Heard v. Costco Wholesale Corporation et al
| Kenneth Heard, Jr. |
| Costco Wholesale Corporation, Alice Jennifer Johnson and Natasha Brooks |
| 2:2019cv00673 |
| April 18, 2019 |
| US District Court for the District of Nevada |
| Las Vegas Office |
| Daniel J Albregts |
| Richard F Boulware |
| Carl W Hoffman |
| Civil Rights: Americans with Disabilities - Employment |
| 28 U.S.C. § 1331 |
| Plaintiff |
Docket Report
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| Filing 64 DECLARATION of Geoffrey C. Westbrook re #63 Non-Opposition by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Exhibit A - March 23, 2021, e-mail communication to Plaintiff, #2 Exhibit B - March 24, 2021, e-mail communication to Plaintiff, #3 Exhibit C - April 8, 2021, e-mail communication to Plaintiff) (Kay, Rory) |
| Filing 63 NON-OPPOSITION to #59 Motion to Dismiss by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 62 CERTIFICATE OF SERVICE for #61 Minute Order regarding Requirements of Klingele, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 61 MINUTE ORDER IN CHAMBERS of the Honorable Judge Richard F. Boulware, II on 3/24/2021. Regarding the Requirements of Klingele v. Eikenberry and Rand v. Rowland as to #59 Motion to Dismiss. Opposition due 14 days from the date of this Minute Order, and reply due seven 7 days after the filing of the opposition. (Copies have been distributed pursuant to the NEF - SLD) |
| Filing 60 DECLARATION of Geoffrey C. Westbrook re #59 Motion to Dismiss by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Exhibit A - February 24, 2020 e-mail communication to Plaintiff, #2 Exhibit B - Defendants' Request for Admissions, #3 Exhibit C - November 2020 e-mail communications with Plaintiff, #4 Exhibit D - Email communications) (Kay, Rory) |
| Filing 59 MOTION to Dismiss by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Responses due by 4/6/2021. (Kay, Rory) |
Filing 58
ORDER granting #55 Motion to Compel; ORDER granting #56 Motion to Extend Time. IT IS FURTHER ORDERED that Defendants shall meet and confer with Plaintiff regarding the attorneys' fees requested for prevailing on the motion to compel and file a motion for attorneys fees within 14 days of this Order if an agreement cannot be reached. A response and reply may be filed within the normal briefing schedule.Discovery due by 2/17/2021. Motions due by 3/19/2021. Proposed Joint Pretrial Order due by 4/15/2021. Signed by Magistrate Judge Daniel J. Albregts on 11/9/2020. (Copies have been distributed pursuant to the NEF - HAM)
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| Filing 57 NOTICE of Plaintiff's Non-Opposition to Motion to Compel and Request for Sanctions by Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson re #55 Motion to Compel,,. (Attachments: #1 Declaration of Geoffrey C. Westbrook in Support of Defendant's Notice of Plaintiff's Non-Opposition to Motion to Compel and Request for Sanctions, #2 Exhibit A - Communications with Mr. Heard, #3 Exhibit B - Executed and sworn declarations provided by Nationwide Legal, LLC) (Kay, Rory) |
| Filing 56 MOTION to Extend Time (Third Request) Scheduling Order Deadlines Due to Plaintiff's Failure to Participate in Discovery re #54 Order, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Declaration of Geoffrey C. Westbrook, #2 Exhibit A - E-mail to Plaintiff) (Kay, Rory) |
| Filing 55 MOTION to Compel (1) Plaintiff's Deposition; (2) A FRCP 35 Mental Examination of Plaintiff; and (3) Plaintiff's Execution of Medical Records Authorizations by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Responses due by 11/5/2020. (Attachments: #1 Declaration of Geoffrey C. Westbrook in Support of Defendant's Motion to Compel, #2 Exhibit A - Authorizations provided by Spring Mountain Treatment Center, Sunrise Hospital and Medical Center, and St. Rose Dominican, #3 Exhibit B - E-mail communications with Plaintiff) (Kay, Rory) |
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Filing 54
ORDER Granting #53 Motion to Extend Time re #47 Order (Second Request). Discovery due by 11/16/2020. Motions due by 12/16/2020. Proposed Joint Pretrial Order due by 1/15/2021. Signed by Magistrate Judge Daniel J. Albregts on 5/11/2020. (Copies have been distributed pursuant to the NEF - MR)
