte application on or before January 30, 2023. If these third parties file an opposition, Defendants may file a reply within 48 hours after service of the opposition. (see document for further details) (hr)
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Filing 142
MINUTE (IN CHAMBERS) ORDER RE: BRIEFING SCHEDULE ON DEFENDANTS' EX PARTE APPLICATION FOR AN ORDER COMPELLING DISCOVERY FROM NON-PARTY KERRIANN BARKLEY-SAU by Magistrate Judge Alicia G. Rosenberg, re: EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #138 . IT IS ORDERED that Kerriann Barkley-Sau may file and serve on Defendants an opposition to the ex parte application on or before January 30, 2023. If Ms. Barkley-Sau file an opposition, Defendants may file a reply within 48 hours after service of the opposition. (see document for further details) (hr)
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| Filing 141 PROOF OF SERVICE filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc., re EX PARTE APPLICATION to Compel Discovery from Non-Parties Robert Jay Barkley and RJB Company #139 served on 01/23/2023. (Iannucci, Michael) |
| Filing 140 PROOF OF SERVICE filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc., re EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #138 served on 01/23/2023. (Iannucci, Michael) |
| Filing 139 EX PARTE APPLICATION to Compel Discovery from Non-Parties Robert Jay Barkley and RJB Company filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Michael Iannucci ISO Ex Parte Application, #2 Exhibit A to Iannucci Declaration ISO Ex Parte Application, #3 Exhibit B to Iannucci Declaration ISO Ex Parte Application, #4 Exhibit C to Iannucci Declaration ISO Ex Parte Application, #5 Exhibit D to Iannucci Declaration ISO Ex Parte Application, #6 Exhibit E to Iannucci Declaration ISO Ex Parte Application, #7 Declaration of Charles Fitzpatrick ISO Ex Parte Application, #8 Proposed Order Granting Ex Parte Application)(Iannucci, Michael) |
| Filing 138 EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Michael Iannucci ISO Ex Parte MTC, #2 Exhibit A to Iannucci Declaration ISO Ex Parte MTC, #3 Exhibit B to Iannucci Declaration ISO Ex Parte MTC, #4 Exhibit C to Iannucci Declaration ISO Ex Parte MTC, #5 Exhibit D to Iannucci Declaration ISO Ex Parte MTC, #6 Exhibit E to Iannucci Declaration ISO Ex Parte MTC, #7 Proposed Order)(Iannucci, Michael) |
| Filing 137 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN FILED DOCUMENT RE: EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #135 , Deficiency in Electronically Filed Documents (G-112A) #136 by Magistrate Judge Alicia G. Rosenberg. The document is stricken. (hr) |
| Filing 136 NOTICE TO FILER OF DEFICIENCIES in Filed Document RE: EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau #135 . The following error(s) was/were found: No notice of ex parte application as required by Local Rule 7-19.1. Fed. R. Civ. P. 5 no proof of service attached. 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. (hr) |
| Filing 135 ***STRICKEN PER DOCKET NO. #137 *** EX PARTE APPLICATION to Compel Discovery from Non-Party Kerriann Barkley-Sau filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Michael Iannucci ISO Ex Parte MTC, #2 Exhibit A to Iannucci Declaration ISO Ex Parte MTC, #3 Exhibit B to Iannucci Declaration ISO Ex Parte MTC, #4 Exhibit C to Iannucci Declaration ISO Ex Parte MTC, #5 Exhibit D to Iannucci Declaration ISO Ex Parte MTC, #6 Exhibit E to Iannucci Declaration ISO Ex Parte MTC, #7 Proposed Order)(Iannucci, Michael) Modified on 1/18/2023 (hr). |
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Filing 134
MINUTE (IN CHAMBERS) ORDER RE: DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.'S EX PARTE MOTION FOR ALTERNATIVE SERVICE by Magistrate Judge Alicia G. Rosenberg: granting #132 Ex Parte Application. IT IS ORDERED that Defendants may serve Mr. Barkley and RJB Company with subpoenas under Fed. R. Civ. P. 45 by overnight service. Nothing in this order precludes Mr. Barkley and RJB Company from objecting to the respective subpoena or filing a motion to quash. (see document for further details) (hr)
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| Filing 133 STATEMENT of Non-opposition to EX PARTE APPLICATION for Order for ALTERNATIVE SERVICE VIA OVERNIGHT COURIER #132 filed by Plaintiff AEG Holdco, LLC. (Weinstein, Alex) |
| Filing 132 EX PARTE APPLICATION for Order for ALTERNATIVE SERVICE VIA OVERNIGHT COURIER filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Proposed Order)(Iannucci, Michael) |
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Filing 131
ORDER RE: FORENSIC PROTOCOL by Magistrate Judge Alicia G. Rosenberg: granting #130 REQUEST for Inspection of Forensic Data on Personal Devices, REQUEST to Supplement re Order on Motion to Compel. The court accepts the proposed protocols submitted by Plaintiff AEG Holdco, LLC (Exh. A to Dkt. No. 130), which are attached to this order, with the following modifications: 1. Within two days after entry of this order, the Individual Defendants shall advise Plaintiff in writing as to the date(s) of the forensic images Ankura obtained from each covered device listed in the protocols. (see document for further details) (Attachments: #1 Attachment) (hr)
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| Filing 130 REQUEST for Inspection of Forensic Data on Personal Devices, REQUEST to Supplement re Order on Motion to Compel #126 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Sabnis, Cheryl) |
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Filing 129
ORDER RE: PLAINTIFF'S REQUEST TO SUPPLEMENT THE RECORD (Dkt. No. 128) by Magistrate Judge Alicia G. Rosenberg. Accordingly, IT IS ORDERED that Plaintiff's request to supplement the record is GRANTED. Defendants' request for an order compelling Plaintiff to search and produce responsive documents on personal mobile devices of Plaintiff's current employees is DEEMED WITHDRAWN WITHOUT PREJUDICE. Granting in part and denying in part Request to Supplement #128 . (See Order for Further Details). (kl)
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| Filing 128 REQUEST to Supplement the record in response to Dkt. 127 re Order on Motion for Order re Discovery Matter, Telephone Conference #127 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration Ex. 1 - Litman Decl.)(Sabnis, Cheryl) |
| Filing 127 MINUTES OF VIDEO DISCOVERY CONFERENCE (Dkt. No. 123) held before Magistrate Judge Alicia G. Rosenberg. Settling Motion for Order #123 . (See Order for Further Details). Court Recorder: CS 11/08/2022. (kl) |
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Filing 126
ORDER RE: PLAINTIFF'S MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES by Magistrate Judge Alicia G. Rosenberg: granting in part and denying in part #110 Motion to Compel. IT IS ORDERED that Plaintiff's motion to compel is GRANTED IN PART AND DENIED WITHOUT PREJUDICE IN PART as follows: 1. On or before November 23, 2022, or another mutually agreeable date, counsel shall (1) identify a mutually acceptable computer forensic vendor; (2) identify any personal electronic device of an Individual Defendant to be turned over to the agreed vendor; (3) identify any electronic device issued on or before January 16, 2021 by Corporate Defendants to a former AEG employee who ultimately came to work for Corporate Defendants environmental services division, to be turned over to the agreed vendor; and (4) prepare a protocol for forensic examination of the electronic devices. (see document for further details) (hr)
