Cofield et al v. Worktime, Inc. et al
Keenan K. Cofield, Laverne Thompson and Dr. Keenan Cofield |
Kayla Nedd, The Progressive Corporation, Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, Worktime, Inc., Worktime Inc. Owners/Operators, Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26, Progressive Insurance Claims, The Progressive Corporation (2), Kevin McNeil, Progressive Insurance Claims (2), Ms. Annie Davis, Glenn M. Renwick, Susan P. Griffith, The Progressive Corporation (3), The Progressive Corporation - Progressive Casualty Insurance Co., Maryland Insurance Administration, The Corporation Trust, Inc., The Hertz Corporation, Abe Essex, LLC, Auto Body Evolution, LLC and Dennie Huff |
Progressive Insurance and Claims Company, State of Maryland, Progressive Insurance the Progressive Corporation, Progressive Insurance Progressive Commercial Casualty Company, Progressive Insurance Progressive Direct Insurance Company, Progressive Insurance and Claims Company the Progressive Corporation, Progressive Claims the Progressive Corporation, Progressive Claims Dept. the Progressive Corp., State of Maryland Maryland Department of Assessments & Taxation, State of Maryland MD State Treasurer-Hon. Dereck E. Davis, MD State Treasurer and State of Maryland Comptroller of Maryland |
1:2022cv00727 |
March 25, 2022 |
US District Court for the District of Maryland |
Stephanie A Gallagher |
Civil Rights: Other |
42 U.S.C. § 1981 cv Civil Rights |
Plaintiff |
Docket Report
This docket was last retrieved on August 29, 2022. A more recent docket listing may be available from PACER.
Document Text |
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Filing 127 [FILED IN ERROR - case not remanded] Correspondence from Clerk re: remand of case (kk5s, Deputy Clerk) Modified on 8/29/2022 (kk5s, Deputy Clerk). |
Filing 126 ORDER granting without prejudice as to Count 8 and denying as moot as to Counts 1-7 #49 and #106 Progressive Defendants' Motions to Dismiss; denying as mooot #121 Plaintiffs' Motion to Consolidate this case with another pending federal action; granting #11 Plaintiffs' Motion to Remand, as to Counts 1-7 in case number 22-cv-1370; remanding the case to the Circuit Court for Baltimore City for adjudication; dismissing Counts 1-7 in case number 22-727 as duplicative; directing Clerk to close case numbers 22-727 and 22-1370. Signed by Judge Stephanie A. Gallagher on 8/29/2022. (kk5s, Deputy Clerk) |
Filing 125 MEMORANDUM OPINION. Signed by Judge Stephanie A. Gallagher on 8/29/2022. (kk5s, Deputy Clerk) |
Filing 124 ORDER denying #122 Plaintiffs' Motion to Disqualify Judge and/or Motion to Recuse. Signed by Judge Stephanie A. Gallagher on 8/29/2022. (kk5s, Deputy Clerk) |
Filing 123 MEMORANDUM OPINION. Signed by Judge Stephanie A. Gallagher on 8/29/2022. (kk5s, Deputy Clerk) |
Filing 122 MOTION to Disqualify Judge and/or Motion to Recuse for Violation of 28 U.S.C. 455, and ABA Rule 2.11, Jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 121 MOTION for Consolidation With Case Number 22-cv-00727-SAG, Jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 120 ORDER denying #108 Motion to Vacate; denying #110 Motion to Extend Time; denying #113 Motion to Strike; terminating ECF #114 and ECF #115 . Signed by Judge Stephanie A. Gallagher on 8/24/2022. (c/m 8/24/2022) (kk5s, Deputy Clerk) |
Filing 119 ORDER directing Clerk to forward filings submitted by Plaintiffs to chambers before they are placed on the docket. Signed by Judge Stephanie A. Gallagher on 8/24/2022. (c/m 8/24/2022)(kk5s, Deputy Clerk) |
Filing 118 REPLY to Response to #111 Motion to Remand by Keenan Cofield(kk5s, Deputy Clerk) Modified on 8/24/2022 (kk5s, Deputy Clerk). |
Filing 117 RESPONSE in Opposition re #111 MOTION to Remand filed by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation. (Attachments: #1 Text of Proposed Order Denying Plaintiffs' Motion to Remand)(Bailen, Mark) |
Filing 116 Supplement to 1:22-cv-1370 No.1 for Record Completeness (Additional State Court Record Document; State Court Record Doc. No. 28: The Maryland Department of Assessments and Taxation's Motion to Dismiss; Filed in Baltimore City Circuit Court on May 31, 2022) (Bailen, Mark) |
Filing 115 MOTION for Summary Judgment by Keenan Cofield (Attachments: #1 Exhibit A, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibits 3 Thru 18 - Part 1, #5 Exhibits 3 Thru 18 - Part 2, #6 Exhibits 3 Thru 18 - Part 3, #7 Exhibits 3 Thru 18 - Part 4, #8 Exhibits 3 Thru 18 - Part 5, #9 Exhibits 3 Thru 18 - Part 6, #10 Exhibits 3 Thru 18 - Part 7, #11 Exhibits 3 Thru 18 - Part 8, #12 Exhibits 3 Thru 18 - Part 9, #13 Exhibits 3 Thru 18 - Part 10)(kk5s, Deputy Clerk) |
Filing 114 MOTION to Deny by Keenan Cofield (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(kk5s, Deputy Clerk) |
Filing 113 MOTION to Strike Defendants of Progressive Motion to Dismiss Document #106, 106-1, and 106-2 Filed 8/3/2022 Dated 6/13/2022, that is Identical to Progressive Same Motion Dated 7/19/2022- or ECF 47, and Several Other Identical Motion to Dismiss Filings/ or in the Alternative Failed to Serve the Plaintiff(s) This Filing by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 112 Correspondence to the Court from Dr. Keenan Cofield, LaVerne Thompson and Kayla Nedd re: Defendants of ABE-Auto Body Evolution reached an agreement and resolved issues; and un-resolved Motions.(bmhs, Deputy Clerk) |
