Retractable Technologies, Inc. v. United States et al
| Retractable Technologies, Inc. |
| United States, U.S. Trade Rep. Katherine C. Tai, Acting Commissioner Troy A. Miller, United States Customs and Border Protection and Office of the United States Trade Representative |
| 1:2024cv00185 |
| September 26, 2024 |
| U.S. Court of International Trade |
| Claire R Kelly |
| Other |
| None |
Docket Report
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This docket was last retrieved on November 19, 2024. A more recent docket listing may be available from PACER.
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| Filing 71 Response to Motion to Dismiss (related document(s) #39 , #41 ). Replies due by 12/10/2024. Filed by Curtis H. Fuller of Romano Law PLLC on behalf of All Plaintiffs. (Attachments: #1 Proposed Order denying Defendant's Motion to Dismiss)(Fuller, Curtis) |
| Filing 70 Letter withdrawing Notice of Intent to Request Redaction. Filed by Curtis H. Fuller of Romano Law PLLC on behalf of All Plaintiffs. (Fuller, Curtis) |
Filing 69
Order entered on 11/8/2024, granting consent motion to revise preliminary injunction order and notice of stipulation. (see attached order). (related document(s) #62 , #67 , #68 ). (Taronji, Steve)
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| Filing 68 Consent Motion to revise preliminary injunction and notice of stipulation (related document(s) #62 , #67 ). Responses due by 11/29/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Bond, Emma) Modified on 11/8/2024 (Taronji, Steve) |
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Filing 67
Order entered on 11/4/2024, Public Slip Op. 24-120. (related document(s) #62 ) (Attachments: #1 Web Pages Cited, #2 Web Pages Cited, #3 Web Pages Cited). (Taronji, Steve)
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| Filing 66 Response to Court's Request/Order Regarding Redaction. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 65 Response to Court's Request/Order regarding redaction. Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Bond, Emma) |
| Filing 64 Notice of Intent to Redact . Filed by Curtis H. Fuller of Romano Law PLLC on behalf of All Plaintiffs. (related document(s) #52 ) (Fuller, Curtis). Modified on 10/30/2024 (Taronji, Steve). |
| Filing 63 Letter filed by Honorable Claire R. Kelly concerning bracketing for Slip-Op 24-120. Responses due by 11/1/2024. (Almonte, Giselle) |
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Filing 62
Order entered on 10/28/2024: Confidential Slip-Op 24-120 Denying in part and granting in part Plaintiff's motion for a temporary restraining order and preliminary injunction. ORDERED that Plaintiff's application for temporary restraining order and motion for preliminary injunction enjoining the collection of Section 301 Tariffs, see ECF No. #5 , are denied; and it is further ORDERED that Plaintiff's motion for preliminary injunction, see ECF No. #5 , enjoining liquidation of Plaintiff's entries during the pendency of this litigation is granted; and it is further ORDERED that Defendants, together with their delegates, officers, agents, and servants, including employees of U.S. Customs and Border Protection, are enjoined during the pendency of this litigation, including any appeals, from liquidating any entry for which they receive a request for suspension of liquidation pursuant to this order, unless, within 14 calendar days from the date Defendants receive a request for suspension of liquidation of such entry, Defendants, at their option, stipulate to refund any duties found to have been illegally collected for that specific entry and notify Plaintiff of such stipulation promptly in writing. (related document(s) #11 , #5 ) (Attachments: #1 Cited Web Page, #2 Cited Web Page, #3 Cited Web Page) (Almonte, Giselle)
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| Filing 61 Form 11 Notice of Appearance of Danielle Yurkew. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc..(Rao, Siddartha) |
| Filing 60 Public Brief after evidentiary hearing on motion for preliminary injunction (bracketing final) (related document(s) #59 , #53 ). Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Bond, Emma) |
