PLEZNAC v. EQUITY RESIDENTIAL MANAGEMENT, L.L.C.
| SARAH S PLEZNAC and SARAH S. PLEZNAC |
| EQUITY RESIDENTIAL MANAGEMENT, L.L.C. |
| 1:2017cv02732 |
| December 21, 2017 |
| US District Court for the District of Columbia |
| Washington, DC Office |
| 11001 |
| Christopher R Cooper |
| Other Fraud |
| 28 U.S.C. § 1441 Petition for Removal |
| Plaintiff |
Docket Report
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| Filing 47 STIPULATION of Dismissal by SARAH S. PLEZNAC. (Weiner, Courtney) |
MINUTE ORDER: In light of the parties' #47 stipulation of dismissal, the case is hereby DISMISSED with prejudice, with each party to bear its own fees and costs. Signed by Judge Christopher R. Cooper on 10/21/19. (lccrc1)
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| Set/Reset Deadlines: Summary Judgment motions due by 11/21/2019. Response to Motion for Summary Judgment due by 12/23/2019. Reply to Motion for Summary Judgment due by 1/13/2020. Replies due by 2/3/2020. (lsj) |
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MINUTE ORDER: In light of #46 Plaintiff's withdrawal of the class allegations, the Court hereby ORDERS that the parties shall file dispositive motions in accordance with the following schedule: Defendant's motion for summary judgment shall be due November 21, 2019; Plaintiff's opposition (and any cross motion for summary judgment) shall be due December 23, 2019; Defendant's reply (and opposition to the cross-motion, if necessary) shall be due January 13, 2020; Plaintiff's reply, if necessary, shall be due February 3, 2020. The parties are directed to Local Civil Rule 7(h) regarding the requirements for motions for summary judgment and oppositions. Parties shall provide bound, tabbed courtesy copies of any document constituting, supporting, or opposing a dispositive motion if said document, together with its exhibits, attachments, declarations, and affidavits, is over one hundred (100) pages. Signed by Judge Christopher R. Cooper on 10/7/19. (lccrc1)
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| Filing 46 RESPONSE TO ORDER TO SHOW CAUSE by SARAH S. PLEZNAC re Order, . (Weiner, Courtney) |
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MINUTE ORDER: Having not received Plaintiff's motion for class certification by the extended due date of September 11, 2019, the Court hereby directs Plaintiff to show cause in writing on or before September 30, 2019 why class certification should not be denied. So Ordered. Signed by Judge Christopher R. Cooper on 9/24/19. (lccrc1)
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| Set/Reset Deadlines: Motions due by 9/11/2019. Responses due by 10/11/2019. Replies due by 10/25/2019. (lsj) |
| Filing 45 NOTICE OF SUBSTITUTION OF COUNSEL by Courtney L. Weiner on behalf of SARAH S. PLEZNAC Substituting for attorney Jamil Zouaoui (Weiner, Courtney) (Main Document 45 replaced on 8/13/2019) (ztd). Modified replaced fillable document on 8/13/2019 (ztd). |
| Filing 44 Consent MOTION for Extension of Time to File Motion for Class Certification by SARAH S. PLEZNAC (Attachments: #1 Text of Proposed Order)(Weiner, Courtney) |
| Filing 43 NOTICE of Appearance by Courtney L. Weiner on behalf of SARAH S. PLEZNAC (Weiner, Courtney) |
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MINUTE ORDER granting #44 Plaintiff's Consent Motion for Extension. Class certification briefing shall now proceed as follows: Plaintiff shall file her motion for class certification by September 11, 2019; Defendant shall file its opposition by October 11, 2019; Plaintiff shall file her reply by October 25, 2019. Signed by Judge Christopher R. Cooper on 8/9/2019. (lccrc1)
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MINUTE ORDER: Class certification briefing shall proceed as follows: Plaintiff shall file her motion for class certification by August 12, 2019; Defendant shall file its opposition by September 11, 2019; Plaintiff shall file her reply by September 25, 2019. Signed by Judge Christopher R. Cooper on 7/12/2019. (lccrc1)
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| Minute Entry for Post-Discovery Hearing held before Judge Christopher R. Cooper on 7/12/2019. Forthcoming Order. (Court Reporter: Scott Wallace) (lsj) |
| Set/Reset Deadlines: Motions due by 8/12/2019. Responses due by 9/11/2019. Replies due by 9/25/2019. (lsj) |
| Set/Reset Hearings: Post-Discovery Hearing set for 7/12/2019 at 11:00 AM in Courtroom 27A before Judge Christopher R. Cooper. (lsj) |