Filing 111 Line Item-Plaintiffs MOTION to Remand this Case Back to the Circuit Court for Baltimore City Maryland is Proper, as the USDC has no Jurisdiction over the Parties and/or Subject-Matter Pursuant to FR Civil Proc 28 USC 1447(c), Jointly by Keenan Cofield, Kayla Nedd, Laverne Thompson(bmhs, Deputy Clerk) |
Filing 110 Corrected MOTION for more definite Statement and/or Motion for Extension of Time by Keenan Cofield, Kayla Nedd, Laverne Thompson(kb3s, Deputy Clerk) |
Filing 109 RESPONSE in Opposition re #106 MOTION to Dismiss, #107 MOTION to Dismiss filed by Keenan Cofield, Kayla Nedd, Laverne Thompson.(kb3s, Deputy Clerk) |
Filing 108 MOTION to Vacate by Keenan Cofield, Kayla Nedd, Laverne Thompson(kb3s, Deputy Clerk) |
Filing 107 MOTION to Dismiss by Worktime, Inc. (Originally filed as ECF 42 on 7/18/2022 in SAG 22-1370). (bas, Deputy Clerk) |
Filing 106 MOTION to Dismiss by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation (Attachments: #1 Memorandum in Support, #2 Exhibit A) (Originally filed as ECF 21 on 6/13/2022 in SAG 22-1370). (bas, Deputy Clerk) |
Filing 105 ORDER granting Motions to Dismiss for failure to state a claim by Defendants Maryland Insurance Administration and the State of Maryland in SAG-22-1370 and dismissing claims against them without prejudice. Maryland Insurance Administration and State of Maryland terminated.. Signed by Judge Stephanie A. Gallagher on 8/2/2022. (kk5s, Deputy Clerk) |
Filing 104 ORDER denying various motions filed by plaintiffs in Civil Action Nos. SAG-22-727 and SAG-22-1370. Signed by Judge Stephanie A. Gallagher on 8/2/2022. (kk5s, Deputy Clerk) |
Filing 103 MOTION for Uncontested, Unrefuted, Unopposed Affidavits, Exhibits, Medical Records, Medical Reports, Pictures of Accident Scene, Pictures of Vehicle Damage, Medical Reports Confirming Plaintiff Dr. Cofield is Permanently Disabled from Vehicle Accident in Further Support of Plaintiff(s) Motions and Motion for Summary Judgment and Denial of Any and All Defendants Motions to Dismiss Without Any Affidavits, Evidence That Negligence Did Not Occur or Plaintiff Cofield Was Not Injured or No Damage Occurred at the Pictured Location that There is No Genuine Issue to Any Material Fact Plaintiff(s) Entitled to Full Relief and/or All Defendants Motion to Dismiss Should Be Denied and This Case be Set for Trial and Scheduling Order, Jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 102 MOTION and Notice to the Court that all Defendants Violated MD State Court Rule After Removal MD Rule(s) 2-321(a), 2-323(a-h), in Failing to File an Answer and the Defendants Information Report, and Under Rule 2-323(h) an Answer and Info Report Both Mandatory or in the Alternative All Defendants Have Violated F.R. Civil Proc. Rules 7(a)(2), Rule 8, Rule 12 as no Defendants Cited or Alleged Any Affirmative Defenses or File a Timely Motion Denying or Alleging Any Defenses are THus Waived, Jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 101 MOTION and Notice to the Court to Take Judicial Notice of the Affidavit of Service by Certified Mail and Private Process Filed in the State and Both Combined Cases as Proof of Service Without Any Objections or Opposition by Any Defendants by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 100 AMENDED ANSWER to #11 Complaint,, by Worktime, Inc.. (Gray, Halle) |
Filing 99 RESPONSE in Opposition re #89 MOTION for Clerk's Entry of Default for want of answer or other defense filed by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation.(Bailen, Mark) |
Filing 98 ORDER granting #71 Plaintiffs' Motion to Consolidate Cases (SAG-22-727 (LEAD) and SAG-22-1370). Signed by Judge Stephanie A. Gallagher on 7/21/2022. (kk5s, Deputy Clerk) |
Filing 97 Local Rule 103.3 Disclosure Statement by Worktime, Inc. (Gray, Halle) |
Filing 96 Rule 12/56 notice mailed to Keenan Cofield, Kayla Nedd, Laverne Thompson. (c/m 7/20/22)(bmhs, Deputy Clerk) |
Deficiency Notice to Worktime, Inc. Your Local Rule 103.3 disclosure statement has not been filed. The Statement must be filed by 7/27/2022 (bmhs, Deputy Clerk) |
Filing 95 REPLY to Response to Motion re #49 MOTION to Dismiss for Failure to State a Claim filed by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation. (Attachments: #1 Exhibit 1 - New Baltimore City Action)(Bailen, Mark) |
Filing 94 MOTION to Dismiss for Failure to State a Claim by Worktime Inc. Owners/Operators, Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26 (Attachments: #1 Text of Proposed Order)(Gray, Halle) |
Filing 93 ANSWER to #12 Amended Complaint,, by Worktime, Inc..(Gray, Halle) |
Filing 92 LINE ITEM- Plaintiff's RESPONSE, Objection and Denial of Defendants All Worktime, Inc., Defendants Motion to Dismiss document #42 or in the alternative Plaintiff's uncontested, unrefuted, unopposed affidavits, exhibits, etc. and IN FURTHER SUPPORT of Plaintiff's motions for summary judgment and in DENIAL of any and all Defendants' motions to dismiss without any affidavits, filed by Keenan Cofield.(dass, Deputy Clerk) |
Filing 91 LINE ITEM- Plaintiff's Uncontested, Unrefuted, Unopposed Affidavits, Exhibits, Medical Records, Medical Reports, Pictures of Accident Scene, Pictures of Vehicle Damage, et al. by Keenan Cofield (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit A-Z)(dass, Deputy Clerk) |
