MV Realty PBC, LLC v. Innovatus Capital Partners, LLC
| MV Realty PBC, LLC |
| Innovatus Capital Partners, LLC |
| 1:2018cv07142 |
| August 8, 2018 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| XX Out of State |
| Louis L Stanton |
| Contract: Other |
| 28 U.S.C. § 1332 Diversity Action |
| None |
Docket Report
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Filing 306
ORDER denying #304 Letter Motion to Seal. While noting Innovatus's politesse in suggesting that the highlighted portion of its opposition should be sealed (on MV's behalf) those portions approach the banal and shall not be sealed. (Signed by Judge Louis L. Stanton on 10/5/2022) (rro)
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| Filing 305 ***SELECTED PARTIES*** MEMORANDUM OF LAW in Opposition re: #297 MOTION in Limine . . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #304 .(Steinberg, Stuart) |
| Filing 304 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Michael H. McGinley dated September 30, 2022. Document filed by Innovatus Capital Partners, LLC..(Steinberg, Stuart) |
| Filing 303 MEMORANDUM OF LAW in Opposition re: #297 MOTION in Limine . . Document filed by Innovatus Capital Partners, LLC..(Steinberg, Stuart) |
| Filing 302 MEMORANDUM OF LAW in Opposition re: #294 MOTION in Limine . . Document filed by Innovatus Capital Partners, LLC..(Steinberg, Stuart) |
| ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #300 Proposed Order #296 Proposed Order was reviewed and approved as to form. (km) |
| Filing 300 PROPOSED ORDER. Document filed by MV Realty PBC, LLC. Related Document Number: #297 ..(Raofield, Jason) Proposed Order to be reviewed by Clerk's Office staff. |
| Filing 299 DECLARATION of Jason C. Raofield in Support re: #297 MOTION in Limine .. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A - Amended and Restated Limited Liability Company Agreement of MV Realty PBC, LLC, #2 Exhibit B - Non-Disclosure and Non-Solicitation Agreement With Restrictive Covenants, #3 Exhibit C - Confidentiality and Non-Circumvention Agreement between MV and Goodwood Inc, #4 Exhibit D - Confidentiality Agreement between MV and Monroe Capital, LLC, #5 Exhibit E - Excerpt of Neuman Deposition Transcript, #6 Exhibit F - Excerpt of Zachman Deposition Transcript).(Raofield, Jason) |
| Filing 298 MEMORANDUM OF LAW in Support re: #297 MOTION in Limine . . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 297 MOTION in Limine . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 296 PROPOSED ORDER. Document filed by MV Realty PBC, LLC. Related Document Number: #294 ..(Raofield, Jason) Proposed Order to be reviewed by Clerk's Office staff. |
| Filing 295 MEMORANDUM OF LAW in Support re: #294 MOTION in Limine . . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 294 MOTION in Limine . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 293 MANDATE of USCA (Certified Copy) USCA Case Number 22-0824. Upon due consideration, it is hereby ORDERED that the motions to dismiss are GRANTED and the appeals (22-327 and 22-328) are DISMISSED for lack of jurisdiction because a final order has not been issued by the district court as contemplated by 28 U.S.C. 1291 and there is no other basis for immediate appeal of an order addressing a request for discovery-related sanctions. See Petrello v. White, 533 F.3d 110, 11314 (2d Cir. 2008); see also Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 108 (2009). Even assuming the motion for leave to file sanction was essentially a request for reconsideration of the dismissal of the claim for injunctive relief in the complaint, Plaintiff-Appellant did not explicitly move for injunctive relief or otherwise demonstrate sufficient urgency to the appeal to allow for immediate appeal of the partial grant of summary judgment. See Sahu v. Union Carbide Corp., 475 F.3d 465, 46768 (2d Cir. 2007) (per curiam). It is further ORDERED that Plaintiff-Appellant's petition for a writ of mandamus (22-824) is DENIED because the petition does not demonstrate a "clear and indisputable" right to the writ. Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 38081 (2004) (quotation marks omitted); see also In re Certain Underwriter, 294 F.3d 297, 302 (2d Cir. 2002). The motions to seal are GRANTED, without prejudice to reconsideration by the district court, and the remaining motions to stay the district court proceedings, reassign the case to a different district judge, and consolidate matters in this Court are DENIED as moot. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Order: 8/16/2022. (tp) |
| Filing 292 MANDATE of USCA (Certified Copy) as to #256 Notice of Appeal, filed by Innovatus Capital Partners, LLC USCA Case Number 22-0328. Upon due consideration, it is hereby ORDERED that the motions to dismiss are GRANTED and the appeals (22-327 and 22-328) are DISMISSED for lack of jurisdiction because a final order has not been issued by the district court as contemplated by 28 U.S.C. 1291 and there is no other basis for immediate appeal of an order addressing a request for discovery-related sanctions. See Petrello v. White, 533 F.3d 110, 11314 (2d Cir. 2008); see also Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 108 (2009). Even assuming the motion for leave to file sanction was essentially a request for reconsideration of the dismissal of the claim for injunctive relief in the complaint, Plaintiff-Appellant did not explicitly move for injunctive relief or otherwise demonstrate sufficient urgency to the appeal to allow for immediate appeal of the partial grant of summary judgment. See Sahu v. Union Carbide Corp., 475 F.3d 465, 46768 (2d Cir. 2007) (per curiam). It is further ORDERED that Plaintiff-Appellant's petition for a writ of mandamus (22-824) is DENIED because the petition does not demonstrate a "clear and indisputable" right to the writ. Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 38081 (2004) (quotation marks omitted); see also In re Certain Underwriter, 294 F.3d 297, 302 (2d Cir. 2002). The motions to seal are GRANTED, without prejudice to reconsideration by the district court, and the remaining motions to stay the district court proceedings, reassign the case to a different district judge, and consolidate matters in this Court are DENIED as moot. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 8/16/2022. (tp) |
| Transmission of USCA Mandate/Order to the District Judge re: #292 USCA Mandate. (tp) |
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Filing 291
ORDER: With no response from Innovatus respecting Mr. Raofield's July 26 Letter, and having checked my own calendar, it seems feasible and appropriate to pick up the March 18, 2022 schedule and set the Final Pre-Trial Conference for Friday, October 21, 2022, at 12:30 PM, at which a firm trial date can be given. As far as my own calendar is concerned, it looks as though that would be (taking into account Innovatus's expert's engagement until Friday, November 11), set to start at 11:00 AM on Monday, November 14, 2022. SO ORDERED., ( Final Pretrial Conference set for 10/21/2022 at 12:30 PM before Judge Louis L. Stanton.) (Signed by Judge Louis L. Stanton on 8/11/2022) (ama)
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| Filing 290 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated July 26, 2022 re: Case Status. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 289
ORDER of USCA (Certified Copy) as to #256 Notice of Appeal, filed by Innovatus Capital Partners, LLC USCA Case Number 22-824. Upon due consideration, it is hereby ORDERED that the motions to dismiss are GRANTED and the appeals (22-327 and 22-328) are DISMISSED for lack of jurisdiction because a final order has not been issued by the district court as contemplated by 28 U.S.C. 1291 and there is no other basis for immediate appeal of an order addressing a request for discovery-related sanctions. See Petrello v. White, 533 F.3d 110, 11314 (2d Cir. 2008); see also Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 108 (2009). Even assuming the motion for leave to file sanction was essentially a request for reconsideration of the dismissal of the claim for injunctive relief in the complaint, Plaintiff-Appellant did not explicitly move for injunctive relief or otherwise demonstrate sufficient urgency to the appeal to allow for immediate appeal of the partial grant of summary judgment. See Sahu v. Union Carbide Corp., 475 F.3d 465, 46768 (2d Cir. 2007) (per curiam). It is further ORDERED that Plaintiff-Appellant's petition for a writ of mandamus (22-824) is DENIED because the petition does not demonstrate a "clear and indisputable" right to the writ. Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 38081 (2004) (quotation marks omitted); see also In re Certain Underwriter, 294 F.3d 297, 302 (2d Cir. 2002). The motions to seal are GRANTED, without prejudice to reconsideration by the district court, and the remaining motions to stay the district court proceedings, reassign the case to a different district judge, and consolidate matters in this Court are DENIED as moot. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Certified: 7/20/2022. (tp)
