ECBI WARNER LLC et al v. TOMS et al
| ANTWON ALSOBROOK, eCBI Warner, LLC, JERRALD RECTOR, A2D, Inc., KEITH D QUARLES, JR, A2D INC and ECBI WARNER LLC |
| CLIFFORD HOLMES, KEVIN LASHLEY, THOMAS RANDALL TOMS, CHARLIE BIBB, DAVID REID, KEITH LAURITSEN, CITY OF WARNER ROBINS GEORGIA, BILL MULKEY, LARRY CURTIS, CITY OF WARNER ROBINS and DAVID REID Individually, and in his capacity doing business as ENOUGH IS ENOUGH IN WARNER ROBINS |
| 5:2021cv00148 |
| April 28, 2021 |
| US District Court for the Middle District of Georgia |
| MARC T TREADWELL |
| Civil Rights: Other |
| 42 U.S.C. § 1981 Civil Rights |
| Plaintiff |
Docket Report
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This docket was last retrieved on October 20, 2022. A more recent docket listing may be available from PACER.
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Filing 73
NOTICE of Voluntary Dismissal by KEITH D QUARLES, JR, A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, JERRALD RECTOR as to All Plaintiffs (CHEELEY, ROBERT)
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REMARK: Pursuant to the filing of #73 Notice of Voluntary Dismissal, this case is closed. (ggs)
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Filing 72
ORDER. The plaintiffs' claims against Defendants Charlie Bibb, Larry Curtis, Clifford Holmes, Keith Lauritsen, and Kevin Lashley; Thomas Randall Toms in his official capacity; and Bill Mulkey in his official capacity are DISMISSED with prejudice. Further, all allegations of Toms and Mulkey acting in their official capacities are deemed struck from the recast complaint. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 5/2/2022. (kat)
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Filing 71
Minute Entry (content for administrative purposes only) for proceedings held before CHIEF DISTRICT JUDGE MARC T TREADWELL: Motion Hearing held on 4/28/2022 re #59 MOTION to Dismiss Amended Complaint; #60 MOTION to Dismiss Amended Complaint; #61 MOTION to Dismiss Amended Complaint. Court Reporter: Darlene Fuller. Time in Court: 1 hour / 33 minutes. (kat)
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***TIME CHANGE ONLY*** NOTICE OF RESETTING HEARING ON MOTION re #60 MOTION to Dismiss Amended Complaint, #61 MOTION to Dismiss Amended Complaint, and #59 MOTION to Dismiss Amended Complaint. Motion Hearing RESET for 4/28/2022 at 10:00 AM in Macon before CHIEF DISTRICT JUDGE MARC T TREADWELL. Hearing will occur IN-PERSON. Counsel, parties, and members of the public and press should review Standing Order 2022-03, available on the court's website, regarding courthouse entrance procedures due to COVID-19. (kat)
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Filing 70
REPLY to Response filed by THOMAS RANDALL TOMS re #60 MOTION to Dismiss Amended Complaint, RESPONSE TO ORDER TO SHOW CAUSE by THOMAS RANDALL TOMS (BENNETT, MATTHEW)
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Notice of Deficiency (related document(s): #69 Notice (Notice of Potential Conflict) filed by A2D INC, ECBI WARNER LLC, ANTWON ALSOBROOK, JERRALD RECTOR, KEITH D QUARLES, JR ); The notice is construed as a notice of leave of absence. Pursuant to Local Rule 83.1.5 Formal applications by attorneys for leaves of absence should not be filed and will not be acted upon unless the attorney has been notified by the court to appear during the time he/she wishes to be absent. There are currently no hearings scheduled during the time period mentioned in the notice.(ggs)
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Filing 69
NOTICE Notice of Potential Conflict by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR (CHEELEY, ROBERT) Modified on 4/8/2022 to edit text. (ggs).
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Filing 68
STIPULATION of DISMISSAL WITH PREJUDICE OF THE ACTIONS AGAINST DEFENDANTS IN THEIR OFFICIAL CAPACITIES by KEITH D QUARLES, JR, A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, JERRALD RECTOR as to LARRY CURTIS (CHEELEY, ROBERT) Modified on 4/7/2022 to edit text. (ggs).
