Camden County v. Union Carbide Corporation
| Camden County |
| Uniion Carbide Corporation and Union Carbide Corporation |
| 2:2022cv00077 |
| August 19, 2022 |
| US District Court for the Southern District of Georgia |
| Benjamin W Cheesbro |
| Lisa G Wood |
| Contract: Other |
| 28 U.S.C. § 1446 Notice of Removal |
| None |
Docket Report
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Filing 25
ORDER granting re #24 Consent MOTION for Extension of Time to respond to Defendant Union Carbide Corporation's motions. Plaintiff shall have through November 1, 2022 to file any responses to Defendant's Motions. Signed by Judge Lisa G. Wood on 10/5/22. (loh)
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| Set/Reset Deadlines as to #21 MOTION for Judicial Notice, #18 MOTION to Dismiss. Responses due by 11/1/2022. (loh) |
| Set/Reset Deadlines: Reply as to #19 RESPONSE in Opposition due by 11/1/2022. (loh) |
| Filing 24 Consent MOTION for Extension of Time to respond to Defendant Union Carbide Corporations Motion to Dismiss (Doc. No. #18 ); Response in Opposition to Plaintiffs Motion to File Complaint Under Seal (Doc. No. #19 ); and Motion for Judicial Notice (Doc. No. #21 ) , by Camden County. Responses due by 10/14/2022. (Attachments: #1 Text of Proposed Order Proposed Order)(Robbins, Richard) Modified on 9/30/2022 (JH). |
| Filing 23 NOTICE of Appearance by Brian Edward Lake on behalf of Camden County (Lake, Brian) |
| Filing 22 Corporate Disclosure Statement by Union Carbide Corporation identifying The Dow Chemical Company as Corporate Parent.. (Bishop, James) |
| Filing 21 MOTION for Judicial Notice by Union Carbide Corporation. Responses due by 10/11/2022. (Attachments: #1 Exhibit Minutes, #2 Exhibit Referendum Petition, #3 Exhibit Referendum Order, #4 Exhibit Referendum Certification, #5 Exhibit Caveat to Petition, #6 Exhibit Order to Deny Caveat, #7 Exhibit Order Denying Petition, #8 Exhibit Notice of Appeal, #9 Exhibit GA Supreme Ct Order)(Bishop, James) |
| Filing 20 MOTION Request for Hearing/Oral Argument re #18 MOTION to Dismiss by Union Carbide Corporation. Responses due by 10/11/2022. (Bishop, James) Modified on 9/28/2022 (thb). |
| Filing 19 RESPONSE in Opposition re #4 Consent MOTION for Extension of Time to File Answer re #1 Notice of Removal, MOTION to Seal filed by Union Carbide Corporation. (Bishop, James) |
| Filing 18 MOTION to Dismiss by Union Carbide Corporation. Responses due by 10/11/2022. (Attachments: #1 Exhibit Minutes, #2 Exhibit Option Agreement, #3 Exhibit Referendum Petition, #4 Exhibit Referendum Order, #5 Exhibit Referendum Certification, #6 Exhibit Caveat to Petition, #7 Exhibit Order to Deny Caveat, #8 Exhibit Order Denying Petition, #9 Exhibit Notice of Appeal, #10 Exhibit GA Supreme Ct Order)(Bishop, James) |
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Filing 17
TEXT ORDER granting #16 Motion for Leave of Absence by Richard Robbins for the dates of: October 10, 2022 through and including October 14, 2022; and November 1, 2022 through and including November 3, 2022. Signed by Magistrate Judge Benjamin W. Cheesbro on August 31, 2022. (edd)
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| MOTIONS REFERRED: #16 MOTION for Leave of Absence as to Camden County (slt) |
| Filing 16 MOTION for Leave of Absence as to Camden County for dates of : October 10, 11, 12, 13, 14, 2022 and November 1, 2 and 3, 2022 by Camden County. Responses due by 9/9/2022. (Robbins, Richard) |
| Filing 15 ***FILED IN ERROR. Modified on 8/26/2022 (gmh). |
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Filing 14
TEXT ORDER granting #7 Motion for Leave to Appear Pro Hac Vice by Shannon Vreeland. James Bishop has entered an appearance in this case and vouches he will satisfy the obligations of local counsel, as this Court's Local Rule 83.4 requires. Signed by Magistrate Judge Benjamin W. Cheesbro on August 26, 2022. (edd)
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Filing 13
TEXT ORDER granting #6 Motion for Leave to Appear Pro Hac Vice by Douglas Arnold. James Bishop has entered an appearance in this case and vouches he will satisfy the obligations of local counsel, as this Court's Local Rule 83.4 requires. Signed by Magistrate Judge Benjamin W. Cheesbro on August 26, 2022. (edd)
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Filing 12
