Woodmansee v. Invictus Global Management, LLC et al
| Joseph A. Woodmansee |
| Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Cindy Chen Delano and Amit Patel |
| 1:2025cv00978 |
| August 5, 2025 |
| U.S. District Court for the District of Delaware |
| Richard G Andrews |
| Labor: E.R.I.S.A. |
| 29 U.S.C. § 1001 E.R.I.S.A.: Employee Retirement |
| None |
Docket Report
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This docket was last retrieved on December 15, 2025. A more recent docket listing may be available from PACER.
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| Filing 42 REPLY BRIEF re #30 MOTION To Stay, or the in the Alternative, Dismiss filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Cohen, Susan) |
| Filing 41 REQUEST for Oral Argument by Cindy Chen Delano re #29 MOTION to Stay, or in the Alternative, Dismiss, #30 MOTION To Stay, or the in the Alternative, Dismiss. (DiGiovanni, Francis) |
| Filing 40 DECLARATION of Alec P. Harris re #39 Reply Brief by Cindy Chen Delano. (Attachments: #1 Exhibit Y-Z)(DiGiovanni, Francis) |
| Filing 39 REPLY BRIEF re #29 MOTION to Stay, or in the Alternative, Dismiss filed by Cindy Chen Delano. (DiGiovanni, Francis) |
| Filing 38 ANSWERING BRIEF in Opposition re #29 MOTION to Stay, or in the Alternative, Dismiss, and #30 MOTION To Stay, or the in the Alternative, Dismiss, filed by Joseph A. Woodmansee. Reply Brief due date per Local Rules is 12/8/2025. (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)(Applebaum, Aaron) Modified on 12/2/2025 (nms). |
| Filing 37 Joint Stipulation and Proposed Order for Extension of Time Regarding Briefing, by Cindy Chen Delano. (DiGiovanni, Francis) Modified on 11/17/2025 (nms). |
SO ORDERED, re #37 Joint Stipulation and Proposed Order for Extension of Time Regarding Briefing (*Reset Briefing Schedule: re #29 MOTION to Stay, or in the Alternative, Dismiss and #30 MOTION To Stay, or the in the Alternative, Dismiss. Answering Brief due 12/1/2025, Reply Brief due 12/15/2025). Ordered by Judge Richard G. Andrews on 11/17/2025. (nms)
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Filing 36
SO ORDERED Granting #35 Joint Stipulation and Proposed Order Regarding Opposition to Motions to Dismiss. Signed by Judge Richard G. Andrews on 11/12/2025. (nms)
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| Filing 35 Joint Stipulation and Proposed Order Regarding Motions to Dismiss, by Joseph A. Woodmansee. (Applebaum, Aaron) Modified on 11/12/2025 (nms). |
| LOCAL RULE 7.1.1 NOTICE: In accordance with Local Rule 7.1.1, except for civil cases involving pro se parties or motions brought by nonparties, every nondispositive motion shall be accompanied by an averment of counsel for the moving party that a reasonable effort has been made to reach agreement with the opposing party on the matters set forth in the motion. Unless otherwise ordered, failure to so aver may result in dismissal of the motion. The records of this case do not reflect such an averment by counsel for DI #30 as it applies to the request for a stay. Please file the averment using the event code STATEMENT, found under OTHER DOCUMENTS. (nms) |
| CORRECTING ENTRY: A pdf of the 7.1.1 Statement has been added to D.I. #30 per counsel's request. The 7.1.1 Statement was inadvertently omitted at the initial time of filing. The NEF for D.I. #30 has been regenerated. (nms) |
| Filing 34 DECLARATION of Lars C. Golumbic re #30 MOTION To Stay, or the in the Alternative, Dismiss, by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Attachments: #1 Exhibit 1)(Cohen, Susan) Modified on 11/6/2025 (nms). |
| Filing 33 OPENING BRIEF in Support re #30 MOTION To Stay or the in the Alternative Dismiss filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel.Answering Brief/Response due date per Local Rules is 11/19/2025. (Cohen, Susan) |
| Filing 32 DECLARATION of Alec P. Harris re #31 Opening Brief in Support, by Cindy Chen Delano. (Attachments: #1 Exhibits A-I, #2 Exhibits J-P, #3 Exhibits Q-X)(DiGiovanni, Francis) Modified on 11/6/2025 (nms). |
| Filing 31 OPENING BRIEF in Support re #29 MOTION to Stay, or in the Alternative, Dismiss, filed by Cindy Chen Delano. Answering Brief/Response due date per Local Rules is 11/19/2025. (DiGiovanni, Francis) Modified on 11/6/2025 (nms). |
