Key Outdoor Inc v. Briggs et al
Plaintiff: Key Outdoor Inc and Key Outdoor Inc.
Defendant: Wayne Briggs, Jr, Motion Media Inc and Motion Media Inc.
Case Number: 3:2019cv00035
Filed: April 24, 2019
Court: US District Court for the Southern District of Iowa
Presiding Judge: Helen C Adams
Referring Judge: Rebecca Goodgame Ebinger
Nature of Suit: Contract: Other
Cause of Action: 28:1332
Jury Demanded By: None
Docket Report

This docket was last retrieved on June 3, 2019. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 3, 2019 Filing 69 STATUS REPORT (JOINT) REGARDING ELECTRONICALLY STORED INFORMATION (ESI) by Wayne Briggs, Jr, Motion Media Inc.. (Lillwitz, Timothy)
May 28, 2019 Filing 68 TEXT ORDER granting #66 Motion to Withdraw as Attorney. Attorney Misty J. Cygan terminated. Signed by Chief Magistrate Judge Helen C. Adams on 5/28/2019. (imk)
May 28, 2019 Filing 67 TEXT ORDER granting #65 Motion to Withdraw as Attorney. Attorney George S. Bellas terminated. Signed by Chief Magistrate Judge Helen C. Adams on 5/28/2019. (imk)
May 28, 2019 Filing 66 MOTION to Withdraw as Attorney by Wayne Briggs, Jr, Motion Media Inc..Motions referred to Helen C. Adams. Responses due by 6/11/2019. (Cygan, Misty)
May 28, 2019 Filing 65 MOTION to Withdraw as Attorney by Wayne Briggs, Jr, Motion Media Inc..Motions referred to Helen C. Adams. Responses due by 6/11/2019. (Bellas, George)
May 28, 2019 Filing 64 TEXT ORDER granting #63 Motion. The parties' Joint Status Report on ESI is dueJune 3, 2019. Signed by Chief Magistrate Judge Helen C. Adams on 5/28/2019. (imk)
May 24, 2019 Filing 63 Joint MOTION TO EXTEND DEADLINE TO FILE JOINT STATUS REPORT ON ESI by Wayne Briggs, Jr, Motion Media Inc..Motions referred to Helen C. Adams. Responses due by 6/7/2019. (Lillwitz, Timothy)
May 23, 2019 Filing 62 TEXT ORDER granting #61 Motion to Withdraw as Attorney. Attorney Steven J Crowley terminated. Signed by Chief Magistrate Judge Helen C. Adams on 5/23/2019. (imk)
May 23, 2019 Filing 61 MOTION to Withdraw as Attorney by Wayne Briggs, Jr.Motions referred to Helen C. Adams. Responses due by 6/6/2019. (Crowley, Steven)
May 21, 2019 Filing 60 NOTICE of Appearance by Timothy N Lillwitz on behalf of All Defendants (Lillwitz, Timothy)
May 20, 2019 Filing 59 STATEMENT of Interest / Corporate Disclosure by Key Outdoor Inc.. (Kelly, Timothy)
May 15, 2019 Filing 58 TEXT ORDER granting #57 Motion for Leave to Appear Pro Hac Vice Timothy M. Kelly. Signed by Chief Magistrate Judge Helen C. Adams on 5/15/2019. (kjw)
May 14, 2019 Filing 57 MOTION for Leave to Appear Pro Hac Vice Receipt Number: 0863-3819891 Fee paid in the amount of $100. by Key Outdoor Inc.. (Armentrout, Randall)
May 14, 2019 Filing 56 NOTICE of Appearance by Randall D Armentrout on behalf of All Plaintiffs (Armentrout, Randall)
May 8, 2019 Filing 55 CERTIFICATE OF SERVICE by Wayne Briggs, Jr, Motion Media Inc. (Bellas, George)
May 8, 2019 Opinion or Order Filing 54 ORDER SETTING STATUS CONFERENCES. See order for more particulars. Status Conference set for 8/8/2019 11:00 AM in Phone Hearing before Chief Magistrate Judge Helen C. Adams. Status Conference set for 10/8/2019 11:00 AM in Phone Hearing before Chief Magistrate Judge Helen C. Adams. Status Conference set for 12/9/2019 11:00 AM in Phone Hearing before Chief Magistrate Judge Helen C. Adams. Signed by Chief Magistrate Judge Helen C. Adams on 5/8/2019. (imk)
