Fredericks v. Lee et al
| Dale E Fredericks |
| Richard D Lee and Thomas L Kirkham, Jr. |
| 3:2023cv00039 |
| January 27, 2023 |
| US District Court for the District of Nevada |
| Carla Baldwin |
| Larry R Hicks |
| Stockholders Suits |
| 28 U.S.C. § 1441 Petition for Removal |
| None |
Docket Report
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This docket was last retrieved on September 11, 2023. A more recent docket listing may be available from PACER.
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Filing 38
CERTIFICATE OF SERVICE for #33 Declaration, #32 Response by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 37
DECLARATION of Richard D. Lee re #34 Motion to Seal by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 34
MOTION to Seal Document by Defendants Thomas L Kirkham, Jr., Richard D Lee. Responses due by 4/6/2023. (Hart, Leslie Bryan)
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Filing 33
DECLARATION of Richard D. Lee re #32 Response by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 32
RESPONSE to #25 Motion to Remand to State Court by Defendants Thomas L Kirkham, Jr., Richard D Lee. Replies due by 3/30/2023. (Hart, Leslie Bryan)
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Filing 31
REPLY to Response to #30 Motion for Leave to File Document/Excess Pages by Plaintiff Dale E Fredericks. (Gunderson, Mark)
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Filing 30
MOTION for Leave to File Document re #29 Reply by Defendants Thomas L Kirkham, Jr., Richard D Lee. Responses due by 3/31/2023. (Hart, Leslie Bryan) (answer)
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Filing 29
REPLY to Response to #14 Motion to Disqualify Counsel, by Plaintiff Dale E Fredericks. (Attachments: #1 Exhibit Declaration of D. Fredericks, #2 Exhibit Declaration of M. Gunderson)(Gunderson, Mark)
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Filing 28
ORDER granting ECF No. #27 Stipulation to Extend Motions Deadlines : Reply re ECF No. #14 Motion to Disqualify Counsel due by 3/13/2023. Response re ECF No. #25 Motion to Remand to State Court due by 3/23/2023. Signed by Judge Larry R. Hicks on 3/3/2023. (Copies have been distributed pursuant to the NEF - DRM)
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Filing 27
STIPULATION FOR EXTENSION OF TIME (First Request) Stipulation and Order to Extend Pending Motion Deadlines re #14 Motion to Disqualify Counsel, #25 Motion to Remand to State Court by Plaintiff Dale E Fredericks. (Reichenberg, Catherine) (extend) (nondispositive)
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Filing 26
Joint STATUS REPORT by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 25
MOTION to Remand to State Court re #1 Petition for Removal,, by Plaintiff Dale E Fredericks. Responses due by 3/13/2023. (Attachments: #1 Declaration)(Reichenberg, Catherine)
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Filing 24
REQUEST for Judicial Notice re #23 Declaration, #22 Reply by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan) Modified on 2/27/2023 link motion #10 (WJ).
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Filing 23
DECLARATION of Robert H. O'Leary re #22 Reply by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Attachments: #1 Exhibit B - 2022 Stock Incentive Plan)(Hart, Leslie Bryan) Modified on 2/27/2023 link to motion #10 (WJ).