Filing 90 Correspondence re: ECF 83 (Attachments: #1 Exhibit, #2 Exhibit)(Gray, Halle) |
Filing 89 MOTION for Clerk's Entry of Default for want of answer or other defense by Keenan Cofield (Attachments: #1 Text of Proposed Clerk's Default Order, #2 Exhibit)(kk5s, Deputy Clerk) |
Filing 88 RESPONSE to Motion re #49 MOTION to Dismiss for Failure to State a Claim filed by Keenan Cofield. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(kk5s, Deputy Clerk) |
Filing 87 MARGINAL ORDER denying #86 Motion to Vacate and Set Aside Court Memorandum and Order Document Numbers 82 and 83 or in the Alternative Motion for Reconsideration and Restore Clerks Order of Entry of Default and Default Judgment, Jointly. Signed by Judge Stephanie A. Gallagher on 7/5/2022. (kk5s, Deputy Clerk) |
Filing 86 MOTION to Vacate and Set Aside Court Memorandum and Order Document Numbers 82 and 83 or in the Alternative Motion for Reconsideration and Restore Clerks Order of Entry of Default and Default Judgment, Jointly by Keenan Cofield (Attachments: #1 Exhibit A, #2 Exhibit B)(kk5s, Deputy Clerk) |
Filing 85 Line Item - Plaintiff(s) to Court to Deny All Motions Except Entry of Default and Set Case with Scheduling Order, Discovery and Trial by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 84 Line Item - Plaintiff(s) Amended Affidavits of Service by Certified Mail-Return Receipts Restricted Delivery Upon All Worktime, Inc. Worktime Defendants by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 83 ORDER granting #47 Worktime's Motion to Vacate Entry of Default; directing parties to meet and confer by telephone or videoconference and to advise this Court, on or before 7/10/2022, whether Worktime will waive formal service of process; directing Clerk to remove from the docket the defendants named in the Amended Complaint (ECF #28 ). Signed by Judge Stephanie A. Gallagher on 6/28/2022. (kk5s, Deputy Clerk) |
Filing 82 MEMORANDUM OPINION. Signed by Judge Stephanie A. Gallagher on 6/28/2022. (kk5s, Deputy Clerk) |
Filing 81 Supplement (Amended Proposed Default Judgment Order) to #50 Corrected MOTION for Default Judgment as to filed by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 80 RESPONSE re #17 Notice of Standing Order 2021-13 Concerning Removal Actions filed by Worktime, Inc..(Gray, Halle) |
Filing 79 RESPONSE in Opposition re #69 MOTION for Summary Judgment filed by Worktime, Inc..(Gray, Halle) |
Filing 78 RESPONSE in Opposition re #68 MOTION filed by Worktime, Inc..(Gray, Halle) |
Filing 77 RESPONSE in Opposition re #66 MOTION filed by Worktime, Inc..(Gray, Halle) |
Filing 76 RESPONSE to Motion re #65 MOTION filed by Worktime, Inc..(Gray, Halle) |
Filing 75 RESPONSE in Opposition re #63 MOTION filed by Worktime, Inc..(Gray, Halle) |
Filing 74 RESPONSE in Opposition re #50 MOTION for Default Judgment as to filed by Worktime, Inc..(Gray, Halle) |
Filing 73 RESPONSE in Opposition re #64 MOTION filed by Worktime, Inc..(Gray, Halle) |
Filing 72 MOTION to Order Progressive Defendants to file any and all Motions, Pleadings, and Filings filed in the State Court Case before Removal by Keenan Cofield, Kayla Nedd, Laverne Thompson. (hmls, Deputy Clerk) |
Filing 71 MOTION to Consolidate Cases by Keenan Cofield, Kayla Nedd, Laverne Thompson. (Attachments: #1 Exhibit A) (hmls, Deputy Clerk) |
Filing 70 [FILED IN ERROR - WRONG CASE] MEMORANDUM OPINION. Signed by Judge Catherine C. Blake on 6/10/2022. (kk5s, Deputy Clerk) Modified on 6/10/2022 (kk5s, Deputy Clerk). |
Filing 69 MOTION for Summary Judgment or in the alternative affidavit of Dr. Keenan Cofield, Jointly in support of motion for summary judgment or in the alternative plaintiff(s) response and motion to dismiss all defendants motions to dismiss, jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 68 Response and Motion to Dismiss All Defendants Worktime, Inc. Only Untimely, Moot and Stale Motion to Vacate Entry of Default and Motion to Dismiss for Violations of Federal Rules Civil Procedure Rules 7(a)(2), 8(c)(1, 12(h)(1), 12(c)(1), and Rule 60(b) by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 67 MOTION to Stay Any Further Response to Defendants Progressive Motion to Dismiss Until the Court Rules on Plaintiff(s) Motion for More Definite Statement or Document #52 and/or Motion for Extension of Time, Jointly by Keenan Cofield (Attachments: #1 Exhibit)(kk5s, Deputy Clerk) |
Filing 66 MOTION for more definite statement and/or motion for extension of time of sixty days to file any answer or response to defendants Progressive/Worktime, Inc. motion to dismiss or in the alternative motion to withdraw any references of any class or class action as alleged by defendants Progressive Insurance, jointly by Keenan Cofield (Attachments: #1 Exhibit B)(kk5s, Deputy Clerk) |
Filing 65 MOTION to Court of All Worktime, Inc. Defendants Violation of Standing Order 2021-13 or Document 17 or Filed 03/31/2022, Local Rule 103.3, and Rule 7.1 (b)(1) Fed Rules of Civil Proc. Jointly, or in the Alternative Requests for Sanctions and/or These Defendants Full Compliance With Standing Order 2021-13 by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 64 MOTION to Court of all defendants violated MD rules 2-321(a), 2-323(a-h), and 2-322(a) Fed Rules civil procedure rules(s) 7(a)(1), and (2), Rule 8(6)(c), and Rule 12(A), (h)(1), when no defendants have and did not file an answer under state or federal rules as required in this case or in the alternative any and all defenses are thus waived from failing to deny by Keenan Cofield (Attachments: #1 Exhibit)(kk5s, Deputy Clerk) |