May 8, 2019 Opinion or Order Filing 53 ORDER FOR STATUS REPORT ON ESI. See order for more particulars. Status Report due by 5/24/2019. Signed by Chief Magistrate Judge Helen C. Adams on 5/8/2019. (imk)
May 8, 2019 Opinion or Order Filing 52 ORDER REGARDING FINAL PRETRIAL CONFERENCE REQUIREMENTS. See order for particulars. Signed by Chief Magistrate Judge Helen C. Adams on 5/8/2019. (imk)
May 8, 2019 Filing 51 SCHEDULING AND TRIAL SETTING ORDER. See order for more particulars. Initial Disclosures Deadline 5/15/2019. Motions to Add Parties due by 8/1/2019. Motions to Amend Pleadings due by 8/1/2019. Defendants Expert Witness Disclosures due by 9/1/2019. Dispositive Motion Deadline 12/1/2019. Final Pretrial Conference set for 2/19/2020 11:00 AM in Des Moines Courthouse before Judge Rebecca Goodgame Ebinger. Plaintiffs Expert Witness Disclosures due by 9/1/2019. Discovery Deadline 11/1/2019. Bench Trial set for 3/9/2020 09:00 AM in Davenport Courthouse before Judge Rebecca Goodgame Ebinger. Estimated length of three days.. Signed by Chief Magistrate Judge Helen C. Adams on 5/8/2019. (imk)
May 8, 2019 Filing 50 TEXT MINUTE ENTRY for proceedings held before Chief Magistrate Judge Helen C. Adams: Telephonic Status Conference held on 5/8/2019. Attorney Timothy Kelly appeared for plaintiff. Attorneys George Bellas and Misty Cygan appeared for defendant. Status of case discussed. Separate orders to follow. Total Court Time: 25 minutes. (imk)
May 6, 2019 Filing 49 TEXT ORDER granting #47 Motion for Leave to Appear Pro Hac Vice George S. Bellas; granting #48 Motion for Leave to Appear Pro Hac Vice Misty J. Cygan. Signed by Chief Magistrate Judge Helen C. Adams on 5/6/2019. (tae)
May 6, 2019 Filing 48 MOTION for Leave to Appear Pro Hac Vice Receipt Number: 0863-3811495 Fee paid in the amount of $100. by Wayne Briggs, Jr, Motion Media Inc.. (Cygan, Misty)
May 6, 2019 Filing 47 MOTION for Leave to Appear Pro Hac Vice Receipt Number: 0863-3811477 Fee paid in the amount of $100. by Wayne Briggs, Jr, Motion Media Inc.. (Bellas, George)
May 3, 2019 Filing 46 NOTICE of Appearance by Steven J Crowley on behalf of All Defendants (Crowley, Steven)
May 2, 2019 Filing 45 TEXT ORDER SETTING STATUS CONFERENCE. A Telephonic Status Conference is set for 5/8/2019 at 11:00 AM before Chief Magistrate Judge Helen C. Adams. Counsel should call 1-877-336-1829 and enter access code 1176783 at the prompt to be joined with the call. Signed by Chief Magistrate Judge Helen C. Adams on 5/2/2019. (imk)
April 25, 2019 Filing 44 CLERK'S NOTICE TO ATTORNEYS/PRO SE PARTY: Your case has been opened in the SDIA and assigned a new case number. Please review the attached document and forms for compliance with this Court's Local Rules. Rule 16 Notice of Dismissal set for 7/24/2019. Mailed and emailed to counsel. (kjw)
April 24, 2019 Judge Rebecca Goodgame Ebinger and Chief Magistrate Judge Helen C. Adams added. (kjw)
April 24, 2019 Filing 43 Case transferred in from District of Illinois Central; Case Number 2:19-cv-02028. Original file certified copy of transfer order and docket sheet received.
