Villella et al v. Chemical & Mining Co. of Chile Inc. et al
| Villella and Megan Villella |
| Chemical & Mining Co. of Chile Inc, Patricio Contesse, Chemical & Mining Co. of Chile Inc., Patricio De Solminihac and Ricardo Ramos |
| Richard Gielata, Leroy Robinson, Arkansas Public Employees Retirement System, The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund, Sam Villella, Anton Mandelstam and Marty Sholtis |
| Lynn Molinaro |
| 1:2015cv02106 |
| March 19, 2015 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| XX Out of State |
| Edgardo Ramos |
| Securities/Commodities |
| 15 U.S.C. § 78 |
| Plaintiff |
Docket Report
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Filing 155
JOINT STIPULATION AND SCHEDULING ORDER AMENDING MAY 9, 2018, JULY 27, 2018 AND OCTOBER 1, 2018 ORDERS, Accordingly, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: Fact Discovery Cutoff is May 31, 2019, Expert Reports Due July 1, 2019, Expert Responses Due August 16, 2019, Expert Discovery Cutoff is September 13, 2019, Dispositive Motions Due October 28, 2019. The above deadlines depend upon timely completion of fact and expert discovery. Each party reserves the right to seek an extension of the above deadlines. SO ORDERED. (Expert Discovery due by 9/13/2019., Fact Discovery due by 5/31/2019., Motions due by 10/28/2019.) (Signed by Judge Edgardo Ramos on 3/18/2019) (kv)
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| Filing 154 PROPOSED SCHEDULING ORDER. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Melamed, Matthew) |
| Filing 153 DECLARATION of Grant Mainland in Support re: (128 in 1:15-cv-02106-ER) MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt.. Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit 1)Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Mainland, Grant) |
| Filing 152 REPLY MEMORANDUM OF LAW in Support re: (128 in 1:15-cv-02106-ER) MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt. . Document filed by Chemical & Mining Co. of Chile Inc.. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Mainland, Grant) |
| Filing 151 NOTICE OF CHANGE OF ADDRESS by Alison Bonelli on behalf of Chemical & Mining Co. of Chile Inc.. New Address: Milbank, LLP, 55 Hudson Yards, New York, New York, USA 10001, (212) 530-5000. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Bonelli, Alison) |
| Filing 150 NOTICE OF CHANGE OF ADDRESS by Scott Alexander Edelman on behalf of Chemical & Mining Co. of Chile Inc.. New Address: Milbank, LLP, 55 Hudson Yards, New York, New York, USA 10001, (212) 530-5000. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Edelman, Scott) |
| Filing 149 NOTICE OF CHANGE OF ADDRESS by Grant Richard Mainland on behalf of Chemical & Mining Co. of Chile Inc.. New Address: Milbank, LLP, 55 Hudson Yards, New York, New York, USA 10001, (212) 530-5000. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Mainland, Grant) |
| Filing 148 NOTICE of Firm Name and Address Change. Document filed by Chemical & Mining Co. of Chile Inc.. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Mainland, Grant) |
| Filing 147 LETTER MOTION for Oral Argument #75 , #128 addressed to Judge Edgardo Ramos from John H. George dated 01/25/2019. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
| Filing 146 DECLARATION of Aelish M. Baig in Support re: #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel.. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Baig, Aelish) |
| Filing 145 REPLY MEMORANDUM OF LAW in Support re: #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel. . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
| Filing 144 MEMORANDUM OF LAW in Opposition re: #128 MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt. . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
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Filing 143
ORDER granting #137 Letter Motion for Discovery; granting #142 Letter Motion for Leave to File Excess Pages. The application is granted. The Clerk of Court is respectfully directed to terminate the motions in Docs. 137, 142. (Signed by Judge Edgardo Ramos on 1/18/2019) (cf)
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| Filing 142 LETTER MOTION for Leave to File Excess Pages addressed to Judge Edgardo Ramos from John H. George dated 01/18/2019. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
| LETTERS ROGATORY ISSUED on January 16, 2019, and picked up by Robbins Geller Rudman & Dowd LLP, to produce documents and give testimony and to compel Wayne R. Brownlee and Nutrien Ltd. in the Saskatchewan Court of Queen's bench in Saskatoon, Canada. (km) |
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Filing 141
MEMO ENDORSEMENT on re: #140 Letter, filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. ENDORSEMENT: The Court has reviewed the modified letters rogatory and concludes that they are consistent with the instructions set forth in the Court Opinion & Order, see Doc. 139. Lead Plaintiff should visit the Clerk's Office to coordinate execution of the letters rogatory. SO ORDERED. (Signed by Judge Edgardo Ramos on 1/15/2019) (kv)
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| Filing 140 LETTER addressed to Judge Edgardo Ramos from John H. George dated 01/14/2019 re: Issuance of Letters Rogatory to Subpoena Foreign Third Parties. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A, #2 Exhibit B)(George, John) |
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Filing 139
OPINION & ORDER re: #110 MOTION for Issuance of Letters Rogatory as to Subpoena Foreign Third Parties in Canada filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. For the reasons aforementioned, the Fund's motion for issuance of letters of request is GRANTED. The Fund is hereby ORDERED to resubmit its proposed letters of request, revised only to include the modifications approved by the Court herein, within seven calendar days of the filing of this Opinion & Order. The Clerk of Court is respectfully directed to terminate the motion, Doc. 110. It is SO ORDERED. (Signed by Judge Edgardo Ramos on 1/11/2019) (mml)
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Filing 138
ORDER granting #124 Letter Motion for Leave to File Document. ENDORSEMENT: Plaintiff's motion to renew its motion for class certification is GRANTED. The Clerk of Court is respectfully directed to place the motion back on the Court's calendar. (Signed by Judge Edgardo Ramos on 1/10/2019) (mro)
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| Filing 137 LETTER MOTION for Discovery #110 addressed to Judge Edgardo Ramos from John H. George dated 01/03/2019. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
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Filing 136
JOINT STIPULATION AND SCHEDULE FOR MOTION TO EXCLUDE BRIEFING: Accordingly, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, that the following deadlines will apply: Motion to Exclude Opposition by January 25, 2019, Motion to Exclude Reply by February 15, 2019. SO ORDERED. (Responses due by 1/25/2019, Replies due by 2/15/2019.) (Signed by Judge Edgardo Ramos on 12/26/2018) Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(kv)
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| Filing 135 PROPOSED STIPULATION AND ORDER. Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
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Filing 134
ORDER granting #131 Motion to Seal limited portions of SQM's opposition to Plaintiff's motion for class certification, appointment of class representative and appointment of class counsel. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (jar) Transmission to Sealed Records Clerk for processing.
