ROSE v. FERRARI NORTH AMERICA, INC. et al
| JEFFREY ROSE, SIXTYSIX CAPITAL, LLC, VAN CARLUCCI and ART BARTOSIK |
| FERRARI NORTH AMERICA, INC., FERRARI N.V., FERRARI S.P.A., ROBERT BOSCH, LLC and ROBERT BOSCH GMBH |
| 2:2021cv20772 |
| December 30, 2021 |
| US District Court for the District of New Jersey |
| Michael E Farbiarz |
| John Michael Vazquez |
| Cathy L Waldor |
| Motor Vehicle Prod. Liability |
| 28 U.S.C. § 1332 Diversity-Motor Vehicle Product Liability |
| Plaintiff |
Docket Report
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Filing 130
TEXT ORDER: Parties shall continue to meet and confer regarding the scope of jurisdictional discovery. The Court will hold a telephone conference, on 12/21/23 at 1:30pm. Parties are to use the Courts teleconference dial-in: 888-808-6929 and Access Code is 9464201.. So Ordered by Magistrate Judge Cathy L. Waldor on 10/17/23. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Telephone Conference held on 10/17/2023. (tjg, )
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Filing 129
STIPULATION AND ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND HARD COPY RECORDS. Signed by Magistrate Judge Cathy L. Waldor on 9/22/2023. (ld, )
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Filing 128
Discovery Confidentiality Order. Signed by Magistrate Judge Cathy L. Waldor on 9/22/2023. (ld, )
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Filing 127
Proposed Order And Joint Stipulation Regarding Discovery of Electronically Stored Information and Hard Copy Records by VAN CARLUCCI, JEFFREY ROSE. (CECCHI, JAMES)
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Filing 126
Proposed Order For Discovery Confidentiality by VAN CARLUCCI, JEFFREY ROSE. (CECCHI, JAMES)
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Filing 125
TEXT ORDER: Per the parties' joint request, and for good cause shown, the parties' deadline to submit a proposed ESI Protocol and a proposed Discovery Confidentiality Order is extended through and including 9/20/23. So Ordered by Magistrate Judge Cathy L. Waldor on 9/11/23. (tjd)
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Filing 124
Letter from Christopher Dalton re #123 Stipulation and Order,. (DALTON, CHRISTOPHER)
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Filing 123
STIPULATION and ORDER regarding the Submission of Discovery Protocols. Plaintiffs and Defendants shall file joint proposed Discovery Protocols on or before 9/8/2023. Should Plaintiffs and Defendants be unable to reach agreement on the Discovery Protocols, they shall submit their respective proposals on 9/8/2023. Signed by Magistrate Judge Cathy L. Waldor on 9/5/2023. (dam)
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Filing 122
Proposed Order And Joint Stipulation Regarding the Submission of Discovery Protocols by VAN CARLUCCI, JEFFREY ROSE. (CECCHI, JAMES)
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Filing 121
JURISDICTIONAL DISCOVERY SCHEDULING ORDER. Signed by Magistrate Judge Cathy L. Waldor on 8/31/2023. (dam)
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Filing 120
Proposed Order Scheduling Jurisdictional Discovery as to Defendant Ferrari S.p.A. by VAN CARLUCCI, JEFFREY ROSE. (CECCHI, JAMES)
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Filing 119
TEXT ORDER: Per Defendants' request, and for good cause shown, (ECF No. 117), the parties' deadline for submitting a proposed schedule for jurisdictional discovery is extended through and including 8/25/23. So Ordered by Magistrate Judge Cathy L. Waldor on 8/21/23. (tjd)
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Filing 118
Letter from Christopher Dalton re 117 Order,. (DALTON, CHRISTOPHER)
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Filing 117
TEXT ORDER: Per Defendants' request, and for good cause shown, (ECF No. 115), the parties' deadline for submitting a proposed schedule for jurisdictional discovery is extended through and including 8/21/23. So Ordered by Magistrate Judge Cathy L. Waldor on 8/15/23.
