Iola Favell et al v. University of Southern California et al
| Iola Favell, Sue Zarnowski and Mariah Cummings |
| University of Southern California and 2U, Inc. |
| 2:2023cv00846 |
| February 3, 2023 |
| US District Court for the Central District of California |
| Sherilyn Peace Garnett |
| Margo A Rocconi |
| Other Fraud |
| 28 U.S.C. § 1441 Notice of Removal - Fraud |
| Plaintiff |
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| Filing 34 Notice of Los Angeles County Superior Court Filings filed by Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski. (Attachments: #1 Exhibit A - Notice of Related Case - 22STCV39350, #2 Exhibit B - Notice of Related Case - 23STCV06899)(Simplicio, Kristen) |
| Filing 33 (IN CHAMBERS) ORDER by Sherilyn Peace Garnett. In light of the First Amended Complaint (ECF No. 32 ), Defendants Motions to Dismiss are DENIED as MOOT, (ECF Nos. 28, 30), and the hearing scheduled for May 17, 2023, is hereby VACATED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY |
| Filing 32 First AMENDED COMPLAINT against Defendants 2U, Inc., University of Southern California amending Complaint - (Discovery),, filed by Plaintiffs Iola Favell, Mariah Cummings, Sue Zarnowski (Attachments: #1 Exhibit A - USC and 2U Services Agreement, #2 Exhibit B - USC CLRA Letter and Certified Mail Receipt, #3 Exhibit C - 2U CLRA Letter and Certified Mail Receipt, #4 Exhibit D - Additional CLRA Notice to USC, #5 Exhibit E - Additional CLRA Notice to 2U)(Simplicio, Kristen) |
Filing 31
ORDER by Judge Sherilyn Peace Garnett: Granting Application of Non-Resident Attorney Roman Martinez to Appear Pro Hac Vice on behalf of Defendant 2U, Inc., designating Joseph Axelrad as local counsel #27 . (iv)
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| Filing 30 NOTICE OF MOTION AND MOTION to Dismiss Plaintiffs Class Action Complaint filed by Defendant University of Southern California. Motion set for hearing on 5/17/2023 at 01:30 PM before Judge Sherilyn Peace Garnett. (Attachments: #1 Proposed Order) (Mallow, Michael) |
| Filing 29 REQUEST FOR JUDICIAL NOTICE re NOTICE OF MOTION AND MOTION to Dismiss Case #28 filed by Defendant 2U, Inc.. (Attachments: #1 Proposed Order)(Blunschi, Melanie) |
| Filing 28 NOTICE OF MOTION AND MOTION to Dismiss Case filed by Defendant 2U, Inc.. Motion set for hearing on 5/17/2023 at 01:30 PM before Judge Sherilyn Peace Garnett. (Attachments: #1 Declaration of Melanie M. Blunschi, #2 Ex. 1 - Services Agreement, #3 Ex. 2 - USNWR Methodology, #4 Ex. 3 - Jones Day Report, #5 Ex. 4 - 12.20.22 Letter from Tycko, #6 Proposed Order) (Blunschi, Melanie) |
| Filing 27 APPLICATION of Non-Resident Attorney Roman Martinez to Appear Pro Hac Vice on behalf of Defendant 2U, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34899625) filed by Defendant 2U, Inc.. (Attachments: #1 NY Certificate, #2 DC Certificate, #3 Proposed Order) (Axelrad, Joseph) |
| Filing 26 Notice of Appearance or Withdrawal of Counsel: for attorney Joseph David Axelrad counsel for Defendant 2U, Inc.. Adding Joseph D. Axelrad as counsel of record for 2U, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant 2U, Inc.. (Attorney Joseph David Axelrad added to party 2U, Inc.(pty:dft))(Axelrad, Joseph) |
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Filing 25
ORDER by Judge Sherilyn Peace Garnett: Granting Application of Non-Resident Attorney Eric Rothschild to Appear Pro Hac Vice on behalf of Plaintiff Iola Favell, Sue Zamowski, and Mariah Cummings et al., designating Annick Persinger as local counsel #21 . (iv)
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Filing 24
ORDER by Judge Sherilyn Peace Garnett: Granting Application of Non-Resident Attorney Anna Haac to Appear Pro Hac Vice on behalf of Plaintiff Iola Favell, Sue Zamowski, and Mariah Cummings et al., designating Annick Persinger as local counsel #20 . (iv)
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| Filing 23 NOTICE TO FILER RE DEFICIENCY by Sherilyn Peace Garnett. Pursuant to the filing of the Applications of Non-Resident Attorneys at Dkt. Nos.[20, 21]. A proposed order was to be e-filed as a separate attachment to any document seeking Court approval in compliance to L. R. 52-4.1. Counsel shall comply by filing a Notice of Lodging of the Proposed Order. In addition, a WordPerfect or Microsoft Word copy of the proposed document along with a PDF copy of the electronically filed main document shall be emailed to Judge Garnetts generic chambers email address in compliance with L.R. 5-4.4.2. Counsel shall comply by February 21, 2023. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY |
