Hayes v. Ford Motor Company et al
| Jennifer Hayes |
| Ford Motor Company, Corporate Services Holdings, Inc. doing business as Bartech and Kweon Pangyu |
| 4:2021cv00769 |
| October 22, 2021 |
| US District Court for the Western District of Missouri |
| Beth Phillips |
| Motor Vehicle |
| 28 U.S.C. § 1446 Petition for Removal- Personal Injury |
| Plaintiff |
Docket Report
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| Filing 81 Clerk's ORDER OF DISMISSAL. (Murphy-Carr, Shauna) |
| Filing 80 STIPULATION of dismissal by Ford Motor Company, Kweon Pangyu. (Rozell, Sherry) |
| Filing 79 STATUS REPORT Joint by Kweon Pangyu. (Rozell, Sherry) |
Filing 78
ORDER: The parties have advised the remaining claims in this case have been resolved. The parties are directed to file a Stipulation of Dismissal or a Status Report by 11/22/2022. Signed on 10/25/2022 by Chief District Judge Beth Phillips. This is a TEXT ONLY ENTRY. No document is attached. (Wolfe, Steve)
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| Filing 77 SUGGESTIONS in support re #76 MOTION for summary judgment filed by John Cusick on behalf of Plaintiff Jennifer Hayes. (Attachments: #1 Exhibit A - Deposition of Pangyu Kweon, #2 Exhibit B - Missouri Uniform Crash Report No KC20013742, #3 Exhibit C - Deposition of Jennifer Hayes, #4 Exhibit D - Deposition of Bartech Corporate Representative)(Related document(s) #76 ) (Cusick, John) |
| Filing 76 MOTION for summary judgment filed by John Cusick on behalf of Jennifer Hayes. Suggestions in opposition/response due by 9/28/2022 unless otherwise directed by the court. (Cusick, John) |
| Filing 75 CERTIFICATE OF SERVICE by Corporate Services Holdings, Inc., Kweon Pangyu Def's Supp Id and Bartech's Supp Discovery Responses filed by Julia A Palmer on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu.(Palmer, Julia) |
| Filing 74 NOTICE to take deposition of Benjamin Bjerke filed by Julia A Palmer on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu.(Palmer, Julia) |
| Filing 73 NOTICE to take deposition of Cori Ingram filed by Julia A Palmer on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu.(Palmer, Julia) |
| Filing 72 SUGGESTIONS in opposition re #71 MOTION for extension of time Re: Scheduling Order Deadlines on behalf of Defendants Bartech and Kweon filed by John Cusick on behalf of Plaintiff Jennifer Hayes. Reply suggestions due by 9/20/2022 unless otherwise directed by the court. (Attachments: #1 Exhibit A - January 21, 2022, Email from John Cusick to Brent Salsbury, #2 Exhibit B - January 26, 2022, Email from Brent Salsbury to John Cusick, #3 Exhibit C - September 2, 2022 Email from Brent Salsbury to John Cusick, #4 Exhibit D - Mediation Invite from Rich McLeod, #5 Exhibit E - May 18 Email from Brent Salsbury, #6 Exhibit F - May 19 Email from Stephen Bledsoe, #7 Exhibit G - June 23-24, 2022 Email from the Court to Counsel)(Related document(s) #71 ) (Cusick, John) |
| Filing 71 MOTION for extension of time Re: Scheduling Order Deadlines on behalf of Defendants Bartech and Kweon filed by Julia A Palmer on behalf of Corporate Services Holdings, Inc.. Suggestions in opposition/response due by 9/15/2022 unless otherwise directed by the court. (Attachments: #1 Exhibit A)(Attorney Julia A Palmer added to party Corporate Services Holdings, Inc.(pty:dft))(Palmer, Julia) |
| Filing 70 Supplemental CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 69 NOTICE of appearance by Sherry A. Rozell on behalf of Corporate Services Holdings, Inc. (Rozell, Sherry) |
| Filing 68 NOTICE of appearance by Sherry A. Rozell on behalf of Corporate Services Holdings, Inc. (Attorney Sherry A. Rozell added to party Corporate Services Holdings, Inc.(pty:dft))(Rozell, Sherry) |
| Filing 67 NOTICE of filing Designation of Mediation by Kweon Pangyu (Rozell, Sherry) |
| Filing 66 Def. Kweon's ANSWER to #63 Amended Complaint on behalf of Kweon Pangyu.(Rozell, Sherry) |
| Filing 65 Defendant Corporate Services Holdings, inc, d/b/a Bartech's ANSWER to #63 Amended Complaint on behalf of Corporate Services Holdings, Inc..(Salsbury, Brent) |
| Filing 64 AMENDED NOTICE OF INCLUSION FOR MEDIATION AND ASSESSMENT PROGRAM (MAP). REVIEW NOTICE AND MAP GENERAL ORDER CAREFULLY FOR IMPORTANT CHANGES, DEADLINES AND REQUIREMENTS.Notice of MAP assignment to an outside mediator. (Attachments: #1 MAP General Order)(Kern, Kendra) |