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Filing 116
REPLY to Response to Motion filed by VAN CARLUCCI, JEFFREY ROSE re #107 MOTION FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFFS' RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS re #98 Declaration, #97 Certification, #93 MOTION to Dismiss Amended Class Action Complaint, #94 Amended MOTION to Dismiss fo (Attachments: #1 Declaration of James E. Cecchi, Esq. in Support of Plaintiffs Reply Memorandum of Law in Further Support of Their Motion for Judicial Notice, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D)(CECCHI, JAMES)
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Filing 115
Letter from Christopher J. Dalton re #111 Opinion,, Order, 112 Order,. (DALTON, CHRISTOPHER)
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Filing 114
RESPONSE in Opposition filed by ROBERT BOSCH GMBH re #107 MOTION FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFFS' RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS re #98 Declaration, #97 Certification, #93 MOTION to Dismiss Amended Class Action Complaint, #94 Amended MOTION to Dismiss fo (Attachments: #1 Declaration Thomas Regan, #2 Certificate of Service)(DEENEY, BRIAN)
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Filing 113
RESPONSE in Opposition filed by FERRARI NORTH AMERICA, INC. re #107 MOTION FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFFS' RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS re #98 Declaration, #97 Certification, #93 MOTION to Dismiss Amended Class Action Complaint, #94 Amended MOTION to Dismiss fo (Attachments: #1 Declaration in Support of Response to Motion)(DALTON, CHRISTOPHER)
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Filing 112
TEXT ORDER: The parties shall meet and confer regarding the jurisdictional discovery contemplated in the Hon. Michael E. Farbiarz, U.S.D.J.'s 7/31/23 Order, (ECF No. 111), and, on or before 8/14/23, submit a proposed schedule for such discovery for the Court's consideration. So Ordered by Magistrate Judge Cathy L. Waldor on 7/31/23. (tjd)
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Filing 111
AMENDED OPINION and ORDER denying #94 Defendant FERRARI S.P.A.'s Motion to Dismiss for Lack of Jurisdiction. This is without prejudice to a challenge later, after jurisdictional discovery is done. Jurisdictional discovery as to the Defendant may go forward. Signed by Judge Michael E. Farbiarz on 7/31/2023. (dam)
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Filing 110
TEXT ORDER: The Opinion and Order issued on Friday, July 28, 2023 included a footnote, number 11, that should have not been there. An Amended Opinion and Order will be placed on the docket this morning, that removes footnote 11 and that also makes certain small conforming changes. So Ordered by Judge Michael E. Farbiarz on 7/31/2023. (ro, )
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Filing 109
OPINION and ORDER denying #94 Defendant FERRARI S.P.A.'s Motion to Dismiss for Lack of Jurisdiction. This is without prejudice to a challenge later, after jurisdictional discovery is done. Jurisdictional discovery as to the Defendant may go forward. Signed by Judge Michael E. Farbiarz on 7/28/2023. (dam)
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Set Deadlines as to #107 MOTION FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFFS' RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS re #98 Declaration, #97 Certification, #93 MOTION to Dismiss Amended Class Action Complaint, #94 Amended MOTION to Dismiss fo. Motion set for 8/21/2023 before Judge Michael E. Farbiarz. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 108
Letter from James E. Cecchi, Esq. to Hon. Michael E. Farbiarz, U.S.D.J. and Hon. Cathy L. Waldor, U.S.M.J.. (CECCHI, JAMES)
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Filing 107
MOTION FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFFS' RESPONSES TO DEFENDANTS' MOTIONS TO DISMISS re #98 Declaration, #97 Certification, #93 MOTION to Dismiss Amended Class Action Complaint, #94 Amended MOTION to Dismiss for Lack of Jurisdiction , #101 Brief in Opposition to Motion,, #100 MOTION to Dismiss Plaintiffs' Amended Complaint, #95 Certification, #99 MOTION to Dismiss , #96 Certification by VAN CARLUCCI, JEFFREY ROSE. (Attachments: #1 Memorandum of Law in Support, #2 Exhibit A, #3 Text of Proposed Order)(CECCHI, JAMES)
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Filing 106
REDACTION Redacted Version of Plaintiffs' Brief in Opposition to Robert Bosch GmbH's Motion to Dismiss by ROBERT BOSCH GMBH. (Attachments: #1 Exhibit F)(DEENEY, BRIAN)
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Filing 105
ORDER granting #103 Motion to Seal; that the Clerk of the Court is directed to maintain the unredacted versions of the Brief i Opposition and Exhibit F to that brief filed by Plaintiffs on May 5, 2023, (ECF No. 101), under seal; that counsel for Robert Bosch GmbH shall file the redacted versions of the Brief in opposition and Exhibit F to that brief on the docket forthwith. Signed by Magistrate Judge Cathy L. Waldor on 6/20/2023. (ld, )
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Filing 104
TEXT ORDER: The Court will hold a telephone conference, on 10/17/23 at 11:30am. Parties are to use the Courts teleconference dial-in: 888-808-6929 and Access Code is 9464201.. So Ordered by Magistrate Judge Cathy L. Waldor on 5/22/23. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Zoom Status Conference held on 5/22/2023. (tjg, )
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Filing 103
MOTION to Seal by ROBERT BOSCH GMBH. (Attachments: #1 Declaration Thomas Regan, Esq., #2 Exhibit A, #3 Appendix U, #4 Text of Proposed Order, #5 Certificate of Service)(DEENEY, BRIAN)
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Set Deadlines as to #103 MOTION to Seal . Motion set for 6/20/2023 before Judge Michael E. Farbiarz. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 102
TEXT ORDER REASSIGNING CASE. Case reassigned to Judge Michael E. Farbiarz for all further proceedings. Judge John Michael Vazquez no longer assigned to case. So Ordered by Chief Judge Renee Marie Bumb on 5/18/2023. (mmb, )
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Set Deadlines as to #100 MOTION to Dismiss Plaintiffs' Amended Complaint. Motion set for 6/5/2023 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 101
BRIEF in Opposition filed by All Plaintiffs re #100 MOTION to Dismiss Plaintiffs' Amended Complaint (Attachments: #1 Declaration Declaration of James E. Cecchi)(CECCHI, JAMES)NOTICE TO COUNSEL: Counsel is advised that pursuant to Local Civil Rule 5.3(c)(2), a single, consolidated motion to seal shall be filed within 14 days following the completed briefing of the materials sought to be sealed, or within 14 days following the date on which the last of such materials was filed under temporary seal if the motion is resolved, unless otherwise directed by the Court.