April 24, 2019 Opinion or Order Filing 42 ORDER entered by Judge Colin Stirling Bruce on 4/24/19. Defendants' Renewed Motion to Transfer Venue #30 is GRANTED. This case is hereby transferred to the Southern District of Iowa.This case is terminated. (TC, ilcd)
April 16, 2019 Opinion or Order TEXT ORDER entered by Magistrate Judge Eric I. Long on 4/16/2019. On April 15, 2019, Defendants filed their Rule 26(a)(1) initial disclosures with the Court #40 . Pursuant to Local Rule 26.3(A) discovery, including disclosures under Rule 26, must not be filed with the Court. Accordingly, the Clerk is directed to strike docket entry #40 . (KE, ilcd)
April 15, 2019 Filing 41 CERTIFICATE OF SERVICE by Wayne Briggs, Jr, Motion Media Inc (Cygan, Misty)
April 15, 2019 Filing 40 STRICKEN - REPORT of Rule 26(f) Planning Meeting by Wayne Briggs, Jr, Motion Media Inc. (Cygan, Misty) Modified on 4/16/2019 to show stricken pursuant to text order entered 4/16/2019. (KE, ilcd).
April 5, 2019 Filing 39 Reply by Key Outdoor Inc re #36 Answer to Complaint Reply to Amended Affirmative Defenses.. (Kelly, Timothy)
March 26, 2019 Set/Reset Hearings: Status Conference set for 4/29/19 at 10:45 AM by telephone from Urbana (court will place call) before Magistrate Judge Eric I. Long. (TC, ilcd)
March 26, 2019 Filing 38 Minute Entry for proceedings held 3/26/19 before Magistrate Judge Eric I. Long. Appearance for Plaintiff by Tim Kelly. Appearance for Defendant by George Bellas. Rule 16 conference held by telephone. Plan approved; dates set. Consent to magistrate judge discussed (form attached). ADR options offered, including court-hosted settlement conference. The following discovery deadlines are set: Initial disclosure due by 4/15/19; Amended pleadings due by 7/1/19; Joinder of parties due by 7/1/19; Plaintiff's expert disclosure and expert reports due by 8/1/19; Plaintiff shall make experts available for deposition by 10/1/19; Defendant's expert disclosure and expert reports due by 8/1/19; Defendant shall make experts available for deposition by 10/1/19; Discovery, including deposition of experts, due by 10/1/19; Case dispositive motions due by 11/1/19. Final Pretrial Conference is scheduled for 2/24/20 at 1:30 PM by personal appearance before Judge Colin S. Bruce, Courtroom A, Urbana. Bench Trial is scheduled for 3/10/20 at 9:00 AM before Judge Colin S. Bruce, Courtroom A, Urbana, (3 days). Status Hearing set before Judge Eric I. Long on 4/29/19 at 10:45 AM by telephone to discuss possible court hosted mediation or summary trial. (Tape #UR-B 11:19 AM.) (TC, ilcd)
March 20, 2019 Opinion or Order TEXT ORDER entered by Judge Colin Stirling Bruce on 3/20/19 finding Notice of Motion #35 STRICKEN as unnecessary. (TC, ilcd)
March 19, 2019 Opinion or Order TEXT ORDER entered by Magistrate Judge Eric I. Long on 3/19/19. This Court has reviewed the parties' Report of Rule 26(f) Planning Meeting #37 and pursuant to the Order #26 scheduling this matter for a Rule 16 hearing conference by personal appearance on March 26, 2019, at 11:15 A.M., the matter is hereby converted from personal appearance to telephone conference on the same date at the same time. The Court will initiate the call. (TC, ilcd)
March 19, 2019 Filing 37 DISCOVERY PLAN - PROPOSED/Report of Rule 26(f)Planning Meeting by Key Outdoor Inc. (Kelly, Timothy)
March 19, 2019 Filing 36 DEFENDANTS' AMENDED ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S COMPLAINT by Wayne Briggs, Jr, Motion Media Inc. (TC, ilcd)
March 19, 2019 Opinion or Order TEXT ORDER entered by Magistrate Judge Eric I. Long on 3/19/19. On February 28, 2019, Defendants filed a Motion for Leave to File Amended Answer #29 . Plaintiff's deadline to oppose the motion was March 14, 2019. As no opposition was filed, the Court will presume Plaintiff does not oppose the Motion. See L.R. 7.1(b)(2). Accordingly, Defendants' Motion for Leave to File Amended Answer #29 is GRANTED. The Clerk is directed to file Defendants' Amended Answer and Affirmative Defenses to Plaintiff's Complaint [29-1] instanter. (TC, ilcd)
March 15, 2019 Opinion or Order TEXT ORDER entered by Judge Colin Stirling Bruce on 3/15/2019. Plaintiff's Motion for Leave to File Response to Motion to Transfer Venue Instanter #34 is GRANTED. The court considers the Response #32 to be properly filed. (JMB, ilcd)
March 15, 2019 Filing 35 **STRICKEN** NOTICE of Motion (Kelly, Timothy) Modified on 3/20/2019 as unnecessary (TC, ilcd).