| Filing 59 Confidential Brief after evidentiary hearing on motion for preliminary injunction (bracketing final) (related document(s) #53 ). Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Bond, Emma) |
| Filing 58 Public Brief after evidentiary hearing on motion for preliminary injunction (related document(s) #54 ). Filed by Curtis H. Fuller of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Fuller, Curtis) Modified on 10/23/2024 (Taronji, Steve). |
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Filing 57
Order entered on 10/23/2024, granting consent Motion for leave to file out of time. ORDERED that the Plaintiff's post-hearing brief, see ECF No. #54 , is deemed filed as of the date of this Order. (Related Doc #5 , #22 , #28 , #29 , #32 , 36 , #37 , #46 , 47 , #50 , #51 , #54 , #55 ). (Taronji, Steve)
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| Filing 56 Form 11 Notice of Appearance . Filed by Curtis H. Fuller of Romano Law PLLC on behalf of Retractable Technologies, Inc..(Fuller, Curtis) |
| Filing 55 Consent Motion for leave to file out of time (related document(s) #54 ). Responses due by 11/13/2024. Filed by Curtis H. Fuller of Romano Law PLLC on behalf of All Plaintiffs. (Attachments: #1 Declaration Declaration of Siddartha Rao ISO Consent Motion, #2 Exhibit Plaintiff's Counsel Email to Defendants' Counsel Regarding Filing Out of Time)(Fuller, Curtis) |
| Filing 54 Confidential Brief after evidentiary hearing on motion for preliminary injunction (related document(s) 47 , #51 ). Filed by Lawrence M. Friedman of Barnes, Richardson & Colburn, LLP on behalf of Retractable Technologies, Inc.. (Friedman, Lawrence) |
| Filing 53 Confidential Brief after evidentiary hearing on motion for preliminary injunction (related document(s) 47 , #51 ). Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Attachments: #1 DX 22)(Bond, Emma) |
| Filing 52 Confidential Transcript of Evidentiary Hearing held on 10/17/2024 filed with court. Pursuant to Administrative Order 08-01 re: the redaction of personal data identifiers. Notice of Intent to Redact Deadline due 10/28/2024. Redaction Request due 11/12/2024. Redacted Transcript Deadline set for 11/21/2024. Release of Transcript Restriction set for 1/21/2025. (Taronji, Steve) |
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Filing 51
Order entered on 10/21/2024, granting consent Motion for extension of time. ORDERED that the parties shall file their post-hearing briefs no later than 5 p.m. on Tuesday, October 22, 2024. (Related Doc #50 ). (Taronji, Steve)
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| Filing 50 Consent Motion for extension of time until 10/22/2024 to file post-hearing briefs (related document(s) 47 ). Responses due by 11/12/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants.(Bond, Emma) |
| Filing 49 Confidential Exhibits DX 23 - Business Record Demonstratives (related document(s) #46 ). Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Bond, Emma) |
| Filing 48 Confidential Digital Audio File regarding Evidentiary Hearing Proceeding #46 held on 10/17/2024 before Judge Claire R. Kelly. AUDIO FILE SIZE (244.6 MB). (Taronji, Steve) |
| Filing 47 Minute Entry entered on 10/17/2024, As indicated at the close of the Evidentiary Hearing held on October 17, 2024, it is Ordered that the parties are to file briefs no later than Monday October 21, 2024, at 5 p.m., of no more than 10 pages, with their arguments regarding the evidence presented at the hearing; and it is further ordered that there will be no responses to the briefs. (related document(s) #46 ). (Taronji, Steve) |
| Filing 46 Confidential Evidentiary Hearing held on 10/17/2024 at 10:00AM in Courtroom 1. Appearance sheet attached. (Taronji, Steve) Modified on 10/18/2024 (Taronji, Steve). |