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Filing 22
REPLY to Response to #10 Motion to Dismiss by Defendants Thomas L Kirkham, Jr., Richard D Lee. (Hart, Leslie Bryan)
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Filing 21
RESPONSE to #14 Motion to Disqualify Counsel, by Defendants Thomas L Kirkham, Jr., Richard D Lee. Replies due by 3/3/2023. (Attachments: #1 Declaration Michael Weil, #2 Declaration Richard Lee, #3 Declaration Neeraj Arora, #4 Declaration William D. Kissinger)(Hart, Leslie Bryan)
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Filing 20
MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Michael D. Weil and DESIGNATION of Local Counsel Leslie Bryan Hart (Filing fee $ 250 receipt number ANVDC-7211008) by Defendants Thomas L Kirkham, Jr., Richard D Lee. (Hart, Leslie Bryan)
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Filing 19
MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Nicholas Pfeiffer and DESIGNATION of Local Counsel Leslie Bryan Hart (Filing fee $ 250 receipt number ANVDC-7211003) by Defendants Thomas L Kirkham, Jr., Richard D Lee. (Hart, Leslie Bryan)
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Filing 18
MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Robert H. O'Leary and DESIGNATION of Local Counsel Leslie Bryan Hart (Filing fee $ 250 receipt number ANVDC-7210990) by Defendants Thomas L Kirkham, Jr., Richard D Lee. (Hart, Leslie Bryan)
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Filing 17
RESPONSE to #10 Motion to Dismiss by Plaintiff Dale E Fredericks. Replies due by 2/24/2023. (Gunderson, Mark)
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Filing 15
RESPONSE to #4 Minute Order Removal Case, by Defendants Thomas L Kirkham, Jr., Richard D Lee. (Hart, Leslie Bryan)
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Filing 14
MOTION to Disqualify Counsel Plaintiff's Motion to Disqualify Morgan, Lewis & Bockius LLP by Plaintiff Dale E Fredericks. Responses due by 2/24/2023. (Attachments: #1 Exhibit Declaration of Dale Fredericks)(Gunderson, Mark)
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Filing 13
ORDER GRANTING MOTION TO SEAL (ECF No. #2 ) - Signed by Magistrate Judge Carla Baldwin on 2/6/2023.(Copies have been distributed pursuant to the NEF - CJS)
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Filing 12
DECLARATION of Robert H. O'Leary re #10 Motion to Dismiss by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Attachments: #1 Exhibit A - Certificate of Incorporatoin)(Hart, Leslie Bryan)
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Filing 11
REQUEST for Judicial Notice re #10 Motion to Dismiss by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 10
MOTION to Dismiss by Defendants Thomas L Kirkham, Jr., Richard D Lee. Responses due by 2/17/2023. (Hart, Leslie Bryan)
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Filing 9
CERTIFICATE of Interested Parties by Thomas L Kirkham, Jr., Richard D Lee that identifies all parties that have an interest in the outcome of this case. Other Affiliate Evolve Lubricants, Inc. for Richard D Lee, Thomas L Kirkham, Jr. added.. (Hart, Leslie Bryan)
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Filing 8
NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Nicholas B. Pfeiffer 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 PACER website www.pacer.gov to register Attorney. Verified Petition due by 2/17/2023. (no image attached) (WJ)
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Filing 7
NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Robert H. O'Leary 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 PACER website www.pacer.gov to register Attorney. Verified Petition due by 2/17/2023. (no image attached) (WJ)
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Filing 6
NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Michael D. Weil 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 PACER website www.pacer.gov to register Attorney. Verified Petition due by 2/17/2023. (no image attached) (WJ)
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Filing 5
CERTIFICATE OF SERVICE for #4 Minute Order Removal Case, by Defendants Thomas L Kirkham, Jr., Richard D Lee.. (Hart, Leslie Bryan)
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Filing 4
MINUTE ORDER IN CHAMBERS of the Honorable Judge Larry R. Hicks on 1/30/2023. Statement regarding removed action is due by 2/14/2023. Joint Status Report regarding removed action is due by 3/1/2023. (Copies have been distributed pursuant to the NEF - DRM)
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Case randomly assigned to Judge Larry R. Hicks and Magistrate Judge Carla Baldwin. (DRM)
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Filing 2
MOTION to Seal Document by Defendants Thomas L Kirkham, Jr., Richard D Lee. Responses due by 2/10/2023. (Attachments: #1 Exhibit A - Lee Declaration, #2 Exhibit B - O'Leary Declaration)(Hart, Leslie Bryan)
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Filing 1
PETITION FOR REMOVAL from Second Judicial District Court, Case Number CV22-02055, (Filing fee $ 402 receipt number ANVDC-7188045) by Richard D Lee, Thomas L Kirkham, Jr.. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A - State Court Record, #3 Exhibit B - Redacted Declaration) (Hart, Leslie Bryan) 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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