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Filing 100
MOTION to Dismiss Plaintiffs' Amended Complaint by ROBERT BOSCH GMBH. Responses due by 5/5/2023. (Attachments: #1 Brief in Support, #2 Text of Proposed Order, #3 Declaration James Cecchi with Exhibits A-E, #4 Exhibit G-Q of Cecchi Declaration, #5 Brief in Further Support, #6 Certificate of Service)(DEENEY, BRIAN)
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Set Deadlines as to #94 Amended MOTION to Dismiss for Lack of Jurisdiction , #99 MOTION to Dismiss . Motion set for 5/15/2023 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 99
MOTION to Dismiss by FERRARI NORTH AMERICA, INC., FERRARI S.P.A.. Responses due by 4/7/2023. (Attachments: #1 Brief in Support, #2 Certification in Support, #3 Text of Proposed Order Granting Motion, #4 Brief in Opposition, #5 Brief in Further Support)(DALTON, CHRISTOPHER)
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Filing 98
DECLARATION of Enrico Gallieri in Support of Motion to Dismiss for Lack of Jurisdiction re #94 Amended MOTION to Dismiss for Lack of Jurisdiction by FERRARI S.P.A.. (DALTON, CHRISTOPHER)
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Filing 97
Certification of James E. Cecchi in Opposition to Motion to Dismiss for Lack of Jurisdiction (Part 3 of 3) on behalf of FERRARI S.P.A. Re #94 Motion to Dismiss/Lack of Jurisdiction,. (DALTON, CHRISTOPHER)
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Filing 96
Certification of James E. Cecchi in Opposition to Motion to Dismiss for Lack of Jurisdiction (Part 2 of 3) on behalf of FERRARI S.P.A. Re #94 Motion to Dismiss/Lack of Jurisdiction,. (DALTON, CHRISTOPHER)
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Filing 95
Certification of James E. Cecchi in Opposition to Motion to Dismiss for Lack of Jurisdiction (Part 1 of 3) on behalf of FERRARI S.P.A. Re #94 Motion to Dismiss/Lack of Jurisdiction,. (DALTON, CHRISTOPHER)
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Filing 94
Amended MOTION to Dismiss for Lack of Jurisdiction by FERRARI S.P.A.. Responses due by 4/7/2023. (Attachments: #1 Brief in Support, #2 Text of Proposed Order Granting Motion, #3 Brief in Opposition, #4 Brief in Further Support)(DALTON, CHRISTOPHER)
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Filing 93
MOTION to Dismiss Amended Class Action Complaint by FERRARI S.P.A.. Responses due by 4/7/2023. (Attachments: #1 Brief In Support of Motion to Dismiss Under Rule 12(b)(2), #2 Text of Proposed Order)(DALTON, CHRISTOPHER)
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Filing 92
TEXT ORDER: In light of Plaintiff Bartosik's notice of voluntary dismissal, (ECF No. 91), the Court will once again conduct the 5/22/23 status conference via Zoom, and will distribute connection information on the day of the session. So Ordered by Magistrate Judge Cathy L. Waldor on 4/3/23. (tjd)
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Filing 91
NOTICE by ART BARTOSIK, SIXTYSIX CAPITAL, LLC OF VOLUNTARY DISMISSAL WITHOUT PREJUDICE (CECCHI, JAMES)
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Filing 90
TEXT ORDER: The Court has reviewed counsel's letter dated 3/28/23. (ECF No. 89). The Court will conduct the conference already scheduled for 5/22/23 IN PERSON in Courtroom 4D of the Martin Luther King Building and U.S. Courthouse, 50 Walnut Street, Newark, New Jersey. Plaintiff Bartosik must attend. So Ordered by Magistrate Judge Cathy L. Waldor on 3/31/23. (tjd)
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Filing 89
Letter from Christopher Dalton. (DALTON, CHRISTOPHER)
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Filing 88
NOTICE by All Plaintiffs of Voluntary Dismissal of Robert Bosch, LLC Without Prejudice (CECCHI, JAMES)
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Status Conference held on 3/9/2023. (tjg, )
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Filing 87
STIPULATION and ORDER that Bosch LLC will serve but not file its renewed Rule 12 motion on or before 3/3/2023. Robert Bosch GmbH will serve but not file its Rule 12 motion in response to the Amended Complaint on or before 3/3/2023. Signed by Magistrate Judge Cathy L. Waldor on 2/24/2023. (dam)
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Filing 86
STIPULATION Regarding Deadlines for Robert Bosch LLC and Robert Bosch GmbH to Respond to Amended Complaint by ROBERT BOSCH GMBH, ROBERT BOSCH, LLC. (REGAN, THOMAS)
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Filing 85
TEXT ORDER: The Court will continue the 1/26/23 zoom status conference on 5/22/23 at 11:30am. So Ordered by U.S.M.J. Cathy L. Waldor. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Status Conference held on 1/26/2023. (tjg, )
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Filing 84
TEXT ORDER: TEXT ORDER: The Court will reschedule the 2/22/23 conference to 3/9/23 at 12:30pm. So Ordered by Magistrate Judge Cathy L. Waldor on 1/11/23. (tjg, )