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| Filing 125 MINUTES OF VIDEO DISCOVERY CONFERENCE re: #123 Motion Re: Informal Discovery Dispute held before Magistrate Judge Alicia G. Rosenberg. IT IS ORDERED that the zoom hearing is continued to Tuesday, November 8, 2022, at 11:00 a.m. Court Recorder: CourtSmart 11/3/2022. (hr) |
| Filing 124 MINUTES OF ORDER RE: PLAINTIFF'S MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES re: #110 Motion to Compel; Motion Hearing held before Magistrate Judge Alicia G. Rosenberg. The court hears oral argument and takes the matter under submission. Court Recorder: CourtSmart 11/3/2022. (hr) |
| Filing 123 NOTICE OF MOTION AND MOTION for Order for Joint Agenda Re: October 28, 2022 Video Discovery Conference filed by Attorneys for Plaintiff AEG Holdco, LLC AEG Holdco, LLC. Telephone Conference set for 11/3/2022 10:30 AM before Magistrate Judge Alicia G. Rosenberg. (Weinstein, Alex) |
| Filing 122 SCHEDULING NOTICE by Magistrate Judge Alicia G. Rosenberg. At the request of the plaintiff, the Court RESCHEDULES the video discovery conference previously scheduled for Friday, October 28, 2022 at 10:00 a.m. PT to Thursday, November 3, 2022 at 10:30 a.m. by Zoom. The joint agenda that lists the discovery issues must now be filed on or before noon PT on Wednesday, November 2, 2022. No argument should be included in the joint agenda. When filing the joint agenda, counsel is directed to use the "Discovery Motions - Order re Discovery Matter" event. The steps to access the Zoom webinar are available on Judge Rosenberg's Procedures & Schedules page (www.cacd.uscourts.gov/honorable-alicia-g-rosenberg). THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kl) TEXT ONLY ENTRY |
| Filing 121 SCHEDULING NOTICE by Magistrate Judge Alicia G. Rosenberg. At the request of the plaintiff, the Court sets a video discovery conference for Friday, October 28, 2022 at 10:00 a.m. PT by Zoom. A joint agenda that lists the discovery issues must be filed on or before noon PT on Thursday, October 27, 2022. No argument should be included in the joint agenda. When filing the joint agenda, counsel is directed to use the "Discovery Motions - Order re Discovery Matter" event. The steps to access the Zoom webinar are available on Judge Rosenberg's Procedures & Schedules page (www.cacd.uscourts.gov/honorable-alicia-g-rosenberg). THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kl) TEXT ONLY ENTRY |
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Filing 120
ORDER GRANTING SECOND STIPULATED APPLICATION TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES #119 by Judge Virginia A. Phillips: Jury Trial set for MAY 9, 2023 08:30 AM; Pretrial Conference set for APRIL 24, 2023 02:30 PM (SEE DOCUMENT FOR ALL SPECIFIED DEADLINES). (lc) Modified on 10/19/2022 (lc). Modified on 10/20/2022 (lc). Modified on 10/20/2022 (lc).
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| Filing 119 Joint APPLICATION to Continue Trial and Pre-Trial Deadlines filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration of Cheryl A. Sabnis, #2 Declaration of Michael A. Iannucci, #3 Declaration of Chris Humphreys, #4 Proposed Order) (Weinstein, Alex) |
| Filing 118 RESPONSE IN SUPPORT of MOTION to Compel Forensic Inspection of Electronic Devices #110 Opposition to Defendants' Objections #115 filed by Plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 117 REPLY in support MOTION to Compel Forensic Inspection of Electronic Devices #110 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Sabnis, Cheryl) |
| Filing 116 OPPOSITION to MOTION to Compel Forensic Inspection of Electronic Devices #110 DEFENDANT LAD (AVIATION), INC.S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 DECLARATION OF CHRISTOPHER C. WILCOXSON IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #2 EXHIBIT 1 TO DECLARATION OF CHRISTOPHER C. WILCOXSON IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #3 EXHIBIT 2 TO DECLARATION OF CHRISTOPHER C. WILCOXSON IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #4 EXHIBIT 3 TO DECLARATION OF CHRISTOPHER C. WILCOXSON IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #5 EXHIBIT 4 TO DECLARATION OF CHRISTOPHER C. WILCOXSON IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #6 DECLARATION OF DANIEL DIPPLE IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #7 EXHIBIT A TO DECLARATION OF DANIEL DIPPLE IN SUPPORT OF DEFENDANTS LAD (AVIATION), INC.S OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION TO COMPEL FORENSIC INSPECTION OF ELECTRONIC DEVICES, #8 [PROPOSED] ORDER DENYING PLAINTIFFS MOTION TO COMPEL)(Iannucci, Michael) |
| Filing 115 Objections to Evidence in Support of Defendants' Opposition to Motion to Compel Objections to Evidence re: MOTION to Compel Forensic Inspection of Electronic Devices #110 filed by Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. (Olson, Gregory) |
| Filing 114 to Motion to Compel Forensic Inspection of Electronic Devices re: MOTION to Compel Forensic Inspection of Electronic Devices #110 filed by Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. (Attachments: #1 Declaration Declaration of Chris Humphreys, #2 Declaration Declaration of Neil Broom, #3 Declaration Declaration of Mark Clews, #4 Proposed Order Proposed Order)(Olson, Gregory) |
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Filing 113
ORDER GRANTING APPLICATION of Non-Resident Attorney Jonathan G. Blevins to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation and designating Nicole B. Metral as local counsel #109 by Judge Virginia A. Phillips. (lc)
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Filing 112
ORDER GRANTING APPLICATION of Non-Resident Attorney Charles A. Fitzpatrick to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. designating Nicole B. Metral as local counsel #108 by Judge Virginia A. Phillips. (lc)
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Filing 111
ORDER by Judge Virginia A. Phillips: the following document(s) be STRICKEN for failure to comply with the Local Rules, General Order and/or the Courts Case Management Order: APPLICATION of Non-Resident Attorney Charles A. Fitzpatrick to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33962719) #104 , APPLICATION of Non-Resident Attorney Jonathan G. Blevins to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33961756) #102 , for the following reasons: Local Rule 5-4.3.4-Application not hand-signed. (lc)
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| Filing 110 NOTICE OF MOTION AND MOTION to Compel Forensic Inspection of Electronic Devices filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Proposed Order)(Sabnis, Cheryl) |
| Filing 109 Corrected APPLICATION of Non-Resident Attorney Jonathan G. Blevins to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 9/12/2022, Receipt No. 33961756) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) |
| Filing 108 Corrected APPLICATION of Non-Resident Attorney Charles A. Fitzpatrick to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 9/12/2022, Receipt No. 33962719) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) |
| Filing 106 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Charles A. Fitzpatrick to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33962719) #104 , APPLICATION of Non-Resident Attorney Jonathan G. Blevins to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33961756) #102 . The following error(s) was/were found: Local Rule 5-4.3.4 Application not hand-signed. Other error(s) with document(s): Please note that electronic, image or stamp signatures are not allowed for either applicant or local counsel. See Instructions for Applicants (1). (lt) |