| Filing 22 NOTICE OF LODGING filed of Supplemental Exhibit re APPLICATION of Non-Resident Attorney Eric J. Rothschild to Appear Pro Hac Vice on behalf of Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34794412) #21 (Attachments: #1 Exhibit A - Pennsylvania Supreme Court Certificate of Good Standing)(Persinger, Annick) |
| Filing 21 APPLICATION of Non-Resident Attorney Eric J. Rothschild to Appear Pro Hac Vice on behalf of Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34794412) filed by Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski. (Attachments: #1 Declaration Of Eric Rothschild In Support Of Application For Admission Pro Hac Vice, #2 District of Columbia Certificate of Good Standing, #3 Pennsylvania Certificate of Good Standing, #4 [Proposed] Order on Application of Non-Resident Attorney Eric J. Rothschild to Appear Pro Hac Vice) (Persinger, Annick) |
| Filing 20 APPLICATION of Non-Resident Attorney Anna C. Haac to Appear Pro Hac Vice on behalf of Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34794356) filed by Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski. (Attachments: #1 District of Columbia Certificate of Good Standing, #2 Maryland Certificate of Good Standing, #3 [Proposed] Order on Application of Non-Resident Attorney Anna C. Haac to Appear Pro Hac Vice) (Persinger, Annick) |
| Filing 19 Notice of Appearance or Withdrawal of Counsel: for attorney Annick Marie Persinger counsel for Plaintiffs Mariah Cummings, Iola Favell, Sue Zarnowski. Adding Annick M. Persinger as counsel of record for Plaintiffs Iola Favell, Sue Zarnowski, and Mariah Cummings for the reason indicated in the G-123 Notice. Filed by Plaintiffs Iola Favell, Sue Zarnowski, and Mariah Cummings. (Attorney Annick Marie Persinger added to party Mariah Cummings(pty:pla), Attorney Annick Marie Persinger added to party Iola Favell(pty:pla), Attorney Annick Marie Persinger added to party Sue Zarnowski(pty:pla))(Persinger, Annick) |
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Filing 18
ORDER GRANTING STIPULATION REGARDING TIME FOR DEFENDANTS TO RESPOND TO THE CLASS ACTION COMPLAINT AND SET A BRIEFING SCHEDULE #17 by Judge Sherilyn Peace Garnett. The deadline for Defendants to answer or otherwise respond to the Class Action complaint will be March 8, 2023. Plaintiffs shall file and serve their opposition on or before April 5, 2023. Defendants shall file and serve replies in support on or before April 26, 2023. (iv)
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| Filing 17 First STIPULATION Extending Time to Answer the complaint as to All Defendants, re Complaint - (Discovery), filed by defendant 2U, Inc.. (Attachments: #1 Proposed Order)(Blunschi, Melanie) |
| Filing 16 Notice of Appearance or Withdrawal of Counsel: for attorney Nalani Lin Crisologo counsel for Defendant University of Southern California. Adding Nalani L. Crisologo as counsel of record for Defendant University of Southern California for the reason indicated in the G-123 Notice. Filed by Defendant University of Southern California. (Attorney Nalani Lin Crisologo added to party University of Southern California(pty:dft))(Crisologo, Nalani) |
| Filing 15 Notice of Appearance or Withdrawal of Counsel: for attorney Mark D. Campbell counsel for Defendant University of Southern California. Adding Mark D. Campbell as counsel of record for Defendant University of Southern California for the reason indicated in the G-123 Notice. Filed by Defendant University of Southern California. (Attorney Mark D. Campbell added to party University of Southern California(pty:dft))(Campbell, Mark) |
| Filing 14 Notice of Appearance or Withdrawal of Counsel: for attorney Michael L. Mallow counsel for Defendant University of Southern California. Adding Michael L. Mallow as counsel of record for Defendant University of Southern California for the reason indicated in the G-123 Notice. Filed by Defendant University of Southern California. (Attorney Michael L. Mallow added to party University of Southern California(pty:dft))(Mallow, Michael) |
| Filing 13 PROOF OF SERVICE filed by defendant 2U, Inc., re Pro Hac Vice Application Due (G-109) - optional html form,,, #11 , Notice to Counsel Re: Consent to Proceed before a US Magistrate Judge - optional html form #9 , Notice to Parties of Court-Directed ADR Program (ADR-8) - optional html form #8 , Initial Order upon Filing of Complaint - form only #10 , Pro Hac Vice Application Due (G-109) - optional html form,,, #12 , Notice of Assignment to United States Judges(CV-18) - optional html form #7 served on February 7, 2023. (Blunschi, Melanie) |
