Wailian Overseas Consulting Group, Ltd. v. New York City Regional Center, LLC
| Wailian Overseas Consulting Group, Ltd. |
| New York city Regional Center, LLC |
| WeiWei Liu, Ning Liu and Qiao Ni |
| 1:2017cv09004 |
| November 17, 2017 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| Louis L Stanton |
| Contract: Other |
| 28 U.S.C. § 1332 bc Diversity-Breach of Contract |
| Plaintiff |
Docket Report
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This docket was last retrieved on May 26, 2023. A more recent docket listing may be available from PACER.
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Filing 116
JOINT STIPULATION OF DISMISSAL AND ORDER: Pursuant to Fed. R. Civ. P. 41(a), Plaintiff Wailian Overseas Consulting Group, Ltd. and Defendant New York City Regional Center LLC hereby stipulate and agree that the above action, including all claims asserted therein, is dismissed with prejudice, with each party to bear its own costs, expenses, and attorneys' fees. (Signed by Judge Louis L. Stanton on 5/26/2023) (rro)
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| Filing 115 PROPOSED STIPULATION AND ORDER. Document filed by Wailian Overseas Consulting Group, Ltd...(Ross, David) |
| Minute Entry for proceedings held before Judge Louis L. Stanton: Scheduling Conference held on 10/14/2022. (ml) |
| Set/Reset Hearings: Scheduling Conference set for 10/14/2022 at 12:30 PM in Courtroom 21C, 500 Pearl Street, New York, NY 10007 before Judge Louis L. Stanton. (ml) |
| Filing 114 LETTER addressed to Judge Louis L. Stanton from Kim Conroy dated October 6, 2022 re: Close of Discovery. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
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Filing 113
ORDER granting #112 Letter Motion for Extension of Time to Complete Discovery. Granted. Deposition due by 9/30/2022.. (Signed by Judge Louis L. Stanton on 9/14/2022) (kv)
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| Filing 112 CONSENT LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge Louis L. Stanton from Kim Conroy dated September 14, 2022. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
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Filing 111
ORDER: On June 15 and July 28, 2022, Defendant's requested that the Court enter a new deadline for fact discovery and sought permission to depose non-party investors. Dkt. Nos. 107 & 110. Plaintiff opposed such non-party depositions. Dkt. No. 109. The fact discovery in this case will close on September 15, 2022. The parties may request extensions shown to be necessary. Either party may request permission to take the deposition of a non-party witness, upon a showing that the information sought is germane and cannot be discovered otherwise. ( Fact Discovery due by 9/15/2022.) (Signed by Judge Louis L. Stanton on 8/3/2022) (rro)
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| Filing 110 LETTER addressed to Judge Louis L. Stanton from Adam B. Banks dated July 28, 2022 re: response to Wailian's letters to the Court on June 15, 2022 and June 23, 2022. (ECF Nos. 108 and 109). Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 109 LETTER addressed to Judge Louis L. Stanton from Kim Conroy dated June 23, 2022 re: Response To Defendant New York City Regional Centers Request To Depose Third-Party Investors. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 108 LETTER addressed to Judge Louis L. Stanton from Kim Conroy dated June 15, 2022 re: update on the status of the pandemic lockdown measures in Shanghai per the Court's June 2, 2022 order. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 107 LETTER addressed to Judge Louis L. Stanton from Adam B. Banks dated June 15, 2022 re: response to the June 2, 2022 Order. Document filed by New York City Regional Center, LLC..(Banks, Adam) |
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Filing 106
ORDER denying #103 Letter Motion to Stay re: #103 LETTER MOTION to Stay / Requesting a temporary stay of discovery and related relief addressed to Judge Louis L. Stanton from Kim Conroy dated May 10, 2022. Plaintiff requests a temporary stay of discovery due to the restrictions in place and lockdown status in Shanghai that make it impossible for its newly designated 30(b) (6) witness to travel to the United States for a deposition. It appearing that the situation in Shanghai is ever changing, an indefinite stay of all discovery is unnecessary, and both parties shall make their witnesses available as soon as possible. If the June deadline is still impracticable for either party, it shall update the Court of the lockdown status in China and move for a reasonable excension of time to complete the remaining depositions once information on the situation is clearer. (Signed by Judge Louis L. Stanton on 6/2/2022) (rro)