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| Filing 133 NOTICE OF APPEARANCE by Alison Bonelli on behalf of Chemical & Mining Co. of Chile Inc.. Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Bonelli, Alison) |
| Filing 132 SEALED DOCUMENT placed in vault.(mhe) |
| Filing 131 LETTER MOTION to Seal Document and for Oral Argument addressed to Judge Edgardo Ramos from Grant R. Mainland dated December 12, 2018. Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| Filing 130 DECLARATION of Grant R. Mainland in Support re: #128 MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt.. Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31)(Mainland, Grant) |
| Filing 129 MEMORANDUM OF LAW in Support re: #128 MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt. . Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
| Filing 128 MOTION to Preclude The Testimony Of Plaintiff's Expert, Bjorn I. Steinholt. Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 127 MEMORANDUM OF LAW in Opposition re: #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel. . Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
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Filing 126
ORDER granting (125) Letter Motion for Leave to File Excess Pages in case 1:15-cv-02106-ER. SQM is granted leave to file (1) an opposition brief of not more than 30 pages and (2) its Daubert motion. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER (jar)
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| Filing 125 LETTER MOTION for Leave to File Excess Pages and Daubert Motion addressed to Judge Edgardo Ramos from Grant R. Mainland dated 12/10/2018. Document filed by Chemical & Mining Co. of Chile Inc..Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER(Mainland, Grant) |
| Filing 124 LETTER MOTION for Leave to File Renewal of Motion for Class Certification #75 , #121 addressed to Judge Edgardo Ramos from John H. George dated 12/3/2018. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
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Filing 123
JOINT STIPULATION AND SCHEDULING ORDER AMENDING MAY 9, 2018 AND JULY 27, 2018 ORDERS: Responses due by 12/12/2018. Replies due by 1/25/2019. Fact Discovery due by 3/30/2019. Expert Discovery due by 8/15/2019. Dispositive Motions due by 9/27/2019, and as further set forth in this order. (Signed by Judge Edgardo Ramos on 10/1/2018) (jwh) Modified on 2/22/2019 (jwh).
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| Filing 122 PROPOSED STIPULATION AND ORDER. Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
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Filing 121
ORDER AMENDING CLASS CERTIFICATION BRIEFING SCHEDULE granting #120 Letter Motion for Extension of Time: The Court hereby orders the following class certification briefing schedule: Class Certification Opposition: 30 days after completion of international discovery from Sarasin & Partners LLP, but in no event later than October 1, 2018, unless good cause for a further extension is shown. Class Certification Reply: 45 days after SQM files and serves its opposition to Plaintiff's class certification motion, Moreover, in light of the international discovery that must take place before Defendants can respond to Plaintiff's class certification motion, Doc. 75, the motion is placed off calendar, subject to renewal by letter motion when discovery is complete. (Signed by Judge Edgardo Ramos on 7/27/2018) (jwh) Modified on 7/30/2018 (jwh).
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| Set/Reset Deadlines as to #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel: Responses due by 10/1/2018 (jwh) |
| Filing 120 LETTER MOTION for Extension of Time to File Class Certification Opposition addressed to Judge Edgardo Ramos from Grant R. Mainland dated July 25, 2018. Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A)(Mainland, Grant) |
| LETTERS ROGATORY ISSUED on June 20, 2018 and picked up by MILBANK, TWEED, HADLEY & MCCLOY LLP, and to be served on the Senior Master of the Queen's Bench Division of the High Court, Royal Courts of Justice, Strand, London. (km) |
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Filing 119
ORDER granting #117 Motion for Armen Zohrabian to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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Filing 118
OPINION & ORDER re: #89 MOTION for Issuance of Letters Rogatory in Great Britain filed by Chemical & Mining Co. of Chile Inc. Accordingly, the Court GRANTS Defendant's motion for the issuance of a letter of request. The Clerk of Court is respectfully directed to terminate the motion, Doc. 89. (Signed by Judge Edgardo Ramos on 6/12/2018) (mro)
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| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #117 MOTION for Armen Zohrabian to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 117 MOTION for Armen Zohrabian to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Affidavit in Support of Motion for Admission Pro Hac Vice of Armen Zohrabian, #2 Exhibit A - Certificate of Good Standing, #3 Text of Proposed Order)(Zohrabian, Armen) |
| >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #115 MOTION for Armen Zohrabian to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-15049856. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Attorney Affidavit or Declaration - see Local Rule 1.3. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Attorney Affidavit or Declaration - attach Proposed Order. (jc) |
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Filing 116
JOINT STIPULATION AND ORDER AMENDING JUNE 8, 2017, SCHEDULING ORDER AND APRIL 23, 2018, SECOND AMENDED CLASS CERTIFICATION ORDER: Accordingly, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: Class Certification Opposition: 30 days after the earlier of (i) any denial of the Hague Convention Motion, or (ii) completion of international discovery from Sarasin after any granting of the Hague Convention Motion, but in no event later than July 30, 2018, unless good cause for further extension is shown. Class Certification Reply: 45 days after SQM files and serves its opposition to the Class Certification Motion. Expert Discovery due by 7/1/2019. Fact Discovery due by 12/14/2018. Motions due by 7/29/2019. (Signed by Judge Edgardo Ramos on 5/9/2018) (jwh)
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| Filing 115 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Armen Zohrabian to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-15049856. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A - Certificate of Good Standing, #2 Text of Proposed Order)(Zohrabian, Armen) Modified on 5/10/2018 (jc). |
| Filing 114 RESPONSE to Motion re: #110 MOTION for Issuance of Letters Rogatory as to Subpoena Foreign Third Parties in Canada . . Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A)(Mainland, Grant) |
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Filing 113