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| Filing 53 MOTION to Extend Time (Second Request) for Disclosure of Experts and Discovery Deadlines re #47 Scheduling Order, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Declaration of Geoffrey C. Westbrook in Support of Motion to Extend Expert Disclosure and Discovery Deadlines) (Westbrook, Geoffrey) |
| Filing 52 Interim STATUS REPORT Pursuant to Local Rule 26-3 by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Westbrook, Geoffrey) |
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Filing 51
ORDER. IT IS ORDERED that #28 , #31 Plaintiff's Motions to Quash Third-Party Subpoenas are granted in part and denied in part. IT IS FURTHER ORDERED that Defendants shall reissue the two subsequent employer subpoenas after narrowly tailoring them consistent with this Order. Signed by Magistrate Judge Daniel J. Albregts on 1/31/2020. (Copies have been distributed pursuant to the NEF - ADR)
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| Filing 50 NOTICE of Intention to Seek a New Attorney by Kenneth Heard, Jr re #49 Order on Motion to Withdraw. (DRS) |
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Filing 49
ORDER granting #48 Motion to Withdraw as Attorney - James P. Kemp and Victoria Lynn Neal withdrawn from the case. Plaintiff shall notify the Court as to whether he intends to proceed pro se or retain counsel by January 24, 2020. Signed by Magistrate Judge Daniel J. Albregts on 1/15/2020.(Copies have been distributed pursuant to the NEF - cc: Plaintiff - DRS)
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| Clerk's note - set deadline for status report for Plaintiff to notify the Court as to representation or pro se status. (Copies have been distributed pursuant to the NEF - DRS) |
| Filing 48 MOTION to Withdraw as Attorney by Kemp & Kemp for Plaintiff Kenneth Heard, Jr. (Neal, Victoria) |
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Filing 47
SCHEDULING ORDER Granting in Part and Denying in Part #46 Stipulation. Discovery due by 7/17/2020. Motions due by 8/31/2020. Proposed Joint Pretrial Order due by 9/30/2020. Signed by Magistrate Judge Daniel J. Albregts on 1/9/2020. (Copies have been distributed pursuant to the NEF - DRS)
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| Filing 46 Joint STIPULATION FOR EXTENSION OF TIME (First Request) and To Modify re #23 Scheduling Order, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson.. (Westbrook, Geoffrey) |
| Filing 45 REPLY to Response to #31 Motion to Quash, by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1) (Neal, Victoria) |
| Filing 44 REPLY to Response to #28 Motion to Quash by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4) (Neal, Victoria) |
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Filing 43
ORDER. IT IS ORDERED that #40 Plaintiff's Motion for Extension of Time to Reply to ECF No. 28 is denied. IT IS FURTHER ORDERED that #41 Plaintiff's Motion for Extension of Time to Reply to ECF No. 31 is denied. IT IS FURTHER ORDERED that Plaintiff's reply briefs shall be due by 10/30/19. Signed by Magistrate Judge Daniel J. Albregts on 10/29/2019. (Copies have been distributed pursuant to the NEF - ADR)
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| Filing 42 RESPONSE to #40 FIRST MOTION to Extend Time re: #28 Motion to Quash, #41 FIRST MOTION to Extend Time re #31 Motion to Quash by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Replies due by 10/30/2019. (Attachments: #1 Declaration of Christopher J. Truxler, #2 Exhibit List, #3 Exhibit A) (Westbrook, Geoffrey) |
| Filing 41 FIRST MOTION to Extend Time re #31 Motion to Quash, filed by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2) (Neal, Victoria) |
| Filing 40 FIRST MOTION to Extend Time re: #28 Motion to Quash; filed by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2) (Neal, Victoria) |
| Filing 39 RESPONSE to #31 Motion to Quash, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Replies due by 10/24/2019. (Attachments: #1 Declaration Of Christopher J. Truxler, #2 Exhibit List, #3 Exhibit A, #4 Exhibit B, #5 Exhibit C) (Westbrook, Geoffrey) |