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Filing 288
ORDER of USCA (Certified Copy) as to #256 Notice of Appeal, filed by Innovatus Capital Partners, LLC USCA Case Number 22-0328. Upon due consideration, it is hereby ORDERED that the motions to dismiss are GRANTED and the appeals (22-327 and 22-328) are DISMISSED for lack of jurisdiction because a final order has not been issued by the district court as contemplated by 28 U.S.C. 1291 and there is no other basis for immediate appeal of an order addressing a request for discovery-related sanctions. See Petrello v. White, 533 F.3d 110, 11314 (2d Cir. 2008); see also Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 108 (2009). Even assuming the motion for leave to file sanction was essentially a request for reconsideration of the dismissal of the claim for injunctive relief in the complaint, Plaintiff-Appellant did not explicitly move for injunctive relief or otherwise demonstrate sufficient urgency to the appeal to allow for immediate appeal of the partial grant of summary judgment. See Sahu v. Union Carbide Corp., 475 F.3d 465, 46768 (2d Cir. 2007) (per curiam). It is further ORDERED that Plaintiff-Appellant's petition for a writ of mandamus (22-824) is DENIED because the petition does not demonstrate a "clear and indisputable" right to the writ. Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 38081 (2004) (quotation marks omitted); see also In re Certain Underwriter, 294 F.3d 297, 302 (2d Cir. 2002). The motions to seal are GRANTED, without prejudice to reconsideration by the district court, and the remaining motions to stay the district court proceedings, reassign the case to a different district judge, and consolidate matters in this Court are DENIED as moot. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Certified: 7/20/2022. (tp)
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| Filing 287 MEMO ENDORSEMENT on re: #284 Letter filed by Innovatus Capital Partners, LLC. ENDORSEMENT: No issue in this case justifies empanelling an advisory jury, and this suggestion is declined. (Signed by Judge Louis L. Stanton on 4/27/2022) (vfr) |
| Filing 286 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated April 26, 2022 re: Response to Innovatus' Apr. 14, 2022 letter (Dkt. 284). Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 285
ORDER: Innovatus's application for a stay of all proceedings in this Court (0kt. No. 320) is denied, with leave to renew it in the event the Court of Appeals does not grant MV Realty's motion in that Court to dismiss Innovatus's pending appeal. (Signed by Judge Louis L. Stanton on 4/18/2022) (rro)
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| Filing 284 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated April 14, 2022 re: Letter in Support of Advisory Jury. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 283
MEMO ENDORSEMENT on re: #282 Proposed Order for Withdrawal of Attorney filed by Innovatus Capital Partners, LLC. ENDORSEMENT: SO ORDERED. Attorney Ryan Martin Moore terminated. (Signed by Judge Louis L. Stanton on 4/13/2022) (rro)
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| Filing 282 PROPOSED ORDER FOR WITHDRAWAL OF ATTORNEY. Document filed by Innovatus Capital Partners, LLC..(Moore, Ryan) |
| Filing 281 MEMORANDUM OF LAW in Opposition re: #272 MOTION to Stay Further District Court Proceedings Pending Appeal.. . Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7).(Raofield, Jason) |
| Filing 280 ENDORSED LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated 3/24/2022 re: seeking leave to file under seal. ENDORSEMENT: After inspection of the exhibits, this application is granted and the four exhibits may be sealed on the above-mentioned understanding.. (Signed by Judge Louis L. Stanton on 3/29/2022) (rro) |
| Filing 279 NOTICE OF APPEARANCE by Robert C Gianchetti on behalf of MV Realty PBC, LLC..(Gianchetti, Robert) |
| Filing 278 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated March 24, 2022 re: #268 LETTER MOTION to Seal Exhibits attached to Innovatus' Motion to Stay Dkt. #267 addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 17, 2022. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 277 ***SELECTED PARTIES***DECLARATION of Michael H. McGinley in Support re: #272 MOTION to Stay Further District Court Proceedings Pending Appeal... Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. (Attachments: #1 Exhibit 1., #2 Exhibit 2., #3 Exhibit 3., #4 Exhibit 4., #5 Exhibit 5., #6 Exhibit 6., #7 Exhibit 7., #8 Exhibit 8., #9 Exhibit 9.)Motion or Order to File Under Seal: #275 .(McGinley, Michael) |
| Filing 276 ***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re: #272 MOTION to Stay Further District Court Proceedings Pending Appeal.. . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #275 .(McGinley, Michael) |
| Filing 275 LETTER MOTION to Seal Portions of Motion to Stay and Declaration of Michael H. McGinley with Exhibits Dkt #272 addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 23, 2022. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 274 DECLARATION of Michael H. McGinley in Support re: #272 MOTION to Stay Further District Court Proceedings Pending Appeal... Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1-9 (Filed under Seal).(McGinley, Michael) |
| Filing 273 MEMORANDUM OF LAW in Support re: #272 MOTION to Stay Further District Court Proceedings Pending Appeal.. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 272 MOTION to Stay Further District Court Proceedings Pending Appeal.. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 271
SCHEDULING ORDER: Fact Discovery due by 3/18/2022. Expert Discovery due by 7/22/2022. Motions due by 9/16/2022., Responses due by 9/30/2022, Replies due by 10/14/2022. SO ORDERED. (Signed by Judge Louis L. Stanton on 3/18/2022) (rro)
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| Filing 270 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated March 18, 2022 re: #269 LETTER MOTION to Stay All Further District Court Proceedings Pending Appeal addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 17, 2022. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Minute Entry for proceedings held before Judge Louis L. Stanton: Status Conference held on 3/18/2022. (Court Reporter Kelly Surina) (ml) |
| Filing 269 ***SELECTED PARTIES*** LETTER MOTION to Stay All Further District Court Proceedings Pending Appeal addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 17, 2022. Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. (Attachments: #1 Exhibit 1., #2 Exhibit 2., #3 Exhibit 3., #4 Exhibit 4., #5 Exhibit 5., #6 Exhibit 6., #7 Exhibit 7., #8 Exhibit 8., #9 Exhibit 9., #10 Exhibit 10., #11 Exhibit 11., #12 Exhibit 12.)Motion or Order to File Under Seal: #268 .(McGinley, Michael) |
| Filing 268 LETTER MOTION to Seal Exhibits attached to Innovatus' Motion to Stay Dkt. #267 addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 17, 2022. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 267 LETTER MOTION to Stay All Further District Court Proceedings Pending Appeal addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 17, 2022. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1-12 (filed under seal)).(McGinley, Michael) |
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Filing 266
