Heidrick & Struggles International, Inc. v. Korn/Ferry International et al
| Heidrick & Struggles International, Inc. |
| Chad Astmann, Korn/Ferry International, Deepali Vyas, Daniel Kaplan and Lorraine Hack |
| 1:2018cv01503 |
| February 20, 2018 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| New York |
| Paul A Engelmayer |
| Other Statutory Actions |
| 18 U.S.C. § 1836 |
| None |
Docket Report
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This docket was last retrieved on July 10, 2018. A more recent docket listing may be available from PACER.
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Filing 109
ORDER OF DISCONTINUANCE. The Court having been advised by the parties that all claims asserted herein have been settled in principle it is ORDERED that the above-entitled action is hereby dismissed and discontinued without costs, and without prejudice to the right to reopen the action within thirty days of the date of this Order if the settlement is not consummated, and as further set forth in this Order of Discontinuance. The Clerk of Court is respectfully directed to close this case. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 7/10/2018) (rjm)
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| Terminate Transcript Deadlines. (rjm) |
| Filing 108 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 6/26/2018 re: #100 LETTER MOTION to Compel Plaintiff to documents addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 20, 2018. . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 107 NOTICE OF CHANGE OF ADDRESS by Colin A. Underwood on behalf of Heidrick & Struggles International, Inc.. New Address: REED SMITH, LLP, 599 LEXINGTON AVE, NEW YORK, NEW YORK, USA 10022, 212-521-5400. (Underwood, Colin) |
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Filing 106
ORDER denying #97 Letter Motion to Compel. Korn/Ferry's motion is denied. The Clerk of Court is respectfully directed to close the motion pending at Dkt. 97. The Court is constrained to admonish counsel from both sides to refrain from raising meritless discovery disputes. (Signed by Judge Paul A. Engelmayer on 6/25/2018) (mro)
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| Filing 105 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 25, 2018 re: #99 LETTER MOTION to Compel CEO, Gary Burnison to Appear for a Deposition addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 6/20/2018. . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 104 DECLARATION of Colin A. Underwood in Opposition re: #91 MOTION to Dismiss / Notice of Defendants' Motion to Dismiss the Amended Complaint.. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit KF complaint, #2 Exhibit Astmann agreement)(Underwood, Colin) |
| Filing 103 MEMORANDUM OF LAW in Opposition re: #91 MOTION to Dismiss / Notice of Defendants' Motion to Dismiss the Amended Complaint. . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 102 LETTER RESPONSE to Motion addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 6/21/2018 re: #97 LETTER MOTION to Compel Plaintiff to produce documents addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 18, 2018. . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
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Filing 101
ORDER granting in part and denying in part #96 Letter Motion to Compel. The following order resolves the discovery disputes reported pending at Dkts. 96 and 98. As to H&S's Request Nos. 9, 12, and 15, H&S's motion is denied. These requests are far too broad and, with discovery about to close, come far too late in the day. As to H&S's Request No. 10, the Court grants H&S's motion. Internal communications within Korn/Ferry regarding its recruitment of the Recruited Employees are relevant to (and from a practical perspective, may be essential to proving) the requirement of bad faith related to H&S's unfair competition claim. The Court orders production of such documents. As to H&S's Request No. 16, the Court views these documents are of limited relevance, if any. While the parties are at liberty to agree to reciprocal exchanges of materials of this nature, the Court will not compel such discovery. As to H&S's request for the production of text messages, that request is also denied. It is unrealistic, at this late date in the discovery period, to ask Korn/Ferry to meet this burdensome request. Had H&S regarded this area of discovery as essential, it needed to have brought this dispute to the Court's attention earlier. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 6/21/2018) (anc)
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| Filing 100 LETTER MOTION to Compel Plaintiff to documents addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 20, 2018. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit A - Correspondence)(Levin, Gabrielle) |
| Filing 99 LETTER MOTION to Compel CEO, Gary Burnison to Appear for a Deposition addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 6/20/2018. Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
| Filing 98 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 20, 2018 re: #96 LETTER MOTION to Compel Defendants to produce documents addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 06/15/2018. . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 97 LETTER MOTION to Compel Plaintiff to produce documents addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 18, 2018. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 96 LETTER MOTION to Compel Defendants to produce documents addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 06/15/2018. Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
