Total Safety U.S., Inc. et al v. Code Red Safety & Rental, LLC et al
| Total Safety U.S., Inc. and Total Safety On-Site Safety Services, Inc. |
| Turnaround Logistics, LLC, Todd Meyer and Code Red Safety & Rental, LLC |
| 2:2019cv12953 |
| October 4, 2019 |
| US District Court for the Eastern District of Louisiana |
| Dana Douglas |
| Martin LC Feldman |
| Other Statutory Actions |
| 18 U.S.C. § 1030 |
| Both |
Docket Report
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This docket was last retrieved on November 27, 2019. A more recent docket listing may be available from PACER.
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| Filing 49 ANSWER to #1 Complaint, with Jury Demand and Affirmative Defenses by Todd Meyer.(Trapani, Paul) Modified text on 11/27/2019 (jeg). |
| Filing 48 ANSWER to #1 Complaint, by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC.(Anderson, Jeremiah) Modified text on 11/27/2019 (jeg). |
Filing 47
ORDER AND REASONS - IT IS ORDERED that #32 Motion to Dismiss for Failure to State a Claim is GRANTED IN PART AND DENIED IN PART. The Motion is GRANTED IN PART as to any claims Total Safety may be asserting against Code Red and Turnaround Logistics for Todd Meyer's alleged violation of the non-solicitation provision of the Confidentiality and Non-Solicitation Agreement, and DENIED, IN PART, as to all other claims. Signed by Judge Martin L.C. Feldman on 11/13/2019. (sa)
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Filing 46
ORDER AND REASONS - IT IS ORDERED that Meyer's Rule 12(b)(6) #29 Motion to dismiss is GRANTED, and Total Safety's breach-of-contract claim is DISMISSED with prejudice, as set forth herein. Signed by Judge Martin L.C. Feldman on 11/6/2019. (sa)
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Filing 45
ORDER - IT IS ORDERED that the hearing on Code Red Safety & Rental, LLC and Turnaround Logistics, LLC's #32 joint motion to dismiss is hereby CONTINUED to November 13, 2019, on the papers. Signed by Judge Martin L.C. Feldman on 11/5/2019.(sa)
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| Filing 44 REPLY to Response to Motion filed by Todd Meyer re #29 MOTION to Dismiss for Failure to State a Claim. (ko) |
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Filing 43
ORDER granting #40 Motion for Leave to File Reply to Plaintiff's Opposition to Motion to Dismiss. Signed by Judge Martin L.C. Feldman on 11/5/19. (ko)
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| Filing 42 REPLY to Response to Motion filed by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC re #32 Joint MOTION to Dismiss for Failure to State a Claim. (ko) |
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Filing 41
ORDER granting #39 Motion for Leave to File Reply in Support of Joint Motion to Dismiss. Signed by Judge Martin L.C. Feldman on 11/5/19. (ko)
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| Filing 40 EXPARTE/CONSENT MOTION for Leave to File Reply to Plaintiffs' Opposition to Motion to Dismiss Pursuant to Rule 12(b)(6) by Todd Meyer. (Attachments: #1 Proposed Order, #2 Proposed Pleading)(Morris, Sheri) |
| Filing 39 EXPARTE/CONSENT Joint MOTION for Leave to File Reply In Support of Joint Motion to Dismiss by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. (Attachments: #1 Proposed Pleading, #2 Proposed Order)(Anderson, Jeremiah) Modified text on 11/5/2019 (clw). |
| Filing 38 Correction of Docket Entry by Clerk re #37 Response/Memorandum in Opposition to Motion. Name of attorney who electronically filed this document does not match name of signatory attorney on pleading. The user log-in and password serve as the required signature for purposes of Rule 11 of the FRCP. No further action is necessary. (clw) |
| Filing 37 RESPONSE/MEMORANDUM in Opposition filed by Total Safety U.S., Inc., Total Safety On-Site Safety Services, Inc. re #32 Joint MOTION to Dismiss for Failure to State a Claim Motion to Dismiss Verified Complaint for Damages and Injunctive Relief Pursuant to Rule 12(B)(6) . (Hubert, Thomas) |
| Filing 36 RESPONSE/MEMORANDUM in Opposition filed by Total Safety U.S., Inc., Total Safety On-Site Safety Services, Inc. re #29 MOTION to Dismiss for Failure to State a Claim (Motion to Dismiss Verified Complaint for Damages and Injunctive Relief Pursuant to Rule 12(B)(6) . (Lavigne, Joseph) |