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NOTICE OF SETTING HEARING ON MOTION re #60 MOTION to Dismiss Amended Complaint, #61 MOTION to Dismiss Amended Complaint, #59 MOTION to Dismiss Amended Complaint. Motion Hearing set for 4/28/2022 at 2:00 PM in Macon before CHIEF DISTRICT JUDGE MARC T TREADWELL. Hearing will occur IN-PERSON. Counsel, parties, and members of the public and press should review Standing Order 2022-03, available on the court's website, regarding courthouse entrance procedures due to COVID-19. (kat)
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Filing 67
RESPONSE to Court Order and RESPONSE TO MOTION filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #60 MOTION to Dismiss Amended Complaint, RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR, #66 ORDER to Show Cause (CHEELEY, ROBERT) Modified on 4/1/2022 to link to order to show cause and to edit text. (ggs).
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Filing 66
ORDER TO SHOW CAUSE. The plaintiffs are ORDERED TO SHOW CAUSE by April 1, 2022, why their complaint should not be dismissed with prejudice. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 3/29/2022. (kat)
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Filing 65
REPLY to Response filed by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN, THOMAS RANDALL TOMS re #61 MOTION to Dismiss Amended Complaint, #60 MOTION to Dismiss Amended Complaint (BENNETT, MATTHEW)
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Filing 64
REPLY to Response filed by CITY OF WARNER ROBINS, BILL MULKEY re #59 MOTION to Dismiss Amended Complaint (DUGGAN, IVY)
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Filing 63
RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #59 MOTION to Dismiss Amended Complaint (CHEELEY, ROBERT)
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Filing 62
ORDER terminating as moot #25 Motion to Dismiss for Failure to State a Claim; terminating as moot #26 Motion to Dismiss Complaint; terminating as moot #26 Motion for More Definite Statement; terminating as moot #27 Motion to Dismiss Complaint. Order re #61 Supplemental Memorandum in Support filed by LARRY CURTIS, CHARLIE BIBB, KEVIN LASHLEY, KEITH LAURITSEN, CLIFFORD HOLMES, #59 Supplemental Memorandum in Support filed by BILL MULKEY, CITY OF WARNER ROBINS, #60 Supplemental Memorandum in Support filed by THOMAS RANDALL TOMS; Their supplemental briefs (Docs. 59; 60; 61) are deemed motions to dismiss the plaintiffs amended complaint. The plaintiffs shall respond, and the defendants shall reply as provided by Rule 12. Fed. R. Civ. P. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 1/28/2022. (ggs)
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Filing 61
MOTION TO DISMISS re #57 AMENDED COMPLAINT re #1 Complaint filed by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN (BENNETT, MATTHEW) Modified on 1/27/2022 to edit text. (ggs). Modified on 1/28/2022 to change document to a motion and to link to amended complaint. (ggs).
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Filing 60
MOTION TO DISMISS re #57 AMENDED COMPLAINT re #1 Complaint filed by THOMAS RANDALL TOMS (BENNETT, MATTHEW) Modified on 1/27/2022 to edit text. (ggs). Modified on 1/28/2022 to change document to a motion and to link to amended complaint. (ggs).
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Filing 59
MOTION TO DISMISS re #57 AMENDED COMPLAINT re #1 Complaint filed by CITY OF WARNER ROBINS, BILL MULKEY (DUGGAN, IVY) Modified on 1/27/2022 to edit text. (ggs). Modified on 1/28/2022 to change document to a motion and to link to amended complaint. (ggs).
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Filing 58
ORDER. The plaintiffs' recast complaint does not assert a claim against David Reid and plaintiffs' counsel has confirmed that the plaintiffs wish to dismiss Reid from this action. No defendant has objected to this dismissal. Accordingly, Reid is terminated from this action. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 1/12/2022. (kat)
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Filing 57
AMENDED COMPLAINT re #1 Complaint against CHARLIE BIBB, CITY OF WARNER ROBINS, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN, BILL MULKEY, THOMAS RANDALL TOMS by KEITH D QUARLES, JR, A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, JERRALD RECTOR (Attachments: #1 Exhibit Ex. 1 - City of Warner Robbins Closing Certificat, #2 Exhibit Ex. 2 - May 11, 2018 Press Release)(BOWERS, MICHAEL) Modified on 1/6/2022 to edit text. (ggs). Modified on 1/28/2022 to edit text. (ggs).