SECOND AMENDED STIPULATION AND ORDER SETTING SCHEDULE FOR PLAINTIFF'S MOTION FOR CLASS CERTIFICATION: Accordingly, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: 1. SQM shall serve and file its opposition to the Class Certification Motion no later than May 14, 2018; 2. Plaintiff shall serve and file its reply in further support of the Class Certification Motion no later than June 29, 2018; 3. The parties shall use their best efforts to negotiate and agree upon, by no later than May 7, 2018, a joint stipulation and proposed order amending the Scheduling Order, which the parties anticipate will include modifications to the deadlines governing fact discovery, class certification briefing, expert discovery, and dispositive motions; and 4. Should the parties be unable to reach an agreement concerning an amendment to the Scheduling Order, the parties reserve the right to seek an order of the Court amending the Scheduling Order. (Set Deadlines/Hearing as to #75 MOTION to Certify Class: Responses due by 5/14/2018, Replies due by 6/29/2018.) (Signed by Judge Edgardo Ramos on 4/23/2018) (jwh)
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| Filing 112 DECLARATION of John H. George in Support re: #110 MOTION for Issuance of Letters Rogatory as to Subpoena Foreign Third Parties in Canada .. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A - Letters Rogatory, #2 Exhibit B - Proposed Subpoenas, #3 Exhibit C - October 17, 2017 Letter)(George, John) |
| Filing 111 MEMORANDUM OF LAW in Support re: #110 MOTION for Issuance of Letters Rogatory as to Subpoena Foreign Third Parties in Canada . . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (George, John) |
| Filing 110 MOTION for Issuance of Letters Rogatory as to Subpoena Foreign Third Parties in Canada . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
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Filing 109
ORDER granting #106 Letter Motion for Conference. The pre-motion conference is waived. Plaintiff is granted leave to file a motion for letters rogatory with the following briefing schedule: moving papers due April 20, 2018, and opposition due May 4, 2018. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| Filing 108 LETTER RESPONSE to Motion addressed to Judge Edgardo Ramos from Grant R. Mainland dated April 4, 2018 re: #106 LETTER MOTION for Conference addressed to Judge Edgardo Ramos from John H. George dated March 27, 2018. . Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
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Filing 107
ORDER re #106 Letter Motion for Conference. Defendant id directed to respond by 5:00 PM Wednesday, April 4, 2018. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| Filing 106 LETTER MOTION for Conference addressed to Judge Edgardo Ramos from John H. George dated March 27, 2018. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
| Filing 105 REPLY MEMORANDUM OF LAW in Support re: #89 MOTION for Issuance of Letters Rogatory in Great Britain . . Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
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Filing 104
ORDER granting #99 LETTER MOTION for Leave to File Reply addressed to Judge Edgardo Ramos from Grant R. Mainland dated March 20, 2018. Document filed by Chemical & Mining Co. of Chile Inc. Defendant is granted leave to file a reply by March 27, 2018. SO ORDERED. (Signed by Judge Edgardo Ramos on 3/22/2018) (rjm)
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| Filing 103 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/8/18 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) |
| Filing 102 TRANSCRIPT of Proceedings re: conference held on 3/8/2018 before Judge Edgardo Ramos. Court Reporter/Transcriber: Lisa Picciano Fellis, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/12/2018. Redacted Transcript Deadline set for 4/23/2018. Release of Transcript Restriction set for 6/20/2018.(McGuirk, Kelly) |
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Filing 101
ORDER granting #97 Motion to Seal Document. The application is granted. (Signed by Judge Edgardo Ramos on 3/20/2018) (jar)
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| Filing 99 LETTER MOTION for Leave to File Reply addressed to Judge Edgardo Ramos from Grant R. Mainland dated March 20, 2018. Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| Filing 100 SEALED DOCUMENT placed in vault.(mps) |
| Filing 98 CERTIFICATE OF SERVICE. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Melamed, Matthew) |
| Filing 97 LETTER MOTION to Seal Document #96 Response to Motion, addressed to Judge Edgardo Ramos from Matthew S. Melamed dated March 19, 2018. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Melamed, Matthew) |
| Filing 96 RESPONSE to Motion re: #89 MOTION for Issuance of Letters Rogatory in Great Britain . . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Melamed, Matthew) |
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Filing 95
AMENDED STIPULATION AND ORDER SETTING SCHEDULE FOR PLAINTIFF'S MOTION FOR CLASS CERTIFICATION: Accordingly, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: 1. SQM shall serve and file its opposition to the Class Certification Motion no later than April 30, 2018; 2. Plaintiff shall serve and file its reply in further support of the Class Certification Motion no later than June 15, 2018; and 3. The above deadlines depend upon timely completion of discovery in connection with the Class Certification Motion. The parties reserve their right to seek an extension of the above deadlines in order to complete discovery relating to the Hague Convention Motion or the Class Certification Motion, or for any other reason. (Set Deadlines/Hearing as to #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel: Responses due by 4/30/2018, Replies due by 6/15/2018.) (Signed by Judge Edgardo Ramos on 3/16/2018) (jwh)
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Filing 94
ORDER granting #92 Motion to Seal Document: The application is granted. (Signed by Judge Edgardo Ramos on 3/13/2018) (jwh)
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| Filing 93 SEALED DOCUMENT placed in vault.(mps) |
| Filing 92 LETTER MOTION to Seal Document and for Oral Argument addressed to Judge Edgardo Ramos from Grant R. Mainland dated March 12, 2018. Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| Filing 91 DECLARATION of Grant R. Mainland in Support re: #89 MOTION for Issuance of Letters Rogatory in Great Britain .. Document filed by Chemical & Mining Co. of Chile Inc.. (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)(Mainland, Grant) |
| Filing 90 MEMORANDUM OF LAW in Support re: #89 MOTION for Issuance of Letters Rogatory in Great Britain . . Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
| Filing 89 MOTION for Issuance of Letters Rogatory in Great Britain . Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| ***DELETED DOCUMENT. Deleted document number #89 RESCHEDULING NOTICE. The document was incorrectly filed in this case. (jar) |
