Cosmopolitan Title Agency, LLC v. JP Morgan Chase Bank, N.A. et al
| Cosmopolitan Title Agency, LLC |
| JP Morgan Chase Bank, N.A. and PNC Bank, N.A. |
| 5:2022cv00286 |
| October 28, 2022 |
| US District Court for the Eastern District of Kentucky |
| Danny C Reeves |
| Matthew A Stinnett |
| Other Fraud |
| 28 U.S.C. § 1441 Petition for Removal |
| Plaintiff |
Docket Report
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This docket was last retrieved on September 22, 2023. A more recent docket listing may be available from PACER.
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Filing 29
REPLY BRIEF to #18 filed by PNC Bank, N.A.. (Bishop, John)
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Filing 27
SCHEDULING ORDER: 1. Within 14 days parties exchange information required by Rule 26(a)(1); 2. NLT 4/3/2023 plaintiff disclose expert witnesses. NLT 5/1/2023 defendant disclose same; 3. Supplementation under Rule 26(e) due within 30 days of discovery of new information but NLT 30 days prior to close of discovery; 4. Discovery due by 8/11/2023; 5. Discovery disputes referred to U.S. Magistrate Judge selected by random draw (Judge Matthew A. Stinnett); 6. All motions for extension of time referred to the undersigned for disposition; 7. Parties may not be agreement extend any deadlines set forth in this Scheduling Order or for responding to motions; 8. Plaintiff file motions to amend pleadings or join additional parties by 3/10/2023. Defendant file same by 4/10/2023; 9. Dispositive Motions and Daubert Motions due by 9/12/2023; 10. NLT 14 days prior to PTC, parties file: witness lists, exhibits lists, pretrial memorandum; 11. NLT 14 days prior to PTC parties pre-mark & number all exhibits; 12. NLT 14 days prior to PTC, counsel file aby objections to use depositions or to admissibility of exhibits; 13. Pretrial filings listed may be submitted to chambers by email; 14. NLT 7 days prior to PTC, parties submit to chambers a copy of each exhibit; 15. JURY TRIAL set for 1/23/2024 at 09:00 AM in LEXINGTON before Judge Danny C. Reeves, with counsel present at 8:30 a.m. (3 days); 16. FINAL PRETRIAL CONFERENCE set for 12/18/2023 at 10:00 AM in LEXINGTON before Judge Danny C. Reeves; 17. Parties directed to file a joint status report the 1st Monday of each month; 18. Parties directed to use services of private mediator in the event they seek to mediate. Signed by Judge Danny C. Reeves on 12/15/2022.(KM)cc: COR,D,JC
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Filing 26
JOINT REPORT of Rule 26(f) Planning Meeting. (Djordjevic, Gregory)
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Filing 25
RESPONSE in Opposition re #18 MOTION to Dismiss for failure to state a claim by PNC Bank, N.A. filed by Cosmopolitan Title Agency, LLC. (Gatlin, Jack)
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***FILE SUBMITTED TO CHAMBERS of Judge Danny C. Reeves for review: #22 Response to Order to Show Cause (KM)
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Filing 24
ORDER: It is ORDERED that the #23 Motion for Heryka R. Knoespel to Appear Pro Hac Vice for defendant PNC Bank, N.A. is GRANTED. Signed by Judge Danny C. Reeves on 11/30/2022. (KM)cc: COR and Heryka Knoespel by US Mail Modified on 11/30/2022 (STC).