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Filing 56
ORDER to Recast Complaint: Plaintiffs shall, no later than January 5, 2022, recast their complaint. ORDER for Response: No later than 21 days after the filing of the amended complaint, the defendants shall file supplemental briefs addressing the effect of the amended complaint on their motions to dismiss. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 12/14/2021. (kat)
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Filing 55
REPLY to Response filed by CITY OF WARNER ROBINS, BILL MULKEY re #50 MOTION to exclude Plaintiffs' exhibits re #38 Response to Motion,,,,, (DUGGAN, IVY)
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Filing 54
RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #50 MOTION to exclude Plaintiffs' exhibits re #38 Response to Motion,,,,, (Attachments: #1 Exhibit Response to Motion to Dismiss Exhibit List [Doc. 38], #2 Exhibit 42 U.S.C. 1983 Exhibit List The Complaint [Doc.1], #3 Exhibit The Interconnect Agreement, #4 Affidavit Affidavits of Quarles, Rector, Thomas, Lee, and Gosline)(CHEELEY, ROBERT)
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Filing 53
REPLY to Response filed by THOMAS RANDALL TOMS re #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM (BENNETT, MATTHEW)
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Filing 52
REPLY to Response filed by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN re #27 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, : (BENNETT, MATTHEW)
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Filing 51
REPLY to Response filed by CITY OF WARNER ROBINS, BILL MULKEY re #26 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :MOTION for More Definite Statement (DUGGAN, IVY)
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Filing 50
MOTION to exclude Plaintiffs' exhibits re #38 Response to Motion,,,,, by CITY OF WARNER ROBINS, BILL MULKEY filed by IVY STEWART DUGGAN. (Attachments: #1 Memorandum in Support of Motion to Exclude Plaintiffs' Exhibits)(DUGGAN, IVY)
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REMARK: Attorney J. TRAVIS HALL terminated as counsel of record for Defendant THOMAS RANDALL TOMS. (ggs)
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Filing 49
MOTION to Substitute Attorney by THOMAS RANDALL TOMS filed by MATTHEW HERBERT BENNETT. (Attachments: #1 Proposed Order Granting Substitution of Counsel)(BENNETT, MATTHEW)
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Filing 48
This is a text only entry; no document issued. ORDER GRANTING #45 Motion for Leave to File Excess Pages as to THOMAS RANDALL TOMS. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 10/4/2021. (kat)
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Filing 47
Letter regarding Rule 6.2 Request for Extension of Time to file Reply Brief re #27 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, : (BENNETT, MATTHEW)
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Notice of Clerk's Granting of Extension Pursuant to Local Rule 6.2 re: #27 MOTION to Dismiss Complaint re #1 Complaint filed by LARRY CURTIS, CHARLIE BIBB, KEVIN LASHLEY, KEITH LAURITSEN, CLIFFORD HOLMES (ggs)
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Filing 46
CONSENT MOTION for Extension of Time to File REPLY TO RESPONSE as to #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by THOMAS RANDALL TOMS filed by JON TRAVIS HALL.(HALL, JON)
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Filing 45
MOTION for Leave to File Excess Pages by THOMAS RANDALL TOMS filed by JON TRAVIS HALL.(HALL, JON)
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Notice of Clerk's Granting of Extension Pursuant to Local Rule 6.2 re: #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by THOMAS RANDALL TOMS (ggs)
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Notice of Deficiency (related document(s): #46 Motion for Extension of Time to File Response/Reply/Object filed by THOMAS RANDALL TOMS ); The Local Rule 6.2 Clerk's Extension is not requested via a motion. (Motions are ruled on by the Court and not the Clerk). Rule 6.2 extensions are requested via a letter filed using the "letter" event. The instant motion will be terminated and construed as a Rule 6.2 request for the Clerk's extension. DO NOT REFILE(ggs)
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Filing 44
This is a text only entry; no document issued. ORDER Granting #42 CONSENT MOTION for Extension of Time to File REPLY TO RESPONSE re #26 MOTION to Dismiss Complaint re #1 Complaint. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on September 29, 2021. Defendants the City of Warner Robins, Georgia and Bill Mulkey shall have until 10/18/2021 to reply to the plaintiffs' response. (alds)
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Filing 43
This is a text only entry; no document issued. ORDER Granting #41 MOTION for Leave to File Excess Pages for Reply Brief in Support of Motion to Dismiss Plaintiffs' Complaint. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on September 29, 2021. (alds)
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Filing 42
CONSENT MOTION for Extension of Time to File REPLY TO RESPONSE as to #26 MOTION to Dismiss Complaint re #1 Complaint, MOTION for More Definite Statement by CITY OF WARNER ROBINS, BILL MULKEY filed by IVY STEWART DUGGAN.(DUGGAN, IVY) Modified on 9/28/2021 to edit text. (ggs).