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| Filing 105 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated May 23, 2022 re: #103 LETTER MOTION to Stay / Requesting a temporary stay of discovery and related relief addressed to Judge Louis L. Stanton from Kim Conroy dated May 10, 2022. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 104 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated May 16, 2022 re: #103 LETTER MOTION to Stay / Requesting a temporary stay of discovery and related relief addressed to Judge Louis L. Stanton from Kim Conroy dated May 10, 2022. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 103 LETTER MOTION to Stay / Requesting a temporary stay of discovery and related relief addressed to Judge Louis L. Stanton from Kim Conroy dated May 10, 2022. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1 - Shanghai to Extend lockdown of 26 million people as it reviews COVID test results, #2 Exhibit 2 - Shanghai locals sleep at work and ration food as lockdown bites, #3 Exhibit 3 - Hunger and anger in Shanghai's unending lockdown nightmare, #4 Exhibit 4 - U.S. consulate staff in China help Marines running low on rations, #5 Exhibit 5 - Voices from Shanghai: The trials of living through a massive COVID lockdown, #6 Exhibit 6 - Shanghai quarantine: 24- hour lights, no hot showers, #7 Exhibit 7 - China Travel Advisory, #8 Exhibit 8 - Nerves fray, frustration grows in Shanghai's lockdown purgatory, #9 Exhibit 9 - Shanghai to Divert International Flights as Virus Spreads, #10 Exhibit 10 - Expats flee as Shanghai's COVID lockdown drags).(Conroy, Kim) |
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Filing 102
STIPULATION AND ORDER REGARDING DISCOVERY SCHEDULE: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by the undersigned counsel on behalf of Plaintiff and Defendant that the following discovery deadlines shall apply: As further set forth by this Order. SO ORDERED. ( Expert Discovery due by 9/13/2022., Fact Discovery due by 6/15/2022.) (Signed by Judge Louis L. Stanton on 3/16/2022) (tg)
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| Filing 101 PROPOSED STIPULATION AND ORDER. Document filed by New York City Regional Center, LLC..(Banks, Adam) |
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Filing 100
ORDER: This case has been delayed many months for reasons beyond the parties' control, but at this point, it is not entirely clear that Chinese law and policies render it impossible for Ms. Liu to safely provide her testimony. Therefore, Wailian shall make Ms. Liu available to testify at a deposition within three months, or designate another 30(b)(6) witness who may so testify within the same time frame. (Signed by Judge Louis L. Stanton on 3/3/2022) (rro)
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| Filing 99 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated March 1, 2022 re: #96 LETTER MOTION for Local Rule 37.2 Conference (Revised letter with exhibit) addressed to Judge Louis L. Stanton from Adam B. Banks dated February 15, 2022. / Letter Response to NYCRC's February 28, 2022 letter. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 98 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated February 28, 2022 re: #96 LETTER MOTION for Local Rule 37.2 Conference (Revised letter with exhibit) addressed to Judge Louis L. Stanton from Adam B. Banks dated February 15, 2022. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 97 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated February 22, 2022 re: #96 LETTER MOTION for Local Rule 37.2 Conference (Revised letter with exhibit) addressed to Judge Louis L. Stanton from Adam B. Banks dated February 15, 2022. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 96 LETTER MOTION for Local Rule 37.2 Conference (Revised letter with exhibit) addressed to Judge Louis L. Stanton from Adam B. Banks dated February 15, 2022. Document filed by New York City Regional Center, LLC. (Attachments: #1 Exhibit A - Notice of Deposition of Wailian).(Banks, Adam) |
| Filing 95 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated February 15, 2022. Document filed by New York City Regional Center, LLC..(Banks, Adam) |
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Filing 94
STIPULATION AND ORDER REGARDING DISCOVERY SCHEDULE: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by the undersigned counsel on behalf of Plaintiff and Defendant that the following discovery deadlines shall apply: Close of Fact Discovery due March 15, 2022. Exchange of Expert Reports due April 15, 2022. Rebuttal Expert Reports due May 13, 2022. Close of Expert Discovery due June 10, 2022. SO ORDERED. ( Expert Discovery due by 6/10/2022., Fact Discovery due by 3/15/2022.) (Signed by Judge Louis L. Stanton on 12/16/2021) (ate)
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| Filing 93 PROPOSED STIPULATION AND ORDER. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
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Filing 92
ORDER REGARDING DISCOVERY SCHEDULE: IT IS HEREBY ORDERED that the following discovery deadlines shall apply: Close of Fact Discovery: 12/15/2021. Exchange of Expert Reports: 1/15/2022. Rebuttal Expert Reports: 2/15/2022. Close of Expert Discovery: 3/15/2022. ( Expert Discovery due by 3/15/2022., Fact Discovery due by 12/15/2021.) (Signed by Judge Louis L. Stanton on 9/1/2021) (rro)
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| Filing 91 MEMO ENDORSEMENT on #90 granting #89 Letter Motion for Extension of Time. ENDORSEMENT: The time for depositions of all four witnesses, including Ms. Sun, is extended for 15 weeks. (Signed by Judge Louis L. Stanton on 9/1/2021) (rro) |
| Filing 90 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated August 31, 2021 re: #89 LETTER MOTION for Extension of Time To The Case Schedule addressed to Judge Louis L. Stanton from David J. Lender dated August 24, 2021. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 89 LETTER MOTION for Extension of Time To The Case Schedule addressed to Judge Louis L. Stanton from David J. Lender dated August 24, 2021. Document filed by New York City Regional Center, LLC. (Attachments: #1 Exhibit A - Proposed Amended Scheduling Order).(Lender, David) |