March 15, 2019 Filing 34 MOTION for Leave to File Response to Motion to Transfer Venue Instanter by Plaintiff Key Outdoor Inc. Responses due by 3/29/2019 (Kelly, Timothy)
March 15, 2019 Filing 33 NOTICE Notice of Filing re #32 Response to Motion (Kelly, Timothy)
March 14, 2019 Filing 32 RESPONSE to Motion re #30 MOTION to Transfer Case filed by Plaintiff Key Outdoor Inc. (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2, #3 Exhibit Exhibit 3, #4 Exhibit Exhibit 4)(Kelly, Timothy)
March 1, 2019 Set/Reset Deadlines: Responses due by 3/14/2019 as to #30 MOTION to Transfer Case. (Filed as MEMORANDUM of Law in Support of Defendants' Motion to Transfer Venue by Wayne Briggs, Jr, Motion Media Inc.) (KM, ilcd)
March 1, 2019 Filing 31 CERTIFICATE of Service. (Cygan, Misty)
February 28, 2019 Filing 30 **MOTION** MEMORANDUM of Law in Support of Defendants' Motion to Transfer Venue by Wayne Briggs, Jr, Motion Media Inc. (Attachments: #1 Exhibit Exhibit A) Responses due by 3/14/2019 (Cygan, Misty) Modified on 3/1/2019 to correct to motion event and add response deadline (KM, ilcd). Modified on 3/4/19 to add the word **MOTION** (TC, ilcd).
February 28, 2019 Filing 29 MOTION for Leave to File Amended Answer by Defendants Wayne Briggs, Jr, Motion Media Inc. Responses due by 3/14/2019 (Attachments: #1 Exhibit Exhibit A)(Cygan, Misty)
February 13, 2019 Filing 28 NOTICE Notice of Filing re #27 Affirmative Defenses (Leslie, William)
February 13, 2019 Filing 27 AFFIRMATIVE DEFENSES Plaintiff's Reply to Affirmative Defenses by Plaintiff Key Outdoor Inc. (Leslie, William)
February 12, 2019 Opinion or Order TEXT ORDER entered by Magistrate Judge Eric I. Long on 2/12/19. On December 12, 2018, Defendants filed a Motion to Transfer Venue #13 asking the Court to transfer this case to the Southern District of Iowa. Plaintiff's Response #19 indicated that Plaintiff's preferred venue was the Central District of Illinois. On February 6, 2019, Judge Chang entered an Order #23 noting that neither party asked that the case remain in the Northern District of Illinois and stated that rather than definitively decide the transfer motion between the Central District of Illinois and the Southern District of Iowa, the Court would transfer the case to the Central District of Illinois, which is more familiar with its own judicial resources. Judge Chang gave Defendants leave to review their transfer motion in this Court. Accordingly, Defendants are given until the close of business on February 28, 2019, to renew their Motion to Transfer Venue, if they wish to do so. (Miscellaneous Deadline set for 2/28/19.) (TC, ilcd)
February 8, 2019 Opinion or Order Filing 26 ORDER setting Rule 16 Scheduling Conference entered by Magistrate Judge Eric I. Long on 2/8/2019. Rule 16 Scheduling Conference set for 3/26/2019 at 11:15 AM in Courtroom B in Urbana before Magistrate Judge Eric I. Long. See written order.(KE, ilcd)
February 6, 2019 Filing 25 Case transferred in from District of Illinois Northern; Case Number 1:18-cv-07206.