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Filing 41
MOTION for Leave to File Excess Pages for Reply Brief in Support of Motion to Dismiss Plaintiffs' Complaint by CITY OF WARNER ROBINS, BILL MULKEY filed by IVY STEWART DUGGAN.(DUGGAN, IVY)
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Filing 40
RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #27 MOTION to Dismiss Complaint re #1 Complaint (CHEELEY, ROBERT) Modified on 9/21/2021 to edit text. (ggs).
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Filing 39
RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM (CHEELEY, ROBERT)
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Filing 38
RESPONSE filed by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR re #26 MOTION to Dismiss Complaint re #1 Complaint, MOTION for More Definite Statement (Attachments: #1 Exhibit 1 (Exhibit List for 1983 Complaint), #2 Exhibit 2 (8-9-2017 WAN Project Meeting Minute), #3 Exhibit 3 (8-22-2017 WAN Project Meeting Minute), #4 Exhibit 4 (9.27.2017 WAN Project Meeting Minute), #5 Exhibit 5 (11.03.2017 City ROW permit), #6 Exhibit 6 (11.03.2017 Houston County ROW permit), #7 Exhibit 7 (11.03.2017 GA DOT Permit), #8 Exhibit 8 (11.03.2017 CSX Transportation permit), #9 Exhibit 9 (Interconnect Agreement), #10 Exhibit Exhibit 10 (1st Amended Declaratory Judgment + Exhibits A-V 07.19.2021), #11 Exhibit 11 (Emails between Gabriel Ramirez and Jerrald Rector), #12 Exhibit 12 (08.12.2021 Letter from Duggan to RDC), #13 Exhibit 13 (09.17.2021 Letter from Duggan to RDC), #14 Affidavit Exhibit 14 (Affidavit of Keith Quarles with Exhibits), #15 Exhibit 15 (Affidavit of Timothy Thomas), #16 Exhibit 16 (Affidavit of Gary Lee), #17 Exhibit 17 (Affidavit of Robbin Gosline), #18 Exhibit 18 (Affidavit of Jerrald Rector w Exhibits))(CHEELEY, ROBERT) Modified on 9/21/2021 to edit text. (ggs).
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Filing 37
This is a text only entry; no document issued. ORDER Granting #36 EMERGENCY MOTION for Extension of Time to File RESPONSE re #26 MOTION to Dismiss Complaint re #1 Complaint (IFP), MOTION for More Definite Statement, #27 MOTION to Dismiss Complaint re #1 Complaint (IFP), #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM. Plaintiffs shall have an additional ten (10) days up to and including September 20, 2021, to respond to the Defendants' Motions to Dismiss. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on September 9, 2021. (alds)
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Filing 36
EMERGENCY MOTION for Extension of Time to File as to #27 MOTION to Dismiss Complaint re #1 Complaint (IFP), #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #26 MOTION to Dismiss Complaint re #1 Complaint (IFP), MOTION for More Definite Statement by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR filed by ROBERT D CHEELEY.(CHEELEY, ROBERT) Modified on 9/9/2021 to edit text. (ggs).
