Da Silva Moore v. Publicis Groupe et al
| Monique Da Silva Moore, Maryellen O'Donohue, Laurie Mayers, Heather Pierce, Katherine Wilkinson, Zaneta Hubbard, Kelly O'Brien McKenna, Ellyn Caravetta, Stephanie Rachel Andrzejewski, Wendy Raenae Clark, Holly Marie Richmond, Amanda B. Rosen, Robyn Faye Leventhal, Diana Robin Scott, JoEllen Zumberge, Maryanne Caruso, Lori Laurent Smith, Erica Beth Bersin, Erin Stephanie Libit, Krista Rochelle Webster, Michelle Dianne Overall, Sheila Gruber McLean, Larissa Severenko Surchin, Melanie Lynn Babcock, Margy Lucas Meislin, Megan Kern Jordan, Erin Michelle Ortiz, Emily Jane Buchanan, Nyree Dawn Wright, Laura Ann Hall and Nancy J. Brenner |
| Publicis Groupe SA and MSLGroup |
| 1:2011cv01279 |
| February 24, 2011 |
| U.S. District Court for the Southern District of New York |
| Foley Square Office |
| Essex |
| Andrew L Carter |
| Andrew J Peck |
| Civil Rights: Jobs |
| 42 U.S.C. § 2000 |
| Plaintiff |
Docket Report
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This docket was last retrieved on October 30, 2013. A more recent docket listing may be available from PACER.
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Filing 277
AFFIDAVIT of Jeremy Pilaar in Opposition re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 276
DECLARATION of MaryEllen O'Donohue in Opposition re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 275
DECLARATION of Monique da Silva Moore in Opposition re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 274
RULE 56.1 STATEMENT. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 273
MEMORANDUM OF LAW in Opposition re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 272
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Paul C. Evans dated 8/10/2012 re: I write in response to Plaintiffs' August 9, 2012 letter, in which Plaintiffs request an additional ten pages for their response to Publicis Motion for Summary Judgment for Lack of Personal Jurisdiction. Publicis does not oppose Plaintiffs' request provided that it is granted an additional ten pages for its reply in support of its Motion for Summary Judgment.ENDORSEMENT: Plaintiff and Publicis are each allowed 10 extra pages. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 8/13/2012) (ama)
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Filing 271
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a MOTIONS proceeding held on 7/11/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 270
TRANSCRIPT of Proceedings re: MOTIONS held on 7/11/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Jerry Harrison, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/4/2012. Redacted Transcript Deadline set for 9/13/2012. Release of Transcript Restriction set for 11/13/2012.(McGuirk, Kelly)
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Filing 269
ORDER: Defendant MSL should immediately provide Plaintiffs with the names and contact information of the five female Managing Directors. So Ordered (Signed by Judge Andrew L. Carter, Jr on 8/7/2012) (js)
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Filing 268
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERNCE proceeding held on 7/20/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 267
TRANSCRIPT of Proceedings re: CONFERNCE held on 7/20/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Martha Drevis, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/30/2012. Redacted Transcript Deadline set for 9/10/2012. Release of Transcript Restriction set for 11/8/2012.(McGuirk, Kelly)
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***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney Jeremy Heisler for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document 285 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (djc)
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Filing 285
SECOND AMENDED CLASS AND COLLECTIVE ACTION COMPLAINT amending 257 Amended Complaint against MSLGroup, Publicis Groupe SA with JURY DEMAND.Document filed by Katherine Wilkinson, Heather Pierce, Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Zaneta Hubbard. Related document: 257 Amended Complaint filed by Laurie Mayers, Katherine Wilkinson, Maryellen O'Donohue, Heather Pierce, Zaneta Hubbard, Monique Da Silva Moore.(djc) Modified on 8/17/2012 (djc). (Redacted)
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Filing 266
ORDER: Defendant MSL should immediately provide Plaintiffs with a complete class list, including employees who signed severance agreements. The Court reserves the question of the exclusion of these employees from the collective action for a subsequent date. (Signed by Judge Andrew L. Carter, Jr on 8/2/2012) (lmb)
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Filing 265
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Siham Nurhussein dated 7/30/2012 re: Plaintiff's request permission to re-file the Second Amended Complaint, which was filed with the Court on July 9, 2012. ENDORSEMENT: So Ordered. (Signed by Judge Andrew L. Carter, Jr on 8/1/2012) (laq)
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Filing 262
ORDER: Before the Court are the status reports dated July 25, 2012 from Plaintiffs and Defendants regarding the form of notice to be mailed to the putative members of the collective action. First, Plaintiffs may not include language directing putative members of the collective action to their website. The following part of Section IV must be stricken in its entirety from the notice: "YOU MAY ALSO OBTAIN A COPY OF THE CONSENT TO JOIN FORM ON PLAINTIFFS COUNSEL'S WEBSITE AT http://www.swhlegal.com/cases/item.html?item id=64034." Second, Plaintiffs must remove the e-mail address "publicis- classaction@swhlegal.com" as their contact information on the notice. The Court accepts Plaintiffs' originally proposed email address "jwipper@swhlegal.com." In the alternative, Plaintiffs recently proposed e-mail address "msl-collectiveaction@swhlegal.com" is allowed upon Defendants' consent. Third, Defendant MSL should provide Plaintiffs with a class list by August 1, 2012, including employee name, dates of employment, positions held, business unit, and contact information. (Signed by Judge Andrew L. Carter, Jr on 7/26/2012) (lmb)
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Filing 261
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERNCE proceeding held on 7/9/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 260
TRANSCRIPT of Proceedings re: CONFERNCE held on 7/9/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Thomas Murray, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/20/2012. Redacted Transcript Deadline set for 8/30/2012. Release of Transcript Restriction set for 10/29/2012.(McGuirk, Kelly)
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Filing 259
NOTICE OF CHANGE OF ADDRESS by Siham Nurhussein on behalf of All Plaintiffs. New Address: Sanford Wittels & Heisler, LLP, 1350 Avenue of the Americas, 31st Floor, New York, NY, USA 10019, 6464025650. (Nurhussein, Siham)
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MEDIATOR SESSION NOT HELD Mediator Session scheduled for 07/19/2012 at 233 Boadway was NOT held.(ms)
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Minute Entry: for proceedings held before Judge Andrew L. Carter, Jr: Status Conference held on 7/20/2012. Steven Wittels, Jeremy Heisler and Siham Nurhussein for Plaintiffs. Paul Evans for Defendant Publicis. Jeffrey Brecher for Defendant MSL Group. The Court ruled on the proposed correctionnotices submitted by both parties, see transcript for complete details. The parties should file a joint status report on 7/25/12 re: the sending of a notice to current and former MSLGroup employees. Court Reporter: Martha Drevis. (djc)
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Filing 258
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck, from Paul C. Evans, dated 7/19/2012, re: the parties jointly request a one-day extension of the jurisdictional discovery deadlines set during the July 9 status conference. The proposed discovery and briefing schedule for jurisdictional discovery would now include the following deadlines: Jurisdictional Discovery Deadline: July 31, 2012; Plaintiff's Opposition due August 14, 2012; and Publicis' Reply due August 21, 2012. ENDORSEMENT: Approved. It is nice to see the parties agree on something (even if it is minor) - perhaps you can keep working on cooperation in other areas. ( Discovery due by 7/31/2012. Responses due by 8/14/2012. Replies due by 8/21/2012.) (Signed by Magistrate Judge Andrew J. Peck on 7/19/2012) Copies Sent By Chambers. (ja)
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Filing 256
MEMORANDUM OF LAW in Opposition re: #251 Objection (non-motion), Objection (non-motion). Document filed by MSLGroup. (Brecher, Jeffrey)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Jeffrey W. Brecher to RE-FILE Document #255 Opposition Brief. Use the event type Memorandum of Law in Opposition(non-motion) found under the event list Other Answers. (ka)
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Filing 255
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - OPPOSITION BRIEF re: #251 Objection (non-motion), Objection (non-motion). Document filed by MSLGroup.(Brecher, Jeffrey) Modified on 7/16/2012 (ka).
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Filing 254
NOTICE of Filing of Consent to Join Forms. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Status Conference held on 7/11/2012. Steven Wittels and Siham Nurhussein for Plaintiff(s). Paul Evans for Defendant Publicis Groupe. Jeffrey Brecher and Victoria Chavey for Defendant MSL Group. Plaintiff(s)'objections to Judge Peck's 5/7/12 and 5/14/12 rulings are overruled. Defendant to provide the email to Plaintiff's by 7/13/12. Plaintiffs' to submit its proposed correction notice to theDefendants' and Court on 7/16/12. Defendants' response due 7/18/12. These submissions are limited to 5 pages. Joint Status Report re: privilege issue due 7/19/12. Status Conference scheduled for 7/20/12 at 10:00 a.m. Court Reporter: Jerry Harrison. ( Status Conference set for 7/20/2012 at 10:00 AM before Judge Andrew L. Carter Jr.). (lmb)
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Filing 257
SECOND AMENDED CLASS AND COLLECTIVE ACTION COMPLAINT against MSLGroup, Publicis Groupe SA with JURY DEMAND.Document filed by Katherine Wilkinson, Heather Pierce, Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Zaneta Hubbard.(djc)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 7/9/2012. Issues re jurisdictional discovery resolved - see transcript. Juris. Discovery cutoff no later than 7/30/2012. Plaintiff's Responses to motion due by 8/13/2012 or sooner. (rjm) Modified on 7/17/2012 (rjm).