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MINUTE ORDER granting in part and denying in part #38 Plaintiff's Motion to Compel the Deposition of Robert Brandon and for Associated Sanctions. Plaintiff shall be permitted to depose Mr. Brandon in his individual capacity on any relevant topics within his personal knowledge that were not previously noticed for his Rule 30(b)(6) deposition. See Fed. R. Civ. P. 30(b)(6) (explaining that a Rule 30(b)(6) deposition "does not preclude a deposition by any other procedure allowed by these rules"). The parties shall work together to schedule any further deposition within 30 days. Given that Mr. Brandon has already been deposed once, Plaintiff's counsel is advised to conduct any further deposition in an efficient manner. The Court declines to impose sanctions on either party. The parties shall appear for a post-discovery status conference in Courtroom 27A on Friday, July 12, 2019 at 11:00 AM. SO ORDERED. Signed by Judge Christopher R. Cooper on 6/6/2019. (lccrc1)
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| Filing 42 SEALED DOCUMENT filed by SARAH S. PLEZNAC re #40 Sealed Reply (This document is SEALED and only available to authorized persons.) (Attachments: #1 Exhibit Exhibit 1)(Zouaoui, Jamil) |
| Filing 41 ENTERED IN ERROR. . . . .SEALED DOCUMENT filed by SARAH S. PLEZNAC re #40 Sealed Reply (This document is SEALED and only available to authorized persons.)(Zouaoui, Jamil) Modified on 5/30/2019 (ztd). |
| NOTICE OF ERROR re #41 Sealed Document; emailed to jzouaoui@mizene.us, cc'd 2 associated attorneys -- The PDF file you docketed contained errors: 1. Incorrect header/caption/case number, 2. Please refile document, 3. All filings must comply with LCvR 5.1(d) Form of Documents. (ztd, ) |
| Filing 40 SEALED REPLY TO OPPOSITION filed by SARAH S. PLEZNAC re #38 MOTION to Compel (This document is SEALED and only available to authorized persons.) (Attachments: #1 Exhibit Exhibit 1)(Zouaoui, Jamil) |
| Filing 39 RESPONSE re #38 MOTION to Compel filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(Busen, Carey) |
| Filing 38 MOTION to Compel by SARAH S. PLEZNAC (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2, #3 Exhibit Exhibit 3, #4 Exhibit Exhibit 4, #5 Exhibit Exhibit 5, #6 Exhibit Exhibit 6, #7 Exhibit Exhibit 7, #8 Exhibit Exhibit 8, #9 Exhibit Exhibit 9, #10 Exhibit Exhibit 10, #11 Exhibit Exhibit 11, #12 Exhibit Exhibit 12, #13 Exhibit Exhibit 13, #14 Exhibit Exhibit 14, #15 Exhibit Exhibit 15, #16 Exhibit Exhibit 16, #17 Exhibit Exhibit 17, #18 Exhibit Exhibit 18, #19 Exhibit Exhibit 19, #20 Exhibit Exhibit 120, #21 Exhibit Exhibit 21, #22 Exhibit Exhibit 22, #23 Exhibit Exhibit 23)(Zouaoui, Jamil) Modified event and text on 5/20/2019 (ztd). |
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MINUTE ORDER: Plaintiff may file a motion to compel deposition testimony from the employee in question. Plaintiff shall file that motion by May 17, 2019; Defendant shall respond to that motion by May 24, 2019; Plaintiff shall file any reply by May 29, 2019. The Court will vacate the deadline for discovery (May 16, 2019) only with respect to this witness, and will vacate the summary judgment briefing schedule pending resolution of this issue. Signed by Judge Christopher R. Cooper on 5/10/2019. (lccrc1)
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| Set/Reset Deadlines: Motions due by 5/17/2019. Responses due by 5/24/2019 Replies due by 5/29/2019. (lsj) |
| Filing 37 TRANSCRIPT OF STATUS CONFERENCE before Judge Christopher R. Cooper held on April 3, 2019; Page Numbers: 1-18. Date of Issuance:April 12, 2019. Court Reporter/Transcriber Lisa A. Moreira, RDR, CRR, Telephone number (202) 354-3187, Transcripts may be ordered by submitting the #Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from th e court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 5/3/2019. Redacted Transcript Deadline set for 5/13/2019. Release of Transcript Restriction set for 7/11/2019.(Moreira, Lisa) |
| Set/Reset Deadlines: Discovery due by 5/16/2019. Summary Judgment motions due by 6/17/2019. Response to Motion for Summary Judgment due by 7/17/2019. Reply to Motion for Summary Judgment due by 8/9/2019. Replies due by 8/23/2019. (lsj) Modified on 4/10/2019 (lsj). |
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Filing 36
ORDER granting in part #34 Motion for Extension of Time to Complete Discovery; denying #34 Motion to Vacate. See full order for details.. Signed by Judge Christopher R. Cooper on 4/3/2019. (lccrc1)