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Filing 35
This is a text only entry; no document issued. ORDER Granting #34 Motion for Extension of Time to File RESPONSE re #26 MOTION to Dismiss Complaint re #1 Complaint (IFP), MOTION for More Definite Statement, #27 MOTION to Dismiss Complaint re #1 Complaint (IFP), #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . The plaintiffs shall have until 09/10/2021 to respond to the defendants' motions to dismiss. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on August 31, 2021. (alds)
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Filing 34
CONSENT MOTION for Extension of Time to File RESPONSE as to #27 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :, #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #26 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :MOTION for More Definite Statement by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR filed by ROBERT D CHEELEY. (Attachments: #1 Proposed Order)(CHEELEY, ROBERT)
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Filing 33
Letter regarding Plaintiffs' Request for Extension of Time to Respond to Defendants' Motions to Dismiss re #27 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :, #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #26 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :MOTION for More Definite Statement (CHEELEY, ROBERT)
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Notice of Clerk's Granting of Extension Pursuant to Local Rule 6.2 re: #26 MOTION to Dismiss Complaint re #1 Complaint, MOTION for More Definite Statement filed by BILL MULKEY, CITY OF WARNER ROBINS, #27 MOTION to Dismiss Complaint re #1 Complaint, filed by LARRY CURTIS, CHARLIE BIBB, KEVIN LASHLEY, KEITH LAURITSEN, CLIFFORD HOLMES, #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by THOMAS RANDALL TOMS. The response and reply deadlines have been reset. (ggs)
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Filing 32
This is a text only entry; no document issued. ORDER GRANTING #29 MOTION for Leave to File Excess Pages for 25, 25-1. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 8/5/2021. (kat)
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Notice of Deficiency (related document(s): #30 Stipulation, filed by A2D INC, ECBI WARNER LLC, ANTWON ALSOBROOK, JERRALD RECTOR, KEITH D QUARLES, JR, #31 Stipulation, filed by A2D INC, ECBI WARNER LLC, ANTWON ALSOBROOK, JERRALD RECTOR, KEITH D QUARLES, JR): MDGA Local Rule 6.2 does not allow parties to stipulate to an extension of time to respond to motions. MDGA Local Rule 6.2 states: "In civil cases, the clerk of the court and his deputies are authorized to permit extensions of time to a date certain not to exceed fourteen (14) days for the filing of briefs. No more than one (1) such extension may be granted by the clerk for the same brief. Permission of the court must be obtained for any additional extensions. A party requesting an additional extension must do so by written motion filed no later than five (5) days before the expiration of the extension granted by the clerk. The motion shall state why an additional extension is needed." Extensions of more than 14 days, pertaining to responses and replies to motions, require leave of court. (ggs) Modified on 8/5/2021 (ggs).