| Filing 63 AMENDED COMPLAINT against Corporate Services Holdings, Inc., Kweon Pangyu filed by John Cusick on behalf of Jennifer Hayes.(Cusick, John) |
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Filing 62
ORDER granting #61 Plaintiff's Motion for Leave to File First Amended Complaint is GRANTED. Plaintiff has 3 business days to electronically file the First Amended Complaint as presented in 61-1. Signed on 7/12/22 by Chief District Judge Beth Phillips. This is a TEXT ONLY ENTRY. No document is attached. (Cordell, Annette)
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| Filing 61 MOTION for leave to file First Amended Complaint filed by John Cusick on behalf of Jennifer Hayes. Suggestions in opposition/response due by 7/25/2022 unless otherwise directed by the court. (Attachments: #1 Exhibit A First Amended Complaint for Damages)(Cusick, John) |
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Filing 60
ORDER granting #59 motion to appear pro hac vice entered by Clerk of Court. Attorney Julia A. Palmer for Kweon Pangyu allowed to appear pro hac vice. This entry will serve as authorization for the pro hac participation by the attorney. Western District of Missouri Local Rule 5.1 requires documents to be filed electronically. If pro hac vice counsel has not already done so, counsel is directed to immediately register for a WDMO e-filing account for NextGen CM/ECF. This will enable counsel to electronically file documents and receive electronic notification of filings. Register for a WDMO e-filing account at #PACER. This is a TEXT ONLY ENTRY. No document is attached. (Berner, Crystal)
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| Filing 59 Motion to allow Julia A. Palmer to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8009378) filed by Sherry A. Rozell on behalf of Kweon Pangyu. (Rozell, Sherry) |
| Filing 58 CERTIFICATE OF SERVICE by Kweon Pangyu regarding Def. Kweon's responses to Pltf's RFAs filed by Sherry A. Rozell on behalf of Defendant Kweon Pangyu.(Rozell, Sherry) |
| Filing 57 NOTICE to take deposition of Defendant Bartech Group's Corporate Representative filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 56 NOTICE to take deposition of Andrew Brown, M.D. filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 55 NOTICE to take deposition of Eric H. Sincoff, MD filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
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Filing 54
ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE DEFENDANTS' EXPERT DESIGNATION OF DR. ALEXANDER BAILEY #45 Plaintiff's Motion to Strike, (Doc. 45), is GRANTED and Defendants will not be permitted to elicit expert testimony from Dr. Bailey at trial. Signed on 6/29/22 by Chief District Judge Beth Phillips. (Cordell, Annette)
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| Filing 53 STIPULATION Re: Extension of Time for Def. Kweon to Respond to Pltf's RFAs by Kweon Pangyu. (Rozell, Sherry) |
| Filing 52 NOTICE of filing Supplemental Exhibit B to Document #48 Defendant's Memorandum in Opposition by Corporate Services Holdings, Inc. re #48 Suggestions in Opposition to Motion, (Salsbury, Brent) |
| Filing 51 NOTICE of filing Supplemental Exhibit A to Document #48 Defendant's Memorandum in Opposition by Corporate Services Holdings, Inc. re #48 Suggestions in Opposition to Motion, (Salsbury, Brent) |
| Filing 50 NOTICE of appearance by Sherry A. Rozell on behalf of Kweon Pangyu (Attorney Sherry A. Rozell added to party Kweon Pangyu(pty:dft))(Rozell, Sherry) |
| Filing 49 REPLY SUGGESTIONS to motion re #45 MOTION in limine to Exclude Defendants Corporate Services Group Holdings, Inc. and Pangyu Kweon's Expert Witness Disclosures and Suggestions in Support filed by John Cusick on behalf of Plaintiff Jennifer Hayes. (Attachments: #1 Exhibit A, Dr. Alexander Bailey's Report, #2 Exhibit B, Plaintiff's Life Care Plan Report, #3 Exhibit C, Plaintiff's Medical Expert Report, #4 Exhibit D, Defendants' Expert Witness Report, #5 Exhibit E, Dr. Alexander Bailey's CV)(Related document(s) #45 ) (Cusick, John) |
| Filing 48 SUGGESTIONS in opposition re #45 MOTION in limine to Exclude Defendants Corporate Services Group Holdings, Inc. and Pangyu Kweon's Expert Witness Disclosures and Suggestions in Support filed by Brent Salsbury on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu. Reply suggestions due by 6/29/2022 unless otherwise directed by the court. (Related document(s) #45 ) (Salsbury, Brent) |