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Filing 253
ORDER. Publicis is to bring the documents on its privilege log and on its "redaction" log to the July 9, 2012 conference. Counsel are to agree on "representative" documents from the privilege log for the Court's review (with the Court's rulings presumptively applying to the similar documents on the privilege log). (Signed by Magistrate Judge Andrew J. Peck on 7/3/2012); Copies by ECF to: All Counsel, Judge Andrew L. Carter, Jr. (bw)
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Filing 252
DECLARATION of Janette Wipper re: #251 Objection (non-motion), Objection (non-motion) Plaintiffs' Rule 72(a) Objection to the Magistrate's June 15, 2012 Opinion and Order. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit Exhibit 1-5, #2 Exhibit Exhibit 6-10, #3 Exhibit Exhibit 11-15, #4 Exhibit Exhibit 16-18, #5 Exhibit Exhibit 19-20, #6 Exhibit Exhibits 21-24, #7 Exhibit Exhibit 25)(Wipper, Janette)
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Filing 251
Objection Plaintiffs' Rule 72(a) Objection to the Magistrate's June 15, 2012 Opinion and Order. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wipper, Janette)
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Filing 250
ORDER granting 111 Motion to Certify Class; granting 111 Motion to Authorize The motion for conditional certification and authorization of notice; granting #133 Motion to Certify Class; granting #154 Motion for Leave to File Document. CONCLUSION: For the reasons set forth above, Plaintiffs' motion to amend the first amended complaint (docket no. 154) is granted, but Plaintiffs are cautioned against amending the complaint again. Plaintiffs should file their second amended complaint consistent with this order no later than July 9,2012. The motion for conditional certification and authorization of notice (docket nos. 111, 133) is granted.(Signed by Judge Andrew L. Carter, Jr on 6/28/2012) (ama)
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Filing 249
ORDER: Upon consideration of Plaintiffs' request for an extension of time to file their Opposition to Defendant Publicis' Motion for Summary Judgment Based on Lack of Personal Jurisdiction, it is so ORDERED:1. Plaintiffs' Opposition will be due two weeks after Defendants have produced all outstanding jurisdictional discovery. 2. Defendant Publicis' Reply shall be due seven days after Plaintiffs file their Opposition. GRANTED. (Signed by Judge Andrew L. Carter, Jr on 6/29/2012) (ama)
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Filing 248
ENDORSED LETTER addressed to Judge Andrew L. Carter from Steven L. Wittels dated 6/28/2012 re: Plaintiffs respectfully request an additional ten pages for their Rule 72( a) Objection to Magistrate Judge Peck's June 15,2012 Rulings, due tomorrow, June 29, 2012. ENDORSEMENT: Application Granted. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 6/29/2012) (ama)
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Filing 247
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 6/5/2012 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 246
TRANSCRIPT of Proceedings re: Conference held on 6/5/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Khristine Sellin, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 7/23/2012. Redacted Transcript Deadline set for 8/2/2012. Release of Transcript Restriction set for 10/1/2012.(McGuirk, Kelly)
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Set/Reset Deadlines: Amended Pleadings due by 7/9/2012. (ama)
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Filing 245
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Siham Nurhussein dated 6/25/2012 re: Due to scheduling conflicts, Plaintiffs write with the consent of all parties to respectfully request the short adjournment of the discovery conference currently scheduled for Friday, July 6th at 2:00 p.m. to Monday, July 9th or another later date that is convenient to the Court. ENDORSEMENT: The Friday, July 6th discovery conference is adjourned to Monday, July 9th at 3:30 p.m.in Courtroom 20D. ( Status Conference set for 7/9/2012 at 03:30 PM in Courtroom 20D, 500 Pearl Street, New York, NY 10007 before Judge Andrew L. Carter Jr.) (Signed by Magistrate Judge Andrew J. Peck on 6/26/2012) (djc)
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Filing 244
DECLARATION of Siham Nurhussein in Support re: #214 Objection (non-motion). Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit G, #2 Exhibit I, #3 Exhibit J, #4 Exhibit K, #5 Exhibit N, #6 Exhibit O)(Wittels, Steven)
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Filing 243
Objection re: #207 Objection (non-motion) Rule 72(a) to the Magistrate's May 7, 2012 Discovery Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit B)(Wittels, Steven)
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Filing 242
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Siham Nurhussein dated 6/22/2012 re: Counsel for the plaintiffs request permission to temporarily file certain documents under seal in connection with their Opposition to Publicis Groupe SA's Motion for Summary Judgment for Lack of Personal Jurisdiction due July 2, 2012. ENDORSEMENT: Granted, but the parties should submit a joint letter by 6/28 informing the Court whether all parties agree that the documents should be sealed the parties should be mindful of the Court's previous ruling regarding sealing. So Ordered. (Signed by Judge Andrew L. Carter, Jr on 6/25/2012) (ft)
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Filing 241
DECLARATION of Victoria woodin Chavey, Esq. in Opposition re: 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by MSLGroup. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Brecher, Jeffrey)
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Filing 240
MEMO ENDORSEMENT on JOINT STATUS REPORT. ENDORSEMENT: Exhibit I should be unsealed. Re: #227 Status Report filed by MSLGroup. (Signed by Judge Andrew L. Carter, Jr on 6/21/2012) (rjm)
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Transmission to Sealed Records Clerk. Transmitted re: #240 Memo Endorsement to the Sealed Records Clerk for the sealing or unsealing of document or case. (rjm)
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Filing 239
ORDER: The Court is in receipt of plaintiffs' June 15, 2012 letter re alleged deficiencies in Publicis' jurisdictional discovery. The Court notes that the letter was sent on June 15 (and received by the Court on June 18), while Publicis' motion for summary judgment on lack of jurisdiction was filed on June 18, 2012. Publicis' motion papers may (or may not) moot some of plaintiffs' issues. Publicis is to discuss the issues with plaintiffs (on a quick review of plaintiffs' letter, some of their concerns seem warranted while others do not; the parties should consider the difference between requesting "all documents" and "documents sufficient to show") and respond to the Court by June 25, 2012 as to what has been agreed with plaintiffs and what issues remain for judicial resolution. Any "reply" letter by plaintiffs is due June 28, 2012. The Court will hold a conference on these issues on July 6, 2012 at 2:00 p.m. Plaintiffs' opposition briefs remain due July 2, 2012 and Publicis' reply papers July 9, 2012. The fact that the parties left the jurisdictional discovery to the last minute should not be allowed to extend the briefing schedule. The Court will allow both sides to submit short supplemental papers after the additional discovery. The Court also takes this opportunity to remind the parties of the Sedona Conference Cooperation Proclamation, and the Court hopes that the parties will start to show more of that cooperative spirit. (Signed by Magistrate Judge Andrew J. Peck on 6/20/2012) (jfe)
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CASHIERS OFFICE REMARK on #223 Motion to Appear Pro Hac Vice in the amount of $200.00, paid on 06/05/2012, Receipt Number 1040151. (jd)
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Set/Reset Deadlines as to #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction..( Responses due by 7/2/2012, Replies due by 7/9/2012.), Set/Reset Hearings:( Status Conference set for 7/6/2012 at 02:00 PM before Magistrate Judge Andrew J. Peck.) (jfe)
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Filing 238
DECLARATION of Peter Miller in Support re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Publicis Groupe SA. (Evans, Paul)
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Filing 237
DECLARATION of Jean-Michel Etienne in Support re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Publicis Groupe SA. (Evans, Paul)
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Filing 236
DECLARATION of Paul C. Evans in Support re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Publicis Groupe SA. (Attachments: #1 Exhibit 1 - Deposition of J.M. Etienne, #2 Exhibit 2 - Interrogatory Responses, #3 Exhibit 3 - RFA Responses, #4 Exhibit 4 - Structure Chart, #5 Exhibit 5 - Excerpts from Janus Book)(Evans, Paul)
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Filing 235
RULE 56.1 STATEMENT. Document filed by Publicis Groupe SA. (Evans, Paul)
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Filing 234
MEMORANDUM OF LAW in Support re: #233 MOTION for Summary Judgment for Lack of Personal Jurisdiction.. Document filed by Publicis Groupe SA. (Evans, Paul)
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Filing 233
MOTION for Summary Judgment for Lack of Personal Jurisdiction. Document filed by Publicis Groupe SA.(Evans, Paul)
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Filing 264
INTERNET CITATION NOTE: Material from decision with Internet citation re: #229 Memorandum & Opinion. (Attachments: #1 legaltech part 2, #2 LegalTech New York 2012 - the most important legal technology event of the, #3 legaltech2011showguide-dl_opened_Part1, #4 legaltech2011showguide-dl_opened_Part2, #5 legaltech2011showguide-dl_opened_Part3, #6 legaltech2011showguide-dl_opened_Part4, #7 LegalTechNY2013prospectus1, #8 The Three Judges Holiday Show_ Perspectives on Machine Assisted Review_ESI, #9 Vol02A-Ch02, #10 Legal Tech CLE FAQ) (tro)
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Filing 263
INTERNET CITATION NOTE: Material from decision with Internet citation re: #229 Memorandum & Opinion. (Attachments: #1 part 2, #2 part 3) (tro)
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Filing 232
DECLARATION of Paul C. Evans re: #231 Opposition Brief. Document filed by Publicis Groupe SA. (Attachments: #1 Exhibit 1 - Supp. Response to Pls.' First Set of Doc. Demands, #2 Exhibit 2 - Excerpts from May 14, 2012 Hearing, #3 Exhibit 3 - Excerpts from Deposition of J.M. Etienne)(Evans, Paul)
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Filing 231
OPPOSITION BRIEF re: #214 Objection (non-motion). Document filed by Publicis Groupe SA.(Evans, Paul)
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Filing 230
OPPOSITION BRIEF re: #214 Objection (non-motion). Document filed by MSLGroup.(Brecher, Jeffrey)
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Filing 229
OPINION AND ORDER # 101968 re: #169 MOTION for Recusal filed by Laurie Mayers, Katherine Wilkinson, Maryellen O'Donohue, Heather Pierce, Zaneta Hubbard, Monique Da Silva Moore. For the reasons discussed above, plaintiffs' recusal motion (Dkt. No. 169) is DENIED as untimely and in any event as without merit. (Signed by Magistrate Judge Andrew J. Peck on 6/15/2012) Copies by ECF. (mro) (Main Document 229 replaced on 6/15/2012) (mro). Modified on 6/21/2012 (ft).
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Filing 228
NOTICE OF COURT CONFERENCE: A STATUS CONFERENCE is scheduled for July 11,2012 at 3:30 p.m. in Courtroom 14A located on the 14th Floor at 500 Pearl Street, New York, New York. Status Conference set for 7/11/2012 at 03:30 PM in Courtroom 14A, 500 Pearl Street, New York, NY 10007 before Judge Andrew L. Carter Jr.. (ama)
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Filing 227
STATUS REPORT. Joint Status Report Document filed by MSLGroup.(Brecher, Jeffrey)
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Filing 226
ORDER FOR ADMISSION PRO HAC VICE ON WRITTEN MOTION. The motion of Krissy A. Katzenstein (Dkt. No. 223) for admission to practice pro hac vice as counsel for Defendant Publicis Groupe SA in the above-captioned action in the United States District Court for the Southern District of New York is granted. Applicant to pay fee to Clerk of Court. (Signed by Magistrate Judge Andrew J. Peck on 6/11/2012) (bw)
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Filing 225
DECLARATION of Siham Nurhussein in Support re: #133 MOTION to Certify Class and Authorize Notice.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R)(Nurhussein, Siham)
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Filing 224
MEMORANDUM OF LAW in Support re: #133 MOTION to Certify Class and Authorize Notice.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Status Conference held on 6/5/2012. Steven Wittels and Deepika Bains for Plaintiff(s). Krissy A. Katzenstein for Defendant Publicis Groupe. Jeffrey Brecher and Victoria Chavey for Defendant MSL Group. Motion to file documents under seal (docket no. 184) denied in part consistent with the rulings made during the hearing. The parties should contact the ECF office and file the appropriate unredacted copies. For further disputes concerning documents placed under seal, the parties are directed to confer before bringing a motion to file under seal and to be mindful of today's rulings. The parties should file a joint status report on June 12 about the documents placed under seal referenced in Plaintiffs' objections to the May 7 and 14 discovery rulings. Plaintiffs' motion to withdraw objections to Judge Peck's April 25, 2012 rulings (docket no. 200) is granted and MSLGroup's request to file supplemental briefing (docket no. 206) is denied. The Court anticipates ruling on Plaintiffs' motions to amend the complaint and for conditional certification by the end of the month. Motion(s) terminated: #200 MOTION to Withdraw #190 Objection (non-motion) to Judge Peck's April 25, 2012 Discovery Rulings. MOTION to Withdraw #190 Objection (non-motion) to Judge Peck's April 25, 2012 Discovery Rulings. filed by Laurie Mayers, Katherine Wilkinson, Maryellen O'Donohue, Heather Pierce, Zaneta Hubbard, Monique Da Silva Moore, #184 MOTION for Discovery. MOTION for Protective Order. filed by MSLGroup. (jfe)
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Filing 223
MOTION for Krissy A. Katzenstein to Appear Pro Hac Vice. Document filed by Publicis Groupe SA.(pgu) (pgu).