| Filing 38 RESPONSE to #28 Motion to Quash by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Replies due by 10/22/2019. (Attachments: #1 Declaration of Christopher J. Truxler, #2 Exhibit List, #3 Exhibit A, #4 Exhibit B, #5 Exhibit C, #6 Exhibit D, #7 Exhibit E, #8 Exhibit F, #9 Exhibit G, #10 Exhibit H, #11 Exhibit I, #12 Exhibit J, #13 Exhibit K) (Westbrook, Geoffrey) |
| Filing 37 CLERK'S NOTICE - Regarding violation of the Local Rules and Attorney Action required as to document #36 ERROR: Document not filed pursuant to LR IC 2-2(c), wrong event was selected by attorney. CORRECTION: Attorney Christopher J. Truxler is advised to refile document #36 using the correct Response to Motion event in accordance with LR IC 2-2(c). Additionally, attorney is advised to properly link newly filed Response to Motion to the appropriate Motion(s) already filed in the case, pursuant to LR IC 2-2(d). Document #36 is terminated as filed in error, pursuant to LR IC 7-1 (no image attached) (RFJ) |
| Filing 36 ERROR: Document not filed pursuant to FRCP 7, LR IC 2-2(b) and LR IC 2-2(c) by Christopher J. Truxler. CORRECTION: Attorney advised to refile document using the correct events in accordance with the local rules. MEMORANDUM to #31 Motion to Quash, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Declaration of Christopher J. Truxler) (Truxler, Christopher) Document #36 terminated as filed in error, pursuant to LR IC 7-1 on 10/15/2019 (RFJ). |
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Filing 35
ORDER Granting #32 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Geoffrey C Westbrook for Defendants and approving Designation of Local Counsel Rory T Kay. Signed by Judge Richard F. Boulware, II on 10/9/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - ADR)
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Filing 34
ORDER Granting #30 Stipulated Protective Order subject to the modifications as listed. Signed by Magistrate Judge Daniel J. Albregts on 10/8/2019.(Copies have been distributed pursuant to the NEF - ADR)
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| Filing 33 MINUTE ORDER IN CHAMBERS of the Honorable Magistrate Judge Daniel J. Albregts on 10/8/2019. Re: #31 Motion to Quash. Having reviewed Plaintiffs Motion to Quash Third Party Subpoena (ECF No. 31), IT IS HEREBY ORDERED that to the extent Defendant has not yet received a response to the subpoena that is the subject of the Motion, the deadline to produce the subpoenaed records is STAYED pending the Courts order on the Motion (ECF No. 31). If Defendant does receive a response, Defendant shall keep the response sealed and not review it pending the Courts order on the Motion (ECF No. 31). (no image attached) (Copies have been distributed pursuant to the NEF - KB) |
| Filing 32 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Geoffrey C. Westbrook and DESIGNATION of Local Counsel Rory T. Kay (Filing fee $ 250 receipt number 0978-5727377) by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 31 MOTION to Quash Third Party Subpoena by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8) (Neal, Victoria) |
| Filing 30 Joint STIPULATION re Discovery Stipulated Protective Order Concerning Confidential Information by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Truxler, Christopher) |
| Filing 29 MINUTE ORDER IN CHAMBERS of the Honorable Magistrate Judge Daniel J. Albregts on 10/2/2019. Re: #28 Emergency Motion to Quash. Having reviewed Plaintiffs Emergency Motion to Quash Third Party Subpoena (ECF No. 28), the Court finds that expedited consideration is unnecessary under LR IA 6-1(d). IT IS THEREFORE ORDERED that responses and replies are due in the ordinary course. IT IS FURTHER ORDERED that to the extent Defendant has not yet received a response to the subpoena attached as Exhibit 2 to the Motion, the deadline to produce the subpoenaed records is STAYED pending the Courts order on the Motion (ECF No. 28). If Defendant does receive a response, Defendant shall keep the response sealed and not review it pending the Courts order on the Motion (ECF No. 28). (no image attached) (Copies have been distributed pursuant to the NEF - KB) |
