Frederick v. United States Olympic Committee et al
| Marcia Frederick, individually, and on behalf of all others similarly situated and Marcia Frederick |
| United States Olympic Committee, Richard Carlson, USA Gymnastics (formerly known as the United States Gymnastics Federation), Muriel Grossfeld, George Ward, the United States Gymnastics Federation), USA Gymnastics and the United States Gymnastics Federation |
| 1:2018cv11299 |
| June 20, 2018 |
| US District Court for the District of Massachusetts |
| Boston Office |
| Suffolk |
| Indira Talwani |
| Other Statutory Actions |
| 28 U.S.C. § 1331 Fed. Question |
| Plaintiff |
Docket Report
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| Filing 96 Judge Indira Talwani: ORDER entered. MEMORANDUM AND ORDER. The court finds that Frederick's motion for leave to amend is futile where the supplemental facts fail to cure the jurisdictional deficiencies identified in the Memorandum and Order [Doc. No. #89 ]. For the foregoing reasons, Frederick's Motion for Leave to File Second Amended Complaint [Doc. No. #91 ] is DENIED. This case is CLOSED.IT IS SO ORDERED. Please see attached. (Kelly, Danielle) |
| Filing 95 CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re #91 MOTION for Leave to File Second Amended Complaint by Kimberly A. Dougherty on behalf of Marcia Frederick filed by on behalf of Marcia Frederick. (Dougherty, Kimberly) |
| Filing 94 Opposition re #91 MOTION for Leave to File Second Amended Complaint filed by Richard Carlson. (Freeley, Austin) |
| Filing 93 Judge Indira Talwani: ELECTRONIC ORDER: granting Carlson's assented-to Motion for Extension of Time #92 to November 15, 2022, to file a response to Frederick's Motion for Leave to File Second Amended Complaint #91 . (Kelly, Danielle) |
| Filing 92 MOTION for Extension of Time to 11/15/2022 to File Opposition to Plaintiff's Motion for Leave to Amend Complaint by Richard Carlson.(Freeley, Austin) Modified on 10/25/2022: Corrected event type (Kelly, Danielle). |
| Filing 91 MOTION for Leave to File Second Amended Complaint by Marcia Frederick. (Attachments: #1 Exhibit Exhibit 1- Second Amended Complaint)(Dougherty, Kimberly) |
| Filing 89 Judge Indira Talwani: ORDER entered. MEMORANDUM AND ORDER. For the foregoing reasons, Carlson's Motion to Dismiss [Doc. No. #48 ] is GRANTED. IT IS SO ORDERED. Please see attached. (Kelly, Danielle) |
| Filing 90 Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Motion Hearing held on 9/15/2022 re #48 MOTION to Dismiss filed by Richard Carlson. Case called. Court heard argument from counsel. The motion will be granted. Plaintiff may file a motion for leave to file an amended complaint; proposed amended complaint must be attached. Order to follow. (Court Reporter: Robert Paschal at rwp.reporter@gmail.com.)(Attorneys present: Kimberly A. Dougherty, Austin J. Freeley) (MacDonald, Gail) |
| Filing 88 ELECTRONIC NOTICE Resetting Hearing on Motion #48 MOTION to Dismiss : Motion Hearing set for 9/15/2022 01:30 PM in Courtroom 9 (In person only) before Judge Indira Talwani. PLEASE NOTE CHANGE IS ONLY TO LATER TIME.(MacDonald, Gail) |
| Filing 87 ELECTRONIC NOTICE Setting Hearing on Motion #48 MOTION to Dismiss : Motion Hearing set for 9/15/2022 10:00 AM in Courtroom 9 (In person only) before Judge Indira Talwani. (MacDonald, Gail) |
| Filing 86 Judge Indira Talwani: ELECTRONIC ORDER: in light of Plaintiff's dismissal of all claims against the United States Olympic Committee and USA Gymnastics, the stay of this action is lifted, and the Motion to Dismiss #38 , Motion to Dismiss #40 , and Motion for Leave to File Supplemental Authority #79 are denied as moot. (MacDonald, Gail) |
| Filing 85 NOTICE of Voluntary Dismissal by Marcia Frederick (Dougherty, Kimberly) |
| Filing 84 NOTICE of Withdrawal of Appearance by Cheryl Lorraine Allen-Ricciardi (Allen-Ricciardi, Cheryl) |
| Judge Indira Talwani: ORDER entered. Case stayed.(MacDonald, Gail) |
| Filing 83 Judge Indira Talwani: ELECTRONIC ORDER: In accordance with the order of the United States Bankruptcy Court for the Southern District of Indiana in case 18-09108-RLM-11, a copy of which is filed here as docket entry #82 , this case is stayed in its entirety pending further order. (Kinsella, Devan) |