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Filing 222
OPPOSITION BRIEF re: #207 Objection (non-motion). Document filed by MSLGroup.(Brecher, Jeffrey)
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Filing 221
NOTICE OF COURT CONFERENCE: The STATUS CONFERENCE scheduled for June 4, 2012 is adjourned to June 5, 2012 at 2:30 p.m. in Courtroom 14A located on the 14th Floor at 500 Pearl Street, New York, New York. Counsel for all parties are directed to appear for the conference in person and report to the Courtroom upon arrival to the Courthouse. ( Status Conference set for 6/5/2012 at 02:30 PM in Courtroom 14A, 500 Pearl Street, New York, NY 10007 before Judge Andrew L. Carter Jr..) (Signed by Judge Andrew L. Carter, Jr on 6/1/2012) (jfe)
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Filing 218
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Siham Nurhussein dated 5/29/2012 re: Plaintiffs respectfully request permission to temporarily file certain documents under seal in connection with their Rule 72(a) Objection to Magistrate Judge Peck's May 14, 2012 Discovery Rulings Regarding Personal Jurisdiction (due today). ENDORSEMENT: Request to file under seal temporarily granted. (Signed by Judge Andrew L. Carter, Jr on 5/29/2012) (jfe)
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Filing 216
SCHEDULING ORDER: The Court will conduct a conference on Monday, June 4 at 9:30 a.m. in courtroom 14A for the limited purposes of discussing the recent motions to file documents under seal and future sealing motions. Status Conference set for 6/4/2012 at 09:30 AM in Courtroom 14A, 500 Pearl Street, New York, NY 10007 before Judge Andrew L. Carter Jr.. (Signed by Judge Andrew L. Carter, Jr on 5/29/2012) (jfe)
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Transmission to Sealed Records Clerk. Transmitted re: #218 Endorsed Letter to the Sealed Records Clerk for the sealing or unsealing of document or case. (jfe)
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Filing 220
DECLARATION of Siham Nurhussein in Support re: 219 Objection. Document filed by Monique Da Silva Moore, Maryellen O'Donohue. (cd)
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Filing 219
Objection re: #196 Order. Document filed by Monique Da Silva Moore, Maryellen O'Donohue et al. (cd)
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Filing 217
SEALED DOCUMENT placed in vault.(nm)
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Filing 215
DECLARATION of Siham Nurhussein re: #214 Objection (non-motion). Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A-C, #2 Exhibit D-H, #3 Exhibit I-K, #4 Exhibit L-O)(Nurhussein, Siham)
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Filing 214
Objection Rule 72(a) to Judge Peck's 5-14-12 Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 213
DECLARATION of Jeffrey W. Brecher in Support re: #184 MOTION for Discovery. MOTION for Protective Order.. Document filed by MSLGroup. (Attachments: #1 Exhibit)(Brecher, Jeffrey)
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Filing 212
REPLY MEMORANDUM OF LAW in Support re: #184 MOTION for Discovery. MOTION for Protective Order.. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 211
Objection re: #206 Notice (Other). Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 210
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/9/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 209
TRANSCRIPT of Proceedings re: conference held on 3/9/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Sonya Ketter Huggins, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 6/15/2012. Redacted Transcript Deadline set for 6/25/2012. Release of Transcript Restriction set for 8/23/2012.(McGuirk, Kelly)
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Filing 208
DECLARATION of Siham Nurhussein in Support re: #207 Objection (non-motion). Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Wittels, Steven)
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Filing 207
Objection Rule 72(a) to the Magistrate's May 7, 2012 Discovery Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 206
NOTICE of of Supplemental Authority in Opposition to Plaintiffs' Motion for Conditional Certification re: #122 Memorandum of Law in Opposition to Motion. Document filed by MSLGroup. (Chavey, Victoria)
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Filing 205
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Steven L. Wittels dated 5/16/12 re: Counsel for the plaintiffs seeks the Court's permission to serve five additional document requests for good cause shown on defendant MSLGroup (listed herein). ENDORSEMENT: The Court will allow requests 24 and 25, limited to "policy" type documents, not individual client pitches, and subject to any burden objections. The other requests are denied-the issue is Publicis UK not interaction of Publicis US subsidiaries with MSL. (Signed by Magistrate Judge Andrew J. Peck on 5/18/2012) (mro)
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Filing 204
MEMORANDUM OF LAW in Opposition re: #184 MOTION for Discovery. MOTION for Protective Order.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 203
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERNECE proceeding held on 5/14/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 202
TRANSCRIPT of Proceedings re: CONFERNECE held on 5/14/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Rebecca Forman, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 6/11/2012. Redacted Transcript Deadline set for 6/21/2012. Release of Transcript Restriction set for 8/20/2012.(McGuirk, Kelly)
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Filing 201
MEMORANDUM OF LAW in Support re: #200 MOTION to Withdraw #190 Objection (non-motion) to Judge Peck's April 25, 2012 Discovery Rulings. MOTION to Withdraw #190 Objection (non-motion) to Judge Peck's April 25, 2012 Discovery Rulings.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 200
MOTION to Withdraw #190 Objection (non-motion) to Judge Peck's April 25, 2012 Discovery Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(Nurhussein, Siham)
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Filing 198
MEMO ENDORSEMENT denying #197 Motion to File Amicus Brief: An alleged amicus brief that is paid for by plaintiffs is hardly necessary or appropriate. The Motion is DENIED. (Signed by Magistrate Judge Andrew J. Peck on 5/14/2012) Copies Faxed By Chambers. (lmb)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 5/14/2012. Discovery disputes re Publicis jurisdictional discovery resolved-see transcript. On reconsideration, AJP stays MSL ESI discovery, because prejudice to defendant, until Judge Carter rules on pending plaintiffs motions for collective action and to amend complaint. Discovery unrelated to MSL ESI production, e.g., non-party discovery, can go forward. Parties to contact if disputes. (mro)
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Filing 197
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to File Amicus Brief in Support of Plaintiffs' Motion for Recusal. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit Brief Amicus Curiae In Support of Plaintiffs' Motion For Recusal)(Wittels, Steven) Modified on 5/15/2012 (db).
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Filing 196
ORDER: On reconsideration, for the reasons stated at today's conference (see transcript), the Court has granted plaintiffs' request to stay MSL's production of ESI, pending Judge Carter's decision on plaintiffs' motions for collective action certification and to amend their complaint. Defendants have consented to the stay. Jurisdictional discovery regarding Publicis, and discovery between plaintiff and MSL unrelated to MSL's ESI production, are not stayed. Plaintiffs' May 9, 2012 objections to my prior denial of the stay (Dkt. No. 190) are moot. (Signed by Magistrate Judge Andrew J. Peck on 5/14/2012) Copies by ECF.(mro)
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Filing 195
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 5/7/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 194
TRANSCRIPT of Proceedings re: CONFERNCE held on 5/7/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Tara Jones, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 6/7/2012. Redacted Transcript Deadline set for 6/18/2012. Release of Transcript Restriction set for 8/16/2012.(McGuirk, Kelly)
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Filing 193
DECLARATION of Steven L. Wittels in Support re: #169 MOTION for Recusal.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit DD-MM, #2 Exhibit NN-PP)(Wittels, Steven)
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Filing 192
REPLY MEMORANDUM OF LAW in Support re: #169 MOTION for Recusal.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 191
DECLARATION of Siham Nurhussein in Support re: #190 Objection (non-motion). Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A-G)(Nurhussein, Siham)
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Filing 190
Objection Rule 72a to Judge Peck's 4-25-12 Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 189
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 4/25/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 188
TRANSCRIPT of Proceedings re: CONFERNCE held on 4/25/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Karen Gorlaski, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 6/4/2012. Redacted Transcript Deadline set for 6/14/2012. Release of Transcript Restriction set for 8/10/2012.(McGuirk, Kelly)
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Filing 187
NOTICE of Joining MSLGroup's Motion to Retain Documents under Seal. Document filed by Publicis Groupe SA. (Evans, Paul)
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Filing 186
MEMORANDUM OF LAW in Support re: #184 MOTION for Discovery. MOTION for Protective Order.. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 185
DECLARATION of Jeffrey W. Brecher in Support re: #184 MOTION for Discovery. MOTION for Protective Order.. Document filed by MSLGroup. (Attachments: #1 Exhibit)(Brecher, Jeffrey)
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Filing 184
MOTION for Discovery., MOTION for Protective Order. Document filed by MSLGroup.(Brecher, Jeffrey)
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Filing 183
NOTICE of Notice of Motion. Document filed by MSLGroup. (Brecher, Jeffrey)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 5/7/2012. (js)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 5/7/2012. Conference continued in afternoon. (lmb)
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Filing 182
ORDER SCHEDULING STATUS CONFERENCE: that a status conference is scheduled for May 14, 2012 at 9:30 a.m. before the undersigned in Courtroom 20D (500 Pearl Street). Please note that this conference is in addition to the conference previously scheduled for Monday, May 7, 2012. ( Status Conference set for 5/14/2012 at 09:30 AM in Courtroom 20D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Andrew J. Peck.) (Signed by Magistrate Judge Andrew J. Peck on 5/4/2012) Copies Sent By Chambers. (pl)
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Filing 181
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 4/25/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 180
TRANSCRIPT of Proceedings re: CONFERNCE held on 4/25/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Karen Gorlaski, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/29/2012. Redacted Transcript Deadline set for 6/7/2012. Release of Transcript Restriction set for 8/3/2012.(McGuirk, Kelly)
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Filing 179
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Victoria Woodin Chavey dated 4/30/12 re: Counsel submits this letter in connection with plaintiffs' letter that was faxed to Your Honor's chambers on 4/27/12.The letter is not an appropriate submission, as it is not permitted by any applicable rule, on that basis MSL requests that the letter be stricken. ENDORSEMENT: Because plaintiffs' letter did not ask for any relief as such, the Court will deal with it at the 5/7 conference, by which point the Court hopes the parties will have met and conferred, and resolved, many of the issues. (Signed by Magistrate Judge Andrew J. Peck on 4/30/2012) (mro) Modified on 5/2/2012 (mro).
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Filing 178
DECLARATION of Brett M. Anders in Opposition re: #169 MOTION for Recusal.. Document filed by MSLGroup. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit)(Brecher, Jeffrey)
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Filing 177
MEMORANDUM OF LAW in Opposition re: #169 MOTION for Recusal.. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 199
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr., from Victoria Woodin Chavey and Paul C. Evans dated 4/17/2012 re: The parties also suggest the following briefing schedule: Defendants to file Motion to Maintain documents Under Sal no later than May 8, 2012; Plaintiffs to file Opposition Brief no later than May 17; and Defendants to file Reply Briefs no later than May 22. ENDORSEMENT: Application approved, subject to the modifications in the briefing schedule. ( Motions due by 5/8/2012, Responses due by 5/17/2012, Replies due by 5/22/2012.) (Signed by Judge Andrew L. Carter, Jr on 4/27/2012) (djc)
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Filing 175
OPINION AND ORDER: #101747 There simply is no review tool that guarantees perfection. The parties and Judge Peck have acknowledged that there are risks inherent in any method of reviewing electronic documents. Manual review with keyword searches is costly, though appropriate in certain situations. However, even if all parties here were willing to entertain the notion of manually reviewing the documents, such review is prone to human error and marred with inconsistencies from the various attorneys determination of whether a document is responsive. Judge Peck concluded that under the circumstances of this particular case, the use of the predictive coding software as specified in the ESI protocol is more appropriate than keyword searching. The Court does not find a basis to hold that his conclusion is clearly erroneous or contrary to law. Thus, Judge Peck's orders are adopted and Plaintiffs' objections are denied. (Signed by Judge Andrew L. Carter, Jr on 4/25/2012) (djc) Modified on 4/26/2012 (djc). Modified on 5/2/2012 (jab).
