Khoshneviszadeh v. Sams West, Inc. et al
Plaintiff: Mohammad Khoshneviszadeh
Defendant: Sams West, Inc. and Kevin Cokeley
Case Number: 4:2022cv00012
Filed: January 10, 2022
Court: US District Court for the Western District of Missouri
Presiding Judge: Roseann Ketchmark
Nature of Suit: Civil Rights: Jobs
Cause of Action: 28 U.S.C. § 1331 Fed. Question: Employment Discrimination
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on April 20, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
April 20, 2022 Opinion or Order Filing 35 CLERK'S JUDGMENT (Wheeler, LaTandra)
April 20, 2022 Opinion or Order Remand letter and instructions sent to Circuit Court of Jackson County, Missouri. This is a text entry only - no document is attached. Mailed to Jackson County Circuit Court, Remand Department, 415 E. 12th Street, Kansas City MO 64106, via certified mail 7012 3460 0001 7395 5155. (Crocker, Susan)
April 19, 2022 Opinion or Order Filing 34 ORDER granting #13 Plaintiff's motion to remand. Signed on 4/19/2022 by District Judge Roseann Ketchmark. (Brown, Jonathan)
April 18, 2022 Opinion or Order Filing 33 REPLY SUGGESTIONS to motion re #22 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM re Counts VI and VII of Plaintiff's Amended Complaint filed by Kyle B. Russell on behalf of Defendant Kevin Cokeley. (Related document(s) #22 ) (Russell, Kyle)
April 4, 2022 Opinion or Order Filing 32 SUGGESTIONS in opposition re #22 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM re Counts VI and VII of Plaintiff's Amended Complaint filed by Phillip M. Murphy, II on behalf of Plaintiff Mohammad Khoshneviszadeh. Reply suggestions due by 4/18/2022 unless otherwise directed by the court. (Related document(s) #22 ) (Murphy, Phillip)
March 22, 2022 Opinion or Order Filing 31 ORDER granting #30 Plaintiff's motion for extension of time to respond as to #22 Defendant Cokeley's motion to dismiss. Plaintiff's suggestions in opposition/response due by 4/5/2022 unless otherwise directed by the court. Signed on 3/22/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
March 22, 2022 Opinion or Order Filing 30 MOTION for extension of time filed by Phillip M. Murphy, II on behalf of Mohammad Khoshneviszadeh. Suggestions in opposition/response due by 4/5/2022 unless otherwise directed by the court. (Murphy, Phillip)
March 18, 2022 Opinion or Order Filing 29 CERTIFICATE OF SERVICE by Sams West, Inc. of its 1st Interrogatories and 1st Requests for Production of Documents to Plaintiff filed by Kyle B. Russell on behalf of Defendant Sams West, Inc..(Russell, Kyle)
March 14, 2022 Opinion or Order Filing 28 Sam's West, Inc.'s ANSWER to #12 Amended Complaint on behalf of Sams West, Inc..(Russell, Kyle)
March 11, 2022 Opinion or Order Filing 27 SCHEDULING ORDER: Discovery due by 9/23/2022. Dispositive Motions due by 10/21/2022. Status Conference set for 8/24/2022 10:30 AM via Teleconference. Initial Pretrial Conference set for 3/17/2023 11:30 AM, Final Pretrial Conference set for 4/14/2023 11:30 AM, and Jury Trial set for 4/17/2023 08:30 AM in Courtroom 8E, Kansas City (RK) before District Judge Roseann Ketchmark. Signed on March 11, 2022 by District Judge Roseann Ketchmark. (Wheeler, LaTandra)
March 9, 2022 Opinion or Order NOTICE of filing: Mediation and Assessment Program Reminder: Your post-mediation status report is due within 10 calendar days after the mediation. See MAP FAQs on Court's website for specifics and submit report(s) to: map@mow.uscourts.gov. (Jones, Robin)
March 7, 2022 Opinion or Order Filing 26 DESIGNATION OF MEDIATOR naming Joe Eischens(Russell, Kyle)
