Lan v. AOL Time Warner, Inc. et al
Plaintiff: Sang Lan
Defendant: Gina Hiu-Hung Liu, Keo-Sung Liu, Gina Liu, Hugh Hu Mo, Ted Turner, Time Warner, Inc., John Does and Jane Does #1 through 15, Inclusive, TIG Insurance Company, Hui-Hung Sie, Hugh Mo, Wilson Xue, AOL Time Warner, Inc., TIG Specialty Insurance Solutions, Does 1-30, Winston Sie, Riverstone Claims Management, LLC and The United States Gymnastics Federation
Petitioner: former attorney Ming Hai
Case Number: 1:2011cv02870
Filed: April 28, 2011
Court: US District Court for the Southern District of New York
Office: Foley Square Office
County: XX Out of U.S.
Presiding Judge: James C Francis
Referring Judge: Analisa Torres
Nature of Suit: Civil Rights: Other
Cause of Action: 42 U.S.C. § 1983
Jury Demanded By: Both
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Docket Report

This docket was last retrieved on November 28, 2016. A more recent docket listing may be available from PACER.

Date Filed Document Text
November 28, 2016 Filing 330 SEALED DOCUMENT placed in vault.(rz)
November 15, 2016 Opinion or Order Filing 329 ORDER for #318 Motion to Dismiss filed by Sang Lan, #328 Report and Recommendations. The Court accepts and adopts the thorough and well-reasoned report and recommendation. Accordingly, Plaintiff's Rule 41 motion for dismissal with prejudice is GRANTED. The Clerk of Court is directed to close the case. (As further set forth in this Order.) (Signed by Judge Analisa Torres on 11/15/2016) (cf)
October 18, 2016 Opinion or Order Filing 328 REPORT AND RECOMMENDATION re: #119 Amended Complaint, filed by Sang Lan, #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. filed by Sang Lan. I recommend granting the plaintiff's motion to voluntarily dismiss this action with prejudice. In addition, Mr. Mo shall have fourteen days from the date of this recommendation to renew the relevant portions of the Third Motion for Rule 11 Sanctions. (As further set forth in this Order.) Objections to R&R due by 11/4/2016 (Signed by Magistrate Judge James C. Francis on 10/18/2016) Copies Sent By Chambers. (cf)
September 16, 2016 Opinion or Order Filing 327 AMENDED ORDER REFERRING CASE TO MAGISTRATE JUDGE. 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 James C. Francis. (Signed by Judge Lorna G. Schofield on 9/16/2016) (kko)
September 9, 2016 Filing 326 REPLY MEMORANDUM OF LAW in Support re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. . Document filed by Sang Lan. (Golaszewski, John)
August 29, 2016 Filing 325 FIRST MEMORANDUM OF LAW in Opposition re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. . Document filed by Hugh Hu Mo. (Medina, Pedro)
August 27, 2016 Filing 324 DECLARATION of Hugh H. Mo in Opposition re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure.. Document filed by Hugh Hu Mo. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K)(Medina, Pedro)
August 27, 2016 Filing 323 FIRST MEMORANDUM OF LAW in Opposition re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. . Document filed by Hugh Hu Mo. (Attachments: #1 Supplement Memorandum Part 2, #2 Supplement Memorandum Part 3)(Medina, Pedro)
August 16, 2016 Filing 322 MEMO ENDORSEMENT on re: #321 Letter filed by Hugh Hu Mo. ENDORSEMENT: Application granted. (Responses due by 8/26/2016, Replies due by 9/9/2016.) (Signed by Magistrate Judge James C. Francis on 8/16/2016) (cf)
August 15, 2016 Filing 321 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Pedro Medina dated August 15, 2016 re: Plaintiff's Motion To Dismiss. Document filed by Hugh Hu Mo.(Medina, Pedro)
August 5, 2016 Filing 320 DECLARATION of John V. Golaszewski, Esq. in Support re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure.. Document filed by Sang Lan. (Golaszewski, John)
August 5, 2016 Filing 319 MEMORANDUM OF LAW in Support re: #318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. . Document filed by Sang Lan. (Golaszewski, John)
August 5, 2016 Filing 318 MOTION to Dismiss Pursuant to Rule 41 of the Rules of Civil Procedure. Document filed by Sang Lan.(Golaszewski, John)
June 22, 2016 Opinion or Order Filing 317 ORDER granting #316 Letter Motion for Conference. As discussed in today's telephone conference, by August 5, 2016, plaintiff shall make any motion to withdraw the action with prejudice; answering papers shall be filed by August 19, 2016 and reply papers by August 26, 2016. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
June 22, 2016 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Telephone Conference held on 6/22/2016. (Bacchus, Michael)
June 7, 2016 Filing 316 LETTER MOTION for Conference Pre-Motion Conference addressed to Judge Analisa Torres from John V. Golaszewski, Esq. dated June 7, 2016. Document filed by Sang Lan.(Golaszewski, John)
June 7, 2016 ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney John Vincent Golaszewski to RE-FILE Document #314 LETTER MOTION for Conference Pre-Motion Conference addressed to Judge Analisa Torres from John V. Golaszewski, Esq. dated June 6, 2016. ERROR(S): Wrong case number on PDF. (db)
June 6, 2016 Filing 315 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated June 6, 2016 re: Response to Plaintiff's counsel's letter dated June 6, 2016. Document filed by Hugh Hu Mo.(Medina, Pedro)
June 6, 2016 Filing 314 FILING ERROR - DEFICIENT DOCKET ENTRY - LETTER MOTION for Conference Pre-Motion Conference addressed to Judge Analisa Torres from John V. Golaszewski, Esq. dated June 6, 2016. Document filed by Sang Lan.(Golaszewski, John) Modified on 6/7/2016 (db).
June 3, 2016 Opinion or Order Filing 313 ORDER granting in part and denying in part #308 Letter Motion for Discovery. This application was held in abeyance while the parties discussed settlement. Now that those discussions are no longer active, the application may be decided. Although Sang Lan's medical condition may have improved, it would still be an undue hardship for her to fly from Beijing to the United States for a deposition. She will therefore be deposed by video in Beijing, and she will bear the costs of the deposition. However, the Liu Defendants' application is granted to the extent that they shall be deposed by video in Nevada and shall be responsible for the costs of that deposition. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
April 18, 2016 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Settlement Conference held on 4/18/2016. (Bacchus, Michael)
April 13, 2016 Filing 312 MEMORANDUM OF LAW in Opposition re: #309 Objection (non-motion), #307 Order, . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Keo-Sung Liu. (Silberstein, Milo)
March 31, 2016 Filing 311 LETTER RESPONSE in Opposition to Motion addressed to Magistrate Judge James C. Francis IV from John V. Golaszewski, Esq. dated March 31, 2016 re: #308 LETTER MOTION for Discovery Sang Lan Deposition Location addressed to Magistrate Judge James C. Francis IV from Milo Silberstein dated March 23, 2016. . Document filed by Sang Lan. (Golaszewski, John)
March 31, 2016 Opinion or Order Filing 310 MEMORANDUM AND ORDER: In a Memorandum and Order dated May 4, 2015, I awarded the defendants in this action $20,627.78 in attorneys' fees and $405.00 in expenses as a sanction for the plaintiff's failure to attend her deposition. (Memorandum and Order dated May 4, 2015 (Fee Assessment Order"). Recently, the plaintiff moved for reconsideration of the Fee Assessment Order. Because the time had long passed for seeking reconsideration, I construed the plaintiff's application as a motion for relief from an order on grounds of mistake or inadvertence pursuant to Rule 60(b)(1) of the Federal Rules of Civil Procedure. I then denied the motion in a Memorandum and Order dated March 16, 2016 ("Reconsideration Order"), in which I found that my calculations in the Fee Assessment Order were consistent with the methodology that I outlined there. The plaintiff has now filed objections to the Reconsideration Order. Because those objections reflect a misunderstanding of the Fee Assessment Order, clarification is appropriate. The plaintiff appears to believe that the only fees allowed under the Fee Assessment Order were those attributable to thirty percent of the time spent by defendants' counsel in deposition preparation. (Plaintiff's Rule 72(a) Objection to the March 16, 2016 Order of Magistrate Judge Francis Fixing the Fees and Costs Awarded Defendants ("Objections") at 1-2). That is not correct. I found that only thirty percent of the time devoted to deposition preparation would be compensated because that preparation would still be largely useful for the rescheduled deposition. (Fee Assessment Order at 3). However, there were a variety of other tasks that counsel performed in anticipation of the aborted deposition that were compensable in full, such as making logistical arrangements for the examination. (Fee Assessment Order at 9). Thus, I first separated compensable from non-compensable work, and then reduced to thirty percent the compensable work that related specifically to deposition preparation. (Fee Assessment Order at 9-101; as further set forth in this Order. (Signed by Magistrate Judge James C. Francis on 3/31/2016) Copies Transmitted By Chambers. (mro) Modified on 4/1/2016 (mro).
March 30, 2016 Filing 309 Objection re: #307 Order, Assessing Sanctions, Pursuant to Fed. R. Civ. P. 72(a). Document filed by Sang Lan. (Golaszewski, John)
March 23, 2016 Filing 308 LETTER MOTION for Discovery Sang Lan Deposition Location addressed to Magistrate Judge James C. Francis IV from Milo Silberstein dated March 23, 2016. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Keo-Sung Liu. (Attachments: #1 Exhibit)(Silberstein, Milo)
March 16, 2016 Opinion or Order Filing 307 MEMORANDUM AND ORDER. Accordingly, the plaintiff's application is denied, and she shall pay to defendants the sanctions awarded in the Fee Assessment Order -- $21,032.78 -- within two weeks of the date of this order. (As further set forth in this Order.) (Signed by Magistrate Judge James C. Francis on 3/16/2016) Copies Sent By Chambers. (adc)
March 14, 2016 Filing 306 LETTER addressed to Magistrate Judge James C. Francis IV from Milo Silberstein dated March 14, 2016 Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Keo-Sung Liu. (Attachments: #1 Exhibit Letter to Judge Francis March 10, 2016, #2 Exhibit Fee Assessment Order, #3 Exhibit Defendant's Memo of Law in Opposition to Plaintiff's Rule 72(a) Objection)(Silberstein, Milo)
March 11, 2016 Opinion or Order Filing 305 ORDER: A pretrial conference having been held on March 10, 2016, it is hereby ORDERED as follows: 1. All discovery shall be completed by July 29, 2016. 2. The pretrial order shall be submitted by August 31, 2016, unless any dispositive motion is filed by that date. If such a motion is filed, the pretrial order shall be due thirty days after the motion is decided. (Discovery due by 7/29/2016., Pretrial Order due by 8/31/2016.) (Signed by Magistrate Judge James C. Francis on 3/11/2016) (cf)
March 10, 2016 Filing 304 LETTER addressed to Magistrate Judge James C. Francis IV from John V. Golaszewski, Esq. dated March 10, 2016 re: Fee Assessment Order. Document filed by Sang Lan. (Attachments: #1 Exhibit A-E)(Golaszewski, John)
March 10, 2016 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Interim Pretrial Conference held on 3/10/2016. (Bacchus, Michael)
March 3, 2016 Opinion or Order Filing 303 ORDER granting #255 Motion to Withdraw as Attorney. Accordingly, the Movants' application to withdraw as counsel for Plaintiff, (ECF No. 255), is granted, and the Defendants' application to unseal portions of the Movants' papers in support of that application, (ECF No. 280), is denied. (As further set forth in this Order.) Attorney X. Bing Xu terminated (Signed by Magistrate Judge Frank Maas on 3/3/2016) (cf)
February 26, 2016 Filing 302 FIRST LETTER addressed to Magistrate Judge Frank Maas from Hugh H. Mo dated February 26, 2016 re: Motion to Withdraw. Document filed by Hugh Hu Mo.(Medina, Pedro)
February 9, 2016 Opinion or Order Filing 301 MEMORANDUM AND ORDER re: #216 Order on Motion for Sanctions. For the reasons stated above, the Court affirms the R & R to the extent that it recommends monetary sanctions, but sustains Plaintiff's objection to the imposition of joint and several liability against her counsel. Defendants shall be awarded reasonable expenses, including attorneys' fees, incurred by them in scheduling and preparing for Plaintiff's deposition, in an amount to be determined by Judge Francis. (As further set forth in this Order.) (Signed by Judge Analisa Torres on 2/9/2016) (kko)
February 9, 2016 Opinion or Order Filing 300 MEMORANDUM AND ORDER for #215 Report and Recommendation. The Court ADOPTS the R&R in its entirety. For the reasons stated above, the Court accepts in full Magistrate Judge Francis' Report and Recommendation, and rejects Plaintiff's objections pursuant to Rule 72 of the Federal Rules of Civil Procedure. Plaintiff's request for voluntary dismissal without prejudice is DENIED. The Clerk of Court is directed to reopen the case. Case reopened. (As further set forth in this Order.) (Signed by Judge Analisa Torres on 2/9/2016) (kko)
January 27, 2016 Opinion or Order Filing 299 CONSENT ORDER GRANTING SUBSTITUTION OF ATTORNEY: Notice is hereby given that, subject to approval by the court, Kao-Sung Liu and Gina Liu substitutes Milo Silbertstein, Dealy Silberstein & Braverman, LLP, State Bar No. 2814382 as counsel of record in place of The Law Firm of Hugh H. Mo, P.C. Attorney Pedro Medina, Jr and Hugh Hu Mo terminated. (Signed by Judge Analisa Torres on 1/27/2016) (mro)
January 22, 2016 Filing 298 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated January 22, 2016 re: Substitution of Counsel. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Appendix)(Medina, Pedro)
January 20, 2016 Filing 297 NOTICE OF APPEARANCE by Milo Silberstein on behalf of Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Keo-Sung Liu. (Silberstein, Milo)
January 20, 2016 Filing 296 NOTICE OF APPEARANCE by Maria Louisa Bianco on behalf of Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Keo-Sung Liu. (Bianco, Maria Louisa)
January 12, 2016 Opinion or Order Filing 295 MEMO ENDORSEMENT on re: #291 LETTER addressed to Magistrate Judge James C. Francis IV from John V. Golaszewski, Esq. dated January 8, 2016 re: Request for Conference. ENDORSEMENT: Application denied without prejudice to renewal once the Court rules on objections to my Feb. 5, 2015 Report and Recommendation. SO ORDERED. (Signed by Magistrate Judge James C. Francis on 1/11/2016) (adc)
January 8, 2016 Filing 294 SECOND LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated January 8, 2016 re: Response to Plaintiff's counsel's second letter dated January 8, 2016. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
January 8, 2016 Filing 293 SECOND LETTER addressed to Magistrate Judge James C. Francis IV from John V. Golaszewski, Esq. dated January 8, 2016 re: Request for Conference. Document filed by Sang Lan.(Golaszewski, John)
January 8, 2016 Filing 292 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated January 8, 2015 re: Response to Plaintiff's counsel's letter dated January 8, 2016. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
January 8, 2016 Filing 291 LETTER addressed to Magistrate Judge James C. Francis IV from John V. Golaszewski, Esq. dated January 8, 2016 re: Request for Conference. Document filed by Sang Lan.(Golaszewski, John)
July 13, 2015 Opinion or Order Filing 290 MEMORANDUM AND ORDER denying #257 Motion for Sanctions: that the defendants' motion (Docket no. 257) is denied without prejudice; the cross-motions of the plaintiff and her counsel (Docket nos. 281 and 283) are denied as moot. (Signed by Magistrate Judge James C. Francis on 7/13/2015) Copies Transmitted By Chambers. (tn)
June 22, 2015 Filing 289 DECLARATION of Hugh H. Mo in Support re: #257 THIRD MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G)(Medina, Pedro)
June 22, 2015 Filing 288 FIRST REPLY MEMORANDUM OF LAW in Support re: #257 THIRD MOTION for Sanctions pursuant to Rule 11. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
June 17, 2015 Filing 287 MEMO ENDORSEMENT on re: #286 Letter, filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu. ENDORSEMENT: Defendants' reply may consist of up to 20 pages. (Signed by Magistrate Judge James C. Francis on 6/17/2015) (tn) (Main Document 287 replaced on 6/17/2015) (tn).