ORDER granting in part #223 Letter Motion for Conference addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. Innovatus's letter motion to compel is granted in part, to the extent the Requests are modified and enforced as follows. Request No. 8. Stricken as overbroad and overburdensome; Request No. 10. Allowed with the words "this litigation, or Innovatus" stricken.; Requests Nos. 13-16. Same as No.8; Request No. 17 Allowed, replacing the words "relating to" with "discussing"; Request No. 18 Allowed with the words "referring to or" stricken. MV shall produce documents relevant to the remaining requests, to the extent they have not already been produced. So Ordered. (Signed by Judge Louis L. Stanton on 3/7/2022) (vfr)
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| Filing 265 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 4, 2022 re: Responding to MVs February 21, 2022 pre-motion conference letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #264 .(McGinley, Michael) |
| Filing 264 MOTION to Seal Innovatus letter responding to MVs February 21, 2022 pre-motion conference letter. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 263 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 4, 2022 re: Responding to MVs February 21, 2022 pre-motion conference letter [Dkt. 259]. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 262 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated March 4, 2022 re: In support of MVs request to seal its February 21, 2022 pre-motion conference letter [Dkt. 258]. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 261 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated February 28, 2022 re: MV Realty Parties February 21, 2022 Pre-Motion Letter. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 260 REDACTION to #259 LETTER MOTION to Compel Innovatus to produce documents addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 21, 2022. by MV Realty PBC, LLC (Attachments: #1 Exhibit A).(Raofield, Jason) |
| Filing 259 ***SELECTED PARTIES*** LETTER MOTION to Compel Innovatus to produce documents addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 21, 2022. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #258 .(Raofield, Jason) |
| Filing 258 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 21, 2022. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 257 MEMO ENDORSEMENT on re: (229 in 1:18-cv-07142-LLS) Response in Support of Motion, filed by Innovatus Capital Partners, LLC, (270 in 1:18-cv-04252-LLS) Response in Support of Motion, filed by Innovatus Capital Partners, LLC. ENDORSEMENT: Upon this understanding, the designated portion of this sentence may remain under seal. (Signed by Judge Louis L. Stanton on 2/17/2022) (rro) |
| Filing 256 NOTICE OF APPEAL from #255 Order,,,,, #91 Memorandum & Opinion,, #108 Memorandum & Opinion,,. Document filed by Innovatus Capital Partners, LLC. Filing fee $ 505.00, receipt number ANYSDC-25748378. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit..(McGinley, Michael) |
| Transmission of Notice of Appeal and Certified Copy of Docket Sheet to US Court of Appeals re: #256 Notice of Appeal. (tp) |
| Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files for #256 Notice of Appeal, filed by Innovatus Capital Partners, LLC were transmitted to the U.S. Court of Appeals. (tp) |
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Filing 255
ORDER: Innovatus seeks leave to move for sanctions based on MV Realty's alleged fraud on the court and discovery abuses. See Dkt. No. 259. Innovatus seeks leave to move for sanctions based on MVRealty's alleged fraud on the court and discovery abuses. SeeDkt. No. 259. As part of the requested relief, Innovatus asks the Court to vacate its December 23, 2020 Order dismissing its request for injunctive relief, arguing that MV obtained that order based on a "series of discovery abuses and factual misrepresentations which only recently have come to light-and which were critically important to its attempt to get Innovatus' injunct ive claim dismissed at a preliminary stage.... " Id. at 1. Innovatushighlights several categories of allegedly newly revealed information that it argues have now disproved the bases for theCourt's summary judgment determination. Id. at 3-4. The parties' charges and countercharges of discovery abuses have fair room for argument, but bristle with questions of fact and are at best only collateral to the core issues set forth in the December 23, 2020 and February 11, 2021 Orders. There may be a time and place for evidentiary hearings of those discovery matters, but at present they are distractions from the main points. Innovatus's above applications are denied. (Signed by Judge Louis L. Stanton on 2/14/2021) (rro)
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| Filing 254 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 14, 2022 re: Supplement to Dkt. 248. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B).(Raofield, Jason) |
| Filing 253 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Jason Raofield dated February 10, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. MV's response to letter at ECF Dkt. No. 252. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 252 LETTER RESPONSE in Support of Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated February 9, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 251 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated February 9, 2022 re: In Response to the MV Realty Parties Letter Request (Dkt. 242). Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 250 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated February 7, 2022 re: Intent to File Response to Feb 7, 2022 Letter [Dkt.290]. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 249
ORDER granting #246 Motion to Withdraw as Attorney. Upon consideration and for good cause shown, the motion by Innovatus Capital Partners, LLC, Plaintiff in the first above-captioned action and Defendant in the second above-captioned action, for an order withdrawing Selby Brown as counsel of record in the above-captioned matters is GRANTED and the clerk of the court is directed to remove Selby Brown from service of any further pleadings in connection with these matters. Attorney Selby Brown terminated (Signed by Judge Louis L. Stanton on 2/7/2022) (rro)
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| Filing 248 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 7, 2022 re: Supplement to Dkt. 243. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B).(Raofield, Jason) |
| Filing 247 PROPOSED ORDER. Document filed by Innovatus Capital Partners, LLC. Related Document Number: #246 ..(Brown, Selby) Proposed Order to be reviewed by Clerk's Office staff. |
| Filing 246 MOTION for Selby Brown to Withdraw as Attorney . Document filed by Innovatus Capital Partners, LLC..(Brown, Selby) |
| ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #247 Proposed Order was reviewed and approved as to form. (km) |
| Filing 245 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated February 3, 2022 re: Intent to File Responses. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 301
MEMO ENDORSEMENT on re: #239 Response in Opposition to Motion, filed by MV Realty PBC, LLC. ENDORSEMENT: nnovatus's January 26 request for sealing, although responsibly made, is denied. So Ordered. (Signed by Judge Louis L. Stanton on 2/1/2022) (ml)
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| Filing 244 REDACTION to #243 Response to Motion, by MV Realty PBC, LLC (Attachments: #1 Exhibit A, #2 Exhibit B).(Raofield, Jason) |
| Filing 243 ***SELECTED PARTIES***LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 1, 2022 re: #223 LETTER MOTION for Conference [Pre-Motion] addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. . Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)Motion or Order to File Under Seal: #242 .(Raofield, Jason) |
| Filing 242 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 1, 2022. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 241 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 31, 2022 re: Response to Innovatus' 1/26/22 letter (Dkt. 233). Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 240 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 31, 2022 re: Response to Innovatus' 1/26/22 letter (Dkt. 236). Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 239 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 31, 2022 re: #235 LETTER MOTION to Seal Portions of Letter Reply to Response to Motion dated January 26, 2022 Dkt. #234 addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 238 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 31, 2022 re: #232 LETTER MOTION to Seal Portions of Letter Reply to Response to Motion dated January 26, 2022 Dkt. #231 addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 237 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 27, 2022 re: sur-replies. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #228 MOTION for Ali Mojibi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25637684. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 236 ***SELECTED PARTIES***LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #235 .(McGinley, Michael) |
