Gwendalyn Douglass v. Reliant Life Shares LLC et al
Plaintiff: Gwendalyn Douglass
Defendant: Reliant Life Shares LLC, Reliant Capital, RLS Financial Services, Inc., RMS Trust, Scott Grady, Paul Roy, David Underwood, Mark Sansoucy, Andrew Murphy, Joel Kleinfeld, UMB Bank N.A., Bank of Utah, Pacific Life Insurance Company, Lincoln Financial Group, Principal Financial Group, General American Life Insurance Company, PHL Variable Insurance Co., The Penn Mutual Life Insurance Company, Lincoln Benefit Life, Beneficial Life Insurance Co., ReliaStar Life Insurance Company, AXA Equitable Life Insurance Company, Zurich American Life Insurance Company, Does 1-20, RLS Financial Services, Inc., Larry Tupler and Vincent Bovino
Petitioner: Reliant Life Shares LLC aka RELIANT CAPITAL and Bank of Utah, as Trustee of the Reliant Life Shares Series Statutory Trust (erroneously sued as Bank of Utah)
Case Number: 2:2023cv00460
Filed: January 20, 2023
Court: US District Court for the Central District of California
Presiding Judge: Stanley Blumenfeld
Referring Judge: Alicia G Rosenberg
Nature of Suit: Securities/Commodities
Cause of Action: 28 U.S.C. § 1441 Notice of Removal
Jury Demanded By: Both
Docket Report

This docket was last retrieved on March 31, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 17, 2023 Filing 38 NOTICE OF MOTION AND MOTION to First Amended Complaint Notice of Removal (Attorney Civil Case Opening),, #1 , NOTICE OF MOTION AND MOTION to Consolidate Cases, as to 2:23-cv-00474-SB-PD; 2:23-cv-00460-SB-AGR, filed by Plaintiff Gwendalyn Douglass. Motion set for hearing on 4/14/2023 at 08:30 AM before Judge Stanley Blumenfeld Jr.. (Attachments: #1 Proposed Order GRANTING PLAINTIFFS MOTION FOR LEAVE TO AMEND COMPLAINTS AND CONSOLIDATE CASES, #2 Declaration of J. Owen Murrin, #3 Exhibit Redlined Complaint (Douglass), #4 Exhibit Proposed Second Amended Complaint (Douglass), #5 Exhibit All Second Amended Complaint Exhibits (Douglass), #6 Declaration of Gwendalyn Douglass, #7 Exhibit Redlined Complaint (Baeza), #8 Exhibit Proposed Second Amended Complaint (Baeza), #9 Exhibit All Second Amended Complaint Exhibits (Baeza), #10 Declaration of Georgeta Masson) (Murrin, John)
March 16, 2023 Opinion or Order Filing 37 ORDER GRANTING STIPULATION TO DISMISS BANK OF UTAH, TRUSTEE OF THE RELIANT LIFE SHARES SERIES STATUTORY TRUST by Judge Stanley Blumenfeld, Jr.: Upon Stipulation #36 , the Court hereby dismisses with prejudice the Bank of Utah, Trustee of the Reliant Life Shares Series Statutory Trust. Plaintiff and the Bank of Utah will bear their own fees and costs incurred in this action. (gk)
March 15, 2023 Filing 36 STIPULATION to Dismiss Defendant Bank of Utah filed by Plaintiff Gwendalyn Douglass. (Attachments: #1 Proposed Order)(Murrin, John)
March 8, 2023 Opinion or Order Filing 35 ORDER RE: MOTION TO AMEND THE PLEADINGS by Judge Stanley Blumenfeld, Jr.: Plaintiffs in these two cases have filed status reports indicating that the parties have been unable to reach agreement on a stipulation to allow Plaintiffs to amend the complaints or to consolidate the cases. Douglass v. Reliant Life Shares LLC et al., Case No. 2:23-cv-00460-SB-AGR (Douglass), Dkt. No. #32 ; Baeza et al. v. Reliant Life Shares, LLC et al., Case No. 2:23-cv-00474-SB-PD (Baeza), Dkt. No. 46. Plaintiffs indicate that they wish to amend the complaints. Accordingly, Plaintiffs are ordered to file one motion to amend the complaints in both cases no later than 3/17/2023. In the motion, Plaintiffs should indicate whether they are proposing to consolidate these cases in light of their substantial similarity. Any opposition to Plaintiffs' motion is due 3/24/2023, and any reply is due 3/31/2023. The motion will be heard on 4/14/2023 at 8:30 AM. See document for further details. (gk)
March 8, 2023 Filing 34 PROOF OF SERVICE filed by Plaintiff Gwendalyn Douglass, re Notice of Removal (Attorney Civil Case Opening),, #1 Defendants David Underwood and RMS Trust were served on 3/7/2023. (Murrin, John)
March 8, 2023 Filing 33 PROOF OF SERVICE Executed by Plaintiff Gwendalyn Douglass, upon Defendant Andrew Murphy served on 2/24/2023, answer due 3/17/2023. Service of the Summons and Complaint were executed upon Defendant Andrew Murphy in compliance with California Code of Civil Procedure by substituted service at home address and by also mailing a copy.Original Summons NOT returned. (Murrin, John)