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Filing 95
ORDER terminating #87 Letter Motion to Compel. This order resolves the discovery dispute pending at Dkt. 87. The Court rules as follows: H&S is directed to produce, by June 18, 2018, a far more specific description of the confidential information it alleges was misappropriated. As discussed in the sole case cited by H&S in its opposition, Uni-Sys., LLC v. US. Tennis Ass'n, No. 17-CV-147KAMCLP, 2017 WL 4081904, (E.D.N.Y. Sept. 13, 2017), "federal courts regularly require...plaintiffs to identify alleged trade secrets with 'reasonable particularity,'" id. at *4. In Uni-Systems, Magistrate Judge Pollack found that this standard was met when the plaintiff "provided 36 pages describing their alleged trade secrets." Id. (emphasis added); see also Sit-Up Ltd. v. IAC/InterActiveCorp., No. 05 CIV. 9292 (DLC), 2008 WL 463884, at *7 (S.D.N.Y. Feb. 20, 2008) (discussing how "plaintiff submitted a twenty-eight-page narrative" of trade secrets at issue (emphasis added)). Here, H&S's less than four-page submission, attached as Exhibit 1 to Korn/Ferry's motion to compel, falls well short of that standard. H&S is directed to try again. H&S is advised that failure to describe with reasonable particularity the confidential information at issue may result in consequences ranging from an order compelling H&S to produce the underlying documents containing the relevant confidential information to dismissal of H&S's misappropriation claims. Absent good cause, H&S will not be permitted to modify its description of the confidential information at issue again. See, e.g., Powerweb Energy, Inc. v. Hubbell Lighting, Inc., No. 3:12CV220 WWE, 2012 WL 3113162, at *2 (D. Conn. July 31, 2012) ("[P]laintiff will be allowed to amend or supplement its list of trade secrets upon a showing to the Court of good cause.") (Signed by Judge Paul A. Engelmayer on 6/11/2018) (mro)
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| Filing 94 LETTER addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 11, 2018 re: oral argument request. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 93 DECLARATION of GABRIELLE LEVIN in Support re: #91 MOTION to Dismiss / Notice of Defendants' Motion to Dismiss the Amended Complaint.. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1 - Contract [Redacted], #2 Exhibit 2 - Contract [Redacted], #3 Exhibit 3 - Contract [Redacted], #4 Exhibit 4 - Correspondence, #5 Exhibit 5 - Email)(Levin, Gabrielle) |
| Filing 92 MEMORANDUM OF LAW in Support re: #91 MOTION to Dismiss / Notice of Defendants' Motion to Dismiss the Amended Complaint. . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 91 MOTION to Dismiss / Notice of Defendants' Motion to Dismiss the Amended Complaint. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 90 LETTER RESPONSE to Motion addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 6/11/2018 re: #87 LETTER MOTION to Compel Heidrick & Struggles International, Inc. to produce documents and databases addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 6, 2018. . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
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Filing 89
ORDER granting in part #82 Letter Motion to Compel; denying #84 Motion for Reconsideration. The Court rules as follows: Korn/Ferry is directed to produce forthwith: (1) communications with all Recruited Employees explicitly named in the Amended Complaint, and (2) the substance of the employment offers provided to them, including terms of compensation; and as further set forth herein. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 6/8/2018) (anc)
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Filing 88
ORDER granting #86 Letter Motion for Leave to File Excess Pages. Granted. The parties may file motion to dismiss briefing of the following lengths: 35 pages for the opening brief, 35 pages for the opposition, and 15 pages for reply. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 6/7/2018) (anc)
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| Filing 87 LETTER MOTION to Compel Heidrick & Struggles International, Inc. to produce documents and databases addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 6, 2018. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit A - Correspondence)(Levin, Gabrielle) |
| Filing 86 CONSENT LETTER MOTION for Leave to File Excess Pages addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 6, 2018. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 85 MEMORANDUM OF LAW in Support re: #84 MOTION for Reconsideration re; #81 Order,,,,,,,, . . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 84 MOTION for Reconsideration re; #81 Order,,,,,,,, . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 83 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated June 1, 2018 re: #82 LETTER MOTION to Compel KORN/FERRY INTERNATIONAL, CHAD ASTMANN, DESPALI VYES, DANIEL KAPLAN & LORRAINE HACK to produce documents and information addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 5/29/2018. . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 82 LETTER MOTION to Compel KORN/FERRY INTERNATIONAL, CHAD ASTMANN, DESPALI VYES, DANIEL KAPLAN & LORRAINE HACK to produce documents and information addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 5/29/2018. Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
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Filing 81