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Filing 88
ORDER that Defendant's request to extend the fact discovery deadline by six months is granted to allow for the depositions of plaintiff's China-based witnesses who are presently unavailable due to travel constraints imposed by the pandemic. At this time, the motion to quash the three subpoenas to the non-party witnesses is also granted. If it becomes clear that defendant will not be able to obtain relevant information regarding plaintiff's communications with its investors from any of the party witnesses or from plaintiff's former employees, defendant may re-serve timely notices via subpoena, and, if asked, the Court will consider the propriety and necessity of the non-party depositions at that time. (Signed by Judge Louis L. Stanton on 3/2/2021) (ml)
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| Filing 87 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Fred H. Perkins dated February 28, 2021 re: #84 LETTER MOTION for Conference pre-motion conference to move to quash the three subpoenas to the Non-Parties addressed to Judge Louis L. Stanton from Fred H. Perkins dated February 24, 2021. Letter in response to the February 26, 2021 letter of Adam Banks, counsel for NYCRC. Document filed by Ning Liu, WeiWei Liu, Qiao Ni. (Attachments: #1 Exhibit A-Orders).(Perkins, Fred) |
| Filing 86 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated February 26, 2021 re: #84 LETTER MOTION for Conference pre-motion conference to move to quash the three subpoenas to the Non-Parties addressed to Judge Louis L. Stanton from Fred H. Perkins dated February 24, 2021. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 85 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated February 26, 2021 re: #82 LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge Louis L. Stanton from Adam B. Banks dated February 22, 2021. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 84 LETTER MOTION for Conference pre-motion conference to move to quash the three subpoenas to the Non-Parties addressed to Judge Louis L. Stanton from Fred H. Perkins dated February 24, 2021. Document filed by WeiWei Liu, Ning Liu, Qiao Ni..(Perkins, Fred) |
| Filing 83 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated February 24, 2021 re: #82 LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge Louis L. Stanton from Adam B. Banks dated February 22, 2021. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 82 LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge Louis L. Stanton from Adam B. Banks dated February 22, 2021. Document filed by New York City Regional Center, LLC. (Attachments: #1 Text of Proposed Order (Exhibit A - Proposed Order)).(Banks, Adam) |
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Filing 81
MEMO ENDORSEMENT on #80 granting #77 Letter Motion for Extension of Time to Complete Discovery. ENDORSEMENT: It sufficiently appearing that at present it is impracticable to take the depositions of Ms. He and Ms. Liu by any method, my October 2, 2020 order is vacated, and the time within which to do so, whether in person or by videotape, is extended by four months to March 1, 2021. By that date, all other factual discovery shall have been completed. No witness shall be excused from testifying, either in person or by videotape, on the ground he or she lacks personal knowledge. The remaining dates in the July 30, 2020 scheduling order are adjusted accordingly. Deposition due by 3/1/2021. (Signed by Judge Louis L. Stanton on 10/27/2020) (rro)
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| Filing 80 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated October 23, 2020 re: #77 LETTER MOTION for Extension of Time to Complete Discovery and for Reconsideration of Court Order addressed to Judge Louis L. Stanton from Adam B. Banks dated October 14, 2020. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 79 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated October 21, 2020 re: #77 LETTER MOTION for Extension of Time to Complete Discovery and for Reconsideration of Court Order addressed to Judge Louis L. Stanton from Adam B. Banks dated October 14, 2020. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 78 LETTER addressed to Judge Louis L. Stanton from Kim Conroy dated October 15, 2020 re: Defendant New York City Regional Center's October 14, 2020 letter motion seeking reconsideration of the Court's October 2, 2020 Order. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 77 LETTER MOTION for Extension of Time to Complete Discovery and for Reconsideration of Court Order addressed to Judge Louis L. Stanton from Adam B. Banks dated October 14, 2020. Document filed by New York City Regional Center, LLC..(Banks, Adam) |
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Filing 76
Vacated as per Judge's Order dated 10/27/2020, Doc. #81 MEMO ENDORSEMENT on #75 granting #73 Letter Motion for Local Rule 37.2 Conference. ENDORSEMENT: As the sole practicable first step, NYCRC may take the depositions of Ms. He and Ms. Liu by written questions under F. R. Civ. P. 3 1(a)(2). Further relief may be granted on application if shown to be necessary and feasible, after the completion of those depositions. The schedule may be adjusted accordingly. So Ordered. (Signed by Judge Louis L. Stanton on 10/2/2020) (rro) Modified on 10/27/2020 (rro).
