ExchangeRight Real Estate, LLC v. JDMO Bundle, LLC et al
| ExchangeRight Real Estate, LLC |
| JDMO Bundle, LLC, JDKS Bundle, LLC and JDMD Bundle, LLC |
| 4:2022cv00735 |
| November 8, 2022 |
| US District Court for the Western District of Missouri |
| Stephen R Bough |
| Contract: Other |
| 28 U.S.C. § 1441 Petition For Removal--Other Contract |
| Plaintiff |
Docket Report
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This docket was last retrieved on January 6, 2023. A more recent docket listing may be available from PACER.
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| Filing 51 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Michael J Abrams on behalf of Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC.(Abrams, Michael) |
| Filing 50 DISCLOSURE OF CORPORATE INTERESTS filed by Michael J Abrams on behalf of Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC.(Abrams, Michael) |
| Filing 49 DISCLOSURE OF CORPORATE INTERESTS filed by Michael Caplan on behalf of Plaintiff ExchangeRight Real Estate, LLC.(Caplan, Michael) |
| NOTICE of filing: Mediation and Assessment Program Reminder: Your Designation of Mediator is due soon (filed as an ADR event in CM/ECF). See Notice of Inclusion and MAP General Order for specifics. (ADI, MAP) |
Filing 48
RULE 16 NOTICE. Proposed scheduling order due by 1/13/2023. Scheduling Conference set for 1/26/2023 at 9:00 AM in Courtroom 7B, Kansas City (SRB) before District Judge Stephen R. Bough. Signed on 12/6/2022 by District Judge Stephen R. Bough. (Richard, Tracey) Modified on 12/6/2022 to correct the year, NEF has been regenerated (Richard, Tracey).
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Filing 47
Before the Court is Defendants JDMO Bundle, LLC, JDKS Bundle, LLC and JDMD Bundle, LLC's ("Defendants") Motion for Withdrawal of Andrew Pauly and Richard Stoll as Local Counsel. (Doc. #46.) Upon review, the motion is GRANTED. It is hereby ORDERED that Andrew Pauly and Richard Stoll are withdrawn as counsel for Defendants. Defendants will continue to be represented by their other counsel of record. Signed on 11/17/2022 by District Judge Stephen R. Bough. This is a TEXT ONLY ENTRY. No document is attached. (Richard, Tracey)
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| Filing 46 MOTION to withdraw as attorney of Andrew Pauly and Richard Stoll as Local Counsel filed by Michael J Abrams on behalf of All Defendants. Suggestions in opposition/response due by 12/1/2022 unless otherwise directed by the court. (Abrams, Michael) |
| Filing 45 Before the Court is Plaintiff ExchangeRight Real Estate, LLC's ("Plaintiff") Motion for Withdrawal of Emil Petrossian as Local Counsel. (Doc. #44.) Upon review, the withdrawal is GRANTED. Emil Petrossian is hereby WITHDRAWN as counsel for Plaintiff. Plaintiff will continue to be represented by its other counsel of record. Signed on 11/15/2022 by District Judge Stephen R. Bough. This is a TEXT ONLY ENTRY. No document is attached. (Richard, Tracey) |
| Filing 44 MOTION to withdraw as attorney for Emil Petrossian as Local Counsel filed by Arthur A Chaykin on behalf of ExchangeRight Real Estate, LLC. Suggestions in opposition/response due by 11/29/2022 unless otherwise directed by the court. (Chaykin, Arthur) |
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Filing 43
ORDER granting #40 , #41 , and #42 motion to appear pro hac vice entered by Clerk of Court. Attorney Michael A. Caplan,T. Waddell, and Ashley C. Brown for ExchangeRight Real Estate, LLC 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. (Warren, Melissa)
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| Filing 42 Motion to allow Ashley C. Brown to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8190476) filed by Arthur A Chaykin on behalf of ExchangeRight Real Estate, LLC. (Chaykin, Arthur) |
| Filing 41 Motion to allow T. Brandon Waddell to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8190469) filed by Arthur A Chaykin on behalf of ExchangeRight Real Estate, LLC. (Chaykin, Arthur) |