| Filing 82 NOTICE by USA Gymnastics USAGs Notice of Orders Entered by the US Bankruptcy Court for the Southern District of Indiana (Attachments: #1 Exhibit A, #2 Exhibit B)(Portinga, D.) |
| Filing 81 NOTICE of Withdrawal of Appearance by Michael J. Derderian (Derderian, Michael) |
| Filing 80 Opposition re #79 MOTION for Leave to File Supplemental Authority in Support of her Opposition to Defendant USOC's Motion to Dismiss filed by United States Olympic Committee. (Maya, Michael) |
| Filing 79 MOTION for Leave to File Supplemental Authority in Support of her Opposition to Defendant USOC's Motion to Dismiss by Marcia Frederick.(Dougherty, Kimberly) |
| Filing 78 REPLY to Response to #48 MOTION to Dismiss Complaint filed by Richard Carlson. (Attachments: #1 Exhibit Deed of Sale (MA), #2 Exhibit Deed of Purchase (CT), #3 Exhibit Transcript of Hearing)(Freeley, Austin) |
| Filing 77 REPLY to Response to #40 MOTION to Dismiss filed by United States Olympic Committee. (Attachments: #1 Exhibit 1)(Maya, Michael) |
| Filing 76 NOTICE is hereby given that an official transcript of a proceeding has been filed by the court reporter in the above-captioned matter. Counsel are referred to the Court's Transcript Redaction Policy, available on the court website at #http://www.mad.uscourts.gov/caseinfo/transcripts.htm (Scalfani, Deborah) |
| Filing 75 Transcript of Scheduling Conference held on November 26, 2018, before Judge Indira Talwani. The Transcript may be purchased through the Court Reporter, viewed at the public terminal, or viewed through PACER after it is released. Court Reporter Name and Contact Information: Linda Walsh at lwalshsteno@gmail.com Redaction Request due 1/2/2019. Redacted Transcript Deadline set for 1/11/2019. Release of Transcript Restriction set for 3/11/2019. (Scalfani, Deborah) |
| Filing 74 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING IN PART, DENYING IN PART Richard Carlson's #71 Motion for leave to file reply. To the extent that Carlson seeks to argue in support of his 12(b)(6) motion that the facts set forth in the complaint are "demonstrably false," that argument is not appropriate on a motion to dismiss. To the extent that additional pages are narrowly focused on responding to arguments made by Plaintiff (and not reiterating points in the opening brief), the motion is ALLOWED, with such brief not to exceed 5 pages. The brief and attachments filed at docket entry #72 are STRICKEN. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (DaSilva, Carolina) |
| Filing 73 Judge Indira Talwani: ELECTRONIC ORDER entered. ALLOWING IN PART, DENYING IN PART United States Olympic Committee's #70 Motion for Leave to File Reply. To the extent the additional pages are designed to "ensure that the parties have roughly equal space to address the Safe Sport Act and timeliness issues," the request is DENIED. To the extent that additional pages are narrowly focused on responding to arguments made by Plaintiff (and not reiterating points in the opening brief), the motion is ALLOWED, with such brief not to exceed 5 pages. Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include- Leave to file granted on (date of order)- in the caption of the document. (DaSilva, Carolina) |
| Filing 72 This document has been STRICKEN from the record per order at [#74] #72 REPLY to Response to #48 MOTION to Dismiss filed by Richard Carlson. (Attachments: #1 Exhibit Deed of Sale (MA), #2 Exhibit Deed of Purchase (Conn.), #3 Exhibit Hearing Transcript, #4 Exhibit Panel's Findings)(Freeley, Austin) (DaSilva, Carolina). |
| Filing 71 MOTION for Leave to File Reply Brief by Richard Carlson.(Freeley, Austin) |
| Filing 70 MOTION for Leave to File Reply Memorandum by United States Olympic Committee. (Attachments: #1 Exhibit A, #2 Exhibit 1)(Maya, Michael) |
| Filing 69 SUGGESTION OF BANKRUPTCY Upon the Record as to USA Gymnastics, Inc. by USA Gymnastics. (Portinga, D.) |
| Filing 68 Judge Indira Talwani: ORDER entered. SCHEDULING ORDER. See Attached Order. (DaSilva, Carolina) |
