Morgan Stanley Smith Barney LLC v. Gupta
| Morgan Stanley Smith Barney LLC |
| Rajesh Gupta |
| 1:2020cv03386 |
| June 9, 2020 |
| US District Court for the Northern District of Illinois |
| Matthew F Kennelly |
| Other Statutes: Arbitration |
| None |
Docket Report
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| Document Text |
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| Filing 93 JOINT STIPULATION AND AGREED ORDER: Signed by the Honorable Matthew F. Kennelly on 5/24/2022. Mailed notice. (mma, ) |
| Filing 92 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 5/24/2022. Joint stipulation and agreed order to follow. Mailed notice. (mma, ) |
| Filing 91 STIPULATION - Joint Stipulation and Agreed Order (Claydon, Jonathan) |
| Filing 90 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 5/18/2022 and continued to 5/24/2022 at 9:00 a.m. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053.The Court will vacate the status if the stipulation of dismissal is filed before the hearing date. Mailed notice. (mma, ) |
| Filing 89 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 5/9/2022. The parties provided an update on the settlement. A telephonic status hearing is set for 5/18/2022 at 9:00 a.m. The following call-in number will be used: 888-684-8852; access code 746-1053. The Court will vacate the status if the stipulation of dismissal is filed before the hearing date. Mailed notice. (mma, ) |
| Filing 88 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 5/3/2022. Defendant's counsel fails to appear for the hearing. Plaintiff's counsel reported on the status of the settlement. A telephonic status hearing is set for 5/9/2022 at 9:00 a.m. The following call-in number will be used: 888-684-8852; access code 746-1053. Both sides are ordered to appear for the next status hearing. Mailed notice. (mma, ) |
| Filing 87 STATUS Report (Joint) by Morgan Stanley Smith Barney LLC (Claydon, Jonathan) |
| Filing 86 MINUTE entry before the Honorable Matthew F. Kennelly: Based on the parties' joint status report, the telephonic status hearing set for 3/23/2022 is vacated and reset to 5/3/2022 at 9:10 a.m. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. A further joint status report is to be filed on 4/26/2022. (mk) |
| Filing 85 STATUS Report Parties' Joint Status Report Pursuant to Order Dated February 17, 2022 by Rajesh Gupta (Lederer, Caren) |
| Filing 84 MINUTE entry before the Honorable Matthew F. Kennelly: Agreed motion to continue #83 is granted. The video evidentiary hearing set for 3/10/2022 and the telephonic status hearing set for 3/1/2022 are both vacated. The case is set for a telephonic status hearing on 3/23/2022 at 9:10 a.m. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. A joint status report is to be filed on 3/16/2022. (mk) |
| Filing 83 MOTION by Plaintiff Morgan Stanley Smith Barney LLC for extension of time - Agreed Motion to Continue Proceedings Regarding Morgan Stanley's Motion to Avoid Fraudulent Transfer of, and for Turnover of Certain Real Property (Claydon, Jonathan) |
| Filing 82 AGREED ORDER CHARGING RAJESH GUPTA'S INTEREST IN IMPACT SERVICES, LLC, signed by the Honorable Matthew F. Kennelly on 1/18/2022. (mk) |
| Filing 81 AGREED ORDER CHARGING RAJESH GUPTA'S INTEREST IN SAGE PRINCE LIFE, LLC, signed by the Honorable Matthew F. Kennelly on 1/18/2022. (mk) |
| Filing 80 AGREED ORDER CHARGING RAJESH GUPTA'S INTEREST IN KIJARA GROUP, LLC, signed by the Honorable Matthew F. Kennelly on 1/18/2022. (mk) |
| Filing 79 AGREED ORDER CHARGING RAJESH GUPTA'S INTEREST IN SAGE LEBLANC, LLC, signed by the Honorable Matthew F. Kennelly on 1/18/2022. (mk) |
| Filing 78 AGREED ORDER CHARGING RAJESH GUPTA'S INTEREST IN GROTON GARDENS, LLC, signed by the Honorable Matthew F. Kennelly on 1/18/2022. (mk) |
| Filing 77 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic ruling on a motion hearing held on 1/13/2022. The Court concludes that an evidentiary hearing is required regarding the claim of Rohit Gupta for an equitable lien. The Court will permit limited discovery prior to the hearing. Claimant is directed to disclose by 1/24/2022 any witnesses who will be called at the hearing. Those witnesses can be deposed for a length of time no more than 90 minutes and those depositions must happen by 2/21/2022. A video evidentiary hearing is set for 3/10/2022 at 2:00 p.m. The Court will send out the video conference invitation a few days in advance of the hearing. A telephonic status hearing is set for 3/1/2022 at 8:50 a.m. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Mailed notice. (mma, ) |