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| Minute Entry for Post-Discovery Hearing held before Judge Christopher R. Cooper on 4/3/2019. Forthcoming Order. (Court Reporter: Lisa Moreira) (lsj) |
| Filing 35 Joint STATUS REPORT of the Parties Positions by SARAH S. PLEZNAC. (Zouaoui, Jamil) |
| Filing 34 MOTION for Extension of Time to Complete Discovery by SARAH S. PLEZNAC (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2, #3 Exhibit Exhibit 3, #4 Exhibit Exhibit 4, #5 Exhibit Exhibit 5, #6 Exhibit Exhibit 6, #7 Exhibit Exhibit 7, #8 Exhibit Exhibit 8)(Zouaoui, Jamil). Added MOTION to Vacate on 4/2/2019 (ztd). |
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MINUTE ORDER: The parties shall still appear tomorrow, April 3, 2019 at 10:00 AM in Courtroom 27A, and may be heard on the arguments made in #34 Plaintiff's Motion for Extension of Time to Complete Discovery and #35 the Parties' Joint Status Report. Signed by Judge Christopher R. Cooper on 4/2/2019. (lccrc1)
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| Set/Reset Hearings: Post-Discovery Hearing set for 4/3/2019 at 10:00 AM in Courtroom 27A before Judge Christopher R. Cooper. (lsj) |
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MINUTE ORDER: The parties' #33 Joint Statement of positions on their discovery disputes does not reflect a good-faith effort to narrow the issues necessary for the Court's resolution. The parties are therefore directed to meet and confer, and reconsider their positions in light of the following general direction from the Court. First, the specific requests cited as examples by defendant--document request numbers 5, 23, 45 and 59--appear clearly overbroad and/or unduly burdensome. Second, no discovery, merits or class, shall be permitted regarding conduct alleged in the claims that have been dismissed. Third, discovery requests targeted specifically to Claim 2 shall be limited to the actionable conduct alleged in that claim--i.e., that defendant violated the Fair Credit Reporting Act, 15 U.S.C. 1681s-2(b), by failing to investigate and correct disputed information provided to credit reporting agencies about the named plaintiff or other tenants of the defendant's D.C. rental properties. Fourth, discovery on Claim 6 shall be limited to the "malice and bad faith retaliation" allegations set forth in paragraphs 54-67 of plaintiff's complaint. Finally, no class discovery as to Count 6 may take place at this juncture. If, having completed the meet and confer process, defendant still has objections to plaintiff's requests, it shall serve its objections in writing within ten (10) days thereafter, in accord with Federal Rules of Civil Procedure 33 and 34. Plaintiff may then proceed by motion under Rule 37 should she so chose. SO ORDERED. Signed by Judge Christopher R. Cooper on 2/22/2019. (lccrc1)
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MINUTE ORDER: In light of the Court's closure due to inclement weather, the Telephone Conference set for 2/20/2019 is vacated. Signed by Judge Christopher R. Cooper on 2/20/19. (lsj)
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| Filing 33 STATUS REPORT With Joint Statement Ordered by Court about Parties Respective Positions about Discovery Dispute by SARAH S. PLEZNAC. (Zouaoui, Jamil) |
| Set/Reset Deadlines/Hearings: Joint Status Report due by 2/19/2019. Telephone Conference set for 2/20/2019 at 1:00 PM in Courtroom 27A before Judge Christopher R. Cooper. (lsj) |
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MINUTE ORDER: The Court will hold a telephonic discovery conference at 1:00 PM on February 20, 2019. The parties shall file by 5:00 PM on February 19, 2019 a joint statement of their respective positions on the dispute, not to exceed a total of five (5) pages. Signed by Judge Christopher R. Cooper on 2/15/2019. (lccrc1)
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Filing 32
PROTECTIVE ORDER setting forth procedures for handling confidential material; allowing designated material to be filed under seal. Signed by Judge Christopher R. Cooper on 1/31/2019. (lccrc1)
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| Filing 31 NOTICE of Proposed Order Stipulated Protective Order by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Busen, Carey) |