| Filing 235 LETTER MOTION to Seal Portions of Letter Reply to Response to Motion dated January 26, 2022 Dkt. #234 addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 234 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 233 ***SELECTED PARTIES***LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #223 LETTER MOTION for Conference [Pre-Motion] addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #232 .(McGinley, Michael) |
| Filing 232 LETTER MOTION to Seal Portions of Letter Reply to Response to Motion dated January 26, 2022 Dkt. #231 addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 231 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #223 LETTER MOTION for Conference [Pre-Motion] addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 230 LETTER RESPONSE in Support of Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #224 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 17, 2022. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 229 LETTER RESPONSE in Support of Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 26, 2022 re: #220 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 13, 2022. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 228 MOTION for Ali Mojibi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25637684. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration, #2 CA Certificate of Good Standing, #3 DC Certificate of Good Standing, #4 Proposed Order).(Mojibi Yazdi, Ali) |
| Filing 227 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 24, 2022 re: replies to Innovatus' motions for sanctions and pre-motion conference and responses to MV motions to seal. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 226 REDACTION to #225 Response to Motion, by MV Realty PBC, LLC (Attachments: #1 Exhibit Exhibit 1 - Filed Under Seal).(Raofield, Jason) |
| Filing 225 ***SELECTED PARTIES***LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 17, 2022 re: #223 LETTER MOTION for Conference [Pre-Motion] addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. . Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1)Motion or Order to File Under Seal: #224 .(Raofield, Jason) |
| Filing 224 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 17, 2022. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 223 LETTER MOTION for Conference [Pre-Motion] addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 14, 2022. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Errata C).(McGinley, Michael) |
| Filing 222 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 13, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. [Redacted]. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 221 ***SELECTED PARTIES***LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 13, 2022 re: #216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. . Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. Motion or Order to File Under Seal: #220 .(Raofield, Jason) |
| Filing 220 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 13, 2022. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 216 LETTER MOTION for Leave to File a Motion for Sanctions addressed to Judge Louis L. Stanton from Michael H. McGinley dated January 3, 2022. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 215
ORDER: It would be premature to make any decision on the merits of this case before the parties have concluded fact discovery. MV Realty's request for leave to seek an order to show cause is denied. At the March 18, 2022 status conference, the parties should be prepared to set a schedule for the submission of the joint Pre-Trial Order and associated material for a trial on the issues defined in the Court's December 23, 2020 Memorandum Opinion and Order. So Ordered. (Signed by Judge Louis L. Stanton on 12/13/2021) (rro)
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| Filing 214 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated December 7, 2021 re: #197 LETTER MOTION to Seal MV's November 18 pre-motion letter and exhibits addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 18, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 213 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated December 7, 2021 re: Response to Innovatus 12/3/21 letter (ECF 208). Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 212 LETTER RESPONSE in Support of Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 6, 2021 re: #197 LETTER MOTION to Seal MV's November 18 pre-motion letter and exhibits addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 18, 2021. . Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A., #2 Exhibit B., #3 Exhibit C.).(McGinley, Michael) |
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Filing 211
MEMO ENDORSEMENT granting #205 Motion to Amend/Correct #205 CONSENT MOTION to Amend/Correct Scheduling Order. ENDORSEMENT: SO ORDERED.. (Signed by Judge Louis L. Stanton on 12/6/2021) (rro)
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| Filing 210 LETTER RESPONSE in Opposition to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated December 6, 2021 re: #207 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 3, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Set/Reset Deadlines: ( Fact Discovery due by 3/18/2022.), Set/Reset Hearings:( Status Conference set for 3/18/2022 at 02:30 PM before Judge Louis L. Stanton.) (rro) |
| Filing 209 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 3, 2021 re: Responses to the MV Realty Parties 11/18/2021 Pre-Motion Conference Letter. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 208 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 3, 2021 re: Response to MV's 11/18/2021 PMC Letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #207 .(McGinley, Michael) |
| Filing 207 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 3, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 206 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated December 3, 2021 re: Response to MV's 11/18/2021 PMC Letter [Dkt. 199]. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 205 CONSENT MOTION to Amend/Correct Scheduling Order. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 204 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 30, 2021 re: Intent to File Responses.. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 203
ORDER: As appears from the parties' recent correspondence, Innovatus's requests for discovery are unquestionably overbroad. It seeks to obtain discovery of several whole categories of documents, including: Documents relating to MV' s relationship with 777 Partners; Documents relating to financial advisors, rating agencies, and investors; Documents relating to MV's Board of Director meetings; Various internal communications. There may be some documents within those spacious business areas that are relevant to the only matter remaining in this case, Innovatus's entitlement to recompense for its contributions to MV' s business if they enhanced its results, and all such documents must be produced. As the Court has reiterated in multiple Orders, Innovatus is only entitled to discovery on that issue, and MV shall produce responsive documents, to whatever extent they have not yet been produced. See Orders dated December 23, 2020 and February 11, 2021. As Redibs exists only to serve Innovatus's interests in the conduct of RTL sales, and Innovatus's control over Redibs borders on the absolute, the two may be regarded as alter egos for purposes of retention and disclosure of documents; and demands for production directed to one taken as also directed to the other, to be complied with by whichever possesses the responsive documents. See also Order dated July 7, 2021. (Signed by Judge Louis L. Stanton on 11/24/2021) (rro)