February 6, 2019 Filing 24 TRANSFERRED to the USDC Central District of Illinois, Urbana Division the electronic record. (sxb, )
February 6, 2019 Opinion or Order Filing 23 ORDER: As the Court explained and predicted at the status hearing, R. 18, in the parties' dueling transfer requests, R. 13, R. 19, neither side actually asks for the case to remain in the Northern District of Illinois. Plaintiff is a Kankakee corporation that, for some reason, filed the state lawsuit in Cook County. Rather than definitively decide the transfer motion as between the Southern District of Iowa and the Central District of Illinois, it is appropriate to transfer the case to the Central District of Illinois, which is more familiar with its judicial resources (one of the Section 1404 factors) than this Court. It would be odd if this Court could bind the Central District of Illinois. Defendants may renew their transfer motion in the Central District of Illinois. The Clerk of the Court shall transfer the case forthwith to the Central District of Illinois, Urbana Division. The status hearing of 02/07/2019 is vacated. Signed by the Honorable Edmond E. Chang on 2/6/2019. Mailed notice. (sxb, )
January 23, 2019 Filing 22 REPLY by Defendants Wayne Briggs, Motion Media, Inc. to memorandum in support of motion #13 to Transfer Venue (Bellas, George)
January 23, 2019 Filing 21 ANSWER to Complaint by Wayne Briggs, Motion Media, Inc. (Attachments: #1 Exhibit Exhibit A)(Bellas, George)
January 9, 2019 Filing 20 NOTICE by All Plaintiffs re Response #19 (Scannell, Thomas)
January 9, 2019 Filing 19 RESPONSE by Plaintiff Key Outdoor Inc. to memorandum in support of motion #13 (Attachments: #1 Exhibit)(Scannell, Thomas)
December 12, 2018 Filing 18 MINUTE entry before the Honorable Edmond E. Chang: Status and motion hearing held on Defendants' motion to transfer venue #13 . The Court explained that, if there is no viable federal venue in NDIL, then it would make sense for CDIL (Plaintiff's business is located in Kankakee County) to decide the transfer motion for itself. Plaintiff's response to the motion to transfer #13 due 01/09/2019, including whether there is venue in NDIL. Defendants' reply due 01/23/2019, and must also address whether there is venue in NDIL. But if truly there is no viable basis for venue here, then Defendants should report that conclusion as quickly as possible so that the case can be transferred to CDIL for decision on S.D. Iowa versus CDIL. Defendants' answer to the complaint due 01/23/2019. Status hearing set for 02/07/2019 at 8:30 a.m.Emailed notice (slb, )
December 11, 2018 Filing 17 MINUTE entry before the Honorable Edmond E. Chang:On the Court's own initiative, the status and motion hearing of 8:30 a.m. on 12/12/2018 is reset to 8:45 a.m. on the same date. Emailed notice (slb, )
December 7, 2018 Filing 16 Rule 26(f) Report for Mandatory Initial Discovery Pilot (MIDP) Joint Initial Status Report, filed by Plaintiff Key Outdoor Inc.. (Kelly, Timothy)
December 7, 2018 Filing 15 NOTICE of Motion by George S. Bellas for presentment of before Honorable Edmond E. Chang on 12/12/2018 at 08:30 AM. (Bellas, George)
December 7, 2018 Filing 14 EXHIBIT by Defendants Wayne Briggs, Motion Media, Inc. regarding memorandum in support of motion #13 (Bellas, George)
December 7, 2018 Filing 13 MEMORANDUM and Motion in Support of Defendants' Motion to Transfer Venue (Bellas, George)
November 15, 2018 Filing 12 AMENDED complaint, #1 Amended Notice of Removal (Bellas, George)
November 2, 2018 Filing 11 MINUTE entry before the Honorable Edmond E. Chang:The Court has reviewed the notice of removal, R. 1, and issues the following jurisdictional inquiry. Defendants have removed this case from the Circuit Court of Cook County, relying on diversity jurisdiction, 28 U.S.C. 1332, for subject matter jurisdiction. R. 1 para. 2. The removing party has the burden of establishing jurisdiction. Carroll v. Stryker Corp., 658 F.3d 675, 680 (7th Cir. 2011). Defendants allege that plaintiff is an Illinois corporation with its principal place of business in Illinois. Id. para. 5 (citing Exh. B, State Court Compl. para. 1). Defendants then note that the complaint allegest that Defendant Wayne Briggs, Jr. "is a natural person residing in Iowa." Id. para. 6 (citing State Court Compl. para. 2). But the *citizenship* of the partiesas distinct from residencyis what matters. Hunter v. Amin, 583 F.3d 486, 491 (7th Cir. 2009). Defendants shall either amend the notice of removal by 11/16/2018 with the necessary allegation (if it can do so in good faith), or file a memorandum by that date explaining why this case should not be remanded to the Circuit Court of Cook County for lack of subject matter jurisdiction. Emailed notice (slb, )