March 3, 2023 Filing 32 JOINT REPORT of CONSOLIDATING CASES AND AMENDING THE COMPLAINT filed by Plaintiff Gwendalyn Douglass. (Murrin, John)
February 22, 2023 Opinion or Order Filing 31 ORDER VACATING MANDATORY SCHEDULING CONFERENCES, ORDERING PARTIES TO MEET AND CONFER, AND STAYING ANSWER DEADLINES FOR ALL DEFENDANTS by Judge Stanley Blumenfeld, Jr.: These two cases were filed a day apart by the same Plaintiffs' counsel against largely the same Defendants alleging largely the same conduct. One of the cases, Baeza v. Reliant Life Shares, LLC, Case No. 2:23-cv-00474-SB-PD (Baeza), is brought as a putative class action on behalf of a class that includes Gwendalyn Douglass, Plaintiff in the other case, Douglass v. Reliant Life Shares LLC, Case No. 2:23-cv-00460-SB-AGR (Douglass). The mandatory scheduling conferences set for February 24, 2023 in both of these cases are hereby VACATED. The Court will reset the scheduling conferences after the other matters discussed in this order are resolved. All parties are ORDERED no later than 3/1/2023 to meet and confer in person or by videoconference to discuss the possible amendment of Plaintiffs' pleadings and a plan for the efficient resolution of these cases. No later than 3/3/2023, the parties shall file a joint report stating their positions as to whether the cases should be consolidated and whether Plaintiffs should be permitted to amend their pleadings. Plaintiffs should be prepared to file by 3/10/2023 either an amended pleading or, if any party objects to amendment, a noticed motion for leave to amend. The Court temporarily stays the deadlines for all Defendants to answer or otherwise respond to the operative complaints. See document for further details. (gk)
February 21, 2023 Filing 30 Joint STIPULATION Extending Time to Answer the complaint as to Lincoln Benefit Life answer now due 3/24/2023, re Complaint - (Discovery),, filed by Defendant Lincoln Benefit Life. (Attachments: #1 Proposed Order)(Salzman, Ryan)
February 21, 2023 Opinion or Order Filing 29 ORDER RE: STIPULATION TO EXTEND TIME TO RESPOND #24 by Judge Stanley Blumenfeld, Jr. The Court will grant the improper stipulation and allow Defendant Kleinfeld until February 27, 2023 to answer or otherwise respond to the FAC. The parties are cautioned that it expects them to carefully comply with the Court's rules in the future. Failure to do so may result in an order to show cause why sanctions should not be imposed. IT IS SO ORDERED. (rolm)
February 21, 2023 Filing 28 Notice of Appearance or Withdrawal of Counsel: for attorney David P. Beitchman counsel for Defendants Vincent Bovino, Paul Roy, Larry Tupler. Adding David P. Beitchman as counsel of record for Vincent Bovino, Paul Roy and Larry Tupler for the reason indicated in the G-123 Notice. Filed by Defendants Vincent Bovino, Paul Roy and Larry Tupler. (Attorney David P. Beitchman added to party Vincent Bovino(pty:dft), Attorney David P. Beitchman added to party Paul Roy(pty:dft), Attorney David P. Beitchman added to party Larry Tupler(pty:dft))(Beitchman, David)
February 21, 2023 Filing 27 Notice of Appearance or Withdrawal of Counsel: for attorney Joseph Duffy counsel for Defendant Beneficial Life Insurance Co.. Adding Joseph Duffy as counsel of record for Beneficial Life Insurance Co. for the reason indicated in the G-123 Notice. Filed by Defendant Beneficial Life Insurance Co.. (Duffy, Joseph)
February 21, 2023 Filing 26 Joint STIPULATION for Extension of Time to File Answer to April 7, 2023 filed by Defendant Beneficial Life Insurance Co.. (Attachments: #1 Proposed Order)(Attorney Joseph Duffy added to party Beneficial Life Insurance Co.(pty:dft))(Duffy, Joseph)
February 21, 2023 Filing 25 Joint STIPULATION for Extension of Time to File Answer to March 3, 2023 filed by Defendants Paul Roy, Larry Tupler, Vincent Bovino. (Attachments: #1 Proposed Order)(Attorney Andre Boniadi added to party Paul Roy(pty:dft), Attorney Andre Boniadi added to party Larry Tupler(pty:dft), Attorney Andre Boniadi added to party Vincent Bovino(pty:dft))(Boniadi, Andre)
February 17, 2023 Filing 24 Joint STIPULATION for Order ORDER GRANTING STIPULATION TO EXTEND DEADLINE TO ANSWER FOR JOEL KLEINFELD filed by Plaintiff Gwendalyn Douglass. (Attachments: #1 Proposed Order)(Murrin, John)