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Filing 31
STIPULATION Stipulation Extending Time for Plfs to Respond to Def Mayor Toms's Motion to Dismiss re #25 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR (CHEELEY, ROBERT)
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Filing 30
STIPULATION Stipulation Extending Time to Respond to Defs Bibbs, Curtis, Holmes, Lauritsen, and Lashley's Motion to Dismiss re #27 MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, : by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR (CHEELEY, ROBERT)
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Filing 29
MOTION for Leave to File Excess Pages for 25, 25-1 by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR filed by ROBERT D CHEELEY.(CHEELEY, ROBERT)
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Filing 28
This is a text only entry; no document issued. ORDER GRANTING #24 MOTION for Leave to File Excess Pages for Brief in Support of Motion to Dismiss. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 7/30/2021. (kat)
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Filing 27
MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, : by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN filed by MATTHEW HERBERT BENNETT. (Attachments: #1 Memorandum in Support of Motion to Dismiss Complaint)(BENNETT, MATTHEW)
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Filing 26
MOTION to Dismiss Complaint re #1 Complaint (IFP),,,,,,, :, MOTION for More Definite Statement by CITY OF WARNER ROBINS, BILL MULKEY filed by IVY STEWART DUGGAN. (Attachments: #1 Memorandum in Support Brief ISO Motion to Dismiss, #2 Exhibit A -- Certified Copy of Warner Robins City Charter, #3 Exhibit B -- Certified Copies of Meeting Minutes)(DUGGAN, IVY)
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Filing 25
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by THOMAS RANDALL TOMS filed by JON TRAVIS HALL. (Attachments: #1 Memorandum in Support)(HALL, JON)
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Filing 24
MOTION for Leave to File Excess Pages for Brief in Support of Motion to Dismiss by THOMAS RANDALL TOMS filed by JON TRAVIS HALL.(HALL, JON)
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Filing 23
This is a text only entry; no document issued. ORDER Granting #22 MOTION for Leave to File Excess Pages for Brief in Support of Motion to Dismiss Plaintiffs' Complaint. The Defendants' Brief in Support of their Motion to Dismiss Plaintiffs' Complaint shall not exceed thirty-five pages. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on July 21, 2021. (alds)
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Filing 22
MOTION for Leave to File Excess Pages for Brief in Support of Motion to Dismiss Plaintiffs' Complaint by CITY OF WARNER ROBINS, BILL MULKEY filed by IVY STEWART DUGGAN.(DUGGAN, IVY)
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Filing 21
STIPULATION Extending Time for Defendants Bibb, Curtis, Holmes, Lauritsen and Lashley to Answer Complaint by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN (BENNETT, MATTHEW)
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Filing 20
AMENDED DOCUMENT by CITY OF WARNER ROBINS, BILL MULKEY,amending #18 Stipulation, Notice of Deficiency, (DUGGAN, IVY)
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Filing 19
STIPULATION Extending Time For Defendant Thomas Randall Toms to file Answer or other Responsive Pleadings to Plaintiffs' Complaint by THOMAS RANDALL TOMS (HALL, JON)
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Notice of Deficiency (related document(s): #19 Stipulation filed by THOMAS RANDALL TOMS, #18 Stipulation, filed by BILL MULKEY, CITY OF WARNER ROBINS ); Certificate of Service for document served outside of CM/ECF not attached. Defendant DAVID REID is pro se. Please make sure to include the method of service upon pro se parties on the certificate of service.(ggs)
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Notice of Deficiency (related document(s): #18 Stipulation of Extension of Time to Answer Complaint, filed by BILL MULKEY, CITY OF WARNER ROBINS ); The parties have stipulated to an extension of time of 30 days or less. The attached order is not necessary and will not be executed by the court.(ggs)
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Filing 18
STIPULATION Extending the Time for Defendants The City of Warner Robins, Georgia and Bill Mulkey to Answer Plaintiffs' Complaint by CITY OF WARNER ROBINS, BILL MULKEY (Attachments: #1 Proposed Order Granting Stipulation)(DUGGAN, IVY)
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Filing 17
ANSWER to Complaint (Document titled "Affidavit" by DAVID REID. (Attachments: #(1) Exhibits - Correspondence)(ggs)
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Filing 16
This is a text only entry; no document issued. ORDER GRANTING #15 Motion to Substitute Attorney. Added attorney MATTHEW HERBERT BENNETT for CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY,and KEITH LAURITSEN. Ordered by CHIEF DISTRICT JUDGE MARC T TREADWELL on 6/1/2021. (kat)
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Filing 15