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Filing 83
TEXT ORDER: The Court will reschedule the 2/22/23 conference to 2/28/23 at 2pm. So Ordered by Magistrate Judge Cathy L. Waldor on 1/11/23. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Status Conference held on 12/22/2022. (tjg, )
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Filing 82
STIPULATION and ORDER extending the deadline for Defendants ROBERT BOSCH, LLC and ROBERT BOSCH GMBH to respond to the Amended Complaint through 2/25/2023. Signed by Magistrate Judge Cathy L. Waldor on 12/19/2022. (dam)
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Filing 81
STIPULATION Regarding Deadlines for Robert Bosch, LLC and Robert Bosch GmbH to Respond to Amended Complaint by ROBERT BOSCH GMBH. (REGAN, THOMAS)
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Filing 80
Corporate Disclosure Statement by SIXTYSIX CAPITAL, LLC. (CECCHI, JAMES)
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Filing 79
AMENDED COMPLAINT against FERRARI NORTH AMERICA, INC., FERRARI S.P.A., ROBERT BOSCH GMBH, ROBERT BOSCH, LLC, SIXTYSIX CAPITAL, LLC, VAN CARLUCCI, ART BARTOSIK, filed by JEFFREY ROSE, SIXTYSIX CAPITAL, LLC, VAN CARLUCCI, ART BARTOSIK. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(CECCHI, JAMES)
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Filing 78
TEXT ORDER: In light of the recent developments in this matter, the telephone conference scheduled for 11/30/22 is CANCELLED. The next event in this matter will be the Zoom conference scheduled for 12/22/22. (ECF No. 71). So Ordered by Magistrate Judge Cathy L. Waldor on 11/29/22. (tjd)
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Filing 77
STIPULATION AND ORDER Extending Time to Respond to Jurisdictional Discovery Requests through and until 12/2/2022. Signed by Magistrate Judge Cathy L. Waldor on 11/23/2022. (wh)
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Filing 76
STIPULATION Extending Time to Respond to Jurisdictional Discovery Requests by ROBERT BOSCH, LLC. (REGAN, THOMAS)
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Filing 75
REVISED STIPULATION AND ORDER extending Plaintiff's Time to File the Amended Complaint and Ferrari Defendants' Time to Respond to the Amended Complaint and Briefing Schedule in Event of Motion to Dismiss. Plaintiff will file his Amended Complaint on or before 12/5/2022. Ferrari Defendants will respond to the Amended Complaint on or before 1/3/2022. Signed by Magistrate Judge Cathy L. Waldor on 11/18/2022. (dam)
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Filing 74
Letter re #73 Stipulation and Order,. (Attachments: #1 Text of Proposed Order)(DALTON, CHRISTOPHER)
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Filing 73
STIPULATION AND ORDER Extending Time to Respond to Amended Complaint and Briefing Schedule. The Ferrari Defendants' time to respond to the Amended Complaint is extended through and until 12/23/2022. Signed by Magistrate Judge Cathy L. Waldor on 11/14/2022. (dam)
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Filing 72
STIPULATION re #68 Order on Motion to Stay,,,,,, Order on Motion for Protective Order,,, Order on Motion to Dismiss,,,,, Extending Ferrari Defendants' Time to Respond to Amended Complaint and Briefing Schedule for Motion to Dismiss by FERRARI NORTH AMERICA, INC., FERRARI S.P.A.. (DALTON, CHRISTOPHER)
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Filing 71
TEXT ORDER: The Court will conduct Zoom status conferences on 12/22/22, 1/26/23, and 2/22/23. Each conference will begin at 1:00 p.m. and the Court will distribute connection information to counsel of record on the day of each conference. The parties shall promptly advise the Court of any discovery or case management issues that arise in the interim. So Ordered by Magistrate Judge Cathy L. Waldor on 11/4/22. (tjd)
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Zoom Status Conference held on 11/4/2022. (tjg, )
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Filing 70
TEXT ORDER: The Court will reschedule the 11/4/22 conference to 11am. So Ordered by Magistrate Judge Cathy L. Waldor on 11/3/22. (tjg, )
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Filing 69
TEXT ORDER: The undersigned has reviewed Judge Vazquez's 10/25/22 Order, (ECF No. 68), and will conduct a status conference, via Zoom, on 11/4/22 at 10:00 a.m. The Court will distribute connection information to counsel of record on the day of the conference. So Ordered by Magistrate Judge Cathy L. Waldor on 10/25/22. (tjd)
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Filing 68