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Filing 35
ORDER GRANTING #33 Joint MOTION to Expedite. The MOTION to Dismiss (Rec. Doc. #32 ) will be submitted on November 6, 2019, on the papers. Any opposition must be filed by 5:00 P.M. on Saturday, November 2, 2019. Signed by Judge Martin L.C. Feldman on 10/29/2019.(sa)
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| Filing 34 Statement of Corporate Disclosure by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC identifying Corporate Parent HEF Safety Intermediate Holdings, LLC dba Coyote Industrial Holdings for Code Red Safety & Rental, LLC, Turnaround Logistics, LLC (Anderson, Jeremiah) |
| Filing 33 EXPARTE/CONSENT Joint MOTION to Expedite Code Red Safety & Rental and Turnaround Logistics' Motion to Dismiss Pursuant to Rule 12(B)(6) by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. (Attachments: #1 Proposed Order)(Anderson, Jeremiah) |
| Filing 32 Joint MOTION to Dismiss for Failure to State a Claim Motion to Dismiss Verified Complaint for Damages and Injunctive Relief Pursuant to Rule 12(B)(6) by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. Motion(s) will be submitted on 11/20/2019. (Attachments: #1 Memorandum in Support, #2 Proposed Order, #3 Notice of Submission)(Anderson, Jeremiah) |
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Filing 31
ORDER GRANTING #30 MOTION to Expedite Motion to Dismiss. IT IS ORDERED that the motion for expedited consideration of #29 Todd Meyer's Rule 12(b)(6) motion to dismiss is GRANTED. The motion (Rec. Doc. 29) will be submitted on November 6, 2019, on the papers. Any opposition must be filed by 5:00 P.M. on Friday, November 1, 2019. Signed by Judge Martin L.C. Feldman on 10/28/2019.(sa)
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| Filing 30 EXPARTE/CONSENT MOTION to Expedite Todd Meyer's Motion to Dismiss Pursuant to Rule 12(B)(6) by Todd Meyer. (Attachments: #1 Proposed Order)(Morris, Sheri) |
| Filing 29 MOTION to Dismiss for Failure to State a Claim (Motion to Dismiss Verified Complaint for Damages and Injunctive Relief Pursuant to Rule 12(B)(6) by Todd Meyer. Motion(s) will be submitted on 11/20/2019. (Attachments: #1 Memorandum in Support, #2 Notice of Submission)Attorney Sheri M. Morris added to party Todd Meyer(pty:dft).(Morris, Sheri) |
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Filing 28
ORDER GRANTING #26 Motion to Approve Forensic Protocol Order. IT IS ORDERED that the Motion is GRANTED, and IT IS FURTHER ORDERED that the Forensic Inspection Protocol Agreement (Filed at Rec. Doc. #26 , Exhibit 1) is ACCEPTED and approved as an Order of the Court. Signed by Judge Martin L.C. Feldman on 10/22/2019. (sa)
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Filing 27
ORDER granting #25 Joint MOTION to Continue the Preliminary Injunction Hearing filed by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC, Todd Meyer, Total Safety On-Site Safety Services, Inc. and Total Safety U.S., Inc.. The preliminary injunction hearing, currently scheduled for October 22, 2019 at 1:30 P.M., is CONTINUED to December 18, 2019 at 10:00 A.M. The temporary restraining order is EXTENDED and shall remain in place through the December 18, 2019 hearing. A brief in support of a preliminary injunction shall be filed by December 4, 2019 at 5:00 P.M. Opposition briefs shall be filed by December 11, 2019 at 5:00 P.M.. Signed by Judge Martin L.C. Feldman on 10/21/2019.(cbs)
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| Filing 26 MOTION Unopposed Motion to Approve Forensic Protocol Order by Total Safety U.S., Inc., Total Safety On-Site Safety Services, Inc. (Attachments: #1 Exhibit)(Hubert, Thomas) (Additional attachment(s) added on 10/21/2019: #2 Proposed Order) (clw). Modified text on 10/21/2019 (clw). |
| Filing 25 EXPARTE/CONSENT Joint MOTION to Continue Preliminary Injunction Hearing and Extend Temporary Restraining Order by Total Safety U.S., Inc., Total Safety On-Site Safety Services, Inc., Turnaround Logistics, LLC, Todd Meyer, Code Red Safety & Rental, LLC. (Attachments: #1 Proposed Order)(Lavigne, Joseph) Modified text/filers on 10/21/2019 (clw). |
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Filing 23