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Filing 23
MOTION for Heryka R. Knoespel to Appear Pro Hac Vice by PNC Bank, N.A. ( Filing fee $125; receipt number AKYEDC-5422511) (Attachments: #1 Exhibit 1: NC Supreme Court Certificate of Good Standing, #2 Exhibit 2: Western District of NC Certificate of Good Standing, #3 Exhibit 3: Middle District of NC Certificate of Good Standing, #4 Proposed Order)(Bishop, John)
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Filing 22
RESPONSE TO ORDER TO SHOW CAUSE by PNC Bank, N.A. #21 filed by PNC Bank, N.A.. (Attachments: #1 Exhibit 1: Pro Hac Motion (State Court Action))(Bishop, John)
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BAR STATUS Check completed as to Heryka R. Knoespel re #23 MOTION for Heryka R. Knoespel to Appear Pro Hac Vice by PNC Bank, N.A. (Filing fee $125; receipt number AKYEDC-5422511). (KM)
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NOTICE FOR ATTORNEY TO REQUEST E-Filing Privileges to Heryka Knoespel: re #24 Order on Motion to Appear Pro Hac Vice. A Pro Hac Vice e-Filing request must be processed through your PACER account. IMPORTANT NOTICE: You are required to electronically file and receive electronic service from the court's automated Electronic Case Filing (ECF) system. If you are not a registered Filing User for the Court's ECF system, please visit the Court's website at www.kyed.uscourts.gov for information and/or training. For additional assistance contact the Help Desk at 1-866-485-6349. cc: COR and via U.S. Mail to Heryka Knoespel (KM)
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Filing 21
ORDER: On or before December 9, 2022, attorney Heryka Knoespel is directed to SHOW CAUSE for her failure to comply with Local Rule 83. Signed by Judge Danny C. Reeves on 11/29/22.(JLM)cc: COR and Knoespel by US Mail
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***FILE SUBMITTED TO CHAMBERS of Judge Reeves for review: #4 Notice to Attorney Heryka R. Knoespel - No response received. (STC)
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Filing 20
ANSWER to #16 Amended Complaint by JP Morgan Chase Bank, N.A..(Djordjevic, Gregory)
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Filing 19
MEMORANDUM in Support of Motion re #18 MOTION to Dismiss for failure to state a claim by PNC Bank, N.A. filed by PNC Bank, N.A.. (Bishop, John)
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Filing 18
MOTION to Dismiss for failure to state a claim by PNC Bank, N.A. (Attachments: #1 Proposed Order)(Bishop, John)
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Filing 17
ORDER: IT IS ORDERED that Defendant PNC Bank, N.A.'s #6 Motion to Dismiss is DENIED as MOOT. Signed by Judge Danny C. Reeves on 11/10/2022. (GLD)cc: COR
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Filing 16
AMENDED COMPLAINT against All Defendants, filed by Cosmopolitan Title Agency, LLC.(Gatlin, Jack)
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Filing 15
FRCP 7.1 DISCLOSURE STATEMENT by Cosmopolitan Title Agency, LLC. (Gatlin, Jack)
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NOTICE FOR ATTORNEY TO REQUEST E-Filing Privileges to Gregory C. Djordjevic: re Order on Motion to Appear Pro Hac Vice. A Pro Hac Vice e-Filing request must be processed through your PACER account. IMPORTANT NOTICE: You are required to electronically file and receive electronic service from the court's automated Electronic Case Filing (ECF) system. If you are not a registered Filing User for the Court's ECF system, please visit the Court's website at www.kyed.uscourts.gov for information and/or training. For additional assistance contact the Help Desk at 1-866-485-6349. cc: COR and via U.S. Mail to Gregory C. Djordjevic (KM)
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VIRTUAL ORDER: granting #13 MOTION for Gregory C. Djordjevic to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. (Filing fee $125; receipt number AKYEDC-5407850). The Court finds that the requirements for pro hac vice admission have been demonstrated by attorney Djordjevic. Signed by Judge Danny C. Reeves on 11/9/2022. (KM)cc: COR and Gregory C. Djordjevic by US Mail
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BAR STATUS Check completed as to Gregory C. Djordjevic re #13 MOTION for Gregory C. Djordjevic to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. (Filing fee $125; receipt number AKYEDC-5407850). (KM)
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Filing 14
VIRTUAL ORDER: granting #12 MOTION for Kyle D. Greene to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. (Filing fee $125; receipt number AKYEDC-5407784). The Court finds that the requirements for pro hac vice admission have been satisfied by attorney Greene. Signed by Judge Danny C. Reeves on 11/8/2022. (KM)cc: COR and Kyle Greene by U.S. mail