| Filing 67 Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Scheduling Conference held on 11/26/2018. Case called. Court has colloquy with counsel. The class cert. issue shall be resolved initially. The court will set a schedule as to all claims other than the Safe Sport Act claim and will set a Status Conf. in re: to discovery. Motions to Dismiss to be taken under advisement. (Court Reporter: Linda Walsh is at lwalshsteno@gmail.com.) (Attorneys present: Dougherty, Lee, Anderson, Soukup, Frederico, Derderian, Freeley) (MacDonald, Gail) Modified on 11/29/2018, to correct Court Reporter's name (MacDonald, Gail). |
| Filing 66 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING IN PART, nunc pro tunc, #56 AMENDED MOTION for Leave to File. The #59 Opposition is accepted as filed. All Counsel are cautioned, however, that: (1) motions for additional pages are not favored in this session; (2) such motions should be made with sufficient time for the court to address the motion before briefs with excessive pages are filed; and (3) all text, including footnotes, must be in at least size 12 font. (DaSilva, Carolina) |
| Filing 65 CERTIFICATION pursuant to Local Rule 16.1 by Marcia Frederick. Filed as a separate document, using the proper event.(DaSilva, Carolina) |
| Filing 64 CERTIFICATION pursuant to Local Rule 16.1 by United States Olympic Committee. Filed as a separate document, using the proper event.(DaSilva, Carolina) |
| Filing 63 Judge Indira Talwani: ELECTRONIC ORDER entered DENYING Defendant George Ward's #42 MOTION to Dismiss as moot in light of #55 NOTICE of Voluntary Dismissal. (DaSilva, Carolina) |
| Filing 62 JOINT STATEMENT of counsel . (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, # 4 Exhibit D- DELETED and refilled as a separate entry )(Dougherty, Kimberly) (DaSilva, Carolina). |
| Filing 61 CERTIFICATION pursuant to Local Rule 16.1 by Defendant Carlson. (Freeley, Austin) |
| Filing 60 CERTIFICATION pursuant to Local Rule 16.1 . (Frederico, Donald) |
| Filing 59 Opposition re #38 MOTION to Dismiss , #40 MOTION to Dismiss filed by Marcia Frederick. (Dougherty, Kimberly) |
| Filing 58 Opposition re #48 MOTION to Dismiss filed by Marcia Frederick. (Dougherty, Kimberly) |
| Filing 57 OPPOSITION to Defendant USOC's Request for Judicial Notice re: #40 MOTION to Dismiss by Marcia Frederick (Dougherty, Kimberly) Modified text and docket entry relationships on 11/19/2018 (DaSilva, Carolina). |
| Filing 56 AMENDED MOTION for Leave to File Excess Pages by Marcia Frederick.(Dougherty, Kimberly) |
| Filing 55 NOTICE of Voluntary Dismissal by Marcia Frederick (Dougherty, Kimberly) |
| Filing 54 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #53 Assented to MOTION for Leave to File Excess Pages and Omnibus Response ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (DaSilva, Carolina) |
| Filing 53 Assented to MOTION for Leave to File Excess Pages and Omnibus Response by Marcia Frederick.(Dougherty, Kimberly) |
| Filing 52 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #50 Motion for Leave to Appear Pro Hac Vice Added Jennie L. Anderson ; ALLOWING #51 Motion for Leave to Appear Pro Hac Vice Added Lori E. Andrus. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (DaSilva, Carolina) |
| Filing 51 Assented to MOTION for Leave to Appear Pro Hac Vice for admission of Lori E. Andrus Filing fee: $ 100, receipt number 0101-7407489 by Marcia Frederick. (Attachments: #1 Exhibit)(Dougherty, Kimberly) |
| Filing 50 Assented to MOTION for Leave to Appear Pro Hac Vice for admission of Jennie L. Anderson Filing fee: $ 100, receipt number 0101-7407482 by Marcia Frederick. (Attachments: #1 Exhibit)(Dougherty, Kimberly) |
| Filing 49 MEMORANDUM in Support re #48 MOTION to Dismiss filed by Richard Carlson. (Attachments: #1 Affidavit Richard Carlson)(Freeley, Austin) |
| Filing 48 MOTION to Dismiss by Richard Carlson.(Freeley, Austin) |
| Filing 47 Judge Indira Talwani: ELECTRONIC ORDER entered granting #46 Motion for Leave to File Excess Pages ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. (MacDonald, Gail) |
| Filing 46 Assented to MOTION for Leave to File Excess Pages by Richard Carlson.(Freeley, Austin) |
| Filing 45 NOTICE of Appearance by Lisa S. Lee on behalf of Marcia Frederick (Lee, Lisa) |