June 16, 2015 Filing 286 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Pedro Medina dated June 16, 2015 re: Request to File Over sized Reply Memorandum of Law. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
June 12, 2015 Opinion or Order Filing 285 ORDER: By letter dated June 10, 2015, Plaintiff requests to: (1) submit to the Court un-redacted copies of Plaintiff's memorandum of law and supporting documents in opposition to Defendants' third Rule 11 motion; and (2) remove her May 27, 2015 letter from the public docket. The Rule 11 motion is before the Honorable James C. Francis. Plaintiff's request to submit un-redacted documents to this Court is DENIED. Plaintiff's request to remove her May 27, 2015 letter from the public docket is DENIED. "Documents may be sealed if specific, on the record findings are made demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest." Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (quoting In re New York Times Co., 828 F.3d 110, 116 (2d Cir. 1987)). Although Plaintiff provided legal justification for the proposed sealing of portions of her opposition to the Rule 11 motion, she provided no basis to justify sealing the May 27, 2015 letter. As the Court has reminded Plaintiff on several occasions, this case is currently before Judge Francis for general pretrial proceedings. Plaintiff shall include Judge Francis on all correspondence and communications with the Court. Plaintiff is warned that failure to comply with the Court's directives may result in sanctions. SO ORDERED. (Signed by Judge Analisa Torres on 6/12/2015) (ajs)
June 12, 2015 Filing 284 LETTER addressed to Judge Analisa Torres from X. Bing Xu, Thomas L. Johnson dated 6/10/2015 re: Request to seal Dkt. No. 270. (ajs)
June 10, 2015 Filing 283 THIRD MEMORANDUM OF LAW in Opposition re: #257 THIRD MOTION for Sanctions pursuant to Rule 11. On Behalf of Plaintiff Sang Lan. Document filed by Sang Lan. (Golaszewski, John)
June 10, 2015 Filing 282 DECLARATION of X. Bing Xu, Esquire in Opposition re: #257 THIRD MOTION for Sanctions pursuant to Rule 11.. Document filed by Sang Lan. (Attachments: #1 Exhibit G)(Xu, X. Bing)
June 10, 2015 Filing 281 MEMORANDUM OF LAW in Opposition re: #257 THIRD MOTION for Sanctions pursuant to Rule 11. and Cross Motion for Rule 11 Sanction Against Defendants and Hugh Mo Esquire, Pedro Medina Esquire and Law Office of Hugh Mo P.C.. Document filed by Sang Lan. (Xu, X. Bing)
June 5, 2015 Filing 280 FIRST MEMORANDUM OF LAW in Opposition re: #255 MOTION for Bing Xu, Esquire and Thomas Johnson, Esquire to Withdraw as Attorney . Response to Motion. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
June 3, 2015 Filing 279 REPLY MEMORANDUM OF LAW re: #268 Objection (non-motion) to Order Assessing Fees and Costs. Document filed by Sang Lan. (Golaszewski, John)
June 2, 2015 Filing 278 ENDORSED LETTER re: #257 THIRD MOTION for Sanctions pursuant to Rule 11. filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu addressed to Magistrate Judge James C. Francis IV from X. Bing Xu dated 5/29/2015 re: Co-counsel to plaintiff Sang Lan requests a reasonable extension to the briefing schedule proposed by Plaintiff and her counsel, and grant counsel's motion for leave to file documents referred to in his motion papers for in camera examination. ENDORSEMENT: Plaintiff's and her counsel's Application to file certain documents or portions thereof under seal is hereby granted. Plaintiff shall respond Defendant Rule 11 Motion on or before June 10, 2015 Plaintiff's counsel shall respond Defendants' Rule 11 Motion on or before June 10, 2015 Defendants shall file their reply on or before June 22, 2015. Set Deadlines/Hearing as to #257 THIRD MOTION for Sanctions pursuant to Rule 11: Responses due by 6/10/2015, Replies due by 6/22/2015. (Signed by Magistrate Judge James C. Francis on 6/1/2015) (tn)
June 1, 2015 Filing 277 DECLARATION of Sang Lan in Support re: #255 MOTION for Bing Xu, Esquire and Thomas Johnson, Esquire to Withdraw as Attorney .. Document filed by Sang Lan. (Xu, X. Bing)
June 1, 2015 Filing 276 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated June 1, 2015 re: Response to Plaintiff's counsel's letter dated May 29, 2015. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
May 29, 2015 Filing 275 DECLARATION of X. Bing Xu, Esquire in Support re: #255 MOTION for Bing Xu, Esquire and Thomas Johnson, Esquire to Withdraw as Attorney .. Document filed by Sang Lan. (Attachments: #1 Exhibit A-G)(Xu, X. Bing)
May 29, 2015 Filing 274 MEMORANDUM OF LAW in Support re: #255 MOTION for Bing Xu, Esquire and Thomas Johnson, Esquire to Withdraw as Attorney . . Document filed by Sang Lan. (Xu, X. Bing)
May 29, 2015 Filing 273 FIRST LETTER addressed to Judge Analisa Torres from Pedro Medina dated May 29, 2015 re: Defendants' Opposition to Plaintiff's Rule 72(a) Objections. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
May 28, 2015 Filing 272 FIRST MEMORANDUM OF LAW in Opposition re: #268 Objection (non-motion) to Magistrate Judge Francis' May 4, 2015 Memorandum and Order. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
May 28, 2015 Opinion or Order Filing 271 ORDER: By letter dated May 27, 2015, Plaintiff requests that the Court deny or stay determination of the Rule 11 motion until the end of litigation, adjust the briefing schedule for the Rule 11 motion, and permit Plaintiff to file her motion papers under seal. This case is currently before the Honorable James C. Francis IV for general pretrial proceedings. Plaintiff's requests are DENIED without prejudice to renewal before Judge Francis. With respect to communications with this Court, Plaintiff shall file all letters electronically on ECF or shall request to file under seal in accordance with Paragraph IV.A of this Court's Individual Practices in Civil Cases. SO ORDERED. (Signed by Judge Analisa Torres on 5/28/2015) (ajs)
May 28, 2015 Filing 270 LETTER addressed to Judge Analisa Torres from X. Bing Xu, Thomas L. Johnson dated 5/27/2015 re: Correspondence under seal. (ajs)
May 28, 2015 Filing 269 LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated 5/1/2014 re: We write in response to the letter, dated April 30, 2014, from plaintiff Sang Lan's attorney, X. Bing Xu, reporting on plaintiff's medical condition and asserting her current inability to participate in discovery in this case at the present time. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(lmb)
May 21, 2015 Filing 268 Objection re: #254 Order, Assessing Fees and Costs. Document filed by Sang Lan. (Golaszewski, John)
May 20, 2015 Opinion or Order Filing 267 ORDER. It is hereby ORDERED that by May 29, 2015, The Bing Law Firm shall file redacted versions of its papers in support of its Motion to Withdraw, (ECF No. 255), and shall file under seal and deliver to my Chambers unredacted versions of those papers. Furthermore, by June 8, 2015, counsel for the Defendants shall file any opposition papers. (Responses due by 6/8/2015) (Signed by Magistrate Judge Frank Maas on 5/20/2015) Copies Sent By Chambers via Fax. (rjm)
May 20, 2015 Transmission to Sealed Records Clerk. Transmitted re: #267 Order, Set Deadlines to the Sealed Records Clerk for the sealing or unsealing of document or case. (rjm)
May 20, 2015 Minute Order Proceedings held before Magistrate Judge Frank Maas: Telephone Conference held on 5/20/2015. (mo)
May 18, 2015 Filing 266 ENDORSED LETTER addressed to Magistrate Judge Frank Maas from X. Bing Xu and Thomas L. Johnson dated 5/15/2015 re: Telephone Conference. ENDORSEMENT: Approved. (Telephone Conference set for 5/20/2015 at 11:00 AM before Magistrate Judge Frank Maas.) (Signed by Magistrate Judge Frank Maas on 5/18/2015) (kko)
May 18, 2015 Opinion or Order Filing 265 ORDER denying #263 Letter Motion for Conference: Plaintiff's request for a conference is DENIED. However, Plaintiff may renew this request before Judge Francis. (HEREBY ORDERED by Judge Analisa Torres)(Text Only Order) (Torres, Analisa)
May 18, 2015 Filing 264 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated May 18, 2015 re: Response to Plaintiff's counsel's letter dated May 15, 2015. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
May 15, 2015 Filing 263 LETTER MOTION for Conference addressed to Judge Analisa Torres from John V. Golaszewski, Esq. dated May 15, 2015. Document filed by Sang Lan.(Golaszewski, John)
May 15, 2015 Filing 262 CERTIFICATE OF SERVICE of Notice of Motion for Sanctions Against Plaintiff; Defendants' Memorandum of Law in Support of Motion for Sanctions; Declaration of Hugh H. Mo, dated May 15, 2015; Declaration of K.S. Liu, dated November 17, 2014 served on Plaintiff Sang Lan on May 15, 2015. Service was made by Mail. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
May 15, 2015 Opinion or Order Filing 261 ORDER: The Court has received correspondence concerning The Bing Law Firm's motion to withdraw from further representation of plaintiff Sang Lan. Judges Torres and Francis have agreed that I will rule with respect to that motion. Since the circumstances are somewhat unusual, I wish to hold a telephone conference to discuss the procedure we will follow. Counsel therefore are directed to place a conference call to my Chambers by May 20, 2015, to arrange a mutually convenient date for the conference. All counsel of record will be required to participate in the telephone conference. (Signed by Magistrate Judge Frank Maas on 5/14/2015) Copies Sent By Chambers. (lmb)
May 15, 2015 Filing 260 DECLARATION of Kao-Sung Liu in Support re: #257 THIRD MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Hugh Mo. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M)(Medina, Pedro)
May 15, 2015 Filing 259 DECLARATION of Hugh H. Mo in Support re: #257 THIRD MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, Pt. 1, #8 Exhibit Exhibit G, Pt. 2, #9 Exhibit Exhibit G, Pt. 3, #10 Exhibit Exhibit G, Pt. 4, #11 Exhibit Exhibit G, Pt. 5, #12 Exhibit Exhibit G, Pt. 6, #13 Exhibit Exhibit G, Pt. 7, #14 Exhibit Exhibit G, Pt. 8, #15 Exhibit Exhibit G, Pt. 9, #16 Exhibit Exhibit G, Pt. 10, #17 Exhibit Exhibit H, #18 Exhibit Exhibit I, #19 Exhibit Exhibit J, #20 Exhibit Exhibit K, #21 Exhibit Exhibit L, #22 Exhibit Exhibit M)(Medina, Pedro)
May 15, 2015 Filing 258 FIRST MEMORANDUM OF LAW in Support re: #257 THIRD MOTION for Sanctions pursuant to Rule 11. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
May 15, 2015 Filing 257 THIRD MOTION for Sanctions pursuant to Rule 11. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
May 13, 2015 Filing 256 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated May 13, 2015 re: Unsealing of Declaration and Exhibits of Plaintiff's attorneys' Notice of Motion to Withdraw. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu.(Mo, Hugh)
May 12, 2015 Filing 255 MOTION for Bing Xu, Esquire and Thomas Johnson, Esquire to Withdraw as Attorney . Document filed by Sang Lan.(Xu, X. Bing)
May 4, 2015 Opinion or Order Filing 254 MEMORANDUM AND ORDER: The inordinate time spent by counsel in litigating this fee issue is symptomatic of the waste of resources in this litigation. Based on reductions in the requested fees to reflect non-compensable time, the defendants are awarded $20,627.78 in attorneys' fees and $405.00 in expenses, for a total of $21,032.78. SO ORDERED. (Signed by Magistrate Judge James C. Francis on 5/4/2015) Copies Sent by Chambers. (ajs)
April 24, 2015 Filing 253 REPLY MEMORANDUM OF LAW in Support re: #237 Objection (non-motion), #251 Memorandum of Law in Opposition, . Document filed by Sang Lan. (Xu, X. Bing)
April 17, 2015 Filing 252 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated April 17, 2015 re: Defendants' Opposition to Plaintiff's Rule 72(a) Objections. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
April 17, 2015 Filing 251 FIRST MEMORANDUM OF LAW in Opposition re: #237 Objection (non-motion) . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Appendix Appendix A, #2 Appendix Appendix B, #3 Appendix Appendix C)(Medina, Pedro)
April 2, 2015 Opinion or Order Filing 250 ORDER: Having reviewed the parties' letters dated April 1, 2015, it is ORDERED that Defendants shall submit opposition papers by April 17, 2015, and Plaintiff shall submit reply papers by April 24, 2015. SO ORDERED. (Signed by Judge Analisa Torres on 4/2/2015) (ajs)
April 1, 2015 Filing 249 LETTER addressed to Judge Analisa Torres from Bing Xu, Esquire and Thomas Johnson, Esquire dated 4/1/2015 re: Response to Defendants 2d Letter. Document filed by Sang Lan.(Xu, X. Bing)
April 1, 2015 Filing 248 SECOND LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated April 1, 2015 re: Proposed Briefing Schedule. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
April 1, 2015 Filing 247 LETTER addressed to Judge Analisa Torres from bing Xu, Esquire and Thomas Johnson, Esquire dated 4/1/2015 re: Mr. Mo's Letter dkt 246 4/1/201. Document filed by Sang Lan.(Xu, X. Bing)
April 1, 2015 Filing 246 FIRST LETTER addressed to Judge Analisa Torres from Hugh H. Mo dated April 1, 2015 re: Proposed Briefing Schedule. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
March 26, 2015 Filing 245 MEMO ENDORSEMENT on re: #244 Letter filed by Sang Lan. ENDORSEMENT: Application denied without prejudice to renewal when the merits of this case are ultimately decided. (Signed by Magistrate Judge James C. Francis on 3/26/2015) (tn)
March 25, 2015 Filing 244 LETTER addressed to Magistrate Judge James C. Francis IV from Bing Xu, Esquire and Thomas Johnson, Esquire dated 3/25/2015 re: Def. Notice of Withdrawal of Rule 11 Motion. Document filed by Sang Lan.(Xu, X. Bing)
March 25, 2015 Opinion or Order Filing 243 ORDER withdrawing #219 Motion for Sanctions. Defendants have withdrawn the motion without prejudice to submitting a subsequent application for sanctions. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
March 24, 2015 Filing 242 NOTICE of Withdrawal of Motion re: #219 SECOND MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
March 20, 2015 Filing 241 MEMORANDUM OF LAW in Opposition re: #219 SECOND MOTION for Sanctions pursuant to Rule 11. . Document filed by Sang Lan. (Attachments: #1 Affidavit Sang Lan Decl. in support, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C)(Xu, X. Bing)
March 20, 2015 Filing 240 FIRST MEMORANDUM OF LAW in Support of Defendants' Application for Attorneys Fees and Costs. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu. (Mo, Hugh)
March 13, 2015 Filing 239 DECLARATION of Bing Xu, Esquire in Opposition re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Sang Lan. (Attachments: #1 Exhibit A1 Summary, #2 Exhibit A2 140717 bill, #3 Exhibit A3 141030 bill, #4 Exhibit A4 141124 bill)(Xu, X. Bing)
March 13, 2015 Filing 238 RESPONSE in Opposition to Motion re: #206 FIRST MOTION for Sanctions pursuant to Rule 37. objection to refiled doc 217. Document filed by Sang Lan. (Attachments: #1 Affidavit Declaration of Bing Xu, Esquire, #2 Exhibit A1 summary, #3 Exhibit A2 140717 bill, #4 Exhibit A3 141030 bill)(Xu, X. Bing)
March 11, 2015 Filing 237 Objection re: #216 Order on Motion for Sanctions, . Document filed by Sang Lan. (Xu, X. Bing)
March 4, 2015 Filing 236 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from X. Bing Xu dated 3/4/2015 re: Counsel requests that the Court grant the request for a 10 day, or any brief and reasonable extension the Court deems necessary and appropriate, to respond to Defendant's Rule 11 motion. ENDORSEMENT: Plaintiff's Application is hereby granted. Plaintiff shall respond Defendants Rule 11 Motion on or before 3/20/15; Defendant shall file their reply on or before 3/27/15. Set Deadlines/Hearing as to #219 SECOND MOTION for Sanctions pursuant to Rule 11: Responses due by 3/20/2015, Replies due by 3/27/2015. (Signed by Magistrate Judge James C. Francis on 3/4/2015) (tn) Modified on 3/4/2015 (tn). Modified on 4/1/2015 (tn).