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 4/25/2012. Discovery issues resolved-see transcript. Status conf set for 5/7/ at 9:30 am. (cd)
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Set/Reset Hearings: Status Conference set for 5/7/2012 at 09:30 AM before Magistrate Judge Andrew J. Peck (cd)
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Filing 174
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Janette Wipper dated 4/20/2012 re: Plaintiffs respectfully request that Your Honor defer ruling on the Rule 72 Objection until a ruling is issued on Plaintiffs' Motion for Recusal or Disqualification of Judge Peck ("Recusal Motion") (Doc. No 170). ENDORSEMENT: Application denied. If the recusal motion is granted, the Court will evaluate the orders that should be vacated. (Signed by Judge Andrew L. Carter, Jr on 4/25/2012) (lmb)
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Filing 173
ENDORSED LETTER addressed to Magistrate Judge Andrew J Peck from Brett M Anders dated 4/18/2012 re: The parties respectfully request that the attached corrected schedule replace the schedule approved by the Court on April 16. ENDORSEMENT: Approved. (Signed by Magistrate Judge Andrew J. Peck on 4/23/2012) Copies Sent By Chambers. (cd)
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***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney Jeremy Heisler for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document #110 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (rjm)
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Filing 176
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Victoria Woodin Chavey dated 4/17/2012 re: This letter is the parties' joint submission, pursuant to your Order dated April 4, 2012. The parties respectfully advise the Court that they have reached some agreement with regard to documents and information that were filed under seal in connection with the Plaintiffs' Motion for Conditional Certification and Motion to File Second Amended Complaint, but disputes remain. The particular documents and information at issue are described generally as follows. ENDORSEMENT: Application Approved, subject to the modifications in the briefing schedule. SO ORDERED., ( Motions due by 5/8/2012., Responses due by 5/17/2012, Replies due by 5/22/2012.) (Signed by Judge Andrew L. Carter, Jr on 4/27/2012) (ama)
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Filing 172
ENDORSED LETTER addressed to Magistrate Judge Andrew J Peck from Brett M Anders dated 4/13/2012 re: Joint request for the listed discovery schedule. ENDORSEMENT: Schedule approved on consent. (Signed by Magistrate Judge Andrew J. Peck on 4/16/2012) (cd)
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Filing 171
DECLARATION of Steven L. Wittels in Support re: #169 MOTION for Recusal.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A-L, #2 Exhibit M-Y, #3 Exhibit AA-CC)(Wittels, Steven)
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Filing 170
MEMORANDUM OF LAW in Support re: #169 MOTION for Recusal.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 169
MOTION for Recusal. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(Wittels, Steven)
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Filing 168
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 4/3/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 167
TRANSCRIPT of Proceedings re: Conference held on 4/3/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Guido Tascione, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/7/2012. Redacted Transcript Deadline set for 5/17/2012. Release of Transcript Restriction set for 7/13/2012.(McGuirk, Kelly)
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Filing 166
DECLARATION of Jennifer McDonough in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 165
DECLARATION of Ellyn Caravetta in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 164
DECLARATION of Christopher Andrew Poterala in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 163
DECLARATION of Stephanie Andrzejewski in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 162
DECLARATION of Paul Wynn in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 161
DECLARATION of Ellyn Caravetta in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 160
DECLARATION of Anna McCollister-Slipp in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 159
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Deepika Bains dated 4/6/2012 re: Pursuant to Your Honor's April 4, 2012 Order, Plaintiffs write to inform the Court that they will not withdraw the six declarations in support of Plaintiffs' Motion for Collective Action Certification previously filed under seal. If the Court requires, Plaintiffs will electronically file the full unredacted versions of the declarations. ENDORSEMENT: Plaintiffs should file the unredacted declaration on ECF. (Signed by Judge Andrew L. Carter, Jr on 4/10/2012) (djc)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Discovery Hearing held on 4/3/2012. Plaintiffs' request to file the six declarations discussed during today's conference under seal is denied. Plaintiffs have until 4/6/12 to inform the Court if they wish to withdraw any of the declarations before the Court unseals the declarations. Plaintiffs and MSLGroup are instructed to discuss and review the remaining documents they have filed under seal. They should submit a joint letter on 4/17/12 informing the Court if they have come to an agreement. If there are disputes, the parties should specify the disputed documents and provide a briefing schedule. Such briefs will be filed in traditional format, not letter format, and should be submitted on ECF. Further, the Court will rule on Plaintiffs' current Rule 72(a) objections without further submissions. (ft)
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Filing 158
ORDER. The Court is in receipt of plaintiffs' March 28, 2012 letter requesting my recusal. Plaintiffs shall advise as to whether they wish to file a formal motion or for the Court to consider the letter as the motion (in which case defendants will have 14 days to respond, from the date of plaintiffs' confirmation that the letter constitutes their motion). The Court notes that my favorable view of computer assisted review technology in general was well known to plaintiffs before I made any ruling in this case, and I have never endorsed Recommind's methodology or technology, nor received any reimbursement from Recommind for appearing at any conference that (apparently) they and other vendors sponsored, such as Legal Tech. I have had no discussions with Mr. Losey about this case, nor was I aware that he is working on the case. It appears that after plaintiffs' counsel and vendor represented to me that they agreed to the use of predictive coding, plaintiffs now claim that my public statements approving generally of computer assisted review make me biased. If plaintiffs were to prevail, it would serve to discourage judges (and for that matter attorneys) from speaking on educational panels about ediscovery (or any other subject for that matter). The Court suspects this will fall on deaf ears, but I strongly suggest that plaintiffs rethink their "scorched earth" approach to this litigation. (Signed by Magistrate Judge Andrew J. Peck on 4/2/2012) Copies Sent By Chambers via ECF. (rjm)
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Filing 157
DECLARATION of Deepika Bains in Support re: #154 MOTION for Leave to File Second Amended Complaint.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Wittels, Steven)
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Filing 156
REPLY MEMORANDUM OF LAW in Support re: #154 MOTION for Leave to File Second Amended Complaint.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven)
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Filing 155
MEMORANDUM OF LAW in Support re: #154 MOTION for Leave to File Second Amended Complaint.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A)(Wittels, Steven)
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Filing 154
MOTION for Leave to File Second Amended Complaint. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(Wittels, Steven)
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Filing 153
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Brett M. Aders dated 3/29/2012 re: counsel for Defendant MSLGROUP Americas, Inc. ("MSL") the parties submit this joint letter supplementing our March 28, 2012 request for an extension of time to complete the review of the seed set of documents pursuant to the ESI Protocol entered by the Court. ENDORSEMENT: Revised schedule approved on consent., ( Request for Production of Documents due by 4/11/2012.) (Signed by Magistrate Judge Andrew J. Peck on 3/30/2012) (pl)
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Filing 152
SEALED DOCUMENT placed in vault.(mps)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Steven Lance Wittels to RE-FILE Document #149 Reply Memorandum of Law in Support of Motion, #151 Declaration in Support of Motion. ERROR(S): Documents linked to filing error. (db)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Steven Lance Wittels to RE-FILE Document #147 MOTION for Leave to File Second Amended Complaint. ERROR(S): Supporting Documents are filed separately, each receiving their own document #. (db)
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Filing 151
FILING ERROR - DEFICIENT DOCKET ENTRY - DECLARATION of Deepika Bains in Support re: #147 MOTION for Leave to File Second Amended Complaint.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Wittels, Steven) Modified on 3/30/2012 (db).
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Filing 150
DECLARATION of Siham Nurhussein in Support re: #133 MOTION to Certify Class and Authorize Notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T)(Bains, Deepika)
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Filing 149
FILING ERROR - DEFICIENT DOCKET ENTRY - REPLY MEMORANDUM OF LAW in Support re: #147 MOTION for Leave to File Second Amended Complaint.. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Wittels, Steven) Modified on 3/30/2012 (db).
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Filing 148
REPLY MEMORANDUM OF LAW in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Bains, Deepika)
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Filing 147
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Leave to File Second Amended Complaint. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A)(Wittels, Steven) Modified on 3/30/2012 (db).
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Filing 146
DECLARATION of Declarant 4 in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 145
DECLARATION of Declarant 3 in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 144
DECLARATION of Declarant 2 in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 143
DECLARATION of Declarant 1 in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 142
DECLARATION of Zaneta Hubbard in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 141
DECLARATION of Monique da Silva Moore in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 140
DECLARATION of MaryEllen O'Donohue in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 139
DECLARATION of Laurie Mayers in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 138
DECLARATION of Katherine Wilkinson in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 137
DECLARATION of Heather Pierce in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 136
DECLARATION of Carol Perlman in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 135
DECLARATION of Siham Nurhussein in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R)(Nurhussein, Siham)
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Filing 134
MEMORANDUM OF LAW in Support re: #133 MOTION to Certify Class and Authorize Notice., 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce. (Nurhussein, Siham)
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Filing 133
MOTION to Certify Class and Authorize Notice. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce.(Nurhussein, Siham)
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Filing 132
DECLARATION of Melanie Babcock in Opposition re: 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 131
SCHEDULING ORDER: Conference set for Tuesday, 4/3/2012 at 03:45 PM in Courtroom 14A, 500 Pearl Street, New York, NY 10007 before Judge Andrew L. Carter Jr, as further set forth in this document. (Signed by Judge Andrew L. Carter, Jr on 3/29/2012) (cd)
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Filing 130
ENDORSED LETTER addressed to Judge Andrew L Carter from Siham Nurhussein dated 3/26/2012 re: Request to file consolidated replies of 20 pages each. ENDORSEMENT: Application granted in part and denied in part. Plaintiffs may file their consolidated reply briefs of up to 15 pages each. (Signed by Judge Andrew L. Carter, Jr on 3/29/2012) (cd)
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Filing 129
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Jeffrey W. Brecher dated 3/23/2012 re: We are writing to request permission to submit an additional Declaration in support of MSL's opposition to Plaintiffs' motion for conditional certification filed earlier this week. ENDORSEMENT: Application granted. Defendants should file the declaration on ECF if they have not already done so. (Signed by Judge Andrew L. Carter, Jr on 3/28/2012) (lmb)
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Filing 128
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Deepika Bains dated 3/27/2012 re: Counsel for the Plaintiff writes to request an adjournment of the conference currently scheduled for 4/16/2012. ENDORSEMENT: Adjournment granted. Conference rescheduled for 4/25/2012 at 2:00 PM. (Status Conference set for 4/25/2012 at 02:00 PM before Magistrate Judge Andrew J. Peck.) (Signed by Magistrate Judge Andrew J. Peck on 3/28/2012) (ab)
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Filing 127
MEMORANDUM OF LAW in Opposition to Plaintiffs' motion for leave to file a Second Amended Complaint. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 126
MEMORANDUM OF LAW in Opposition re: #110 Amended Complaint, Opposition to Plaintiffs' Motion for Leave to File Second Amended Complaint. Document filed by Publicis Groupe SA. (Attachments: #1 Exhibit 1)(Evans, Paul)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Paul Clayton Evans to RE-FILE Document #121 Opposition Brief. Use the event type Memorandum of Law in opposition to motion found under the event list Replies, Opposition and Supporting Documents. (ka)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Jeffrey W. Brecher to RE-FILE Document #116 Opposition Brief,. Use the event type Memorandum of Law in Opposition to motion found under the event list Replies, Opposition and Supporting Documents. (ka)
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Filing 125
DECLARATION of Paul J. Neale in Support re: #123 Reply,. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Nurhussein, Siham)
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Filing 124
DECLARATION of Siham Nurhussein in Support re: #123 Reply,. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Nurhussein, Siham)
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Filing 123
FIRST REPLY re: #104 Opposition Brief to Plaintiffs' Rule 72a Objections to Judge Peck's 2-8-12 Rulings. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 122
MEMORANDUM OF LAW in Opposition re: 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by Publicis Groupe SA. (Attachments: #1 Exhibit 1-Sept. 21, 2011 Letter to J. Sullivan)(Evans, Paul)
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Filing 121
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - OPPOSITION BRIEF in Opposition to Plaintiffs' Motion for Leave to File Second Amended Complaint. Document filed by Publicis Groupe SA. (Attachments: #1 Exhibit 1-Proposed Joint Scheduling Order)(Evans, Paul) Modified on 3/20/2012 (ka).