March 7, 2022 Opinion or Order Filing 25 ORDER granting #21 Defendant Sam's West Inc.'s unopposed Motion for Extension of Time to Answer Plaintiff's amended complaint. Sam's West, Inc.'s answer due 3/14/2022. Signed on 3/7/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
March 7, 2022 Opinion or Order Filing 24 SUGGESTIONS in opposition re #13 MOTION to remand filed by Kyle B. Russell on behalf of Defendants Kevin Cokeley, Sams West, Inc.. Reply suggestions due by 3/21/2022 unless otherwise directed by the court. (Related document(s) #13 ) (Russell, Kyle)
March 7, 2022 Opinion or Order Filing 23 SUGGESTIONS in support re #22 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM re Counts VI and VII of Plaintiff's Amended Complaint filed by Kyle B. Russell on behalf of Defendant Kevin Cokeley. (Related document(s) #22 ) (Russell, Kyle)
March 7, 2022 Opinion or Order Filing 22 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM re Counts VI and VII of Plaintiff's Amended Complaint filed by Kyle B. Russell on behalf of Kevin Cokeley. Suggestions in opposition/response due by 3/21/2022 unless otherwise directed by the court. (Russell, Kyle)
March 7, 2022 Opinion or Order Filing 21 Second MOTION for extension of time to file answer to Plaintiff's Amended Complaint filed by Kyle B. Russell on behalf of Sams West, Inc.. Suggestions in opposition/response due by 3/21/2022 unless otherwise directed by the court. (Russell, Kyle)
February 25, 2022 Opinion or Order Filing 20 Joint PROPOSED SCHEDULING ORDER and Jury Trial by Kevin Cokeley, Sams West, Inc.. (Russell, Kyle)
February 25, 2022 Opinion or Order Filing 19 ORDER that #18 joint motion for extension of time to designate mediator is DENIED without prejudice. Extensions regarding the MAP program must be made pursuant to the MAP General Order (see Doc. [3-1]). Signed on 2/25/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
February 25, 2022 Opinion or Order Filing 18 Joint MOTION for extension of time to Designate a Mediator filed by Kyle B. Russell on behalf of Kevin Cokeley, Sams West, Inc.. Suggestions in opposition/response due by 3/11/2022 unless otherwise directed by the court. (Russell, Kyle)
February 23, 2022 Opinion or Order Filing 17 ORDER granting #16 Defendants' unopposed motion for extension of time to (1) answer or respond to Plaintiff's amended complaint (Doc. #12 ), and (2) respond to Plaintiff's motion to remand (Doc. #13 ). Defendants' answer or responsive filing to Plaintiff's amended complaint and response to Plaintiff's motion to remand are due on or before 3/7/2022 unless otherwise ordered by the court. Signed on 2/23/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
February 23, 2022 Opinion or Order Filing 16 MOTION for extension of time to file answer re #13 MOTION to remand , #12 Amended Complaint (Unopposed) filed by Kyle B. Russell on behalf of Kevin Cokeley, Sams West, Inc.. Suggestions in opposition/response due by 3/9/2022 unless otherwise directed by the court. (Related document(s) #13 , #12 ) (Russell, Kyle)
February 10, 2022 Opinion or Order Filing 15 ORDER finding as moot #7 Motion to Dismiss for Failure to State a Claim and #9 Motion to Dismiss for Failure to State a Claim as a result of the filing of #12 Plaintiff's Amended Complaint. Signed on 2/10/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
February 9, 2022 Opinion or Order Filing 14 SUGGESTIONS in support re #13 MOTION to remand filed by Phillip M. Murphy, II on behalf of Plaintiff Mohammad Khoshneviszadeh. (Attachments: #1 Exhibit Ex. A, MCHR Right to Sue)(Related document(s) #13 ) (Murphy, Phillip)
February 9, 2022 Opinion or Order Filing 13 MOTION to remand filed by Phillip M. Murphy, II on behalf of Mohammad Khoshneviszadeh. Suggestions in opposition/response due by 2/23/2022 unless otherwise directed by the court. (Murphy, Phillip)