| Filing 44 AFFIDAVIT of George Ward in Support re #42 MOTION to Dismiss filed by George Ward. (Davis, Joseph) |
| Filing 43 MEMORANDUM in Support re #42 MOTION to Dismiss filed by George Ward. (Davis, Joseph) |
| Filing 42 MOTION to Dismiss by George Ward.(Davis, Joseph) |
| Filing 41 MEMORANDUM in Support re #40 MOTION to Dismiss filed by United States Olympic Committee. (Maya, Michael) |
| Filing 40 MOTION to Dismiss by United States Olympic Committee.(Maya, Michael) (Main Document 40 replaced on 10/19/2018) (Garvin, Brendan). |
| Filing 39 MEMORANDUM in Support re #38 MOTION to Dismiss filed by USA Gymnastics. (Frederico, Donald) |
| Filing 38 MOTION to Dismiss by USA Gymnastics.(Frederico, Donald) |
| Filing 37 NOTICE of Appearance by Cheryl Lorraine Allen-Ricciardi on behalf of USA Gymnastics (Allen-Ricciardi, Cheryl) |
| Filing 36 Judge Indira Talwani: ELECTRONIC ORDER entered granting in part and denying in part #35 Emergency Motion for Extension of Time. Counsel's assertion that additional time is necessary to respond to the Amended Complaint in part because of "the little time" Defendant Richard Carlson "has been afforded" to respond to the Amended Complaint is frivolous where the previous deadline was set with the agreement of Defendant Carlson's original counsel and the motion provides no explanation for original counsel's failure to meet the agreed-upon deadline. As a courtesy to newly retained the counsel, the court will extend the time to respond to October 26, 2018. (Talwani, Indira) |
| Filing 35 Emergency MOTION for Extension of Time to November 9, 2018 to File dispositive motion by Richard Carlson.(Freeley, Austin) |
| Filing 34 NOTICE of Appearance by Austin J. Freeley on behalf of Richard Carlson (Freeley, Austin) |
| Filing 33 Judge Indira Talwani: ELECTRONIC ORDER entered granting #32 Motion for Leave to File Excess Pages ; Counsel using the Electronic Case Filing System should now file the document for which leave to file has been granted in accordance with the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on (date of order)- in the caption of the document. Any similar request by Plaintiff must be made by motion. (MacDonald, Gail) |
| Filing 32 MOTION for Leave to File Excess Pages by USA Gymnastics, United States Olympic Committee.(Maya, Michael) |
| Filing 31 NOTICE of Scheduling Conference Scheduling Conference set for 11/26/2018 02:45 PM in Courtroom 9 before Judge Indira Talwani. Counsel for the plaintiff(s) is responsible for ensuring that all parties and/or their attorneys who have not filed an answer or appearance with the court are notified of the date of the scheduling conference. (MacDonald, Gail) |
| Filing 30 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #29 Joint Motion Concerning Initial Case Scheduling. (DaSilva, Carolina) |
| Filing 29 Joint Motion Concerning Initial Case Scheduling. (Dougherty, Kimberly) Modified event type and docket text on 10/4/2018 (DaSilva, Carolina). |
| Filing 28 Judge Indira Talwani: ELECTRONIC ORDER entered granting #27 Joint MOTION Concerning Initial Case Scheduling filed by George Ward. George Ward answer/response to Am.Complaint due 10/19/2018. (MacDonald, Gail) |
| Filing 27 Joint MOTION Concerning Initial Case Scheduling by George Ward.(Bradshaw, Kelly) |
| Filing 26 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #23 Motion for Leave to Appear Pro Hac Vice Added D. Andrew Portinga. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (DaSilva, Carolina) |
| Filing 25 NOTICE of Appearance by Kelly M. Bradshaw on behalf of George Ward (Bradshaw, Kelly) |
| Filing 24 NOTICE of Appearance by Joseph P. Davis, III on behalf of George Ward (Davis, Joseph) |
| Filing 23 MOTION for Leave to Appear Pro Hac Vice for admission of D. Andrew Portinga Filing fee: $ 100, receipt number 0101-7344802 by USA Gymnastics. (Attachments: #1 Exhibit A - Declaration)(Frederico, Donald) |
| Filing 22 AMENDED COMPLAINT against Muriel Grossfeld, Richard Carlson, USA Gymnastics, United States Olympic Committee, George Ward, filed by Marcia Frederick.(Dougherty, Kimberly) |
| Filing 21 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #20 Motion for Leave to Appear Pro Hac Vice Added Carolyn June Kubota. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (DaSilva, Carolina) |
