AMERICAN MARITIME SERVICES OF NEW YORK v. M/V COSTA GRANDE D'AVORIO et al
| AMERICAN MARITIME SERVICES OF NEW YORK INC. and AMERICAN MARITIME SERVICES OF NEW YORK |
| M/V COSTA GRANDE D'AVORIO, Grimaldi Deep Sea, S.p.A. and GRIMALDI DEEP SEA S.P.A. |
| PORTS AMERICA, ALESSANDRO MORETTI, BENITO LAFAUCI, THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, CITY OF NEWARK, MICHELE BROOKS and MARIA ACABOU |
| 2:2023cv04109 |
| August 1, 2023 |
| US District Court for the District of New Jersey |
| Jose R Almonte |
| Evelyn Padin |
| Other Statutory Actions |
| None |
Docket Report
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This docket was last retrieved on September 20, 2023. A more recent docket listing may be available from PACER.
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| Pro Hac Vice counsel, KASPAR KIELLAND and MATTEO BONUZZI, have 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. (wh) |
| Filing 67 Notice of Request by Pro Hac Vice Matteo Bonuzzi to receive Notices of Electronic Filings. (LEVY, JOHN) |
| Filing 66 Notice of Request by Pro Hac Vice Kaspar Kielland to receive Notices of Electronic Filings. (LEVY, JOHN) |
| Pro Hac Vice fee: $300.00, receipt number NEW49007 as to KASPAR KIELLAND & MATTEO BONUZZI. (ps) |
| Filing 65 Letter from John J. Levy, Esq. to Judge Padin giving notice of crew departure. (LEVY, JOHN) |
Filing 64
ORDER granting #39 and #63 Motions for Leave to Appear Pro Hac Vice of KASPAR KIELLAND and MATTEO BONUZZI. Signed by Magistrate Judge Jose R. Almonte on 9/13/2023. (wh)
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| Set Deadlines as to #63 MOTION for Leave to Appear Pro Hac Vice of Matteo Bonuzzi, Esq.. Motion set for 10/16/2023 before Magistrate Judge Jose R. Almonte. 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. (wh) |
| CLERK'S QUALITY CONTROL MESSAGE - The #62 Supplemental Declaration of Kaspar Kielland filed by JOHN LEVY on 9/11/2023 was submitted incorrectly as a "Motion for Leave to Appear Pro Hac Vice". As this filing was not a new motion in its own right, it should have been filed using the event "Declaration" or "Exhibit (to Document)" and linked back to the #39 MOTION for Leave to Appear Pro Hac Vice of Kaspar Kielland. This is for informational purposes only and the appropriate changes have been made by the Clerk's Office. (wh) |
| Filing 63 MOTION for Leave to Appear Pro Hac Vice of Matteo Bonuzzi, Esq. by GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO. (Attachments: #1 Certification of John J. Levy, Esq. in Support, #2 Declaration of Matteo Bonuzzi, Esq. in Support, #3 Text of Proposed Order)(LEVY, JOHN) |
| Filing 62 MOTION for Leave to Appear Pro Hac Vice (Supplemental Declaration of K. Kielland, Esq. per the Court's 8/24/23 Text Order (D.E. 46)) by GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO. (LEVY, JOHN) |
| Filing 61 Letter from John J. Levy, Esq.. (LEVY, JOHN) |
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Filing 60
STIPULATION AND ORDER: Grimaldi shall permit completion of AMS's Inspection and Testing Requests once the Vessel arrives at a ship repair yard. AMS consents to the Vessel's departure from the United States on 9/6/2023, or anytime thereafter. This Agreement constitutes "further notice to the Court," as contemplated by the 8/16/2023 Order (Dkt. No. 33), and the Vessel can in fact now leave the Court's jurisdiction. Signed by Magistrate Judge Jose R. Almonte on 9/8/2023. (wh)
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Filing 59