March 3, 2015 Filing 235 DECLARATION of Hugh H. Mo re: #234 Response, #223 Objection to Report and Recommendations . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B)(Medina, Pedro)
March 3, 2015 Filing 234 FIRST RESPONSE re: #223 Objection to Report and Recommendations . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
February 27, 2015 Filing 233 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from X. Bing Xu, and Thomas L. Johnson dated 2/26/2015 re: Counsel request a conference, either in person or via telephone, with the Court such that we may discuss outstanding discovery, and set a new discovery timeline. ENDORSEMENT: Plaintiff shall respond to the fee affidavit by March 13, 2015, and defendants shall reply by March 20, 2015. Plaintiff has filed an objection to the Report & Recommendation that recommended denial of the motion to dismiss without prejudice. It would be premature to set any further discovery schedule until the objection is ruled upon. (Signed by Magistrate Judge James C. Francis on 2/27/2015) (tn)
February 27, 2015 Filing 232 LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated February 27, 2015 re: Response to Plaintiff's counsel's letter dated February 26, 2015. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
February 27, 2015 Opinion or Order Filing 231 ORDER denying #224 Motion for Reconsideration. Plaintiff has failed to identify any controlling case law or factual information on the record that the Court overlooked. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
February 26, 2015 Filing 230 NOTICE OF APPEARANCE by Brian Patrick Fredericks on behalf of Sang Lan. (Fredericks, Brian)
February 26, 2015 Filing 229 NOTICE OF APPEARANCE by Allan Steven Schiller on behalf of Sang Lan. (Schiller, Allan)
February 26, 2015 Filing 228 NOTICE OF APPEARANCE by John Vincent Golaszewski on behalf of Sang Lan. (Golaszewski, John)
February 24, 2015 Filing 227 AFFIDAVIT OF SERVICE of Defendants' Memorandum of Law in Opposition to Plaintiff's Motion to Reconsider served on X. Bing Xu on February 24, 2015. Service was made by Mail. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu. (Mo, Hugh)
February 23, 2015 Filing 226 FIRST MEMORANDUM OF LAW in Opposition re: #224 MOTION for Reconsideration re; #216 Order on Motion for Sanctions, . . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Appendix Appendix A, #2 Appendix Appendix B)(Medina, Pedro)
February 19, 2015 Filing 225 MEMORANDUM OF LAW in Support re: #224 MOTION for Reconsideration re; #216 Order on Motion for Sanctions, . . Document filed by Sang Lan. (Xu, X. Bing)
February 19, 2015 Filing 224 MOTION for Reconsideration re; #216 Order on Motion for Sanctions, . Document filed by Sang Lan.(Xu, X. Bing)
February 19, 2015 Filing 223 OBJECTION to #215 Report and Recommendations with incorporated Memorandum of Law Document filed by Sang Lan. (Xu, X. Bing)
February 18, 2015 Filing 222 DECLARATION of Hugh H. Mo in Support re: #219 SECOND MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H (Part 1), #9 Exhibit Exhibit H (Part 2), #10 Exhibit Exhibit H (Part 3), #11 Exhibit Exhibit H (Part 4), #12 Exhibit Exhibit H (Part 5), #13 Exhibit Exhibit H (Part 6), #14 Exhibit Exhibit H (Part 7), #15 Exhibit Exhibit H (Part 8), #16 Exhibit Exhibit H (Part 9), #17 Exhibit Exhibit H (Part 10), #18 Exhibit Exhibit I, #19 Exhibit Exhibit J, #20 Exhibit Exhibit K, #21 Exhibit Exhibit L)(Medina, Pedro)
February 18, 2015 Filing 221 FIRST MEMORANDUM OF LAW in Support re: #219 SECOND MOTION for Sanctions pursuant to Rule 11. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
February 18, 2015 Filing 220 DECLARATION of Kao-Sung Liu in Support re: #219 SECOND MOTION for Sanctions pursuant to Rule 11.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M)(Medina, Pedro)
February 18, 2015 Filing 219 SECOND MOTION for Sanctions pursuant to Rule 11. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
February 18, 2015 Filing 218 AFFIDAVIT OF SERVICE of Defendants' Affidavit for Costs and Attorneys' Fees Pursuant to Rule 37 Sanctions served on X. Bing Xu on February 18, 2015. Service was made by Mail. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu, Hugh Mo. (Mo, Hugh)
February 18, 2015 Filing 217 AFFIDAVIT of Hugh H. Mo For Costs and Attorneys' Fees Pursuant to Rule 37 Sanctions. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu, Hugh Mo. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Mo, Hugh)
February 5, 2015 Opinion or Order Filing 216 MEMORANDUM AND ORDER granting in part and denying in part #206 Motion for Sanctions: For the foregoing reasons, the defendants' motion for Rule 37 sanctions (Docket no. 206) is granted with respect to monetary sanctions and denied with respect to terminating sanctions. (Signed by Magistrate Judge James C. Francis on 2/5/2015) Copies Mailed By Chambers. (tn)
February 5, 2015 Filing 215 REPORT AND RECOMMENDATION: For the foregoing reasons, dismissal without prejudice at this juncture would be improper. I therefore recommend that the plaintiff's motion to dismiss without prejudice be denied and that the Clerk of Court be directed to re-open the case, which was closed upon the filing of the ineffective notice of voluntary dismissal. Pursuant to 28 U.S.C. 636(b)(1) and Rules 72, 6(a), and 6(d) of the Federal Rules of Civil Procedure, the parties shall have fourteen (14) days from this date to file written objections to this Report and Recommendation. Such objections shall be filed with the Clerk of the Court, with extra copies delivered to the chambers of the Honorable Analisa Torres, Room 2210, and to the chambers of the undersigned, Room 1960, 500 Pearl Street, New York, New York 10007. Failure to file timely objections will preclude appellate review. Objections to R&R due by 2/23/2015 (Signed by Magistrate Judge James C. Francis on 2/5/2015) Copies Mailed By Chambers. (tn) Modified on 2/26/2015 (tn).
November 17, 2014 Filing 214 FIRST REPLY MEMORANDUM OF LAW in Support re: #206 FIRST MOTION for Sanctions pursuant to Rule 37. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
November 17, 2014 Filing 213 DECLARATION of Hugh H. Mo in Support re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M, #14 Exhibit Exhibit N, #15 Exhibit Exhibit O, #16 Exhibit Exhibit P, #17 Exhibit Exhibit Q, #18 Exhibit Exhibit R, #19 Exhibit Exhibit S, #20 Exhibit Exhibit T, #21 Exhibit Exhibit U, #22 Exhibit Exhibit V, #23 Exhibit Exhibit W, #24 Exhibit Exhibit X, #25 Exhibit Exhibit Y, #26 Exhibit Exhibit Z, #27 Exhibit Exhibit AA, #28 Exhibit Exhibit BB, #29 Exhibit Exhibit CC, #30 Exhibit Exhibit DD, #31 Exhibit Exhibit EE, #32 Exhibit Exhibit FF, #33 Exhibit Exhibit GG, #34 Exhibit Exhibit HH, #35 Exhibit Exhibit II, #36 Exhibit Exhibit JJ)(Medina, Pedro)
November 17, 2014 Filing 212 DECLARATION of Kao-Sung Liu in Support re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M)(Medina, Pedro)
November 10, 2014 Filing 211 DECLARATION of ZHENXING SUN in Opposition re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Sang Lan. (Xu, X. Bing)
November 10, 2014 Filing 210 DECLARATION of Sang Lan in Opposition re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit C1, #5 Exhibit c2, #6 Exhibit c3, #7 Exhibit c4, #8 Exhibit D, #9 Exhibit E, #10 Exhibit F, #11 Exhibit G, #12 Exhibit H, #13 Exhibit I, #14 Exhibit J, #15 Exhibit K, #16 Exhibit L, #17 Exhibit M, #18 Exhibit N, #19 Exhibit O, #20 Exhibit P, #21 Exhibit Q, #22 Exhibit R, #23 Exhibit S, #24 Exhibit T, #25 Exhibit U, #26 Exhibit V, #27 Exhibit W, #28 Exhibit X, #29 Exhibit Y, #30 Exhibit Z, #31 Exhibit AA, #32 Exhibit BB, #33 Exhibit CC, #34 Exhibit DD, #35 Exhibit EE, #36 Exhibit FF, #37 Exhibit GG, #38 Exhibit HH, #39 Exhibit II, #40 Exhibit JJ)(Xu, X. Bing)
November 10, 2014 Filing 209 MEMORANDUM OF LAW in Opposition re: #206 FIRST MOTION for Sanctions pursuant to Rule 37., #202 FIRST LETTER MOTION for Conference re: #200 Memo Endorsement, #201 Notice of Voluntary Dismissal,, requesting leave to file motion to dismiss Fourth Amended Complaint with prejudice addressed to Judge Analisa Torres from Hugh H. Mo date 11/10/2014. Document filed by Sang Lan. (Xu, X. Bing)
October 24, 2014 Filing 208 DECLARATION of Hugh H. Mo in Support re: #206 FIRST MOTION for Sanctions pursuant to Rule 37.. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I, #10 Exhibit Exhibit J, #11 Exhibit Exhibit K, #12 Exhibit Exhibit L, #13 Exhibit Exhibit M, #14 Exhibit Exhibit N, #15 Exhibit Exhibit O, #16 Exhibit Exhibit P, #17 Exhibit Exhibit Q, #18 Exhibit Exhibit R, #19 Exhibit Exhibit S, #20 Exhibit Exhibit T, #21 Exhibit Exhibit U, #22 Exhibit Exhibit V, #23 Exhibit Exhibit W)(Medina, Pedro)
October 24, 2014 Filing 207 FIRST MEMORANDUM OF LAW in Support re: #206 FIRST MOTION for Sanctions pursuant to Rule 37. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
October 24, 2014 Filing 206 FIRST MOTION for Sanctions pursuant to Rule 37. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
October 21, 2014 Filing 205 MEMO ENDORSEMENT on re: #204 Letter, filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu. ENDORSEMENT: The schedule set forth above is adopted. (Motions due by 10/24/2014. Responses due by 11/10/2014. Replies due by 11/17/2014.) (Signed by Magistrate Judge James C. Francis on 10/21/2014) (tn)
October 20, 2014 Filing 204 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated October 20, 2014 re: Briefing Schedule Regarding Motion Pursuant to Rule 37. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
October 16, 2014 Opinion or Order Filing 203 ORDER OF REFERENCE A MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Dispositive Motion (i.e., motion requiring a Report and Recommendation): Motion to dismiss with prejudice (as discussed in Defendants' October 15, 2014 letter). Specific Non-Dispositive Motion/Dispute - Any additional relief sought in Defendants' October 15, 2014 letter. Referred to Magistrate Judge James C. Francis. (Signed by Judge Analisa Torres on 10/15/2014) (ajs)
October 15, 2014 Filing 202 FIRST LETTER MOTION for Conference re: #200 Memo Endorsement, #201 Notice of Voluntary Dismissal,, requesting leave to file motion to dismiss Fourth Amended Complaint with prejudice addressed to Judge Analisa Torres from Hugh H. Mo dated October 15, 2014. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B)(Medina, Pedro)
October 11, 2014 Filing 201 NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, Without prejudice against the defendant(s) Does 1-30, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, John Does and Jane Does #1 through 15, Inclusive, Keo-Sung Liu, Hugh Mo. Document filed by Sang Lan. (Xu, X. Bing)
October 10, 2014 Filing 200 MEMO ENDORSEMENT on re: #199 Letter, filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu. ENDORSEMENT: Application granted. This resolves docket no. 199. (Signed by Magistrate Judge James C. Francis on 10/10/2014) (djc)
October 10, 2014 Set/Reset Deadlines: Deposition due by 10/16/2014. (djc)
October 9, 2014 Filing 199 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Pedro Medina dated October 9, 2014 re: Direct Plaintiff's Attendance For Her Deposition. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F)(Medina, Pedro)
October 2, 2014 Opinion or Order Filing 198 ORDER denying #197 Letter Motion for Extension of Time to Complete Discovery. The party depositions should long since have been scheduled, and there is still a month to complete them. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
October 1, 2014 Filing 197 LETTER MOTION for Extension of Time to Complete Discovery addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated October 1, 2014. Document filed by Gina Hiu-Hung Liu(individually), Hugh Hu Mo, Keo-Sung Liu.(Mo, Hugh)
September 23, 2014 Opinion or Order Filing 196 ORDER denying #193 Letter Motion for Conference. The requested relief is not warranted. There is no basis for a stay of discovery that would further delay resolution of this case. Plaintiff has complied with my July 30, 2014 Order by matching her production to defendants' discovery requests. To the extent that the production demonstrates that plaintiff has no factual basis for her claims, that issue will be adjudicated in any Rule 11 motion and/or motion for summary judgment. At the same time, plaintiff's suggestion that she may decline to proffer the relevance of information she has produced on the ground that it is attorney work product is frivolous. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
September 19, 2014 Filing 195 LETTER RESPONSE in Support of Motion addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 19, 2014 re: #193 FOURTH LETTER MOTION for Conference re: #189 Memo Endorsement, Set Deadlines/Hearings,, #187 Order,,,,, addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 10, 2014. . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H)(Medina, Pedro)
September 18, 2014 Filing 194 LETTER RESPONSE in Opposition to Motion addressed to Magistrate Judge James C. Francis IV from Bing Xu, Esquire dated 9/18/2014 re: #193 FOURTH LETTER MOTION for Conference re: #189 Memo Endorsement, Set Deadlines/Hearings,, #187 Order,,,,, addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 10, 2014. . Document filed by Sang Lan. (Attachments: #1 Exhibit Liu statement: fight to the end, #2 Exhibit Mo press release 9/9/14, #3 Exhibit Liu Blog 9/9/14)(Xu, X. Bing)
September 10, 2014 Filing 193 FOURTH LETTER MOTION for Conference re: #189 Memo Endorsement, Set Deadlines/Hearings,, #187 Order,,,,, addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 10, 2014. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H)(Medina, Pedro)
September 10, 2014 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - NON-ECF DOCUMENT ERROR. Note to Attorney Pedro Medina. Document No. #191 Letter. This document is not filed via ECF. The Court permits the filing of letters including certain types of letter motions, a Motion to Stay must be formally filed. (db)
September 8, 2014 Filing 192 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 8, 2014 re: Rule 11 Safe Harbor. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, John Does and Jane Does #1 through 15, Inclusive, Sang Lan, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G)(Medina, Pedro)
September 8, 2014 Filing 191 FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - THIRD LETTER MOTION for Conference re: #189 Memo Endorsement, Set Deadlines/Hearings,, #187 Order,,,,, addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated September 8, 2014. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H)(Medina, Pedro) Modified on 9/10/2014 (db).