ORDER granting #18 Motion to Appear Pro Hac Vice as to Steven Godwin Williamson. Signed by Judge Martin L.C. Feldman on 10/16/19. (Attachments: #1 Notice) (ko)
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Filing 24
ORDER granting #19 Motion to Appear Pro Hac Vice as to Charles Brannon Robertson. Signed by Judge Martin L.C. Feldman on 10/16/19. (Attachments: #1 Notice) (ko)
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Filing 22
ORDER granting #17 Motion to Appear Pro Hac Vice as to Jeremiah J Anderson. Signed by Judge Martin L.C. Feldman on 10/19/19. (Attachments: #1 Notice) (ko)
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Filing 21
ORDER granting #16 Motion to Enroll as Counsel of Record for Attorneys David M. Whitaker, Zoe Wilde Vermeulen for Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. Signed by Judge Martin L.C. Feldman on 10/16/19. (ko)
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| Filing 20 Correction of Docket Entry by Clerk re #15 MOTION to Amend/Correct #11 MOTION to Appear Pro Hac Vice Jeremiah Johnson Anderson (Filing fee $ 100 receipt number 053L-7901725) , #14 MOTION to Amend/Correct #10 Notice of Appearance, Motion to Enroll. **These are duplicate filings of documents 16 and 17 and will be noted as such. No further action is necessary.** (pp) |
| Filing 19 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Charles Brannon Robertson (Fee previously paid) by Code Red Safety & Rental, LLC. (Attachments: #1 Proposed Order, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C)(Whitaker, David) |
| Filing 18 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Steven Godwin Williamson (Fee previously paid) by Turnaround Logistics, LLC. (Attachments: #1 Proposed Order, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C)(Whitaker, David) |
| Filing 17 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Jeremiah Johnson Anderson (Fee previously paid) by Turnaround Logistics, LLC. (Attachments: #1 Proposed Order, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C)(Whitaker, David) |
| Filing 16 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. (Attachments: #1 Proposed Order)(Whitaker, David) |
| Filing 15 ERROR: SEE DOC. 17 EXPARTE/CONSENT MOTION to Amend/Correct #11 MOTION to Appear Pro Hac Vice Jeremiah Johnson Anderson (Filing fee $ 100 receipt number 053L-7901725) by Turnaround Logistics, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Proposed Order)(Whitaker, David) Modified on 10/16/2019 (pp). |
| Filing 14 ERROR:SEE DOC. 16 EXPARTE/CONSENT MOTION to Amend/Correct #10 Notice of Appearance, Motion to Enroll by Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. (Attachments: #1 Proposed Order)(Whitaker, David) Modified on 10/16/2019 (pp). |
| Filing 13 **DEFICIENT** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Charles Brannon Robertson (Filing fee $ 100 receipt number 053L-7903269) by Code Red Safety & Rental, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Proposed Order)(Whitaker, David) Modified on 10/15/2019 (clw). |
| Filing 12 **DEFICIENT** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Steven Godwin Williamson (Filing fee $ 100 receipt number 053L-7901778) by Turnaround Logistics, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Proposed Order)(Whitaker, David) Modified on 10/15/2019 (clw). |
| Filing 11 **DEFICIENT** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Jeremiah Johnson Anderson (Filing fee $ 100 receipt number 053L-7901725) by Turnaround Logistics, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Proposed Order)(Whitaker, David) Modified on 10/15/2019 (clw). |
| Filing 10 **DEFICIENT** NOTICE of Appearance by David M. Whitaker on behalf of Code Red Safety & Rental, LLC, Turnaround Logistics, LLC. Attorney David M. Whitaker added to party Code Red Safety & Rental, LLC(pty:dft), Attorney David M. Whitaker added to party Turnaround Logistics, LLC(pty:dft).(Whitaker, David) Modified on 10/15/2019 (clw). |
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Filing 9