ORDER denying without prejudice as moot #50 , #51 Defendants' Motions to Stay; denying without prejudice as moot #61 Defendant Bosch's Motion for Protective Order; granting #22 Defendant Ferrari North America Inc.'s Motion to Dismiss; denying #25 Defendant Bosch's Motion to Dismiss; dismissing the Complaint as to Ferrari without prejudice. Plaintiff is granted leave to file an Amended Pleading that remedies the identified deficiencies as to Ferrari. Defendant Bosch is given leave to file a renewed Motion to Dismiss after the completion of jurisdictional discovery. The renewed motion must be filed within four (4) months from the date of the Order. Signed by Judge John Michael Vazquez on 10/25/2022. (dam)
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Filing 67
OPINION. Signed by Judge John Michael Vazquez on 10/25/2022. (dam)
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Filing 66
BRIEF in Opposition filed by All Plaintiffs re #61 MOTION for Protective Order (CECCHI, JAMES)
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Reset Deadlines as to #61 MOTION for Protective Order. Motion reset for 11/7/2022 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk's Office and does not supersede any previous or subsequent orders from the Court. (dam)
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Filing 65
LETTER ORDER granting #63 Plaintiff's Letter requesting to modify the deadlines and Motion Day regarding the #61 Motion for Protective Order. Signed by Magistrate Judge Cathy L. Waldor on 10/3/2022. (dam)
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Filing 64
STIPULATION AND ORDER extending Defendant FERRARI S.P.A.'s time to respond to the Complaint through and until 11/7/2022. Signed by Magistrate Judge Cathy L. Waldor on 9/30/2022. (dam)
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Filing 63
Letter from Caroline F. Bartlett, Esq. to the Honorable Cathy L. Waldor Regarding an Extension of Time re Set/Reset Motion and R&R Deadlines/Hearings, #61 MOTION for Protective Order . (BARTLETT, CAROLINE)
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Filing 62
STIPULATION re #1 Complaint, Extending Ferrari SPA's Time to Respond by FERRARI S.P.A.. (DALTON, CHRISTOPHER)
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Filing 61
MOTION for Protective Order by ROBERT BOSCH, LLC. (Attachments: #1 Brief, #2 Certification Thomas Regan, Esq., #3 Exhibit A, #4 Exhibit B, #5 Text of Proposed Order, #6 Certificate of Service)(DEENEY, BRIAN)
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Set Deadlines as to #61 MOTION for Protective Order . Motion set for 10/17/2022 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 60
TEXT ORDER: The Court will hold a telephone conference, on 11/30/22 at 10:30am. Parties are to use the Courts teleconference dial-in: 888-808-6929 and Access Code is 9464201.. So Ordered by Magistrate Judge Cathy L. Waldor on 8/29/22. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Telephone Conference held on 8/23/2022. (tjg, )
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Filing 59
ORDER that James E. Cecchi of Carella, Byrne, Cecchi, Olstein, Brody & Agnello, P.C ("Carella Byrne"); Michael J. Flannery of Cuneo Gilbert & LaDuca, LLP ("CGL"); and Gary K. Burger of Burger Law, LLC ("Burger Law") are hereby appointed as Interim Class Counsel on behalf of the Plaintiff and the proposed class. James E. Cecchi is also hereby appointed as Interim Liaison Counsel for Plaintiff and the proposed class.. Signed by Judge John Michael Vazquez on 8/19/2022. (ld, )
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Filing 58
RESPONSE re #55 Notice (Other),. (Attachments: #1 Exhibit A, #2 Exhibit B)(BAYLY, MELISSA)
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Filing 57
Letter from James E. Cecchi to the Hon. John M. Vazquez, U.S.D.J. regarding Appointment of Proposed Interim Class Counsel. (Attachments: #1 Text of Proposed Order)(CECCHI, JAMES)
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Filing 56
TEXT ORDER: The Court will reschedule the 8/18/22 conference to 8/23/22 at 10:30am. So Ordered by Magistrate Judge Cathy L. Waldor on 8/10/22. (tjg, )
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Filing 55
NOTICE by All Plaintiffs re #24 Memorandum in Support of Motion, #50 MOTION to Stay re #46 Order , #51 MOTION to Stay re #46 Order , #25 MOTION to Dismiss (Attachments: #1 Exhibit A)(CECCHI, JAMES)
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Filing 54
BRIEF in Opposition filed by All Plaintiffs re #50 MOTION to Stay re #46 Order , #51 MOTION to Stay re #46 Order (CECCHI, JAMES)
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Filing 53
REPLY BRIEF to Opposition to Motion filed by ROBERT BOSCH, LLC re #25 MOTION to Dismiss (DEENEY, BRIAN)
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Filing 52
REPLY BRIEF to Opposition to Motion filed by FERRARI NORTH AMERICA, INC. re #22 MOTION to Dismiss (DALTON, CHRISTOPHER)
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Set Deadlines as to #50 MOTION to Stay re #46 Order , #51 MOTION to Stay re #46 Order . Motion set for 6/21/2022 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 51