TEXT ORDER: The Court has reviewed petitioner's letter dated September 6, 2023 (ECF No. 56). Because the parties resolved their dispute prior to the conference scheduled for September 6, 2023, that conference was adjourned. A status conference is scheduled for November 28, 2023, at 3:00 p.m. For the conference, please dial (888) 684-8852 and enter access code 1364268. No later than November 21, 2023, the parties shall file a joint letter not to exceed five (5) pages summarizing the status of the case. To the extent the parties wish to raise a discovery dispute, they shall do so consistent with the Court's #Case Management Order. So Ordered by Magistrate Judge Jose R. Almonte on 9/7/2023. (akw)
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| Filing 58 Proposed Order and Stipulation by AMERICAN MARITIME SERVICES OF NEW YORK re #57 Letter,. (KARPOUSIS, JOHN) |
| Filing 57 Letter from John F. Karpousis to Judge Almonte. (Attachments: #1 Exhibit A - AMS Requests for Inspection and Testing, #2 Exhibit B - Grimaldi Response to Requests for Inspection and Testing, #3 Exhibit C - AMS Reply to Grimaldi including Protocols, #4 Exhibit D - Grimaldi Reply to AMS)(KARPOUSIS, JOHN) Modified on 9/7/2023 (wh). |
| Filing 56 Letter from John F. Karpousis. (KARPOUSIS, JOHN) |
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Filing 55
TEXT ORDER: The Court has reviewed the parties' correspondence dated September 5, 2023 (ECF Nos. 53, 54). The Court will address the issues raised therein at a discovery dispute conference scheduled for September 6, 2023, at 10:00 a.m. via Zoom. The Court will provide the parties with the Zoom information in advance. So Ordered by Magistrate Judge Jose R. Almonte on 9/5/2023. (akw)
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| Filing 54 Letter from Gino A. Zonghetti, Esq.. (Attachments: #1 Exhibit Email)(ZONGHETTI, GINO) |
| Filing 53 Letter from John F. Karpousis. (Attachments: #1 Exhibit Correspondence, #2 Exhibit Email Correspondence)(KARPOUSIS, JOHN) |
| Filing 52 Letter from Respondent Grimaldi Deep Sea S.P.A.. (LEVY, JOHN) |
| Filing 51 Letter from John Levy to Judge Padin giving notice of crew departure. (LEVY, JOHN) |
| Pro Hac Vice counsel, JOHN J. REILLY, 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. (wh) |
| Filing 50 Notice of Request by Pro Hac Vice John J. Reilly, Esq. to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-14606862.) (KIM, PAUL) |
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Filing 49
ORDER granting #48 Motion for Leave to Appear Pro Hac Vice of JOHN J. REILLY. Signed by Magistrate Judge Jose R. Almonte on 8/29/2023. (wh)
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| Filing 48 Consent MOTION for Leave to Appear Pro Hac Vice of John J. Reilly, Esq. by THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY. (Attachments: #1 Declaration - Paul Myung Han Kim in Support, #2 Declaration - John J. Reilly in Support, #3 Text of Proposed Order)(KIM, PAUL) |
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Filing 47
TEXT ORDER: The Court is in receipt of the parties various correspondence, including American Maritime Services of New York's ("AMS") letter indicating that "depositions will commence next week." (ECF No. 45) In light of that representation, the Court does not see a need to hold a discovery dispute conference. The Court, however, will remind the parties that Local Civil Rule 37.1 requires them to meet and confer in good faith. Only after the parties have exhausted that process are they allowed to raise discovery disputes before this Court. All discovery disputes shall be raised via the ONE JOINT letter process spelled out in the Court's #Case Management Order. The failure of any party to participate in this process in good faith may delay the resolution of the dispute and may result in the Court finding that a party waived its argument. So Ordered by Magistrate Judge Jose R. Almonte on 8/24/2023. (akw)