ORDER : The Court rules as follows. 1. On the issue of documents related to the recruited employees, the Court asks the parties to make renewed letter submissions, to take into account H&S's amended complaint, whose new claims may bear on this issue. However, to the extent that the Recruited Employees include individuals such as Hussain and Viola who are named in the H&S's complaint and were allegedly recruited by an Individual Defendant in breach of his or her employment contracts, the Court holds with H&S. As to such persons, the requested documents are clearly relevant. Those documents are to be produced forthwith. 2. On the issue of compensation, the Court holds with H&S, to the extent that the employee as to whom this information is sought is either (a) an Individual Defendant or (b) an individual named in the Complaint and alleged recruited in breach of an Individual Defendant's employment agreement. That is because the relative compensation of such persons is inherently part of the dispute here. And Korn/Feny itself has made that compensation all the more relevant insofar as indicated that it intends to argue that the Individual Defendants and possibly others who are claimed to have been unlawfully solicited s, as well as possibly Viola and Hussain, left their employment at H&S for Korn/Ferry not as a result of any unlawful conduct, but exclusively because of the prospect of earning more money at Korn/Ferry. H&S is entitled to examine in discovery the reasons for these employees' departures for Korn/Ferry, including the role the compensation arrangement at Korn/Ferry may have played in that decision. This information is also to provided forthwith. To the extent that H&S seeks compensation information for other Recruited Employees, the Court withholds judgment and directs counsel to revisit this issue, too, in their renewed letter motions taking into account the amended complaint. (Signed by Judge Paul A. Engelmayer on 5/25/2018) (rro)
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Filing 80
ORDER terminating #75 Motion for Extension of Time. The Court has received two letter requests regarding scheduling. Plaintiff seeks an extension of discovery deadlines. The Court extends by four weeks all discovery deadlines set in the case management plan, such that fact discovery will now end on July 30, 2018. The parties should not expect further extensions of these deadlines. Defendants seek expedited schedule on the motion to dismiss. The Court denies that motion and leaves the schedule intact. The Court expects to hold oral argument on the forthcoming motion to dismiss and will contact counsel early next week to set a date for argument. The Court adjourns the argument presented for June 11, 2018. The Court respectfully directs the Clerk of Court to close the motion pending at Dkt. 75. (Signed by Judge Paul A. Engelmayer on 5/25/2018) (rro)
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Filing 79
ORDER terminating #69 Letter Motion for Local Rule 37.2 Conference. This order resolves discovery disputes between the parties regarding the production of documents related to (1) the departures of Abrue Hussain and Paul Viola and (2) confidential information of plaintiff Heidrick & Struggles ("H&S"); as set forth herein. On the issue of documents related to the departures of Hussain and Viola, the Court holds with defendants. While H&S may prove correct that the decisive legal issue is what motivated Hussain and Viola's resignations, it is wrong that documents in H&S's possession regarding Hussain and Viola's proffered reasons for leaving H&S are irrelevant to their case. Those documents have potential to corroborate, or alternatively to undermine, Hussain and Viola's professed motivations for leaving. They might, for example, contain prior consistent-or inconsistent-statements by Hussain and Viola. They might contain an account of another employee who witnessed Hussain's harassment that could bolster, or undermine, the credibility of her claims that such harassment actually occurred and actually motivated her departure. They might contain information about a proposed promotion that was offered to Viola, corroborating his testimony that he was offered such a promotion but it was not ultimately given to him. The Court cannot know what is in those documents at this stage, but they have clear potential to contain information relevant to the defendants' defenses. The Court therefore grants defendants' motion with respect to document requests one and two. H&S is directed to comply with those requests forthwith. As to request three, relating to documents reflecting H&S's confidential information, the Court views this discovery dispute is premature. H&S has offered to provide a document or documents that describe with particularity the confidential information that it contends was misappropriated. Until H&S has done so, and defendants have reviewed it and determined whether there is good-faith basis to object to this means of meeting defendants' request, it will be premature for the Court to assess whether H&S has met its obligations. Accordingly, the Court directs H&S-within one week of this order-to furnish to defendants a document or documents sufficient to describe with particularity the confidential information that H&S contends was misappropriated. Defendants' motion regarding request number three is therefore denied without prejudice to renewal following H&S's submission of such material to defendants. (Signed by Judge Paul A. Engelmayer on 5/25/2018) (mro)
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Filing 78