MOTION to Stay re #46 Order by ROBERT BOSCH, LLC. (Attachments: #1 Brief, #2 Certification Thomas Regan, Esq., #3 Text of Proposed Order, #4 Certificate of Service)(DEENEY, BRIAN)
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Filing 50
MOTION to Stay re #46 Order by FERRARI NORTH AMERICA, INC.. (Attachments: #1 Brief in Support of Motion to Stay Discovery, #2 Text of Proposed Order)(DALTON, CHRISTOPHER)
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Pro Hac Vice counsel, JOHN M. THOMAS, ERIC C. TEW and KRISTA L. LENART, has been added to receive Notices of Electronic Filing. Pursuant to L.Civ.R. 101.1, only local counsel are entitled to sign and file papers, enter appearances and receive payments on judgments, decrees or orders. (lag, )
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Filing 49
Notice of Request by Pro Hac Vice John Thomas to receive Notices of Electronic Filings. (DEENEY, BRIAN)
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Filing 48
Notice of Request by Pro Hac Vice Eric Tew to receive Notices of Electronic Filings. (DEENEY, BRIAN)
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Filing 47
Notice of Request by Pro Hac Vice Krista Lenart to receive Notices of Electronic Filings. (DEENEY, BRIAN)
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Pro Hac Vice fee for Kathy A. Wisiewski and Stephen D'Aunoy: $ 300, receipt number NEW046610 (jr)
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Filing 46
STIPULATION AND ORDER REGARDING MOTIONS TO STAY DISCOVERY. Signed by Magistrate Judge Cathy L. Waldor on 5/3/2022. (sm)
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Filing 45
ORDER APPOINTING SPECIAL PROCESS SERVER re: #42 . Signed by Magistrate Judge Cathy L. Waldor on 5/3/2022. (sm)
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Pro Hac Vice fee received as to Krista L. Lenart, John M. Thomas, and Eric C. Tew: $ 450, receipt number TRE126258 (jdg)
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Filing 44
BRIEF in Opposition filed by All Plaintiffs re #22 MOTION to Dismiss , #25 MOTION to Dismiss (CECCHI, JAMES)
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Filing 43
STIPULATION re 41 Order, Briefing Schedule on Motions to Stay Discovery by FERRARI NORTH AMERICA, INC.. (DALTON, CHRISTOPHER)
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Filing 42
MOTION TO APPOINT A SPECIAL PROCESS SERVER by All Plaintiffs. (Attachments: #1 Text of Proposed Order)(CECCHI, JAMES)
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Set Deadlines as to #42 MOTION TO APPOINT A SPECIAL PROCESS SERVER . Motion set for 6/6/2022 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (lag, )
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Filing 41
TEXT ORDER: Parties will submit a briefing schedule addressing the motion for a stay. Parties shall meet and confer and discuss what if any jurisdictional discovery is necessary and inform the Court on the docket of same, with a schedule for that proposed discovery. The Court will hold a telephone conference, on 8/18/22 at 11:30am. Parties are to use the Courts teleconference dial-in: 888-808-6929 and Access Code is 9464201.. So Ordered by Magistrate Judge Cathy L. Waldor on 4/26/22. (tjg, )
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Minute Entry for proceedings held before Magistrate Judge Cathy L. Waldor: Initial Pretrial Conference held on 4/25/2022. (tjg, )
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Filing 40
TEXT ORDER: The Court will conduct the telephone conference already scheduled for 4/25/22 via its dedicated conference line. The parties are instructed to dial 1-888-808-6929 and enter Access Code 9464201 at the time of the conference. So Ordered by Magistrate Judge Cathy L. Waldor on 4/21/2022. (tjd)
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Filing 39
Joint Discovery Plan by All Plaintiffs.(BARTLETT, CAROLINE)
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Filing 38
Notice of Request by Pro Hac Vice Jordan M. Steele to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13300438.) (CECCHI, JAMES)
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Filing 37
Notice of Request by Pro Hac Vice Dylan T. Martin to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13300412.) (CECCHI, JAMES)
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Filing 36
Notice of Request by Pro Hac Vice James Mitchell Williams to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13300389.) (CECCHI, JAMES)
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Filing 35
Notice of Request by Pro Hac Vice H. Clay Barnett, III to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13300375.) (CECCHI, JAMES)
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Filing 34
Notice of Request by Pro Hac Vice W. Daniel "Dee" Miles, III to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13300343.) (CECCHI, JAMES)
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Filing 33