Filing 63 MOTION to Court of Defendants Worktime Inc., Nicole Winder, Worktime, Inc. Dump Truck Driver #26 John or Jane Doe, Are in Violation of Fed. Rules of Civil Procedure Rules 12(h)(1)(2), 12(a)(1)(A)(i)(ii), & 12(b)(1-7) and/or Waived Any and All Rights to Any Affirmative Defenses, Jointly by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 62 ORDER denying #7 Cofield's Motion for Order Compelling Discovery; denying #9 Cofield's Motion to Strike for Failure to Serve; denying without prejudice #13 Cofield's Motion for Summary Judgment; denying #15 Cofield's Motion for Default Judgment; denying #35 Cofield's Motion for Judgment on the Pleadings; denying #41 Cofield's Motion to Strike Correspondence; terminating #46 Cofield's Motion for Default Judgment; denying #52 Cofield's Motion for More Definite Statement; denying #56 Cofield's Motion under Rule 56(d)(2). Signed by Judge Stephanie A. Gallagher on 6/8/2022. (c/m 6/8/2022 ols, Deputy Clerk) |
Filing 61 Rule 12/56 notice mailed to Kayla Nedd (c/m 6/8/2022 ols, Deputy Clerk) |
Filing 60 Rule 12/56 notice mailed to Laverne Thompson (c/m 6/8/2022 ols, Deputy Clerk) |
Filing 59 Rule 12/56 notice mailed to Keenan Cofield (ols, Deputy Clerk) |
Filing 58 NOTICE to Court of All Defendant Violated MD Rules 2-321(a), 2-323(a-h), and 2-322(a) Fed Rules Civil Procedure Rule(s) 7(a)(1), and (2), Rule 8(6)(c), and Rule 12(A),(h)(1), When No Defendants Have and Did File An Answer Under State or Federal Riles as Required in this Case or in the Alternative Any and All Defenses are Thus Waived for Failing to Deny by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 57 Line Item - Corrected NOTICE of Stay Any Further Response to Defendants Progressive Motion to Dismiss Until the Court Rules on Plaintiff(s) Motion for More Definite Statement or Document #52 and/or Motion for Extension of Time, Jointlyby Keenan Cofield (kk5s, Deputy Clerk) |
Filing 56 MOTION and/or Request Pursuant to Federal Rule 56(d)(2) by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 55 NOTICE to Court of All Worktime, Inc. Defendants Violation of Standing Order 2021-13 or Document 17 or Filed 03/31/2022, Local Rule 103.3, and Rule 7.1 (b)(1) Fed Rules of Civil Proc. Jointly, or in the Alternative Requests for Sanctions and/or These Defendants Full Compliance With Standing Order 2021-13 by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 54 NOTICE of Stay Any Further Response to Defendants Progressive Motion to Dismiss Until the Court Rules on Plaintiff(s) Motion for More Definite Statement or Document #52 and/or Motion for Extension of Time, Jointly by Keenan Cofield (Attachments: #1 Exhibit A)(kk5s, Deputy Clerk) |
Filing 53 NOTICE to Withdraw Any Alleged Complaints or Pleadings References or Incorrect Citation of Any Class or Class Action As Alleged by Defendants of Progressive Insurance by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 52 MOTION for More Definite Statement or in the Alternative Notice to Withdraw Any References of Any Class or Class Action as Alleged by Defendants of Progressive Insurance, and Motion to Strike, Jointly by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 51 RESPONSE to Motion re #47 MOTION to Vacate filed by Keenan Cofield. (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 50 Corrected MOTION for Default Judgment as to Worktime, Inc., Worktime, Inc. Owners/Operators, Worktime, Inc. John Doe, and Jane Doe-Driver of Dump Truck #26 by Keenan Cofield (Attachments: #1 Cover Letter, #2 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 49 MOTION to Dismiss for Failure to State a Claim by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation (Attachments: #1 Memorandum in Support of Progressive Defendant's Motion to Dismiss, #2 Exhibit 1. Emails to Barnes, #3 Exhibit 2. Emails to Williams, #4 Exhibit 3. Further Emails to Williams, #5 Exhibit 4. Personal Injury Demand Letter, #6 Exhibit 5. Emails to McNeil, #7 Exhibit 6. Progressive Offer Letter, #8 Exhibit 7. Felder v. McDonald's Corp., et al., #9 Exhibit 8. MD Dismissal Orders)(Bailen, Mark) |
Filing 48 NOTICE of Appearance by Halle Gray on behalf of Worktime Inc. Owners/Operators, Worktime, Inc., Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26 (Gray, Halle) |
Filing 47 MOTION to Vacate by Worktime Inc. Owners/Operators, Worktime, Inc., Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26 (Attachments: #1 Exhibit, #2 Exhibit, #3 Text of Proposed Order)(Finamore, Paul) |
Filing 46 MOTION for Default Judgment as to Worktime, Inc., Worktime, Inc. Owners/Operators, Worktime, Inc. John Doe, and Jane Doe-Driver of Dump Truck #26 by Keenan Cofield (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit B, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Exhibit 9, #11 Affidavit, #12 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 45 NOTICE OF DEFAULT as to Worktime, Inc. (kk5s, Deputy Clerk) |