| Filing 45 Confidential Exhibits DX 21 - 30(b)(6) deposition transcript of Retractable Technologies, Inc., and deposition exhibits (related document(s) #39 , #41 ). Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Attachments: #1 Notice of Deposition, #2 DX 12 - Lervisit Decl., #3 DX 5 - 2023 financial statements, #4 DX 13 - Fort Decl., #5 DX 8 - 2024 Q2 Financial Statements, #6 Plaintiff demonstrative topics 1 and 2, #7 Plaintiff demonstrative topic 3, #8 Plaintiff demonstrative topic 4, #9 Plaintiff demonstrative topic 5, #10 Plaintiff demonstrative topic 7)(Bond, Emma) |
| Filing 44 Witness list deemed filed. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (related document(s) #28 , #38 , #42 , 43 ). (Taronji, Steve) Modified on 10/16/2024 (Taronji, Steve). |
| Filing 43 Minute Entry entered on 10/16/2024, Pursuant to the Court's Order granting Plaintiff's motion to Correct Errata to fix the naming of its exhibits, see ECF No. #38 , it is Ordered that Plaintiff's corrected version of the naming of its exhibits, see ECF No. 42-1, is deemed filed as of the date of this Order. (Related Doc #28 , #42 ). (Taronji, Steve) |
| Filing 42 Motion for errata to correct exhibit descriptions document number# 28 filed with the Court electronically on 10/09/2024 (related document(s) #28 ). Responses due by 11/5/2024. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Corrected Filing - Redline, #2 Corrected Filing)(Rao, Siddartha) |
| Filing 41 Public Motion to dismiss case and Opposition to Plaintiff's Motion for Preliminary Injunction. Response to Dispositive Motion due by 11/19/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31)(Bond, Emma) |
| Filing 40 Response to Court's Request/Order for Mode and Order of Examining Witnesses. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 39 Confidential Motion to dismiss case and Opposition to Plaintiff's Motion for Preliminary Injunction. Deemed Filed. Response to Dispositive Motion due by 11/19/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of All Defendants. (Related Doc #5 , #33 , #38 ). (Taronji, Steve) |
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Filing 38
Order entered on 10/15/2024, granting Motion for errata. ORDERED that Defendant's corrected version of the confidential motion to dismiss and opposition to Plaintiff's Motion for preliminary injunction, see ECF No. 35-2, is deemed filed as of the date of this Order; and it is further ORDERED that the Defendant file a public version of the corrected motion to dismiss and opposition to Plaintiff's Motion for preliminary injunction; and it is further ORDERED that Plaintiff's motion to Correct Errata to fix the naming of its exhibits is granted; and it is further ORDERED that pursuant to the parties' agreement, Assistant Center Director Amstutz; Retractable Technologies, Inc.'s founder and CEO Thomas J. Shaw; Retractable Technologies, Inc.'s Vice President, Chief Financial Officer, and member of the Board of Directors, John W. Fort III; and Retractable Technologies, Inc.'s General Counsel, Michele Larios shall be allowed to testify remotely; and it is further ORDERED that for the Thursday Oct. 17 evidentiary hearing all witnesses will be excluded from the courtroom while other witnesses are testifying so that they cannot hear other witnesses' testimony, except that Plaintiff may designate an officer or employee as the party's representative; and it is further ORDERED that the courtroom will be closed to the public due to the confidential nature of the business proprietary information to be discussed. (Related Doc #35 , #37 ). (Taronji, Steve) Modified on 10/17/2024 (Taronji, Steve).
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| Filing 37 Telephone Conference via AT&T held on 10/15/2024 at 11:00 AM in Offsite. Appearance sheet attached. (Taronji, Steve) |
| Filing 36 Telephone Conference set for 10/15/2024 11:00 AM. (Taronji, Steve) |
| Filing 35 Confidential Motion for errata to correct Motion to Dismiss and Opposition to Motion for Preliminary Injunction document number# 33 filed with the Court electronically on 10/11/2024 (related document(s) #33 ). Responses due by 11/4/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Attachments: #1 Corrected Filing - Redline, #2 Corrected Filing)(Bond, Emma) |