August 15, 2014 Filing 190 NOTICE of Service of Addition Documents and responses re: #187 Order,,,,,. Document filed by Sang Lan. (Xu, X. Bing)
August 14, 2014 Opinion or Order Filing 189 MEMO ENDORSEMENT on #188 Letter, filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu. ENDORSEMENT: Application granted. (Discovery due by 10/31/2014. Pretrial Order due by 11/29/2014.) (Signed by Magistrate Judge James C. Francis on 8/13/2014) (cd) Modified on 8/18/2014 (cd).
August 1, 2014 Filing 188 LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated August 1, 2014 re: Discovery. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
July 30, 2014 Opinion or Order Filing 187 ORDER: It is hereby ORDERED as follows: 1. By August 15, 2014, plaintiff shall produce all documents requested in the Individual Defendants' First Request for Production of Documents to Plaintiff Sang Lan ("Defendants' Document Request"). 2. By August 15, 2014, plaintiff shall propound written responses to Defendants' Document Request in which plaintiff specifically identifies by bates number which documents are responsive to each document request. While Rule 34 of the Federal Rules of Civil Procedure permits a party to produce documents as kept in the regular course of business, that rule nevertheless "requires responding parties to provide documents in some kind of organized, indexed fashion rather than as a mass of undifferentiated, unlabeled data." Where, as here, documents are maintained in a wholly disorganized manner, the responding party cannot simply produce them in the same way. 3. By August 15, 2014, plaintiff shall provide amended answers to Individual Defendants' First Set of Interrogatories to Plaintiff Sang Lan that properly respond to each interrogatory and do not simply refer defendants to plaintiff's entire document production. 4. Failure to comply with this order shall result in sanctions, potentially including an award of attorneys' fees and costs. (Signed by Magistrate Judge James C. Francis on 7/30/2014) Copies Mailed By Chambers. (kgo)
July 7, 2014 Filing 186 SECOND LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated July 7, 2014 re: Discovery. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu, Hugh Mo.(Mo, Hugh)
June 25, 2014 Filing 185 MANDATE of USCA (Certified Copy) as to #165 Notice of Interlocutory Appeal, filed by Sang Lan USCA Case Number 14-1654....that the appeal is hereby WITHDRAWN pursuant to Rule 42 of the Federal Rules of Appellate Procedure. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 06/25/2014. (nd)
June 20, 2014 Opinion or Order Filing 184 MEMORANDUM AND ORDER: denying #170 Motion for Protective Order. The plaintiff's motion for a protective order (Docket No. 170) is denied. (Signed by Magistrate Judge James C. Francis on 6/20/2014) Copies Sent By Chambers (djc)
June 20, 2014 Filing 183 MEMO ENDORSEMENT on re: #180 Letter, filed by Gina Hiu-Hung Liu, Hugh Hu Mo, Keo-Sung Liu. ENDORSEMENT: Application granted in part and denied in part. For plaintiff's deposition, the parties shall utilize the protocol used in 12 civ. 7103, as it apparently worked and plaintiff has not proposed a detailed alternative. Defendants shall bear the costs of the deposition. Huang Jian shall not attend plaintiff's deposition. (Signed by Magistrate Judge James C. Francis on 6/20/2014) (djc) Modified on 6/20/2014 (djc).
June 20, 2014 Filing 182 NOTICE OF CHANGE OF ADDRESS by Pedro Medina, Jr on behalf of Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. New Address: The Law Firm of Hugh H. Mo, P.C., 225 Broadway, Suite 2702, New York, NEW YORK, United States 10007, 2123851500. (Medina, Pedro)
June 20, 2014 Filing 181 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated June 20, 2014 re: Motion to Compel Responses. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Defendants' Request for Production of Documents, #2 Exhibit Defendants' Interrogatories, #3 Exhibit Plaintiffs' Response to Request for Production of Documents, #4 Exhibit Plaintiffs' Response to Defendants' Interrogatories, #5 Exhibit Defendant's Initial Disclosure)(Medina, Pedro)
June 16, 2014 Filing 180 FIRST LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated June 13, 2014 re: Discovery Disputes. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H)(Medina, Pedro)
June 16, 2014 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney Pedro Medina to RE-FILE Document #179 THIRD LETTER MOTION for Conference re: #172 Order, Set Motion and R&R Deadlines/Hearings, for an protective order excluding non-party witness from Plaintiff's deposition, order determining Plaintiff should bear costs of videoconferen. Use the event type Letter found under the event list Other Documents. (db)
June 13, 2014 Filing 179 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - THIRD LETTER MOTION for Conference re: #172 Order, Set Motion and R&R Deadlines/Hearings, for an protective order excluding non-party witness from Plaintiff's deposition, order determining Plaintiff should bear costs of videoconference of deposition addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated June 13, 2014. Document filed by Keo-Sung Liu. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D, #5 Exhibit Exhibit E, #6 Exhibit Exhibit F, #7 Exhibit Exhibit G, #8 Exhibit Exhibit H, #9 Exhibit Exhibit I)(Medina, Pedro) Modified on 6/16/2014 (db).
May 30, 2014 Filing 178 REPLY MEMORANDUM OF LAW in Support re: #170 MOTION for Protective Order . . Document filed by Sang Lan. (Attachments: #1 Exhibit A Plaintiff letter, #2 Exhibit B Plaintiff letter, #3 Exhibit C Plaintiff letter)(Xu, X. Bing)
May 30, 2014 Filing 177 CERTIFICATE OF SERVICE of Memorandum of Law in Opposition to Plaintiff's Motion for a Protective Order and the Declaration of Hugh H. Mo served on X. Bing Xu on May 27, 2014. Service was made by Mail. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
May 28, 2014 Opinion or Order Filing 176 ORDER granting #173 Motion for Thomas L. Johnson to Appear Pro Hac Vice. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
May 27, 2014 Filing 175 FIRST MEMORANDUM OF LAW in Opposition re: #170 MOTION for Protective Order . . Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Medina, Pedro)
May 27, 2014 Filing 174 DECLARATION of Hugh H. Mo in Opposition re: #170 MOTION for Protective Order .. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu. (Attachments: #1 Exhibit April 30, 2014 Correspondence, #2 Exhibit May 1, 2014 Correspondence, #3 Exhibit Endorsed Letter, #4 Exhibit May 8, 2014 Correspondence, #5 Exhibit May 9, 2014 Correspondence, #6 Exhibit May 9, 2014 Correspondence, #7 Exhibit May 13, 2014 Correspondence, #8 Exhibit May 14, 2014 Correspondence, #9 Exhibit Press Conference Correspondence)(Medina, Pedro)
May 27, 2014 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #173 MOTION for Thomas L. Johnson to Appear Pro Hac Vice Corrected. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
May 22, 2014 Filing 173 MOTION for Thomas L. Johnson to Appear Pro Hac Vice Corrected. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Sang Lan. (Attachments: #1 Exhibit Certificate of Goodstanding, #2 Text of Proposed Order Order granting prohavic)(Xu, X. Bing)
May 20, 2014 Opinion or Order Filing 172 ORDER: Defendants shall answer the motion for a protective order by May 27, 2014; plaintiff shall reply by May 30, 2014. Defendants' request for a conference with respect to this issue is respectfully denied. Plaintiff's application to stay discovery and defer her deposition is denied. The medical documentation reveals that plaintiff "is allowed to accept media visitors under supervision by the doctor and special care medical staff." If plaintiff is capable of participating in media events, she is capable of participating in the litigation that she initiated. Counsel shall make arrangements for taking her deposition by videoconference, under supervision of the appropriate medical personnel. Set Deadlines/Hearing as to #170 MOTION for Protective Order: Responses due by 5/27/2014, Replies due by 5/30/2014. (Signed by Magistrate Judge James C. Francis on 5/20/2014) Copies Mailed By Chambers. (tn)
May 15, 2014 Filing 171 MEMORANDUM OF LAW in Support re: #170 MOTION for Protective Order . Confidentiality as to Pre-Trial Materials. Document filed by Sang Lan. (Xu, X. Bing)
May 15, 2014 Filing 170 MOTION for Protective Order . Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit B1, #4 Exhibit C, #5 Exhibit D)(Xu, X. Bing)
May 15, 2014 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney X. Bing Xu to RE-FILE Document #169 Memorandum of Law in Support of Motion. ERROR(S): Document linked to filing error. (db)
May 15, 2014 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Note to Attorney X. Bing Xu to RE-FILE Document #168 MOTION for Protective Order Confidentiality as to Pre-Trial Materials. Use the event type Memorandum in Support of Motion found under the event list Replies, Opposition and Supporting Documents. ***REMINDER*** - Motion WAS NOT FILED. (db)
May 14, 2014 Filing 169 FILING ERROR - DEFICIENT DOCKET ENTRY - MEMORANDUM OF LAW in Support re: #168 MOTION for Protective Order Confidentiality as to Pre-Trial Materials. . Document filed by Sang Lan. (Xu, X. Bing) Modified on 5/15/2014 (db).
May 14, 2014 Filing 168 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MOTION for Protective Order Confidentiality as to Pre-Trial Materials. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit B1, #4 Exhibit C, #5 Exhibit D)(Xu, X. Bing) Modified on 5/15/2014 (db).
May 14, 2014 Filing 167 FILING ERROR - DEFICIENT DOCKET ENTRY - AMENDED MOTION for Thomas L. Johnson to Appear Pro Hac Vice Corrected. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Sang Lan. (Attachments: #1 Exhibit Certificate of Goodstanding, #2 Text of Proposed Order proposed order)(Xu, X. Bing) Modified on 5/14/2014 (wb).
May 14, 2014 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice regarding Document No. #167 AMENDED MOTION for Thomas L. Johnson to Appear Pro Hac Vice Corrected. Motion and supporting papers to be reviewed by Clerk's Office staff.. Certificate of Good Standing Must be issued from the Supreme Court of Florida with a Clerk of Court Signature. Re-file the document as a Corrected Motion to Appear Pro Hac Vice and attach a valid Certificate of Good Standing, issued within the past 30 days. (wb)
May 14, 2014 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice regarding Document No. #166 MOTION for Thomas L. Johnson to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-9670084. Motion and supporting papers to be reviewed by Clerk's Office staff.. The filing is deficient for the following reason(s): Missing Certificate of Good Standing.Missing Proposed Order. Certificates of Good Standing Must be issued form the Suprme Court not the District Court with a Clerk of Court Signature. Re-file the document as a Corrected Motion to Appear Pro Hac Vice and attach a valid Certificate of Good Standing, issued within the past 30 days.Re-file the document as a Corrected Motion to Appear Pro Hac Vice and attach a Proposed Order. (wb)
May 13, 2014 Filing 166 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Thomas L. Johnson to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-9670084. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Sang Lan.(Xu, X. Bing) Modified on 5/14/2014 (wb).