Filing 44 Clerk's ENTRY OF DEFAULT as to Worktime, Inc. (kk5s, Deputy Clerk) |
Filing 43 NOTICE by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation Regarding Local Rule 103.5(a) (Bailen, Mark) |
Filing 42 PAPERLESS ORDER granting #37 Motion to Appear Pro Hac Vice on behalf of Michael K Farrell, Emily S.P. Baxter. Directing attorney Michael K Farrell, Emily S.P. Baxter to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so; granting #38 Motion to Appear Pro Hac Vice on behalf of Michael K Farrell, Emily S.P. Baxter. Directing attorney Michael K Farrell, Emily S.P. Baxter to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so; granting #39 Motion to Appear Pro Hac Vice on behalf of Michael K Farrell, Emily S.P. Baxter. Directing attorney Michael K Farrell, Emily S.P. Baxter to register for pro hac vice filing in the District of Maryland through PACER at https://pacer.uscourts.gov/ if attorney has not already done so. Signed by Clerk on 4/20/2022. (dm4s, Deputy Clerk) |
Filing 41 MOTION to Strike #36 Correspondence re: Cofield et al. v. Worktime, Inc. et al., Case No. 1:22-cv-00727 Filings by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 40 Consent to receive notice and service electronically by Keenan Cofield. The Court recommends that all documents received electronically be printed or saved for future reference.(kk5s, Deputy Clerk) |
Filing 39 MOTION to Appear Pro Hac Vice for Emily S. P. Baxter (Filing fee $100, receipt number AMDDC-9878305.) by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company(Bailen, Mark) |
Filing 38 MOTION to Appear Pro Hac Vice for Kendall C. Kash (Filing fee $100, receipt number AMDDC-9878286.) by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation(Bailen, Mark) |
Filing 37 MOTION to Appear Pro Hac Vice for Michael K. Farrell (Filing fee $100, receipt number AMDDC-9878223.) by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation(Bailen, Mark) |
Filing 36 Correspondence re: Cofield et al. v. Worktime, Inc. et al., Case No. 1:22-cv-00727 Filings (Bailen, Mark) |
Filing 35 MOTION for Judgment on the Pleadings by Keenan Cofield (Attachments: #1 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 34 Supplemental to #13 MOTION for Summary Judgment filed by Keenan Cofield (Attachments: #1 Attachment 1, #2 Attachment 2)(kk5s, Deputy Clerk) |
Filing 33 NOTICE to Court of Defendants Worktime Inc., Nicole Winter, Worktime, Inc. Dump Truck Driver #26 John or Jane Does, are in Violation of Fed. Rules of Civil Procedure Rules 12(h)(1)(2), 12(a)(1)(A)(i)(ii), and 12(b)(1-7) and/or Waived Any and All Rights to Any Affirmative Defenses, Jointly by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 32 RESPONSE re #29 Statement Pursuant to Standing Order 2021-13 filed by Keenan Cofield.(kk5s, Deputy Clerk) |
Filing 31 AMENDED Emergency NOTICE to Court of Defendants Worktime Inc., Nicole Winter, Worktime, Inc. Dump Truck Driver #26 John or Jane Doe, are in Violation of Document #17/ Notice of Standing Order 2-21-13 and Further in Default or in the Alternative Notice Defendants Worktime, Inc. Nicole Winder, Worktime, Inc. Dump Truck Drive #26 John or Jane Doe, Never Consented to Removal by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 30 NOTICE to Court of Defendants Worktime Inc., Nicole Winter, Worktime, Inc. Dump Truck Driver #26 John or Jane Doe, are in Violation of Document #17/ Notice of Standing Order 2-21-13 and Further in Default by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 29 NOTICE by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation Statement Pursuant to Standing Order 2021-13 (Bailen, Mark) |
Filing 28 AMENDED COMPLAINT against The Corporation Trust, Inc., The Hertz Corporation, Abe Essex, LLC, Auto Body Evolution, LLC, Dennie Huff, filed by Keenan Cofield. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Summons)(kk5s, Deputy Clerk) |
Filing 27 Verification of Motion for Summary Judgment and Affidavit of Plaintiff in Further Support of Motion for Affidavit for Entry of Default by Clerk for Amount Due from Each Defendant by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 26 Supplemental to #21 MOTION for Clerk's Entry of Default for want of answer or other defense filed by Keenan Cofield (Attachments: #1 Attachment)(kk5s, Deputy Clerk) |
Filing 25 RETURN DOCUMENT ORDER. Signed by Judge Stephanie A. Gallagher on 4/4/2022. (Attachments: #1 First Page of Returned Document)(kk5s, Deputy Clerk) |
Filing 24 Second AFFIDAVIT of Service for Summons, Complaint, Motion for Summary Judgment, etc served on Worktime, Inc./Owners/Operators and Nicole Winder on 4/4/2022, filed by Keenan Cofield. (Attachments: #1 Exhibit B)(kk5s, Deputy Clerk) |
Filing 23 AFFIDAVIT of Service for Summons, Complaint, Motion for Summary Judgment, etc served on Worktime, Inc./Owners/Operators and Nicole Winder on 3/2/2022, filed by Keenan Cofield. (Attachments: #1 Exhibit A)(kk5s, Deputy Clerk) |
Filing 22 NOTICE to Withdraw in Part All Progressive Insurance Entities from Motion for Affidavit for Entry of Default-By Clerk- for Amount Due from Each Defendant by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 21 MOTION for Clerk's Entry of Default for want of answer or other defense by Keenan Cofield (Attachments: #1 Verification of Complaint and Affidavit of Dr. Keenan Cofield, #2 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 20 ORDER granting #19 Consent Motion for Extension of Time to Move, Answer, or Otherwise Respond to Plaintiffs' Complaint. Signed by Judge Stephanie A. Gallagher on 4/1/2022. (kk5s, Deputy Clerk) |