| Filing 12 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Eric Rothschild. 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. (car) |
| Filing 11 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Anna C Haac. 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. (car) |
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Filing 10
STANDING ORDER upon filing of the complaint by Judge Sherilyn Peace Garnett. (pg)
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| Filing 9 Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (car) |
| Filing 8 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (car) |
| Filing 7 NOTICE OF ASSIGNMENT to District Judge Sherilyn Peace Garnett and Magistrate Judge Margo A. Rocconi. (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiffs Iola Favell, Mariah Cummings, Sue Zarnowski, upon Defendant University of Southern California served on 1/10/2023, answer due 1/31/2023. Service of the Summons and Complaint were executed upon Beong-Soo Kim, Office of General Counsel, University of Southern California in compliance with California Code of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Original Summons NOT returned. Filed in State Court on 1/24/2023 Submitted with Attachment 19 Exhibit S to Notice of Removal #1 (car) |
| CONFORMED COPY OF COMPLAINT against Defendants 2U, Inc., University of Southern California. Jury Demanded, filed by Plaintiffs Iola Favell, Mariah Cummings, Sue Zarnowski. Filed in State Court on 12/20/2022 Submitted with Attachment Exhibit A to Notice of Removal #1 (car) |
| Filing 6 PROOF OF SERVICE filed by Defendant 2U, Inc., re Notice of Removal (Attorney Civil Case Opening),,,,, #1 , Notice of Appearance or Withdrawal of Counsel (G-123), #4 , Certificate/Notice of Interested Parties #3 , Civil Cover Sheet (CV-71) #2 , Notice of Appearance or Withdrawal of Counsel (G-123), #5 served on 2/3/2022. (Deeley, Elizabeth) |
| Filing 5 Notice of Appearance or Withdrawal of Counsel: for attorney Elizabeth Lee Deeley counsel for Defendant 2U, Inc.. Adding Elizabeth L. Deeley as counsel of record for 2U, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant 2U, Inc.. (Attorney Elizabeth Lee Deeley added to party 2U, Inc.(pty:dft))(Deeley, Elizabeth) |
| Filing 4 Notice of Appearance or Withdrawal of Counsel: for attorney Melanie M Blunschi counsel for Defendant 2U, Inc.. Adding Malanie M. Blunschi as counsel of record for 2U, Inc. for the reason indicated in the G-123 Notice. Filed by Defendant 2U, Inc.. (Blunschi, Melanie) |
| Filing 3 NOTICE of Interested Parties filed by Defendant 2U, Inc., identifying Iola Favell, Sue Zarnowski, Mariah Cumming, University of Southern California, 2U, Inc.. (Blunschi, Melanie) |
| Filing 2 CIVIL COVER SHEET filed by Defendant 2U, Inc.. (Blunschi, Melanie) |
| Filing 1 NOTICE OF REMOVAL from Superior Court of the State of California for the County of Los Angeles, case number 22STCV39350 Receipt No: ACACDC-34739302 - Fee: $402, filed by Defendant 2U, Inc.. (Attachments: #1 Exhibit Ex. A - Complaint, #2 Exhibit Ex. B - Summons, #3 Exhibit Ex. C - Civil Case Cover Sheet & Addendum, #4 Exhibit Ex. D - Notice of Case Assignment, #5 Exhibit Ex. E - First Amended General Order, #6 Exhibit Ex. F - ADR Packet, #7 Exhibit Ex. G - Voluntary Efficient Litigation Stipulation Packet, #8 Exhibit Ex. H - Certificate of Mailing, #9 Exhibit Ex. I - Initial Status Conference Order, #10 Exhibit Ex. J - Notice of Hearing and Motion and Verified Pro Hac Vice Application of Eric Rothschild, #11 Exhibit Ex. K - Notice of Appearance Elizabeth Deeley, #12 Exhibit Ex. L - Notice of Appearance Melanie M. Blunschi, #13 Exhibit Ex. M - Notice of Posting of Complex Fees, #14 Exhibit Ex. N - Affidavit of Service on 2U, Inc., #15 Exhibit Ex. O - Affidavit of Service on 2U, Inc., #16 Exhibit Ex. P - Affidavit of Service on California State Bar, #17 Exhibit Ex. Q - Affidavit of Service on University of Southern California, #18 Exhibit Ex. R - Proof of Service on 2U, Inc., #19 Exhibit Ex. S - Proof of Service on University of Southern California, #20 Exhibit Ex. T - Los Angeles Superior Court Docket) (Attorney Melanie M Blunschi added to party 2U, Inc.(pty:dft))(Blunschi, Melanie) |
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