May 7, 2014 Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files for #165 Notice of Interlocutory Appeal, filed by Sang Lan were transmitted to the U.S. Court of Appeals. (nd)
May 7, 2014 Transmission of Notice of Appeal and Certified Copy of Docket Sheet to US Court of Appeals re: #165 Notice of Interlocutory Appeal,. (nd)
May 6, 2014 Filing 165 NOTICE OF INTERLOCUTORY APPEAL from #160 Order on Motion for Reconsideration, #149 Order Adopting Report and Recommendations,. Document filed by Sang Lan. Filing fee $ 505.00, receipt number 0208-9643718. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit. (Xu, X. Bing)
May 5, 2014 Filing 164 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from X. Bing Xu dated 4/30/2014 re: I spoke with Mr. Huang Jian (Sang Lan's Husband) on April 25 and 29, 2014 by telephone. Mr. Huang informed that Sang Lan's doctors have not released her from the Hospital because of complications, unhealed wounds and extreme fluctuations of blood pressures and "blood sugar" (I am told the medical term is Pathoglycemia). The doctors need to closely monitor her blood pressure and "blood sugar" to prevent serious complications. Apparently, the wounds are a problem, according to her doctors. There is no significant recovery and she cannot meaningfully participate in discovery at this time. ENDORSEMENT: In light of the information contained in the May 1, 2014 letter of defendants' counsel, third-hand information is no longer sufficient. Subsequent updates shall include documentation from plaintiff's physicians. (Signed by Magistrate Judge James C. Francis on 5/5/2014) (djc)
April 16, 2014 Opinion or Order Filing 163 ORDER denying #159 Letter Motion for Conference. No conference is necessary. Plaintiff's deposition shall precede the depositions of defendants. In light of the fact that plaintiff's counsel has indicated that his client has a medical emergency, plaintiff's counsel shall advise the Court by letter on the first and fifteenth of each month of the plaintiff's medical condition until such time as she is fully capable of participating in the case. (HEREBY ORDERED by Magistrate Judge James C. Francis)(Text Only Order) (Francis, James)
April 16, 2014 Filing 162 CERTIFICATE OF SERVICE of Answer to Fourth Amended Complaint served on X. Bing Xu on April 15, 2014. Service was made by Mail. Document filed by Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu, Hugh Mo. (Medina, Pedro)
April 15, 2014 Filing 161 ANSWER to #119 Amended Complaint, with JURY DEMAND. Document filed by Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Keo-Sung Liu.(Medina, Pedro)
April 11, 2014 Opinion or Order Filing 160 ORDER. Plaintiff's motion is DENIED. The Clerk of Court is directed to terminate the motion at ECF No. 150. Denying #150 Motion for Reconsideration. (Signed by Judge Analisa Torres on 4/11/2014) (rjm)
April 11, 2014 Filing 159 FIRST LETTER MOTION for Conference re: #157 Order, Set Deadlines,,,, addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated April 11, 2014. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo. (Attachments: #1 Appendix Correspondence, #2 Appendix Proposed Order)(Medina, Pedro)
April 4, 2014 Filing 158 NOTICE OF CHANGE OF ADDRESS by Pedro Medina, Jr on behalf of K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo. New Address: The Law Firm of Hugh H. Mo, P.C., 225 Broadway, 27th Floor, New York, New York, United States 10007, 2123851500. (Medina, Pedro)
April 2, 2014 Opinion or Order Filing 157 ORDER: A pretrial conference having been held by telephone on April 1, 2014, it is hereby ORDERED as follows: 1. The scheduling order dated April 1, 2014 (Docket no. 146) is vacated. 2. parties shall exchange Rule 26(a) (1) initial disclosures by April 30, 2014. 3. All discovery shall be completed by August 29, 2014. 4. The pretrial order shall be submitted by September 30, 2014, unless any dispositive motion is filed by that date. If such a motion is filed, the pretrial order shall be due thirty days after the motion is decided. (Discovery due by 8/29/2014. Motions due by 9/30/2014. Pretrial Order due by 9/30/2014.) (Signed by Magistrate Judge James C. Francis on 4/2/2014)Copies Mailed By Chambers (djc) Modified on 4/2/2014 (djc).
April 1, 2014 Opinion or Order Filing 156 ORDER: A pretrial conference having been held by telephone on April 1, 2014, it is hereby ORDERED as follows: 1. The parties shall exchange Rule 26(a) (1) initial disclosures by April 1, 2014. 2. All discovery shall be completed by August 29, 2013. 2. The pretrial order shall be submitted by September 30, 2014, unless any dispositive motion is filed by that date. If such a motion is filed, the pretrial order shall be due thirty days after the motion is decided. 3. If all parties consent to proceed before a United States Magistrate Judge pursuant to 28 U.S.C. 636(c), the enclosed consent form should be executed and returned. (Pretrial Order due by 9/30/2014.) (Signed by Magistrate Judge James C. Francis on 4/1/2014) Copies Mailed By Chambers. (djc)
April 1, 2014 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Telephone Conference held on 4/1/2014. (Bacchus, Michael)
March 31, 2014 Filing 155 REPLY MEMORANDUM OF LAW in Opposition re: #150 MOTION for Reconsideration re; #149 Order Adopting Report and Recommendations,.. Document filed by Time Warner, Inc.. (Bakowski, Alan)
March 26, 2014 Filing 154 NOTICE OF APPEARANCE by Pedro Medina, Jr on behalf of K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo. (Medina, Pedro)
March 26, 2014 Filing 153 CERTIFICATE OF SERVICE of Memorandum in Opposition served on Plaintiff on March 26, 2014. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo. (Medina, Pedro)
March 26, 2014 Filing 152 MEMORANDUM OF LAW in Opposition re: #150 MOTION for Reconsideration re; #149 Order Adopting Report and Recommendations,.. Document filed by Gina Liu, K.S. Liu, Keo-Sung Liu, Hugh Mo. (Medina, Pedro)
March 12, 2014 Filing 151 MEMORANDUM OF LAW in Support re: #150 MOTION for Reconsideration re; #149 Order Adopting Report and Recommendations,.. Document filed by Sang Lan. (Xu, X. Bing)
March 12, 2014 Filing 150 MOTION for Reconsideration re; #149 Order Adopting Report and Recommendations,. Document filed by Sang Lan.(Xu, X. Bing)
February 25, 2014 Opinion or Order Filing 149 ORDER. For the reasons stated above, the Individual Defendants' motion to dismiss is DENIED as to Counts Five and Six. The Individual Defendants' motion to dismiss Count Eight is DENIED only as to the allegations that the Lius (1) failed to account for the Fund and (5) misappropriated of Fund assets. In all other respects, Judge Francis' R&R is AFFIRMED. Adopting in part #140 Report and Recommendations. (Signed by Judge Analisa Torres on 2/25/2014) (rjm)
August 9, 2013 Opinion or Order Filing 148 ORDER withdrawing #90 Motion to Compel. Counsel for the plaintiff having represented that the motion to compel filed on January 24, 2012, may be withdrawn, the Clerk of Court is respectfully directed to withdraw the motion (Docket no. 90). The motion may be renewed when and if circumstances warrant. (Signed by Magistrate Judge James C. Francis on 8/9/2013) Copies Mailed By Chambers. (tro)
August 8, 2013 ***DELETED DOCUMENT. Deleted document number #148 Report and Recommendations. The document was incorrectly filed in this case. (lmb)
June 24, 2013 Filing 147 RESPONSE re: #146 Objection to Report and Recommendations and Memorandum of Law in Support of Magistrate Judge Francis's Report and Recommendation. Document filed by Time Warner, Inc.. (Bakowski, Alan)
June 5, 2013 Filing 146 OBJECTION to #140 Report and Recommendations Document filed by Sang Lan. (Xu, X. Bing)
May 22, 2013 Filing 145 NOTICE OF CASE REASSIGNMENT to Judge Analisa Torres. Judge Loretta A. Preska is no longer assigned to the case. (pgu)
May 21, 2013 Filing 144 NOTICE OF CASE REASSIGNMENT to Judge Loretta A. Preska. Judge Analisa Torres is no longer assigned to the case. (pgu)
May 17, 2013 Filing 143 NOTICE OF CASE REASSIGNMENT to Judge Analisa Torres. Judge Leonard B. Sand is no longer assigned to the case. (pgu)
May 2, 2013 Filing 142 ENDORSED LETTER addressed to Judge Leonard B. Sand, from James A. Lamberth, dated 4/30/2013, re: Request for Extension or Enlargement of Time to File Responses or Objection to U.S. Magistrate Judge's Report and Recommendation of April 19, 2013. ENDORSEMENT: Parties are hereby granted extension of time to file their responses or objections to James C. Francis, IV, U.S. Magistrate Judge's Report and Recommendation on or before June 5, 2013. #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT, #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted. ( Responses due by 6/5/2013, Objections to R&R due by 6/5/2013) (Signed by Judge Leonard B. Sand on 5/2/2013) (ja)
April 30, 2013 Opinion or Order Filing 141 MEMORANDUM AND ORDER: ADOPTING REPORT AND RECOMMENDATIONS for #81 Report and Recommendations; #103 Motion to Set Aside filed by Ming Hai. Having reviewed the R&R and Hai's objections thereto, we adopt the R&R and deny Hai's motion. Any other argument made by Hai is meritless. There are no clear errors in the parts of the R&R to which Hai did not object. For the reasons set forth herein, we adopt Judge Francis's R&R and Hai's motion to set aside the Stipulation is DENIED. SO ORDERED. (Signed by Judge Leonard B. Sand on 4/30/2013) (ja) Modified on 4/30/2013 (ja).
April 19, 2013 Filing 140 REPORT AND RECOMMENDATION re: #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted. #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT. For the foregoing reasons, I recommend that Time Warner's motion to dismiss (Docket no. 127) be granted in its entirety. I further recommend that the Individual Defendants motion to dismiss (Docket no. 130) be granted in part and denied in part.Specifically, I recommend that the Individual Defendants motion to dismiss be granted with respect to Count Five (Accounting as to Other Property); Count Six (Unjust Enrichment) to the extent that it pertains to the Other Property; Count Seven (Conversion) to the extent that it pertains to insurance proceeds; Count Eight (Breach of Fiduciary Duty against the Lius); Count Nine (Breach of Fiduciary Duty against Mr. Mo); Count Ten (Defamation) to the extent that it pertains to the statements set out in the Fourth Amended Complaint, 185(c) & (d), and the document (and its translation) attached to the Fourth Amended Complaint as part of Exh. M (the translation begins, Sang Lan got injured and paralysis at Goodwill Games held in New York in 1998); and Count Twelve(Cyberharassment). The motion should be denied in all other respects. Pursuant to 28 U.S.C. 636(b) (1) and Rules 72, 6(a), and 6(d) of the Federal Rules of Civil Procedure, the parties shall have fourteen (14) days from this date to file written objections to this Report and Recommendation. Objections to R&R due by 5/6/2013. Respectfully Submitted. (Signed by Magistrate Judge James C. Francis on 4/19/2013) Copies Mailed by Chambers. (rsh) Modified on 4/22/2013 (rsh).
March 1, 2013 Filing 139 REPLY MEMORANDUM OF LAW in Support re: #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Bakowski, Alan)
March 1, 2013 Filing 138 CERTIFICATE OF SERVICE of Defendants' Reply Memorandum of Law served on Sang Lan and Time Warner, Inc. on 03/01/13. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Keo-Sung Liu, Hugh Mo. (Mo, Hugh)
March 1, 2013 Filing 137 REPLY MEMORANDUM OF LAW in Support re: #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
February 15, 2013 Filing 136 MEMORANDUM OF LAW in Opposition re: #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by Sang Lan. (Xu, X. Bing)
February 15, 2013 Filing 135 MEMORANDUM OF LAW in Opposition re: #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Sang Lan. (Xu, X. Bing)
January 29, 2013 Opinion or Order Filing 134 ENDORSED LETTER addressed to Magistrate Judge James C. Francis, IV, from X. Bing Xu, dated 1/29/2013, re: request for additional time to file Plaintiff's response to defendants' Motion to Dismiss. ENDORSEMENT: Plaintiff is hereby granted extension of time to respond to Defendant Lius and Mo's Motion to Dismiss on or before February 15, 2013; Defendant Lius and Mo shall file their reply on or before March 1, 2013. Plaintiff is hereby granted extension of time to respond to Defendant Time Warner's Motion to Dismiss on or before February 15 2013; Defendant Time Warner shall file its reply on or before March 1, 2013. So Ordered. ( Motions due by 2/15/2013, Responses due by 2/15/2013, Replies due by 3/1/2013.) (Signed by Magistrate Judge James C. Francis on 1/29/2013) (ja)
December 27, 2012 Filing 133 CERTIFICATE OF SERVICE of NOTICE OF MOTION TO DISMISS FOURTH AMENDED COMPLAINT, MEMORANDUM OF LAW IN SUPPORT, DECLARATION IN SUPPORT, AND EXHIBITS served on ALL PARTIES on 12/27/2012. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
December 27, 2012 Filing 132 DECLARATION of Hugh H. Mo, Esq. in Support re: #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: #1 Exhibit Exhibit "A")(Mo, Hugh)
December 27, 2012 Filing 131 MEMORANDUM OF LAW in Support re: #130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
December 27, 2012 Filing 130 MOTION to Dismiss FOURTH AMENDED COMPLAINT. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. Responses due by 1/30/2013 (Attachments: #1 Exhibit Letter Requesting Oral Argument)(Mo, Hugh)
December 14, 2012 Filing 129 DECLARATION of Alan W. Bakowski in Support re: #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Bakowski, Alan)
December 14, 2012 Filing 128 MEMORANDUM OF LAW in Support re: #127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Bakowski, Alan)
December 14, 2012 Filing 127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted. Document filed by Time Warner, Inc.. Responses due by 1/30/2013(Bakowski, Alan)
December 14, 2012 Filing 126 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Time Warner, Inc..(Bakowski, Alan)
December 14, 2012 Filing 125 WAIVER OF SERVICE RETURNED EXECUTED. All Plaintiffs. Document filed by Time Warner, Inc.. (Xu, X. Bing)
December 12, 2012 Opinion or Order Filing 124 ENDORSED LETTER addressed to Magistrate Judge James C. Francis from Hugh H. Mo dated 12/12/2012 re: Defense counsel writes due to unforeseen circumstances and delays, including repercussions from Hurricane Sandy, the Individual Defendants respectfully ask Your Honor to grant, this application for a brief two-week extension of time to answer, move or otherwise respond to Plaintiff's Fourth Amended Complaint to December 28, 2012. This constitutes our first application as it pertains to the Fourth Amended Complaint. ENDORSEMENT: Application granted. So Ordered., K.S. Gina Hiu-Hung answer due 12/28/2012; Gina Hiu-Hung Liu(individually) answer due 12/28/2012; Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund) answer due 12/28/2012; Hugh Hu Mo answer due 12/28/2012. (Signed by Magistrate Judge James C. Francis on 12/12/2012) (ago)
December 10, 2012 Opinion or Order Filing 123 ORDER FOR ADMISSION PRO HAC VICE: granting #120 Motion for Alan W. Bakowski to Appear Pro Hac Vice. (Signed by Magistrate Judge James C. Francis on 12/10/2012) (djc)
December 10, 2012 Opinion or Order Filing 122 ORDER FOR ADMISSION PRO HAC VICE: granting #121 Motion for James A. Lamberth to Appear Pro Hac Vice. (Signed by Magistrate Judge James C. Francis on 12/10/2012) (djc)
December 6, 2012 Filing 121 MOTION for James A. Lamberth to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038667. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Time Warner, Inc.. (Attachments: #1 Exhibit Certificates of Good Standing, #2 Text of Proposed Order)(Lamberth, James)
December 6, 2012 Filing 120 MOTION for Alan W. Bakowski to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038498. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Time Warner, Inc.. (Attachments: #1 Exhibit Certificates of Good Standing, #2 Text of Proposed Order)(Bakowski, Alan)
December 6, 2012 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #120 MOTION for Alan W. Bakowski to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038498. Motion and supporting papers to be reviewed by Clerk's Office staff., #121 MOTION for James A. Lamberth to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038667. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
December 3, 2012 ***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document #119 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (mro)
November 20, 2012 Filing 119 FOURTH AMENDED COMPLAINT amending #32 Amended Complaint, against Time Warner, Inc., Keo-Sung Liu, Gina Hiu-Hung Liu, Gina Hiu-Hung Liu, Hugh Hu Mo, Does 1-30 with JURY DEMAND.Document filed by Sang Lan. Related document: #32 Amended Complaint, filed by Sang Lan.(mro) (Additional attachment(s) added on 12/17/2012: #1 Exhibit A to F, #2 Exhibit g j, #3 Exhibit k m) (sac).