STIPULATION AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Paul A. Engelmayer on 5/24/2018) (ne)
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| Filing 77 LETTER RESPONSE to Motion addressed to Judge Paul A. Engelmayer from Mitchell A. Karlan dated May 24, 2018 re: #75 LETTER MOTION for Extension of Time addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 5/23/2018. . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Karlan, Mitchell) |
| Filing 76 AMENDED COMPLAINT against Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
| Filing 75 LETTER MOTION for Extension of Time addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 5/23/2018. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit Proposed Amended Fact Discovery Plan and Scheduling Order)(Underwood, Colin) |
| Filing 74 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated May 21, 2018 re: #72 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated May 16, 2018. . Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 73 NOTICE OF APPEARANCE by Mitchell Alan Karlan on behalf of Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Karlan, Mitchell) |
| Filing 72 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated May 16, 2018. Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
| Filing 71 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated May 16, 2018 re: #69 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated May 11, 2018. . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 70 NOTICE OF APPEARANCE by Douglas Fuchs on behalf of Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Fuchs, Douglas) |
| Filing 69 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated May 11, 2018. Document filed by Chad Astmann, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
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Filing 68
ORDER: Accordingly, it is hereby ORDERED that plaintiff shall file any amended complaint by May 23, 2018. No further opportunities to amend will ordinarily be granted. If plaintiff does amend, by June 11, 2018, defendants shall: (1) file an answer; (2) file a new motion to dismiss; or (3) submit a letter to the Court, copying plaintiff, stating that they rely on the previously filed motion to dismiss. It is further ORDERED that if no amended complaint is filed, plaintiff shall serve any opposition to the motion to dismiss by May 23, 2018. Defendants' reply, if any, shall be served by May 30, 2018. At the time any reply is served, the moving party shall supply the Court with two courtesy copies of all motion papers by mailing or delivering them to the Thurgood Marshall United States Courthouse, 40 Centre Street, New York, New York 10007.SO ORDERED. (Amended Pleadings due by 5/23/2018. Motions due by 6/11/2018.) (Signed by Judge Paul A. Engelmayer on 4/25/2018) (anc)
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Filing 67
ORDER: Accordingly, it is hereby ORDERED that plaintiff shall file any amended complaint by May 23, 2018. No further opportunities to amend will ordinarily be granted. If plaintiff does amend, by June 11, 2018, defendants shall: (1) file an answer; (2) file a new motion to dismiss; or (3) submit a letter to the Court, copying plaintiff, stating that they rely on the previously filed motion to dismiss. It is further ORDERED that if no amended complaint is filed, plaintiff shall serve any opposition to the motion to dismiss by May 23, 2018. Defendants reply, if any, shall be served two courtesy copies of all motion papers by mailing or delivering them to the Thurgood Marshall United States Courthouse, 40 Centre Street, New York, New York 10007. SO ORDERED. (Amended Pleadings due by 5/23/2018.) (Signed by Judge Paul A. Engelmayer on 4/24/2018) (mml)
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Filing 66
MEMO ENDORSEMENT on re: #65 LETTER addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated April 23, 2018 re: Request for oral argument. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. ENDORSEMENT: The Court schedules oral argument on this motion for June 11, 2018 at 10:00 a.m. SO ORDERED. (Oral Argument set for 6/11/2018 at 10:00 AM before Judge Paul A. Engelmayer.) (Signed by Judge Paul A. Engelmayer on 4/24/2018) (rjm)
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| Filing 65 LETTER addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated April 23, 2018 re: request for oral argument. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 64 DECLARATION of GABRIELLE LEVIN in Support re: #62 MOTION to Dismiss the Complaint.. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1 - Astmann Employment Agreement, #2 Exhibit 2 - Vyas Employment Agreement, #3 Exhibit 3 - Kaplan Employment Agreement, #4 Exhibit 4 - Hack Employment Agreement)(Levin, Gabrielle) |
| Filing 63 MEMORANDUM OF LAW in Support re: #62 MOTION to Dismiss the Complaint. . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 62 MOTION to Dismiss the Complaint. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 61 NOTICE OF APPEARANCE by Ilissa Stacy Samplin on behalf of Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Samplin, Ilissa) |
| Filing 60 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a argument proceeding held on 4/4/18 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 59 TRANSCRIPT of Proceedings re: argument held on 4/4/2018 before Judge Paul A. Engelmayer. Court Reporter/Transcriber: Jennifer Thun, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/2/2018. Redacted Transcript Deadline set for 5/14/2018. Release of Transcript Restriction set for 7/10/2018.(McGuirk, Kelly) |