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Filing 46
TEXT ORDER: The Court is in receipt of Respondents' request to admit Kaspar Kielland, Esq., to appear before this Court pro hac vice (ECF No. 39). The Certification of Kaspar Kielland, however, does not include the addresses of the official or office maintaining the roll of the members for each bar to which Kaspar Kielland is admitted as required by Local Civil Rule 101.1(c)(1). The Certification of Kaspar Kielland also does not indicate whether the request is made with the consent of the parties. No later than August 30, 2023, Respondents shall file a certification supplementing the application for admission pro hac vice with this information. So Ordered by Magistrate Judge Jose R. Almonte on 8/23/2023. (akw)
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| Pro Hac Vice counsel, ROBERT E. O'CONNOR, 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. (jr) Modified on 8/30/2023 (wh). |
| Pro Hac Vice fee: $150.00, receipt number NEW48891 as to ROBERT E. O'CONNOR. (ps) Modified on 8/30/2023 (wh). |
| Filing 45 Letter from John F. Karpousis CORRECTED re #41 Letter. (KARPOUSIS, JOHN) |
| Filing 44 Letter from John F. Karpousis re #41 Letter. (KARPOUSIS, JOHN) |
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Filing 43
TEXT ORDER: The Court has reviewed D.E. #41 . First, the Court notes that its 08/16/2023 Order, D.E. 33 , prohibits only the removal of the Vessel. Second, it is ORDERED that parties are to contact Magistrate Judge Jose R. Almonte regarding the schedule of the depositions and any further discovery issues. So Ordered by Judge Evelyn Padin on 8/23/2023. (bt)
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| Filing 42 Letter from The Port Authority of New York and New Jersey in Response to Letter from John J. Levy, Esq. re #41 Letter. (KIM, PAUL) |
| Filing 41 Letter from John J. Levy, Esq.. (LEVY, JOHN) |
| Filing 39 MOTION for Leave to Appear Pro Hac Vice of Kaspar Kielland, Esq. by GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO. (Attachments: #1 Certification of John J. Levy, Esq. in Support, #2 Declaration of Kaspar Kielland, Esq. in Support, #3 Text of Proposed Order)(LEVY, JOHN) |
| Set Deadlines as to #39 MOTION for Leave to Appear Pro Hac Vice of Kaspar Kielland, Esq.. Motion set for 9/18/2023 before Judge Evelyn Padin. 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 38
TEXT ORDER: Pursuant to D.E. #35 and D.E. #37 , it is ORDERED that counsel for Petitioner, Respondent, and other Interested Parties are to coordinate discovery with counsel for the City of Newark and counsel for Brooks and Acabou. So Ordered by Judge Evelyn Padin on 8/21/2023. (bt)
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| Filing 37 Letter from Mark A. Apostolos, Esq.. (APOSTOLOS, MARK) |
| Filing 36 NOTICE of Appearance by MARK ALEXANDER APOSTOLOS on behalf of MICHELE BROOKS, proposed administrator of the Estate of WAYNE BROOKS, JR., dec'd, and MARIA ACABOU as proposed executrix of the Estate of AUGUSTO ACABOU, dec'd. (APOSTOLOS, MARK) Modified on 8/21/2023 (wh). |
| Filing 35 Letter from City of Newark re #31 Letter,. (LIPSHUTZ, GARY) |
| Filing 34 NOTICE of Appearance by GARY S. LIPSHUTZ on behalf of CITY OF NEWARK (LIPSHUTZ, GARY) |
| Filing 40 Transcript of Preliminary Injunction Hearing held on August 15, 2023, before Judge Evelyn Padin. Court Reporter: Sara Killian (973-776-3885). NOTICE REGARDING (1) REDACTION OF PERSONAL IDENTIFIERS IN TRANSCRIPTS AND (2) MOTION TO REDACT AND SEAL: The parties have seven (7) calendar days to file with the Court a Notice of Intent to Request Redaction of this Transcript to comply with Fed.R.Civ.P.5.2(a) (personal identifiers). Parties seeking to redact and seal this Transcript, or portions thereof, pursuant to L.Civ.R. 5.3(g) must e-file a Motion to Redact and Seal utilizing the event `Redact and Seal Transcript/Digital Recording`. Redaction Request to Court Reporter due, but not filed, by 9/7/2023. Redacted Transcript Deadline set for 9/18/2023. Release of Transcript Restriction set for 11/15/2023. (adc) |