TEXT ORDER granting #5 Motion for Leave to Appear Pro Hac Vice by W. Clay Massey. James Bishop has entered an appearance in this case and vouches he will satisfy the obligations of local counsel, as this Court's Local Rule 83.4 requires. Signed by Magistrate Judge Benjamin W. Cheesbro on August 26, 2022. (edd)
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Filing 11
TEXT ORDER granting #4 Defendant's Consent Motion for Extension of Time to Respond to Complaint and Motion to File Complaint Under Seal. Defendant shall file its desired response to the Complaint and motion to file under seal on or before September 27, 2022. Signed by Magistrate Judge Benjamin W. Cheesbro on August 23, 2022. (edd)
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| MOTIONS REFERRED: #6 MOTION for Leave to Appear Pro Hac Vice of Douglas S. Arnold, #7 MOTION for Leave to Appear Pro Hac Vice of Shannon N. Vreeland, #5 MOTION for Leave to Appear Pro Hac Vice of W. Clay Massey, #10 Notice of Filing Signed Applications. PRO HAC VICE PAID by James A. Bishop, Sr for Union Carbide Corporation; Amount 600.00 Receipt # 400000005 Date: 8/22/22 for attorneys W. Clay Massey, Douglas Arnold, and Shannon Vreeland. (thb) |
| Filing 10 NOTICE of Filing by Union Carbide Corporation re #6 MOTION for Leave to Appear Pro Hac Vice of Douglas S. Arnold Fee Amount $200,, #7 MOTION for Leave to Appear Pro Hac Vice of Shannon N. Vreeland Fee Amount $200,, #5 MOTION for Leave to Appear Pro Hac Vice of W. Clay Massey Fee Amount $200, Notice of Filing Signed Applications (Attachments: #1 Supplement Fully signed application, #2 Supplement Fully signed application, #3 Supplement Fully signed application)(Bishop, James) |
| Filing 9 NOTICE of Appearance by Richard L. Robbins on behalf of Camden County (Robbins, Richard) |
| Filing 8 NOTICE of Filing Deficiency re #6 MOTION for Leave to Appear Pro Hac Vice of Douglas S. Arnold, #7 MOTION for Leave to Appear Pro Hac Vice of Shannon N. Vreeland, #5 MOTION for Leave to Appear Pro Hac Vice of W. Clay Massey. After 14 days a notice of noncompliance will be submitted to a judicial officer for possible sanctions, to include dismissal. Compliance due by 9/5/2022. (thb) |
| Filing 7 MOTION for Leave to Appear Pro Hac Vice of Shannon N. Vreeland Fee Amount $200, by Uniion Carbide Corporation. Responses due by 9/5/2022. (Attachments: #1 Exhibit List of Prior Cases, #2 Exhibit Certificate of Good Standing)(Bishop, James) |
| Filing 6 MOTION for Leave to Appear Pro Hac Vice of Douglas S. Arnold Fee Amount $200, by Uniion Carbide Corporation. Responses due by 9/5/2022. (Attachments: #1 Exhibit List of Prior Cases, #2 Exhibit Certificate of Good Standing)(Bishop, James) |
| Filing 5 MOTION for Leave to Appear Pro Hac Vice of W. Clay Massey Fee Amount $200, by Uniion Carbide Corporation. Responses due by 9/5/2022. (Attachments: #1 Exhibit List of Prior Cases, #2 Exhibit Certificate of Good Standing)(Bishop, James) |
| Filing 4 Consent MOTION for Extension of Time to File Answer re #1 Notice of Removal, by Uniion Carbide Corporation. Responses due by 9/5/2022. (Attachments: #1 Exhibit Acknowledgment of Service and Extension of Time, #2 Text of Proposed Order Proposed Order)(Bishop, James). ***ENTERED IN ERROR**Added MOTION to Seal on 8/22/2022 (thb). Modified on 8/22/2022 (thb). Modified on 9/22/2022 to correct terminated date (kjm). |
| MOTIONS REFERRED: #4 Consent MOTION for Extension of Time to File Answer re #1 Notice of Removal. (thb) |
| PRO HAC VICE PAID by James A. Bishop, Sr for Union Carbide Corporation; Amount 600.00 Receipt # 400000005 Date: 8/22/22 for attorneys W. Clay Massey, Douglas Arnold, and Shannon Vreeland. (wwp) |
| Filing fee: $ 402.00, receipt number 400000001. (jrb) |
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Filing 3
RULE 26(f) ORDER. Signed by Magistrate Judge Benjamin W. Cheesbro on 08/19/2022. (jlh)
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| Filing 2 Removal NOTICE to All Counsel of Record. (Set/Reset Deadlines: Compliance due by 9/2/2022.) (jlh) |
| Filing 1 NOTICE OF REMOVAL from Superior Court of Camden County, State of Georgia, case number SUCV2022000577, filed by Uniion Carbide Corporation. (Attachments: #1 Exhibit 1 - Complaint, #2 Exhibit 2 - Plaintiff's Motion to File Compalint Under Seal, #3 Exhibit 3 - Summons, #4 Exhibit 4 - Case Filing Information Form, and #5 Exhibit 5 - Acknowledgment of Service.) (jlh) (Additional attachment(s) added on 8/19/2022: #6 Civil Cover Sheet) (jlh). |
| Set/Reset Deadlines: Uniion Carbide Corporation answer due 8/26/2022. (jlh) |
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