| Filing 20 MOTION for Leave to Appear Pro Hac Vice for admission of Carolyn J. Kubota Filing fee: $ 100, receipt number 0101-7339722 by United States Olympic Committee. (Attachments: #1 Exhibit A, #2 Text of Proposed Order)(Maya, Michael) |
| Filing 19 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #17 Motion for Leave to Appear Pro Hac Vice Added Mitchell Aaron Kamin. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (DaSilva, Carolina) |
| Filing 18 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING the parties' #12 Joint Motion Concerning Initial Case Scheduling. Plaintiff shall file an Amended Complaint on or before September 28, 2018. Defendants shall respond on or before October 19, 2018. If either Defendant files a motion to dismiss, Plaintiff shall file any opposition on or before November 16, 2018. (DaSilva, Carolina) |
| Filing 17 MOTION for Leave to Appear Pro Hac Vice for admission of Mitchell A. Kamin Filing fee: $ 100, receipt number 0101-7337851 by United States Olympic Committee. (Attachments: #1 Exhibit A, #2 Text of Proposed Order)(Maya, Michael) |
| Filing 16 Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING #15 Motion for Leave to Appear Pro Hac Vice Added Andrew Soukup. Attorneys admitted Pro Hac Vice must register for electronic filing if the attorney does not already have an ECF account in this district. To register go to the Court website at www.mad.uscourts.gov. Select Case Information, then Electronic Filing (CM/ECF) and go to the CM/ECF Registration Form. (DaSilva, Carolina) |
| Filing 15 MOTION for Leave to Appear Pro Hac Vice for admission of Andrew Soukup Filing fee: $ 100, receipt number 0101-7337455 by United States Olympic Committee. (Attachments: #1 Exhibit A, #2 Text of Proposed Order)(Maya, Michael) |
| Filing 14 CORPORATE DISCLOSURE STATEMENT by United States Olympic Committee. (Maya, Michael) |
| Filing 13 NOTICE of Appearance by Michael M. Maya on behalf of United States Olympic Committee (Maya, Michael) |
| Filing 12 Joint Motion Concerning Initial Case Scheduling (Dougherty, Kimberly) Modified text and event type on 9/26/2018 (DaSilva, Carolina). |
| Filing 11 NOTICE of Appearance by Michael J. Derderian on behalf of USA Gymnastics (Derderian, Michael) |
| Filing 10 NOTICE of Appearance by Donald R. Frederico on behalf of USA Gymnastics (Frederico, Donald) |
| Filing 9 SUMMONS Returned Executed George Ward served on 9/12/2018, answer due 10/3/2018. (Dougherty, Kimberly) |
| Filing 8 SUMMONS Returned Executed Muriel Grossfeld served on 9/12/2018, answer due 10/3/2018. (Dougherty, Kimberly) |
| Filing 7 WAIVER OF SERVICE Returned Executed by Marcia Frederick. United States Olympic Committee waiver sent on 9/14/2018, answer due 11/13/2018. (Dougherty, Kimberly) |
| Filing 6 AFFIDAVIT OF SERVICE Executed by Marcia Frederick. Richard Carlson served on 9/11/2018, answer due 10/2/2018. Acknowledgement filed by Marcia Frederick. (Dougherty, Kimberly) |
| Filing 5 AFFIDAVIT OF SERVICE Executed by Marcia Frederick. USA Gymnastics served on 9/6/2018, answer due 9/27/2018. Acknowledgement filed by Marcia Frederick. (Dougherty, Kimberly) |
| Filing 4 AFFIDAVIT OF SERVICE Executed by Marcia Frederick. United States Olympic Committee served on 9/5/2018, answer due 9/26/2018. Acknowledgement filed by Marcia Frederick. (Dougherty, Kimberly) |
| Filing 3 Summons Issued as to Richard Carlson, Muriel Grossfeld, USA Gymnastics, United States Olympic Committee, George Ward. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (Vieira, Leonardo) |
| Filing 2 ELECTRONIC NOTICE of Case Assignment. Judge Indira Talwani assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge M. Page Kelley. (Pacho, Arnold) |
| Filing 1 COMPLAINT Class Action Complaint re Safe Sport Act Violations against All Defendants Filing fee: $ 400, receipt number 0101-7195354 (Fee Status: Filing Fee paid), filed by Marcia Frederick, individually, and on behalf of all others similarly situated. (Attachments: #1 Civil Cover Sheet, #2 Category Sheet)(Dougherty, Kimberly) |
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