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Filing 58
FACT DISCOVERY PLAN AND SCHEDULING ORDER: Deposition due by 6/30/2018. Fact Discovery due by 6/30/2018. (Signed by Judge Paul A. Engelmayer on 4/9/2018) (mro)
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| Filing 57 NOTICE OF APPEARANCE by Peter M. Ellis on behalf of Heidrick & Struggles International, Inc.. (Ellis, Peter) |
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Filing 56
ORDER: For avoidance of doubt, H&S had five business days from the appointment of the arbitrator in which to seek preliminary relief before the preliminary injunction automatically expired. Based on counsel's representation in Court today, it is this Court's understanding that H&S has done so. Therefore, the preliminary injunction as ordered by the Court remains in effect until the earliest of (1) August 7, 2018 or (2) a decision on preliminary injunctive relief in the pending arbitration commenced by H&S against Hack. And as set forth herein. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 4/04/2018) (ama)
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Filing 55
ORDER: On the record at the oral argument today, April 4, 2018, the Court denied H&S' request for a preliminary injunction against Daniel Kaplan and Deepali Vyas. However, the Court set an expedited timetable for fact discovery, which the Court believes is amply justified for the reasons stated on the record. Fact discovery is set to close on June 30, 2018. The Court has given the parties until Monday to submit a case management plan consistent with that deadline. The Court denied defendant's request to stay discovery in light of their anticipated motion to dismiss. SO ORDERED., ( Fact Discovery due by 6/30/2018.) (Signed by Judge Paul A. Engelmayer on 4/04/2018) (ama)
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Filing 54
ORDER FOR ADMISSION PRO HAC VICE OF PETER M. ELLIS ON WRITTEN MOTION: granting #28 Motion for Peter M. Ellis to Appear Pro Hac Vice. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 4/04/2018) (ama)
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| Minute Entry for proceedings held before Judge Paul A. Engelmayer: Oral Argument held on 4/4/2018. Colin Underweood & Joseph Teig present for Plaintiff. Gabrielle Levin present for Defendants. Court reporter present. (ajs) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #28 MOTION for Peter M. Ellis 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. (bcu) |
| Filing 53 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a DECISON 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 52 TRANSCRIPT of Proceedings re: DECISON held on 3/8/2018 before Judge Paul A. Engelmayer. Court Reporter/Transcriber: Rose Prater, (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 4/23/2018. Redacted Transcript Deadline set for 5/3/2018. Release of Transcript Restriction set for 7/2/2018.(McGuirk, Kelly) |
| Filing 51 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 2/26/18 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 50 TRANSCRIPT of Proceedings re: CONFERENCE held on 2/26/2018 before Judge Paul A. Engelmayer. Court Reporter/Transcriber: Jennifer Thun, (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 4/23/2018. Redacted Transcript Deadline set for 5/3/2018. Release of Transcript Restriction set for 7/2/2018.(McGuirk, Kelly) |
| Filing 49 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 3/5/18 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 48 TRANSCRIPT of Proceedings re: conference held on 3/5/2018 before Judge Paul A. Engelmayer. Court Reporter/Transcriber: Rose Prater, (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 4/20/2018. Redacted Transcript Deadline set for 4/30/2018. Release of Transcript Restriction set for 6/28/2018.(McGuirk, Kelly) |
| NOTICE of Hearing: Oral Argument set for 4/4/2018 at 02:30 PM in Courtroom 1305, 40 Centre Street, New York, NY 10007 before Judge Paul A. Engelmayer. The argument, previously scheduled for 4/4/2018 at 4:00 PM, is hereby rescheduled for 4/4/2018 at 02:30 PM. Notice entered by Courtroom Deputy A.J. Smallman.(ajs) |
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Filing 47
ORDER granting #45 Letter Motion to Adjourn Conference. Granted. Due to the Court's busy schedule, including a trial beginning Monday, April 2, 2018, oral argument is rescheduled for April 4, 2018 at 4 p.m. SO ORDERED. (Oral Argument set for 4/4/2018 at 04:00 PM before Judge Paul A. Engelmayer.) (Signed by Judge Paul A. Engelmayer on 3/28/2018) (anc)
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| Filing 46 REPLY MEMORANDUM OF LAW in Support re: #21 MOTION for Preliminary Injunction . . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 45 CONSENT LETTER MOTION to Adjourn Conference / Adjournment of Oral Argument addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated March 22, 2018. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
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Filing 44
ORDER granting #42 Letter Motion for Leave to File Document. Granted. H&S may file a reply brief in support of its pending preliminary injunction motions by no later than March 27, 2018. H&S, however, is not permitted to file supporting factual declarations. On this point, the record is closed. The Court will hear oral argument on Friday, March 30, 2018 at 4:30 p.m. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 3/22/2018) (anc) Modified on 3/23/2018 (anc).