| Filing 76 ATTORNEY Appearance for Intervenor Defendant Rohit Gupta by Toni J. Falligant (Falligant, Toni) |
| Filing 75 ATTORNEY Appearance for Intervenor Defendant Rohit Gupta by Caren A. Lederer (Lederer, Caren) |
| Filing 74 MOTION by Intervenor Defendant Rohit Gupta to intervene and maintain rights (Attachments: #1 Exhibit A)(Lederer, Caren) |
| Filing 73 AGREED ORDER ON MOTION TO TRANSFER PROCEEDS, signed by the Honorable Matthew F. Kennelly on 1/11/2022. (mk) |
| Filing 72 MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's unopposed motion for turnover of the proceeds of sale of certain real property #71 is granted, but plaintiff failed to provide - as directed on Judge Kennelly's web page - a Word version of the draft order for signature. The Court will grant this motion, subject to the appropriate order being sent to the proposed order e-mail address today, but in the future noncompliance will result in denial of such a motion. (mk) |
| Filing 71 MOTION by Plaintiff Morgan Stanley Smith Barney LLC- Unopposed Motion For Turnover of Proceeds of Sale of Certain Real Property (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Claydon, Jonathan) |
| Filing 70 REPLY by Morgan Stanley Smith Barney LLC to MOTION by Plaintiff Morgan Stanley Smith Barney LLC to Avoid Fraudulent Transfer of and For Turnover of Certain Real Property #41 (Attachments: #1 Exhibit A)(Claydon, Jonathan) |
Filing 69
ORDER EXTENDING CITATIONS signed by the Honorable Matthew F. Kennelly on 12/22/2021. (mk)
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| Filing 68 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 12/21/2021. Counsel reported that they are working on an agreed order on the motion for charging orders #61 . Case remains set for a telephonic status hearing on 1/13/2022 at 8:45 a.m. #45 . The following call-in number will be used for the hearing: 888-684-8852 conference code 746-1053. Mailed notice. (mma, ) |
| Filing 67 MINUTE entry before the Honorable Matthew F. Kennelly: Unopposed motion for extension of citations #66 is granted. Plaintiff's counsel is directed to provide a draft order to Judge Kennelly's proposed order e-mail address listing all of the citation respondents whose citations are being extended. (mk) |
| Filing 66 MOTION by Plaintiff Morgan Stanley Smith Barney LLC for extension of time (Unopposed) (Claydon, Jonathan) |
| Filing 65 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic motion hearing held on 12/15/2021. Plaintiff's motion for order #61 is granted, subject to presentation of an appropriate order. A telephonic status hearing is set for 12/21/2021 at 9:20 a.m. The following call-in number will be used for the hearing: 888-684-8852 conference code 746-1053. The due date for the reply on the motion to avoid fraudulent transfer #41 is extended to 1/7/2022. Mailed notice. (mma, ) |
| Filing 64 MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for charging orders #61 is set for a telephonic hearing on 12/15/2021 at 8:40 AM, using call-in number 888-684-8852, access code 746-1053. (mk) |
| Filing 63 RESPONSE by Rajesh Gupta to MOTION by Plaintiff Morgan Stanley Smith Barney LLC to Avoid Fraudulent Transfer of and For Turnover of Certain Real Property #41 (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Lederer, Caren) |
| Filing 62 ATTORNEY Appearance for Defendant Rajesh Gupta by Toni J. Falligant (Falligant, Toni) |
| Filing 61 MOTION by Plaintiff Morgan Stanley Smith Barney LLC for order /Charging Orders (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Claydon, Jonathan) |
| Filing 60 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 11/24/2021. Defendant's motions to quash #48 #50 #51 are denied for the reasons stated on the record. Any documents to be produced are subject to the existing protective order. Case remains set for a telephonic status hearing on 1/13/2022 at 8:45 a.m. #45 . The following call-in number will be used for the hearing: 888-684-8852 conference code 746-1053. Mailed notice. (mma, ) |