| Filing 107 MINUTES OF VIDEO DISCOVERY CONFERENCE settling #105 Motion Re: Informal Discovery Dispute, #103 Joint Agenda; Telephone Conference held before Magistrate Judge Alicia G. Rosenberg. As agreed on the record, Plaintiff will respond to Item No. 1 on the joint agenda within one week after today's hearing. As agreed on the record, Plaintiff will provide evidence to defense counsel regarding Item No. 2 by Thursday, September 15, 2022. (see document for further details) Court Recorder: CS 09/12/2022. (hr) |
| Filing 105 MOTION RE: INFORMAL DISCOVERY DISPUTE. The parties have requested an informal discovery conference with Magistrate Judge Alicia G. Rosenberg. (hr) |
| Filing 104 (STRICKEN PER 9/20/2022 ORDER DOCKET NO.111). APPLICATION of Non-Resident Attorney Charles A. Fitzpatrick to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33962719) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) Modified on 9/21/2022 (lc). |
| Filing 103 Notice Joint Agenda for the September 12, 2022 Video Discovery Conference filed by Plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 102 (STRICKEN PER 9/20/2022 ORDER DOCKET NO.111). APPLICATION of Non-Resident Attorney Jonathan G. Blevins to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33961756) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) Modified on 9/21/2022 (lc). |
| Filing 101 SCHEDULING NOTICE by Magistrate Judge Alicia G. Rosenberg. Per Judge Rosenberg's Order (Dkt. No. #100 ), a continued discovery conference is scheduled for 11:00 a.m. PT on September 12, 2022, via Zoom. The steps to access the Zoom webinar are available on Judge Rosenberg's Procedures & Schedules page (www.cacd.uscourts.gov/honorable-alicia-g-rosenberg). THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kl) TEXT ONLY ENTRY |
| Filing 100 MINUTES OF VIDEO DISCOVERY CONFERENCE held before Magistrate Judge Alicia G. Rosenberg: Case is called. Counsel state their appearances. The court and counsel conferred as stated on the record regarding the parties' joint agenda. (Dkt. No. 94.) The court and counsel started addressing the document requests at issue. IT IS ORDERED that the hearing is continued to September 12, 2022 at 11:00 a.m. via zoom. IT IS FURTHER ORDERED that, by 10:30 a.m. on September 12, 2022, counsel shall file a joint agenda that lists the document requests in dispute and, for each disputed document request, specifies whether the dispute is over objections, a date for production, or both. Court Reporter: CS 09/07/2022. (et) |
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Filing 99
ORDER GRANTING REQUEST to Substitute attorney Cheryl A. Sabnis in place of attorney Ramon Andres Miyar, Ann Voigt and Rachel Sarah Rubens for Plaintiff AEG Holdco, LLC #93 by Judge Virginia A. Phillips. (lc)
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Filing 98
ORDER GRANTING APPLICATION of Non-Resident Attorney Alex C. Weinstein to Appear Pro Hac Vice on behalf of Plaintiff AEG Holdco, LLC and designating Cheryl A. Sabnis as local counsel #92 by Judge Virginia A. Phillips. (lc)
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Filing 97
STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg: granting #85 Request for Protective Order re REQUEST for Protective Order for Protected Material #85 . [See Order for details] (et)
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Filing 96
RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN FILED DOCUMENT RE: Joint MOTION for Order for Order re Discovery Matter #94 by Magistrate Judge Alicia G. Rosenberg. The hearing date has been rescheduled. Telephone Conference set for 9/7/2022 11:00 AM before Magistrate Judge Alicia G. Rosenberg. (kl)
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| Filing 95 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Joint MOTION for Order for Order re Discovery Matter #94 . The following error(s) was/were found: Hearing information is missing, incorrect, or untimely. 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. (kl) |
| Filing 94 NOTICE OF MOTION AND Joint MOTION for Order for Order re Discovery Matter filed by Corporate Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Telephone Conference set for 9/7/2022 11:00 AM before Judge Virginia A. Phillips. (Attachments: #1 Exhibit Exhibit A)(Wilcoxson, Christopher) |
| Filing 93 Corrected REQUEST to Substitute attorney Cheryl A. Sabnis in place of attorney Ramon Andres Miyar, Ann Voigt and Rachel Sarah Rubens filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Proposed Order) (Sabnis, Cheryl) |
| Filing 92 Corrected APPLICATION of Non-Resident Attorney Alex C. Weinstein to Appear Pro Hac Vice on behalf of Plaintiff AEG Holdco, LLC (Pro Hac Vice Fee - $500 Previously Paid on 9/26/2022, Receipt No. 33883588) filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Proposed Order) (Sabnis, Cheryl) |
| Filing 91 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: REQUEST TO SUBSTITUTE ATTORNEY Cheryl A. Sabnis in place of attorney Ramon Andres Miyar #90 . The following error(s) was/were found: Proposed Document was not submitted as separate attachment. Missing Corresponding proposed order form (G-01). Other error(s) with document(s): As an alternative, prepare and e-file a formal Notice of Lodging, to be docketed only under its specific event: Notice of Lodging, to which the formal proposed order is submitted as a Separate Attachment thereto.. 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. (lc) |
| Filing 90 REQUEST TO SUBSTITUTE ATTORNEY Cheryl A. Sabnis in place of attorney Ramon Andres Miyar filed by plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 89 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Alex C. Weinstein to Appear Pro Hac Vice on behalf of Plaintiff AEG Holdco, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33883588) #88 . The following error(s) was/were found: Local Rule 5-4.3.4 Application not hand-signed. Local Rule 83-2.1.3.3(d) Certificate of Good Standing not attached for every state court listed to which the applicant has been admitted. Other error(s) with document(s): Please note that electronic, image or stamp signatures are not allowed for either applicant or local counsel. See Instructions for Applicants (1). Certificates of Good Standing have been required since 9/08. See LR 83-2.1.3.3. See Instructions for Applicants (1) (G-64). (lt) |
| Filing 88 APPLICATION of Non-Resident Attorney Alex C. Weinstein to Appear Pro Hac Vice on behalf of Plaintiff AEG Holdco, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-33883588) filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Proposed Order) (Sabnis, Cheryl) |
| Filing 87 SCHEDULING NOTICE by Magistrate Judge Alicia G. Rosenberg. At the request of the parties, the Court sets a video discovery conference for Wednesday, September 7, 2022, at 11:00 a.m. PT by Zoom. A joint agenda that lists the discovery issues must be filed on or before noon PT on Tuesday, September 6, 2022. No argument should be included in the joint agenda. When filing the joint agenda, counsel is directed to use the "Discovery Motions - Order re Discovery Matter" event. The steps to access the Zoom webinar are available on Judge Rosenberg's Procedures & Schedules page (www.cacd.uscourts.gov/honorable-alicia-g-rosenberg). THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kl) TEXT ONLY ENTRY |
| Filing 86 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Stipulation for Protective Order #85 . The following error(s) was/were found: Incorrect event selected. The correct event to be used is Civil Events -> Stipulations -> Protective Order. 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. (hr) |
| Filing 85 REQUEST for Protective Order for Protected Material filed by plaintiff AEG Holdco, LLC.(Sabnis, Cheryl) |