February 14, 2023 Opinion or Order Filing 23 ORDER by Judge Stanley Blumenfeld, Jr. Granting Application of Non-Resident Attorney David T. McDowell to Appear Pro Hac Vice on behalf of Defendants American General Life Insurance Company, PHL Variable Insurance Company, Equitable Financial Life Insurance Company of America, Pacific Life Insurance Company, The Penn Mutual Life Insurance Company, and ReliaStar Life Insurance Company, designating Colleen T. Flaherty as local counsel #15 . (gk)
February 14, 2023 Filing 22 JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 2 weeks, filed by Plaintiff Gwendalyn Douglass.. (Murrin, John)
February 14, 2023 Filing 21 NOTICE OF DISMISSAL filed by Plaintiff Gwendalyn Douglass pursuant to FRCP 41a(1) as to Lincoln Financial Group. (Murrin, John)
February 14, 2023 Filing 20 NOTICE OF DISMISSAL filed by Plaintiff Gwendalyn Douglass pursuant to FRCP 41a(1) as to Lincoln Financial Group. (Murrin, John)
February 14, 2023 Filing 19 NOTICE OF DISMISSAL filed by Plaintiff Gwendalyn Douglass pursuant to FRCP 41a(1) as to AXA Equitable Life Insurance Company, General American Life Insurance Company, PHL Variable Insurance Co., Pacific Life Insurance Company, ReliaStar Life Insurance Company, The Penn Mutual Life Insurance Company. (Murrin, John)
February 9, 2023 Filing 18 Notice of Appearance or Withdrawal of Counsel: for attorney Stephanie Chau counsel for Defendant Zurich American Life Insurance Company. Adding Stephanie G. Chau as counsel of record for Zurich American Life Insurance Company for the reason indicated in the G-123 Notice. Filed by Defendant Zurich American Life Insurance Company. (Attorney Stephanie Chau added to party Zurich American Life Insurance Company(pty:dft))(Chau, Stephanie)
February 8, 2023 Filing 17 WAIVER OF SERVICE Returned Executed filed by Defendant Zurich American Life Insurance Company. upon Zurich American Life Insurance Company waiver sent by Plaintiff on 1/31/2023, answer due 4/3/2023. Waiver of Service signed by Stephanie G. Chau. (Chau, Stephanie)
January 31, 2023 Filing 16 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice of Removal (Attorney Civil Case Opening) #14 . 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)
January 30, 2023 Filing 15 APPLICATION of Non-Resident Attorney David T. McDowell to Appear Pro Hac Vice on behalf of Defendants General American Life Insurance Company, PHL Variable Insurance Co. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34707703) filed by Defendants General American Life Insurance Company, PHL Variable Insurance Co.. (Attachments: #1 Proposed Order) (Flaherty, Colleen)
January 27, 2023 Filing 14 NOTICE OF REMOVAL from Los Angeles Superior Court, case number 22STCV38044 with filing fee previously paid ($402 paid on 1/20/2023, receipt number ACACDC-34655169), filed by Defendant Bank of Utah.(Walton, Lewis)
January 27, 2023 Filing 13 STIPULATION for Extension of Time to File Response filed by Defendant UMB Bank N.A..(Attorney Dean A Olson added to party UMB Bank N.A.(pty:dft))(Olson, Dean)
January 26, 2023 Filing 12 Joint STIPULATION Extending Time to Answer the complaint as to Lincoln Benefit Life answer now due 2/24/2023, re Complaint - (Discovery),, filed by Defendant Lincoln Benefit Life.(Attorney Ryan Matthew Salzman added to party Lincoln Benefit Life(pty:dft))(Salzman, Ryan)
January 25, 2023 Filing 11 STIPULATION Extending Time to Answer the complaint as to Mark Sansoucy answer now due 2/25/2023; RLS Financial Services, Inc. answer now due 2/25/2023, re Notice of Removal (Attorney Civil Case Opening),, #1 filed by defendant Mark Sansoucy; RLS Financial Services, Inc..(Attorney Peter Berlin added to party Mark Sansoucy(pty:dft), Attorney Peter Berlin added to party RLS Financial Services, Inc.(pty:dft))(Berlin, Peter)
January 25, 2023 Filing 10 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney David T. McDowell. 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)
January 24, 2023 Filing 9 NOTICE OF DEFICIENCIES in Attorney Case Opening RE: Notice of Removal (Attorney Civil Case Opening), #1 . The following error(s) was found: Other error(s) with document(s): Attachments No. 2 Affidavit and Notice of Related Parties should not have been attached to Docket Entry No. 1. Each document should have been filed separately. You are not required to take any action to correct this deficiency unless the Court so directs. (lh)