Filing 19 MOTION for Extension of Time for 60 days by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation (Attachments: #1 Exhibit A - Bailen/Cofield Emails, #2 Text of Proposed Order Granting Time Extension)(Bailen, Mark) |
Filing 18 Local Rule 103.3 Disclosure Statement by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation identifying Corporate Parent The Progressive Corporation, Other Affiliate Progressive Northern Insurance Company, Other Affiliate Progressive Classic Insurance Company, Other Affiliate Protective Insurance Company, Other Affiliate Progressive Mountain Insurance Company, Other Affiliate Progressive Direct Insurance Company, Other Affiliate Progressive Southeastern Insurance Company, Other Affiliate Garden Sun Insurance Services, Inc., Other Affiliate Mountain Laurel Assurance Company, Other Affiliate National Continental Insurance Company, Other Affiliate Pacific Motor Club, Other Affiliate ProgNY Agency, Inc., Other Affiliate Progressive Adjusting Company, Inc., Other Affiliate Progressive American Insurance Company, Other Affiliate Progressive Auto Pro Insurance Agency, Inc., Other Affiliate Progressive Bayside Insurance Company, Other Affiliate Progressive Capital Management Corp., Other Affiliate Progressive Preferred Insurance Company, Other Affiliate Progressive Max Insurance Company, Other Affiliate Progressive Gulf Insurance Company, Other Affiliate Progressive Gulf Insurance Company, Other Affiliate Progressive Northwestern Insurance Company, Other Affiliate Progressive Universal Insurance Company, Other Affiliate Progressive West Insurance Company, Other Affiliate Progressive Marathon Insurance Company, Other Affiliate Progressive Paloverde Insurance Company, Other Affiliate Progressive Security Insurance Company, Other Affiliate Progressive Express Insurance Company, Other Affiliate Progressive Michigan Insurance Company, Other Affiliate Progressive Advanced Insurance Company, Other Affiliate Progressive Choice Insurance Company, Other Affiliate Progressive Freedom Insurance Company, Other Affiliate Progressive Garden State Insurance Company, Other Affiliate Progressive Specialty Insurance Company, Other Affiliate United Financial Casualty Company, Other Affiliate ARX Holding Corp., Other Affiliate American Strategic Insurance Corp., Other Affiliate Progressive Select Insurance Company, Other Affiliate Drive Insurance Holdings, Inc., Other Affiliate Protective Insurance Corporation, Other Affiliate Ark Royal Underwriters, LLC, Other Affiliate ASI Assurance Corp., Other Affiliate ASI Home Insurance Corp., Other Affiliate ASI Lloyds, Inc., Other Affiliate ASI Preferred Insurance Corp., Other Affiliate ASI Underwriters Corp., Other Affiliate ASI Underwriters of Texas, Inc., Other Affiliate Progressive Property Insurance Company, Other Affiliate PropertyPlus Insurance Agency, Inc., Other Affiliate Sunshine Security Insurance Agency, Inc., Other Affiliate Drive New Jersey Insurance Company, Other Affiliate PC Investment Company, Other Affiliate Trussville/Cahaba, AL, LLC, Other Affiliate Progressive Commercial Advantage Agency, Inc., Other Affiliate Progressive Hawaii Insurance Corp., Other Affiliate Progressive Commercial Holdings, Inc., Other Affiliate Artisan and Truckers Casualty Company, Other Affiliate Blue Hill Specialty Insurance Company, Inc., Other Affiliate B&L Brokerage Services, Inc., Other Affiliate Transport Specialty Insurance Agency, Inc., Other Affiliate B&L Insurance, Ltd., Other Affiliate B&L Management Inc., Other Affiliate Protective Specialty Insurance Company, Other Affiliate Sagamore Insurance Company, Other Affiliate Progressive Direct Holdings, Inc., Other Affiliate Progressive Advantage Agency, Inc., Other Affiliate Gadsden, AL, LLC, Other Affiliate Progressive Premier Insurance Company of Illinois, Other Affiliate Progressive Innovation Co., Other Affiliate Progressive Investment Company, Inc., Other Affiliate Progressive Life Insurance Company, Other Affiliate Progressive Premium Budget, Inc., Other Affiliate Progressive RSC, Inc., Other Affiliate Progressive Vehicle Service Company, Other Affiliate Village Transport Corp., Other Affiliate Wilson Mills Land Co., Other Affiliate 358 Ventures, Inc., Other Affiliate ASI Select Insurance Corp., Other Affiliate ASI Select Auto Insurance Corp. for Progressive Casualty Insurance Company, Progressive Commercial Casualty Company; Corporate Parent The Progressive Corporation, Other Affiliate Progressive Casualty Insurance Company, Other Affiliate Progressive Northern Insurance Company, Other Affiliate Progressive Classic Insurance Company, Other Affiliate Protective Insurance Company, Other Affiliate Progressive Mountain Insurance Company, Other Affiliate Progressive Southeastern Insurance Company, Other Affiliate Garden Sun Insurance Services, Inc., Other Affiliate Mountain Laurel Assurance Company, Other Affiliate National Continental Insurance Company, Other Affiliate Pacific Motor Club, Other Affiliate ProgNY Agency, Inc., Other Affiliate Progressive Adjusting Company, Inc., Other