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Filing 84
ORDER GRANTING STIPULATED APPLICATION TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES, #82 by Judge Virginia A. Phillips: The Court hereby GRANTS the Parties Stipulated Application and continues the jury trial and associated pre-trial deadlines set by the Court in its order of February 11, 2022 (ECF No. 81) to the following dates: Discovery cut-off November 14, 2022., Jury Trial reset for February 7, 2023 at 8:30 a.m.; Pretrial Conference set for January 23, 2023 2:30 p.m. IT IS SO ORDERED. See order for more information. (shb)
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| Filing 83 TEXT ONLY NOTICE RE: Stipulation to Continue Trial & Pre-Trial Deadlines #82 . In compliance with Central District of California's Local Rule 5-4.4.2, counsel are to email the Stipulation in PDF format, and the proposed order in Microsoft Word to the Judge's generic chambers email no later than 4:00 p.m. of May 16, 2022. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cch) TEXT ONLY ENTRY |
| Filing 82 STIPULATION to Continue Trial and Pre-Trial Deadlines from October 4, 2022 to February 6, 2023 filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Cheryl A. Sabnis, #2 Declaration of Michael A. Iannucci, #3 Proposed Order)(Wilcoxson, Christopher) |
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Filing 80
CIVIL TRIAL SCHEDULING ORDER by Judge Virginia A. Phillips. Initial Designation of Expert Witnesses due by: May 23, 2022, Designation of Rebuttal Expert Witnesses due by: June 6, 2022, Summary Judgment Motion hearing cut-off by August 29, 2022 at 2:00 p.m., Last day to conduct mediation: April 11, 2022, Amended Pleadings due by 3/21/2022. Discovery cut-off 7/18/2022. Pretrial Conference set for 9/26/2022 at 02:30 PM. Jury Trial set for 10/4/2022 at 08:30 AM before Judge Virginia A. Phillips. Trial Estimate: 4 days. (cch)
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Filing 79
ORDER/REFERRAL to ADR Procedure No 3 by Judge Virginia A. Phillips. 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 April 11, 2022. (cch)
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Filing 81
MINUTE ORDER SETTING DATES (IN CHAMBERS) by Judge Virginia A. Phillips: The Court has reviewed the parties Joint Rule 26(f) Report. (Dkt. No. 77.) The Court adopts the following schedule (note changes from the parties requested dates): Last date for hearing motions to amend pleadings or add parties: March 21, 2022. Last date to conduct settlement conference (ADR No. 3): April 11, 2022. Pre-trial conference (hearing on motions in limine): September 26, 2022 at 2:30 p.m.; Trial date (jury trial, 4 days): October 4, 2022 at 8:30 a.m. The parties shall notify the Court within 5 days of their settlement conference byfiling a status report indicating whether this action has resolved by settlement. IT IS SO ORDERED. See order for more information. (shb)
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Filing 78
SCHEDULING NOTICE AND ORDER (IN CHAMBERS) by Judge Virginia A. Phillips. COUNSEL OF RECORD ARE HEREBY NOTIFIED, on the Court's own motion, the Scheduling Conference set on February 14, 2022 is TAKEN OFF CALENDAR. No appearance by counsel will be necessary. Accordingly, the parties' Stipulation for Order to Hold Scheduling Conference Virtually #76 is deemed moot. The Court will issue such further orders as deemed appropriate. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cch) TEXT ONLY ENTRY
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| Filing 77 JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 10 days, filed by Plaintiff AEG Holdco, LLC.. (Sabnis, Cheryl) |
| Filing 76 STIPULATION for Order to Hold Scheduling Conference Virtually filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order)(Wilcoxson, Christopher) |
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Filing 75
ORDER CONTINUINGSCHEDULING CONFERENCE #74 by Judge Virginia A. Phillips. Having reviewed the Parties Joint Stipulation Continuing Scheduling Conference, the Court finds good cause to continue the December 13, 2021 scheduling conference. The scheduling conference will be rescheduled for February 14, 2022 at 1:30 p.m.IT IS SO ORDERED. (yl)
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| Filing 74 Joint STIPULATION to Continue Scheduling Conference from December 13, 2021 to February 14, 2022 Re: Initial Order Setting R26 Scheduling Conference - form only #73 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order)(Metral, Nicole) |
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Filing 73
ORDER SETTING SCHEDULING CONFERENCE by Judge Virginia A. Phillips. Scheduling Conference set for 12/13/2021 at 01:30 PM before Judge Virginia A. Phillips. (cch)
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| Filing 72 ANSWER to Amended Complaint/Petition #9 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc..(Metral, Nicole) |
| Filing 71 ANSWER to Amended Complaint/Petition #9 filed by Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez.(Olson, Gregory) |
| Filing 70 NOTICE OF FILING TRANSCRIPT filed for proceedings 09/13/2021 at 2:00 p.m. re Transcript #69 THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (Ponce, Myra) TEXT ONLY ENTRY |
| Filing 69 TRANSCRIPT for proceedings held on 09/13/2021 at 2:00 p.m. Court Reporter/Electronic Court Recorder: Myra L. Ponce, CSR, RDR, CRR, e-mail address myraponce@sbcglobal.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Electronic Court Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Notice of Intent to Redact due within 7 days of this date. Redaction Request due 10/26/2021. Redacted Transcript Deadline set for 11/5/2021. Release of Transcript Restriction set for 1/3/2022. (Ponce, Myra) |
| Filing 68 SEALED DOCUMENT Supplemental Memorandum of Points and Authorities in Opposition to Plaintiff AEG Holdco, LLC's Motion for a Preliminary Injuncation and Expedited Discovery re APPLICATION to file document SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY under seal #62 , APPLICATION to file document at ECF No. 62 under seal #64 , APPLICATION for Leave to file documents under seal DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.S APPLICATION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL IN CONNECTION WITH DEFENDANTS SUPPLEMENTAL MEMORANDUM OF POINTS AND A #63 , Order on Motion for Leave to File Document,, #66 , Order on Motion for Leave to File Document Under Seal, #67 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration - Supplemental Declaration of Cullen Sophy ISO Opposition to Motion for Preliminary Injunction and Expedited Discovery)(Metral, Nicole) |
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Filing 67
ORDER GRANTING DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.S APPLICATION FOR LEAVE TO FILE DOCUMENTS AT ECF #62 UNDER SEAL by Judge Virginia A. Phillips: The Court hereby GRANTS Plaintiff Leave to file the above documents under seal and Orders that Docket 62 and its attachments remain under seal. (See document for further details) (yl)
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Filing 66
ORDER GRANTING DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.'S APPLICATION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL IN CONNECTION WITH DEFENDANTS SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLC'S MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY by Judge Virginia A. Phillips: The Court hereby GRANTS Plaintiff Leave to file the above documents under seal. Upon receipt of this Order, Plaintiff shall file the sealed documents in accordance with L.R. 79-5.2.2. (See document for further details) #63 (yl).