| Filing 28 MOTION to Quash Subpoena; filed by Plaintiff Kenneth Heard, Jr. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7) (Neal, Victoria) |
| Filing 27 CLERK'S NOTICE that due to the retirement of U.S. Magistrate Judge Carl W. Hoffman, this case is reassigned to U.S. Magistrate Judge Daniel J. Albregts for all further proceedings. All further documents must bear the correct case number 2:19-cv-00673-RFB-DJA. (no image attached) (ADR) |
| Filing 26 MINUTES OF PROCEEDINGS - Early Neutral Evaluation session held on 7/9/2019 before Magistrate Judge Cam Ferenbach. Pla Counsel: James P. Kemp, Esq.; Victoria Lynn Neal, Esq., Plaintiff Kenneth Heard; Def Counsel: Mark P. Grajski, Esq., Rory T. Kay, Esq., Jason Sifers, Esq.; Rep. Michele Hughes, Esq.; Defs. Natasha Brooks, Alice Jennifer Johnson; Time of Hearing: 10:00 AM - 11:40 AM; The court met and conferred with the parties and counsel; however, a settlement agreement was not reached. Accordingly, IT IS HEREBY ORDERED that the case returns to the normal litigation track. (no image attached) (Copies have been distributed pursuant to the NEF - MT) |
| Filing 25 WITHDRAWAL of #22 Motion to Compel by Plaintiff Kenneth Heard, Jr. (Neal, Victoria) |
| Filing 24 NOTICE PURSUANT TO LOCAL RULE IB 2-2: In accordance with 28 USC 636(c) and FRCP 73, the parties in this action are provided with a link to the "AO 85 Notice of Availability, Consent, and Order of Reference - Exercise of Jurisdiction by a U.S. Magistrate Judge" form on the Court's website - #www.nvd.uscourts.gov. AO 85 Consent forms should NOT be electronically filed. Upon consent of all parties, counsel are advised to manually file the form with the Clerk's Office. (A copy of form AO 85 has been mailed to parties not receiving electronic service.) (no image attached) (ADR) |
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Filing 23
SCHEDULING ORDER Re: #21 Proposed Discovery Plan/Scheduling Order. Discovery due by 3/13/2020. Motions due by 4/13/2020. Proposed Joint Pretrial Order due by 5/13/2020. Signed by Magistrate Judge Carl W. Hoffman on 6/25/2019. (Copies have been distributed pursuant to the NEF - ADR)
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| Filing 22 MOTION to Compel Discovery; filed by Plaintiff Kenneth Heard, Jr. Responses due by 7/8/2019. (Attachments: #1 Exhibit List, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3) (Neal, Victoria) |
| Filing 21 PROPOSED Discovery Plan/Scheduling Order by Plaintiff Kenneth Heard, Jr (Neal, Victoria) |
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Filing 20
ORDER Granting #18 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Mark P Grajksi for Costco Wholesale Corporation and approving Designation of Local Counsel Rory T Kay. Signed by Judge Richard F. Boulware, II on 5/28/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - MR)
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Filing 19
ORDER Granting #17 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Christopher Truxler and approving Attorney Rory T. Kay as Designation of Local Counsel for Costco Wholesale Corporation. Signed by Judge Richard F. Boulware, II on 5/28/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - SLD)
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| Filing 18 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Mark P. Grajski and DESIGNATION of Local Counsel Rory T. Kay (Filing fee $ 250 receipt number 0978-5560302) by Defendant Costco Wholesale Corporation. (Kay, Rory) |
| Filing 17 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Christopher J. Truxler and DESIGNATION of Local Counsel Rory T. Kay (Filing fee $ 250 receipt number 0978-5560283) by Defendant Costco Wholesale Corporation. (Kay, Rory) |
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Filing 16
ORDER Granting #13 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Mark P Grajksi and approving Designation of Local Counsel Rory T. Kay. Signed by Judge Richard F. Boulware, II on 5/22/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - ADR)
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Filing 15
