Ramos et al v. ZK Technology LLC et al
| Richard Ramos and Pavel Balaz |
| ZK Technology LLC and ZKTeco USA LLC |
| 1:2021cv02074 |
| April 16, 2021 |
| US District Court for the Northern District of Illinois |
| Andrea R Wood |
| P.I.: Other |
| 28 U.S.C. § 1332 |
| None |
Docket Report
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| Filing 21 MINUTE entry before the Honorable Andrea R. Wood: Defendant has filed a motion to dismiss this action for lack of personal jurisdiction #18 . The parties have advised the Court by joint emailed request that they desire to conduct limited discovery regarding personal jurisdiction prior to proceeding with briefing of the motion. Accordingly, the Court sets the following schedule. Plaintiff shall serve written discovery requests upon Defendant solely regarding matters related to personal jurisdiction by 6/11/2021. Defendant shall respond to Plaintiff's discovery requests by 7/12/2021. Plaintiff's jurisdictional discovery shall be limited to no more than ten (10) interrogatories and ten (10) requests for production. Plaintiff may also serve a Rule 30(b)(6) deposition notice covering only topics necessary to determine personal jurisdiction. All jurisdictional discovery, including any Rule 30(b)(6) deposition, must be completed by 8/9/2021. As stipulated by the parties, Defendant has not waived any jurisdictional or other defenses by agreeing to respond to jurisdictional discovery requested by Plaintiff. Nor has Defendant waived any objection to the scope or subject matter of Plaintiff's jurisdictional discovery. The initial telephonic status hearing set for 6/9/2021 is stricken and reset for 8/12/2021 at 9:30 AM. The Court will set a schedule for the completion of briefing of Defendant's motion at the telephonic status hearing. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice (aw,) |
| Filing 20 MINUTE entry before the Honorable Andrea R. Wood: The parties having filed a stipulation of partial dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii) #17 , all claims against Defendant ZKTeco USA LLC and Plaintiff Ramos's claims against Defendant ZK Technology LLC are dismissed without prejudice. Defendants' unopposed motion for extension of time to respond to complaint #16 is granted. Defendant ZK Technology LLC's motion to dismiss for lack of personal jurisdiction #18 is deemed timely filed. The parties may jointly email a proposed briefing schedule for the motion to the courtroom deputy (David_lynn@ilnd.uscourts.gov) by 5/28/2021. If the parties do not propose a schedule, the Court will set one during the initial status hearing on 6/9/20201. Mailed notice (dal, ) |
| Filing 19 MEMORANDUM by ZK Technology LLC in support of motion to dismiss/lack of jurisdiction #18 (Attachments: #1 Exhibit A - Declaration of Jaimin Shah)(Dean, Christopher) |
| Filing 18 MOTION by Defendant ZK Technology LLC to dismiss for lack of jurisdiction Motion to Dismiss for Lack of Personal Jurisdiction (Dean, Christopher) |
| Filing 17 STIPULATION of Partial Dismissal (Dean, Christopher) |
| Filing 16 MOTION by Defendants ZK Technology LLC, ZKTeco USA LLC for extension of time Unopposed Motion for Extension of Time to Respond to Complaint (Dean, Christopher) |
| Filing 15 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ZKTeco USA LLC and Rule 7.1 Disclosure Statement (Dean, Christopher) |
| Filing 14 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ZK Technology LLC and Rule 7.1 Disclosure Statement (Dean, Christopher) |
| Filing 13 ATTORNEY Appearance for Defendant ZKTeco USA LLC by Christopher Graham Dean (Dean, Christopher) |
| Filing 12 ATTORNEY Appearance for Defendant ZKTeco USA LLC by Jacob Daniel Radecki (Radecki, Jacob) |
| Filing 11 MINUTE entry before the Honorable Andrea R. Wood: Telephonic initial status hearing set for 6/9/2021 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. The parties are directed to meet and conduct a planning conference pursuant to Federal Rule of Civil Procedure 26(f). At least seven days before the initial status hearing, the parties shall file a joint written status report, not to exceed five pages in length. The initial status report shall provide the information described on the Court's website at www.ilnd.uscourts.gov under District Judges, Judge Andrea R. Wood, Initial Status Conference. Mailed notice (dal, ) |
| Filing 10 ATTORNEY Appearance for Plaintiffs Pavel Balaz, Richard Ramos by Mara Ann Baltabols (Baltabols, Mara) |
| Filing 9 ATTORNEY Appearance for Plaintiffs Pavel Balaz, Richard Ramos by David J. Fish (Fish, David) |
| Filing 8 MAILED notice of removal letter to plaintiffs counsel of record. (nsf, ) |
| Filing 7 ATTORNEY Appearance for Plaintiffs Pavel Balaz, Richard Ramos by Megan Shannon (Shannon, Megan) |
| Filing 6 ATTORNEY Appearance for Plaintiffs Pavel Balaz, Richard Ramos by James B. Zouras (Zouras, James) |
| CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (jg, ) |
| Filing 5 ATTORNEY Appearance for Plaintiffs Pavel Balaz, Richard Ramos by Ryan F Stephan (Stephan, Ryan) |
| Filing 4 ATTORNEY Appearance for Defendant ZK Technology LLC by Christopher Graham Dean (Dean, Christopher) |
| Filing 3 ATTORNEY Appearance for Defendant ZK Technology LLC by Jacob Daniel Radecki (Radecki, Jacob) |
| Filing 2 CIVIL Cover Sheet (Radecki, Jacob) |
| Filing 1 NOTICE of Removal from Circuit Court of Cook County, Illinois, case number (2021CH00996) filed by ZK Technology LLC Filing fee $ 402, receipt number 0752-18136416. (Attachments: #1 Exhibit A - Declaration of Manish Dalal, #2 Exhibit B - Declaration of Jaimin Shah, #3 Exhibit C - Complaint)(Radecki, Jacob) |
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