| Filing 59 MINUTE entry before the Honorable Matthew F. Kennelly: The Court has just reviewed a filing by plaintiff Morgan Stanley in which it states that despite this Court's order of 11/17/2021 stating that compliance with plaintiff's subpoena was "held in abeyance pending a ruling by the Court on the motion[ ] to quash," subpoena respondent PNC Bank took it upon itself, on 11/19/2021, to comply with the subpoena and produce records to plaintiff. The Court certainly understands that PNC Bank is a third party, but it did not have the authority to countermand or disregard the Court's order, nor did plaintiff have the authority to do so. The Court is also disturbed that plaintiff did not immediately advise the Court on 11/19/2021 of PNC Bank's action. Plaintiff and its counsel are hereby ordered to immediately (i.e., as of right now) obtain all copies made or sent of the PNC documents, segregate them, and not review or disseminate them further, pending an order by the Court. The Court will address this further at tomorrow's telephonic hearing and reserves the right to take further action given the noncompliance with its order. (mk) |
| Filing 58 SEALED RESPONSE by Morgan Stanley Smith Barney LLC to response in opposition to motion, #55 (Claydon, Jonathan) |
| Filing 57 SEALED RESPONSE by Morgan Stanley Smith Barney LLC to Response #54 (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)(Claydon, Jonathan) |
| Filing 56 MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to seal document #53 is granted. The plaintiff is directed to file complete and unredacted versions under seal and redacted versions in the public record. Mailed notice. (mma, ) |
| Filing 55 RESPONSE by Morgan Stanley Smith Barney LLCin Opposition to MOTION by Defendant Rajesh Gupta to quash or limit Subpoena to Wells Fargo Bank #51 , MOTION by Defendant Rajesh Gupta to quash or limit Subpoena to PNC Bank #50 - Redacted (Attachments: #1 Exhibit)(Claydon, Jonathan) |
| Filing 54 RESPONSE by Plaintiff Morgan Stanley Smith Barney LLC to motion to quash #48 , motion to seal document #53 (Claydon, Jonathan) |
| Filing 53 MOTION by Plaintiff Morgan Stanley Smith Barney LLC to seal document (Claydon, Jonathan) |
| Filing 52 MINUTE entry before the Honorable Matthew F. Kennelly: Response to motions to quash subpoenas to Wells Fargo Bank #51 and PNC Bank #50 is to be filed by 11/22/2021. Telephonic motion hearing is set for 11/24/2021 at 9:30 AM, using call-in number 888-684-8852, access code 746-1053. The party that served the subpoenas is directed to immediately advise the recipients of the subpoenas that compliance is to be held in abeyance pending a ruling by the Court on the motions to quash. (mk) |
| Filing 51 MOTION by Defendant Rajesh Gupta to quash or limit Subpoena to Wells Fargo Bank (Attachments: #1 Exhibit A)(Lederer, Caren) |
| Filing 50 MOTION by Defendant Rajesh Gupta to quash or limit Subpoena to PNC Bank (Attachments: #1 Exhibit A)(Lederer, Caren) |
| Filing 49 MINUTE entry before the Honorable Matthew F. Kennelly: Response to motion to quash subpoena #48 is to by filed by 11/19/2021. Telephone motion hearing is set for 11/24/2021 at 9:30 AM, using call-in number 888-684-8852, access code 746-1053. The party that served the subpoena is directed to immediately advise the recipient of the subpoena that compliance with the subpoena is to be held in abeyance pending a ruling by the Court on the motion to quash. (mk) |
| Filing 48 MOTION by Defendant Rajesh Gupta to quash Subpoena to West Suburban Bank (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Lederer, Caren) |
| Filing 47 CITATION to Discover Assets issued as to GROWTH DATA ENTERPRISES. (THIRD PARTY)(NO NOTICE) (nsf, ) |
| Filing 46 CITATION to Discover Assets issued as to RAJESH N. GUPTA (NO NOTICE). (nsf, ) |
| Filing 45 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 11/3/2021. Plaintiff's motion for leave to amend the citation to discovery assets #43 is granted. Defendant's response to the motion to avoid fraudulent transfer #41 is due 12/10/2021; plaintiff's reply is due 12/31/2021. A telephonic status and possible ruling on the motion hearing are set for 1/13/2022 at 8:45 a.m. The following call-in number will be used for the hearing: 888-684-8852 conference code 746-1053. Mailed notice. (mma, ) |
| Filing 44 ATTORNEY Appearance for Plaintiff Morgan Stanley Smith Barney LLC by Aaron Seth Klein (Klein, Aaron) |
| Filing 43 MOTION by Plaintiff Morgan Stanley Smith Barney LLC for leave to file / Amend Citation to Discover Assets (Attachments: #1 Exhibit A)(Claydon, Jonathan) |