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Filing 65
ORDER DENYING Motion for Preliminary Injunction by Judge Virginia A. Phillips: For the foregoing reasons, the Court DENIES Plaintiffs Motion for Preliminary Injunction. As discussed at the hearing, should Plaintiff obtain discovery in this action that would demonstrate its likelihood of success on the merits, Plaintiff may file a new motion for preliminary injunction. The parties shall conduct their Rule 26(d)(1) conference within five business days of the entry of this Order, following which discovery may commence. IT IS SO ORDERED. (See document for further details) (yl)
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| Filing 64 APPLICATION to file document at ECF No. 62 under seal filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Redacted Document - Supplemental Declaration of Cullen Sophy ISO Opposition to Motion for Preliminary Injunction and Expedited Discovery, #2 Redacted Document - Supplemental Memorandum of Points and Authorities in Opposition to Motion for Preliminary Injunction and Expedited Discovery, #3 Proposed Order)(Metral, Nicole) |
| Filing 63 APPLICATION for Leave to file documents under seal DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.S APPLICATION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL IN CONNECTION WITH DEFENDANTS SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Memorandum SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY, #2 Declaration SUPPLEMENTAL DECLARATION OF CULLEN SOPHY IN SUPPORT OF DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD, #3 Proposed Order [PROPOSED] ORDER GRANTING DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY AND LAD (AVIATION), INC.S APPLICATION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL IN CONNECTION WITH DEFENDANTS SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY) (Metral, Nicole) |
| Filing 62 APPLICATION to file document SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY under seal filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration DECLARATION OF MICHAEL A. IANNUCCI IN SUPPORT OF DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD (AVIATION), INC.S APPLICATION TO FILE UNDER SEAL, #2 Declaration SUPPLEMENTAL DECLARATION OF CULLEN SOPHY IN SUPPORT OF DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD)(Metral, Nicole) |
| Filing 61 NOTICE OF ERRATA filed by Plaintiff AEG Holdco, LLC. correcting Supplement(Motion related) #60 (Attachments: #1 Exhibit A - Corrected Supplemental Brief)(Sabnis, Cheryl) |
| Filing 60 SUPPLEMENT to NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 filed by Plaintiff AEG Holdco, LLC. (Sabnis, Cheryl) |
| Filing 59 DEFENDANTS SUPPLEMENTAL BRIEF IN SUPPORT OF OPPOSITION re NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 Defendants Supplemental Brief in Support of Opposition to Motion for Preliminary Injuction and Expedited Discovery filed by Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. (Olson, Gregory) |
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Filing 58
TEXT ONLY ORDER RE: APPLICATIONS TO FILE UNDER SEAL (Dkt. #26 & #29 ) by Judge Virginia A. Phillips. The Court denied Plaintiff's Ex Parte Application for Temporary Restraining Order on August 9, 2021 (Dkt. #34 ). Plaintiff's Applications to file documents under seal (Dkt. #26 & #29 ) are hereby DENIED AS MOOT. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cch) TEXT ONLY ENTRY
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| Filing 56 NOTICE of Appearance filed by attorney Anne M Voigts on behalf of Plaintiff AEG Holdco, LLC (Attorney Anne M Voigts added to party AEG Holdco, LLC(pty:pla))(Voigts, Anne) |
| Filing 57 MINUTE ORDER of Plaintiff's Motion for Preliminary Injunction #10 held before Judge Virginia A. Phillips: Case called, and counsel make their appearance. The Court hears oral argument and takes the matter under submission. The parties are ordered to file supplemental briefs no later than September 20, 2021. Upon review of the parties submissions, the Court will issue an Order. Court Reporter: Myra Ponce. (yl) |
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Filing 55
ORDER by Judge Virginia A. Phillips: granting #39 #52 Non-Resident Attorney Blair A. Gerold APPLICATION to Appear Pro Hac Vice on behalf of Charles Taylor Insurance General Agency, Inc. and for LAD Aviation, Inc., designating Nicole B Metral as local counsel. (lom)
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Filing 54
ORDER by Judge Virginia A. Phillips: granting #38 #53 Non-Resident Attorney Michael A. Iannucci APPLICATION to Appear Pro Hac Vice on behalf of Charles Taylor Insurance General Agency, Inc. and for LAD Aviation, Inc., designating Nicole B Metral as local counsel. (lom)
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| Filing 53 APPLICATION of Non-Resident Attorney Michael A. Iannucci to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 8/23/2021, Receipt No. ACACDC31852329) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order (PROPOSED) ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE) (Metral, Nicole) |
| Filing 52 APPLICATION of Non-Resident Attorney Blair A. Gerold to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 8/23/2021, Receipt No. ACACDC-31854710) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order (PROPOSED) ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE) (Metral, Nicole) |
| Filing 51 NOTICE OF ERRATA filed by Plaintiff AEG Holdco, LLC. correcting Reply (Motion related), #50 (Attachments: #1 Exhibit Exhibit A - Corrected Reply)(Sabnis, Cheryl) |
| Filing 50 REPLY in Support of NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration Miyar Declaration, #2 Exhibit Ex. A to Miyar Declaration, #3 Exhibit Ex. B to Miyar Declaration, #4 Exhibit Ex. C to Miyar Declaration)(Sabnis, Cheryl) |
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Filing 49
ORDER EXTENDING PLAINTIFF'S PAGE LIMIT FOR ITS REPLY IN SUPPORT OF PRELIMINARY INJUNCTION MOTION by Judge Virginia A. Phillips #47 Plaintiff is hereby granted leave to file a single reply brief in support of its Preliminary Injunction Motion, not to exceed 18 pages in length. IT IS SO ORDERED. (See document for further details) (yl)
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Filing 48
ORDER by Judge Virginia A. Phillips: granting #37 Non-Resident Attorney Wilcoxson, Christopher C. APPLICATION to Appear Pro Hac Vice on behalf of Charles Taylor Insurance General Agency, Inc. and LAD (Aviation), Inc., designating Metral, Nicole B. as local counsel. (yl)
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| Filing 47 STIPULATION to Exceed Page Limitation as to Plaintiff's Reply in Support of Motion for Preliminary Injunction and Expedited Discovery filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Proposed Order Extending Reply Page Limit)(Miyar, Ramon) |
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Filing 46