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Filing 120
MEMORANDUM OF LAW in Opposition re: 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by MSLGroup. (Brecher, Jeffrey)
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Filing 119
DECLARATION of Victoria Woodin Chavey, Esq. in Opposition re: 111 MOTION to Certify Class. MOTION to Authorize of notice.. Document filed by MSLGroup. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Brecher, Jeffrey)
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Filing 118
STIPULATION AND ORDER PURSUANT TO F.R.E. 502(d) AND F.R.E. 502(e): The protections afforded by the attorney-client privilege and work product doctrine shall not be waived by a party's disclosure of otherwise protected information in connection with the within litigation, unless such disclosure was made with the specific intention by the party to waive such protections as to the communication or document in question. A party who produces any privileged document or communication, without the specific intention to waive such protections as to the document or communication in question, may, within ten days after the producing party actually discovers, through any source, that such inadvertent production occurred, notify the other party that such document or communication was inadvertently produced and should have been withheld as protected by the attorney-client privilege or work product doctrine. If such notice occurs. the production will not constitute a. waiver of the protections afforded by the attorney-client privilege and work product doctrine. Once the producing party provides such notice to the requesting party, the requesting party must promptly return the specified document or communication and any copies thereof and destroy any notes relating to same. (Signed by Magistrate Judge Andrew J. Peck on 3/19/2012) (ft)
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Filing 117
AFFIRMATION of Jeffrey W. Brecher in Opposition. Document filed by MSLGroup. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit)(Brecher, Jeffrey)
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Filing 116
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - OPPOSITION BRIEF in opposition to Plaintiffs' motion for leave to file a Second Amended Complaint. Document filed by MSLGroup.(Brecher, Jeffrey) Modified on 3/20/2012 (ka).
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Filing 115
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Siham Nurhussein dated 3/9/12 re: Counsel for the plaintiffs request the opportunity to file a ten page reply brief in response to defendants opposition to plaintiffs' objections to Magistrate Judge Peck's 2/8/12 ruling. ENDORSEMENT: Application granted. Plaintiff's reply due on or before 3/19/12. (Signed by Judge Andrew L. Carter, Jr on 3/13/2012) (mro)
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Set/Reset Hearings: Status Conference set for 4/16/2012 at 02:30 PM before Magistrate Judge Andrew J. Peck. (cd)
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Set/Reset Deadlines: Jurisdictional Discovery due by 6/18/2012. (cd)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 3/9/2012. Defendants can take depo of Dr. Madden on 3/12 at 2 pm. Jurisdictional discovery cutoff 6/18. Defendant Publicis motion to dismiss due 6/18. See transcript for other discovery rulings. Status conf to be held before Judge Peck on 4/16 at 2:30 pm. (cd)
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Filing 109
AMENDED JOINT SCHEDULING ORDER REGARDING JURISDICTIONAL DISCOVERY: Motions due by 6/18/2012. Responses due by 7/2/2012 Replies due by 7/9/2012. Discovery due by 6/18/2012. Further extensions are extremely unlikely. (Signed by Magistrate Judge Andrew J. Peck on 3/9/2012) (lmb)
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Filing 108
STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL INFORMATION...regarding procedures to be followed that shall govern the handling of confidential material... Sealed records which have been filed with the Clerk shall be removed by the party submitting them (1) within ninety (90) days after a final decision is rendered if no appeal is taken, or (2) if an appeal is taken, within thirty (30) days after final disposition of the appeal. Parties failing to comply with this order shall be notified by the Clerk that, should they fail to remove the sealed records within thirty (30) days, the Clerk may dispose of them. (Signed by Magistrate Judge Andrew J. Peck on 3/8/2012) (ft)
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Filing 107
DECLARATION of Jan Puzicha in Opposition re: #104 Opposition Brief. Document filed by MSL Group. (Anders, Brett)
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Filing 106
DECLARATION of Eric Seggebruch in Opposition re: #104 Opposition Brief. Document filed by MSL Group. (Anders, Brett)
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Filing 105
DECLARATION of Brett M. Anders in Opposition re: #104 Opposition Brief. Document filed by MSL Group. (Attachments: #1 Exhibits A and B, #2 Exhibit C, Part 1 of 2, #3 Exhibit C, Part 2 of 2, #4 Exhibits D, E and F, #5 Exhibit G, Part 1 of 2, #6 Exhibit G, Part 2 of 2)(Anders, Brett)
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Filing 104
OPPOSITION BRIEF to Plaintiffs' Rule 72(a) Objection to Judge Peck's February 8, 2012 Rulings. Document filed by MSL Group.(Anders, Brett)
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Filing 103
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Jeffrey W. Brecher dated 3/01/2012 re: We represent Defendant MSL Group Americas, Inc. In light of Plaintiffs' pending Objection to the Court's rulings regarding the ESI Protocol, the parties jointly request that the Court adjourn the status conference scheduled for March 9, 2012 at 9:30 a.m, and stay the execution of the ESI Protocol pending Judge Carter's decision. ENDORSEMENT: Request Denied. SO ORDERED. (Signed by Magistrate Judge Andrew J. Peck on 3/01/2012) Copies Sent By Chambers. (ama)
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Filing 101
ORDER: All counsel are reminded of the requirement of my Individual Practices to provide courtesy copies o fall papers filed with the Court, including Objections and letters to Judge Carter. Further failures in this regard will result in sanctions. SO ORDERED. (Signed by Magistrate Judge Andrew J. Peck on 3/01/2012) Copies Sent By Chambers. (ama)
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Filing 114
DECLARATION of Heather Pierce in Support re: 111 PLAINTIFFS' NOTICE OF MOTION FOR CONDITIONAL CERTIFICATION AND AUTHORIZATION OF NOTICE. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (lmb)
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Filing 113
DECLARATION of Siham Nurhussein in Support re: 111 PLAINTIFFS' NOTICE OF MOTION FOR CONDITIONAL CERTIFICATION AND AUTHORIZATION OF NOTICE. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (lmb)
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Filing 112
MEMORANDUM OF LAW in Support re: 111 PLAINTIFFS' NOTICE OF MOTION FOR CONDITIONAL CERTIFICATION AND AUTHORIZATION OF NOTICE. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (lmb)
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Filing 111
PLAINTIFFS' NOTICE OF MOTION FOR CONDITIONAL CERTIFICATION AND AUTHORIZATION OF NOTICE. Document filed by Monique Da Silva Moore, Zaneta Hubbard, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(lmb)
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Filing 110
SECOND AMENDED COMPLAINT amending #4 Amended Complaint, against MSLGroup, Publicis Groupe SA with JURY DEMAND.Document filed by Katherine Wilkinson, Heather Pierce, Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Zaneta Hubbard. Related document: #4 Amended Complaint, filed by Laurie Mayers, Katherine Wilkinson, Maryellen O'Donohue, Heather Pierce, Monique Da Silva Moore.(lmb) (ama).
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Filing 102
SEALED DOCUMENT placed in vault.(nm) Modified on 3/1/2012 (nm).
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Filing 99
ENDORSED LETTER addressed to Judge Andrew L. Carter, Jr. from Siham Nurhussein dated 2/28/2012 re: Pursuant to the Sealed Records Filing Instructions of the United States District Court for the Southern District of New York, Plaintiffs respectfully request permission to file certain confidential documents under seal. Defendant Publicis Groupe ("Publicis") has consented. Defendant MSL Group ("MSL") has requested a list of documents being filed under seal so that it can determine whether it consents, but Plaintiffs are not yet in a position to provide such a list. Plaintiffs plan to seek conditional certification of a collective action and leave to file a proposed Second Amended Complaint on Wednesday, February 29, 2012. Many of the documents relied upon for Plaintiffs' conditional certification motion and proposed Second Amended Complaint are ones that have been marked "Confidential" by the parties pursuant to their Confidentiality Agreement (attached hereto as Ex. A, and to be filed with the Court shortly). Accordingly, Plaintiffs request permission to file any confidential exhibits, as well as portions of the conditional certification motion and Second Amended Complaint that reference confidential material, under seal. ENDORSEMENT: Plaintiffs are permitted to file certain confidential documents under seal. If MSL Group objects to a specific document(s), it should file a letter no later 3/2/12. The Court will then determine if the contested document(s) should remain under seal. (Signed by Judge Andrew L. Carter, Jr on 2/29/2012) (djc)
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Filing 98
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 2/8/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 97
TRANSCRIPT of Proceedings re: Conference held on 2/8/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Thomas Murray, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/23/2012. Redacted Transcript Deadline set for 4/2/2012. Release of Transcript Restriction set for 6/1/2012.(McGuirk, Kelly)
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Filing 100
INTERNET CITATION NOTE: Material from decision with Internet citation re: #96 Memorandum & Opinion. (Attachments: #1 Sedona Conference Download Request, #2 The Sedona Conference, #3 grossman3) (tro)
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Filing 96
OPINION AND ORDER: #101473 this Opinion appears to be the first in which a Court has approved of the use of computer-assisted review. That does not mean computer-assisted review must be used in all cases, or that the exact ESI protocol approved here will be appropriate in all future cases that utilize computer-assisted review. Nor does this Opinion endorse any vendor (the Court was very careful not to mention the names of the parties' vendors in the body of this Opinion, although it is revealed in the attached ESI Protocol), nor any particular computer-assisted review tool. What the Bar should take away from this Opinion is that computer-assisted review is an available tool and should be seriously considered for use in large-data-volume cases where it may save the producing party (or both parties) significant amounts of legal fees in document review. Counsel no longer have to worry about being the "first" or "guinea pig" for judicial acceptance of computer- assisted review. As with keywords or any other technological solution to ediscovery, counsel must design an appropriate process, including use of available technology, with appropriate quality control testing, to review and produce relevant ESI while adhering to Rule 1 and Rule 26(b )(2)(C) proportionality. Computer-assisted review now can be considered judicially-approved for use in appropriate cases. (Signed by Magistrate Judge Andrew J. Peck on 2/24/2012) Copies By ECF. (pl) Modified on 2/24/2012 (pl). Modified on 2/24/2012 (jab).