November 5, 2012 Opinion or Order Filing 118 JOINT STIPULATION AND ORDER ON BRIEFING SCHEDULE: Time Warner, the Liu's, and Attorney Mo wish to proceed directly to motions challenging the allegations in the Fourth Amended Complaint. Time Warner, the Liu's, and Attorney Mo take no position Plaintiff's Motion to Add Party. Accordingly, Plaintiffs Motion to Add Party (Docket No. 115) is granted and the Fourth Amended Complaint shall be deemed filed as of the date of this Stipulation. This Stipulation may be executed in two or more counterparts, each of which shall be deemed an original including facsimile, copy or email forms, and all of which together shall constitute one and the same document. SO ORDERED. John Does and Jane Does #1 through 15, Inclusive answer due 12/14/2012; Gina Liu answer due 12/14/2012; K.S. Liu answer due 12/14/2012; Hugh Mo answer due 12/14/2012; Ted Turner answer due 12/14/2012.( Responses due by 1/30/2013, Replies due by 2/27/2013.) (Signed by Magistrate Judge James C. Francis on 11/05/2012) (ama)
October 5, 2012 Filing 116 AFFIRMATION of X. Bing Xu, Esquire in Support re: #115 MOTION to Add Party(ies) Time Warner, Inc... Document filed by Sang Lan. (Attachments: #1 Supplement 4th Amended Complaint, #2 Exhibit exhibit a-f to cpl, #3 Exhibit exhibit g-j to cpl, #4 Exhibit exhibit k-m to cpl)(Xu, X. Bing)
October 5, 2012 Filing 115 MOTION to Add Party(ies) Time Warner, Inc.. Document filed by Sang Lan.(Xu, X. Bing)
August 27, 2012 Filing 114 OBJECTION to #113 Report and Recommendations Document filed by Ming Hai. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Affidavit of Service)(Hai, Ming)
August 13, 2012 Opinion or Order Filing 113 REPORT AND RECOMMENDATION: re: #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal, filed by Ming Hai. For the reasons set forth above, Mr. Hais motion to rescind the settlement agreement (Docket no. 103) should be denied. Objections to R&R due by 8/30/2012 (Signed by Magistrate Judge James C. Francis on 8/13/2012) Copies Mailed By Chambers. (jfe)
July 25, 2012 Opinion or Order Filing 112 ORDER: A pretrial conference having been held by telephone on July 25, 2012, it is hereby ORDERED as follows: 1. Any motion to amend the pleadings shall be served and filed by October 7, 2012. 2. All discovery shall be completed by February 28, 2013. 3. The pretrial order shall be submitted by March 29, 2013 unless any dispositive motion is filed by that date. If such a motion is filed, the pretrial order shall be due thirty days after the motion is decided. ( Discovery due by 2/28/2013. Motions due by 10/7/2012. Pretrial Order due by 3/29/2013.) (Signed by Magistrate Judge James C. Francis on 7/25/2012) Copies Mailed By Chambers. (ja)
July 12, 2012 Filing 111 REPLY AFFIRMATION of Ming Hai in Support re: #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal,,,.. Document filed by Ming Hai. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Affidavit of Service)(Hai, Ming)
July 3, 2012 Filing 110 CERTIFICATE OF SERVICE of Memorandum of Law in Opposition to Attorney Hai's Motion to Set Aside Settlement, Declaration of Hugh H. Mo, Esq., and exhibits served on SANG LAN and MING HAI, ESQ. on 06/29/12. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
June 29, 2012 Filing 109 DECLARATION of Hugh H. Mo in Opposition re: #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal,,,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: #1 Exhibit "A", #2 Exhibit "B", #3 Exhibit "C", #4 Exhibit "D", #5 Exhibit "E", #6 Exhibit "F")(Mo, Hugh)
June 29, 2012 Filing 108 MEMORANDUM OF LAW in Opposition re: #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal,,,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
June 5, 2012 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Telephone Conference held on 6/5/2012. (cd)
June 5, 2012 Opinion or Order Filing 107 ORDER: Set Deadlines/Hearing as to #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal:( Responses due by 6/29/2012, Replies due by 7/13/2012.) (Signed by Magistrate Judge James C. Francis on 6/5/2012) Copies Mailed By Chambers. (cd)
May 29, 2012 Filing 105 NOTICE OF REASSIGNMENT OF A REFERRAL TO ANOTHER MAGISTRATE JUDGE. The referral in the above entitled action has been reassigned to Magistrate Judge James C. Francis, for Specific Non-Dispositive Motion/Dispute. Magistrate Judge James C. Francis no longer referred to the case. (sjo)
May 14, 2012 Transmission to Case Assignment Clerk. Transmitted re: #102 Order Referring Case to Magistrate Judge, to the Case Assignment Clerk for preparation of notice of case assignment/reassignment. (cd)
May 14, 2012 Filing 104 AFFIRMATION of Ming Hai in Support re: #103 MOTION to Set Aside #96 Stipulation and Order of Dismissal,,,.. Document filed by Ming Hai. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Affidavit of Service)(Hai, Ming)
May 14, 2012 Filing 103 MOTION to Set Aside #96 Stipulation and Order of Dismissal,,,. Document filed by Ming Hai.(Hai, Ming)
May 14, 2012 Opinion or Order Filing 102 ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Specific Non-Dispositive Motion/Dispute: Ming Hai's 5/10/2012 Motion to Set Aside Stipulation and Order of Dismissal. Referred to Magistrate Judge James C. Francis. (Signed by Judge Leonard B. Sand on 5/14/2012) (cd)
May 14, 2012 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document #100 FIRST MOTION to Set Aside #96 Stipulation and Order of Dismissal, by Ming Hai, former attorney for plaintiff. FIRST MOTION to Set Aside #96 Stipulation and Order of Dismissal, by Ming Hai, former attorney for plaintiff. ERROR(S): No signature or s/. (db)
May 14, 2012 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document #101 Affirmation in Support of Motion. ERROR(S): Document linked to filing error. (db)
May 11, 2012 Filing 101 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Ming Hai in Support re: #100 FIRST MOTION to Set Aside #96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for plaintiff.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Affidavit of Service)(Hai, Ming) Modified on 5/14/2012 (db).
May 11, 2012 Filing 100 FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION to Set Aside #96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for plaintiff. Document filed by Sang Lan.(Hai, Ming) Modified on 5/14/2012 (db).
May 10, 2012 ***NOTE TO ATTORNEY THAT THE ATTEMPTED FILING OF Document No. #99 HAS BEEN REJECTED. Note to Attorney Ming Hai : THE CLERK'S OFFICE DOES NOT ACCEPT LETTERS FOR FILING, either through ECF or otherwise, except where the judge has ordered that a particular letter be docketed. Letters may be sent directly to a judge. (ldi)
May 10, 2012 Filing 99 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - FIRST MOTION to Set Aside #96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for Plainitff. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Errata C, #4 Exhibit D, #5 Affidavit of Service)(Hai, Ming) Modified on 5/11/2012 (ldi).
May 9, 2012 Opinion or Order Filing 98 MEMORANDUM AND ORDER: for #47 Motion for Sanctions filed by Winston Sie, K.S. Gina Hiu-Hung, K.S. Liu, Gina Liu, Wilson Xue, Hugh Mo, #81 Report and Recommendations, #34 Motion to Dismiss/Lack of Jurisdiction filed by Winston Sie, K.S. Gina Hiu-Hung, K.S. Liu, Gina Liu, Wilson Xue, Hugh Mo, #28 Motion to Dismiss Case as Frivolous filed by K.S. Gina Hiu-Hung, K.S. Liu, Wilson Xue, Hugh Mo, #43 Motion to Amend/Correct filed by Sang Lan. For the above reasons, Defendants' motion for sanctions against Plaintiff is denied: Defendants' motion to dismiss Count 9 is granted with leave to replead; and Defendants' motion to dismiss Count 10 is granted with respect to Hugh Mo and denied with respect to K.S. Liu and Gina Liu. In all other respects, Judge Francis's R&R is affirmed. (Signed by Judge Leonard B. Sand on 5/9/2012) (jfe)
April 23, 2012 ***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document #1 Complaint, to: caseopenings@nysd.uscourts.gov. (rjm)
April 23, 2012 ***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document #4 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (rjm)
April 23, 2012 ***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu to E-MAIL the PDF for Document #32 Amended Complaint to: caseopenings@nysd.uscourts.gov. All pdfs must include case number and corresponding document number. (rjm)
March 6, 2012 Opinion or Order Filing 97 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated 3/4/2012 re: We kindly ask the Court to replace the first page of the Settlement Agreement with the enclosed copy, which includes a footnote. ENDORSEMENT: Application granted. The Settlement Agreement and release is amended accordingly. So ordered. (Signed by Magistrate Judge James C. Francis on 3/6/2012) (rjm) (Main Document 97 replaced on 3/7/2012, as per Chamber's instructions, page 2 redacted version) (tro). Modified on 3/7/2012 (tro).
March 2, 2012 Opinion or Order Filing 96 STIPULATION AND ORDER OF PARTIAL DISMISSAL OF RULE 11 MOTION: the undersigned counsel hereby consents to the partial dismissal of their pending Motion for Sanctions. pursuant to Fed. R. Civ. P. Rule 11, only as against attorney Ming Hai, Esq., with prejudice, and without costs, expenses or attorneys' fees to any of the parties as against the other, and pursuant to the attached Agreement of Settlement, with the settlement amount redacted. (Signed by Magistrate Judge James C. Francis on 3/2/2012) (pl) Modified on 3/5/2012 (pl). (Main Document 96 replaced on 3/6/2012, See Page 3 replaced. See Endorsed Letter #97 which ordered that this page be replaced.) (tro). Modified on 3/6/2012 (tro). (Main Document 96 replaced on 3/7/2012, pursuant to instructions from Chambers, page 3 redacted) (tro). Modified on 3/7/2012 (tro).
February 27, 2012 Minute Entry for proceedings held before Magistrate Judge James C. Francis: Settlement Conference held on 2/27/2012. (js)
February 3, 2012 Opinion or Order Filing 95 ORDER: Settlement Conference set for 2/27/2012 at 09:00 AM in Courtroom 18D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge James C. Francis, and as further set forth in this document. (Signed by Magistrate Judge James C. Francis on 2/3/2012) Copies Mailed By Chambers. (cd)
January 26, 2012 Filing 94 RESPONSE re: #81 Report and Recommendations,,,,, #84 Order, Set Motion and R&R Deadlines/Hearings,,,,,,. Document filed by Sang Lan. (Xu, X. Bing)
January 25, 2012 Filing 93 AFFIRMATION of Sang Lan's former attorney Ming Hai in Opposition re: #90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Hai, Ming)
January 24, 2012 Filing 92 AFFIRMATION of Sang Lan in Support re: #90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit B1, #4 Exhibit B1 translation)(Xu, X. Bing)
January 24, 2012 Filing 91 AFFIRMATION of X. Bing Xu, Esquire in Support re: #90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Xu, X. Bing)
January 24, 2012 Filing 90 MOTION to Compel Ming Hai to Turn Over Documents. Document filed by Sang Lan.(Xu, X. Bing) Modified on 8/8/2013 (lmb).
January 24, 2012 Filing 89 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Sang Lan's former attorney Ming Hai in Opposition re: #87 MOTION to Compel Ming Hai to turn over documents.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Hai, Ming) Modified on 1/24/2012 (ldi).
January 24, 2012 Filing 88 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Sang Lan in Support re: #87 MOTION to Compel Ming Hai to turn over documents. Document filed by Sang Lan. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B)(Xu, X. Bing) Modified on 1/24/2012 (ldi).
January 24, 2012 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document #89 Affirmation in Opposition to Motion. ERROR(S): Document linked to filing error. (ldi)
January 24, 2012 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney X. Bing Xu to RE-FILE Document #88 Affirmation in Support of Motion. ERROR(S): Document linked to filing error. (ldi)
January 23, 2012 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney X. Bing Xu to RE-FILE Document #87 MOTION to Compel Ming Hai to turn over documents. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Affirmation in Support of Motion is found under the event list Replies, Opposition and Supporting Documents. (ldi)
January 23, 2012 Filing 87 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Compel Ming Hai to turn over documents. Document filed by Sang Lan. Return Date set for 2/23/2012 at 09:00 AM. (Attachments: #1 Affidavit Affirmation in support of Motion to Compel, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Supplement Case, #8 Supplement Case2)(Xu, X. Bing) Modified on 1/24/2012 (ldi).