January 24, 2023 Filing 8 NOTICE OF DEFICIENCIES in Attorney Case Opening RE: Notice of Removal (Attorney Civil Case Opening), #1 . The following error(s) was found: Other error(s) with document(s): Attachments No. 1 Civil Cover Sheet should not have been attached to Docket Entry No. 1. Each document should have been filed separately. You are not required to take any action to correct this deficiency unless the Court so directs. (lh)
January 24, 2023 Opinion or Order Filing 7 ORDER SETTING SCHEDULING CONFERENCE by Judge Stanley Blumenfeld, Jr.: The Court sets an in-person Mandatory Scheduling Conference set for hearing on February 24, 2023 at 8:30 AM before Judge Stanley Blumenfeld Jr. The parties shall file a Joint Rule 26(f) Report by February 14, 2023. SEE ORDER FOR FURTHER DETAILS. (jgr)
January 24, 2023 Opinion or Order Filing 6 CIVIL STANDING ORDER upon filing of the complaint by Judge Stanley Blumenfeld, Jr. (jgr)
January 24, 2023 Filing 5 Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (lh)
January 24, 2023 Filing 4 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh)
January 24, 2023 Filing 3 NOTICE OF ASSIGNMENT to District Judge Stanley Blumenfeld, Jr and Magistrate Judge Alicia G. Rosenberg. (lh)
January 23, 2023 Filing 2 STIPULATION Extending Time to Answer the complaint as to re Notice of Removal (Attorney Civil Case Opening),, #1 filed by Defendant American General Life Insurance Company, Phl Variable Insurance Company, Reliastar Life Insurance Company, The Penn Mutual Life Insurance Company, Equitable Financial Life Insurance Company of America, Pacific Life Insurance Company.(Attorney Colleen Therese Flaherty added to party American General Life Insurance Company(pty:dft), Attorney Colleen Therese Flaherty added to party Equitable Financial Life Insurance Company of America(pty:dft), Attorney Colleen Therese Flaherty added to party Pacific Life Insurance Company(pty:dft), Attorney Colleen Therese Flaherty added to party Phl Variable Insurance Company(pty:dft), Attorney Colleen Therese Flaherty added to party The Penn Mutual Life Insurance Company(pty:dft), Attorney Colleen Therese Flaherty added to party Reliastar Life Insurance Company(pty:dft))(Flaherty, Colleen)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Mark Sansoucy served on 12/15/2022, answer due 1/5/2023. in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Pacific Life Insurance Company served on 12/20/2022, answer due 1/10/2023. Service of the Summons and Complaint were executed upon Roy, an employee who works in the mail Room of Pacific Life Insurance Company in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/21/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Zurich American Life Insurance Company served on 12/8/2022, answer due 12/29/2022. in compliance with California Code of Civil Procedure by mail service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/22/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Paul Roy served on 12/15/2022, answer due 1/5/2023. Service of the Summons and Complaint were executed upon Jasmine, the receptionist for Reliant Life Shares, LLC in compliance with California Code of Civil Procedure by substituted service at business address and no service by mail was executed. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Lincoln Benefit Life served on 12/8/2022, answer due 12/29/2022 in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/22/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Scott Grady served on 12/15/2022, answer due 1/5/2023. Service of the Summons and Complaint were executed upon Jasmine, the receptionist for Reliant Life Shares, LLC in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF COMPLAINT against Defendants AXA Equitable Life Insurance Company, Bank of Utah, Beneficial Life Insurance Co., Does, General American Life Insurance Company, Scott Grady, Joel Kleinfeld, Lincoln Benefit Life, Lincoln Financial Group, Andrew Murphy, PHL Variable Insurance Co., Pacific Life Insurance Company, Principal Financial Group, RMS Trust, ReliaStar Life Insurance Company, Reliant Life Shares LLC, Paul Roy, Mark Sansoucy, The Penn Mutual Life Insurance Company, UMB Bank N.A., David Underwood. Jury Demanded, filed by Plaintiff Gwendalyn Douglass. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/5/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant ReliaStar Life Insurance Company served on 12/8/2022, answer due 12/29/2022 in compliance with California Code of Civil Procedure by mail service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/22/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Andrew Murphy served on 12/15/2022, answer due 1/5/2023. Service of the Summons and Complaint were executed upon Jasmine, the receptionist for Reliant Life Shares, LLC in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant RMS Trust served on 12/15/2022, answer due 1/5/2023. Service of the Summons and Complaint were executed upon Jasmine, the receptionist for Reliant Life Shares, LLC in compliance with California Code of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant David Underwood served on 12/16/2022, answer due 1/6/2023. in compliance with California Code of Civil Procedure by substituted service at business address and no service by mail was executed. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/20/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant PHL Valriable Insurance Company in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/23/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant AXA Equitable Life Insurance Company served on 12/20/2022, answer due 1/10/2023 in compliance with California Code of Civil Procedure by mail service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 1/6/2023 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF ANSWER to Complaint, filed by Defendants Bank of Utah, Reliant Life Shares LLC. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 1/17/2023 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 )(lh)
January 20, 2023 CONFORMED FILED COPY OF ANSWER to Complaint, filed by Defendant Scott Grady. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 1/17/2023 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 )(Attorney Christopher M Stevens added to party Scott Grady(pty:dft))(lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Bank of Utah served on 1/4/2023, answer due 1/25/2023. in compliance with California Code of Civil Procedure by mail service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 1/17/2023 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Reliant Life Shares LLC served on 12/21/2022, answer due 1/11/2023. Service of the Summons and Complaint were executed upon Christopher Moore Stevens, Registered Agent in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/29/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF FIRST AMENDED COMPLAINT against Defendants AXA Equitable Life Insurance Company, Bank of Utah, Beneficial Life Insurance Co., Does, General American Life Insurance Company, Scott Grady, Joel Kleinfeld, Lincoln Benefit Life, Lincoln Financial Group, Andrew Murphy, PHL Variable Insurance Co., Pacific Life Insurance Company, Principal Financial Group, RMS Trust, ReliaStar Life Insurance Company, Reliant Life Shares LLC, Paul Roy, Mark Sansoucy, The Penn Mutual Life Insurance Company, UMB Bank N.A., David Underwood amending Complaint,, filed by Plaintiff Gwendalyn Douglass. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/27/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 )(lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant Beneficial Life Insurance Co. served on 12/23/2022, answer due 1/13/2023. in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/23/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant General American Life Insurance Company served on 12/8/2022, answer due 12/29/2022. in compliance with California Code of Civil Procedure by mail service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/22/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant The Penn Mutual Life Insurance Company served on 12/23/2022, answer due 1/13/2023 in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/23/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 CONFORMED FILED COPY OF PROOF OF SERVICE SUMMONS Executed by Plaintiff Gwendalyn Douglass, upon Defendant PHL Variable Insurance Co. served on 12/23/2022, answer due 1/13/2023. in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 12/23/2022 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh)