ORDER granting #6 Motion to Expedite Motion for Discovery. IT IS ORDERED that Defendants shall be prepared to argue the merits of Plaintiffs Motion for Expedited Discovery (Rec. Doc. #4 ) at any hearing on Plaintiffs request for a temporary restraining order. Any discovery objections must be submitted with all briefing materials not later than 5:00 p.m., October 18, 2019. Signed by Judge Martin L.C. Feldman on 10/4/2019. (sa)
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Filing 8
ORDER granting #4 Motion for Discovery. IT IS ORDERED that Defendants Code Red Safety & Rental, LLC, Turnaround Logistics, LLC, and Todd Meyer shall, within five days of this Order, provide access to the items as set forth herein. IT IS FURTHER ORDERED that the parties are authorized to initiate expedited discovery immediately in aid of preliminary injunction proceedings before the Court. IT IS FURTHER ORDERED that the parties shall preserve all evidence relevant to the facts and circumstances alleged in Plaintiffs' Verified Complaint for Damages and Injunctive Relief. IT IS FURTHER ORDERED that Code Red Safety & Rental, LLC, Turnaround Logistics, LLC, and Todd Meyer shall appear for deposition within ten days notice of the Order. Signed by Judge Martin L.C. Feldman on 10/4/2019. (sa)
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Filing 7
ORDER granting #2 Motion for Temporary Restraining Order. IT IS ORDERED that a temporary restraining order is entered, enjoining and prohibiting Defendants Code Red Safety & Rental, LLC, Turnaround Logistics, LLC, and Todd Meyer, and those persons or entities in active concert or participation as set forth in Order. IT IS FURTHER ORDERED that this temporary restraining order, unless extended for good cause, will expire by its terms within 14 days of the date and hour of its issuance. IT IS FURTHER ORDERED that Plaintiffs shall post a bond in the amount of $1,000.00 to be deposited with the registry of the Court within 7 days of the date of the entry of this temporary restraining order. IT IS FURTHER ORDERED that oral argument will be held on October 22, 2019, at 1:30 p.m., on whether the Court should enter a preliminary injunction until a full trial on the merits of Plaintiffs' claims. Signed by Judge Martin L.C. Feldman on 10/4/2019. (sa)
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| Filing 6 EXPARTE/CONSENT MOTION to Expedite #4 Motion for Expedited Consideration of Discovery Motion by Total Safety On-Site Safety Services, Inc., Total Safety U.S., Inc. (Attachments: #1 Proposed Order Order)(Lavigne, Joseph) Modified text/link on 10/4/2019 (sa). |
| Filing 5 Statement of Corporate Disclosure by Total Safety On-Site Safety Services, Inc., Total Safety U.S., Inc. identifying Corporate Parent Total Safety U.S., Inc. for Total Safety On-Site Safety Services, Inc.; Corporate Parent TS Midco, Inc. for Total Safety U.S., Inc. (Lavigne, Joseph) |
| Filing 4 Emergency MOTION for Discovery - Expedited by Total Safety On-Site Safety Services, Inc., Total Safety U.S., Inc. Motion(s) will be submitted on 10/23/2019. (Attachments: #1 Memorandum in Support, #2 Proposed Order, #3 Notice of Submission)(Lavigne, Joseph) Modified text/referral on 10/4/2019 (sa). |
| Filing 3 Initial Case Assignment to Judge Martin L.C. Feldman and Magistrate Judge Dana Douglas. (aj) |
| Filing 2 EXPARTE/CONSENT Emergency MOTION for Temporary Restraining Order and to Set Hearing for Preliminary Injunction by Total Safety On-Site Safety Services, Inc., Total Safety U.S., Inc. (Attachments: #1 Memorandum in Support, #2 Exhibit Rule 65(b) Attorney Certification, #3 Proposed Order)(Lavigne, Joseph) Modified text on 10/4/2019 (sa). |
| Filing 1 VERIFIED COMPLAINT for Damages and Injunctive Relief, with jury demand against Code Red Safety & Rental, LLC, Todd Meyer, Turnaround Logistics, LLC (Filing fee $ 400 receipt number 053L-7888714) filed by Total Safety U.S., Inc., Total Safety On-Site Safety Services, Inc. (Attachments: #1 Exhibit Verification of Ryan Adams, #2 Exhibit 1 - Non Solicitation and Confidentiality Agreement, #3 Exhibit 2 - Cease and Desist Letter, #4 Exhibit 3 - Declaration of Patrick Ervin, #5 Civil Cover Sheet) Attorney Joseph F. Lavigne added to party Total Safety On-Site Safety Services, Inc.(pty:pla), Attorney Joseph F. Lavigne added to party Total Safety U.S., Inc.(pty:pla).(Lavigne, Joseph) Modified text on 10/4/2019 (sa). |
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