| Filing 40 Motion to allow Michael A. Caplan to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8190460) filed by Arthur A Chaykin on behalf of ExchangeRight Real Estate, LLC. (Chaykin, Arthur) |
| Filing 39 NOTICE of appearance by Jon Dedon on behalf of ExchangeRight Real Estate, LLC (Attorney Jon Dedon added to party ExchangeRight Real Estate, LLC(pty:pla))(Dedon, Jon) |
| Filing 38 NOTICE of appearance by Arthur A Chaykin on behalf of ExchangeRight Real Estate, LLC (Attorney Arthur A Chaykin added to party ExchangeRight Real Estate, LLC(pty:pla))(Chaykin, Arthur) |
| Filing 37 NOTICE of appearance by Michael J Abrams on behalf of JDMD Bundle, LLC (Attorney Michael J Abrams added to party JDMD Bundle, LLC(pty:dft))(Abrams, Michael) |
| Filing 36 NOTICE of appearance by Michael J Abrams on behalf of JDKS Bundle, LLC, JDMO Bundle, LLC (Attorney Michael J Abrams added to party JDKS Bundle, LLC(pty:dft), Attorney Michael J Abrams added to party JDMO Bundle, LLC(pty:dft))(Abrams, Michael) |
| Filing 35 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)(Matthes Mitra, Renea) |
| Filing 34 CASE TRANSFERRED IN from District of California Central; Case Number 2:22-cv-07768. |
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Filing 33
ORDER TRANSFERRING CASE TO THE WESTERN DISTRICT OF MISSOURI, WESTERN DIVISION, PURSUANT TO STIPULATION by Judge Percy Anderson transferring case to USDC, Western District of Missouri. Having reviewed and considered the Parties' Stipulation to Transfer Case to the Western District of Missouri, Western Division, and finding that transferring this action to the United States District Court for the Western District of Missouri would serve the interests of justice under 28 U.S.C. 1404(a), the Court TRANSFERS this action to the Western District of Missouri, Western Division. (MD JS-6. Case Terminated.) (aco) [Transferred from cacd on 11/8/2022.]
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| Filing 32 STIPULATION to Transfer Case to Western District of Missouri, Western Division filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. (Attachments: #1 Exhibit Proposed Order)(Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 31 Declaration of Warren Thomas Submitted Pursuant to Court's November 2, 2022 Order filed by Plaintiff ExchangeRight Real Estate, LLC re: Status Conference - optional html form, #28 (Caplan, Michael) [Transferred from cacd on 11/8/2022.] |
| Filing 30 Defendant Limited Liability Companies' Membership Identification for Diversity Jurisdiction filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 29 TRANSCRIPT ORDER as to Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC for Court Reporter. Court will contact Andrew S. Pauly at apauly@shoreline-law.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 28 MINUTES OF STATUS CONFERENCE held before Judge Percy Anderson. Court and counsel confer concerning the Notice of Removal filed by defendants JDMO Bundle, LLC, JDKS Bundle, LLC, and JDMD Bundle, LLC. (Docket No. 1.) The Court orders the parties to file declarations by the manager or member of their respective LLCs setting forth all of the members of their respective LLCs and their members' citizenship no later than November 8, 2022. Court Reporter: Suzanne McKennon. (aco) [Transferred from cacd on 11/8/2022.] |
| Filing 27 Notice Court's Issuance of Standing Order filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. NOTICE OF COURT'S ISSUANCE OF STANDING ORDER (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 26 SCHEDULING NOTICE by Judge Percy Anderson Status Conference by zoom is set for 11/2/2022 at 01:30 PM before Judge Percy Anderson. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kss) TEXT ONLY ENTRY [Transferred from cacd on 11/8/2022.] |
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Filing 25
ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE by Judge Percy Anderson. APPLICATION of Timothy B. Waddell to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC, designating Emil Petrossian as local counsel.; granting #16 Non-Resident Attorney Timothy B. Waddell. (aco) [Transferred from cacd on 11/8/2022.]