January 20, 2023 Filing 1 NOTICE OF REMOVAL from Los Angeles Superior Court, case number 22STCV438044 Receipt No: ACACDC-34655169 - Fee: $402, filed by Defendant Bank of Utah, as Trustee of the Reliant Life Shares Series Statutory Trust (erroneously sued as Bank of Utah). (Attachments: #1 Civil Cover Sheet, #2 Affidavit and Notice of Related Parties) (Attorney Lewis Richard Walton, Jr added to party Bank of Utah, as Trustee of the Reliant Life Shares Series Statutory Trust (erroneously sued as Bank of Utah)(pty:bkmov))(Walton, Lewis)

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Search for this case: Gwendalyn Douglass v. Reliant Life Shares LLC et al
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Plaintiff: Gwendalyn Douglass
Represented By: John Owen Murrin, III
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Petitioner: Reliant Life Shares LLC aka RELIANT CAPITAL
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Petitioner: Bank of Utah, as Trustee of the Reliant Life Shares Series Statutory Trust (erroneously sued as Bank of Utah)
Represented By: Lewis Richard Walton, Jr
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Defendant: Reliant Life Shares LLC
Represented By: Lewis Richard Walton, Jr
Represented By: Brian M Kandel
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Defendant: Reliant Capital, RLS Financial Services, Inc.
Represented By: Lewis Richard Walton, Jr
Represented By: Brian M Kandel
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Defendant: RMS Trust
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Defendant: Scott Grady
Represented By: Christopher M Stevens
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Defendant: Paul Roy
Represented By: Andre Boniadi
Represented By: David P. Beitchman
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Defendant: David Underwood
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Defendant: Mark Sansoucy
Represented By: Peter Berlin
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Defendant: Andrew Murphy
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Defendant: Joel Kleinfeld
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Defendant: UMB Bank N.A.
Represented By: Dean A. Olson
Represented By: Wendi J Frisch
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Defendant: Bank of Utah
Represented By: Lewis Richard Walton, Jr
Represented By: Brian M Kandel
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Defendant: Pacific Life Insurance Company
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: Lincoln Financial Group
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Defendant: Principal Financial Group
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Defendant: General American Life Insurance Company
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: PHL Variable Insurance Co.
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: The Penn Mutual Life Insurance Company
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: Lincoln Benefit Life
Represented By: Ryan Matthew Salzman
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Defendant: Beneficial Life Insurance Co.
Represented By: Joseph Duffy
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Defendant: ReliaStar Life Insurance Company
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: AXA Equitable Life Insurance Company
Represented By: Colleen Therese Flaherty
Represented By: David T. McDowell
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Defendant: Zurich American Life Insurance Company
Represented By: Stephanie Chau
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Defendant: Does 1-20
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Defendant: RLS Financial Services, Inc.
Represented By: Peter Berlin
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Defendant: Larry Tupler
Represented By: Andre Boniadi
Represented By: David P. Beitchman
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Defendant: Vincent Bovino
Represented By: Andre Boniadi
Represented By: David P. Beitchman
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