| Filing 30 TRANSCRIPT OF SCHEDULING CONFERENCE before Judge Christopher R. Cooper held on October 1, 2018; Page Numbers: 1-15. Date of Issuance:October 23, 2018. Court Reporter/Transcriber Lisa A. Moreira, RDR, CRR, Telephone number (202) 354-3187, Transcripts may be ordered by submitting the #Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 11/13/2018. Redacted Transcript Deadline set for 11/23/2018. Release of Transcript Restriction set for 1/21/2019.(Moreira, Lisa) |
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Filing 29
SCHEDULING ORDER: Upon consideration of the Parties' Joint Rule 16.3 Meet and Confer Statement, it is hereby ORDERED that discovery in this case shall proceed according to the following schedule: Initial Disclosures by December 3, 2018; Motion to Add or Amend Pleadings by December 3, 2018; Post-Rule 26(a) Discovery requests by January 2, 2019; Proponent's Rule 26(a)(2) Statements by January 30, 2019; Opponent's Rule 26(a)(2) Statements by March 1, 2019; Close of Discovery on April 1, 2019; Post-Discovery Status Conference on April 3, 2019 in Courtroom 27A at 10:00 AM (SEE FULL ORDER FOR DETAILS). Signed by Judge Christopher R. Cooper on 10/02/2018. (lccrc1)
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| Set/Reset Hearings: Post-Discovery Hearing set for 4/1/2019 at 10:00 AM in Courtroom 27A before Judge Christopher R. Cooper. (lsj) |
| Minute Entry for Initial Scheduling Conference held before Judge Christopher R. Cooper held on 10/1/2018. Forthcoming Scheduling Order. (Court Reporter: Lisa Moreira) (lsj) |
| Filing 28 MEET AND CONFER STATEMENT. (Zouaoui, Jamil) |
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Filing 27
ORDER FOR INITIAL SCHEDULING CONFERENCE. The parties are to appear on October 1, 2018 at 10:00 AM in Courtroom 27A. Signed by Judge Christopher R. Cooper on 08/29/2018. (lccrc1) Modified on 8/29/2018 (zlsj).
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| Set/Reset Hearings: Initial Scheduling Conference set for 10/1/2018 at 10:00 AM in Courtroom 27A before Judge Christopher R. Cooper. (lsj) |
| Filing 26 ANSWER to Complaint by EQUITY RESIDENTIAL MANAGEMENT, L.L.C..(Busen, Carey) |
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Filing 25
MEMORANDUM OPINION re #24 Order. Signed by Judge Christopher R. Cooper on 8/8/2018. (lccrc1)
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Filing 24
ORDER granting in part and denying in part #12 Defendant's Motion to Dismiss. Signed by Judge Christopher R. Cooper on 8/8/2018. (lccrc1)
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Filing 23
ORDER of USCA ORDERED that the petition be denied. USCA Case Number 18-8005. (zrdj)
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| Filing 22 REPLY to opposition to motion re #12 MOTION to Dismiss filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Busen, Carey) |
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MINUTE ORDER granting #21 Defendant's Motion for Extension of Time to File Reply in Support of Motion to Dismiss. Defendant's reply is due by June 13, 2018. The parties are reminded that, under this Court's local rules, documents must be in 12-point font and double spaced (with the exception of footnotes, which should be single spaced). See Local Civ. R. 5.1(d). Signed by Judge Christopher R. Cooper on 5/25/2018. (lccrc1)
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| Set/Reset Deadlines: Response to Dispositive Motions due by 6/13/2018. (lsj) |
| Filing 21 MOTION for Extension of Time to File Response/Reply Defendant's Motion for an Extension of Time to File Rely in Support of Motion to Dismiss by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Attachments: #1 Exhibit 1, #2 Text of Proposed Order)(Busen, Carey) |
| Filing 20 Memorandum in opposition to re #12 MOTION to Dismiss filed by SARAH S. PLEZNAC. (Attachments: #1 Exhibit)(Zouaoui, Jamil) |
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Filing 19
OPINION AND ORDER denying #10 Plaintiff's Motion to Remand. Signed by Judge Christopher R. Cooper on 5/8/2018. (lccrc1)
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MINUTE ORDER: With the Court having denied #10 Plaintiff's motion to remand, the stay of the briefing schedule associated with #12 Defendant's motion to dismiss is lifted. Plaintiff is ORDERED to file any response to Defendant's motion to dismiss by May 23, 2018. Signed by Judge Christopher R. Cooper on 5/8/2018. (lccrc1)
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MINUTE ORDER granting #4 Defendant's Motion to Admit Attorney Craig M. White Pro Hac Vice. Signed by Judge Christopher R. Cooper on 5/8/2018. (lccrc1)