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Filing 33
TEXT ORDER: For the reasons set forth on the record on 08/15/23, AMS' Petition to Perpetuate Testimony, D.E. #1 , is GRANTED, subject to the following stipulated conditions. It is ORDERED that parties are to exchange document requests by 08/29/2023, and parties are to respond to the requests by 09/29/23. It is further ORDERED that Grimaldi is to respond to AMS and Ports America's vessel inspection request by 08/18/23, AMS and Ports America are to respond to Grimaldi by 08/22/23, and the parties are to reach a resolution by 08/25/23; the vessel is not to leave the Court's jurisdiction without further notice to the Court. It is further ORDERED that the parties are to complete depositions of the remaining crewmembers in the Courts jurisdiction by 9/15/2023, with the schedule to be determined by the parties' mutual agreement; the remaining crewmembers are not to leave the Court's jurisdiction without further notice to the Court. It is finally ORDERED that Port Authority is to contact counsel for the City of Newark to identify potential parties and determine whether those parties seek to participate in this matter. So Ordered by Judge Evelyn Padin on 8/16/2023. (bt)
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| Filing 31 Letter from The Port Authority of New York and New Jersey Re: Confirmation of Provision of Notice to the City of Newark and Corporation Counsel. (Attachments: #1 Notice to City of Newark, #2 Notice to City of Newark, #3 Notice to Corporation Counsel)(KIM, PAUL) |
| Filing 32 Minute Entry for proceedings held before Judge Evelyn Padin: Preliminary Injunction Hearing held on 8/15/2023. (Court Reporter, Sara Killian (973-776-3885)) (bt) |
| Filing 30 STATUS REPORT by AMERICAN MARITIME SERVICES OF NEW YORK. (KARPOUSIS, JOHN) |
| Filing 29 Letter from Thomas L. Tisdale re: Opposition to Petition. (NAST, TIMOTHY) |
| Pro Hac Vice counsel, THOMAS L. TISDALE, 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. (wh) |
| CLERK'S QUALITY CONTROL MESSAGE - Please be advised that the #23 Request for Electronic Notification of Pro Hac Vice Counsel ROBERT E. O'CONNOR submitted by JOHN LEVY on 8/10/2023 cannot be processed until pro hac counsel has been admitted and the application fee paid. Please review the Electronic Notification for Pro Hac Vice instructions on our website. Counsel is advised to resubmit the Request for Electronic Notification of Pro Hac Vice Counsel once payment has been recorded. This message is for informational purposes only. (wh) |
| Filing 28 Letter from Robert A. Suarez re #12 Order to Show Cause,,. (SUAREZ, ROBERT) |
| Filing 27 Letter from The Port Authority of New York and New Jersey Re: Request to Join Petition as an Interested Party. (KIM, PAUL) |
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Filing 26
TEXT ORDER: The Court has reviewed D.E. #18 . The 08/15/23 hearing, D.E. #12 , will not be rescheduled. So Ordered by Judge Evelyn Padin on 8/10/2023. (akw)
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| Filing 25 NOTICE of Appearance by PAUL MYUNG HAN KIM on behalf of THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY (KIM, PAUL) |
| Filing 24 Notice of Request by Pro Hac Vice Thomas L. Tisdale to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 150 receipt number ANJDC-14517842.) (NAST, TIMOTHY) |