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| Set/Reset Deadlines: Replies due by 3/27/2018. Set/Reset Hearings: Oral Argument set for 3/30/2018 at 04:30 PM before Judge Paul A. Engelmayer. (anc) |
| Filing 43 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated March 21, 2018 re: #42 LETTER MOTION for Leave to File Short Reply Brief in Support addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 3/21/2018. . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 42 LETTER MOTION for Leave to File Short Reply Brief in Support addressed to Judge Paul A. Engelmayer from Colin A. Underwood dated 3/21/2018. Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
| Filing 41 LETTER addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated March 19, 2018 re: request for oral argument. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 40 MEMORANDUM OF LAW in Support re: #39 MOTION to Strike Document No. [23 and 24] - DECLARATIONS OF DAVID BOEHMER AND RICK GREENE. . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 39 MOTION to Strike Document No. [23 and 24] - DECLARATIONS OF DAVID BOEHMER AND RICK GREENE. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 38 DECLARATION of JODI FOURNIER in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 37 DECLARATION of ABRUE HUSSAIN in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 36 DECLARATION of PAUL VIOLA in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 35 DECLARATION of MAGALY URBAN in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 34 DECLARATION of DAN KAPLAN in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1 - Email, #2 Exhibit 2 - Email, #3 Exhibit 3 - Letter)(Levin, Gabrielle) |
| Filing 33 DECLARATION of DEEPALI VYAS in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1 - Letter, #2 Exhibit 2 - Letter, #3 Exhibit 3 - Letter)(Levin, Gabrielle) |
| Filing 32 DECLARATION of GABRIELLE LEVIN in Opposition re: #21 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1 - Kaplan Contract, #2 Exhibit 2 - Vyas Contract, #3 Exhibit 3 - Email, #4 Exhibit 4 - Preliminary Conference Transcript, #5 Exhibit 5 - Conference Transcript)(Levin, Gabrielle) |
| Filing 31 MEMORANDUM OF LAW in Opposition re: #21 MOTION for Preliminary Injunction . DEFENDANTS' MEMORANDUM OF LAW IN OPPOSITION TO PLAINTIFF'S MOTION FOR A PRELIMINARY INJUNCTION AGAINST DEFENDANTS DEEPALI VYAS AND DANIEL KAPLAN. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
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Filing 30
ORDER granting #29 Letter Motion for Extension of Time to File Response/Reply re #21 MOTION for Preliminary Injunction . Granted. The Court extends the deadline to file an opposition to plaintiff's motion to March 19, 2018. SO ORDERED. (Responses due by 3/19/2018.) (Signed by Judge Paul A. Engelmayer on 3/15/2018) (anc)
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| Filing 29 LETTER MOTION for Extension of Time to File Response/Reply as to #21 MOTION for Preliminary Injunction . addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated March 14, 2018. Document filed by Korn/Ferry International.(Levin, Gabrielle) |
| Filing 28 MOTION for Peter M. Ellis to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Affidavit of Peter M. Ellis in Support of Motion to Admit Counsel Pro Hac Vice, #2 Exhibit A (Illinois Good Standing), #3 [Proposed] Order for Admission Pro Hac Vice of Peter M. Ellis on Written Motion)(Underwood, Colin) |
| Filing 27 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Peter M. Ellis to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-14798001. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Affidavit of Colin A. Underwood in Support of the Motion to Admit Peter M. Ellis as Counsel Pro Hac Vice, #2 Exhibit A (Illinois Good Standing), #3 Exhibit B (Ohio Cert.), #4 [Proposed] Order for Admission Pro Hac Vice of Peter M. Ellis on Written Motion)(Underwood, Colin) Modified on 3/12/2018 (ma). |
