Keller North America, Inc. v. Advanced Geosolutions Inc. et al
| Keller North America, Inc. |
| Advanced Geosolutions Inc., Riaz Jiwani, Chase M. Henri, Thang Van Nguyen and Does 1 through 50 inclusive |
| 8:2023cv01200 |
| July 5, 2023 |
| US District Court for the Central District of California |
| John D Early |
| Fred W Slaughter |
| Autumn D Spaeth |
| Trademark |
| 28 U.S.C. § 1441 Notice of Removal |
| Both |
Docket Report
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Filing 20
MINUTE (IN CHAMBERS) Further Order Regarding Plaintiff's Request for Telephonic Appearance at the Hearing on Plaintiff's Motion for Leave to File a Second Amended Complaint and Motion for Order Remanding Case to state Court Schedule for 8/31/2023 at 10:00 AM #18 by Judge Fred W. Slaughter: In light of the court vacating the August 31, 2023, scheduled in-person hearings for the Motions, the Request is DENIED AS MOOT. (See document for further information). (jp)
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| Filing 19 SCHEDULING NOTICE by Judge Fred W. Slaughter: Before the court are Plaintiff's Motion to File a Second Amended Complaint, Or to Have the Second Amended Complaint Deemed Properly Filed #11 and Plaintiff's Motion to Remand Case to Orange County Superior Court #12 . The court finds these matters appropriate for decision without oral argument. See Fed. R. Civ. P. 78(b); C.D. Cal. R. 7-15. Accordingly, the hearings set for August 31, 2023, at 10:00 a.m. are VACATED/OFF CALENDAR and the court takes the matters UNDER SUBMISSION. In light of the motions being taken under submission, the court also DENIES AS MOOT Plaintiffs Counsels Request for Telephonic Appearance the August 31st Motion Hearings #18 . THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. TEXT ONLY ENTRY. (mku) |
| Filing 18 REQUEST for Leave of Counsel for Plaintiff Keller North America, Inc. to Appear for Hearings on Plaintiff's Motion for Leave to File Second Amended Complaint and for Order Remanding Case scheduled for August 31, 2023 at 10 a.m. via Telephonic Appearance filed by plaintiff Keller North America, Inc.. (Attachments: #1 Proposed Order) (Case, Thomas) |
| Filing 17 REPLY in support of NOTICE OF MOTION AND MOTION to Remand Case to Orange County Superior Court #12 , NOTICE OF MOTION AND MOTION to File a Second Amended Complaint, Or to Have the Second Amended Complaint Deemed Properly Filed #11 filed by Plaintiff Keller North America, Inc.. (Case, Thomas) |
| Filing 16 DECLARATION of Anna R. Buono in opposition NOTICE OF MOTION AND MOTION to Remand Case to Orange County Superior Court #12 filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen. (Buono, Anna) |
| Filing 15 OPPOSITION in opposition re: NOTICE OF MOTION AND MOTION to Remand Case to Orange County Superior Court #12 filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen. (Buono, Anna) |
| Filing 14 DECLARATION of Anna R. Buono in opposition NOTICE OF MOTION AND MOTION to File a Second Amended Complaint, Or to Have the Second Amended Complaint Deemed Properly Filed #11 filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen. (Buono, Anna) |
| Filing 13 OPPOSITION IN OPPOSITION re: NOTICE OF MOTION AND MOTION to File a Second Amended Complaint, Or to Have the Second Amended Complaint Deemed Properly Filed #11 filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen. (Buono, Anna) |
| Filing 12 NOTICE OF MOTION AND MOTION to Remand Case to Orange County Superior Court filed by plaintiff Keller North America, Inc.. Motion set for hearing on 8/31/2023 at 01:30 PM before Judge Fred W. Slaughter. (Attachments: #1 Declaration of Thomas Case, #2 Exhibit 1 to Declaration (Meet and confer email), #3 Proposed Order) (Case, Thomas) |
| Filing 11 NOTICE OF MOTION AND MOTION to File a Second Amended Complaint, Or to Have the Second Amended Complaint Deemed Properly Filed filed by plaintiff Keller North America, Inc.. Motion set for hearing on 8/31/2023 at 01:30 PM before Judge Fred W. Slaughter. (Attachments: #1 Declaration Declaration of Thomas Case, #2 Exhibit Ex 1 to Declaration of Thomas Case (Meet and Confer Email), #3 Plaintiffs Notice of Lodging, #4 Notice of Lodging Attachment - Plaintiff's Second Amended Complaint, #5 Notice of Lodging Attachment - Ex 1 to Second Amended Complaint (Jiwani non-disclosure), #6 Notice of Lodging Attachment - Ex 2 to Second Amended Complaint (Nguyen employment agreement), #7 Notice of Lodging Attachment - Ex 3 to Second Amended Complaint (Henri non-disclosure), #8 Notice of Lodging Attachment - Ex 4 to Second Amended Complaint (Estuary Hotel Submittal), #9 Notice of Lodging Attachment - Ex 5 to Second Amended Complaint (Inglewood Parking Garage Submittal), #10 Appendix, #11 Attachment to Appendix - Redline of Second Amended Complaint, #12 Proposed Order) (Case, Thomas) |
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Filing 10