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| Filing 202 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 22, 2021 re: MV's November 16, 2021 letter [Doc# 194]. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 201 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 22, 2021 re: Response to Innovatus' 11/19/21 letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 200 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 19, 2021 re: MV Realty Parties' November 8, 2021 Letter Dkt. #190 .. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 199 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 18, 2021 re: pre-motion letter. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibits 1-23 (public slipsheet), #2 Exhibit 24).(Raofield, Jason) |
| Filing 198 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 18, 2021 re: pre-motion letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4-1, #5 Exhibit 4-2, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Exhibit 9, #11 Exhibit 10, #12 Exhibit 11, #13 Exhibit 12, #14 Exhibit 13, #15 Exhibit 14, #16 Exhibit 15, #17 Exhibit 16, #18 Exhibit 17, #19 Exhibit 18, #20 Exhibit 19, #21 Exhibit 20, #22 Exhibit 21, #23 Exhibit 22, #24 Exhibit 23, #25 Exhibit 24)Motion or Order to File Under Seal: #197 .(Raofield, Jason) |
| Filing 197 LETTER MOTION to Seal MV's November 18 pre-motion letter and exhibits addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 18, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 196 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 16, 2021 re: Response to Innovatus' November 5, 2021 letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 195 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 16, 2021 re: Response to Innovatus' November 5, 2021 letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #194 .(Raofield, Jason) |
| Filing 194 LETTER MOTION to Seal MV's November 16, 2021 letter addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 16, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 193 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 15, 2021 re: Responses to MV Letters. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 192
ORDER denying #187 Letter Motion to Seal. Innovatus writes to supplement MV Realty's October 25, 2021 letter motion to seal (Dkt. No. 219) portions of MV's response (Dkt. No. 220) to Innovatus's October 11, 2021 letter (Dkt. No. 207). See Dkt. No. 227. Considering Innovatus s supplemental letter, the Court grants MV 's letter motion to seal. The letter response (Dkt. No. 220) may be filed with the proposed redactions, and Exhibit 4 may be filed wholly under seal. The Court previously agreed that the information contained in Exhibit 4 discloses " business thought processes and reveals, to some degree, the roadmap Innovatus has used and continues to use in its RTL business", and therefore, it may remain sealed at this stage, as long as itis understood that the temporarily protected information may ultimately need to be revealed at trial. MV also writes in response to Innovatus's November 5, 2021 letter motion to seal (Dkt. No. 229), stating that it does not seek to seal the information redacted by Innovatus in its November 5, 2021 letter motion (Dkt. No. 228), with the exception of Exhibit F, which MV describes as a patent license agreement with a third party that includes "a confidentiality provision and identifies terms on which the third party was willing to grant the license to MV". See Dkt. No. 231. While the attached agreement does include a section prohibiting the disclosure of " confidential information" (as defined in the agreement in Section 9), that provision does not render the agreement itself, or any terms contained therein, confidential. Therefore, the Court does not find justification for sealing Exhibit F and Innovatus ' s letter motion to seal (Dkt. No. 229), as supplemented by MV ' s letter (Dkt. No. 231), is denied. So Ordered.. (Signed by Judge Louis L. Stanton on 11/15/2021) (rro)
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| Filing 191 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021 re: MOTION to Seal Portions of Innovatus' November 5, 2021 Letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #187 .(McGinley, Michael) |
| Filing 190 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 8, 2021 re: Reply to Innovatus' 11/5/21 letter response (ECF 184). Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 189 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated November 8, 2021 re: #187 LETTER MOTION to Seal Portions of Innovatus' November 5, 2021 Letter addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 188 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021 re: MOTION to Seal Portions of Innovatus' November 5, 2021 Letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C-1, #4 Exhibit C-2, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I)Motion or Order to File Under Seal: #187 .(McGinley, Michael) |
| Filing 187 LETTER MOTION to Seal Portions of Innovatus' November 5, 2021 Letter addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 186 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021 re: #165 LETTER MOTION for Conference Regarding the MV Realty Parties' Failure to Produce Highly Relevant Documents addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. and Reply to [Dkt. 181]. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I).(McGinley, Michael) |
| Filing 185 LETTER RESPONSE in Support of Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021 re: #177 LETTER MOTION to Seal portions of MVs October 25, 2021 response letter and the exhibits thereto addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 25, 2021. . Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A).(McGinley, Michael) |
| Filing 184 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated November 5, 2021 re: #171 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 22, 2021. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #183 MOTION for Kristin M. Cobb to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25263296. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies. (aea) |
| Filing 183 MOTION for Kristin M. Cobb to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25263296. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration in Support of Motion, #2 Text of Proposed Order, #3 DC Certificate of Good Standing, #4 VA Certificate of Good Standing).(Cobb, Kristin) |
| Filing 182 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 28, 2021 re: Responses to MV Letters. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 181 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 26, 2021 re: Response to Innovatus' "supplement" (Dkt. 173). Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2).(Raofield, Jason) |
| Filing 180 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 26, 2021 re: #174 LETTER MOTION to Seal portions of the October 25, 2021 letter [Doc # 173] supplementing October 11, 2021 letter requesting a pre motion conference addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 25, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 179 REDACTION to #178 Response to Motion,, by MV Realty PBC, LLC (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8).(Raofield, Jason) |
| Filing 178 ***SELECTED PARTIES***LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 25, 2021 re: #165 LETTER MOTION for Conference Regarding the MV Realty Parties' Failure to Produce Highly Relevant Documents addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. . Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8)Motion or Order to File Under Seal: #177 .(Raofield, Jason) |
| Filing 177 LETTER MOTION to Seal portions of MVs October 25, 2021 response letter and the exhibits thereto addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 25, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 176
ORDER denying #170 Letter Motion to Seal. My examination of the material sought to be sealed shows that it is far below the standards of Lugosch and its progeny, and any application for its sealing would be denied. Accordingly the application in this letter (quite properly made) would be futile and is denied.. (Signed by Judge Louis L. Stanton on 10/24/2021) (kv) Modified on 10/28/2021 (kv).