| Filing 30 MOTION To Stay, or the in the Alternative, Dismiss - filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Attachments: #1 Proposed Order, #2 Proposed Order)(Cohen, Susan) Modified on 11/6/2025 (nms). (Additional attachment(s) added on 11/6/2025: #3 7.1.1 Statement) (nms). |
| Filing 29 MOTION to Stay, or in the Alternative, Dismiss - filed by Cindy Chen Delano. (Attachments: #1 7.1.1 Certification, #2 Proposed Order, #3 Proposed Order)(DiGiovanni, Francis) Modified on 11/6/2025 (nms). |
| Pro Hac Vice Attorney Richard Pearl for Cindy Chen Delano added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (slk) |
| Pro Hac Vice Attorney Alec P. Harris for Cindy Chen Delano added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (jmn) |
| Pro Hac Vice Attorney Josh Peterson for Cindy Chen Delano added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (jmn) |
| Pro Hac Vice Attorney John Ursu for Cindy Chen Delano added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (jmn) |
| Filing 28 Pro Hac Vice Fee - Credit Card Payment received for Jonathan G. Rose. ( re #27 MOTION for Pro Hac Vice Appearance of Attorney Jonathan G. Rose )( Payment of $ 50, receipt number ADEDC-4820175).(Applebaum, Aaron) |
| Filing 27 MOTION for Pro Hac Vice Appearance of Attorney Jonathan G. Rose - filed by Joseph A. Woodmansee. (Attachments: #1 Certificate of Service)(Applebaum, Aaron) |
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SO ORDERED, re #27 MOTION for Pro Hac Vice Appearance of Attorney Jonathan G. Rose filed by Joseph A. Woodmansee. Signed by Judge Richard G. Andrews on 10/23/2025. (aas)
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| Filing 26 Pro Hac Vice Fee - Credit Card Payment received for John W. Ursu, Josh Peterson, Alec P. Harris, and Richard Pearl. ( re #25 MOTION for Pro Hac Vice Appearance of Attorney John W. Ursu, Josh Peterson, Alec P. Harris, and Richard Pearl )( Payment of $ 200, receipt number ADEDC-4819267).(DiGiovanni, Francis) |
| Filing 25 MOTION for Pro Hac Vice Appearance of Attorney John W. Ursu, Josh Peterson, Alec P. Harris, and Richard Pearl - filed by Cindy Chen Delano. (DiGiovanni, Francis) |
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SO ORDERED, re #25 MOTION for Pro Hac Vice Appearance of Attorney John W. Ursu, Josh Peterson, Alec P. Harris, and Richard Pearl filed by Cindy Chen Delano. Signed by Judge Richard G. Andrews on 10/22/2025. (aas)
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| Pro Hac Vice Attorney Lars C. Golumbic, Richard A. Smith, Ross P. McSweeney for Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, and Amit Patel added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (cdd) |
| Filing 24 Pro Hac Vice Fee - Credit Card Payment received for Ross P. McSweeney, Richard A. Smith, Jr., and Lars C. Golumbic. ( re #21 MOTION for Pro Hac Vice Appearance of Attorney Ross P. McSweeney, #23 MOTION for Pro Hac Vice Appearance of Attorney Lars C. Golumbic, #22 MOTION for Pro Hac Vice Appearance of Attorney Richard A. Smith, Jr. )( Payment of $ 150, receipt number ADEDC-4808047).(Koch, Rudolf) |
| Filing 23 MOTION for Pro Hac Vice Appearance of Attorney Lars C. Golumbic - filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Koch, Rudolf) |
| Filing 22 MOTION for Pro Hac Vice Appearance of Attorney Richard A. Smith, Jr. - filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Koch, Rudolf) |
| Filing 21 MOTION for Pro Hac Vice Appearance of Attorney Ross P. McSweeney - filed by Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel. (Koch, Rudolf) |
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SO ORDERED, re #21 MOTION for Pro Hac Vice Appearance of Attorney Ross P. McSweeney filed by Invictus Special Situations I GP, LLC, Invictus Global Management, LLC, Amit Patel, #23 MOTION for Pro Hac Vice Appearance of Attorney Lars C. Golumbic filed by Invictus Special Situations I GP, LLC, Invictus Global Management, LLC, Amit Patel, #22 MOTION for Pro Hac Vice Appearance of Attorney Richard A. Smith, Jr. filed by Invictus Special Situations I GP, LLC, Invictus Global Management, LLC, Amit Patel. Signed by Judge Richard G. Andrews on 10/7/2025. (aas)