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Filing 13
MOTION for Gregory C. Djordjevic to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. ( Filing fee $125; receipt number AKYEDC-5407850) (Attachments: #1 Exhibit A - Affidavit of Gregory C. Djordjevic, #2 Proposed Order Proposed Order)(Lipcius, Jesse)
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Filing 12
MOTION for Kyle D. Greene to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. ( Filing fee $125; receipt number AKYEDC-5407784) (Attachments: #1 Exhibit A - Affidavit of Kyle D. Greene, #2 Proposed Order Proposed Order)(Lipcius, Jesse)
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NOTICE FOR ATTORNEY TO REQUEST E-Filing Privileges to Kyle Greene: re 14 Order on Motion to Appear Pro Hac Vice. A Pro Hac Vice e-Filing request must be processed through your PACER account. IMPORTANT NOTICE: You are required to electronically file and receive electronic service from the court's automated Electronic Case Filing (ECF) system. If you are not a registered Filing User for the Court's ECF system, please visit the Court's website at www.kyed.uscourts.gov for information and/or training. For additional assistance contact the Help Desk at 1-866-485-6349. cc: COR and via U.S. Mail to Kyle Greene (KM)
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BAR STATUS Check completed as to Kyle D. Greene re #12 MOTION for Kyle D. Greene to Appear Pro Hac Vice by JP Morgan Chase Bank, N.A. (Filing fee $125; receipt number AKYEDC-5407784). (KM)
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Filing 11
NOTICE TO ATTORNEY Kyle Greene by Clerk re: L.R. 83 - Attorney Admission procedures w/ a copy of L.R. 83.1 and 83.2 (KM)
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Filing 10
ORDER FOR MEETING AND REPORT: 1. w/in 30 days, parties conduct Rule 26(f) meeting; 2. counsel exchange Rule 26(a)(1) disclosures at time of meeting; 3. written joint report outlining proposed discovery plan due 10 days after meeting; consent forms attached. Signed by Judge Danny C. Reeves on 11/07/2022. (Attachments: #1 AO 85)(STC)cc: COR and Heryka Knoespel and Kyle Greene by U.S. mail. Modified on 11/7/2022 (KM).
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Filing 9
ANSWER to Complaint by JP Morgan Chase Bank, N.A..(Lipcius, Jesse)
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Filing 8
FRCP 7.1 DISCLOSURE STATEMENT by PNC Bank, N.A. identifying Corporate Parent PNC Financial Services Group, Inc. for PNC Bank, N.A... (Bishop, John)
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Filing 7
MEMORANDUM IN SUPPORT of #6 Motion to Dismiss for Failure to State a Claim filed by PNC Bank, N.A.. (Bishop, John)
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Filing 6
MOTION to Dismiss for failure to state a claim by PNC Bank, N.A. (Attachments: #1 Proposed Order Exhibit 1 - Proposed Order)(Bishop, John)
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Filing 5
FIRST FRCP 7.1 DISCLOSURE STATEMENT by JP Morgan Chase Bank, N.A. identifying Corporate Parent JPMorgan Chase & Co. for JP Morgan Chase Bank, N.A... (Lipcius, Jesse)
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Filing 4
NOTICE TO ATTORNEY Heryka R. Knoespel by Clerk re: L.R. 83 - Attorney Admission procedures w/ a copy of L.R. 83.1 and 83.2 (Attachments: #1 Rule 83.1, #2 Rule 83.2)(SAM)
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Filing 3
NOTICE OF DEFICIENCY RE: FAILURE TO FILE FRCP 7.1 DISCLOSURES to counsel of record, Jesse R. Lipcius. #1 Notice of Removal,,, has been filed by JP Morgan Chase Bank, N.A. without the required Rule 7.1 Disclosure statement. Rule 7.1 Disclosures must be filed within fourteen (14) calendar days. Failure to file the Disclosure Statement will cause the case to be submitted to the presiding judge for further action. cc: COR (SAM)
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Filing 1
NOTICE OF REMOVAL from Fayette Circuit Court, case number 22-CI-02773. ( Filing fee $402; receipt number AKYEDC-5399043), filed by JP Morgan Chase Bank, N.A.. (Attachments: #1 Exhibit A State Court Docket, #2 Exhibit B Complaint, #3 Exhibit C Summons (PNC Bank), #4 Exhibit D Summons (JPMC Bank), #5 Exhibit E Financial Transaction Report, #6 Exhibit F Receipt, #7 Exhibit G Return of Service, #8 Exhibit H JPMC Motion for Leave to Plead, #9 Exhibit I Notice of Hearing, #10 Exhibit J Summons (PNC Bank), #11 Exhibit K Financial Transaction Report, #12 Exhibit L Receipt, #13 Exhibit M PNC Motion to Dismiss, #14 Exhibit N PNC Memo in Support of Motion to Dismiss, #15 Exhibit O Motion to Appear Pro Hac Vice, #16 Exhibit P Invoice, #17 Exhibit Q Pro Hac Vice Receipt, #18 Exhibit R Amended 2022 Annual Report for LLC, #19 Exhibit S LLC Amendment)(SAM)
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Conflict Check run. (SAM)
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