ORDER PERMITTING PRO HAC VICE ADMISSION OF W. DANIEL DEE MILES, III, H. CLAY BARNETT, III, JAMES MITCHELL WILLIAMS, DYLAN T. MARTIN, AND JORDAN M. STEELE; etc. Signed by Magistrate Judge Cathy L. Waldor on 3/28/2022. (sm)
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Filing 32
ORDER PERMITTING PRO HAC VICE ADMISSION OF KRISTA L. LENART, JOHN M. THOMAS, AND ERIC C. TEW; etc. Signed by Magistrate Judge Cathy L. Waldor on 3/28/2022. (sm)
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Filing 31
TEXT ORDER: The Court will hold an initial conference (rule 16) before U.S.M.J. C. Waldor by telephone on 4/25/22 at 10:30am. Plaintiff shall initiate the call and local counsel for any/all parties must participate. Parties are to submit a completed Pretrial Scheduling Order (for Judge Salas cases, please use her dedicated PTSO found in the same location) found in the Notice of Judicial Preferences link to chambers via email at CLW_Orders@njd.uscourts.gov no later than 3 days before the scheduled conference.. Please contact chambers with any questions or concerns at (973) 776 7862. So Ordered by Magistrate Judge Cathy L. Waldor on 3/28/22. (tjg, )
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Notice of Judicial Preferences. #Click here for the Judge's Individual Procedure Requirements. (tjg, )
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Filing 30
Letter from James E. Cecchi. (Attachments: #1 Certification of James E. Cecchi, #2 Certification of Clay Barnett, III, #3 Certification of James E. Cecchi, #4 Certification of W. Daniel "Dee" Miles, III, #5 Certification of James E. Cecchi, #6 Certification of Dylan T. Martin, #7 Certification of James E. Cecchi, #8 Certification of James Mitchell Williams, #9 Certification of James E. Cecchi, #10 Certification Jordan M. Steele, #11 Text of Proposed Order)(CECCHI, JAMES)
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Filing 29
MOTION for Leave to Appear Pro Hac Vice by ROBERT BOSCH, LLC. (Attachments: #1 Certification Certification of Krista L. Lenart, #2 Certification Certification of John M. Thomas, #3 Certification Certification of Eric C. Tew, #4 Declaration Declaration on behalf of Krista L. Lenart, #5 Declaration Declaration on behalf of John M. Thomas, #6 Declaration Declaration on behalf of Eric C. Tew, #7 Text of Proposed Order Proposed Order for PHV Admission)(KAMARIS, KARLEY)
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Filing 28
Notice of Request by Pro Hac Vice Kathy Wisniewski to receive Notices of Electronic Filings. (WEYAND, JACQUELINE)
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Filing 27
Notice of Request by Pro Hac Vice Stephen D'Aunoy to receive Notices of Electronic Filings. (WEYAND, JACQUELINE)
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Set Deadlines as to #22 MOTION to Dismiss , #25 MOTION to Dismiss . Motion set for 4/18/2022 before Judge John Michael Vazquez. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (sm)
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Filing 26
ORDER GRANTING ADMISSION PRO HAC VICE OF KATHY A. WISNIEWSKI AND STEPHEN D'AUNOY; etc. Signed by Magistrate Judge Cathy L. Waldor on 3/14/2022. (sm)
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Filing 25
MOTION to Dismiss by ROBERT BOSCH, LLC. Responses due by 5/23/2022 (Attachments: #1 Text of Proposed Order, #2 Brief)(KAMARIS, KARLEY)
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Filing 24
MEMORANDUM in Support filed by FERRARI NORTH AMERICA, INC. re #22 MOTION to Dismiss (Attachments: #1 Certificate of Service)(DALTON, CHRISTOPHER)
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Filing 23
CERTIFICATION in Support filed by FERRARI NORTH AMERICA, INC. re #22 MOTION to Dismiss (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(DALTON, CHRISTOPHER)
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Filing 22
MOTION to Dismiss by FERRARI NORTH AMERICA, INC.. Responses due by 5/23/2022 (Attachments: #1 Certificate of Service, #2 Text of Proposed Order)(DALTON, CHRISTOPHER)
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Filing 21
Corporate Disclosure Statement by FERRARI NORTH AMERICA, INC. identifying Defendant Ferrari North America, Inc. is a wholly owned subsidiary of Ferrari S.p.A., which in turn is wholly owned by Ferrari N.V., which is a publicly-traded company. as Corporate Parent.. (Attachments: #1 Certificate of Service)(DALTON, CHRISTOPHER)
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Filing 20
Letter from Christopher J. Dalton. (Attachments: #1 Exhibit Certification of C. Dalton in Support of Application for pro hac vice admission of Kathy A. Wisniewski, #2 Exhibit Certification of C. Dalton in Support of Application for pro hac vice admission of Stephen A. DAunoy, #3 Exhibit Certification of K. Wisniewski, #4 Exhibit Certification of D. DAunoy, #5 Exhibit Proposed Order)(DALTON, CHRISTOPHER)
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Filing 19