| Minute Entry for proceedings held before Judge Edgardo Ramos: Pre-Motion Conference held on 3/8/2018. Plaintiff's counsel and Defendant's counsel both appear by telephone. Defendant is granted leave to file a motion under the Hague Convention on the taking of evidence abroad with the following briefing scheduling: moving papers due March 12, 2018; and opposition due March 19, 2018. (Motions due by 3/12/2018. Responses due by 3/19/2018.) (Court Reporter Lisa Fellis) (jar) |
| Filing 88 LETTER RESPONSE to Motion addressed to Judge Edgardo Ramos from Matthew S. Melamed dated March 6, 2018 re: #83 LETTER MOTION for Conference Pre-Motion Letter for Informal Conference addressed to Judge Edgardo Ramos from Grant R. Mainland dated 02/19/2018. . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Melamed, Matthew) |
| Filing 87 RESCHEDULING NOTICE: The pre-motion conference currently scheduled for March 7, 2018 at 11:30 AM is hereby rescheduled to March 8, 2018 at 2:00 PM in Courtroom 619 before the Hon. Edgardo Ramos, at the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007. Pre-Motion Conference set for 3/8/2018 at 02:00 PM in Courtroom 619, 40 Centre Street, New York, NY 10007 before Judge Edgardo Ramos. (Signed by Judge Edgardo Ramos on 3/6/2018) (jwh) |
| Filing 86 LETTER REPLY to Response to Motion addressed to Judge Edgardo Ramos from Grant R. Mainland dated March 5, 2018 re: #83 LETTER MOTION for Conference Pre-Motion Letter for Informal Conference addressed to Judge Edgardo Ramos from Grant R. Mainland dated 02/19/2018. . Document filed by Chemical & Mining Co. of Chile Inc.. (Mainland, Grant) |
| DOCKET ANNOTATION: Scheduling Notice. The Court grants Plaintiff's application to conduct the March 7 pre-motion conference via telephone. Plaintiff is directed to organize the parties and then call the Court at (212) 805-0294. (jar) |
| Filing 85 LETTER RESPONSE to Motion addressed to Judge Edgardo Ramos from Matthew S. Melamed dated February 28, 2018 re: #83 LETTER MOTION for Conference Pre-Motion Letter for Informal Conference addressed to Judge Edgardo Ramos from Grant R. Mainland dated 02/19/2018. . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Melamed, Matthew) |
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Filing 84
ORDER granting #83 Letter Motion for Conference. A pre-motion conference will be held on March 7, 2018 at 11:30 am. Plaintiff is directed to file a written response not longer than 3 pages by 5:00 pm Wednesday, February 28, 2018. (Pre-Motion Conference set for 3/7/2018 at 11:30 AM before Judge Edgardo Ramos.) (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| Filing 83 LETTER MOTION for Conference Pre-Motion Letter for Informal Conference addressed to Judge Edgardo Ramos from Grant R. Mainland dated 02/19/2018. Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Mainland, Grant) |
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Filing 82
STIPULATION AND ORDER SETTING SCHEDULE FOR LEAD PLAINTIFF'S MOTION FOR CLASS CERTIFICATION. IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: 1. SQM shall serve and file its opposition to the Class Certification Motion no later than March 30, 2018; and 2. Plaintiff shall serve and file its reply in further support of the Class Certification Motion no later than June 1, 2018. 3. The above deadlines depend upon timely completion of discovery in connection with the Class Certification Motion. The parties reserve their right to seek an extension of the above deadlines due to any discovery delays or for any other reason. So ordered. (Responses due by 3/30/2018. Replies due by 6/1/2018.) (Signed by Judge Edgardo Ramos on 1/25/2018) (rjm)
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| Filing 81 MEMO ENDORSEMENT on #80 Letter filed by Chemical & Mining Co. of Chile Inc. granting #76 Motion to Seal Document. ENDORSEMENT: In view of Government's decision to keep these third-party names private, and the weight courts give the privacy interests of third parties, the Court GRANTS Plaintiff's letter motion requesting leave to file certain documents in redacted form and under seal. The Clerk of Court is respectfully requested to terminate the letter motion, Doc. 76. (Signed by Judge Edgardo Ramos on 1/17/2018) (mro) |
| Filing 80 LETTER addressed to Judge Edgardo Ramos from Grant R. Mainland dated January 16, 2018 re: Plaintiff's Motion to Seal (Dkt. No. 76). Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| Filing 79 MEMO ENDORSEMENT on re: #76 LETTER MOTION to Seal Document #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel. and Ex. A addressed to Judge Edgardo Ramos from Aelish M. Baig dated January 10, 2018. filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. ENDORSEMENT: Defendant, as the designating party, is directed to inform the Court as to why the information sought to be placed under seal overcomes the presumption of public access and the qualified First Amendment right to access judicial documents. (Signed by Judge Edgardo Ramos on 1/11/2018) (cf) |
| Filing 78 SEALED DOCUMENT placed in vault.(rz) |
| Filing 77 CERTIFICATE OF SERVICE. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
| Filing 76 LETTER MOTION to Seal Document #75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel. and Ex. A addressed to Judge Edgardo Ramos from Aelish M. Baig dated January 10, 2018. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Baig, Aelish) |
| Filing 75 MOTION to Certify Class , Appointment of Class Representative and Appointment of Class Counsel. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Declaration of Aelish M. Baig, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D)(Baig, Aelish) |
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Filing 74
JOINT STIPULATION AND PROTECTIVE ORDER:...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Edgardo Ramos on 7/17/2017) (ap)
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| Set/Reset Deadlines: Motions due by 2/11/2019. (ap) |
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Filing 73
ORDER: The Court has reviewed the parties' proposed discovery schedules. (Doc. 71). The Court hereby orders the following discovery schedule: First Request for Production of Documents due by 5/25/2017. Motion for Class Certification due by 1/10/2018. Production of Documents Substantially complete 4/23/2018. Fact Discovery due by 7/23/2018. Initial Expert Reports Due by 9/14/2018. Discovery for Initial Reports due by 11/2/2018. Responding Expert Reports Due 12/3/2018. Discovery for Responding Experts due by 1/14/2019. Dispositive Motions due by 2/11/2019. Joinder of Parties only with leave of Court. Amended Pleadings only with leave of Court. (Signed by Judge Edgardo Ramos on 6/8/2017) (ap) Modified on 6/8/2017 (ap). (Main Document 73 replaced on 6/9/2017) (ap). Modified on 6/9/2017 (ap).