| >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #27 MOTION for Peter M. Ellis to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-14798001. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): PLEASE REMOVE THE INACTIVE BARS (AND DISTRICT COURT) FROM THE MOTION ALONG WITH THEIR CERTIFICATES AND THE AFFIDAVIT MUST LIST ALL THREE STATEMENTS PURSUANT TO 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 Proposed Order.. (ma) |
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Filing 26
ORDER IMPOSING PRELIMINARY INJUNCTION granting #8 Motion for Preliminary Injunction. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED pursuant to Fed. R. Civ. P. Rule 65 that Hack is preliminarily enjoined from soliciting or contacting, or performing service for, any individual or entity that Hack knows to be or to have been an H&S client, including but not limited to any H&S client for whom Hack performed services while at H&S, whether or not any such client is also a client of defendant Korn/Ferry International, until the earliest of August 7, 2018; a decision on preliminary injunctive relief in the pending arbitration commenced by H&S against Hack under American Arbitration Association Case Number 01-18-0000-7912 (the "Arbitration"); or five (5) days after the appointment of the arbitrator in the Arbitration, should H&S fail to seek preliminary injunctive relief within that time period; and as further set forth herein. The Clerk of Court is respectfully directed to close the motion pending at Dkt. 8. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 3/9/2018) (anc)
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| Minute Entry for proceedings held before Judge Paul A. Engelmayer: Preliminary Injunction Hearing held on 3/8/2018. Colin A. Underwood & Joseph Benjamin Teig present for Plaintiffs. Gabrielle Levin present for Defendants. Court reporter present. (ajs) |
| Filing 25 MEMORANDUM OF LAW in Support re: #21 MOTION for Preliminary Injunction . . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 24 DECLARATION of Rick Greene in Support re: #21 MOTION for Preliminary Injunction .. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Underwood, Colin) |
| Filing 23 DECLARATION of David Boehmer in Support re: #21 MOTION for Preliminary Injunction .. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Underwood, Colin) |
| Filing 22 DECLARATION of Colin A. Underwood in Support re: #21 MOTION for Preliminary Injunction .. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Underwood, Colin) |
| Filing 21 MOTION for Preliminary Injunction . Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
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Filing 20
ORDER denying #16 Motion to Strike. On March 5, 2018, the Court held oral argument on Heidrick & Struggles International, Inc.'s ("H&S") motion for a preliminary injunction against Lorraine Hack. The Court denied Korn/Ferry's motion to strike the declaration of Rebecca Foremen Janjic in support of H&S's Hack preliminary injunction motion. Dkt. 10. The Court intends to resolve the Hack preliminary injunction motion from the bench on March 8, 2018 at 3 p.m. The Court also discussed H&S' s motion for a temporary restraining order/preliminary injunction against two other individual defendants, Deepali Vyas and Daniel Kaplan. H&S agreed to resubmit that motion as solely a motion for a preliminary injunction. The Court set the deadline for Vyas and Kaplan's response for March 15, 2018. (Signed by Judge Paul A. Engelmayer on 3/6/2018) (mro)
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| Set/Reset Deadlines: Responses due by 3/15/2018 (mro) |
| Minute Entry for proceedings held before Judge Paul A. Engelmayer: Status Conference held on 3/5/2018. Colin A. Underwood & Joseph Benjamin Teig present for Plaintiffs. Gabrielle Levin present for Defendants. Court reporter present. (ajs) |
| Filing 19 NOTICE OF APPEARANCE by Steven Cooper on behalf of Heidrick & Struggles International, Inc.. (Cooper, Steven) |
| Filing 18 LETTER addressed to Judge Paul A. Engelmayer from Gabrielle Levin dated March 2, 2018 re: Oral Argument. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 17 MEMORANDUM OF LAW in Support re: #16 MOTION to Strike Document No. #10 . . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 16 MOTION to Strike Document No. #10 . Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas.(Levin, Gabrielle) |