| Filing 47 NOTICE of filing Plaintiff's Request for Judicial Notice by Jennifer Hayes (Cusick, John) |
| Filing 46 NOTICE of appearance by Kenneth E. Barnes on behalf of Jennifer Hayes (Attorney Kenneth E. Barnes added to party Jennifer Hayes(pty:pla))(Barnes, Kenneth) |
| Filing 45 MOTION in limine to Exclude Defendants Corporate Services Group Holdings, Inc. and Pangyu Kweon's Expert Witness Disclosures and Suggestions in Support filed by John Cusick on behalf of Jennifer Hayes. Suggestions in opposition/response due by 6/22/2022 unless otherwise directed by the court. (Attachments: #1 Exhibit A - Defendants' Expert Witness Report, #2 Exhibit B - Salsbury 20220427 Email)(Cusick, John) |
| Filing 44 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Brent Salsbury on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu.(Salsbury, Brent) |
| Filing 43 CERTIFICATE OF SERVICE by Jennifer Hayes of Plaintiff's Requests for Admissions to Defendants Pangyu Kweon and Corporate Services Group Holdings, Inc. d/b/a Bartech filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 42 CERTIFICATE OF SERVICE by Jennifer Hayes of Plaintiff's First Discovery Requests to Defendant Corporate Services Holdings Group, Inc. d/b/a Bartech filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
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Filing 41
ORDER granting #40 Defendants Unopposed Motion for Extension of Time to Disclose Rebuttal Experts is GRANTED, up to and including June 1, 2022. Signed on 4/27/22 by Chief District Judge Beth Phillips. This is a TEXT ONLY ENTRY. No document is attached. (Cordell, Annette)
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| Filing 40 MOTION for extension of time to Disclose Rebuttal Experts filed by Brent Salsbury on behalf of Corporate Services Holdings, Inc.. Suggestions in opposition/response due by 5/11/2022 unless otherwise directed by the court. (Salsbury, Brent) |
| Filing 39 Clerk's ORDER OF DISMISSAL as to Defendant Ford Motor Company. (Murphy-Carr, Shauna) |
| Filing 38 STIPULATION of dismissal Without Prejudice by Ford Motor Company. (Bledsoe, Stephen) |
| Filing 37 NOTICE to take deposition of Jennifer Hayes filed by Brent Salsbury on behalf of Defendants Corporate Services Holdings, Inc., Kweon Pangyu.(Salsbury, Brent) |
| Filing 36 CERTIFICATE OF SERVICE by All Plaintiffs filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 35 NOTICE to take deposition of Sarah Landers, M.D. filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 34 CERTIFICATE OF SERVICE by Jennifer Hayes filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 33 CERTIFICATE OF SERVICE by Ford Motor Company filed by Stephen M. Bledsoe on behalf of Defendant Ford Motor Company.(Bledsoe, Stephen) |
| Filing 32 First NOTICE to take deposition of Pangyu Kweon filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 31 PROTECTIVE ORDER. The Court enters a Protective Order. Signed on 2/9/22 by Chief District Judge Beth Phillips. (Attachments: #1 Exhibit A: Declaration) (Cordell, Annette) |
| Filing 30 CERTIFICATE OF SERVICE by Kweon Pangyu filed by Brent Salsbury on behalf of Defendant Kweon Pangyu.(Salsbury, Brent) |
| Filing 29 Joint MOTION for protective order filed by Stephen M. Bledsoe on behalf of Ford Motor Company. Suggestions in opposition/response due by 2/22/2022 unless otherwise directed by the court. (Bledsoe, Stephen) |
| Filing 28 CERTIFICATE OF SERVICE by Ford Motor Company filed by Stephen M. Bledsoe on behalf of Defendant Ford Motor Company.(Bledsoe, Stephen) |
| Filing 27 CERTIFICATE OF SERVICE by Ford Motor Company filed by Stephen M. Bledsoe on behalf of Defendant Ford Motor Company.(Bledsoe, Stephen) |
| Filing 26 CERTIFICATE OF SERVICE by Jennifer Hayes of Plaintiff's Amended Opening Interrogatories to Defendant Ford Motor Company filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 25 CERTIFICATE OF SERVICE by Jennifer Hayes of Plaintiff's Amended Opening Interrogatories to Defendant Pangyu Kweon filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
| Filing 24 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Brent Salsbury on behalf of Defendant Kweon Pangyu.(Salsbury, Brent) |