| Filing 23 Notice of Request by Pro Hac Vice Robert E. O'Connor to receive Notices of Electronic Filings. (LEVY, JOHN) |
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Filing 22
ORDER granting #20 Motion for Leave to Appear Pro Hac Vice of THOMAS L. TISDALE. Signed by Magistrate Judge Jose R. Almonte on 8/10/2023. (wh)
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Filing 21
ORDER granting #17 Motion for Leave to Appear Pro Hac Vice of ROBERT E. O'CONNOR. Signed by Magistrate Judge Jose R. Almonte on 8/10/2023. (wh)
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| CLERK'S QUALITY CONTROL MESSAGE - The Declaration of Robert E. O'Connor contained in the #17 MOTION for Leave to Appear Pro Hac Vice submitted by JOHN LEVY on 8/09/2023 contains an improper signature. Only Registered Users are permitted to sign electronically filed documents with an s/. This document contains an s/ signature for Attorney Robert E. O'Connor, now admitted Pro Hac Vice. Please be advised going forward that documents signed by a Pro Hac Vice Attorney would need to be submitted with a wet/scanned signature. (wh) |
| Filing 20 MOTION for Leave to Appear Pro Hac Vice by Benito LaFauci, Alessandro Moretti. (Attachments: #1 Declaration of Timothy J. Nast, #2 Declaration of Thomas L. Tisdale)(NAST, TIMOTHY) |
| Filing 19 NOTICE of Appearance by TIMOTHY JAMES NAST on behalf of Alessandro Moretti, Benito LaFauci (NAST, TIMOTHY) |
| Filing 18 Letter from John J. Levy, Esq. to the Hon. Evelyn Padin, U.S.D.J.. (LEVY, JOHN) |
| Filing 17 MOTION for Leave to Appear Pro Hac Vice of Robert E. O'Connor, Esq. by GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO. (Attachments: #1 Certification of John J. Levy, Esq. in Support, #2 Declaration of Robert E. O'Connor, Esq. in Support, #3 Text of Proposed Order)(LEVY, JOHN) |
| Filing 16 RESPONSE re #12 Order to Show Cause,, #1 Application/Petition,,. (Attachments: #1 Declaration of Timothy Semenoro, Esq., #2 Exhibit 1 to Semenoro Declaration, #3 Exhibit 2 to Semenoro Declaration, #4 Exhibit 3 to Semenoro Declaration, #5 Exhibit 4 to Semenoro Declaration, #6 Exhibit 5 to Semenoro Declaration, #7 Exhibit 6 to Semenoro Declaration, #8 Exhibit 7 to Semenoro Declaration, #9 Exhibit 8 to Semenoro Declaration, #10 Exhibit 9 to Semenoro Declaration, #11 Exhibit 10 to Semenoro Declaration, #12 Exhibit 11 to Semenoro Declaration, #13 Exhibit 12 to Semenoro Declaration, #14 Exhibit 13 to Semenoro Declaration, #15 Exhibit 14 to Semenoro Declaration, #16 Exhibit 15 to Semenoro Declaration, #17 Exhibit 16 to Semenoro Declaration, #18 Exhibit 17 to Semenoro Declaration, #19 Exhibit 18 to Semenoro Declaration, #20 Exhibit 19 to Semenoro Declaration, #21 Declaration of Nicholo Rae Lequigan, #22 Declaration of Abelardo Pua, #23 Declaration of Alessandro Moretti, #24 Declaration of Renato Madapat, #25 Declaration of Benito La Fauci, #26 Declaration of Giuliano Petrellese)(LEVY, JOHN) |
| Filing 15 NOTICE of Appearance by TIMOTHY SEMENORO on behalf of GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO (SEMENORO, TIMOTHY) |
| Filing 14 CERTIFICATE OF SERVICE by AMERICAN MARITIME SERVICES OF NEW YORK re #12 Order to Show Cause,, Certificate of Service of Order to Show Cause by AMS on Grimaldi and Ports America (Attachments: #1 Exhibit Ex. A - Electronic Mail Service of Order to Show Cause on Counsel for Vessel and Owner, #2 Exhibit Ex. B - Electronic Mail Service of Order to Show Cause on Counsel for Ports America)(PALLAY, MATTHEW) |
| Filing 13 NOTICE of Appearance by JOHN J. LEVY on behalf of GRIMALDI DEEP SEA S.P.A., M/V COSTA GRANDE D'AVORIO (LEVY, JOHN) |
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Filing 12