February 9, 2022 Opinion or Order Filing 12 AMENDED COMPLAINT against All Defendants filed by Phillip M. Murphy, II on behalf of Mohammad Khoshneviszadeh.(Murphy, Phillip)
January 28, 2022 Opinion or Order Filing 11 DISCLOSURE OF CORPORATE INTERESTS filed by Kyle B. Russell on behalf of Defendant Sams West, Inc..(Russell, Kyle)
January 28, 2022 Opinion or Order Filing 10 SUGGESTIONS in support re #9 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Counts VI and VII of Plaintiff's Petition filed by Kyle B. Russell on behalf of Defendant Kevin Cokeley. (Related document(s) #9 ) (Russell, Kyle)
January 28, 2022 Opinion or Order Filing 9 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Counts VI and VII of Plaintiff's Petition filed by Kyle B. Russell on behalf of Kevin Cokeley. Suggestions in opposition/response due by 2/11/2022 unless otherwise directed by the court. (Russell, Kyle)
January 28, 2022 Opinion or Order Filing 8 SUGGESTIONS in support re #7 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiff's Petition (Partial) filed by Kyle B. Russell on behalf of Defendant Sams West, Inc.. (Related document(s) #7 ) (Russell, Kyle)
January 28, 2022 Opinion or Order Filing 7 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiff's Petition (Partial) filed by Kyle B. Russell on behalf of Sams West, Inc.. Suggestions in opposition/response due by 2/11/2022 unless otherwise directed by the court. (Russell, Kyle)
January 19, 2022 Opinion or Order Filing 6 ORDER granting #5 Defendants' unopposed motion for extension of time to answer or otherwise respond to Plaintiff's petition. Defendants' answer or responsive pleading due by 1/28/2022. Signed on 1/19/2022 by District Judge Roseann Ketchmark. This is a TEXT ONLY ENTRY. No document is attached. (Brown, Jonathan)
January 18, 2022 Opinion or Order Filing 5 Consent MOTION for extension of time to file answer or Otherwise Respond to Plaintiff's Petition filed by Kyle B. Russell on behalf of Kevin Cokeley, Sams West, Inc.. Suggestions in opposition/response due by 2/1/2022 unless otherwise directed by the court. (Russell, Kyle)
January 12, 2022 Opinion or Order Filing 4 RULE 16 NOTICE. Rule 26 conference due by 2/11/2022. Proposed scheduling order due by 2/25/2022. Signed on January 12, 2022 by District Judge Roseann Ketchmark. (Wheeler, LaTandra)
January 10, 2022 Opinion or Order Filing 3 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)(Woods, Gloria)
January 10, 2022 Opinion or Order Filing 2 NOTICE of filing to Plaintiff of Removal by Kevin Cokeley, Sams West, Inc. (Attachments: #1 Exhibit A - Notice of Removal)(Russell, Kyle)
January 10, 2022 Opinion or Order Filing 1 NOTICE OF REMOVAL from Circuit Court of Jackson County, case number 2116-CV25207, filed by Kyle B. Russell. Filing fee $402, receipt number AMOWDC-7749275. (Attachments: #1 Exhibit A - Civil Cover Sheet, #2 Exhibit B - Documents filed in the State Court Action, #3 Exhibit C - Plaintiffs EEOC Notice of Right to Sue, #4 Exhibit D - Sams West, Inc.s Annual Report filed with the Missouri Secretary of State)(Russell, Kyle)

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Plaintiff: Mohammad Khoshneviszadeh
Represented By: Phillip M. Murphy, II
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Defendant: Sams West, Inc.
Represented By: Kyle B. Russell
Represented By: Joshua J Cervantes
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Defendant: Kevin Cokeley
Represented By: Kyle B. Russell
Represented By: Joshua J Cervantes
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