ORDER Granting #12 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Christopher Truxler and approving Designation of Local Counsel Rory T. Kay. Signed by Judge Richard F. Boulware, II on 5/22/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website #www.nvd.uscourts.gov(Copies have been distributed pursuant to the NEF - ADR)
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| Filing 14 Joint STATUS REPORT by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 13 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Mark P. Grajski and DESIGNATION of Local Counsel Rory T. Kay (Filing fee $ 250 receipt number 0978-5555471) by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 12 MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Christopher J. Truxler and DESIGNATION of Local Counsel Rory T. Kay (Filing fee $ 250 receipt number 0978-5555449) by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 11 STATEMENT REGARDING REMOVAL by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 10 ANSWER to Complaint filed by Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. Discovery Plan/Scheduling Order due by 6/9/2019.(Kay, Rory) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court. |
| Filing 9 CERTIFICATE OF SERVICE for #5 Minute Order Removal Case, by Defendants Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
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Filing 8
ORDER setting Early Neutral Evaluation session. Early Neutral Evaluation set for 7/9/2019 at 10:00 AM in LV Chambers before Magistrate Judge Cam Ferenbach. The written evaluation statements must be delivered directly to my chambers, U.S. Magistrate Judge Cam Ferenbach, in a sealed envelope-MARKED CONFIDENTIAL AND DO NOT FILE, not later than 4:00 p.m., 7/2/19. Signed by Magistrate Judge Cam Ferenbach on 4/22/2019. (Copies have been distributed pursuant to the NEF - JQC)
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| Filing 7 CERTIFICATE of Interested Parties by Kenneth Heard, Jr. There are no known interested parties other than those participating in the case (Neal, Victoria) |
| Filing 6 NOTICE: Pursuant to Local Rule 16-6 this case has been assigned to the Early Neutral Evaluation Program. Magistrate Judge Cam Ferenbach will be the evaluating judge in this case. (no image attached) (ADR) |
| Filing 5 MINUTE ORDER IN CHAMBERS of the Honorable Judge Richard F. Boulware, II on 4/19/2019. Statement regarding removed action is due by 5/4/2019. Joint Status Report regarding removed action is due by 5/19/2019. (Copies have been distributed pursuant to the NEF - ADR) |
| Filing 4 NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Mark P Grajksi and Christopher Truxler to comply with completion and filing of the Verified Petition and Designation of Local Counsel. For your convenience, click on the following link to obtain the form from the Court's website - #www.nvd.uscourts.gov. Upon approval of the Verified Petition, counsel is required to register for the Court's Case Management and Electronic Case Filing (CM/ECF) system and the electronic service of documents. Please visit the Court's website www.nvd.uscourts.gov to register Attorney. Verified Petition due by 6/3/2019. (no image attached) (ADR) |
| Case randomly assigned to Judge Richard F. Boulware, II and Magistrate Judge Carl W. Hoffman. (ADR) |
| Filing 3 NOTICE - Corporate Disclosure Statement [Fed. R. Civ. P. 7.1] by Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Kay, Rory) |
| Filing 2 CERTIFICATE of Interested Parties by Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. There are no known interested parties other than those participating in the case (Kay, Rory) |
| Filing 1 PETITION FOR REMOVAL from 8th Judicial District Court, Clark County, Case Number A-19-789030-C, (Filing fee $ 400 receipt number 0978-5512052) by Natasha Brooks, Costco Wholesale Corporation, Alice Jennifer Johnson. (Attachments: #1 Exhibit 1 - Complaint, #2 Exhibit 2 - Declaration of Christopher P. Truxler, #3 Civil Cover Sheet)(Kay, Rory) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court. |
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