| Filing 15 DECLARATION of Lorraine Hack in Opposition re: #8 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Levin, Gabrielle) |
| Filing 14 DECLARATION of Coram Williams in Opposition re: #8 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Levin, Gabrielle) |
| Filing 13 DECLARATION of Gabrielle Levin in Opposition re: #8 MOTION for Preliminary Injunction .. Document filed by Chad Astmann, Lorraine Hack, Daniel Kaplan, Korn/Ferry International, Deepali Vyas. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Levin, Gabrielle) |
| Filing 12 MEMORANDUM OF LAW in Opposition re: #8 MOTION for Preliminary Injunction . . Document filed by Korn/Ferry International. (Levin, Gabrielle) |
| Filing 11 MEMORANDUM OF LAW in Support re: #8 MOTION for Preliminary Injunction . . Document filed by Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 10 DECLARATION of Rebecca Foremen Janjic in Support re: #8 MOTION for Preliminary Injunction .. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit Exh. A)(Underwood, Colin) |
| Filing 9 DECLARATION of Colin A. Underwood in Support re: #8 MOTION for Preliminary Injunction .. Document filed by Heidrick & Struggles International, Inc.. (Attachments: #1 Exhibit Summons & Complaint, #2 Exhibit Arbitration Demand, #3 Exhibit Letter, #4 Exhibit Letter, #5 Exhibit Preliminary Conference Transcript, #6 Exhibit Letter, #7 Exhibit Letter)(Underwood, Colin) |
| Filing 8 MOTION for Preliminary Injunction . Document filed by Heidrick & Struggles International, Inc..(Underwood, Colin) |
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Filing 7
ORDER: The Court, accordingly, set the following deadlines on the record: The motion for a temporary injunction and supporting papers are due February 27, 2018; and defendant Hack's response is due March 2, 2018. Also, defense counsel agreed to accept service on behalf of all defendants. The Court set the deadline for defendants to respond to the complaint for April 23, 2018. SO ORDERED. (Chad Astmann answer due 4/23/2018; Lorraine Hack answer due 4/23/2018; Daniel Kaplan answer due 4/23/2018; Korn/Ferry International answer due 4/23/2018; Deepali Vyas answer due 4/23/2018.)( Motions due by 2/27/2018. Responses due by 3/2/2018.) (Signed by Judge Paul A. Engelmayer on 2/26/2018) (anc)
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| Filing 6 NOTICE OF APPEARANCE by Colin A. Underwood on behalf of Heidrick & Struggles International, Inc.. (Underwood, Colin) |
| Filing 5 NOTICE OF APPEARANCE by Melissa I. Rubenstein on behalf of Heidrick & Struggles International, Inc.. (Rubenstein, Melissa) |
| Filing 4 NOTICE OF APPEARANCE by Joseph Benjamin Teig on behalf of Heidrick & Struggles International, Inc.. (Teig, Joseph) |
| ***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Gabrielle Frances Levin. The following case opening statistical information was erroneously selected/entered: Other Court Name New York State Supreme Court, New York County; Other Court Number 650750/2018. The following corrections have been made to your case entry: the Other Court Name has been modified to State Court - Supreme; the Other Court Number has been modified to 650750-2018. (pne) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Paul A. Engelmayer. 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. (pne) |
| 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. (pne) |
| Case Designated ECF. (pne) |
| Filing 3 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Korn/Ferry International.(Levin, Gabrielle) |
| Filing 2 CIVIL COVER SHEET filed. (Levin, Gabrielle) |
| Filing 1 NOTICE OF REMOVAL from Supreme Court of the State of New York, County of New York. Case Number: 650750/2018. (Filing Fee $ 400.00, Receipt Number 0208-14716878).Document filed by Lorraine Hack, Deepali Vyas, Chad Astmann, Korn/Ferry International, Daniel Kaplan. (Attachments: #1 Exhibit A - Complaint, New York State Court, #2 Exhibit B - Notice of Filing of Notice of Removal)(Levin, Gabrielle) |
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