Affiliate Progressive American Insurance Company, Other Affiliate Progressive Auto Pro Insurance Agency, Inc., Other Affiliate Progressive Bayside Insurance Company, Other Affiliate Progressive Capital Management Corp., Other Affiliate Progressive Preferred Insurance Company, Other Affiliate Progressive Max Insurance Company, Other Affiliate Progressive Gulf Insurance Company, Other Affiliate Progressive Gulf Insurance Company, Other Affiliate Progressive Northwestern Insurance Company, Other Affiliate Progressive Universal Insurance Company, Other Affiliate Progressive West Insurance Company, Other Affiliate Progressive Marathon Insurance Company, Other Affiliate Progressive Paloverde Insurance Company, Other Affiliate Progressive Security Insurance Company, Other Affiliate Progressive Express Insurance Company, Other Affiliate Progressive Michigan Insurance Company, Other Affiliate Progressive Advanced Insurance Company, Other Affiliate Progressive Choice Insurance Company, Other Affiliate Progressive Freedom Insurance Company, Other Affiliate Progressive Garden State Insurance Company, Other Affiliate Progressive Specialty Insurance Company, Other Affiliate United Financial Casualty Company, Other Affiliate ARX Holding Corp., Other Affiliate American Strategic Insurance Corp., Other Affiliate Progressive Select Insurance Company, Other Affiliate Drive Insurance Holdings, Inc., Other Affiliate Protective Insurance Corporation, Other Affiliate Progressive Commercial Casualty Company, Other Affiliate Ark Royal Underwriters, LLC, Other Affiliate ASI Assurance Corp., Other Affiliate ASI Home Insurance Corp., Other Affiliate ASI Lloyds, Inc., Other Affiliate ASI Preferred Insurance Corp., Other Affiliate ASI Underwriters Corp., Other Affiliate ASI Underwriters of Texas, Inc., Other Affiliate Progressive Property Insurance Company, Other Affiliate PropertyPlus Insurance Agency, Inc., Other Affiliate Sunshine Security Insurance Agency, Inc., Other Affiliate Drive New Jersey Insurance Company, Other Affiliate PC Investment Company, Other Affiliate Trussville/Cahaba, AL, LLC, Other Affiliate Progressive Commercial Advantage Agency, Inc., Other Affiliate Progressive Hawaii Insurance Corp., Other Affiliate Progressive Commercial Holdings, Inc., Other Affiliate Artisan and Truckers Casualty Company, Other Affiliate Blue Hill Specialty Insurance Company, Inc., Other Affiliate B&L Brokerage Services, Inc., Other Affiliate Transport Specialty Insurance Agency, Inc., Other Affiliate B&L Insurance, Ltd., Other Affiliate B&L Management Inc., Other Affiliate Protective Specialty Insurance Company, Other Affiliate Sagamore Insurance Company, Other Affiliate Progressive Direct Holdings, Inc., Other Affiliate Progressive Advantage Agency, Inc., Other Affiliate Gadsden, AL, LLC, Other Affiliate Progressive Premier Insurance Company of Illinois, Other Affiliate Progressive Innovation Co., Other Affiliate Progressive Investment Company, Inc., Other Affiliate Progressive Life Insurance Company, Other Affiliate Progressive Premium Budget, Inc., Other Affiliate Progressive RSC, Inc., Other Affiliate Progressive Vehicle Service Company, Other Affiliate Village Transport Corp., Other Affiliate Wilson Mills Land Co., Other Affiliate 358 Ventures, Inc., Other Affiliate ASI Select Insurance Corp., Other Affiliate ASI Select Auto Insurance Corp. for Progressive Direct Insurance Company. (Attachments: #1 Exhibit The Progressive Corp. 10-K Excerpt)(Bailen, Mark) |
Filing 17 Clerk's Notice of Standing Order concerning removal actions filed in this Court, which can be downloaded #here. (kk5s, Deputy Clerk) |
Filing 16 Notice of filing of state court discovery material (Deposition) by Keenan Cofield (Attachments: #1 Notice of Filing of Discovery Matters)(kk5s, Deputy Clerk) |
Filing 15 State Court MOTION for Default Judgment as to by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 14 Supplemental to #13 State Court MOTION for Summary Judgment filed by Keenan Cofield (kk5s, Deputy Clerk) |
Filing 13 State Court MOTION for Summary Judgment by Keenan Cofield(kk5s, Deputy Clerk) |
Filing 12 STATE COURT AMENDED COMPLAINT against Annie Davis, Susan P. Griffith, Kevin McNeil, Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, Progressive Insurance Claims, Progressive Insurance Claims (2), Glenn M. Renwick, The Progressive Corporation, The Progressive Corporation (2), The Progressive Corporation (3), The Progressive Corporation - Progressive Casualty Insurance Co., Worktime Inc. Owners/Operators, Worktime, Inc., Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26, Maryland Insurance Administration, filed by Laverne Thompson, Keenan Cofield, K.N..(kk5s, Deputy Clerk) |
Filing 11 STATE COURT COMPLAINT against Annie Davis, Susan P. Griffith, Kevin McNeil, Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, Progressive Insurance Claims, Progressive Insurance Claims (2), Glenn M. Renwick, The Progressive Corporation, The Progressive Corporation (2), The Progressive Corporation (3), The Progressive Corporation - Progressive Casualty Insurance Co., Worktime Inc. Owners/Operators, Worktime, Inc., Worktime, Inc. John Doe or Jane Doe - Driver of Dump Truck #26, filed by Laverne Thompson, Keenan Cofield, K.N..(kk5s, Deputy Clerk) |