| Filing 34 Confidential Affidavit/declarations of Diane Amstutz. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Bond, Emma) |
| Filing 33 [***NOTE: THE MOTION TO DISMISS HAS BEEN SUPERSEDED BY DOC #39 ***] Confidential Motion to dismiss case and opposition to motion for preliminary injunction. Response to Dispositive Motion due by 11/15/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31)(Bond, Emma) Modified on 10/15/2024 (Taronji, Steve). |
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Filing 32
Order entered on 10/11/2024, ORDERED that an evidentiary hearing will be held on Thursday, October 17, 2024, at 10:00 a.m., in person, in Courtroom 1 of the United States Court of International Trade, One Federal Plaza, New York, NY; and it is further ORDERED that pursuant to the parties' agreement, Assistant Center Director Amstutz shall be allowed to testify remotely; and it is further ORDERED that the parties may agree to the remote testimony of any witnesses and inform the Court in writing no later than 10:00 a.m. on Tuesday, October 15, 2024, so that technological arrangements to allow such testimony can be made; and it is further ORDERED that if any party wishes to exclude any witness from the courtroom pursuant to Federal Rule of Evidence 615, it must inform the Court in writing no later than 10:00 a.m. on Tuesday October 15, 2024. (related document(s) #22 , #27 ). (Taronji, Steve)
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| Filing 31 Confidential Exhibits 22 (related document(s) #29 ). Filed by Lawrence M. Friedman of Barnes, Richardson & Colburn, LLP on behalf of Retractable Technologies, Inc.. (Friedman, Lawrence) Modified on 10/11/2024 (Taronji, Steve). |
| Filing 30 Confidential Exhibits 15 (related document(s) #29 ). Filed by Lawrence M. Friedman of Barnes, Richardson & Colburn, LLP on behalf of Retractable Technologies, Inc.. (Friedman, Lawrence) |
| Filing 29 Exhibits (related document(s) #22 ). Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Exhibit Exhibit 1 - Comment from Thomas Shaw (USTR-2018-0005-2024), #2 Exhibit Exhibit 2 - Initiation of Four-Year Review Process China's Acts Policies and Practices Related to Technology Transfer Intellectual Property and Innovation, #3 Exhibit Exhibit 3 - October 17, 2022 USTR Request for Comments, #4 Exhibit Exhibit 4 - March 7, 2024 USTR Request for Comments, #5 Exhibit Exhibit 5 - BD Comments USTR-2024-0002-0124 (Supply Chain), #6 Exhibit Exhibit 6 - Transcript - USTR Promoting Supply Chain Resilience - DC Hearing Day 1 (1), #7 Exhibit Exhibit 7 - Four-Year Review of Actions Taken in The Section 301 Investigation Chinas Acts Policies And Practices Related To Technology Transfer Intellectual Property And Innovation, #8 Exhibit Exhibit 8 - Memorandum, #9 Exhibit Exhibit 9 - USTR May 28, 2024 Request for Comment - 2024-0007 (Tariffs), #10 Exhibit Exhibit 10 - RTI Comments USTR-2024-0002-0293 (Supply Chain), #11 Exhibit Exhibit 11 - BD Comments USTR-2024-0007-00108103 (Tariffs), #12 Exhibit Exhibit 12 - RTI Comments June 28, 2024 - USTR-2024-0007-00108483 (Tariffs), #13 Exhibit Exhibit 13 - July 31, 2024 Comments on Proposed Modifications to the Actions US Senators, #14 Exhibit Exhibit 14 - September 18, 2024 Notice of Modification Chinas Acts Policies and Practices Related to Technology Transfer Intellectual Property and Innovation, #15 Exhibit Exhibit 15 - REDACTED Tariff Impact, #16 Exhibit Exhibit 16 - 2019-2023 Financials, #17 Exhibit Exhibit 17 - 2024 Financials, #18 Exhibit Exhibit 18 - Medline Comments, #19 Exhibit Exhibit 19 - AHCA_NCAL Comments, #20 Exhibit Exhibit 20 - Flyers, #21 Exhibit Exhibit 21 - DOJ Comments, #22 Exhibit Exhibit 22 - REDACTED Re - Small Business and the Tariff Process)(Rao, Siddartha) |
| Filing 28 [***NOTE: THIS DOCUMENT HAS BEEN SUPERSEDED BY DOC #44 ***] Witness list . Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) Modified on 10/16/2024 (Taronji, Steve). |