MOTION to Substitute Attorney by CHARLIE BIBB, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN filed by MATTHEW HERBERT BENNETT. (Attachments: #1 Proposed Order Proposed Order)(BENNETT, MATTHEW)
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Filing 14
WAIVER OF SERVICE Returned Executed by All Plaintiffs. as to THOMAS RANDALL TOMS (CHEELEY, ROBERT)
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Filing 13
WAIVER OF SERVICE Returned Executed by All Plaintiffs. as to BILL MULKEY (CHEELEY, ROBERT)
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Filing 12
WAIVER OF SERVICE Returned Executed by All Plaintiffs. as to CITY OF WARNER ROBINS (CHEELEY, ROBERT)
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Filing 11
NOTICE of Withdrawal of Christopher J. Watkins as Counsel of Record for Plaintiffs and Entry of Appearance of Andre T. Tennille, III by A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, KEITH D QUARLES, JR, JERRALD RECTOR (CHEELEY, ROBERT)
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Filing 10
NOTICE of Attorney Appearance by SARAH C MARTIN on behalf of CHARLIE BIBB, CITY OF WARNER ROBINS, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN, BILL MULKEY Attorney SARAH C MARTIN added to party CHARLIE BIBB(pty:dft), Attorney SARAH C MARTIN added to party CITY OF WARNER ROBINS(pty:dft), Attorney SARAH C MARTIN added to party LARRY CURTIS(pty:dft), Attorney SARAH C MARTIN added to party CLIFFORD HOLMES(pty:dft), Attorney SARAH C MARTIN added to party KEVIN LASHLEY(pty:dft), Attorney SARAH C MARTIN added to party KEITH LAURITSEN(pty:dft), Attorney SARAH C MARTIN added to party BILL MULKEY(pty:dft)(MARTIN, SARAH)
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Filing 9
NOTICE of Attorney Appearance by JON TRAVIS HALL on behalf of THOMAS RANDALL TOMS Attorney JON TRAVIS HALL added to party THOMAS RANDALL TOMS(pty:dft)(HALL, JON)
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Notice of Deficiency (related document(s): SECOND NOTICE TO COUNSEL AMY PARKER ZUPANIC). PLEASE DISREGARD SECOND NOTICE TO COUNSEL. Attorney Zupancic was admitted to USDC on 5/04/2021. (mdm)
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SECOND NOTICE TO COUNSEL AMY PARKER ZUPANIC - Counsel is notified that they do not show in the court records that they meet the required attorney admissions policies of this court. If within 14 days of this notice all requirements, including the payment of Pro Hac Vice or admissions fees, have not been met, a show cause hearing will be scheduled. PLEASE BE ADVISED you will no longer receive electronic notification of electronic filings until you comply with the admissions requirements.(ggs)
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Filing 8
NOTICE of Attorney Appearance by JOHN MATTHEW HAWKINS on behalf of CHARLIE BIBB, CITY OF WARNER ROBINS, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN, BILL MULKEY Attorney JOHN MATTHEW HAWKINS added to party CHARLIE BIBB(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party CITY OF WARNER ROBINS(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party LARRY CURTIS(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party CLIFFORD HOLMES(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party KEVIN LASHLEY(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party KEITH LAURITSEN(pty:dft), Attorney JOHN MATTHEW HAWKINS added to party BILL MULKEY(pty:dft)(HAWKINS, JOHN)
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Filing 7
NOTICE of Attorney Appearance by IVY STEWART DUGGAN on behalf of CHARLIE BIBB, CITY OF WARNER ROBINS, LARRY CURTIS, CLIFFORD HOLMES, KEVIN LASHLEY, KEITH LAURITSEN, BILL MULKEY Attorney IVY STEWART DUGGAN added to party CHARLIE BIBB(pty:dft), Attorney IVY STEWART DUGGAN added to party CITY OF WARNER ROBINS(pty:dft), Attorney IVY STEWART DUGGAN added to party LARRY CURTIS(pty:dft), Attorney IVY STEWART DUGGAN added to party CLIFFORD HOLMES(pty:dft), Attorney IVY STEWART DUGGAN added to party KEVIN LASHLEY(pty:dft), Attorney IVY STEWART DUGGAN added to party KEITH LAURITSEN(pty:dft), Attorney IVY STEWART DUGGAN added to party BILL MULKEY(pty:dft)(DUGGAN, IVY)
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Filing 6
Corporate Disclosure Statement by A2D INC identifying Other Affiliate eCBI WARNER, LLC for A2D INC. (CHEELEY, ROBERT)
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Notice of Deficiency (related document(s): #5 Corporate Disclosure Statement filed by A2D INC ); Document does not include ECBI WARNER LLC, which is a subsidiary (i.e. "Other Affiliate") as stated in the corporate disclosure statement filed on behalf of ECBI WARNER LLC. Document must correcte4d and re-filed to add the subsidiary corporation.(ggs)
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Filing 5
Corporate Disclosure Statement by A2D INC (CHEELEY, ROBERT)
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Filing 4
Corporate Disclosure Statement by ECBI WARNER LLC identifying Corporate Parent A2D, Inc. for ECBI WARNER LLC. (CHEELEY, ROBERT) Modified on 5/5/2021 to correct docket entry. (ggs).
