Keystone Hospitality, LLC v. Landers et al
| Keystone Hospitality, LLC |
| Jake Landers, Trimark USA, LLC, Gregg H Adams, Strategic Equipment, LLC, Steve Parker, Freddy Luster and Focus Brands, LLC |
| 4:2024cv00084 |
| February 2, 2024 |
| US District Court for the Western District of Missouri |
| Greg Kays |
| Contract: Other |
| 28 U.S.C. § 1446 Petition for Removal |
| Defendant |
Docket Report
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This docket was last retrieved on April 1, 2024. A more recent docket listing may be available from PACER.
| Document Text |
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| Filing 41 DESIGNATION of Neutral by Focus Brands, LLC, Freddy Luster, Steve Parker. (McClain, Daniel) |
| Filing 40 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by Daniel L. McClain on behalf of Defendants Focus Brands, LLC, Freddy Luster, Steve Parker.(McClain, Daniel) |
| Filing 39 CERTIFICATE OF SERVICE OF INITIAL RULE 26 DISCLOSURES filed by James F. Freeman, III on behalf of Plaintiff Keystone Hospitality, LLC.(Freeman, James) |
| Filing 38 SUGGESTIONS in opposition re #36 MOTION for extension of time / Rule 26 Motion to Extend Time Within Which to File the Parties Rule 26 Disclosures and Proposed Scheduling Order and Extend the Time Within Which to Reply to Trimark Defendants Motion to Dismiss [Doc 32] and Defendant, #34 MOTION to dismiss case for Lack of Personal Jurisdiction and for Failure to State a Claim, #32 MOTION to dismiss case filed by Dane C. Martin on behalf of Defendants Gregg H Adams, Focus Brands, LLC, Jake Landers, Freddy Luster, Steve Parker, Strategic Equipment, LLC, Trimark USA, LLC. Reply suggestions due by 4/5/2024 unless otherwise directed by the court. (Related document(s) #36 , #34 , #32 ) (Martin, Dane) |
| Filing 37 MOTION to stay Partial Stay Pending Resolution of Motions to Dismiss filed by Dane C. Martin on behalf of All Defendants. Suggestions in opposition/response due by 4/5/2024 unless otherwise directed by the court. (Attorney Dane C. Martin added to party Focus Brands, LLC(pty:dft), Attorney Dane C. Martin added to party Freddy Luster(pty:dft), Attorney Dane C. Martin added to party Steve Parker(pty:dft))(Martin, Dane) |
| Filing 36 MOTION for extension of time / Rule 26 Motion to Extend Time Within Which to File the Parties Rule 26 Disclosures and Proposed Scheduling Order and Extend the Time Within Which to Reply to Trimark Defendants Motion to Dismiss [Doc 32] and Defendants Steve Parker, Freddy Luster, and Focus Brands, LLCs Motion to Dismiss [Doc 34] filed by James F. Freeman, III on behalf of Keystone Hospitality, LLC. Suggestions in opposition/response due by 4/1/2024 unless otherwise directed by the court. (Freeman, James) |
| Filing 35 SUGGESTIONS in support re #34 MOTION to dismiss case for Lack of Personal Jurisdiction and for Failure to State a Claim filed by Daniel L. McClain on behalf of Defendants Focus Brands, LLC, Freddy Luster, Steve Parker. (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)(Related document(s) #34 ) (McClain, Daniel) |
| Filing 34 MOTION to dismiss case for Lack of Personal Jurisdiction and for Failure to State a Claim filed by Daniel L. McClain on behalf of Focus Brands, LLC, Freddy Luster, Steve Parker. Suggestions in opposition/response due by 3/18/2024 unless otherwise directed by the court. (McClain, Daniel) |
| Filing 33 SUGGESTIONS in support re #32 MOTION to dismiss case filed by Dane C. Martin on behalf of Defendants Gregg H Adams, Jake Landers, Strategic Equipment, LLC, Trimark USA, LLC. (Related document(s) #32 ) (Martin, Dane) |