| Filing 27 Motion to Permit Remote Testimony, with accompanying Witness List and Exhibit List (related document(s) #22 ). Responses due by 10/30/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Attachments: #1 Defendants' Exhibit List, #2 DX 1 - Financial Statements (2019), #3 DX 2 - Financial Statements (2020), #4 DX 3 - Financial Statements (2021), #5 DX 4 - Financial Statements (2022), #6 DX 5 - Financial Statements (2023), #7 DX 6 - Financial Statements (2024 Quarter 1), #8 DX 7 - Financial Statements (2024 Quarter 2), #9 DX 8 - Financial Statements (2024 Quarter 3), #10 DX 9 - Contract W911SR-20-3-0004 (July 1, 2020), #11 DX 10 - Contract W911SR-20-3-0004W911- Modification P00002 (July 1, 2020), #12 DX 11 - Shaw Decl., #13 DX 12 - Lervisit Decl., #14 DX 13 - Fort Decl., #15 DX 14 - Press Release, Medical Countermeasures, #16 DX 15 - DOD & HHS Press Release Title III Agreement, #17 DX 16 - Retractable Comment (June 28, 2024), #18 DX 17 - Retractable Comment, Attachment (June 28, 2024), #19 DX 18 - Retractable Comment - Comments on USTR2024-0002 (June 4, 2024)) (Bond, Emma) Modified on 10/9/2024 (Taronji, Steve) |
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Filing 26
Order entered on 10/9/2024, ORDERED that Plaintiff's motion to quash the pre-hearing deposition subpoena is DENIED; and it is further ORDERED that if the Plaintiff wishes to reschedule the evidentiary hearing to allow more time to prepare for the deposition, it will inform the Court no later than 3 p.m. tomorrow, October 10, 2024, either by motion or by contacting the case manager Mr. Taronji of its intent to move to reschedule. (Related Doc #24 ). (Taronji, Steve) Modified on 10/9/2024 (Taronji, Steve).
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Filing 25
Order entered on 10/9/2024, granting consent Motion for protective order. (Related Doc #23 ). (Taronji, Steve)
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| Filing 24 Motion to quash 30(b)(6) Deposition Subpoena. Responses due by 10/29/2024. Filed by Lawrence M. Friedman of Barnes, Richardson & Colburn, LLP, Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Proposed Order Granting Motion to Quash, #2 Declaration of Siddartha Rao in Support of Motion, #3 Exhibit A - Email Correspondences Concerning Notice of Deposition, #4 Exhibit B - Notice of Deposition, #5 Exhibit C - Email Correspondences Concerning Objection, #6 Exhibit D - 30(b)(6) Subpoena)(Rao, Siddartha) |
| Filing 23 Consent Motion for protective order . Responses due by 10/29/2024. Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Office of the United States Trade Representative, Katherine C. Tai, United States, United States Customs and Border Protection. (Attachments: #1 Proposed Protective Order)(Bond, Emma) |
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Filing 22
Order entered on 10/1/2024, ORDERED that the United States et al. ("Defendant") file its response to Plaintiff's motion no later than 5 p.m. on Friday, October 11, 2024; and it is further ORDERED that an evidentiary hearing will be held on Wednesday, October 16, 2024, at 9 a.m., in person, in Courtroom 1 of the United States Court of International Trade, One Federal Plaza, New York, NY; and it is further ORDERED that the parties submit a list of witnesses and the subject of their testimony as well as any exhibits the parties may use no later than 5 p.m. on Wednesday, October 9, 2024; and it is further ORDERED that the Defendant be prepared to discuss whether the government would agree to suspension of liquidation for the relevant entries. (related document(s) #5 , #16 ). (Taronji, Steve)
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Filing 21
Order entered on 9/30/2024, assigning action to Judge Claire R. Kelly. (Taronji, Steve)
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| Filing 20 Affidavit/declarations of John W. Fort III. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 19 Affidavit/declarations of Woot Lervisit. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 18 Affidavit/declarations of Thomas Shaw. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Exhibit A - Comment from Thomas Shaw (USTR-2018-0005-2024))(Rao, Siddartha) |