| Filing 42 MINUTE entry before the Honorable Matthew F. Kennelly: This case is set for a telephonic status hearing on 11/3/2021 at 9:05 AM, to discuss setting a schedule for briefing plaintiff's motion to avoid transfer. The following call-in number will be used: 888-684-8852, access code 746-1053. The parties should wait for the case to be called before announcing themselves. The following must participate: counsel for plaintiff; and defendant or his attorney. Because the Court does not know whether defendant (Mr. Gupta) is currently represented by counsel, plaintiff's counsel is directed to promptly transmit a copy of this order to Mr. Gupta so that he is aware of the telephonic status hearing. (mk) |
| Filing 41 MOTION by Plaintiff Morgan Stanley Smith Barney LLC to Avoid Fraudulent Transfer of and For Turnover of Certain Real Property (Attachments: #1 Exhibit A-J)(Claydon, Jonathan) |
| Filing 40 CITATION to Discover Assets issued as to Nisha Gupta (Third party). (daj, ) |
| Filing 39 CITATION to Discover Assets issued as to Vijay Gupta, PNC Bank NA, and Om Gupta. (Attachments: #1 Notice of Citation Hearing)(lw, ) |
| Filing 38 CITATION to Discover Assets issued as to Sage Prince Holdings, LLC (Third Party), Rajesh Gupta. (No Notice Filed) (rc, ) |
| Filing 37 CITATION to Discover Assets issued as to Golan Christie Taglia LLP, Maduff & Maduff LLC. (All Third Party) (All No Notice Filed) (rc, ) |
| Filing 36 ATTORNEY Appearance for Plaintiff Morgan Stanley Smith Barney LLC by Martin S. Kedziora (Kedziora, Martin) |
| Filing 34 ANSWER OF THIRD PARTY RESPONDENT CITATION by E*TRADE Securities LLC as to Rajesh N. Gupta(mc, ) |
| Filing 33 CITATION to Discover Assets issued as to E*TRADE Securities LLC (Third Party) (No Notice). (mc, ) |
| Filing 32 RESPONSE by Defendant Rajesh Gupta to citation issued #23 (Attachments: #1 Certificate of Service)(Lederer, Caren) |
| Filing 29 AGREED PROTECTIVE ORDER signed by the Honorable Matthew F. Kennelly on 1/28/2021. (mk) |
| Filing 28 MINUTE entry before the Honorable Matthew F. Kennelly: Agreed motion for protective order #27 is granted. However, counsel did not send a Word version of the order to Judge Kennelly's proposed order e-mail address concurrently with the filing of the motion, as directed on Judge Kennelly's web page. They are to do so promptly. (mk) |
| Filing 27 MOTION by Defendant Rajesh Gupta for protective order (Agreed) (Attachments: #1 Exhibit A)(Lederer, Caren) |
| Filing 26 MINUTE entry before the Honorable Matthew F. Kennelly: Defendant's motion for extension of time to 1/20/2021 to respond to plaintiff's citation to discover assets is granted. (mk) |
| Filing 25 MOTION by Defendant Rajesh Gupta for extension of time to Respond to Citation (Attachments: #1 Exhibit Exhibit 1)(Lederer, Caren) |
| Filing 24 ATTORNEY Appearance for Defendant Rajesh Gupta by Caren A. Lederer (Lederer, Caren) |
| Filing 23 CITATION to Discover Assets issued as to Rajesh Gupta. (rc, ) |
| Filing 22 ENTERED JUDGMENT: Civil case terminated. Mailed notice. (mma, ) |
| Filing 21 MINUTE entry before the Honorable Matthew F. Kennelly: The Court directs entry of judgment confirming the arbitration award in favor of plaintiff Morgan Stanley Smith Barney, LLC in the amount of $1,965,075.83, consisting of the arbitration award of $1,829,115.18, post-award interest of $42,960.65, and attorney's fees of $93,000.00. Mailed notice. (mma, ) |
| Filing 20 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic hearing on motion held on 10/9/2020. Defendant's motion to stay #13 is denied for the reasons stated on the record. Petition to confirm arbitration and convert to judgment is granted. Judgment is to be entered in favor of the plaintiff confirming the arbitration award. The parties are directed to submit a Final Judgment Order to Judge Kennelly's proposed order email address by 10/13/2020. Mailed notice. (mma, ) |
| Filing 19 REPLY by Rajesh Gupta to response in opposition to motion #18 to Stay Proceedings (Maduff, Aaron) |
| Filing 18 RESPONSE by Morgan Stanley Smith Barney LLCin Opposition to MOTION by Defendant Rajesh Gupta to stay Opposed Motion to Stay Confirmation Proceedings Pending Settlement and Resolution of USERRA Arbitration #13 (Claydon, Jonathan) |
| Filing 17 MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 9/17/2020. Plaintiff's response to the defendant's motion to stay #13 , is to be filed by 9/25/2020; defendant's reply is due 10/2/2020. A telephonic status and ruling on the motion hearings are set for 10/9/2020 at 9:00 a.m. The following call-in number will be used for the hearings: 888-684-8852, access code 746-1053. Counsel should wait for the case to be called before announcing themselves. Mailed notice. (mma, ) |