December 15, 2011 Filing 86 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Sang Lan.(Xu, X. Bing)
December 15, 2011 Filing 85 NOTICE OF APPEARANCE by X. Bing Xu on behalf of Sang Lan (Xu, X. Bing)
December 14, 2011 Filing 84 MEMORANDUM: Having successfully moved to be relieved as an attorney after a motion to withdraw as attorney for plaintiff, Ming Hai has no standing to file any documents on behalf of plaintiff in this capacity. He seeks standing to file in the capacity of a party against whom defendants continue to seek monetary sanctions but his 23 page memorandum is not limited to the questions of this alleged liability. This document is not received on behalf of the plaintiff and will not be so regarded by this Court. If plaintiff wishes to file a document in response to the Magistrate's report she may do so by 1/31/2012 but not thereafter. Set Deadlines/Hearing as to (Objections to R&R due by 1/31/2012) (Signed by Judge Leonard B. Sand on 12/14/2011) (ft)
December 8, 2011 Filing 83 OBJECTION to #81 Report and Recommendations by Defendants Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Attachments: #1 Affidavit of Translation, #2 Exhibit Photos of CD and Cover Pages, #3 Exhibit English Translations)(Mo, Hugh)
December 5, 2011 Filing 82 OBJECTION to #81 Report and Recommendations by the Magistrate Judge Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit C, #3 Exhibit D, #4 Affidavit of Service)(Hai, Ming)
November 21, 2011 Filing 106 INTERNET CITATION NOTE: Material from decision with Internet citation re: #81 Report and Recommendations. (tro)
November 21, 2011 Filing 81 REPORT AND RECOMMENDATION: Plaintiff's motion to amend the complaint (Docket no. 43) should be granted. The defendants motion to dismiss for lack of subject matter jurisdiction (Docket no. 34) should be denied. The defendants motion to dismiss for failure to state a claim (Docket no. 28) should be granted with regard to the plaintiffs claims for defamation against Mr. Mo and Ms. Liu, civil conspiracy, primafacie tort, promissory estoppel, intentional infliction of emotional distress, negligent infliction of emotional distress, and eight of her ten alleged breaches of fiduciary duty. The motion should granted with leave for the plaintiff to re-plead with regard to her claims for unjust enrichment, conversion, and breach of fiduciary duty based on misappropriation of funds. The motion should be denied with respect to the plaintiffs claim for breach of fiduciary duty based on the defendants unauthorized use of her likeness in 2008, for invasion of privacy, and for defamation against Mr. Liu. The defendants motion for sanctions (Docket no. 47) should be denied without prejudice to being reviewed when the extent to which sanctions are proper becomes clear. Objections to R&R due by 12/8/2011 (Signed by Magistrate Judge James C. Francis on 11/21/2011) (ft)
October 31, 2011 Opinion or Order Filing 80 MEMORANDUM AND ORDER granting #73 Motion to Withdraw as Attorney. Attorney Ming Hai terminated. Because plaintiff's counsel proffers satisfactory reasons for requesting to be relieved pursuant to Local Civil Rule 1.4, and because his withdrawal will not unnecessarily delay the proceedings, his motion to withdraw is granted. The Court shall, however, retain jurisdiction over Mr. Hai in connection with the defendant's motion for sanctions, which will be considered in conjunction with the pending motions to amend and dismiss. Mr. Hai shall immediately deliver a copy of this Order to the plaintiff and turn over to the plaintiff all documents in his possession related to this litigation. By 12/15/2011, the plaintiff shall appear by new counsel or shall advise the Court in writing that she intends to proceed pro se. (Signed by Magistrate Judge James C. Francis on 10/31/2011) Copies Mailed By Chambers. (ae)
October 12, 2011 Opinion or Order Filing 79 ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Dispositive Motion (i.e., motion requiring a Report and Recommendation). Referred to Magistrate Judge James C. Francis. (Signed by Judge Leonard B. Sand on 10/11/2011) (ama)
September 19, 2011 Filing 78 REPLY to Response to Motion re: #73 MOTION for Ming Hai to Withdraw as Attorney for plaintiff.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E of emails of Sang Lan and Huang Jian, #6 Affidavit of Service)(Hai, Ming)
September 8, 2011 Filing 77 RESPONSE to Motion re: #73 MOTION for Ming Hai to Withdraw as Attorney for plaintiff.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
September 1, 2011 Opinion or Order Filing 76 ORDER: that plaintiff and defendants shall submit any response to the motion no later than 9/16/2011 and Ming Hai shall reply by 9/23/2011. (Signed by Magistrate Judge James C. Francis on 9/1/2011) (ft)
August 31, 2011 Filing 75 AFFIDAVIT of Rachel Yang in Support re: #73 MOTION for Ming Hai to Withdraw as Attorney for plaintiff.. Document filed by Sang Lan. (Attachments: #1 Affidavit of Service, #2 Affidavit of additional service by FedEx)(Hai, Ming)
August 31, 2011 Filing 74 AFFIDAVIT of Ming Hai in Support re: #73 MOTION for Ming Hai to Withdraw as Attorney for plaintiff.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Affidavit of Service, #6 Affidavit of Additional Service by FedEx)(Hai, Ming)
August 31, 2011 Filing 73 MOTION for Ming Hai to Withdraw as Attorney for plaintiff. Document filed by Sang Lan. Return Date set for 9/15/2011 at 09:30 AM.(Hai, Ming)
August 8, 2011 Filing 72 REPLY AFFIDAVIT of SANG LAN in Support re: #43 SECOND MOTION to Amend/Correct #32 Amended Complaint,.. Document filed by Sang Lan. (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 Affidavit OF SERVICE)(Hai, Ming)
August 8, 2011 Filing 71 REPLY AFFIRMATION of Ming Hai in Support re: #43 SECOND MOTION to Amend/Correct #32 Amended Complaint,.. Document filed by Sang Lan. (Attachments: #1 Affidavit of service)(Hai, Ming)
August 8, 2011 Filing 70 DECLARATION of Hugh H. Mo in Support re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
August 5, 2011 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Hugh Hu Mo to RE-FILE Document #68 Reply Memorandum of Law in Support of Motion. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Declaration in Support of Motion is found under the event list Replies, Opposition and Supporting Documents. (ldi)
August 5, 2011 Filing 69 CERTIFICATE OF SERVICE of Memorandum of Law, and accompanying Declaration of Hugh H. Mo, in Reply and in Further Support of Defendants' Motion for Sanctions pursuant to Fed. R. Civ. P. Rule 11 served on Plaintiff on 08/05/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
August 5, 2011 Filing 68 FILING ERROR - DEFICIENT DOCKET ENTRY - REPLY MEMORANDUM OF LAW in Support re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: #1 Affidavit Declaration of Hugh H. Mo in Reply and in Further Support of Defendants' Motion for Sanctions)(Mo, Hugh) Modified on 8/8/2011 (ldi).
August 5, 2011 Filing 67 CERTIFICATE OF SERVICE of Memorandum of Law in Reply and in Further Support of Motion to Dismiss pursuant to Fed. R. Civ. P. Rule 12(b)(6) served on Plaintiff on 08/05/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
August 5, 2011 Filing 66 REPLY MEMORANDUM OF LAW in Support re: #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
August 5, 2011 Filing 65 CERTIFICATE OF SERVICE of Memorandum of Law in Reply and In Further Support of Motion to Dismiss pursuant to Fed. R. Civ. P. Rule 12(b)(1) served on Plaintiff on 08/05/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
August 5, 2011 Filing 64 REPLY MEMORANDUM OF LAW in Support re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
July 29, 2011 Filing 63 CERTIFICATE OF SERVICE of Memorandum of Law, Declaration of Franklin K. Chiu, and exhibits annexed thereto, in Opposition to Plaintiff's Second Motion for Leave to Amend and File a Third Amended Complaint served on Plaintiff Sang Lan on 07/29/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
July 29, 2011 Filing 62 DECLARATION of Franklin K. Chiu in Opposition re: #43 SECOND MOTION to Amend/Correct #32 Amended Complaint,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: #1 Exhibit Plaintiff's Initial Complaint, #2 Exhibit Plaintiff's First Amended Complaint, #3 Exhibit Plaintiff's Second Amended Complaint, #4 Exhibit Plaintiff's Affidavit in Opposition to Defendants' Motions to Dismiss, #5 Exhibit Plaintiff's Attorney's Affirmation in Opposition to Defendants' Motions to Dismiss, #6 Exhibit 5/12/11 AP Article)(Mo, Hugh)
July 29, 2011 Filing 61 MEMORANDUM OF LAW in Opposition re: #43 SECOND MOTION to Amend/Correct #32 Amended Complaint,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh)
July 28, 2011 Filing 60 AFFIDAVIT of Sang Lan in Opposition re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq.. Document filed by Sang Lan. (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 Affidavit Service)(Hai, Ming)
July 28, 2011 Filing 59 AFFIRMATION of Ming Hai in Opposition re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq.. Document filed by Sang Lan. (Attachments: #1 Exhibit A, 3rd Amended Complaint, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Certificate of Translation, #9 Affidavit of Service)(Hai, Ming)
July 25, 2011 Filing 58 FILING ERROR - DEFICIENT DOCKET ENTRY - (SEE DOCUMENT #59) - AFFIRMATION of Attorney Ming Hai in corrected version in Opposition re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction., #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by Sang Lan. (Attachments: #1 Exhibit O, #2 Exhibit P, #3 Affidavit of Service)(Hai, Ming) Modified on 7/28/2011 (lb).
July 25, 2011 Filing 57 FILING ERROR - DUPLICATED DOCKET ENTRY (SEE DOCUMENT #59) - AFFIRMATION of attorney Ming Hai in Opposition re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction., #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6). Document filed by Sang Lan. (Attachments: #1 Exhibit O, #2 Exhibit P)(Hai, Ming) Modified on 7/25/2011 (ldi). Modified on 7/28/2011 (lb).
July 22, 2011 Filing 56 AFFIRMATION of Ming Hai in Opposition re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction., #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by Sang Lan. (Attachments: #1 Exhibit O, #2 Exhibit P, #3 Affidavit of Service)(Hai, Ming)
July 22, 2011 Filing 55 AFFIDAVIT of Sang Lan in Opposition re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction., #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by Sang Lan. (Attachments: #1 3rd Amended Complaint, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Exhibit N, #16 Affidavit of service)(Hai, Ming)
July 19, 2011 Opinion or Order Filing 54 ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Dispositive Motion (i.e., motion requiring a Report and Recommendation) - Motion to Dismiss and Specific Non-Dispositive Motion/Dispute - Motion for Sanctions. Referred to Magistrate Judge James C. Francis. Motions referred to James C. Francis. (Signed by Judge Leonard B. Sand on 7/18/11) (rjm)
July 18, 2011 Opinion or Order Filing 53 STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE: IT IS HEREBY STIPULATED AND AGREED AS BETWEEN PLAINTIFF SANG LAN and the DEFENDANTS, TIG INSURANCE COMPANY, TIG SPECIALTY INSURANCE SOLUTIONS, RIVERSTONE CLAIMS MANAGEMENT, LLC and THE UNITED STATES GYMNASTICS FEDERATION D/B/A USA GYMNASTICS, as follows: That, as no party hereto is an infant or incompetent, this action and all claims asserted therein are voluntarily dismissed with prejudice and with no order of costs or attorney's fees to either party. (Signed by Judge Leonard B. Sand on 7/18/2011) (jfe)
July 18, 2011 Filing 52 ENDORSED LETTER addressed to Magistrate Judge James C. Francis from Ming Hai dated 7/15/11 re: counsel for plaintiff respectfully requests an extension of time for the plaintiff/her attorney to submit an opposition to Defendants Rule 11 Sanction Motion for 90 days or until determinations of the two pending "Motions to Dismiss", whichever is later. ENDORSEMENT: Application denied. Plaintiff shall answer the Rule 11 motion by July 29, 2011, and defendants shall reply by August 5, 2011. ( Responses due by 7/29/2011, Replies due by 8/5/2011.) (Signed by Magistrate Judge James C. Francis on 7/18/11) (pl)
July 13, 2011 Opinion or Order Filing 51 STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE: IT IS HEREBY STIPULATED AND AGREED That, as no party hereto is an infant or incompetent, this action and all claims asserted therein are vohuntarily dismissed with prejudice and with no order of costs or attorney's fees to either party. (Signed by Judge Leonard B. Sand on 7/13/2011) (jfe) Modified on 7/18/2011 (djc).
July 12, 2011 Filing 50 CERTIFICATE OF SERVICE of Notice of Motion for Sanctions, Memorandum of Law in Support, Declaration of Franklin K. Chiu, and exhibits annexed thereto served on Plaintiff Sang Lan on 06/19/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Mo, Hugh)
July 12, 2011 Filing 49 MEMORANDUM OF LAW in Support re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Mo, Hugh)
July 12, 2011 Filing 48 DECLARATION of Franklin K. Chiu, Esq. in Support re: #47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (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)(Mo, Hugh)
July 12, 2011 Filing 47 MOTION for Sanctions against Plaintiff Sang Lan and her attorney Ming Hai, Esq. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue.(Mo, Hugh)
July 11, 2011 Opinion or Order Filing 46 ENDORSED LETTER addressed to Judge Leonard B. Sand from Hugh H. Mo dated 6/30/11 re: Defendants have filed two Motions to Dismiss pursuant to Fed. R. Civ. P. Rule 12(b)(6) and Rule 12(b)(1), on June 19 and 24, 2011, Docket Entries #28 and #34, respectively. We have conferred with plaintiff's counsel regarding a joint briefing schedule for both of these motions, and have reached an agreement on consent that: Plaintiff's answering papers to both motions must be served on or before July 25, 2011; and, Defendants' reply papers as to both motions must be served on or before August 5, 2011. ENDORSEMENT: Oral argument will be scheduled upon resolution of motion to amend. So ordered (Signed by Judge Leonard B. Sand on 7/6/11) (djc)
July 8, 2011 Opinion or Order Filing 45 ENDORSED LETTER: addressed to Magistrate Judge James C. Francis from Hugh H. Mo dated 7/8/2011 re: Plaintiff has recently filed a Second Motion to Amend Plaintiff's Amended Complaint, and the parties have agreed to a briefing schedule that defendants will submit opposition to said Motion by July 29, 2011, and Plaintiff's reply by August 12. 2011. ENDORSEMENT: So Ordered. (Signed by Magistrate Judge James C. Francis on 7/8/11) (js)
July 6, 2011 Filing 44 DECLARATION of Ming Hai in Support re: #43 SECOND MOTION to Amend/Correct #32 Amended Complaint,.. Document filed by Sang Lan. (Attachments: #1 amended complaint, #2 Exhibit A, affidavit of Ping Lu, #3 Exhibit B, statement of Gina Liu, #4 Exhibit C, commercials by using Sang Lan's image, etc., #5 Affidavit of service of Motion with supporting documents)(Hai, Ming)
July 6, 2011 Filing 43 SECOND MOTION to Amend/Correct #32 Amended Complaint,. Document filed by Sang Lan.(Hai, Ming)
July 6, 2011 Opinion or Order Filing 42 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated 6/28/11 re: Defendants respectfully submit that this Court should deny Attorney Hai's request for an extension of time to cure the deficiencies of Plaintiff's Action as referenced in Defendants' Rule 11 Motion, because it is an independent application that does not rely upon the outcome of Defendants' two pending Motions to Dismiss under Rules 12(b)(1) and 12(b)(6). ENDORSEMENT: As no Rule 11 motion is currently pending, there is no deadline to be extended. So ordered. (Signed by Magistrate Judge James C. Francis on 7/6/11) (rjm)
June 29, 2011 Filing 41 NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed without prejudice against the defendant(s) AOL Time Warner, Inc.. (Signed by Judge Leonard B. Sand on 6/29/2011) (jpo)
June 29, 2011 ***NOTE TO ATTORNEY - DOCUMENT REFERRED TO JUDGE FOR APPROVAL. Note to Attorney Ming Hai Document #39 Notice of Voluntary Dismissal, was referred to Judge Leonard B. Sand for approval. (ml)
June 28, 2011 Opinion or Order Filing 40 NOTICE OF VOLUNTARY DISCONTINUANCE AGAINST WINSTON SIE: Please take notice that the plaintiff, through her attorney, hereby voluntarily discontinues this action against Winston Sie without prejudice, on the ground that Sie's counsel Hugh Mo has provided new evidences indicating that Winston Sie has been living in a foreign country since February, 2002. This Notice has been served on Hugh Mo via ECF and mail on the date below by the undersigned. ENDORSEMENT: So Ordered. (Signed by Judge Leonard B. Sand on 6/28/2011) (mbe)
June 28, 2011 Filing 39 DOCUMENT REFERRED TO JUDGE FOR APPROVAL - NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) AOL Time Warner, Inc.. Document filed by Sang Lan. (Hai, Ming) Modified on 6/29/2011 (ml).