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Filing 95
DECLARATION of Paul J. Neale in Support re: #93 Objection (non-motion). Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Nurhussein, Siham)
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Filing 94
DECLARATION of Siham Nurhussein in Support re: #93 Objection (non-motion). Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G)(Nurhussein, Siham)
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Filing 93
Objection Rule 72a to Judge Peck's 2-8-12 Rulings. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 92
PARTIES' PROPOSED PROTOCOL RELATING TO THE PRODUCTION OF ELECTRONICALLY STORED INFORMATION ("ESI") & ORDER: This protocol may be executed in counterparts. Each counterpart, when so executed, will be deemed and original, and will constitute the same instrument. SO ORDERED. (Signed by Magistrate Judge Andrew J. Peck on 2/22/2012) (ama)
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Filing 91
TRANSCRIPT of Ruling by Judge Peck via telephone on 2/2/2012. (mro)
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Filing 90
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Siham Nurhussein dated 2/20/12 re: Counsel for the plaintiffs writes to request clarification regarding Your Honor's rulings on the parties' proposed ESI Protocols, which were addressed at the 1/4/12 and 2/8/12 conferences. ENDORSEMENT: The time to file objections runs from the hearing date (2/8), although the Court does plan to issue a written decision. (Signed by Magistrate Judge Andrew J. Peck on 2/21/2012) Copies by ECF. (mro)
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Filing 89
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 2/8/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 88
TRANSCRIPT of Proceedings re: Conference held on 2/8/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Thomas Murray, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/12/2012. Redacted Transcript Deadline set for 3/22/2012. Release of Transcript Restriction set for 5/21/2012.(McGuirk, Kelly)
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Filing 87
NOTICE OF APPEARANCE by Brett Michael Anders on behalf of MSL Group (Anders, Brett)
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Filing 86
ORDER: Accordingly, Plaintiffs' objections are DENIED and Judge Peck's January 4, 2012 discovery rulings are affirmed. If Plaintiffs need further clarification concerning Judge Peck's rulings, they are directed to ask Judge Peck. Further, the transcript reflects that some of the issues will be re-visited by Judge Peck at the appropriate time. Plaintiffs submitted a letter on February 9, 2012 requesting an emergency conference to discuss Judge Peck's February 8, 2012 rulings. Plaintiffs request for an emergency conference is denied. The Court has reviewed the submissions and the transcript from February 8. If Plaintiffs wish to file Rule 72 objections, they are free to do so. If the Court decides to reverse Judge Peck's rulings, it will remain mindful that the Court's decision will be filed after the service of Plaintiffs' motion. If Plaintiffs wish to submit a joint request to the Court seeking an extension of the personal jurisdiction discovery schedule concerning Defendant Publicis Groupe SA (Dkt. 44), they should submit the request to Judge Peck. All general, non-dispositive pretrial matters, including the scheduling of the collective action motion, have been referred to the magistrate judge. The undersigned will decide the motion once it is fully briefed. (Signed by Judge Andrew L. Carter, Jr on 2/14/2012) (mro)
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Filing 85
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a telephonic status conference proceeding held on 1/18/2012 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(tro)
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Filing 84
TRANSCRIPT of Proceedings re: telephonic status conference held on 1/18/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Ruth Ann Hager. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/5/2012. Redacted Transcript Deadline set for 3/15/2012. Release of Transcript Restriction set for 5/14/2012.(tro)
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Filing 83
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Deepika Bains dated 2/8/12 re: Counsel writes concerning Plaintiffs' third party subpoena, served on defendant MSL's payroll services company and discussed at the February 8 conference. Counsel misstated plaintiffs' position at the conference and plaintiffs will not withdraw the subpoena. ENDORSEMENT: The subpoena is quashed. Moreover, the Court expects counsel at conferences who make statements to the Court to not be overruled by more senior attorneys who are not at the conf. Copies by ECF. (Signed by Magistrate Judge Andrew J. Peck on 2/9/2012) (mro)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 2/8/2012. Court resolved issues re ESI protocol - see transcript. Final ESI protocol incorporating Court's rulings due 2/17. See transcript for other rulings. Collective action motion due 2/29. Status conf. to be held before Judge Peck on 3/9 at 9:30 AM. ( Motions due by 2/29/2012.), ( Status Conference set for 3/9/2012 at 09:30 AM before Magistrate Judge Andrew J. Peck.) (lmb)
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Filing 82
OPPOSITION BRIEF re: #69 Objection (non-motion) to Plaintiffs' Rule 72(A) Objection to Mag. Judge Peck's Jan. 4, 2012 Rulings. Document filed by MSL Group.(Brecher, Jeffrey)
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Filing 81
AFFIRMATION of Jeffrey W. Brecher in Opposition re: #80 Opposition Brief. Document filed by MSL Group. (Attachments: #1 Exhibit, #2 Exhibit)(Brecher, Jeffrey)
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Filing 80
FILING ERROR - DEFICIENT DOCKET ENTRY - SIGNATURE ERROR - SEE DOCUMENT #82 - OPPOSITION BRIEF re: #69 Objection (non-motion) to Plaintiffs' Rule 72(A) Objection to Mag. Judge Peck's January 4, 2012 Rulings. Document filed by MSL Group.(Brecher, Jeffrey) Modified on 2/15/2012 (lb).
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Telephone Conference held on 2/2/2012. Parties call from Morgan deposition. See transcript for rulings. (djc) Modified on 2/9/2012 (djc).
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Set/Reset Hearings: Status Conference set for 2/8/2012 at 03:00 PM before Magistrate Judge Andrew J. Peck. (js)
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Filing 79
ENDORSED LETTER: addressed to Magistrate Judge Andrew J. Peck from Paul C. Evans dated 2/1/2012 re: Counsel for defendant request that the February 2, 2012 status conference be adjourned. ENDORSEMENT: Conference adjourned at defendants' request to 2/8 at 3:00 p.m. So Ordered., ( Status Conference set for 2/8/2012 at 03:00 PM before Magistrate Judge Andrew J. Peck) (Signed by Magistrate Judge Andrew J. Peck on 2/1/2012) (js)
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Filing 78
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a status conference proceeding held on 1/12/2012 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(tro)
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Filing 77
TRANSCRIPT of Proceedings re: status conference held on 1/12/2012 before Judge Andrew L. Carter, Jr.. Court Reporter/Transcriber: Shari Riemer, (518) 581-8973. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/21/2012. Redacted Transcript Deadline set for 3/1/2012. Release of Transcript Restriction set for 4/30/2012.(tro)
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Filing 76
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Janette Wipper dated 1/27/2012 re: Counsel for the plaintiffs request permission to appear telephonically at the scheduled conference. ENDORSEMENT: APPROVED. (Signed by Magistrate Judge Andrew J. Peck on 1/27/2012) (ft)
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Filing 75
ORDER: Both sides shall have their ESI consultants attend the February 2,2012 conference. SO ORDERED. (Signed by Magistrate Judge Andrew J. Peck on 1/26/2012) (ama)
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Filing 74
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Jeffrey W. Brecher dated 1/23/2012 re: We are writing to request a two week extension to produce a sample of "Personnel Action Notices" ("PANs") and "Promotion Recommendation Forms" discussed at the Court conference held on January 4, 2012. ENDORSEMENT: On consent, approved. (Signed by Magistrate Judge Andrew J. Peck on 1/23/2012) Copies Sent By Chambers via ECF. (rjm)
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Filing 73
STIPULATION LIMITING PLAINTIFFS' CLAIMS FOR EMOTIONAL DISTRESS DAMAGES: Plaintiffs' claims for emotional distress damages are limited to only "garden variety" emotional distress and Plaintiffs may introduce and rely on evidence in support of such claim only as set forth in this Stipulation, and as further set forth in this document. (Signed by Judge Andrew L. Carter, Jr on 1/23/2012) (cd)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Telephone Conference held on 1/19/2012. Janet Wipper and Deepika Brains for Plaintiffs. Jeffrey Brecher for Defendant MSL Group. The parties will E-mail a revised stipulation consistent with today's rulings on or before January 20. Further discovery disputes should be addressed to Judge Peck. See transcript for details. Visit http://www1.nysd.uscourts.gov/courtrm tech/php with respect to ordering a transcript of a recorded proceeding via "Courtflow". (js)
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Filing 72
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 1/4/12 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 71
TRANSCRIPT of Proceedings re: Conference held on 1/4/2012 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Andrew Walker, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/14/2012. Redacted Transcript Deadline set for 2/24/2012. Release of Transcript Restriction set for 4/23/2012.(McGuirk, Kelly)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Telephone Conference held on 1/18/2012. Janet Wipper and Deepika Bains for Pltffs. Jeffrey Brecher for Dft. MSL Group. The parties will email a revised stipulation consistent with today's rulings on or before January 20. Further discovery disputes should be addressed to Judge Peck. See transcript for details. Visit http://www1.nysd.uscourts.gov/courtrm tech.php with respect to ordering a transcript of a recorded proceeding via Courtflow". (rjm)
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Filing 70
DECLARATION of Siham Nurhussein in Support re: #69 Objection (non-motion). Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Attachments: #1 Exhibit A- 12-27-11 Motion to Compel Pre-Motion Letter, #2 Exhibit B- 12-29-11 Motion for Sanctions Pre-Motion Letter, #3 Exhibit C- Transcript of 1-4-12 Conference, #4 Exhibit D- MSL000821)(Nurhussein, Siham)
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Filing 69
Objection to Magistrate Judge Peck's January 4, 2012 Discovery Rulings. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson. (Nurhussein, Siham)
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Filing 68