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| Filing 75 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated September 25, 2020 re: #73 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Kim Conroy dated September 18, 2020. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 74 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated September 22, 2020 re: #73 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Kim Conroy dated September 18, 2020. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 73 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Kim Conroy dated September 18, 2020. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
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Filing 72
STIPULATION AND ORDER REGARDING DISCOVERY SCHEDULE: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by the undersigned counsel on behalf of Plaintiff and Defendant that the following discovery deadlines shall apply: Deposition due by 10/30/2020., Expert Discovery due by 2/5/2021., Fact Discovery due by 10/30/2020. SO ORDERED. (Signed by Judge Louis L. Stanton on 7/30/2020) (rro)
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| Filing 71 PROPOSED STIPULATION AND ORDER. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
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Filing 70
ORDER with respect to #65 Letter Motion for Local Rule 37.2 Conference: Plaintiff must comply with NYCRC's Amended Request No. 8. (Signed by Judge Louis L. Stanton on 5/5/2020) (ml)
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| Filing 69 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated April 22, 2020 re: #65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated April 6, 2020. . Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 68 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Kim Conroy dated April 15, 2020 re: #65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated April 6, 2020. . Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit A: Subscription Agreement Excerpt, #2 Exhibit B: March 12, 2020 letter from D. Ross to A. Banks).(Conroy, Kim) |
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Filing 67
ORDER granting #66 Letter Motion for Extension of Time to File Response/Reply re #65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated April 6, 2020. Responses due by 4/15/2020. So Ordered. (Signed by Judge Louis L. Stanton on 4/9/2020) (rro)
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| Filing 66 CONSENT LETTER MOTION for Extension of Time to File Response/Reply as to #65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated April 6, 2020. addressed to Judge Louis L. Stanton from Kim Conroy dated April 9, 2020. Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Adam B. Banks dated April 6, 2020. Document filed by New York City Regional Center, LLC..(Banks, Adam) |
| Filing 64 MEMORANDUM ENDORSEMENT on re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents. filed by Wailian Overseas Consulting Group, Ltd.: That Wailian's Requests for Production 16 and 17 are vacated as overbroad, and NYCRC is directed to disclose to Wailian on a confidential basis its profits separately on each of the four remaining projects, and the portions thereof allocable to the investors produced byWailian. (Signed by Judge Louis L. Stanton on 3/30/2020) (ml) |
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Filing 63
MEMO ENDORSEMENT on re: #62 Letter, filed by Wailian Overseas Consulting Group, Ltd. ENDORSEMENT: SO ORDERED. (Deposition due by 7/31/2020., Expert Discovery due by 10/29/2020., Fact Discovery due by 7/31/2020.) (Signed by Judge Louis L. Stanton on 3/18/2020) (rro)
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| Filing 62 JOINT LETTER addressed to Judge Louis L. Stanton from Kim Conroy dated March 18, 2020 re: Requesting an extension of the Joint Amended Scheduling Order dated January 30, 2020 (ECF Doc. No. 50). Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 61 DECLARATION of Danielle R. Gill in Support re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents.. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1 - November 22, 2019 letter from David E. Ross to Adam B. Banks, #2 Exhibit 2 - Transcript of the January 31, 2020 Court Conference).(Conroy, Kim) |