June 28, 2011 ***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney Ming Hai for noncompliance with Section (18.4) of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document #38 Notice of Voluntary Dismissal, to: judgments@nysd.uscourts.gov. (dt)
June 27, 2011 Filing 38 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) Winston Sie. Document filed by Sang Lan. (Hai, Ming) Modified on 6/28/2011 (dt).
June 24, 2011 Filing 37 CERTIFICATE OF SERVICE of Notice of Motion to Dismiss Action FRCP 12(b)(1), Memorandum of Law, Declaration and Exhibits served on Plaintiff Sang lan on 06/24/2011. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Mo, Hugh)
June 24, 2011 Filing 36 DECLARATION of Franklin K. Chiu, Esq. in Support re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Mo, Hugh)
June 24, 2011 Filing 35 MEMORANDUM OF LAW in Support re: #34 FIRST MOTION to Dismiss for Lack of Jurisdiction.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Mo, Hugh)
June 24, 2011 Filing 34 FIRST MOTION to Dismiss for Lack of Jurisdiction. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue.(Mo, Hugh)
June 23, 2011 Opinion or Order Filing 33 STIPULATION AND ORDER, IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel, that the time for defendants TIG Insurance Company, TIG Specialty Insurance Solutions and SilverStone Claims Management, LLC, to answer, move or otherwise respond to plaintiff's Summons and Second Amended Complaint in this action, be and the same hereby is extended to and including July 29, 2011. Defendants consent to the Jurisdiction of the Court. (Riverstone Claims Management, LLC answer due 7/29/2011; TIG Insurance Company answer due 7/29/2011; TIG Specialty Insurance Solutions answer due 7/29/2011).( Motions due by 7/29/2011.) (Signed by Magistrate Judge James C. Francis on 6/23/11) (djc)
June 19, 2011 Filing 31 CERTIFICATE OF SERVICE of Notice of Motion to Dismiss, Declaration in Support, Exhibits and Memorandum of Law in Support served on Plaintiff Sang Lan on 06/19/2011. Service was made by Mail. Document filed by K.S. Gina Hiu-Hung, K.S. Liu, Hugh Mo, Wilson Xue. (Mo, Hugh)
June 19, 2011 Filing 30 MEMORANDUM OF LAW in Support re: #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by K.S. Gina Hiu-Hung, K.S. Liu, Hugh Mo, Wilson Xue. (Mo, Hugh)
June 19, 2011 Filing 29 DECLARATION of Franklin K. Chiu in Support re: #28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6).. Document filed by K.S. Gina Hiu-Hung, K.S. Liu, Hugh Mo, Wilson Xue. (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)(Mo, Hugh)
June 19, 2011 Filing 28 FIRST MOTION to Dismiss Case as Frivolous Pursuant to FRCP 12(b)(6). Document filed by K.S. Gina Hiu-Hung, K.S. Liu, Hugh Mo, Wilson Xue.(Mo, Hugh)
June 17, 2011 Filing 32 AMENDED COMPLAINT against AOL Time Warner, Inc., John Does and Jane Does #1 through 15, Inclusive, Gina Liu, K.S. Liu, Hugh Mo, Riverstone Claims Management, LLC, Winston Sie, TIG Insurance Company, TIG Specialty Insurance Solutions, The United States Gymnastics Federation, Ted Turner with JURY DEMAND. Document filed by Sang Lan. (ft) (Additional attachment(s) added on 5/7/2014: #1 Exhibit) (nd).
June 17, 2011 SUMMONS ISSUED as to AOL Time Warner, Inc., John Does and Jane Does #1 through 15, Inclusive, Gina Liu, K.S. Liu, Hugh Mo, Riverstone Claims Management, LLC, Winston Sie, TIG Insurance Company, TIG Specialty Insurance Solutions, The United States Gymnastics Federation, Ted Turner. (ft)
June 16, 2011 Filing 27 NOTICE OF APPEARANCE by Hugh Hu Mo on behalf of Wilson Xue (Mo, Hugh)
June 16, 2011 Filing 26 NOTICE OF APPEARANCE by Hugh Hu Mo on behalf of K.S. Liu (Mo, Hugh)
June 16, 2011 Filing 25 NOTICE OF APPEARANCE by Hugh Hu Mo on behalf of K.S. Gina Hiu-Hung (Mo, Hugh)
June 16, 2011 Filing 24 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Wilson Xue served on 6/6/2011, answer due 6/27/2011. Service was made by fix and mail. Document filed by Sang Lan. (Hai, Ming)
June 16, 2011 Filing 23 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. K.S. Liu served on 6/6/2011, answer due 6/27/2011. Service was made by fix and mail. Document filed by Sang Lan. (Hai, Ming)
June 16, 2011 Filing 22 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. K.S. Gina Hiu-Hung served on 6/6/2011, answer due 6/27/2011. Service was made by Posted to the door and mail. Document filed by Sang Lan. (Hai, Ming)
June 15, 2011 Filing 21 ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from Ming Hai dated 6/14/2011 re: Counsel for the Plaintiff writes to inform the Court that opposing counsel will not be opposing the Plaintiff's motion to amended the amended complaint. ENDORSEMENT: Plaintiffs' motion to amend (Docket no. 18) is granted as unopposed. Plaintiff shall promptly serve and file the Amended Complaint. Judges initials are to appear on ALL papers submitted to this Court. (Signed by Magistrate Judge James C. Francis on 6/14/2011) (ab)
June 14, 2011 Filing 20 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - RESPONSE to Motion re: #18 FIRST MOTION to Amend/Correct Amended Complaint. Document filed by Sang Lan. (Attachments: #1 Exhibit Opposing counsel Hugh Mo's response)(Hai, Ming) Modified on 6/14/2011 (ldi).
June 14, 2011 ***NOTE TO ATTORNEY THAT THE ATTEMPTED FILING OF Document No. #20 HAS BEEN REJECTED. Note to Attorney Ming Hai : THE CLERK'S OFFICE DOES NOT ACCEPT LETTERS FOR FILING, either through ECF or otherwise, except where the judge has ordered that a particular letter be docketed. Letters may be sent directly to a judge. (ldi)
June 9, 2011 Filing 19 AFFIRMATION of Ming Hai in Support re: #18 FIRST MOTION to Amend/Correct Amended Complaint.. Document filed by Sang Lan. (Attachments: #1 2nd Amended Complaint, #2 Exhibit Ping Lu Affidavit, #3 Exhibit Gina Liu Statement, #4 Affidavit Affidavit of Service of Motion Papers)(Hai, Ming)
June 9, 2011 Filing 18 FIRST MOTION to Amend/Correct Amended Complaint. Document filed by Sang Lan.(Hai, Ming)
June 8, 2011 ***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document #17 FIRST MOTION to Amend/Correct Amended Complaint. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Declaration in Support of Motion is found under the event list Replies, Opposition and Supporting Documents. NOTE: Only re-file one motion, and declaration with attachments. (ldi)
June 8, 2011 Filing 17 FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION to Amend/Correct Amended Complaint. Document filed by Sang Lan. (Attachments: #1 Affidavit attorney declaration, #2 2nd Amended Complaint, #3 Affidavit Exhibit A: affidavit by Ping Lu, #4 Exhibit Exhibit B: statement by Gina Liu, #5 Affidavit Affidavit of Service of motion papers)(Hai, Ming) Modified on 6/9/2011 (ldi).
June 8, 2011 Filing 16 FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION to Amend/Correct Amended Complaint. Document filed by Sang Lan. (Attachments: #1 Affidavit attorney declaration, #2 2nd amended complaint, #3 Affidavit affidavit of service of motion)(Hai, Ming) Modified on 6/9/2011 (ldi).
June 6, 2011 Filing 15 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Service was made by certified mail for additional service. Document filed by Sang Lan. (Hai, Ming)
June 6, 2011 Filing 14 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Service was made by certified mail for additional service. Document filed by Sang Lan. (Hai, Ming)
June 6, 2011 Filing 13 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. TIG Specialty Insurance Solutions served on 6/6/2011, answer due 6/27/2011. Service was accepted by Aixa Flores. Service was made by Mail, too. Document filed by Sang Lan. (Hai, Ming)
June 6, 2011 Filing 12 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. TIG Insurance Company served on 6/6/2011, answer due 6/27/2011. Service was accepted by Axia Flores. Service was made by Mail, too. Document filed by Sang Lan. (Hai, Ming)
June 6, 2011 Filing 11 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Riverstone Claims Management, LLC served on 6/6/2011, answer due 6/27/2011. Service was accepted by Axia Flores. Service was made by Mail, too. Document filed by Sang Lan. (Hai, Ming)
June 2, 2011 Filing 10 ENDORSED LETTER addressed to Judge Leonard B. Sand from Hugh H. Mo dated 5/27/11 re: Counsel requests that Your Honor grant application to extend the undersigned parties' time to answer or otherwise respond to plaintiff's Amended Complaint until 60 days after plaintiff also serves her Amended Complaint upon the Liu's. ENDORSEMENT: Defendant Mo's time to answer or move with respect to the amended complaint is extended to July 15, 2011, Hugh Mo answer due 7/15/2011. (Motions due by 7/15/2011.) (Signed by Magistrate Judge James C. Francis on 6/2/11) (djc)
June 2, 2011 Opinion or Order Filing 9 ORDER REFERRING CASE TO MAGISTRATE JUDGE. 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 James C. Francis. (Signed by Judge Leonard B. Sand on 6/2/2011) (jpo)
May 27, 2011 Filing 8 NOTICE OF APPEARANCE by Hugh Hu Mo on behalf of Hugh Mo (Mo, Hugh)
May 24, 2011 Filing 7 NOTICE OF VOLUNTARY DISCONTINUANCE AS AGAINST TED TURNER, the plaintiff, through her attorney, hereby voluntarily discontinues any and all claims/cause of actions as against Ted Turner in this action with prejudice. (Signed by Judge Leonard B. Sand on 5/24/11) (pl)
May 23, 2011 ***NOTE TO ATTORNEY - DOCUMENT REFERRED TO JUDGE FOR APPROVAL. Note to Attorney Ming Hai Document #5 Notice of Voluntary Dismissal, was referred to Judge Leonard B. Sand for approval. (dt)
May 20, 2011 Filing 6 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Hugh Mo served on 5/20/2011, answer due 6/10/2011. Service was accepted by Hugh Mo. Document filed by Sang Lan. (Hai, Ming)
May 20, 2011 Filing 5 DOCUMENT REFERRED TO JUDGE FOR APPROVAL - NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, with prejudice against the defendant(s) Ted Turner. Document filed by Sang Lan. (Hai, Ming) Modified on 5/23/2011 (dt).
May 17, 2011 Filing 3 NOTICE OF CASE REASSIGNMENT to Judge Leonard B. Sand. Judge Thomas P. Griesa is no longer assigned to the case. (sjo)
May 13, 2011 Filing 4 AMENDED COMPLAINT amending #1 Complaint, against AOL Time Warner, Inc., K.S. Gina Hiu-Hung, K.S. Liu, Riverstone Claims Management, LLC, TIG Insurance Company, TIG Specialty Insurance Solutions, The United States Gymnastics Federation, Ted Turner, Wilson Xue, Hugh Mo, John Does and Jane Does #1 through 15, Inclusive with JURY DEMAND.Document filed by Sang Lan. Related document: #1 Complaint, filed by Sang Lan.(cd) (nd).
May 13, 2011 ***NOTE TO ATTORNEY THAT THE ATTEMPTED FILING OF Document No. #2 HAS BEEN REJECTED. Note to Attorney Ming Hai : THE CLERK'S OFFICE DOES NOT ACCEPT LETTERS FOR FILING, either through ECF or otherwise, except where the judge has ordered that a particular letter be docketed. Letters may be sent directly to a judge. (db)
May 13, 2011 Filing 2 FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION to Amend/Correct #1 Complaint. Document filed by Sang Lan. (Attachments: #1 amended verified complaint)(Hai, Ming) Modified on 5/16/2011 (db).
April 28, 2011 Filing 1 COMPLAINT against AOL Time Warner, Inc., K.S. Gina Hiu-Hung, K.S. Liu, Riverstone Claims Management, LLC, TIG Insurance Company, TIG Specialty Insurance Solutions, The United States Gymnastics Federation, Ted Turner. (Filing Fee $ 350.00, Receipt Number 465401005294)Document filed by Sang Lan.(rdz) (nd).
April 28, 2011 SUMMONS ISSUED as to All Defendants. (rdz)
April 28, 2011 Case Designated ECF. (rdz)
April 28, 2011 Magistrate Judge James C. Francis IV is so designated. (rdz)

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Search for this case: Lan v. AOL Time Warner, Inc. et al
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Defendant: Gina Hiu-Hung Liu
Represented By: Pedro Medina, Jr
Represented By: Milo Silberstein
Represented By: Hugh Hu Mo
Represented By: Maria Louisa Bianco
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Defendant: Keo-Sung Liu
Represented By: Pedro Medina, Jr
Represented By: Milo Silberstein
Represented By: Hugh Hu Mo
Represented By: Maria Louisa Bianco
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Defendant: Gina Liu
Represented By: Pedro Medina, Jr
Represented By: Milo Silberstein
Represented By: Hugh Hu Mo
Represented By: Maria Louisa Bianco
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Defendant: Hugh Hu Mo
Represented By: Pedro Medina, Jr
Represented By: Hugh Hu Mo
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Defendant: Ted Turner
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Defendant: Time Warner, Inc.
Represented By: James Andrew Lamberth
Represented By: Alan William Bakowski
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Defendant: John Does and Jane Does #1 through 15, Inclusive
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Defendant: TIG Insurance Company
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Defendant: Hui-Hung Sie
Represented By: Pedro Medina, Jr
Represented By: Milo Silberstein
Represented By: Hugh Hu Mo
Represented By: Maria Louisa Bianco
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Defendant: Hugh Mo
Represented By: Hugh Hu Mo
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Defendant: Wilson Xue
Represented By: Hugh Hu Mo
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Defendant: AOL Time Warner, Inc.
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Defendant: TIG Specialty Insurance Solutions
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Defendant: Does 1-30
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Defendant: Winston Sie
Represented By: Hugh Hu Mo
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Defendant: Riverstone Claims Management, LLC
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Defendant: The United States Gymnastics Federation
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Plaintiff: Sang Lan
Represented By: Ming Hai
Represented By: Allan Steven Schiller
Represented By: John Vincent Golaszewski
Represented By: Brian Patrick Fredericks
Represented By: X. Bing Xu
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Petitioner: former attorney Ming Hai
Represented By: Ming Hai
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