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Filing 20
ORDER: The Motion to Extend Time to Respond to Complaint (D.I. #9 ) is GRANTED (*Reset Answer Deadlines: Cindy Chen Delano answer due 11/5/2025; Invictus Global Management, LLC answer due 11/5/2025; Invictus Special Situations I GP, LLC answer due 11/5/2025; Amit Patel answer due 11/5/2025). Signed by Judge Richard G. Andrews on 10/3/2025. (nms)
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| Filing 19 REPLY BRIEF re #9 MOTION to Extend Time to Respond to Complaint, filed by Cindy Chen Delano. (Attachments: #1 Exhibits A-C)(DiGiovanni, Francis) Modified on 10/3/2025 (nms). |
| Filing 18 OBJECTIONS to #9 Motion to Extend Time to Respond to Complaint, by Joseph A. Woodmansee. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Applebaum, Aaron) Modified on 9/30/2025 (nms). |
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Filing 17
ORDER: The Unopposed Motion for Expedited Briefing and Consideration (D.I. #10 ) is GRANTED. Opposition to the Motion to Extend Time (D.I. #9 ) is due by 9/30/2025, and the reply in further support is due by 10/2/2025. Signed by Judge Richard G. Andrews on 9/26/2025. (nms)
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| Filing 16 NOTICE of Appearance by Nicole M. Henry on behalf of Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel (Henry, Nicole) |
| Filing 15 NOTICE of Appearance by Robert Lewis Burns on behalf of Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel (Burns, Robert) |
| Filing 14 NOTICE of Appearance by Susan H. Cohen on behalf of Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel (Cohen, Susan) |
| Filing 13 Disclosure Statement pursuant to Rule 7.1: identifying Corporate Parent VAASS LLC for Invictus Special Situations I GP, LLC filed by Invictus Special Situations I GP, LLC. (Koch, Rudolf) |
| Filing 12 Disclosure Statement pursuant to Rule 7.1: identifying Corporate Parent VAASS LLC for Invictus Global Management, LLC filed by Invictus Global Management, LLC. (Koch, Rudolf) |
| Filing 11 NOTICE of Appearance by Rudolf Koch on behalf of Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel (Koch, Rudolf) |
| Filing 10 Unopposed Motion for Expedited Briefing and Consideration - filed by Cindy Chen Delano. (Attachments: #1 7.1.1 Certification, #2 Proposed Order)(DiGiovanni, Francis) Modified on 9/24/2025 (nms). |
| Filing 9 MOTION to Extend Time to Respond to Complaint - filed by Cindy Chen Delano. (Attachments: #1 7.1.1 Certification, #2 Proposed Order)(DiGiovanni, Francis) Modified on 9/24/2025 (nms). |
| Case Assigned to Judge Richard G. Andrews. Please include the initials of the Judge (RGA) after the case number on all documents filed. (alb) |
| Filing 8 WAIVER OF SERVICE returned executed by Joseph A. Woodmansee: For Invictus Special Situations I GP, LLC waiver sent on 8/7/2025, answer due 10/6/2025. (Applebaum, Aaron) |
| Filing 7 WAIVER OF SERVICE returned executed by Joseph A. Woodmansee: For Invictus Global Management, LLC waiver sent on 8/7/2025, answer due 10/6/2025. (Applebaum, Aaron) |
| Filing 6 WAIVER OF SERVICE returned executed by Joseph A. Woodmansee: For Amit Patel waiver sent on 8/7/2025, answer due 10/6/2025. (Applebaum, Aaron) |
| Filing 5 WAIVER OF SERVICE returned executed by Joseph A. Woodmansee: For Cindy Chen Delano waiver sent on 8/8/2025, answer due 10/7/2025. (Applebaum, Aaron) |
| Filing 4 Summons Issued as to Cindy Chen Delano on 8/5/2025; Invictus Global Management, LLC on 8/5/2025; Invictus Special Situations I GP, LLC on 8/5/2025; Amit Patel on 8/5/2025. (Attachments: #1 Summons Issued, #2 Summons Issued, #3 Summons Issued)(mrr) |
| Filing 3 Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed filed by Joseph A. Woodmansee. (mrr) |
| Filing 2 Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (mrr) |
| Filing 1 COMPLAINT against Cindy Chen Delano, Invictus Global Management, LLC, Invictus Special Situations I GP, LLC, Amit Patel (Filing fee $ 405, receipt number ADEDC-4751804) - filed by Joseph A. Woodmansee. (Attachments: #1 Civil Cover Sheet)(mrr) |
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