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Filing 24
ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE by Judge Percy Anderson. APPLICATION of Attorney Michael A. Caplan to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC, designating Emil Petrossian as local counsel.; granting #15 Non-Resident Attorney Michael A. Caplan. (aco) [Transferred from cacd on 11/8/2022.]
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Filing 23
ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE by Judge Percy Anderson. Corrected APPLICATION of Attorney Ashley C. Brown to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC, designating Emil Petrossian as local counsel.; granting #20 Non-Resident Attorney Ashley C. Brown. (aco) [Transferred from cacd on 11/8/2022.]
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| Filing 22 SCHEDULING MEETING OF COUNSEL [FRCP 16, 26(f)] by Judge Percy Anderson. SCHEDULING CONFERENCE set for December 12, 2022, at 10:30 a.m. (See document for further details). (aco) [Transferred from cacd on 11/8/2022.] |
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Filing 21
STANDING ORDER by Judge Percy Anderson. READ THIS ORDER CAREFULLY. IT CONTROLS THE CASE AND DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. This action has been assigned to the calendar of Judge Percy Anderson. (SEE DOCUMENT FOR FURTHER DETAILS). (aco) [Transferred from cacd on 11/8/2022.]
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| Filing 20 Corrected APPLICATION of Non-Resident Attorney Ashley C. Brown to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC (Pro Hac Vice Fee - $500 Previously Paid on 10/26/2022, Receipt No. 34223505) filed by plaintiff ExchangeRight Real Estate, LLC. (Attachments: #1 Proposed Order) (Petrossian, Emil) [Transferred from cacd on 11/8/2022.] |
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Filing 19
ORDER TO REASSIGN CASE Pursuant General Order 21-01 (identical case) by Judge Josephine L. Staton, Case Management and Assignment Committee Chair. Case transferred to the calendar of Judge Percy Anderson for all further proceedings. All discovery matters are transferred to Magistrate Judge Margo A. Rocconi. Case number now reads as 2:22-cv-07768 PA(MARx). (rn) [Transferred from cacd on 11/8/2022.]
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| Filing 18 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Ashley C. Brown to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34223505) #17 . The following error(s) was/were found: Local Rule 83-2.1.3.3(a) Application not complete: state and/or federal courts to which the applicant has been admitted are not listed. Failed to list GA State Bar admission. (lt)[Transferred from cacd on 11/8/2022.] |
| Filing 17 APPLICATION of Non-Resident Attorney Ashley C. Brown to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34223505) filed by plaintiff ExchangeRight Real Estate, LLC. (Attachments: #1 Proposed Order) (Petrossian, Emil) [Transferred from cacd on 11/8/2022.] |
| Filing 16 APPLICATION of Non-Resident Attorney Timothy B. Waddell to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34223503) filed by plaintiff ExchangeRight Real Estate, LLC. (Attachments: #1 Proposed Order) (Petrossian, Emil) [Transferred from cacd on 11/8/2022.] |
| Filing 15 APPLICATION of Non-Resident Attorney Michael A. Caplan to Appear Pro Hac Vice on behalf of Plaintiff ExchangeRight Real Estate, LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34223500) filed by plaintiff ExchangeRight Real Estate, LLC. (Attachments: #1 Proposed Order) (Petrossian, Emil) [Transferred from cacd on 11/8/2022.] |