ORDER GRANTING STIPULATION TO EXTEND TIME TO RESPOND TO AMENDED COMPLAINT by Judge Virginia A. Phillips, re Stipulation for Extension of Time to File Response/Reply #36 . The Court having read and considered the Stipulation to Extend Time to Respond to the Amended Complaint, and good cause appearing, ORDERS that all Defendants' time to answer, move or otherwise respond to Plaintiff AEG Holdco LLC's Amended Complaint is extended until fourteen (14) days after the Court issues its decision on AEG Holdco LLC's Motion for Preliminary Injunction. (mrgo)
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| Filing 45 RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN ELECTRONICALLY FILED DOCUMENTS. Counsel shall submit corrected applications. See Notice to Filer of Deficiences in Electronically filed Pro Hac Vice Application #44 . (cch) |
| Filing 44 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Michael Iannucci to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31852329) #38 , APPLICATION of Non-Resident Attorney Blair A. Gerold to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31854710) #39 . The following error(s) was/were found: Local Rule 83-2.1.3.3(d) Certificate of Good Standing not attached for every state court listed to which the applicant has been admitted. Other error(s) with document(s): A declaration is required regarding unavailability to provide GSC due to COVID-19. See Court's website on Coronavirus (COVID-19) Guidance. NJ missing. (lt) |
| Filing 43 MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 filed by Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration of Michael A. Iannucci, #2 Declaration of Ashish Barot, #3 Declaration of Cullen Sophy, #4 Proposed Order)(Metral, Nicole) |
| Filing 42 CORPORATE DISCLOSURE STATEMENT AND NOTICE OF INTERESTED PARTIES filed by Defendant Charles Taylor Insurance General Agency, Inc. identifying CTC Americas, Inc. as Corporate Parent. (Metral, Nicole) |
| Filing 41 CORPORATE DISCLOSURE STATEMENT filed by Defendant LAD Aviation, Inc. identifying CTC Americas, Inc. as Corporate Parent. (Metral, Nicole) |
| Filing 40 OPPOSITION to NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 filed by Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. (Attachments: #1 Declaration Declaration of Chris Humphreys, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Declaration Declaration of Kellie Vasquez, #9 Declaration Declaration of Kyle Gamez, #10 Declaration Declaration of Nadiezhda Hernandez)(Olson, Gregory) |
| Filing 39 APPLICATION of Non-Resident Attorney Blair A. Gerold to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31854710) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) |
| Filing 38 APPLICATION of Non-Resident Attorney Michael Iannucci to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31852329) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order) (Metral, Nicole) |
| Filing 37 APPLICATION of Non-Resident Attorney Christopher C. Wilcoxson to Appear Pro Hac Vice on behalf of Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31846157) filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order (PROPOSED) ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE) (Attorney Christopher Cody Wilcoxson added to party Charles Taylor Insurance General Agency, Inc.(pty:dft), Attorney Christopher Cody Wilcoxson added to party LAD Aviation, Inc.(pty:dft)) (Wilcoxson, Christopher) |
| Filing 36 STIPULATION for Extension of Time to File Response as to Amended Complaint/Petition #9 filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Proposed Order)(Metral, Nicole) |
| Filing 35 Notice of Appearance or Withdrawal of Counsel: for attorney Christian D Humphreys counsel for Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. Adding Chris Humphreys as counsel of record for Kellie Vazquez, Kyle Gamez, and Nadiezhda Hernandez for the reason indicated in the G-123 Notice. Filed by defendant Kellie Vazquez, Kyle Gamez, and Nadiezhda Hernandez. (Attorney Christian D Humphreys added to party Kyle Gamez(pty:dft), Attorney Christian D Humphreys added to party Nadiezhda Hernandez(pty:dft), Attorney Christian D Humphreys added to party Kellie Vazquez(pty:dft))(Humphreys, Christian) |
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Filing 34
MINUTE ORDER: DENYING TEMPORARY RESTRAINING ORDER [DKT. NO. #28 ]; AND GRANTING CONTINUANCE [DKT. NO. #24 ] (IN CHAMBERS) by Judge Virginia A. Phillips: The Ex Parte Application for a TRO is DENIED. The Court hereby CONTINUES the hearing on the Motion for Preliminary Injunction to September 13, 2021 at 2:00 p.m. Defendants' opposition to the Motion must be filed no later than August 23, 2021 at 4:00 p.m. Plaintiff's reply shall be filed no later than August 30, 2021 at 4:00 p.m. (See document for further details) (yl)
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| Filing 33 Notice of Appearance or Withdrawal of Counsel: for attorney Gregory P Olson counsel for Defendants Kyle Gamez, Nadiezhda Hernandez, Kellie Vazquez. Adding Gregory P. Olson as counsel of record for Kellie Vazquez, Kyle Gamez, Nadiezhda Hernandez for the reason indicated in the G-123 Notice. Filed by defendants Gregory P. Olson. (Attorney Gregory P Olson added to party Kyle Gamez(pty:dft), Attorney Gregory P Olson added to party Nadiezhda Hernandez(pty:dft), Attorney Gregory P Olson added to party Kellie Vazquez(pty:dft))(Olson, Gregory) |
| Filing 32 PROOF OF SERVICE filed by Plaintiff AEG Holdco, LLC, re Sealed Declaration in SupportDeclaration, #30 , APPLICATION to file document Exhibits A and B to the Declaration of Cheryl A. Sabnis in Support of Plaintiff's Ex Parte Application for TRO under seal #29 , EX PARTE APPLICATION for Temporary Restraining Order as to Misappropriation of Trade Secrets and Violation of DTSA, CUTSA, and Confidentiality Agreements #28 served on August 9, 2021. (Sabnis, Cheryl) |
| Filing 31 PROOF OF SERVICE filed by Plaintiff AEG Holdco, LLC, re Objection/Opposition (Motion related),, #25 , Sealed Declaration in SupportDeclaration, #27 , APPLICATION to file document Declarations of Garrett Rau and Brittney Luther under seal #26 served on August 6, 2021. (Sabnis, Cheryl) |
| Filing 30 SEALED DECLARATION IN SUPPORT OF APPLICATION to file document Exhibits A and B to the Declaration of Cheryl A. Sabnis in Support of Plaintiff's Ex Parte Application for TRO under seal #29 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Unredacted Document Unredacted Exhibit A to Sabnis Decl., #2 Unredacted Document Unredacted Exhibit B to Sabnis Decl.)(Miyar, Ramon) |
| Filing 29 APPLICATION to file document Exhibits A and B to the Declaration of Cheryl A. Sabnis in Support of Plaintiff's Ex Parte Application for TRO under seal filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Proposed Order Proposed Order)(Miyar, Ramon) |
| Filing 28 EX PARTE APPLICATION for Temporary Restraining Order as to Misappropriation of Trade Secrets and Violation of DTSA, CUTSA, and Confidentiality Agreements filed by Plaintiff AEG Holdco, LLC. Ex Parte Application set for hearing on 8/11/2021 at 02:00 PM before Judge Virginia A. Phillips. (Attachments: #1 Memorandum Memo of P's & A's i/s/o TRO, #2 Declaration Decl. of Cheryl A. Sabnis, #3 Exhibit Exhibit C to Sabnis Decl., #4 Exhibit Exhibit D to Sabnis Decl., #5 Exhibit Exhibit E to Sabnis Decl., #6 Exhibit Exhibit F to Sabnis Decl., #7 Exhibit Exhibit G to Sabnis Decl., #8 Proposed Order Proposed TRO) (Sabnis, Cheryl) |