| Filing 32 MOTION to dismiss case filed by Dane C. Martin on behalf of Gregg H Adams, Jake Landers, Strategic Equipment, LLC, Trimark USA, LLC. Suggestions in opposition/response due by 3/18/2024 unless otherwise directed by the court. (Martin, Dane) |
Filing 31
ORDER granting #30 motion for leave to exceed page limitations. Signed on February 29, 2024, by District Judge Greg Kays. This is a TEXT ONLY ENTRY. No document is attached. (Law clerk)
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| Filing 30 MOTION for leave to file Exceed Page Limitation filed by Dane C. Martin on behalf of Gregg H Adams, Jake Landers, Strategic Equipment, LLC, Trimark USA, LLC. Suggestions in opposition/response due by 3/13/2024 unless otherwise directed by the court. (Martin, Dane) |
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Filing 29
ORDER granting in part and denying in part #28 motion for leave to file excess pages. The argument and authorities portion of Defendants' suggestions in support of their omnibus motion to dismiss shall not exceed 24 pages. Signed on February 20, 2024, by District Judge Greg Kays. This is a TEXT ONLY ENTRY. No document is attached. (Law clerk)
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| Filing 28 MOTION for leave to file excess pages for Defendants' Suggestions in Support of Their Motion to Dismiss Plaintiff's Petition for Lack of Personal Jurisdiction and Failure to State a Claim for Relief filed by Daniel L. McClain on behalf of Focus Brands, LLC, Freddy Luster, Steve Parker. Suggestions in opposition/response due by 3/4/2024 unless otherwise directed by the court. (McClain, Daniel) |
| Filing 27 DEMAND for Trial by Jury by Focus Brands, LLC, Freddy Luster, Steve Parker. (McClain, Daniel) |
| Filing 26 DISCLOSURE OF CORPORATE INTERESTS filed by James F. Freeman, III on behalf of Plaintiff Keystone Hospitality, LLC.(Freeman, James) |
| Filing 25 DEMAND for Trial by Jury by Keystone Hospitality, LLC. (Freeman, James) |
| Filing 24 DEMAND for Trial by Jury by Gregg H Adams, Jake Landers, Strategic Equipment, LLC, Trimark USA, LLC. (Martin, Dane) |
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Filing 23
ORDER granting #22 motion to appear pro hac vice entered by Clerk of Court. Attorney Anne P. Caiola for Focus Brands, LLC, Freddy Luster and Steve Parker 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 22 Motion to allow Anne P. Caiola to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8868875) filed by Daniel L. McClain on behalf of Focus Brands, LLC, Freddy Luster, Steve Parker. (McClain, Daniel) |
| Filing 21 RETURN OF WAIVER OF SERVICE filed by Steve Parker, Freddy Luster. (McClain, Daniel) |
| Filing 20 NOTICE of filing - Consent to Removal by Freddy Luster re #1 Notice of Removal, (McClain, Daniel) |
| Filing 19 NOTICE of filing - Consent to Removal by Steve Parker re #1 Notice of Removal, (McClain, Daniel) |
| Filing 18 NOTICE of appearance by Katie Ann Deutsch on behalf of Freddy Luster, Steve Parker (Attorney Katie Ann Deutsch added to party Freddy Luster(pty:dft), Attorney Katie Ann Deutsch added to party Steve Parker(pty:dft))(Deutsch, Katie) |
| Filing 17 NOTICE of appearance by Daniel L. McClain on behalf of Freddy Luster, Steve Parker (Attorney Daniel L. McClain added to party Freddy Luster(pty:dft), Attorney Daniel L. McClain added to party Steve Parker(pty:dft))(McClain, Daniel) |
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Filing 16
RULE 16 NOTICE. Rule 26 conference due by 3/11/2024. Proposed scheduling order due by 3/25/2024. Signed on 2/8/24 by District Judge Greg Kays. (Strodtman, Tracy)
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Filing 15