(IN CHAMBERS) ORDER by Judge Fred W. Slaughter: The court is in receipt of the Parties Stipulation to Stay Action Pending Mediation (Dkt. #9 ) (the Stipulation), filed on July 20, 2023. The Stipulation requests the Second Amended Complaint should be deemed withdrawn, and the case be stayed for 90 days... to allow the Parties to resolve thiscase through mediation and settlement. (Dkt. #9 at 3.) The Stipulation also states, The parties believe that they may be able to resolve this case through private mediation, and wish to minimize litigation costs pending mediation, and [t]he Parties agree that the relief sought herein is necessary to proceed with the case in the most economical fashion, yet allow sufficient time to schedule and complete discovery, if necessary. (Id. at 2-3.) Based on the state of the record, as applied to the applicable law, including the cases cited by the Parties in the Stipulation, the court finds that the Stipulation does not establish adequate good cause and the Parties have made an insufficient showing for the relief sought. Accordingly, the Stipulation is DENIED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (mku) TEXT ONLY ENTRY
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| Filing 9 STIPULATION to Stay Case pending Mediation filed by plaintiff Keller North America, Inc.. (Attachments: #1 Proposed Order)(Case, Thomas) |
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Filing 8
CIVIL STANDING ORDER by Judge Fred W. Slaughter. (dgo)
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| Filing 7 NOTICE OF REASSIGNMENT of MJDAP case from Magistrate Judge John D. Early to Judge Fred W. Slaughter for all further proceedings. Any discovery matters that may be referred to a Magistrate Judge are assigned to U.S. Magistrate Judge Autumn D. Spaeth. The case number will now reflect the initials of the transferee Judges 8:23-cv-01200 FWS(ADSx). (rn) |
| Filing 6 Notice of Interested Parties and Corporate Disclosure Statement NOTICE of Interested Parties filed by Plaintiff Keller North America, Inc., (Case, Thomas) |
| Filing 5 SECOND AMENDED COMPLAINT against Defendants All Defendants amending Amended Complaint,, filed by plaintiff Keller North America, Inc. (Attachments: #1 Exhibit Ex 1 - Jiwani non-disclosure provisions employment agreement, #2 Exhibit Ex 2 - Nguyen employment agreement with Disclosure and Confidentiality provisions, #3 Exhibit Ex 3 - Henri non-disclosure provisions in the employment agreement and offer letter, #4 Exhibit Ex 4 - Estuary Hotel Submittal, #5 Exhibit Ex 5 - Inglewood Parking Garage Submittal)(Case, Thomas) |
| Filing 4 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): Attachment(s): # 1 Civil Cover Sheet Civil Cover Sheet The document(s) should have been filed separately. You are not required to take any action to correct this deficiency unless the Court so directs.. (sh) |
| Filing 3 NOTICE TO COUNSEL re Magistrate Judge Direct Assignment Program. This case has been randomly assigned to Magistrate Judge John D. Early. (sh) |
| Filing 2 CORPORATE DISCLOSURE STATEMENT filed by Defendant ADVANCED GEOSOLUTIONS, INC., a California corporation identifying ADVANCED GEOSOLUTIONS, INC. has no parent corporation as Corporate Parent. (Buono, Anna) |
| Filing 1 NOTICE OF REMOVAL from Orange County Superior Court, case number 30-2022-01268368 Receipt No: ACACDC-35611592 - Fee: $402, filed by defendant CHASE M. HENRI, RIAZ JIWANI, ADVANCED GEOSOLUTIONS, INC., a California corporation, THANG VAN NGUYEN. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Exhibit Exhibit A, #3 Exhibit Exhibit B, #4 Exhibit Exhibit C, #5 Exhibit Exhibit D, #6 Exhibit Exhibit E, #7 Exhibit Exhibit F, #8 Exhibit Exhibit G, #9 Exhibit Exhibit H, #10 Exhibit Exhibit I, #11 Exhibit Exhibit J, #12 Exhibit Exhibit K) (Attorney Anna R Buono added to party ADVANCED GEOSOLUTIONS, INC., a California corporation(pty:dft), Attorney Anna R Buono added to party CHASE M. HENRI(pty:dft), Attorney Anna R Buono added to party RIAZ JIWANI(pty:dft), Attorney Anna R Buono added to party THANG VAN NGUYEN(pty:dft))(Buono, Anna) |
| CONFORMED EFILED COPY OF COMPLAINT against Defendants Advanced Geosolutions Inc., Does, Chase M. Henri, Riaz Jiwani, Thang Van Nguyen.Jury Demanded., filed by Plaintiff Keller North America, Inc.[FILED IN STATE COURT 07/06/2022 SUBMITTED AS ATTACHMENT NO. 2 EXHIBIT A TO THE NOTICE OF REMOVL #1 ] (sh) |
| NON CONFORMED COPY OF FIRST AMENDED COMPLAINT against Defendants Advanced Geosolutions Inc., Does, Chase M. Henri, Riaz Jiwani, Thang Van Nguyen amending Complaint - (Discovery),, filed by Plaintiff Keller North America, Inc. [STATE COURT FILE DATE NOT INDICATED SUBMITTED AS ATTACHMENT NO. 11 EXHIBIT J TO THE NOTICE OF REMOVAL #1 ](sh) |
| NONCONFORMED COPY OF ANSWER to Amended Complaint, filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen.[STATE COURT FILE DATE NOT INDICATED SUBMITTED AS ATTACHMENT NO. 12 EXHIBIT K TO THE NOTICE OF REMOVAL #1 ](sh) |
| CONFORMED EFILED COPY OF ANSWER to Complaint - (Discovery), filed by Defendants Advanced Geosolutions Inc., Chase M. Henri, Riaz Jiwani, Thang Van Nguyen. [FILED IN STATE COURT 09/09/2022 SUBMITTED AS ATTACHMENT NO. 8 EXHIBIT G TO THE NOTICE OF REMOVAL #1 ](sh) |
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