| Filing 23 ANSWER to Complaint on behalf of Kweon Pangyu.(Attorney C Zachary Vaughn added to party Kweon Pangyu(pty:dft))(Vaughn, C) |
| Filing 22 NOTICE of filing CONSENT TO REMOVAL by Kweon Pangyu re #1 Notice of Removal, (Salsbury, Brent) |
| Filing 21 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Stephen M. Bledsoe on behalf of Defendant Ford Motor Company.(Bledsoe, Stephen) |
| Filing 20 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by John Cusick on behalf of Plaintiff Jennifer Hayes.(Cusick, John) |
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Filing 19
ORDER denying #12 Plaintiff's Motion to Remand is DENIED. Signed on 11/30/21 by Chief District Judge Beth Phillips. (Cordell, Annette)
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| Filing 18 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Brent Salsbury on behalf of Defendant Corporate Services Holdings, Inc..(Salsbury, Brent) |
| Filing 17 REPLY SUGGESTIONS to motion re #12 MOTION to remand filed by John Cusick on behalf of Plaintiff Jennifer Hayes. (Related document(s) #12 ) (Cusick, John) |
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Filing 16
SCHEDULING ORDER: Discovery due by 9/6/2022. Dispositive Motions due by 10/3/2022. Teleconference set for 2/9/2023 at 1:30 PM. Pretrial Conference set for 2/23/2023 at 1:30 PM Courtroom 7A, Kansas City (BP) before Chief District Judge Beth Phillips. Jury Trial set for 3/6/2023 at 8:30 AM in Courtroom 7A, Kansas City (BP) before Chief District Judge Beth Phillips. Signed on 11/23/21 by Chief District Judge Beth Phillips. (Cordell, Annette)
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| Filing 15 REPORT of Rule 26(f) planning meeting. (Cusick, John) |
| Filing 14 SUGGESTIONS in opposition re #12 MOTION to remand filed by Brent Salsbury on behalf of Defendant Corporate Services Holdings, Inc.. Reply suggestions due by 11/30/2021 unless otherwise directed by the court. (Related document(s) #12 ) (Salsbury, Brent) |
| Filing 13 SUGGESTIONS in support re #12 MOTION to remand filed by John Cusick on behalf of Plaintiff Jennifer Hayes. (Related document(s) #12 ) (Cusick, John) |
| Filing 12 MOTION to remand filed by John Cusick on behalf of Jennifer Hayes. Suggestions in opposition/response due by 11/22/2021 unless otherwise directed by the court. (Cusick, John) |
| Filing 11 ANSWER to Complaint on behalf of Corporate Services Holdings, Inc.(Vaughn, C) Modified on 11/2/2021: Main document replaced. NEF regenerated. (Melvin, Greg) |
| Filing 10 DISCLOSURE OF CORPORATE INTERESTS filed by Stephen M. Bledsoe on behalf of Defendant Ford Motor Company.(Bledsoe, Stephen) |
| Filing 9 ANSWER to Complaint on behalf of Ford Motor Company.(Bledsoe, Stephen) |
| Filing 8 NOTICE of appearance by Laura K. Brooks on behalf of Ford Motor Company (Attorney Laura K. Brooks added to party Ford Motor Company(pty:dft))(Brooks, Laura) |
| Filing 7 NOTICE of appearance by Stephen M. Bledsoe on behalf of Ford Motor Company (Bledsoe, Stephen) |
| Filing 6 DEMAND for Trial by Jury by Corporate Services Holdings, Inc. (Vaughn, C) Modified on 10/27/2021: Docket text corrected to match filing event. Motion termed. NEF regenerated. (Melvin, Greg) |
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Filing 5
ORDER. RULE 16 NOTICE. Proposed scheduling order due by 12/10/2021. Rule 26 conference due by 11/26/2021. Signed on 10/26/21 by Chief District Judge Beth Phillips. (Cordell, Annette)
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| Filing 4 NOTICE OF INCLUSION FOR MEDIATION AND ASSESSMENT PROGRAM (MAP). REVIEW NOTICE AND MAP GENERAL ORDER CAREFULLY FOR DEADLINES AND REQUIREMENTS.Notice of MAP assignment to Program Director. (Attachments: #1 MAP General Order)(Woods, Gloria) |
| Filing 3 DISCLOSURE OF CORPORATE INTERESTS filed by C Zachary Vaughn on behalf of Defendant Corporate Services Holdings, Inc., dba Bartech.(Vaughn, C) |
| Filing 2 NOTICE of appearance by C Zachary Vaughn on behalf of Corporate Services Holdings, Inc., dba Bartech (Vaughn, C) |
| Filing 1 NOTICE OF REMOVAL from Circuit Court of Jackson County, case number 2116-CV20018, filed by C Zachary Vaughn. Filing fee $402, receipt number AMOWDC-7639966. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D)(Vaughn, C) |
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