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| Filing 175 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 25, 2021 re: supplement to October 11, 2021 letter requesting a pre motion conference. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #174 .(McGinley, Michael) |
| Filing 174 LETTER MOTION to Seal portions of the October 25, 2021 letter [Doc # 173] supplementing October 11, 2021 letter requesting a pre motion conference addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 25, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 173 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 25,2021 re: supplement to October 11, 2021 letter requesting a pre motion conference. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 172 REDACTION to #171 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 22, 2021. by MV Realty PBC, LLC (Attachments: #1 Exhibit 1, #2 Exhibit 2).(Raofield, Jason) |
| Filing 171 ***SELECTED PARTIES*** LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 22, 2021. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2)Motion or Order to File Under Seal: #170 .(Raofield, Jason) |
| Filing 170 LETTER MOTION to Seal portions of MVs October 22, 2021 pre-motion conference letter addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 22, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 169
ORDER granting #166 Letter Motion to Seal. Innovatus correctly preserved MV's option to seek sealing. Although MV correctly waived it. (Signed by Judge Louis L. Stanton on 10/21/2021) (rro)
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| Filing 168 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated October 20, 2021 re: #166 LETTER MOTION to Seal Portions of Innovatus Letter Motion for Conference, Doc. #165 addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 167 ***SELECTED PARTIES*** LETTER MOTION for Conference addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. (Attachments: #1 Exhibit A., #2 Exhibit B., #3 Exhibit C., #4 Exhibit D.)Motion or Order to File Under Seal: #166 .(McGinley, Michael) |
| Filing 166 LETTER MOTION to Seal Portions of Innovatus Letter Motion for Conference, Doc. #165 addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 165 LETTER MOTION for Conference Regarding the MV Realty Parties' Failure to Produce Highly Relevant Documents addressed to Judge Louis L. Stanton from Michael H. McGinley dated October 11, 2021. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A. Redacted, #2 Exhibit B. Redacted, #3 Exhibit C. Redacted, #4 Exhibit D. Redacted).(McGinley, Michael) |
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Filing 164
ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE granting #161 Motion for Connor J. Kelley to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 9/24/2021) (rro)
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Filing 163
MEMO ENDORSEMENT on re: (205 in 1:18-cv-04252-LLS) Letter, filed by Amanda Zachman, Greg Williams, Antony Mitchell, Jonathan Neuman, Daryl Clark, Ritz Advisors, LLC, (162 in 1:18-cv-07142-LLS) Letter filed by MV Realty PBC, LLC. ENDORSEMENT: So ordered. Attorney Margaret H Brennan terminated. (Signed by Judge Louis L. Stanton on 9/17/2021) (rro)
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| Filing 162 LETTER addressed to Judge Louis L. Stanton from Margaret H. Brennan dated September 16, 2021 re: Withdrawal as attorney. Document filed by MV Realty PBC, LLC..(Brennan, Margaret) |
| Filing 161 MOTION for Connor J. Kelley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24942386. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration, #2 Proposed Order, #3 DC Certificate of Good Standing, #4 VA Certificate of good Standing).(Kelley, Connor) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #161 MOTION for Connor J. Kelley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24942386. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
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Filing 160
MEMO ENDORSEMENT granting #159 Motion to Amend/Correct #159 CONSENT MOTION to Amend/Correct #123 Order on Motion to Amend/Correct . ENDORSEMENT: SO ORDERED. (Signed by Judge Louis L. Stanton on 8/16/2021) (rro)
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| Set/Reset Deadlines: ( Deposition due by 1/14/2022., Fact Discovery due by 1/14/2022.), Set/Reset Hearings:( Status Conference set for 1/21/2022 at 12:30 PM before Judge Louis L. Stanton.) (rro) |
| Filing 159 CONSENT MOTION to Amend/Correct #123 Order on Motion to Amend/Correct . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 158
ORDER: Pursuant to the Court's June 1, 2021 Order, Innovatus submitted briefing detailing the basis for its request to seal certain content in the MV Realty Parties' May 24, 2021 and June 9, 2021 Letters and attached Exhibit A. See Dkt. No. 186. MV Realty filed a brief letter in response, arguing that much of the information Innovatus seeks to seal already appears on the public docket. See Dkt. No. 188. The information Innovatus seeks to seal does disclose business thought processes and reveals, to some degree, the "roadmap" Innovatus has used and continues to use in its RTL business. Bearing in mind the much- reduced level of secrecy required to be shown to justify sealing materials on discovery matters rather than on a motion addressed to the merits of the case, Innovatus may redact the requested information, to the extent such information is not already disclosed in publicly filed materials. So Ordered. (Signed by Judge Louis L. Stanton on 8/3/2021) (rro)
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Filing 157
ORDER ADMITTING STEVEN B. FEIRSON PRO HAC VICE granting #114 Motion for Steven B. Feirson to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 8/2/2021) (rro)
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Filing 156
ORDER ADMITTING STUART STEINBERG PRO HAC VICE: granting #152 Motion for Stuart T. Steinberg to Appear Pro Hac Vice. So Ordered. (Signed by Judge Louis L. Stanton on 7/7/2021) (js)
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| Filing 155 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated July 6, 2021 re: MV Realty Parties' May 24, 2021 Pre-Motion Letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 154 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 22. 2021 re: Response to Innovatus June 22 Letter at ECF Dkt. No. 153. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 153 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 22, 2021 re: Reply to MV Realty Parties' Letter at ECF 151. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #152 MOTION for Stuart T. Steinberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24681055. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) |
| Filing 152 MOTION for Stuart T. Steinberg to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24681055. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Declaration of Stuart T. Steinberg In Support of Pro Hac Vice Motion, #2 Certificate of Good Standing, #3 Text of Proposed Order).(Steinberg, Stuart) |
| Filing 151 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 15, 2021 re: Reply to Innovatus' Letter at ECF 191. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 150 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 15, 2021 re: #147 LETTER MOTION to Seal Portions of Innovatus' June 14, 2021 Letter addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 14, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 149 RESPONSE re: #139 Reply to Response to Motion, . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 148 ***SELECTED PARTIES*** RESPONSE re: #139 Reply to Response to Motion, . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #147 .(McGinley, Michael) |
| Filing 147 LETTER MOTION to Seal Portions of Innovatus' June 14, 2021 Letter addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 14, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 146 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 14, 2021 re: Innovatus Briefing at ECF Dkt. No. 144. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 145 DECLARATION of Joseph Schottland in Support re: #143 MOTION to Seal Portions of the MV Realty Parties' May 24, 2021 Pre-Motion Conference Letter and June 9, 2021 Reply Letter, and the Entirety of Exhibit A Attached Thereto.. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 144 MEMORANDUM OF LAW in Support re: #143 MOTION to Seal Portions of the MV Realty Parties' May 24, 2021 Pre-Motion Conference Letter and June 9, 2021 Reply Letter, and the Entirety of Exhibit A Attached Thereto. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 143 MOTION to Seal Portions of the MV Realty Parties' May 24, 2021 Pre-Motion Conference Letter and June 9, 2021 Reply Letter, and the Entirety of Exhibit A Attached Thereto. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 142
ORDER granting #140 Letter Motion for Extension of Time to File. Extension to Monday June 14 at 12 o'clock noon is allowed. So Ordered. (Signed by Judge Louis L. Stanton on 6/10/2021) (rro)
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Filing 141
ORDER ADMITTING RYAN M. MOORE PRO HAC VICE granting #127 Motion for Ryan M. Moore to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 6/8/2021) (rro)