Filing 10 REDACTED NOTICE OF REMOVAL (Attachments: #1 Exhibit Uth Declaration, #2 Civil Cover Sheet Civil Cover Sheet (Redacted), #3 Baltimore City Docket Case Information (Redacted), #4 State Court Doc. No. 2 Complaint with Coversheet and Attachments (Redacted), #5 State Court Doc. No. 2 Demand for Trial By Jury and Amended Complaint, #6 State Court Doc. No. 3 Plaintiff Notice of Discovery Materials, #7 State Court Doc. No. 4 Notice of Service of Discovery Material, #8 State Court Doc. No. 5 Motion for Summary Judgment with Memorandum and Exhibits (Redacted), #9 State Court Doc. No. 6 Request for Trial by Jury, #10 State Court Doc. No. 8 Notice of Rule 2-311b, #11 State Court Doc. No. 21 Amended Motion for Summary Judgment, #12 State Court Doc. No. 22 Motion for Default Judgment, #13 State Court Doc. No. Unknown McNeil Writ of Summons, #14 State Court Doc. No. Unknown Progressive Ins. & Claims Co. Writ of Summons, #15 State Court Doc. No. Unknown Progressive Ins./Progressive Direct Ins. Co. Writ of Summons, #16 State Court Doc. No. Unknown Progressive Ins./Progressive Commercial Casualty Co. Writ of Summons, #17 State Court Doc. No. Unknown Progressive Insurance/The Progressive Corporation Writ of Summons, #18 State Court Doc. No. Unknown Progressive Insurance Claims Writ of Summons, #19 State Court Doc. No. Unknown Progressive Insurance Claims (VA) Writ of Summons, #20 State Court Doc. No. Unknown Progressive Insurance/Progressive Casualty Ins. Co. Writ of Summons, #21 State Court Doc. No. Unknown Progressive Claims Writ of Summons, #22 State Court Doc. No. Unknown WorkTime, Inc. Owners/Operators Writ of Summons, #23 State Court Doc. No. Unknown Progressive Insurance & Claims Co., The Progressive Corp. Writ of Summons, #24 State Court Doc. No. Unknown WorkTime, Inc. (Nicole Winter) Writ of Summons)(Bailen, Mark) Modified on 3/31/2022 (kk5s, Deputy Clerk). |
THE ABOVE DOCUMENTS (11-16) ARE COPIES OF ORIGINAL PAPERS FILED IN THE CIRCUIT COURT FOR BALTIMORE CITY. (kk5s, Deputy Clerk) |
Filing 5 QC NOTICE: #2 Local Rule 103.3 Disclosure Statement, filed by Progressive Direct Insurance Company, Progressive Casualty Insurance Company, The Progressive Corporation, Progressive Commercial Casualty Company was filed incorrectly. **All corporate parents and/or affiliates should be added at the time of filing. Please refile and add the corporate parents and/or affiliates for the associated parties. It has been noted as FILED IN ERROR, and the document link has been disabled. (kk5s, Deputy Clerk) |
Filing 4 QC NOTICE: #1 Notice of Removal, filed by Progressive Direct Insurance Company, Progressive Casualty Insurance Company, The Progressive Corporation, Progressive Commercial Casualty Company was filed incorrectly. **State Court documents should be scanned and attached individually, as well as being labeled with the title of each document. Please contact the Clerk's office with any questions, if needed, prior to refiling. Use the event "Notice-other" and attach the state court document as the main document, with any other documents as attachments with proper labels (kk5s, Deputy Clerk) |
Case Reassigned to Judge Stephanie A. Gallagher. Senior District Judg Ellen Lipton Hollander no longer assigned to the case. (kos, Deputy Clerk) |
Filing 9 MOTION to Strike for Failure to Serve All Plaintiff(s) Any and All Documents Relating to Notice of Removal to USDC by Keenan Cofield (Attachments: #1 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 8 NOTICE to Amend and/or Supplement the Plaintiff(s) Motion for Summary Judgment and Any Untimely Response by All the Defendants with Additional Medical Billing Records in Further Support of Plaintiff(s) Motion for Summary Judgment by Keenan Cofield (Attachments: #1 Continuing Medical Attachments, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit 1, #8 Exhibit 2, #9 Exhibit 3)(kk5s, Deputy Clerk) |
Filing 7 MOTION for an Order Compelling Discovery or in the Alternative to Request Judicial Notice of State Court Filing Motion Upon Removal by Keenan Cofield (Attachments: #1 Text of Proposed Order)(kk5s, Deputy Clerk) |
Filing 6 Consent to receive notice and service electronically by Keenan Cofield. The Court recommends that all documents received electronically be printed or saved for future reference.(kk5s, Deputy Clerk) |
Filing 3 UNREDACTED Civil Cover Sheet by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation (Bailen, Mark) Modified on 3/30/2022 (kk5s, Deputy Clerk). |
Filing 2 [FILED IN ERROR] Local Rule 103.3 Disclosure Statement by Progressive Casualty Insurance Company, Progressive Commercial Casualty Company, Progressive Direct Insurance Company, The Progressive Corporation (Attachments: #1 Exhibit The Progressive Corp. 10-K Excerpt)(Bailen, Mark) Modified on 3/30/2022 (kk5s, Deputy Clerk). |
Filing 1 UNREDACTED NOTICE OF REMOVAL from Circuit Court of Baltimore City, case number 24C22001064. ( Filing fee $ 402 receipt number AMDDC-9840971), filed by Progressive Commercial Casualty Company, The Progressive Corporation, Progressive Direct Insurance Company, Progressive Casualty Insurance Company. (Attachments: #1 Exhibit Declaration of Michael R. Uth, #2 UNREDACTED Exhibit State Court Filings)(Bailen, Mark) Modified on 3/30/2022 (kk5s, Deputy Clerk). |
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