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| Set/Reset Deadlines: Fact Discovery due by 7/23/2018. (ap) |
| Filing 72 ANSWER to #40 Amended Complaint,. Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 71 RULE 26(f) DISCOVERY PLAN REPORT.Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Baig, Aelish) |
| Filing 70 STIPULATION EXTENDING DEFENDANT CHEMICAL AND MINING COMPANY OF CHILE, INC.'S TIME TO ANSWER: IT IS HEREBY STIPULATED AND AGREED that SQM shall answer the Complaint on or before April 25, 2017. Chemical & Mining Co. of Chile Inc. answer due 4/25/2017. (Signed by Judge Edgardo Ramos on 4/10/2017) (mro) |
| Filing 69 MEMO ENDORSEMENT on re: #68 Letter filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. ENDORSEMENT: The initial conference is adjourned to April 20, 2017, at 11:45 am. The application is granted. (Initial Conference set for 4/20/2017 at 11:45 AM before Judge Edgardo Ramos.) (Signed by Judge Edgardo Ramos on 3/30/2017) (jwh) Modified on 4/11/2017 (jwh). |
| Filing 68 LETTER addressed to Judge Edgardo Ramos from Matthew S. Melamed dated March 28, 2017 re: Dkt. No. 67 and Rescheduling PTC. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Melamed, Matthew) |
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Filing 67
OPINION AND ORDER re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc.. filed by Chemical & Mining Co. of Chile Inc.: For the reasons set forth above, Defendant's motion to dismiss on grounds of forum non conveniens is DENIED. Defendant's motion to dismiss for failure to state a claim is DENIED in part and GRANTED in part. Specifically, Defendant's motion to dismiss Plaintiffs claims that SQM made material misstatements in its SEC filings regarding its (1) compliance with applicable law, (2) effectiveness of internal controls, and (3) financial reporting and accounting is DENIED. Defendant's motion to dismiss Plaintiffs claims that SQM made material misrepresentations with respect to its statements regarding its code of ethics and its lease negotiations with Corfo is GRANTED. The parties are directed to appear for an initial pre-trial conference on Thursday, April 13, 2017at10:00 AM. The Clerk of Court is respectfully directed to terminate the motions, Docs. 42, 59. ( Initial Conference set for 4/13/2017 at 10:00 AM before Judge Edgardo Ramos.) (Signed by Judge Edgardo Ramos on 3/28/2017) (jwh) Modified on 4/3/2017 (jwh).
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| Filing 66 LETTER addressed to Judge Edgardo Ramos from Aelish M. Baig dated January 27, 2017 re: Dkt. No. 65. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Baig, Aelish) |
| Filing 65 LETTER addressed to Judge Edgardo Ramos from Scott A. Edelman dated January 25, 2017 re: Lead Plaintiff's Letter Dated January 18, 2017. Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 64 LETTER addressed to Judge Edgardo Ramos from Aelish M. Baig dated January 18, 2017 re: Dkt. No. 61. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Baig, Aelish) |
| Filing 63 NOTICE OF CHANGE OF ADDRESS by Grant Richard Mainland on behalf of Chemical & Mining Co. of Chile Inc.. New Address: Milbank, Tweed, Hadley & McCloy LLP, 28 Liberty Street, New York, NY, United States 10005, (212) 530-5000. (Mainland, Grant) |
| Filing 62 LETTER addressed to Judge Edgardo Ramos from Matthew S. Melamed dated October 14, 2016 re: Dkt. No. 61. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Melamed, Matthew) |
| Filing 61 LETTER addressed to Judge Edgardo Ramos from Scott A. Edelman dated October 13, 2016 re: Lead Plaintiff's Letter Dated October 7, 2016 (ECF No. 60). Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 60 LETTER addressed to Judge Edgardo Ramos from Matthew S. Melamed dated October 7, 2016 re: Defendant Chemical Mining Co. of Chile, Inc.'s Motion to Dismiss the Consolidated Complaint (Dkt. No. 43). Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Pirnik v. Fiat Chrysler Automobile, N.V., et al.)(Melamed, Matthew) |
| Filing 59 LETTER MOTION for Oral Argument addressed to Judge Edgardo Ramos from Scott A. Edelman dated June 29, 2016. Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 58 DECLARATION of Pedro Pablo Vergara in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
| Filing 57 DECLARATION of Grant R. Mainland in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A)(Edelman, Scott) |
| Filing 56 REPLY MEMORANDUM OF LAW in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc.. Reply Memorandum of Law in Further Support of Defendant Chemical and Mining Company of Chile, Inc.'s Motion to Dismiss the Consolidated Complaint. Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
| Filing 55 LETTER addressed to Judge Edgardo Ramos from Aelish M. Baig dated June 10, 2016 re: Certified Translated Copies of Exs. 6 and 7 to Dkt. No. 50. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Certified Translations of Exhibits 6 and 7 to Dkt. No. 50)(Baig, Aelish) |
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Filing 54
ORDER granting #53 Motion for Sabrina E. Tirabassi to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| Filing 53 MOTION for Sabrina E. Tirabassi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-12372478. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit A- Certificate of Good Standing - Supreme Court, #2 Text of Proposed Order)(Tirabassi, Sabrina) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #53 MOTION for Sabrina E. Tirabassi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-12372478. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sdi) |
| Filing 52 NOTICE of Request for Judicial Notice re: #50 Declaration in Opposition to Motion, #49 Memorandum of Law in Opposition to Motion,. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