| Filing 60 REPLY MEMORANDUM OF LAW in Support re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents. . Document filed by Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 59 DECLARATION of Adam B. Banks in Opposition re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents.. Document filed by New York City Regional Center, LLC. (Attachments: #1 Exhibit A - Cited excerpts from transcript from Status Conference, dated January 31, 2020, #2 Exhibit B - Responses and Objections to Defendant's First Set of Interrogatories, dated July 17, 2019, #3 Exhibit C - Plaintiff's First Set of Requests for Production, dated May 10, 2019, #4 Exhibit D - Letter from David Ross to Adam Banks, dated October 21, 2019).(Banks, Adam) |
| Filing 58 MEMORANDUM OF LAW in Opposition re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents. . Document filed by New York City Regional Center, LLC..(Lender, David) |
| Filing 57 NOTICE OF APPEARANCE by Kim Conroy on behalf of Wailian Overseas Consulting Group, Ltd...(Conroy, Kim) |
| Filing 56 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 1/31/2020 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 55 TRANSCRIPT of Proceedings re: CONFERENCE held on 1/31/2020 before Judge Louis L. Stanton. Court Reporter/Transcriber: Eve Giniger, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/17/2020. Redacted Transcript Deadline set for 3/27/2020. Release of Transcript Restriction set for 5/26/2020..(McGuirk, Kelly) |
| Filing 54 LETTER MOTION for Oral Argument on plaintiffs motion to compel (ECF Doc. Nos. 51-53) addressed to Judge Louis L. Stanton from David E. Ross dated February 21, 2020. Document filed by Wailian Overseas Consulting Group, Ltd...(Ross, David) |
| Filing 53 DECLARATION of David R. Ross in Support re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents.. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1: Excerpts from Plaintiffs First Set of Requests for Production dated May 10, 2019, #2 Exhibit 2: Excerpts from Defendants Responses & Objections to Plaintiffs First Set of Requests for Production dated June 10, 2019).(Ross, David) |
| Filing 52 MEMORANDUM OF LAW in Support re: #51 MOTION to Compel New York City Regional Center, LLC to produce documents. . Document filed by Wailian Overseas Consulting Group, Ltd...(Ross, David) |
| Filing 51 MOTION to Compel New York City Regional Center, LLC to produce documents. Document filed by Wailian Overseas Consulting Group, Ltd...(Ross, David) |
| Minute Entry for proceedings held before Judge Louis L. Stanton: Status Conference held on 1/31/2020. (Court Reporter Eve Giniger) (ml) |
| Filing 50 MEMO ENDORSEMENT on re: #49 Letter, filed by Wailian Overseas Consulting Group, Ltd. ENDORSEMENT: Granted. (Deposition due by 5/21/2020., Expert Discovery due by 8/20/2020., Fact Discovery due by 5/21/2020.) (Signed by Judge Louis L. Stanton on 1/30/2020) (rro) |
| Filing 49 JOINT LETTER addressed to Judge Louis L. Stanton from David E. Ross dated January 30, 2020 re: Requesting an extension of the Joint Amended Scheduling Order dated August 5, 2019 (ECF Doc. No. 40). Document filed by Wailian Overseas Consulting Group, Ltd..(Ross, David) |
| Set/Reset Hearings: Status Conference set for 1/31/2020 at 02:30 PM in Courtroom 21C, 500 Pearl Street, New York, NY 10007 before Judge Louis L. Stanton. (ml) |
| Filing 48 LETTER addressed to Judge Louis L. Stanton from David E. Ross dated January 13, 2020 re: Further support of the points set forth in the letter from Plaintiff Wailian Overseas Group, Ltd. dated December 11, 2019 (Dkt. No. 43) and in reply to the opposition filed on December 16, 2019 by New York City Regional Center LLC (Dkt. No. 44). Document filed by Wailian Overseas Consulting Group, Ltd..(Ross, David) |
| Filing 47 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Adam B. Banks dated January 9, 2020 re: #45 LETTER MOTION for Conference (Request for Pre-Motion Conference) addressed to Judge Louis L. Stanton from Adam B. Banks dated December 16, 2019. . Document filed by New York City Regional Center, LLC. (Banks, Adam) |
| Filing 46 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from David E. Ross dated 12/23/19 re: #45 LETTER MOTION for Conference (Request for Pre-Motion Conference) addressed to Judge Louis L. Stanton from Adam B. Banks dated December 16, 2019. . Document filed by Wailian Overseas Consulting Group, Ltd.. (Ross, David) |
| Filing 45 LETTER MOTION for Conference (Request for Pre-Motion Conference) addressed to Judge Louis L. Stanton from Adam B. Banks dated December 16, 2019. Document filed by New York City Regional Center, LLC.(Banks, Adam) |