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Brett M. Anders dated 1/13/2012 re: Counsel for the Defendant writes to request an additional week, until 1/25/2012, to complete the joint ESI Protocol. ENDORSEMENT: The deadline for the Joint ESI Protocol is extended to 1/25/2012. Further extensions are unlikely. (Signed by Magistrate Judge Andrew J. Peck on 1/17/2012) (ab)
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Filing 67
NOTICE OF COURT CONFERENCE: The Court is in receipt of Plaintiffs and Defendant MSL Group's proposed stipulations and directs the parties to continue working on the stipulation. The parties should submit the proposed stipulation(s), in MS Word format, to ALCarterNYSDChambers@nysd.uscourts.gov, no later than 7:00 p.m. on Tuesday, January 17. There will be a telephone conference on Wednesday, January 18, 2012 at 3:30 p.m. Plaintiffs' counsel is ordered to initiate the call by dialing (212) 805-7943 with all participants on the line. ( Telephone Conference set for 1/18/2012 at 03:30 PM before Judge Andrew L. Carter Jr.) (Signed by Judge Andrew L. Carter, Jr on 1/13/2012) (mro)
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Minute Entry for proceedings held before Judge Andrew L. Carter, Jr: Telephone Conference held on 1/12/2012. Janette Wipper, Deepika Bains and Siham Nurhussein for Plaintiff, George Stohner for Dft. Publicis Group. Jeffrey Brecher and Victoria Chavey for Dft. MSL Group. Plaintiff's objections to Judge Peck's decisions were discussed. Judge Peck's decisions are modified subject to the stipulation between Plaintiffs and Defendant MSL Group, which will be faxed to Judge Carter's chambers by the end of the day. (lmb)
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Filing 66
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 12/2/11 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 65
TRANSCRIPT of Proceedings re: Conference held on 12/2/2011 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Denise Richards, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/6/2012. Redacted Transcript Deadline set for 2/17/2012. Release of Transcript Restriction set for 4/13/2012.(McGuirk, Kelly)
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Filing 64
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Janette Wipper dated 1/10/12 re: Counsel for the plaintiffs requests Your Honor stay the discovery rulings made on December 2, 5, and 6, 2011 that are the subject of Plaintiffs' Rule 72(a) objections. ENDORSEMENT: Request for a stay is DENIED. (Signed by Magistrate Judge Andrew J. Peck on 1/11/2012) Copies by ECF. (mro)
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Filing 63
NOTICE OF CASE REASSIGNMENT to Judge Andrew L. Carter, Jr. Judge Richard J. Sullivan is no longer assigned to the case. (sjo)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 1/4/2012. Discovery issues resolved - see transcript for rulings. Helped parties resolve some of their issues re ESI protocol. Final ESI protocol due 1/8. Defendant to produce docs. specified at conf. by 1/25. Parties to consider earlier class/collective action motion re FLSA/NY Labor Law issues. To advise at next conf. Status conf. 2/2 at 9:30 a.m. ( Status Conference set for 2/2/2012 at 09:30 AM before Magistrate Judge Andrew J. Peck.). (jfe)
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Filing 62
DECLARATION of Jeffrey W. Brecher, Esq. in Support re: #61 Declaration in Support. Document filed by MSL Group. (Brecher, Jeffrey)
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Filing 61
DECLARATION of Jeffrey W. Brecher, Esq. in Support. Document filed by MSL Group. (Brecher, Jeffrey)
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Filing 60
OPPOSITION BRIEF to Plaintiffs' Rule 72(A) Objection to Magistrate Judge Peck's Rulings. Document filed by MSL Group.(Brecher, Jeffrey)
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Filing 59
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Janette Wipper dated 12/30/2011 re: Counsel request that Plaintiffs' ESI experts from DOAR Litigation Consulting be permitted to attend the upcoming ESI conference scheduled for January 4, 2012. ENDORSEMENT: Approved. (Signed by Magistrate Judge Andrew J. Peck on 12/30/2011) (jfe)
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Filing 58
ENDORSED LETTER addressed to Magistrate Judge Andrew J. Peck from Janette Wipper dated 12/19/2011 re: Counsel for the Plaintiffs writes to request an adjournment of the discovery conference currently scheduled for 12/21/2011 to a date in early January. ENDORSEMENT: 1. Conf. adjourned at Plaintiff's request to 1/4 at 11 AM. The Court expects the ediscovery protocol to be completed by then. 2. As to predictive coding, you should read my article, "Search, Forward" in the Oct. 2011 issue of Law Technology News. (Status Conference set for 1/4/2012 at 11:00 AM before Magistrate Judge Andrew J. Peck.) (Signed by Magistrate Judge Andrew J. Peck on 12/20/2011) (ab)
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Filing 57
DECLARATION of Siham Nurhussein in Support re: #55 Brief. Document filed by Monique Da Silva Moore. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K)(Nurhussein, Siham)
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***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Siham Nurhussein to RE-FILE Document #56 Brief. Use the event type Declaration in Support(non-motion) found under the event list Other Answers. (ka)
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Filing 56
FILING ERROR - WRONG DOCUMENT TYPE SELECTED FROM MENU - BRIEF re: #55 Brief Declaration in Support of Rule 72(a) Objection to Magistrate's Ruling. Document filed by Monique Da Silva Moore. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K)(Nurhussein, Siham) Modified on 12/19/2011 (ka).
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Filing 55
BRIEF Rule 72(a) Objection to Magistrate's Rulings. Document filed by Monique Da Silva Moore.(Nurhussein, Siham)
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Filing 54
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 12/5/11 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 53
TRANSCRIPT of Proceedings re: Conference held on 12/5/2011 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Ann Hairston, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 1/9/2012. Redacted Transcript Deadline set for 1/20/2012. Release of Transcript Restriction set for 3/19/2012.(McGuirk, Kelly)
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Filing 52
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 12/2/2011 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 51
TRANSCRIPT of Proceedings re: Conference held on 12/2/2011 before Magistrate Judge Andrew J. Peck. Court Reporter/Transcriber: Denise Richards, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 1/9/2012. Redacted Transcript Deadline set for 1/20/2012. Release of Transcript Restriction set for 3/19/2012.(McGuirk, Kelly)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Telephone Conference held on 12/6/2011. Call from deposition - Plaintiff's counsel's instruction to witness not to answer certain questions re emotional distress treatment is overruled; witness to answer questions. Plaintiff's counsel warned that continued attempts to revisit the issue will result in sanctions. See transcript. (ft)
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Minute Entry for proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 12/5/2011. Defendant's depos of Plaintiff's Wilkinson (12/6), pierce (12/7) and Hubbard (12/21 in Atlanta) to go forward as scheduled; also plaintiff DaSilva Moore week of 1/9. Court refuses to revisit the issue of emotional distress damage discovery ruled on by Judge Sullivan and by me on 12/2. (ft)
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Set Deadlines/Hearings: Status Conference set for 12/21/2011 at 02:00 PM before Magistrate Judge Andrew J Peck. (cd)
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Minute Order Proceedings held before Magistrate Judge Andrew J. Peck: Status Conference held on 12/2/2011. Next status conference to be held before Judge Peck on 12/21 at 2 pm. (cd)
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Filing 50
ORDER SCHEDULING STATUS CONFERENCE: Status Conference set for 12/2/2011 at 04:00 PM in Courtroom 20D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Andrew J. Peck, and as further set forth in this document. (Signed by Magistrate Judge Andrew J. Peck on 11/29/2011) Copies Sent By Chambers By ECF. (cd)
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Filing 49
ORDER: in a letter dated November 15, 2011, Plaintiffs requested a pre-motion conference to file a motion for sanctions against MSL for its purported refusal to comply with the September 14, 2011 Order. MSL responded by letter dated November 18, 2011. Having reviewed the parties' various submissions, the Court hereby deems the sanctions motions made and denied without prejudice for renewal. Furthermore, by an order dated November 28, 2011, the above-captioned matter was referred for general pre-trial purposes to Magistrate Judge Peck, to whom all subsequent discovery disputes should be addressed. (Signed by Judge Richard J. Sullivan on 11/28/2011) (pl)
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Filing 48
REFERRAL ORDER. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Referred to Magistrate Judge Andrew J. Peck. (Signed by Judge Richard J. Sullivan on 11/28/2011) (pl)
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Filing 47
ORDER: Accordingly,, Plaintiffs' requests for a protective order and the opportunity to fully brief the issue are hereby denied. Discovery shall proceed as specified in the order dated August 9, 2011 (Signed by Judge Richard J. Sullivan on 11/9/2011) (js)
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Filing 46
ORDER: that the parties are ordered to confer and submit a joint letter describing the issue of defendants third party subpoenas on plaintiffs; past, current or prospective employers. (Signed by Judge Richard J. Sullivan on 10/28/2011) (cd)
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Filing 45
ORDER ADMITTING ATTORNEY PRO HAC VICE: Attorney Paul Clayton Evans for Publicis Groupe SA is admitted Pro Hac Vice. (Signed by Judge Richard J. Sullivan on 10/14/2011) (laq)
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Filing 44
JOINT SCHEDULING ORDER REGARDING JURISDICTIONAL DISCOVERY: The Court hereby adopts the following Scheduling Order governing jurisdictional discovery: All jurisdictional discovery is to be completed no later than March 12, 2012. Amended filings may not be filed except with leave of the Court. Publicis shall make a dispositive motion for lack of personal jurisdiction no later than April 16, 2012. Plaintiffs shall make an opposition to the dispositive motion no later than May 7, 2012. Publicis shall make a reply in support of the dispositive motion no later than May 21, 2012. (Signed by Judge Richard J. Sullivan on 10/12/2011) (mro) Modified on 10/17/2011 (mro).
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Filing 42
ORDER FOR ADMISSION PRO HAC VICE ON WRITTEN MOTION. The motion of Paul C. Evans for admission to practice pro hac vice as counsel for Defendant Publicis Groupe SA in this action in the United States District Court for the Southern District of New York is granted. Attorney Paul C. Evans for Publicis Groupe admitted Pro Hac Vice. (Signed by Judge Richard J. Sullivan on 10/7/2011) (ft) Modified on 3/20/2012 (tro).