| Filing 51 DECLARATION of Andres Jana L. in Opposition re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
| Filing 50 DECLARATION of Aelish M. Baig in Opposition re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(Baig, Aelish) |
| Filing 49 MEMORANDUM OF LAW in Opposition re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc.. . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Baig, Aelish) |
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Filing 48
ORDER granting #47 Motion for John Hamilton George to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #47 MOTION for John Hamilton George to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-12236891. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sdi) |
| Filing 47 MOTION for John Hamilton George to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-12236891. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(George, John) |
| Filing 46 DECLARATION of Matias Astaburuaga in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
| Filing 45 DECLARATION of Pedro Pablo Vergara in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A)(Edelman, Scott) |
| Filing 44 DECLARATION of Grant R. Mainland in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc... Document filed by Chemical & Mining Co. of Chile Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Edelman, Scott) |
| Filing 43 MEMORANDUM OF LAW in Support re: #42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc.. Memorandum of Law in Support of Defendant Chemical and Mining Company of Chile, Inc.'s Motion to Dismiss the Consolidated Complaint. Document filed by Chemical & Mining Co. of Chile Inc.. (Edelman, Scott) |
| Filing 42 MOTION to Dismiss Notice of Motion to Dismiss of Defendant Chemical and Mining Company of Chile, Inc.. Document filed by Chemical & Mining Co. of Chile Inc.. Responses due by 5/26/2016(Edelman, Scott) |
| Filing 41 EXHIBIT TO PLEADING re: #40 Amended Complaint,. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Baig, Aelish) |
| Filing 40 CORRECTED CONSOLIDATED COMPLAINT amending #1 Complaint, against Chemical & Mining Co. of Chile Inc. with JURY DEMAND.Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. Related document: #1 Complaint, filed by Megan Villella. (Attachments: #1 Attachment A)(Baig, Aelish) Modified on 2/10/2016 (laq). Modified on 2/16/2016 (laq). |
| Filing 39 AMENDED COMPLAINT amending #1 Complaint, against Chemical & Mining Co. of Chile Inc. with JURY DEMAND.Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. Related document: #1 Complaint, filed by Megan Villella. (Attachments: #1 Attachment A)(Baig, Aelish) Modified on 1/25/2016 (laq). Modified on 1/25/2016 (laq). Modified on 2/11/2016 (laq). |
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Filing 38
STIPULATION AND ORDER REGARDING SERVICE, TIME TO FILE CONSOLIDATED CLASS ACTION COMPLAINT AND SETTING SCHEDULE FOR BRIEFING DEFENDANT'S MOTION TO DISMISS: IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, subject to Court approval, as follows: 1. SQM waives service of process and any defense based on insufficient service of process on SQM; 2. Defendants Patricio Contesse Gonzalez, Patricio de Solminihac Tampier and Ricardo Ramos Rodriguez are hereby dismissed without prejudice; 3. Lead Plaintiff shall have until Friday, January 15, 2016 to file and serve its Consolidated Complaint; 4. SQM shall file its answer or motion to dismiss the Consolidated Complaint by Wednesday, March 30, 2016; 5. Lead Plaintiff shall file its opposition to any motion to dismiss by Thursday, May 26, 2016; 6. SQM shall file any reply in support of its motion to dismiss by Wednesday, June 29, 2016. ( Amended Pleadings due by 1/15/2016., Motions due by 3/30/2016., Responses due by 5/26/2016, Replies due by 6/29/2016., Service due by 1/15/2016.) (Signed by Judge Edgardo Ramos on 11/13/2015) (mro)
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Filing 37
ORDER granting #34 FIRST LETTER MOTION for Extension of Time addressed to Judge Edgardo Ramos from Multiple Parties dated November 4, 2015. Document filed by Chemical & Mining Co. of Chile Inc. The application is granted. (Signed by Judge Edgardo Ramos on 11/5/2015) (rjm)
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Filing 36
ORDER granting #33 Motion for Matthew Seth Melamed to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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Filing 35
ORDER granting #32 Motion for Aelish Marie Baig to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (Ramos, Edgardo)
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| Filing 34 FIRST LETTER MOTION for Extension of Time addressed to Judge Edgardo Ramos from Multiple Parties dated November 4, 2015. Document filed by Chemical & Mining Co. of Chile Inc..(Mainland, Grant) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #32 MOTION for Aelish Marie Baig to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-11585708. Motion and supporting papers to be reviewed by Clerk's Office staff., #33 MOTION for Matthew Seth Melamed to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-11585730. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 33 MOTION for Matthew Seth Melamed to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-11585730. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Melamed, Matthew) |
| Filing 32 MOTION for Aelish Marie Baig to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-11585708. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund.(Baig, Aelish) |
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Filing 31