| Filing 44 LETTER addressed to Judge Louis L. Stanton from Adam B. Banks dated December 16, 2019 re: Response to Plaintiff's Request for a Pre-Motion Conference (ECF 43). Document filed by New York City Regional Center, LLC.(Banks, Adam) |
| Filing 43 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from David E. Ross dated December 11, 2019. Document filed by Wailian Overseas Consulting Group, Ltd..(Ross, David) |
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Filing 42
STIPULATION AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material...SO ORDERED. (Signed by Judge Louis L. Stanton on 9/25/2019) (ne)
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| Filing 41 PROPOSED PROTECTIVE ORDER. Document filed by New York City Regional Center, LLC. (Lender, David) |
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Filing 40
JOINT AMENDED SCHEDULING ORDER granting #39 Letter Motion for Extension of Time to Complete Discovery. All fact witness depositions shall be completed by January 29, 2020. Status conference adjourned to Jan. 31, 2020 at 2:30 p.m. All fact discovery, including any interrogatories, requests for admission, document production, and any fact discovery from non-parties, shall be completed by January 29, 2020. Expert discovery, including all expert depositions, shall be completed on or by March 20, 2020. Plaintiff has demanded a trial by jury. The parties estimate that five to seven days will be required for trial. (Signed by Judge Louis L. Stanton on 8/13/2019) (mro)
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| Set/Reset Deadlines: ( Deposition due by 3/20/2020., Expert Discovery due by 3/20/2020., Fact Discovery due by 1/29/2020.), Set/Reset Hearings:( Status Conference set for 1/31/2020 at 02:30 PM before Judge Louis L. Stanton.) (mro) |
| Filing 39 LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge Louis L. Stanton from David E. Ross dated August 5, 2019. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Text of Proposed Order Proposed Amended Joint Scheduling Order)(Ross, David) |
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Filing 38
JOINT SCHEDULING ORDER: All fact witness depositions shall be completed by October 31,2019. All fact discovery, including any interrogatories, requests for admission, document production, and any fact discovery from non-parties, shall be completed by October 31, 2019. Status Conference set for 11/8/2019 at 12:00 PM before Judge Louis L. Stanton. Expert discovery, including all expert depositions, shall be completed on or by December 20, 2019. Plaintiff has demanded a trial by jury. The parties estimate that five to seven days will be required for trial. SO ORDERED. (Signed by Judge Louis L. Stanton on 4/19/2019) (rro) Modified on 4/22/2019 (rro).
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| Minute Entry for proceedings held before Judge Louis L. Stanton: Initial Pretrial Conference held on 4/19/2019. (ml) |
| Set/Reset Hearings: Initial Conference set for 3/29/2019 is adjourned to 4/19/2019 at 02:30 PM in Courtroom 21C, 500 Pearl Street, New York, NY 10007 before Judge Louis L. Stanton. (ml) |
| Filing 37 LETTER MOTION to Adjourn Conference addressed to Judge Louis L. Stanton from David J. Lender dated March 8, 2019. Document filed by New York City Regional Center, LLC.(Lender, David) |
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Filing 36
ORDER FOR CONFERENCE PURSUANT TO RULE 16(b): Initial Conference set for 3/29/2019 at 02:30 PM in Courtroom 21C, 500 Pearl Street, New York, NY 10007 before Judge Louis L. Stanton and further set forth in this Order. (Signed by Judge Louis L. Stanton on 2/25/2019) (rro)
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| Filing 35 ANSWER to #23 Amended Complaint, with JURY DEMAND. Document filed by New York City Regional Center, LLC.(Lender, David) |
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Filing 34
ORDER granting in part and denying in part #24 Motion to Dismiss. NYCRC's motion to partially dismiss Wailian's Amended Complaint (Dkt. No. 24) is granted in part and denied in part. The motion to dismiss with respect to the CBD and Medical Campus projects is granted, and the motion to dismiss with respect to the Navy Yard II project is denied. So ordered. (Signed by Judge Louis L. Stanton on 2/7/2019) (rro)
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| Filing 33 REPLY MEMORANDUM OF LAW in Support re: #24 MOTION to Dismiss the Amended Complaint. . Document filed by New York City Regional Center, LLC. (Lender, David) |