| Filing 27 SEALED DECLARATION IN SUPPORT OF APPLICATION to file document Declarations of Garrett Rau and Brittney Luther under seal #26 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Unredacted Document Declaration of Brittney Luther, #2 Unredacted Document Declaration of Garrett Rau)(Miyar, Ramon) |
| Filing 26 APPLICATION to file document Declarations of Garrett Rau and Brittney Luther under seal filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Redacted Document Declaration of Brittney Luther, #2 Redacted Document Declaration of Garrett Rau, #3 Proposed Order Granting Application to Seal Documents)(Miyar, Ramon) |
| Filing 25 Opposition to Defendants Charles Taylor and LAD Aviation Ex Parte Application Opposition re: EX PARTE APPLICATION to Continue August 30, 2021 from August 30, 2021 to September 27, 2021 Re: NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited EX PARTE APPLICATION for Hearing CONTINUING THE AUGUST 30, 2021 HEARING DATE AND EXTENDING TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY #24 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration Sabnis Decl.)(Sabnis, Cheryl) |
| Filing 24 EX PARTE APPLICATION to Continue August 30, 2021 from August 30, 2021 to September 27, 2021 Re: NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 , EX PARTE APPLICATION for Hearing CONTINUING THE AUGUST 30, 2021 HEARING DATE AND EXTENDING TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY filed by defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. (Attachments: #1 Declaration DECLARATION OF MICHAEL A. IANNUCCI IN SUPPORT OF DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD (AVIATION), INC.S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE AUGUST 30, 2021 HEARING DATE AND EXTENDING TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY, #2 Exhibit EXHIBIT 1 TO DECLARATION OF MICHAEL A. IANNUCCI IN SUPPORT OF DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD (AVIATION), INC.S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE AUGUST 30, 2021 HEARING DATE AND EXTENDING TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY, #3 Proposed Order [PROPOSED] ORDER GRANTING DEFENDANTS CHARLES TAYLOR INSURANCE GENERAL AGENCY, INC. AND LAD (AVIATION), INC.S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE AUGUST 30, 2021 HEARING DATE AND EXTENDING TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF AEG HOLDCO, LLCS MOTION FOR A PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY) (Metral, Nicole) |
| Filing 23 Notice of Appearance or Withdrawal of Counsel: for attorney Nicole Bartz Metral counsel for Defendants Charles Taylor Insurance General Agency, Inc., LAD Aviation, Inc.. Adding Nicole Bartz Metral as counsel of record for Charles Taylor Insurance for the reason indicated in the G-123 Notice. Filed by defendants Charles Taylor Insurance. (Attorney Nicole Bartz Metral added to party Charles Taylor Insurance General Agency, Inc.(pty:dft), Attorney Nicole Bartz Metral added to party LAD Aviation, Inc.(pty:dft))(Metral, Nicole) |
| Filing 22 PROOF OF SERVICE filed by Plaintiff AEG Holdco, LLC, re Sealed Document,,,,,,, #20 , Memorandum in Support of Motion,, #21 served on 08/05/2021. (Miyar, Ramon) |
| Filing 21 MEMORANDUM in Support of NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 (REDACTED) filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Declaration of Robert Jay Barkley in Support of Motion for Preliminary Injunction (REDACTED), #2 Declaration of Kerriann Barkley in Support of Motion for Preliminary Injunction (REDACTED), #3 Exhibit 11 to Declaration of Kerriann Barkley (REDACTED), #4 Declaration of David Kudlinski in Support of Motion for Preliminary Injunction (REDACTED))(Sabnis, Cheryl) |
| Filing 20 SEALED DOCUMENT Sealed Memorandum of Points and Authorities, Declarations, and Supporting Exhibits re NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery #10 , Order on Motion for Leave to File Document Under Seal, #19 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Exhibit Exhibit 1 to Declaration of Gareth Sweeney, #2 Exhibit Sweeney Decl. Exhibit 2, #3 Declaration Declaration of Robert Jay Barkley (Unredacted), #4 Exhibit R.J. Barkley Decl. Exhibit 1, #5 Exhibit R.J. Barkley Decl. Exhibit 2, #6 Exhibit R.J. Barkley Decl. Exhibit 3, #7 Exhibit R.J. Barkley Decl. Exhibit 4, #8 Exhibit R.J. Barkley Decl. Exhibit 5, #9 Exhibit R.J. Barkley Decl. Exhibit 7, #10 Exhibit R.J. Barkley Decl. Exhibit 8, #11 Exhibit R.J. Barkley Decl. Exhibit 9, #12 Exhibit R.J. Barkley Decl. Exhibit 10, #13 Declaration Declaration of Kerriann Barkley (Unredacted), #14 Exhibit K. Barkley Decl. Exhibit 2, #15 Exhibit K. Barkley Decl. Exhibit 3, #16 Exhibit K. Barkley Decl. Exhibit 4, #17 Exhibit K. Barkley Decl. Exhibit 5, #18 Exhibit K. Barkley Decl. Exhibit 6, #19 Exhibit K. Barkley Decl. Exhibit 7, #20 Exhibit K. Barkley Decl. Exhibit 8, #21 Exhibit K. Barkley Decl. Exhibit 9, #22 Exhibit K. Barkley Decl. Exhibit 10, #23 Exhibit K. Barkley Decl. Exhibit 11 (Unredacted), #24 Exhibit K. Barkley Decl. Exhibit 14, #25 Exhibit K. Barkley Decl. Exhibit 15, #26 Exhibit Exhibit 1 to Declaration of Sally Litman, #27 Exhibit Litman Decl. Exhibit 2, #28 Exhibit Litman Decl. Exhibit 3, #29 Exhibit Litman Decl. Exhibit 4, #30 Exhibit Litman Decl. Exhibit 6, #31 Exhibit Litman Decl. Exhibit 7, #32 Declaration Declaration of David Kudlinski (Unredacted))(Sabnis, Cheryl) |
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Filing 19
ORDER GRANTING PLAINTIFF AEG HOLDCO, LLC'S APPLICATION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL by Judge Virginia A. Phillips: The Court hereby GRANTS Plaintiff leave to file the following documents under seal: (See document for further details) #11 (yl)
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| Filing 18 PROOF OF SERVICE Executed by Plaintiff AEG Holdco, LLC, upon Defendant LAD Aviation, Inc. served on 7/29/2021, answer due 8/19/2021. Service of the Summons and Complaint were executed upon Trudy Desbians - Authorized Agent in compliance with statute not specified by personal service.Original Summons NOT returned. (Sabnis, Cheryl) |
| Filing 17 PROOF OF SERVICE Executed by Plaintiff AEG Holdco, LLC, upon Defendant Charles Taylor Insurance General Agency, Inc. served on 7/29/2021, answer due 8/19/2021. Service of the Summons and Complaint were executed upon Daisy Montenegro - Authorized Agent in compliance with statute not specified by personal service.Original Summons NOT returned. (Sabnis, Cheryl) |
| Filing 16 PROOF OF SERVICE Executed by Plaintiff AEG Holdco, LLC, upon Defendant Nadiezhda Hernandez served on 7/29/2021, answer due 8/19/2021. Service of the Summons and Complaint were executed upon Nadiezhda Hernandez - Defendant in compliance with statute not specified by personal service.Original Summons NOT returned. (Sabnis, Cheryl) |
| Filing 15 PROOF OF SERVICE Executed by Plaintiff AEG Holdco, LLC, upon Defendant Kyle Gamez served on 7/29/2021, answer due 8/19/2021. Service of the Summons and Complaint were executed upon Kyle Gamez - Defendant in compliance with statute not specified by personal service.Original Summons NOT returned. (Sabnis, Cheryl) |