| Filing 16 CERTIFICATE of Service by Daniel Gajda on behalf of Rajesh Gupta regarding attorney appearance #15 (Gajda, Daniel) |
| Filing 15 ATTORNEY Appearance for Defendant Rajesh Gupta by Daniel Gajda (Gajda, Daniel) |
| Filing 14 MINUTE entry before the Honorable Matthew F. Kennelly: The Court sets this case for a telephone status hearing on 9/17/2020 at 8:40 AM, using call-in number 888-684-8852, access code 746-1053. (mk) |
| Filing 13 MOTION by Defendant Rajesh Gupta to stay Opposed Motion to Stay Confirmation Proceedings Pending Settlement and Resolution of USERRA Arbitration (Maduff, Aaron) |
| Filing 12 ANSWER to Complaint by Rajesh Gupta(Maduff, Aaron) |
| Filing 11 MINUTE entry before the Honorable Matthew F. Kennelly: The telephone status hearing set for 9/1/2020 is vacated. Defendant is directed to file a written response to the petition to confirm arbitration award by 9/15/2020; plaintiff is directed to file a reply to the response by 9/25/2020. (mk) |
| Filing 10 STATUS Report (Joint) by Morgan Stanley Smith Barney LLC (Claydon, Jonathan) |
| Filing 9 ATTORNEY Appearance for Defendant Rajesh Gupta by Aaron Benjamin Maduff (Maduff, Aaron) |
| Filing 8 WAIVER OF SERVICE returned executed by Morgan Stanley Smith Barney LLC. (Claydon, Jonathan) |
| Filing 7 MINUTE entry before the Honorable Matthew F. Kennelly: By no later than 8/24/2020, the parties (or, if no defendant has yet appeared, the plaintiff(s)) are to file a joint status report that includes the following information: (1) the status of service of process upon each defendant; (2) a description of each party's claims and defenses; (3) details regarding any discussions concerning settlement, whether before or after the filing of the lawsuit; (4) a proposed discovery and pretrial schedule; and (5) any other matters that any party wishes to bring to the Court's attention. The case is set for a case management conference under Federal Rule of Civil Procedure 16 (a "status hearing," in local parlance) on 9/1/2020 at 9:25 a.m. The case management conference will be conducted by telephone, using the following call-in number: 888-684-8852, access code 746-1053. Plaintiff's counsel is directed to provide a copy of this order to any defendant that has not yet appeared by counsel via regular mail at the address at which the defendant has been or is to be served with process. (mk) |
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Filing 6
ORDER Fifth Amended General Order 20-0012 IN RE: CORONAVIRUS COVID-19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on July 10, 2020. This Order does not extend or modify any deadlines set in civil cases. No motions may be noticed for in-person presentment; the presiding judge will notify parties of the need, if any, for a hearing by electronic means or in-court proceeding. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 7/10/2020: Mailed notice. (Clerk10, Docket)
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| Filing 4 ATTORNEY Appearance for Plaintiff Morgan Stanley Smith Barney LLC by Lucia Lynn Marker-Moore (Marker-Moore, Lucia) |
| Filing 3 ATTORNEY Appearance for Plaintiff Morgan Stanley Smith Barney LLC by Jonathan Hale Claydon (Claydon, Jonathan) |
| Filing 2 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Morgan Stanley Smith Barney LLC (Claydon, Jonathan) |
| Filing 1 MISCELLANEOUS CASE by Morgan Stanley Smith Barney LLC Petition to Confirm Arbitration and Convert to Judgment Filing fee $ 47, receipt number 0752-17092752. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Civil Cover Sheet)(Claydon, Jonathan) |
| CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (acm, ) |
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Filing 5
ORDER Fourth Amended General Order 20-0012 IN RE: CORONAVIRUS COVID-19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on May 26, 2020. This Order does not extend or modify any deadlines set in civil cases. For non-emergency motions, no motion may be noticed for presentment on a date earlier than July 15, 2020. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 5/26/2020: Mailed notice (ec, )
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| Defendant: Rajesh Gupta | |
| Represented By: | Aaron Benjamin Maduff |
| Represented By: | Daniel Gajda |
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| Plaintiff: Morgan Stanley Smith Barney LLC | |
| Represented By: | Jonathan Hale Claydon |
| Represented By: | Lucia Lynn Marker-Moore |
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