| Filing 32 DECLARATION of David E. Ross in Opposition re: #24 MOTION to Dismiss the Amended Complaint.. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1-Redline Amended Complaint)(Ross, David) |
| Filing 31 MEMORANDUM OF LAW in Opposition re: #24 MOTION to Dismiss the Amended Complaint. . Document filed by Wailian Overseas Consulting Group, Ltd.. (Ross, David) |
| Filing 30 STIPULATION. IT IS HEREBY STIPULATED AND AGREED, subject to the Court's approval, by and between the undersigned counsel for the parties, as follows: 1. Plaintiff's time to file its opposition to the Motion shall be extended to August 29, 2018. 2. Defendant's reply in further support of the Motion shall be due on or before September 21, 2018. 3. One previous request for an extension of time to respond to the Motion has been made and granted. (Responses due by 8/29/2018. Replies due by 9/21/2018.) (Signed by Judge Louis L. Stanton on 8/21/2018) (rjm) |
| Filing 29 PROPOSED STIPULATION AND ORDER. Document filed by Wailian Overseas Consulting Group, Ltd.. (Ross, David) |
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Filing 28
STIPULATION: IT IS HEREBY STIPULATED AND AGREED, subject to the Court's approval, by and between the undersigned counsel for the parties, as follows: 1. Plaintiff's time to file its opposition to the Motion shall be extended to August 22, 2018. 2. Defendant's reply in further support of the Motion shall be due on or before September 14, 2018. (As further set forth in this Order.) (Responses due by 8/22/2018, Replies due by 9/14/2018.) (Signed by Judge Louis L. Stanton on 7/12/2018) (cf)
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| Filing 27 LETTER addressed to Judge Louis L. Stanton from Adam B. Banks dated July 9, 2018 re: to request oral argument on Defendant's Motion to Dismiss the Amended Complaint. Document filed by New York City Regional Center, LLC.(Banks, Adam) |
| Filing 26 DECLARATION of David J. Lender in Support re: #24 MOTION to Dismiss the Amended Complaint.. Document filed by New York City Regional Center, LLC. (Attachments: #1 Exhibit A - Referral Agreement, #2 Exhibit B - Schedule A to the Referral Agreement, #3 Exhibit C - Email from Paul Levinsohn to Jenny Liu, dated July 18, 2011, #4 Exhibit D - Email from Paul Levinsohn to Linda He and Jenny Liu, dated August 5, 2011, #5 Exhibit E - Schedule A to the Referral Agreement for the Brooklyn Navy Yard Redevelopment Project II, #6 Exhibit F - Email from Paul Levinsohn to Linda He and Jenny Liu, dated September 4, 2011, #7 Exhibit G - Email from Paul Levinsohn to Jenny Liu, dated July 3, 2012, #8 Exhibit H - Schedule A to the Referral Agreement for the New York City Central Business District Redevelopment Project, #9 Exhibit I - Email from Paul Levinsohn to Jenny Liu, dated March 7, 2012, #10 Exhibit J - Amended Schedule A to the Referral Agreement for the New York City Medical Office Campus Project)(Lender, David) |
| Filing 25 MEMORANDUM OF LAW in Support re: #24 MOTION to Dismiss the Amended Complaint. . Document filed by New York City Regional Center, LLC. (Lender, David) |
| Filing 24 MOTION to Dismiss the Amended Complaint. Document filed by New York City Regional Center, LLC.(Lender, David) |
| Filing 23 AMENDED COMPLAINT amending #1 Complaint against New York City Regional Center, LLC with JURY DEMAND.Document filed by Wailian Overseas Consulting Group, Ltd.. Related document: #1 Complaint. (Attachments: #1 Exhibit A - Amounts Owed by NYCRC)(Ross, David) |
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Filing 22
STIPULATION: Defendant's time to answer, move or otherwise respond to the Complaint, or to any amended complaint timely filed by Plaintiff pursuant to the Order, shall be on or before July 9, 2018. (New York City Regional Center, LLC answer due 7/9/2018.) (Signed by Judge Louis L. Stanton on 5/30/2018) (rro) Modified on 8/14/2018 (rro).
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Filing 21
MEMORANDUM & ORDER granting in part and denying in part #13 Motion to Dismiss: that NYCRC's motion partially to dismiss Wailian's complaint (0kt. No. 13) is granted in part and denied in part. The motion to dismiss the breach of contract claim with respect to the CBD and Medical Campus projects is granted, with leave to repleadwithin 30 days of the date of this order. In all other respects, the motion is denied. The motion for oral argument (0kt. No. 16) is denied. (Signed by Judge Louis L. Stanton on 5/17/18) (ml) Modified on 5/18/2018 (ml).