ORDER TO SHOW CAUSE: Counsel for the Vessel and Owner shall appear before the Court on 8/15/2023 at 1:00 PM in Judge Padin's courtroom Courtroom 4C. A copy of this order, together with the papers upon which it is granted, shall be served via mail or electronic means upon counsel for the Vessel and Vessel Owner and Ports America within 1 day of the entry of this Order and proof of service filed forthwith. Counsel for Ports America shall appear before the Court on 8/15/2023 at 1:00 PM. Briefing and opposition to the AMS Petition shall be filed no later than 10:00 AM, 8/11/2023. Signed by Judge Evelyn Padin on 8/7/2023. (wh)
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| Filing 11 CERTIFICATE OF SERVICE by AMERICAN MARITIME SERVICES OF NEW YORK (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F)(HONEA, JOHN) |
| Filing 10 NOTICE of Appearance by GINO A. ZONGHETTI on behalf of PORTS AMERICA (ZONGHETTI, GINO) |
| Filing 9 NOTICE of Appearance by ROBERT ANTHONY SUAREZ on behalf of PORTS AMERICA (SUAREZ, ROBERT) |
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Filing 8
TEXT ORDER: It is ORDERED that Petitioner shall serve Respondents the Order to Show Cause, D.E. #1 , and accompanying attachments via email and same day courier by 8/3/2023, and file proof of service forthwith. Upon filing proof of service, the Court will consider the Order to Show Cause. So Ordered by Judge Evelyn Padin on 8/2/2023. (bt)
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| Filing 7 Exhibit to QC - Civil Cover Sheet JS44,, #1 Application/Petition,, by AMERICAN MARITIME SERVICES OF NEW YORK. (HONEA, JOHN) |
| Filing 6 Corporate Disclosure Statement by AMERICAN MARITIME SERVICES OF NEW YORK. (HONEA, JOHN) Modified on 8/2/2023 (wh). |
| Filing 5 Clerk's Letter: Complaint not accompanied by the filing fee or application to proceed in forma pauperis. (wh) |
| Case assigned to Judge Evelyn Padin and Magistrate Judge Jose R. Almonte. (jr) |
| CLERK'S QUALITY CONTROL MESSAGE - Please be advised, pursuant to Fed. R. Civ. P. 7.1, a disclosure statement is required to be filed by a nongovernmental corporate party or intervenor. Please refer to the Court's website at #www.njd.uscourts.gov for a form and filing instructions. (wh) |
| CLERK'S QUALITY CONTROL MESSAGE - The case you electronically filed did not include a Civil Cover Sheet (JS-44), which is required to be submitted along with the initial pleading, as indicated in the Attorney Case Opening Guide. Please complete and file a #Civil Cover Sheet using the event Exhibit (to Document) found under Civil/Other Filings/Other Documents. Please refer to the Attorney Case Opening Guide for processing electronically filed cases. (wh) |
| Filing fee: $ 402, receipt number NEW48766 (jr) |
| Filing 4 NOTICE of Appearance by JOHN TANNER HONEA on behalf of AMERICAN MARITIME SERVICES OF NEW YORK INC. (HONEA, JOHN) |
| Filing 3 NOTICE of Appearance by MATTHEW JASON PALLAY on behalf of AMERICAN MARITIME SERVICES OF NEW YORK INC. (PALLAY, MATTHEW) |
| Filing 2 NOTICE of Appearance by JOHN F. KARPOUSIS on behalf of AMERICAN MARITIME SERVICES OF NEW YORK INC. (KARPOUSIS, JOHN) |
| Filing 1 APPLICATION/PETITION for Perpetuating Testimony Pursuant to Fed. R. Civ. P. 27 for by AMERICAN MARITIME SERVICES OF NEW YORK INC.. (Attachments: #1 Declaration of John F. Karpousis, #2 Exhibit Ex. 1, Litigation Hold and Demand Production, #3 Exhibit Ex. 2, Demand for Production, #4 Exhibit Ex. 3, Owner's Refusal to Produce, #5 Exhibit Ex. 4, AMS's Requests for Documents, #6 Exhibit Ex. 5, Vessel Overseas Repairs, #7 Exhibit Ex. 6, Ongoing Alterations to Vessel, #8 Declaration Deegan, #9 Declaration Dolente, #10 Declaration Goodman, #11 Text of Proposed Order)(KARPOUSIS, JOHN) Modified on 8/2/2023 (wh). |
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