OPINION AND ORDER re: (7 in 1:15-cv-02106-ER, 7 in 1:15-cv-02106-ER, 7 in 1:15-cv-02106-ER) MOTION to Appoint Counsel The Rosen Law Firm. MOTION to Appoint Lead Plaitniff. MOTION to Consolidate Cases. filed by Anton Mandelstam, (20 in 1:15-cv-02106-ER) MOTION to Appoint Arkansas Public Employees Retirement System to serve as lead plaintiff(s), filed by Arkansas Public Employees Retirement System, (9 in 1:15-cv-02106-ER, 9 in 1:15-cv-02106-ER) MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-2884. MOTION to Appoint Richard Gielata to serve as lead plaintiff(s) , filed by Megan Villella, (15 in 1:15-cv-02106-ER, 15 in 1:15-cv-02106-ER, 15 in 1:15-cv-02106-ER) MOTION to Appoint Counsel Glancy Prongay & Murray LLP. MOTION to Appoint Marty Sholtis to serve as lead plaintiff(s). MOTION to Consolidate Cases 15-cv-2106-ER and 15-cv-2884-ER, filed by Marty Sholtis, (18 in 1:15-cv-02106-ER, 18 in 1:15-cv-02106-ER, 18 in 1:15-cv-02106-ER) MOTION to Appoint The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund to serve as lead plaintiff(s). MOTION to Appoint Counsel. MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-02884, filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund, (12 in 1:15-cv-02106-ER, 12 in 1:15-cv-02106-ER, 12 in 1:15-cv-02106-ER) MOTION to Consolidate Cases. MOTION to Appoint LEAD PLAINTIFF. MOTION to Approve COUNSEL, filed by Megan Villella, Leroy Robinson, Sam Villella. For the aforementioned reasons, the motions to consolidate are GRANTED. All future filings in this case shall be filed in the 15 Civ. 2016 case number and bear the same caption as that case number. All related actions subsequently filed in, or transferred to, this District shall be consolidated into the 15 Civ. 2106 case number, absent order of the Court. The Clerk of the Court is respectfully directed to close the 15 Civ. 2884 case and terminate any pending motions in that case. Additionally, Tyne and Wear's motion for appointment as lead plaintiff and approval of lead counsel (Doc. 18) is GRANTED. All other movants' motions for appointment as lead plaintiff and approval of lead counsel (Docs. 7, 9, 12, 15, 20) are DENIED. The Clerk of the Court is respectfully directed to terminate the following motions in the 15 Civ. 2106 case: Docs. 7, 9, 12, 15, 18, and 20. (As is further set forth in this Order.) (Signed by Judge Edgardo Ramos on 10/14/2015) Filed In Associated Cases: 1:15-cv-02106-ER, 1:15-cv-02884-ER. (spo)
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| Filing 30 NOTICE OF APPEARANCE by Grant Richard Mainland on behalf of Chemical & Mining Co. of Chile Inc., Patricio De Solminihac, Ricardo Ramos. (Mainland, Grant) |
| Filing 29 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Chemical & Mining Co. of Chile Inc..(Edelman, Scott) |
| Filing 28 NOTICE OF APPEARANCE by Scott Alexander Edelman on behalf of Chemical & Mining Co. of Chile Inc., Patricio De Solminihac, Ricardo Ramos. (Edelman, Scott) |
| Filing 27 NOTICE of NOTICE OF WITHDRAWAL OF MOTION BY SAM AND MEGAN VILLELLA AND LEROY ROBINSON FOR CONSOLIDATION, APPOINTMENT AS LEAD PLAINTIFF, AND APPROVAL OF COUNSEL re: #12 MOTION to Consolidate Cases . MOTION to Appoint LEAD PLAINTIFF. MOTION to Approve COUNSEL .. Document filed by Leroy Robinson, Megan Villella(Individually), Sam Villella. (Lieberman, Jeremy) |
| Filing 26 MEMORANDUM OF LAW in Support re: #18 MOTION to Appoint The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund to serve as lead plaintiff(s) . MOTION to Appoint Counsel . MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-02884- . and in Opposition to the Competing Motions. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Rosenfeld, David) |
| Filing 25 NOTICE of Non-Opposition. Document filed by Arkansas Public Employees Retirement System. (Silk, Gerald) |
| Filing 24 RESPONSE in Support of Motion re: #9 MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-2884 . MOTION to Appoint Richard Gielata to serve as lead plaintiff(s) . and statement of non-opposition to competing motions. Document filed by Richard Gielata. (Zweig, Jason) |
| Filing 23 DECLARATION of Gerald H. Silk in Support re: #20 MOTION to Appoint Arkansas Public Employees Retirement System to serve as lead plaintiff(s) .. Document filed by Arkansas Public Employees Retirement System. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Silk, Gerald) |
| Filing 22 MEMORANDUM OF LAW in Support re: #20 MOTION to Appoint Arkansas Public Employees Retirement System to serve as lead plaintiff(s) . . Document filed by Arkansas Public Employees Retirement System. (Silk, Gerald) |
| Filing 21 DECLARATION in Support re: #18 MOTION to Appoint The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund to serve as lead plaintiff(s) . MOTION to Appoint Counsel . MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-02884- .. Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Exhibit 1 - certification, #2 Exhibit 2 - damages loss chart, #3 Exhibit 3 - press release, #4 Exhibit 4 - Robbins Geller firm resume)(Rosenfeld, David) |
| Filing 20 MOTION to Appoint Arkansas Public Employees Retirement System to serve as lead plaintiff(s) . Document filed by Arkansas Public Employees Retirement System.(Silk, Gerald) |
| Filing 19 MEMORANDUM OF LAW in Support re: #18 MOTION to Appoint The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund to serve as lead plaintiff(s) . MOTION to Appoint Counsel . MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-02884- . . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Rosenfeld, David) |
| Filing 18 MOTION to Appoint The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund to serve as lead plaintiff(s) ., MOTION to Appoint Counsel ., MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-02884- . Document filed by The Council of the Borough of South Tyneside Acting in Its Capacity as the Administering Authority of the Tyne and Wear Pension Fund. (Attachments: #1 Text of Proposed Order)(Rosenfeld, David) |