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| Filing 20 REPLY MEMORANDUM OF LAW in Support re: #13 MOTION to Dismiss the Complaint. . Document filed by New York City Regional Center, LLC. (Lender, David) |
| Filing 19 DECLARATION of David E. Ross in Opposition re: #13 MOTION to Dismiss the Complaint.. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1 - Oct. 30, 2011 Email)(Ross, David) |
| Filing 18 MEMORANDUM OF LAW in Opposition re: #13 MOTION to Dismiss the Complaint. . Document filed by Wailian Overseas Consulting Group, Ltd.. (Ross, David) |
| Filing 17 STIPULATION: IT IS HEREBY STIPULATED AND AGREED by and between the undersigned attorneys for the parties, subject to the Court's approval, that: Plaintiff shall me its response to the Motion on or before February 9, 2018. Defendant shall file its reply in further support of the Motion, if any, on or before March 2, 2018. Defendant previously requested and was granted an extension of time to respond to the Complaint. There have been no other requests for extension or adjournment in this action. (Responses due by 2/9/2018. Replies due by 3/2/2018.) (Signed by Judge Louis L. Stanton on 1/16/2018) (ap) |
| Filing 16 LETTER MOTION for Oral Argument addressed to Judge Louis L. Stanton from David J. Lender dated January 5, 2018. Document filed by New York City Regional Center, LLC.(Lender, David) |
| Filing 15 DECLARATION of David J. Lender in Support re: #13 MOTION to Dismiss the Complaint.. Document filed by New York City Regional Center, LLC. (Attachments: #1 Exhibit A - Referral Agreement, #2 Exhibit B - Schedule A for Medical Campus Project, #3 Exhibit C - Schedule A for East River Waterfront Project, #4 Exhibit D - Schedule A for George Washington Bridge Bus Station Project, #5 Exhibit E - Schedule A for Brooklyn Arena Infrastructure Project, #6 Exhibit F - September 4 Email from Levinsohn to He and Liu, #7 Exhibit G - Schedule A for Brooklyn Navy Yard Project II, #8 Exhibit H - Schedule A for Central Business District Project, #9 Exhibit I - Amended Schedule A for Medical Campus Project)(Lender, David) |
| Filing 14 MEMORANDUM OF LAW in Support re: #13 MOTION to Dismiss the Complaint. . Document filed by New York City Regional Center, LLC. (Lender, David) |
| Filing 13 MOTION to Dismiss the Complaint. Document filed by New York City Regional Center, LLC.(Lender, David) |
| Filing 12 STIPULATION EXTENDING TIME: IT IS HEREBY STIPULATED AND AGREED, subject to the Court's approval, by and between the undersigned counsel for the parties in the above-captioned action, as follows: Defendant New York City Regional Center LLC ("NYCRC") hereby accepts service of the Summons and Complaint without waiver of any defenses except as to sufficiency of service of process. NYCRC's time to answer, move or otherwise respond to the Complaint is extended through and including January 5, 2018. There has been no previous request for an extension of time by either party in this action. New York City Regional Center, LLC answer due 1/5/2018. (Signed by Judge Louis L. Stanton on 12/7/2017) (ap) |
| Filing 11 NOTICE OF APPEARANCE by Adam B Banks on behalf of New York city Regional Center, LLC. (Banks, Adam) |
| Filing 10 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by New York city Regional Center, LLC.(Lender, David) |
| Filing 9 NOTICE OF APPEARANCE by David Lender on behalf of New York city Regional Center, LLC. (Lender, David) |
| Filing 8 AFFIDAVIT of David E. Ross re: #6 Order,,, Set Deadlines,, . Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit 1 - November 22, 2017 D. Ross letter to NYCRC, #2 Exhibit 2 - December 1, 2017 NYCRC response to November 22 letter re Citizenship)(Ross, David) |
| Filing 7 AFFIDAVIT OF SERVICE of Summons and Complaint. New York city Regional Center, LLC served on 11/21/2017, answer due 12/12/2017. Service was accepted by Jane Yan, who was authorized to accept service of process on behalf of New York City Regional Center, LLC. Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Summons in a Civil Action)(Ross, David) |
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Filing 6
ORDER, Absent a filing, on or before December 21, 2017, of an amended complaint or affidavit adequately establishing the citizenship of each of the defendant's members, including, if any of its members are LLCs, partnerships, or other unincorporated entities, the citizenship of their members or partners, the action will be dismissed without further notice for lack of subject-matter jurisdiction. So ordered. (Amended Pleadings due by 12/21/2017.) (Signed by Judge Louis L. Stanton on 11/21/17) (yv)
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| Filing 5 ELECTRONIC SUMMONS ISSUED as to New York city Regional Center, LLC. (kl) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Louis L. Stanton. Please download and review the Individual Practices of the assigned District Judge, located at #http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #http://nysd.uscourts.gov/ecf_filing.php. (kl) |
| Magistrate Judge Barbara C. Moses is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #http://nysd.uscourts.gov/forms.php. (kl) |
| Case Designated ECF. (kl) |
| Filing 4 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Wailian Overseas Consulting Group, Ltd..(Ross, David) |
| Filing 3 CIVIL COVER SHEET filed. (Ross, David) |
| Filing 2 REQUEST FOR ISSUANCE OF SUMMONS as to New York City Regional Center, LLC, re: #1 Complaint. Document filed by Wailian Overseas Consulting Group, Ltd.. (Ross, David) |
| Filing 1 COMPLAINT against New York city Regional Center, LLC. (Filing Fee $ 400.00, Receipt Number 0208-14378488)Document filed by Wailian Overseas Consulting Group, Ltd.. (Attachments: #1 Exhibit A)(Ross, David) |
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