| Filing 17 Minute Entry entered on 9/27/2024, Defendant's responses to the TRO and Preliminary Injunction should be filed no later than 5 pm on Friday, October 11, 2024. Court will hold an Evidentiary Hearing on Tuesday, October 15, 2024. Time to be determined at a later date. (related document(s) #5 , #16 ). (Taronji, Steve) |
| Filing 16 Telephone Conference via AT&T held on 9/27/2024 at 1:30PM in Offsite. Appearance sheet attached. (Taronji, Steve) |
| Filing 15 Telephone Conference. Hearing set for 9/27/2024 at 01:30 PM. (Almonte, Giselle) |
| Filing 14 Form 11 Notice of Appearance . Filed by Emma E. Bond of U.S. Department of Justice on behalf of Troy A. Miller, Katherine C. Tai, United States, United States Customs and Border Protection, United States Trade Representative.(Bond, Emma) |
| Filing 13 Form 11 Notice of Appearance Lawrence M. Friedman. Filed by Lawrence M. Friedman of Barnes, Richardson & Colburn, LLP on behalf of Retractable Technologies, Inc..(Friedman, Lawrence) |
| Filing 12 Amended Proposed Order Granting Temporary Restraining Order. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 11 Proposed Order Granting Preliminary Injunction. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 10 [***NOTE: THIS DOCUMENT HAS BEEN SUPERSEDED BY DOC #12 ***] Proposed Order Granting Temporary Restraining Order. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) Modified on 9/30/2024 (Almonte, Giselle). |
| Filing 9 Affidavit/declarations of Siddartha Rao. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Exhibit B - Initiation of Four-Year Review Process China's Acts Policies and Practices Related to Technology Transfer Intellectual Property and Innovation, #2 Exhibit B-1 - USTR Request for Comments, #3 Exhibit B-2 - USTR Request USTR-2024-0002, #4 Exhibit C - BD Comments USTR-2024-0002-0124 (Supply Chain), #5 Exhibit D - Transcript - USTR Promoting Supply Chain Resilience - DC Hearing Day 1, #6 Exhibit E - Four-Year Review of Actions Taken in The Section 301 Investigation Chinas Acts Policies And Practices Related To Technology Transfer Intellectual Property And Innovation, #7 Exhibit F - Memorandum, #8 Exhibit G - Request for Comment USTR-2024-0007 (Tariffs), #9 Exhibit H - RTI Comments USTR-2024-0002-0293 (Supply Chain), #10 Exhibit I - BD Comments USTR-2024-0007-00108103 (Tariffs), #11 Exhibit J - RTI Comments USTR-2024-0007-00108483 (Tariffs).pdf, #12 Exhibit K - Comments on Proposed Modifications to the Actions US Senators, #13 Exhibit L - Comments on Proposed Modifications to the Actions Georgia Senators, #14 Exhibit M - Notice of Modification Chinas Acts Policies and Practices Related to Technology Transfer Intellectual Property and Innovation, #15 Exhibit N - Barry Lynn Book First Edition, #16 Exhibit O - Barry Lynn Book Second Edition)(Rao, Siddartha) |
| Filing 8 [***NOTE: THIS DOCUMENT HAS BEEN SUPERSEDED BY DOC #20 ***] Affidavit/declarations of John W. Fort III. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) Modified on 9/30/2024 (Almonte, Giselle). |
| Filing 7 [***NOTE: THIS DOCUMENT HAS BEEN SUPERSEDED BY DOC #19 ***] Affidavit/declarations of Woot Lervisit. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) Modified on 9/30/2024 (Almonte, Giselle). |
| Filing 6 [***NOTE: THIS DOCUMENT HAS BEEN SUPERSEDED BY DOC #18 ***] Affidavit/declarations of Thomas Shaw. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Attachments: #1 Exhibit A - Comment from Thomas Shaw (USTR-2018-0005-2024))(Rao, Siddartha) Modified on 9/30/2024 (Almonte, Giselle). |
| Filing 5 Application/Motion for temporary restraining order and Application/Motion for preliminary injunction. Responses due by 10/17/2024. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 4 Complaint against All Defendants. Answer due by 11/25/2024. Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc..(Rao, Siddartha) |
| Filing 3 Form 13 Corporate Disclosure Statement . Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 2 Form 5 Information Statement . Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
| Filing 1 Summons . Filed by Siddartha Rao of Romano Law PLLC on behalf of Retractable Technologies, Inc.. (Rao, Siddartha) |
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