October 31, 2018 Filing 10 ATTORNEY Appearance for Plaintiff Key Outdoor Inc. by Thomas Joseph Scannell (Scannell, Thomas)
October 31, 2018 Filing 9 ATTORNEY Appearance for Plaintiff Key Outdoor Inc. by William D. Leslie (Leslie, William)
October 31, 2018 Filing 8 ATTORNEY Appearance for Plaintiff Key Outdoor Inc. by Timothy Michael Kelly (Kelly, Timothy)
October 31, 2018 Filing 7 MINUTE entry before the Honorable Edmond E. Chang:Initial status hearing set for 12/12/2018 at 8:30 a.m. The parties must file a joint initial status report with the content described in the attached status report requirements at least 3 business days before the initial status hearing. Plaintiff must still file the report even if not all Defendants have been served or have responded to requests to craft a joint report. Because the Procedures are occasionally revised, counsel must read them anew even if counsel has appeared before Judge Chang in other cases. Emailed notice (Attachments: #1 Status Report Requirements) (slb, )
October 31, 2018 Filing 6 ATTORNEY Appearance for Defendants Wayne Briggs, Motion Media, Inc. by Misty J. Cygan (Cygan, Misty)
October 31, 2018 Filing 5 ATTORNEY Appearance for Defendants Wayne Briggs, Motion Media, Inc. by George S. Bellas (Bellas, George)
October 31, 2018 Filing 4 CIVIL Cover Sheet (Bellas, George)
October 31, 2018 Filing 3 MAILED Notice of Removal letter to counsel of record (sxb, )
October 31, 2018 Filing 2 NOTICE TO THE PARTIES - The Court is participating in the Mandatory Initial Discovery Pilot (MIDP). The key features and deadlines are set forth in this Notice which includes a link to the (MIDP) Standing Order and a Checklist for use by the parties. In cases subject to the pilot, all parties must respond to the mandatory initial discovery requests set forth in the Standing Order before initiating any further discovery in this case. Please note: The discovery obligations in the Standing Order supersede the disclosures required by Rule 26(a)(1). Any party seeking affirmative relief must serve a copy of the following documents (Notice of Mandatory Initial Discovery and the Standing Order) on each new party when the Complaint, Counterclaim, Crossclaim, or Third-Party Complaint is served. (sxb, )
October 30, 2018 CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (rc, )
October 29, 2018 Filing 1 NOTICE of Removal filed by Motion Media, Inc. and Wayne Briggs; Filing fee $400, receipt number 0752-15115147. (Attachments: #1 Exhibit Cook County Circuit Court Summons, #2 Exhibit Cook County Circuit Court Complaint #3 Exhibit Cook County Circuit Court Notice of Filing Notice of Removal)(Bellas, George) (Docket text modified by Clerks' Office) (sxb, ). Modified on 2/6/19 to identify Exhibits (TC, ilcd).

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Plaintiff: Key Outdoor Inc
Represented By: Thomas Joseph Scannell
Represented By: Timothy M Kelly
Represented By: William D Leslie
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Plaintiff: Key Outdoor Inc.
Represented By: Randall D Armentrout
Represented By: Timothy M Kelly
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Defendant: Wayne Briggs, Jr
Represented By: Misty J Cygan
Represented By: George S Bellas
Represented By: Timothy N Lillwitz
Represented By: Misty J. Cygan
Represented By: Steven J Crowley
Represented By: George S. Bellas
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Defendant: Motion Media Inc
Represented By: Misty J Cygan
Represented By: George S Bellas
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Defendant: Motion Media Inc.
Represented By: Timothy N Lillwitz
Represented By: Misty J. Cygan
Represented By: Steven J Crowley
Represented By: George S. Bellas
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