| Filing 17 DECLARATION of Lesley F. Portnoy in Support re: #15 MOTION to Appoint Counsel Glancy Prongay & Murray LLP. MOTION to Appoint Marty Sholtis to serve as lead plaintiff(s) . MOTION to Consolidate Cases 15-cv-2106-ER and 15-cv-2884-ER .. Document filed by Marty Sholtis. (Attachments: #1 Exhibit A - Press Release, #2 Exhibit B - Movant Certification, #3 Exhibit C - Loss Chart, #4 Exhibit D - Firm Resume)(Portnoy, Lesley) |
| Filing 16 MEMORANDUM OF LAW in Support re: #15 MOTION to Appoint Counsel Glancy Prongay & Murray LLP. MOTION to Appoint Marty Sholtis to serve as lead plaintiff(s) . MOTION to Consolidate Cases 15-cv-2106-ER and 15-cv-2884-ER . . Document filed by Marty Sholtis. (Portnoy, Lesley) |
| Filing 15 MOTION to Appoint Counsel Glancy Prongay & Murray LLP., MOTION to Appoint Marty Sholtis to serve as lead plaintiff(s) ., MOTION to Consolidate Cases 15-cv-2106-ER and 15-cv-2884-ER . Document filed by Marty Sholtis. (Attachments: #1 Text of Proposed Order)(Portnoy, Lesley) |
| Filing 14 DECLARATION in Support re: #12 MOTION to Consolidate Cases . MOTION to Appoint LEAD PLAINTIFF. MOTION to Approve COUNSEL .. Document filed by Leroy Robinson, Megan Villella(on behalf of all others similarly situated), Sam Villella. (Attachments: #1 Exhibit A - Press Release, #2 Exhibit B - Certifications, #3 Exhibit C - Loss Chart, #4 Exhibit D - Firm Resume)(Lieberman, Jeremy) |
| Filing 13 MEMORANDUM OF LAW in Support re: #12 MOTION to Consolidate Cases . MOTION to Appoint LEAD PLAINTIFF. MOTION to Approve COUNSEL . . Document filed by Leroy Robinson, Megan Villella(on behalf of all others similarly situated), Sam Villella. (Lieberman, Jeremy) |
| Filing 12 MOTION to Consolidate Cases ., MOTION to Appoint LEAD PLAINTIFF., MOTION to Approve COUNSEL . Document filed by Megan Villella(on behalf of all others similarly situated), Sam Villella, Leroy Robinson. (Attachments: #1 Text of Proposed Order)(Lieberman, Jeremy) |
| Filing 11 DECLARATION of Reed R. Kathrein in Support re: #9 MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-2884 . MOTION to Appoint Richard Gielata to serve as lead plaintiff(s) .. Document filed by Megan Villella(on behalf of all others similarly situated). (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Zweig, Jason) |
| Filing 10 MEMORANDUM OF LAW in Support re: #9 MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-2884 . MOTION to Appoint Richard Gielata to serve as lead plaintiff(s) . . Document filed by Megan Villella(on behalf of all others similarly situated). (Zweig, Jason) |
| Filing 9 MOTION to Consolidate Cases 1:15-cv-02106; 1:15-cv-2884 ., MOTION to Appoint Richard Gielata to serve as lead plaintiff(s) . Document filed by Megan Villella(on behalf of all others similarly situated).(Zweig, Jason) |
| Filing 8 MEMORANDUM OF LAW in Support re: #7 MOTION to Appoint Counsel The Rosen Law Firm. MOTION to Appoint Lead Plaitniff. MOTION to Consolidate Cases . . Document filed by Anton Mandelstam. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Kim, Phillip) |
| Filing 7 MOTION to Appoint Counsel The Rosen Law Firm., MOTION to Appoint Lead Plaitniff., MOTION to Consolidate Cases . Document filed by Anton Mandelstam. (Attachments: #1 Text of Proposed Order)(Kim, Phillip) |
| Filing 6 MEMO ENDORSEMENT on re: #5 NOTICE of WITHDRAWAL OF COUNSEL. Document filed by Megan Villella. ENDORSEMENT: The application is granted. Attorney Francis P. McConville terminated. (Signed by Judge Edgardo Ramos on 4/24/2015) (rjm) |
| Filing 5 NOTICE of WITHDRAWAL OF COUNSEL. Document filed by Megan Villella(Individually). (McConville, Francis) |
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Filing 4
STIPULATION REGARDING SERVICE OF COMPLAINT AND TIME TO RESPOND TO COMPLAINT: Defendant SQM expressly reserves all rights, defenses, and or other objections,including insufficient process or insufficient service of process, except that defendant SQM hereby waives any defense based on the 120 day lime limit for service in Federal Rule of Civil Procedure 4(m) with respect to the delivery of the Villella Complaint; Defendant SQM need not answer or otherwise respond to the Villella Complaint in the above-captioned action; and Within 20 days after this Court consolidates any additional actions filed against defendants, if appropriate, and appoints a lead plaintiff, the lead plaintiff and defendant SQM will submit to the Court a proposed schedule for: (1) lead plaintiff's filing of an amended complaint, (2) defendant SQM's time to answer or otherwise respond to the current complaint or to an amended complaint and, to the extent that service has not been otherwise accepted or effected by that time, (3) defendant SQM's filing of a motion to quash or to dismiss based on insufficient process or insufficient service of process. SO ORDERED. (Signed by Judge Edgardo Ramos on 4/20/2015) (ama)
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| Filing 3 SUMMONS RETURNED EXECUTED. Chemical & Mining Co. of Chile Inc. served on 4/7/2015, answer due 4/28/2015. Service was accepted by Sebastian Sanchez. Document filed by Megan Villella(Individually). (Lieberman, Jeremy) |
| Filing 2 CIVIL COVER SHEET filed. (moh) |
| Filing 1 COMPLAINT against Chemical & Mining Co. of Chile Inc., Patricio Contesse, Patricio De Solminihac, Ricardo Ramos. (Filing Fee $ 350.00, Receipt Number 465401120255)Document filed by Megan Villella(Individually), Megan Villella(on behalf of all others similarly situated).(moh) |
| SUMMONS ISSUED as to Chemical & Mining Co. of Chile Inc., Patricio Contesse, Patricio De Solminihac, Ricardo Ramos. (moh) |
| Case Designated ECF. (moh) |
| Magistrate Judge Gabriel W. Gorenstein is so designated. (moh) |
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