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| Filing 140 LETTER MOTION for Extension of Time to File re: May 24, 2021 Pre-Motion Conference Order Dkt #129 addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 10, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 139 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 9, 2021 re: #126 LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 138 ***SELECTED PARTIES***LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 9, 2021 re: #126 LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. . Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #137 .(Raofield, Jason) |
| Filing 137 LETTER MOTION to Seal MV Realty Parties' letter reply to Innovatus' 6/2/21 response letter addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 9, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 136
ORDER denying #130 Letter Motion to Seal. Denied. (Signed by Judge Louis L. Stanton on 6/7/2021) (rro)
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| Filing 135 LETTER addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 7, 2021 re: Supplemental Letter re: Innovatus Letter Response to Motion #132 . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 134 REPLY re: #133 Response to Motion, Motion to Seal. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 133 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 3, 2021 re: #130 LETTER MOTION to Seal Innovatus Capital Partners LLC's Response to Letter Motion for Conference dated May 24, 2021 addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 2, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 132 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 2, 2021 re: #126 LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| Filing 131 ***SELECTED PARTIES***LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 2, 2021 re: #126 LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. . Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. Motion or Order to File Under Seal: #130 .(McGinley, Michael) |
| Filing 130 LETTER MOTION to Seal Innovatus Capital Partners LLC's Response to Letter Motion for Conference dated May 24, 2021 addressed to Judge Louis L. Stanton from Michael H. McGinley dated June 2, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 129
ORDER: Innovatus's unopposed request for an administrative stay is granted to the following extent. Innovatus has until 5:00 PM on June 10, 2021 to brief the issue of redaction of the words in the seventh through twelfth lines of the third paragraph of MV Realty's May 2, 2021 Letter, starting with "only through October" and ending with in its approach". Its briefing must define what in that part deserves protection from disclosure, how its disclosure would benefit its competitors, and must articulate the specific reasons for nondisclosure of the information by facts, rather than epithets and generalities. (Signed by Judge Louis L. Stanton on 6/1/2021) (rro)
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| Filing 128 LETTER MOTION to Stay addressed to Judge Louis L. Stanton from Michael H. McGinley dated May 28, 2021. Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #127 MOTION for Ryan M. Moore to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24594159. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 127 MOTION for Ryan M. Moore to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24594159. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Declaration of Ryan M. Moore, #2 Moore PA Good Standing Certificate, #3 Text of Proposed Order).(Moore, Ryan) |
| Filing 126 LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 125 ***SELECTED PARTIES*** LETTER MOTION for Conference Regarding Innovatus' Refusal to Comply with the Court's Orders of February 11, 2021 and March 23, 2021 addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC.Motion or Order to File Under Seal: #124 .(Raofield, Jason) |
| Filing 124 LETTER MOTION to Seal MV Realty Parties' May 24, 2021 Letter Seeking a Pre-Motion Conference addressed to Judge Louis L. Stanton from Jason Raofield dated May 24, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 123
MEMO ENDORSEMENT granting #122 Motion to Amend/Correct #122 CONSENT MOTION to Amend/Correct #110 Order on Motion to Amend/Correct . ENDORSEMENT: SO ORDERED. (Signed by Judge Louis L. Stanton on 4/29/2021) (rro)
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| Set/Reset Deadlines: ( Fact Discovery due by 9/15/2021.), Set/Reset Hearings:( Status Conference set for 9/17/2021 at 02:30 PM before Judge Louis L. Stanton.) (rro) |
| Filing 122 CONSENT MOTION to Amend/Correct #110 Order on Motion to Amend/Correct . Document filed by Innovatus Capital Partners, LLC..(McGinley, Michael) |
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Filing 121
ORDER ADMITTING ROGER A. DIXON PRO HAC VICE granting #118 Motion for Roger A. Dixon to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 4/13/2021) (nb)
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Filing 120
ORDER ADMITTING MICHAEL H. MCGINLEY PRO HAC VICE granting #117 Motion for MICHAEL H. MCGINLEY to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 4/13/2021) (nb)
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Filing 119
ORDER ADMITTING SELBY P. BROWN PRO HAC VICE granting #116 Motion for Selby P. Brown to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 4/7/2021) (nb)
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| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #118 MOTION for Roger A. Dixon to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number BNYSDC-24334695. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) |
| Filing 118 MOTION for Roger A. Dixon to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number BNYSDC-24334695. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Declaration of Roger A. Dixon In Support of Pro Hac Vice Motion, #2 Text of Proposed Order).(Dixon, Roger) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #117 MOTION for Michael H. McGinley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24328089. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) |
| Filing 117 MOTION for Michael H. McGinley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24328089. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Declaration of Michael H. McGinley, #2 Exhibit McGinley PA COGS, #3 Exhibit McGinley DC COGS, #4 Text of Proposed Order).(McGinley, Michael) |
| Filing 116 MOTION for Selby P. Brown to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24291667. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Declaration of Selby P. Brown In Support of Pro Hac Vice Motion, #2 Certificate of Good Standing, #3 Text of Proposed Order).(Brown, Selby) |
| Filing 115 NOTICE OF APPEARANCE by Kaitlyn Walsh on behalf of Innovatus Capital Partners, LLC..(Walsh, Kaitlyn) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #116 MOTION for Selby P. Brown to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24291667. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 114 MOTION for Steven B. Feirson to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24288038. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Affirmation of Steven B. Feirson In support of Pro Hac Vice Motion, #2 Certificate of Good Standing, #3 Text of Proposed Order).(Feirson, Steven) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #114 MOTION for Steven B. Feirson to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24288038. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| Filing 113 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated March 8, 2021 re: #112 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Edward P. Grosz dated March 3, 2021. . Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A - Innovatus RFA Responses, #2 Exhibit B - Defs Third Set of Interrogatories, #3 Exhibit C - Kailas Email re RealTrends Subpoena, #4 Exhibit D - Kailas Email re Cantrell Subpoena).(Raofield, Jason) |
| Filing 112 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Edward P. Grosz dated March 3, 2021. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit January 13, 2021 Letter from Counsel for the MV Realty Parties, #2 Exhibit Responses and Objections of Stifel, #3 Exhibit Responses and Objections of Realty Holdings, #4 Exhibit Pages from Summary Judgment Brief of the MV Realty Parties).(Grosz, Edward) |
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Filing 110
MEMO ENDORSEMENT granting #109 Motion to Amend/Correct. ENDORSEMENT:SO ORDERED this 18th Day of February 2021. Status Conference Sept. 17, 2021 at 2:30pm. (Signed by Judge Louis L. Stanton on 2/18/2021) (nb)
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| Filing 109 CONSENT MOTION to Amend/Correct #69 Order on Motion to Amend/Correct . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 111
ORDER granting #94 Letter Motion to Seal. With respect to Counsels' recent letters to the Court on sealing (Jan. 19, 2021 and Jan. 21, 2021). The two exhibits may be sealed in toto. The Jan. 19, 2021 letter must be unredacted and unsealed. In case no. 18 cv 4252, the Clerk of the Court is directed to modify the viewing level for sealed doc. 134 and 134-1 (The two letters) to public. Sealed Doc. 134 - 2 (Ex. A) and 134 - 3 (Ex. B) is to remain under seal under Selected Parties viewing level. In case no. 18 cv 7142, the Clerk of the Court is directed to modify the viewing level for sealed doc. 95 and 95 - 1 (The two letters) to public. Sealed Doc. 95 - 2 (Ex. A) and 95 - 3 (Ex. B) is to remain under seal under Selected Parties viewing level. (Signed by Judge Louis L. Stanton on 2/12/2021) (nb)