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Filing 3
SUMMONS Returned Executed by KEITH D QUARLES, JR, A2D INC, ANTWON ALSOBROOK, ECBI WARNER LLC, JERRALD RECTOR as to DAVID REID. (CHEELEY, ROBERT)
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Notice of Deficiency (related document(s): #1 Complaint (IFP), filed by A2D INC, ECBI WARNER LLC, et al); Pursuant to Local Rule 87.1, all nongovernmental corporate parties must file a Corporate Disclosure Statement. Please file the required corporate disclosures immediately.(ggs)
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Filing 2
Summons Issued as to All Defendants. (Attachments: #1 Summons City of Wraner Robins, #2 Summons Charlie Bibb, #3 Summons Larry Curtis, #4 Summons Clifford Holmes, #5 Summons Keith Lauritsen, #6 Summons Kevin Lashley, #7 Summons Bill Mulkey, #8 Summons David Reid)(vs)
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Filing 1
COMPLAINT (IFP) against All Defendants filed by All Plaintiffs. Filing Fee Paid $402.00 Receipt Number AGAMDC-3781347 (Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Summons Thomas Randall Toms individually, and in his capacity as Mayor of the City of Warner Robins, #3 Summons City of Warner Robins as a municipal entity and body politic, #4 Summons Charlie Bibb in his capacity as duly elected members of the City Council for the City of Warner Robins, #5 Summons Larry Curtis in his capacity as duly elected members of the City Council for the City of Warner Robins, #6 Summons Clifford Holmes in his capacity as duly elected members of the City Council for the City of Warner Robins, #7 Summons Keith Lauritsen in his capacity as duly elected members of the City Council for the City of Warner Robins, #8 Summons Kevin Lashly in his capacity as duly elected members of the City Council for the City of Warner Robins, #9 Summons Bill Mulkey individually and in his capacity as Director of Buildings and Transportation for the City of Warner Robins, #10 Summons David Reid individually and in his capacity dba Enough is Enough in Warner Robins, #11 Exhibit Ex. 1 Memorandum of Understanding (MOU), #12 Exhibit Ex. 2 Management Agreement, #13 Exhibit Ex. 3 General Service Agreement, #14 Exhibit Ex. 4 Bill of Sale, #15 Exhibit Ex. 5 August 20 2020 Email From Bill Mulkey, #16 Exhibit Ex. 6 Writ of Mandamus with Exhibits, #17 Exhibit Ex. 7 Affidavit of Bobby Taylor, #18 Exhibit Ex. 7A Houston Home Journal Article 05.13.2020, #19 Exhibit Ex. 8 Call Before You Dig Program, #20 Exhibit Ex. 9 Emails Between Parties 03.22.2020 to 04.15.2020, #21 Exhibit Ex. 10 Emails Between Parties 03.12.2020 to 04.15.2020, #22 Exhibit Ex. 11 Demand for Retraction 03.24.2021)(CHEELEY, ROBERT) Modified on 4/29/2021 to add payment information(vs).
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NOTICE TO COUNSEL AMY PARKER ZUPANIC - Counsel is notified that they do not show in the court records that they meet the required attorney admissions policies of this court. If within 14 days of this notice all requirements, including the payment of Pro Hac Vice or admissions fees, have not been met, a show cause hearing will be scheduled.(vs)
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Notice of Deficiency (related document(s): #1 Complaint (IFP), filed by A2D INC, ECBI WARNER LLC, ANTWON ALSOBROOK, JERRALD RECTOR, KEITH D QUARLES, JR ); Notice to Counsel - Christopher J. Watkins - Your contact information in CM/ECF is not current. Please update your contact information via PACER.(vs)
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