Notice of Request by Pro Hac Vice Gary K. Burger to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13224390.) (CECCHI, JAMES)
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Filing 18
Notice of Request by Pro Hac Vice Alexandra C. Warren to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13224383.) (CECCHI, JAMES)
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Filing 17
Notice of Request by Pro Hac Vice Michael J. Flannery to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13224377.) (CECCHI, JAMES)
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Filing 16
Notice of Request by Pro Hac Vice Charles J. LaDuca to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-13224354.) (CECCHI, JAMES)
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Filing 15
NOTICE of Appearance by KARLEY E. KAMARIS on behalf of ROBERT BOSCH, LLC (KAMARIS, KARLEY)
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Filing 14
ORDER PERMITTING PRO HAC VICE ADMISSION OF CHARLES J. LADUCA, MICHAEL J. FLANNERY,ALEXANDRA C. WARREN, AND GARY K. BURGER; etc. Signed by Magistrate Judge Cathy L. Waldor on 2/18/2022. (sm)
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Filing 13
Letter from James E. Cecchi. (Attachments: #1 Certification of James E. Cecchi in Support of Application for pro hac vice Admission of Gary K. Burger, #2 Certification of James E. Cecchi in Support of Application for pro hac vice Admission of Charles J. LaDuca, #3 Certification of James E. Cecchi in Support of Application for pro hac vice Admission of Michael J. Flannery, #4 Certification of James E. Cecchi in Support of Application for pro hac vice Admission of Alexandra C. Warren, #5 Certification of Gary K. Burger, #6 Certification of Charles J. LaDuca, #7 Certification of Michael J. Flannery, #8 Certification of Alexandra C. Warren, #9 Text of Proposed Order)(CECCHI, JAMES)
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Filing 12
STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT AND BRIEFING SCHEDULE FOR MOTION TO DISMISS. Signed by Magistrate Judge Cathy L. Waldor on 2/14/2022. (sm)
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Filing 11
STIPULATION re #1 Complaint, and Proposed Order Setting Briefing Schedule on Motions to Dismiss by FERRARI NORTH AMERICA, INC.. (DALTON, CHRISTOPHER)
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Answer Due Deadline Update - The document #8 submitted by ROBERT BOSCH, LLC has been GRANTED. The answer due date has been set for 2/28/2022. (sm)
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Filing 10
STIPULATION AND ORDER EXTENDING TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO COMPLAINT that the time for Defendant Robert Bosch LLC to file its response to Plaintiff's Complaint is extended to 2/28/2022. Signed by Magistrate Judge Cathy L. Waldor on 1/31/2022. (sm)
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Filing 9
Corporate Disclosure Statement by ROBERT BOSCH, LLC identifying Robert Bosch GmbH as Corporate Parent.. (DEENEY, BRIAN)
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Filing 8
STIPULATION EXTENDING TIME TO RESPOND TO THE COMPLAINT by ROBERT BOSCH, LLC. (DEENEY, BRIAN)
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Filing 7
NOTICE of Appearance by BRIAN DEENEY on behalf of ROBERT BOSCH, LLC (DEENEY, BRIAN)
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Filing 6
Application and Proposed Order for Clerk's Order to extend time to answer as to Ferrari North America, Inc.. Attorney CHRISTOPHER J. DALTON,JACQUELINE M. WEYAND,MELISSA JEAN BAYLY for FERRARI NORTH AMERICA, INC. added. (DALTON, CHRISTOPHER)
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Filing 5
SUMMONS Returned Executed by JEFFREY ROSE. ROBERT BOSCH, LLC served on 1/7/2022, answer due 1/28/2022. (CECCHI, JAMES)
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Filing 4
SUMMONS Returned Executed by JEFFREY ROSE. FERRARI NORTH AMERICA, INC. served on 1/6/2022, answer due 1/27/2022. (CECCHI, JAMES)
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Filing 3
NOTICE of Appearance by CAROLINE F. BARTLETT on behalf of JEFFREY ROSE (BARTLETT, CAROLINE)
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Filing 2
SUMMONS ISSUED as to FERRARI N.V., FERRARI NORTH AMERICA, INC., FERRARI S.P.A., ROBERT BOSCH GMBH, ROBERT BOSCH, LLC. Attached is the official court Summons, please fill out Defendant and Plaintiffs attorney information and serve. (sm)
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Filing 1
COMPLAINT against FERRARI N.V., FERRARI NORTH AMERICA, INC., FERRARI S.P.A., ROBERT BOSCH GMBH, ROBERT BOSCH, LLC ( Filing and Admin fee $ 402 receipt number ANJDC-13075851) with JURY DEMAND, filed by JEFFREY ROSE. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Civil Cover Sheet)(CECCHI, JAMES)
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Judge John Michael Vazquez and Magistrate Judge Cathy L. Waldor added. (ps)
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