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| Filing 18 SUPPLEMENTAL MEMORANDUM re: #10 MOTION to Remand to State Court Supplemental Brief by SARAH S. PLEZNAC (Attachments: #1 Exhibit Orders regarding Rent Concessions)(Zouaoui, Jamil) Modified to add linkage on 5/8/2018 (td). |
| Filing 17 Memorandum in opposition to re #10 MOTION to Remand to State Court Defendant's Supplemental Brief is Support of Opposition to Motion to Remand filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Busen, Carey) |
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Filing 16
ORDER DIRECTING SUPPLEMENTAL BRIEFING re #10 Plaintiff's Motion for Remand. Defendant's supplemental brief and any supporting evidence is due by April 30, 2018. Plaintiff's response and any supporting evidence is due by May 7, 2018. Signed by Judge Christopher R. Cooper on 4/16/2018. (lccrc1)
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| Set/Reset Deadlines: Brief due by 4/30/2018. Responses due by 5/7/2018 (lsj) |
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MINUTE ORDER granting #15 Plaintiff's Amended Motion for Extension of Time to File Opposition. The deadline for Plaintiff's opposition to #12 Defendant's motion to dismiss is stayed until the Court resolves Plaintiff's pending #10 Motion to Remand. Signed by Judge Christopher R. Cooper on 3/8/2018. (lccrc1)
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| Filing 15 Amended MOTION for Extension of Time to File Response/Reply as to #12 MOTION to Dismiss by SARAH S. PLEZNAC (Attachments: #1 Appendix Confer email per local rule 7(m))(Zouaoui, Jamil) |
| Filing 14 MOTION for Extension of Time to File Response/Reply as to #12 MOTION to Dismiss by SARAH S. PLEZNAC (Attachments: #1 Appendix Confer email per local rule 7(m))(Zouaoui, Jamil) |
| Filing 13 REPLY to opposition to motion re #10 MOTION to Remand to State Court filed by SARAH S. PLEZNAC. (Zouaoui, Jamil) |
| Filing 12 MOTION to Dismiss by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Attachments: #1 Memorandum in Support, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Text of Proposed Order)(Busen, Carey) |
| Filing 11 Memorandum in opposition to re #10 MOTION to Remand to State Court filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Attachments: #1 Exhibit 1, #2 Text of Proposed Order)(Busen, Carey) |
| Filing 10 MOTION to Remand to State Court by SARAH S. PLEZNAC (Attachments: #1 Text of Proposed Order proposed order)(Zouaoui, Jamil) |
| Set/Reset Deadlines: Answer due by 2/12/2018 (lsj) |
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MINUTE ORDER granting #5 Defendant's Motion for Extension of Time to File Answer. Defendant's answer or other response is due by February 12, 2018. Signed by Judge Christopher R. Cooper on 1/10/2018. (lccrc1)
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| Filing 9 Receipt on 01/05/2018 of ORIGINAL FILE, certified copy of transfer order and docket sheet from Superior Court. Superior Court Number 17-CA-006680. (jf) |
| Filing 8 NOTICE to Counsel/Party. (zsth) |
| Filing 7 CIVIL COVER SHEET Corrected Civil Cover Sheet by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C..(Busen, Carey) |
| Filing 6 ERRATA by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Attachments: #1 Exhibit A)(Busen, Carey) |
| Case Assigned to Judge Christopher R. Cooper. (zsth) |
| Filing 5 MOTION for Extension of Time to File Answer by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Text of Proposed Order)(Busen, Carey) |
| Filing 4 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Craig M. White, :Firm- Baker & Hostetler LLP, :Address- 191 N. Wacker Drive, Suite 3100, Chicago, IL 60606. Phone No. - 312-416-6207. Fax No. - 312-416-6270 Filing fee $ 100, receipt number 0090-5258883. Fee Status: Fee Paid. by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Attachments: #1 Exhibit, #2 Text of Proposed Order)(Busen, Carey) |
| Filing 3 LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Busen, Carey) |
| Filing 2 NOTICE of Appearance by Carey S. Busen on behalf of EQUITY RESIDENTIAL MANAGEMENT, L.L.C. (Busen, Carey) |
| Filing 1 NOTICE OF REMOVAL from Superior Court of the District of Columbia, case number 2017 CA 006680 B Filing fee $ 400, receipt number 0090-5258356 filed by EQUITY RESIDENTIAL MANAGEMENT, L.L.C.. (Attachments: #1 Exhibit Documents from Superior Court, #2 Exhibit, #3 Civil Cover Sheet, #4 Exhibit)(Busen, Carey) |
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