INITIAL STANDING ORDER. All attorneys and unrepresented parties shall carefully study and comply with the ISO along with the Federal Rules of Civil Procedure and the Western District of Missouri's Local Rules (the Local Rules). Failure to comply with the ISO may result in the Court imposing sanctions, including but not limited to monetary payments, dismissal of claims or cases, entry of default judgment, or other appropriate sanctions. Signed on 2/8/24 by District Judge Greg Kays. (Strodtman, Tracy)
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Filing 14
ORDER granting #7 Motion for Extension of Time to Answer. Signed on February 8, 2024, by District Judge Greg Kays. This is a TEXT ONLY ENTRY. No document is attached. (Law clerk)
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| SUMMONS ISSUED as to Freddy Luster. (Woods, Gloria) |
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Filing 13
ORDER granting #8 motion to appear pro hac vice entered by Clerk of Court. Attorney Jennifer Butler Routh for Trimark USA, 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 12 NOTICE of appearance by Katie Ann Deutsch on behalf of Focus Brands, LLC (Attorney Katie Ann Deutsch added to party Focus Brands, LLC(pty:dft))(Deutsch, Katie) |
| Filing 11 DISCLOSURE OF CORPORATE INTERESTS filed by Daniel L. McClain on behalf of Defendant Focus Brands, LLC.(McClain, Daniel) |
| Filing 10 STIPULATION of Consent to Removal by Focus Brands, LLC. (McClain, Daniel) |
| Filing 9 NOTICE of appearance by Daniel L. McClain on behalf of Focus Brands, LLC (Attorney Daniel L. McClain added to party Focus Brands, LLC(pty:dft))(McClain, Daniel) |
| Filing 8 Motion to allow Jennifer Butler Routh to appear pro hac vice (Pro Hac fee $100 receipt number AMOWDC-8848268) filed by Patrick A. McInerney on behalf of Jake Landers, Trimark USA, LLC. (McInerney, Patrick) (Main Document 8 replaced on 2/6/2024) (Crocker, Susan). |
| Filing 7 Consent MOTION for extension of time to file answer filed by Dane C. Martin on behalf of Gregg H Adams, Focus Brands, LLC, Jake Landers, Strategic Equipment, LLC, Trimark USA, LLC. Suggestions in opposition/response due by 2/20/2024 unless otherwise directed by the court. (Martin, Dane) |
| Filing 6 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 outside neutral category I. (Attachments: #1 MAP General Order)(Melvin, Greg) |
| Filing 5 NOTICE of appearance by Patrick A. McInerney on behalf of All Defendants (Attorney Patrick A. McInerney added to party Gregg H Adams(pty:dft), Attorney Patrick A. McInerney added to party Focus Brands, LLC(pty:dft), Attorney Patrick A. McInerney added to party Jake Landers(pty:dft), Attorney Patrick A. McInerney added to party Freddy Luster(pty:dft), Attorney Patrick A. McInerney added to party Steve Parker(pty:dft), Attorney Patrick A. McInerney added to party Strategic Equipment, LLC(pty:dft), Attorney Patrick A. McInerney added to party Trimark USA, LLC(pty:dft))(McInerney, Patrick) |
| Filing 4 DISCLOSURE OF CORPORATE INTERESTS filed by Dane C. Martin on behalf of Defendant Trimark USA, LLC.(Martin, Dane) |
| Filing 3 DISCLOSURE OF CORPORATE INTERESTS filed by Dane C. Martin on behalf of Defendant Strategic Equipment, LLC.(Martin, Dane) |
| Filing 2 NOTICE of appearance by Dane C. Martin on behalf of All Defendants (Martin, Dane) |
| Filing 1 NOTICE OF REMOVAL from Circuit Court of Johnson County, case number 23JO-CC00230, filed by Dane C. Martin. Filing fee $405, receipt number AMOWDC-8844326. (Attachments: #1 Exhibit State Court Records, #2 Civil Cover Sheet)(Martin, Dane) |
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