| Filing 14 PROOF OF SERVICE Executed by Plaintiff AEG Holdco, LLC, upon Defendant Kellie Vazquez served on 7/29/2021, answer due 8/19/2021. Service of the Summons and Complaint were executed upon Kellie Vazquez - Defendant in compliance with statute not specified by personal service.Original Summons NOT returned. (Sabnis, Cheryl) |
| Filing 13 TEXT ONLY NOTICE RE: Application to File Documents Under Seal #11 . In compliance with Central District of California's Local Rule 5-4.4.2, counsel shall email the Application in PDF format, and the proposed order in Microsoft Word to the Judge's generic chambers email, no later than 4:00 pm of July 29, 2021. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (cch) TEXT ONLY ENTRY |
| Filing 12 SEALED DECLARATION IN SUPPORT OF APPLICATION to file document Declarations, Exhibits, and Memorandum of Points and Authorities in Support of Plaintiff's Motion for Preliminary Injunction under seal #11 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Unredacted Document Memorandum of Points and Authorities in Support of Plaintiff's Motion for a Preliminary Injunction, #2 Unredacted Document Declaration of David Kudlinksi, #3 Unredacted Document Declaration of Kerriann Barkley, #4 Unredacted Document Exhibit 2 to K. Barkley Declaration, #5 Unredacted Document Exhibit 3 to K. Barkley Declaration, #6 Unredacted Document Exhibit 4 to K. Barkley Declaration, #7 Unredacted Document Exhibit 5 to K. Barkley Declaration, #8 Unredacted Document Exhibit 6 to K. Barkley Declaration, #9 Unredacted Document Exhibit 7 to K. Barkley Declaration, #10 Unredacted Document Exhibit 8 to K. Barkley Declaration, #11 Unredacted Document Exhibit 9 to K. Barkley Declaration, #12 Unredacted Document Exhibit 10 to K. Barkley Declaration, #13 Unredacted Document Exhibit 11 to K. Barkley Declaration, #14 Unredacted Document Exhibit 14 to K. Barkley Declaration, #15 Unredacted Document Exhibit 15 to K. Barkley Declaration, #16 Unredacted Document Exhibit 1 to Declaration of Sally Litman, #17 Unredacted Document Exhibit 2 to Declaration of Sally Litman, #18 Unredacted Document Exhibit 3 to Declaration of Sally Litman, #19 Unredacted Document Exhibit 4 to Declaration of Sally Litman, #20 Unredacted Document Exhibit 6 to Declaration of Sally Litman, #21 Unredacted Document Exhibit 7 to Declaration of Sally Litman, #22 Unredacted Document Declaration of Robert Jay Barkley, #23 Unredacted Document Exhibit 1 to R.J. Barkley Declaration, #24 Unredacted Document Exhibit 2 to R.J. Barkley Declaration, #25 Unredacted Document Exhibit 3 to R. J. Barkley Declaration, #26 Unredacted Document Exhibit 4 to R.J. Barkley Declaration, #27 Unredacted Document Exhibit 5 to R.J. Barkley Declaration, #28 Unredacted Document Exhibit 7 to R.J. Barkley Declaration, #29 Unredacted Document Exhibit 8 to R.J. Barkley Declaration, #30 Unredacted Document Exhibit 9 to R.J. Barkley Declaration, #31 Unredacted Document Exhibit 10 to R.J. Barkley Declaration, #32 Unredacted Document Exhibit 1 to Declaration of Gareth Sweeney, #33 Unredacted Document Exhibit 2 to Declaration of Gareth Sweeney)(Sabnis, Cheryl) |
| Filing 11 APPLICATION to file document Declarations, Exhibits, and Memorandum of Points and Authorities in Support of Plaintiff's Motion for Preliminary Injunction under seal filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Redacted Document Declaration of Robert Jay Barkley, #2 Redacted Document Declaration of Kerriann Barkley, #3 Redacted Document Exhibit 11 to Declaration of Kerriann Barkley, #4 Redacted Document Declaration of David Kudlinski, #5 Redacted Document Memorandum of Points and Authorities in Support of Plaintiff's Motion for a Preliminary Injunction and Expedited Discovery, #6 Proposed Order Granting Application for Leave to File Documents Under Seal)(Sabnis, Cheryl) |
| Filing 10 NOTICE OF MOTION AND MOTION for Preliminary Injunction re Misappropriation of Trade Secrets and Confidential Information and Request for Expedited Discovery filed by Plaintiff AEG Holdco, LLC. Motion set for hearing on 8/30/2021 at 02:00 PM before Judge Virginia A. Phillips. (Attachments: #1 Declaration of Fred Perez, #2 Declaration of Chris Heffernan, #3 Declaration of Sally Litman, #4 Exhibit 1 to Litman Declaration (Subject to Application to Seal), #5 Exhibit 2 to Litman Declaration (Subject to Application to Seal), #6 Exhibit 3 to Litman Declaration (Subject to Application to Seal), #7 Exhibit 4 to Litman Declaration (Subject to Application to Seal), #8 Exhibit 5 to Litman Declaration, #9 Exhibit 6 to Litman Declaration (Subject to Application to Seal), #10 Exhibit 7 to Litman Declaration (Subject to Application to Seal), #11 Exhibit 8 to Litman Declaration, #12 Declaration of Gareth Sweeney, #13 Exhibit 1 to Sweeney Declaration (Subject to Application to Seal), #14 Exhibit 2 to Sweeney Declaration (Subject to Application to Seal), #15 Exhibit 3 to Sweeney Declaration, #16 Exhibit 4 to Sweeney Declaration, #17 Exhibit A to Sweeney Declaration, #18 Exhibit 6 to Declaration of Robert Jay Barkley, #19 Exhibit 1 to Declaration of Kerriann Barkley, #20 Exhibit 12 to Declaration of Kerriann Barkley, #21 Exhibit 13 to Declaration of Kerriann Barkley, #22 Exhibit 1 to Declaration of David Kudlinski, #23 Proposed Order Granting Motion for Preliminary Injunction) (Sabnis, Cheryl) |
| Filing 9 FIRST AMENDED COMPLAINT against Defendants All Defendants amending Complaint (Attorney Civil Case Opening) #1 , filed by Plaintiff AEG Holdco, LLC (Attachments: #1 Exhibit A)(Sabnis, Cheryl) |
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Filing 8
STANDING ORDER upon filing of the complaint by Judge Virginia A. Phillips. (cch)
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| Filing 7 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening) #1 as to Defendants Charles Taylor Insurance General Agency, Inc., Kyle Gamez, Nadiezhda Hernandez, LAD Aviation, Inc., Kellie Vazquez. (Attachments: #1 Summons as to Defendant Kyle Gamez, #2 Summons as to Defendant Nadiezhda Hernandez, #3 Summons as to Defendant Charles Taylor Insurance General Agency, Inc., #4 Summons as to Defendant LAD Aviation, Inc.) (lh) |
| Filing 6 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) |
| Filing 5 NOTICE OF ASSIGNMENT to District Judge Virginia A. Phillips and Magistrate Judge Alicia G. Rosenberg. (lh) |
| Filing 4 Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening) #1 filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Request for Civil Summons to Kyle Gamez, #2 Request for Civil Summons to Nadiezhda Hernandez, #3 Request for Civil Summons to Charles Taylor Insurance General Agency, Inc., #4 Request for Civil Summons to LAD (Aviation), Inc. d/b/a Premier Environmental Assessments, A Charles Taylor Company)(Miyar, Ramon) |
| Filing 3 CORPORATE DISCLOSURE STATEMENT and Notice of Interested Parties filed by Plaintiff AEG Holdco, LLC (Sabnis, Cheryl) |
| Filing 2 CIVIL COVER SHEET filed by Plaintiff AEG Holdco, LLC. (Miyar, Ramon) |
| Filing 1 COMPLAINT Receipt No: ACACDC-31550439 - Fee: $402, filed by Plaintiff AEG Holdco, LLC. (Attachments: #1 Exhibit A) (Attorney Ramon Andres Miyar added to party AEG Holdco, LLC(pty:pla))(Miyar, Ramon) |
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