| Filing 14 Notice of Submission of State Court Docket filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. NOTICE OF SUBMISSION OF STATE COURT DOCKET FOR LOS ANGELES COUNTY SUPERIOR COURT CASE NO. 22STCV32373 (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 13 Notice of Assignment to United States Judge, etc. filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. NOTICE OF ASSIGNMENT TO UNITED STATES JUDGE, NOTICE TO COUNSEL RE CONSENT TO PROCEED BEFORE A UNITED STATES MAGISTRATE JUDGE, AND NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 12 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Ashley C. Brown. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 11 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney T. Brandon Waddell. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 10 NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Michael A. Caplan. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 9 Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 8 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 7 NOTICE OF ASSIGNMENT to District Judge Andre Birotte Jr and Magistrate Judge Alka Sagar. (sh) [Transferred from cacd on 11/8/2022.] |
| CONFORMED E-FILED COPY OF COMPLAINT against Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC.Jury Demanded., filed by Plaintiff ExchangeRight Real Estate, LLC.[FILED IN STATE COURT 10/03/2022 SUBMITTED AS ATTACHMENT NO. 2 EXHIBIT B TO THE NOTICE OF REMOVAL #1 ] (sh) [Transferred from cacd on 11/8/2022.] |
| NON-CONFORMED COPY OF PROOF OF SERVICE Executed by Plaintiff ExchangeRight Real Estate, LLC, upon Defendant JDMO Bundle, LLC served on 10/7/2022. in compliance with California Code of Civil Procedure by personal service.Original Summons NOT returned. [STATE COURT FILE DATE NOT INDICATED SUBMITTED AS ATTACHMENT NO. 2 EXHIBIT B TO THE NOTICE OF REMOVAL #1 ] (sh) [Transferred from cacd on 11/8/2022.] |
| NON-CONFORMED COPY OF PROOF OF SERVICE Executed by Plaintiff ExchangeRight Real Estate, LLC, upon Defendant JDKS Bundle, LLC served on 10/7/2022. in compliance with California Code of Civil Procedure by personal service.Original Summons NOT returned. [STATE COURT FILE DATE NOT INDICATED SUBMITTED AS ATTACHMENT NO. 2 EXHIBIT B TO THE NOTICE OF REMOVAL #1 ] (sh) [Transferred from cacd on 11/8/2022.] |
| NON-CONFORMED COPY OF PROOF OF SERVICE Executed by Plaintiff ExchangeRight Real Estate, LLC, upon Defendant JDMD Bundle, LLC served on 10/7/2022. in compliance with California Code of Civil Procedure by personal service.Original Summons NOT returned. [STATE COURT FILE DATE NOT INDICATED SUBMITTED AS ATTACHMENT NO. 2 EXHIBIT B TO THE NOTICE OF REMOVAL #1 ] (sh) [Transferred from cacd on 11/8/2022.] |
| Filing 6 CERTIFICATE OF SERVICE filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC, re Notice of Removal (Attorney Civil Case Opening),, #1 CERTIFICATE OF SERVICE OF NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA served on 10/25/2022. (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 5 CERTIFICATE OF SERVICE filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC, re Civil Cover Sheet (CV-71) #2 , Notice of Removal (Attorney Civil Case Opening),, #1 , Certificate/Notice of Interested Parties #3 , Notice of Related Case(s) #4 served on 10/25/2022. (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 4 NOTICE of Related Case(s) filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. Related Case(s): 2:22-cv-06957 (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 3 NOTICE of Interested Parties filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC, (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 2 CIVIL COVER SHEET filed by Defendants JDKS Bundle, LLC, JDMD Bundle, LLC, JDMO Bundle, LLC. (Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
| Filing 1 NOTICE OF REMOVAL from Los Angeles County Superior Court, case number 22STCV32373 Receipt No: ACACDC-34211116 - Fee: $402, filed by Defendants JDKS Bundle, LLC, JDMO Bundle, LLC, JDMD Bundle, LLC. (Attachments: #1 Exhibit A - Summons, #2 Exhibit B - State Court Complaint, #3 Exhibit C - State Court Answer) (Attorney Andrew S Pauly added to party JDKS Bundle, LLC(pty:dft), Attorney Andrew S Pauly added to party JDMD Bundle, LLC(pty:dft), Attorney Andrew S Pauly added to party JDMO Bundle, LLC(pty:dft))(Pauly, Andrew) [Transferred from cacd on 11/8/2022.] |
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