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Filing 43
MOTION for Paul C. Evans to Appear Pro Hac Vice. Document filed by Publicis Groupe.(pgu)
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Filing 41
ORDER: that the parties shall confer and submit a joint proposed scheduling order by 10/7/2011 concerning jurisdictional discovery necessary for the Court to resolve Defendant's contemplated motion. (Signed by Judge Richard J. Sullivan on 9/27/2011) (ft)
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MEDIATOR SESSION SCHEDULED First Mediation Session scheduled for 7/19/12 10:00 AM 233 Broadway.(gom)
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Filing 40
ORDER: Having reviewed Plaintiffs' Requests for Production, the Court concludes that Plaintiffs are entitled to examine documents related to company-wide employment data as it relates to public relations professionals (Plaintiffs' Request for Production 1). Additionally, Plaintiffs are entitled to discovery with regard to MSL's corporate structure and reorganization (Plaintiffs' Requests for Production 6 and 11). Accordingly, Defendants are hereby ordered to produce those documents and as further set forth in this order. (Signed by Judge Richard J. Sullivan on 9/13/2011) (lmb)
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Filing 39
ORDER: The Court is in receipt of the September 12, 2011 letter from Defendant Publicis Groupe S.A. ("Publicis") requesting an extension of time to answer or otherwise respond to Plaintiff's Class Action Complaint. IT IS HEREBY ORDERED that Publicis submit its answer or otherwise respond to Plaintiff's Class Action Complaint by Wednesday, September 21, 2001 at 4:00 p.m. Publicis Groupe answer due 9/21/2011. (Signed by Judge Richard J. Sullivan on 9/13/2011) (lmb)
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Filing 38
NOTICE OF APPEARANCE by Melissa Ruth Kelly on behalf of Publicis Groupe (Kelly, Melissa)
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Filing 37
ORDER; that, by September 1, 2011, the parties shall submit a joint letter to the Court enclosing copies of the challenged requests for production and interrogatories. If any of the requests and interrogatories have been narrowed by agreement of the parties, they shall so indicate in the joint letter. (Signed by Judge Richard J. Sullivan on 8/29/11) (pl)
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Filing 36
CONSENT TO JOIN CLASS. Document filed by Monique Da Silva Moore. (Attachments: #1 Exhibit A)(Nurhussein, Siham)
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Filing 35
CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to disposition of this case by a Magistrate Judge, pursuant to 28 USC 636(c). Motions for class and collective action certification due by 4/13/2013. Deposition due by 6/30/2012. All Discovery due by 3/1/2013, fact discovery due by 6/30/12, see document for other deadlines. Jury trial, parties unable to estimate length of trial. (Signed by Judge Richard J. Sullivan on 8/9/11) (cd)
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Filing 34
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 7/21/11 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 33
TRANSCRIPT of Proceedings re: Conference held on 7/21/2011 before Judge Richard J. Sullivan. Court Reporter/Transcriber: Patricia Nilsen, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/29/2011. Redacted Transcript Deadline set for 9/8/2011. Release of Transcript Restriction set for 11/7/2011.(McGuirk, Kelly)
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CASHIERS OFFICE REMARK on #29 Motion to Appear Pro Hac Vice in the amount of $200.00, paid on 07/19/2011, Receipt Number 11921. (jd)
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Minute Entry for proceedings held before Judge Richard J. Sullivan: Telephone Conference held on 7/21/2011. The Court ordered the parties to submit a proposed case management plan and joint letter by July 29, 2011. In the joint letter, Defendant MSL Group shall state whether it intends to file its motion and, if so, propose a briefing schedule. The parties shall also state in the joint letter their views on when mediation should take place. (ft)
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Filing 32
ORDER: The Court is in receipt of a letter from Plaintiff and Defendant MSLGROUP dated July 19, 2011. In the letter, MSLGROUP asks the Court to vacate the Standing Administrative Order referring this case to mediation in light of its pending motion to dismiss this action. Alternatively, the parties request a date for mediation on or around July 19, 2012. The Court sees no reason why these issues cannot be raised with the Mediation Office or the assigned mediator in the first instance. Accordingly, the parties' requests are DENIED without prejudice to renewal. (Signed by Judge Richard J. Sullivan on 7/19/2011) (jfe)
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Filing 31
ORDER FOR ADMISSION OF DAVID SANFORD, ESQ PRO HAC VICE ON WRITTEN MOTION: granting #29 Motion for David Sanford to Appear Pro Hac Vice. (Signed by Judge Richard J. Sullivan on 7/19/2011) (jfe)
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Filing 30
ENDORSED LETTER addressed to Judge Richard J. Sullivan from Janette Wipper dated 7/18/11 re: I respectfully request permission to appear telephonically at the pre-motion conference. ENDORSEMENT: The Court will conduct the entire conference telephonically. All parties are to gather on one line, then contact the Court at (212) 805-0137. So ordered. (Telephone Conference set for 7/21/2011 at 03:00 PM before Judge Richard J. Sullivan.) (Signed by Judge Richard J. Sullivan on 7/19/11) (rjm)
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Filing 29
MOTION for David Sanford to Appear Pro Hac Vice. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(pgu)
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Filing 28
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Conference proceeding held on 6/16/11 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 27
TRANSCRIPT of Proceedings re: Conference held on 6/16/2011 before Judge Richard J. Sullivan. Court Reporter/Transcriber: Samuel Mauro, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/12/2011. Redacted Transcript Deadline set for 8/22/2011. Release of Transcript Restriction set for 10/20/2011.(McGuirk, Kelly)
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Filing 26
ORDER. IT IS HEREBY ORDERED THAT the parties shall appear for a pre-motion conference on July 21, 2011 at 3:00 p.m. Plaintiffs shall respond to Defendant MSL Group's letter by July 11, 2011. In light of this scheduled pre-motion conference, IT IS FURTHER ORDERED THAT the deadline for the parties to submit their revised proposed case management plan is adjourned sine die. (Pre-Motion Conference set for 7/21/2011 at 03:00 PM before Judge Richard J. Sullivan.) (Signed by Judge Richard J. Sullivan on 7/7/11) (rjm)
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Filing 25
NOTICE of Filing of Consent to Join Forms. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Filing 24
AFFIDAVIT OF SERVICE. Publicis Groupe served on 6/21/2011, answer due 7/12/2011. Service was accepted by Steve Schwartz, Managing Agent. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Minute Entry for proceedings held before Judge Richard J. Sullivan: Status Conference held on 6/16/2011. The Court ordered the parties to submit a revised proposed case management plan by July 15, 2011. The Court extended the time for Plaintiffs to serve Defendant Publicis Groupe pursuant to the Hague Convention. (ft)
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Filing 23
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying MMS USA Investments, Inc, MMS USA Holdings, Inc., Publicis Groupe U.S. Investments LLC, Publicis Investments B.V., Publicis Groupe, S.A. as Corporate Parent. Document filed by MSL Group.(Chavey, Victoria)
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Filing 22
NOTICE OF APPEARANCE by Jeffrey W. Brecher on behalf of MSL Group (Brecher, Jeffrey)
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Filing 21
NOTICE OF APPEARANCE by Siham Nurhussein on behalf of Monique Da Silva Moore (Nurhussein, Siham)
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Filing 20
ORDER OF AUTOMATIC REFERRAL TO MEDIATION (See M-10-468 Order filed July 15, 2010) Mediator to be Assigned by 6/16/2011. Mediator Expertise Request due by 6/13/2011. (Signed by Judge Loretta A. Preska on 01/03/11) (sc)
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NOTICE OF MEDIATOR ASSIGNMENT - Notice of assignment of mediator. Mediator Schedule due by 7/6/2011.(ms)
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Filing 19
ANSWER to #4 Amended Complaint,. Document filed by MSL Group.(Chavey, Victoria)
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Filing 18
ORDER. In light of the parties' stipulation extending the time for Defendant MSLGroup to answer or otherwise respond to Plaintiffs' Amended Complaint to June 6, 2011, IT IS HEREBY ORDERED THAT the scheduled May 12, 2011 conference is adjourned to June 16, 2011 at 9:15 a.m. IT IS FURTHER ORDERED THAT the deadline for the submission of the parties' joint letter and proposed case management plan is extended to June 9, 2011 at 4:00 p.m. If the parties wish to hold an earlier conference, they may so notify the Court. (Status Conference set for 6/16/2011 at 09:15 AM before Judge Richard J. Sullivan.) (Signed by Judge Richard J. Sullivan on 5/5/11); (djc)
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Filing 17
STIPULATION EXTENDING DEFENDANT MSLGROUP'S TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFFS' COMPLAINT. MSL Group answer due 6/6/2011. (Signed by Judge Richard J. Sullivan on 5/5/11) (djc)
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Set Deadlines/Hearings: Motions due by 6/6/2011. (djc)
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CASHIERS OFFICE REMARK on #11 Motion to Appear Pro Hac Vice in the amount of $25.00, paid on 04/19/2011, Receipt Number 4495. (jd)
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Filing 16
NOTICE OF APPEARANCE by Victoria Woodin Chavey on behalf of MSL Group (Chavey, Victoria)
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Filing 15
NOTICE OF APPEARANCE by Noel P. Tripp on behalf of MSL Group (Tripp, Noel)
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Filing 14
NOTICE OF APPEARANCE by Paul J. Siegel on behalf of MSL Group (Siegel, Paul)
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Filing 13
ENDORSED LETTER addressed to Judge Richard J. Sullivan from Janette Wipper dated 4/21/2011 re: Requesting an adjournment of Case Management Conference scheduled for April 28, 2011, until May 10, 2011. The parties also respectfully request that the date upon which the Parties must submit their joint letter and proposed case management plan and scheduling order be adjourned from April 21, 2011 at 4 pm to May 3, 2011 at 4 pm, 7 days in advance of the adjourned conference. ENDORSEMENT: The request to adjourn the due date of the parties' joint letter and proposed case management plan violates Rule 1.D of my Individual Practices, which requires any extension request be made at least 48 hours in advance of the scheduled deadline. Nevertheless, the Court will adjourn the scheduled April 28, 2011 conference to May 12, 2011 at 10:00 am. The parties shall submit their joint letter and proposed case management plan no later than May 5, 2011 at 4:00 pm. (Signed by Judge Richard J. Sullivan on 4/21/2011) (jpo)
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Filing 12
ORDER FOR ADMISSION OF JANETTE WIPPER, ESQ PRO HAC VICE ON WRITTEN MOTION granting #11 Motion for Janette Wipper to Appear Pro Hac Vice. (Signed by Judge Richard J. Sullivan on 4/21/2011) (jpo)
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Filing 11
MOTION for Janette Wipper to Appear Pro Hac Vice. Document filed by Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue, Heather Pierce, Katherine Wilkinson.(mbe)
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Filing 10
AFFIDAVIT OF SERVICE of Order Status Conference, First Notice of Filing of Consent to Join Forms served on Publicis Groupe SA on 04/14/2011. Service was accepted by Roberto Morales, Managing Agent. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Filing 9
AFFIDAVIT OF SERVICE of Order Status Conference, First Notice of Filing of Consent to Join Forms served on MSLGroup on 04/14/2011. Service was accepted by Steve Schwartz, Managing Agent. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Filing 8
AFFIDAVIT OF SERVICE of Summons and Complaint, Amended Complaint,. Publicis Groupe served on 4/14/2011, answer due 5/5/2011. Service was accepted by Roberto Morales, Managing Agent. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Filing 7
AFFIDAVIT OF SERVICE of Summons and Complaint, Amended Complaint,. MSL Group served on 4/14/2011, answer due 5/5/2011. Service was accepted by Steve Schwartz. Document filed by Monique Da Silva Moore. (Wittels, Steven)
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Filing 6
NOTICE OF APPEARANCE by Deepika Bains on behalf of Monique Da Silva Moore (Bains, Deepika)
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Filing 5
NOTICE OF APPEARANCE by Steven Lance Wittels on behalf of Monique Da Silva Moore (Wittels, Steven)
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Filing 4
AMENDED CLASS ACTION COMPLAINT amending #1 Complaint against MSL Group, Publicis Groupe with JURY DEMAND.Document filed by Katherine Wilkinson, Heather Pierce, Monique Da Silva Moore, Laurie Mayers, Maryellen O'Donohue. Related document: #1 Complaint filed by Monique Da Silva Moore.(ama) (ama).
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Filing 3
CONSENT TO JOIN CLASS. Document filed by Monique Da Silva Moore.(Wittels, Steven)
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***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney Jeremy Heisler To: E-MAIL the PDF for Document #4 Amended Class Action Complaint, to: case_openings@nysd.uscourts.gov. (ama)
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Filing 2
ORDER Status Conference set for 4/28/2011 at 09:15 AM in Courtroom 21C, 500Pearl Street, New York, NY 10007 before Judge Richard J. Sullivan, and as further set forth in this document. (Signed by Judge Richard J. Sullivan on 3/28/11) (cd)
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Filing 1
COMPLAINT against MSL Group, Publicis Groupe. (Filing Fee $ 350.00, Receipt Number 930261)Document filed by Monique Da Silva Moore.(ama) (ama).
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Case Designated ECF. (ama)
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Magistrate Judge Andrew J. Peck is so designated. (ama)
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SUMMONS ISSUED as to MSL Group, Publicis Groupe. (ama)
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