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Filing 108
MEMORANDUM OPINION & ORDER: Accordingly, each party must reveal the degree, if any, it has used that material, and whether it is still doing so. That will furnish a pragmatic basis on which the value, experiences, utility and profitability of that method can be discussed and judged. The parties and Counsel must follow that path. Failure to do so produces not illumination, but abstract argument, debate and rhetoric, which retards preparation of the case, yet increases the expense in doing so. So ordered. (Signed by Judge Louis L. Stanton on 2/11/2021) (nb)
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| Filing 107 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 9, 2021 re: Pre-motion Letters Filed on January 13, 2021 and February 4, 2021. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 106 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated February 9, 2021 re: Response to Letter dated February 8, 2021 Regarding Request for a Pre-Motion Conference. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 105 LETTER REPLY to Response to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 8, 2021 re: #103 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 4, 2021. Reply to the February 5, 2021 letter from Innovatus at Dkt. No. 104. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 104 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated February 5, 2021 re: Response to Letter dated February 4, 2021 Requesting a Pre-Motion Discovery Conference. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 103 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 4, 2021. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A: Innovatus Initial Disclosures, #2 Exhibit B: Innovatus RFA Responses).(Raofield, Jason) |
| Filing 102 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 4, 2021. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A: Innovatus Initial Disclosures, #2 Exhibit B: Innovatus RFA Responses).(Raofield, Jason) |
| Filing 101 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 27, 2021 re: Response to Innovatus' January 26, 2021 letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 100 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 26, 2021 re: Response to Letter dated January 25, 2021. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 99 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 25, 2021 re: Response to Innovatus' surreply letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 98 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 25, 2021 re: Response to Letter dated January 21, 2021 Letter Regarding Request for Pre-Motion Conferene. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 97 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 21, 2021 re: Reply to Innovatus' January 19, 2021 letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 96 LETTER RESPONSE to Motion addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 21, 2021 re: #94 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 19, 2021. . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 95 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 19, 2021 re: Motion to Seal Letter to Judge Stanton Dated January 19, 2021. Document filed by All Plaintiffs. (Attachments: #1 Exhibit Unredacted Letter to Judge Stanton dated January 19, 2021, #2 Exhibit Unredacted Exhibit A to Letter to Judge Stanton dated January 19, 2021, #3 Exhibit Unredacted Exhibit B to Letter to Judge Stanton dated January 19, 2021)Motion or Order to File Under Seal: #94 .(Grosz, Edward) |
| Filing 94 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 19, 2021. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Redacted Letter to Judge Stanton dated January 19, 2021, #2 Exhibit Redacted Exhibit A to Letter to Judge Stanton dated January 19, 2021, #3 Exhibit Redacted Exhibit B to Letter to Judge Stanton dated January 19, 2021).(Grosz, Edward) |
| Filing 93 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated January 19, 2021 re: Response to Letter dated January 13, 2021 Requesting a Pre-Motion Conference. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit, #2 Exhibit).(Grosz, Edward) |
| Filing 92 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated January 13, 2021 re: Request for Pre-Motion Conference. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 91
MEMORANDUM OPINION & ORDER re: (98 in 1:18-cv-04252-LLS) MOTION for Summary Judgment filed by Amanda Zachman, Greg Williams, Antony Mitchell, Jonathan Neuman, Daryl Clark, Ritz Advisors, LLC. Innovatus's claim for an injunction enforcing the restrictive covenant in the NDA is dismissed. Its entitlement to recompense for its contributions, to the extent that they have benefitted the enterprise, is still to be evaluated. So ordered. (Signed by Judge Louis L. Stanton on 12/23/2020) (rro) Modified on 1/15/2021 (rro).
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| Filing 90 NOTICE OF APPEARANCE by Brett Van Benthysen on behalf of Innovatus Capital Partners, LLC..(Van Benthysen, Brett) |
| Filing 89 ENDORSED LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated 12/4/2020 re: requests that the Court permit Innovatus to file unredacted documents. ENDORSEMENT: Granted. (Signed by Judge Louis L. Stanton on 12/9/2020) (rro) |
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Filing 88
STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel for the parties as follows: The time for Innovatus Capital Partners, LLC to serve its opposition papers with respect to Defendants' Motion shall be extended from November 12, 2020 to November 17, 2020. The time for Defendants to serve reply papers with respect to the Motion shall be extended from November 30, 2020 to December 8, 2020. A facsimile or scanned copy of this stipulation containing the signatures of counsel for the parties shall be deemed an original. SO ORDERED. (Signed by Judge Louis L. Stanton on 11/6/2020) (rro)
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Filing 87
STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel for the parties as follows: Innovatus Capital Partners, LLC shall serve its opposition papers with respect to Defendants' Motion on or before November 12, 2020. Defendants shall serve reply papers with respect to the Defendants' Motion on or before November 30, 2020. SO ORDERED. (Signed by Judge Louis L. Stanton on 10/15/2020) (rro)
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| Filing 86 DECLARATION of Joseph Schottland in Support re: #78 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated August 28, 2020.. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Interrogatories Redacted in Accordance with Judge Stanton's Order dated September 2, 2020).(Grosz, Edward) |
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Filing 85
ORDER: The issues raised in counsels' July 31, August 24, August 27, August 31, and September 1 letters are disposed of as follows: MV Realty has leave to make a single motion for summary judgment on any and all grounds available to it without a pre-motion conference. To the extent MV Realty requests a stay, the request is denied. After a careful item- by- item consideration by the Court, all items listed by Innovatus in the Schottland Declaration verified July 24, 2020 must be unsealed and publicly filed without redactions, with the exceptions of INNOV0000087, INNOV0000089, INNOV0000096-0000097, INNOV0000102, INNOV0000718-0000730, INNOV0003959-0003960, which may be redacted from the public file. The penultimate sentence in the paragraph continuing on page 13 of that Declaration may redact three words, so it reads, "The [XXX] came from Innovatus." (Signed by Judge Louis L. Stanton on 9/2/2020) (rro)
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| Filing 84 ***SELECTED PARTIES*** LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated September 2, 2020 re: Exhibits Discussed in August 31, 2020 Letter. Document filed by MV Realty PBC, LLC, Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit INNOV0000001 - 0000004, #2 Exhibit INNOV0000005 - 0000008)Motion or Order to File Under Seal: #83 .(Raofield, Jason) |
| Filing 83 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Jason C. Raofield dated September 2, 2020. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 82 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated September 1, 2020 re: Innovatus' August 27, 2020 Letter Response at ECF Dkt. No. 88. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 81 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated August 31, 2020 re: Request for Leave to Seek Summary Judgment. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 80 ***SELECTED PARTIES***DECLARATION of Joseph Schottland in Support re: #78 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated August 28, 2020.. Document filed by Innovatus Capital Partners, LLC, MV Realty PBC, LLC. (Attachments: #1 Exhibit Highlighted Copy of Interrogatory Responses Showing Proposed Redactions)Motion or Order to File Under Seal: #78 .(Grosz, Edward) |
| Filing 79 DECLARATION of Joseph Schottland in Support re: #78 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated August 28, 2020.. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Redacted Copy of Interrogatory Responses).(Grosz, Edward) |
| Filing 78 LETTER MOTION to Seal addressed to Judge Louis L. Stanton from Edward P. Grosz dated August 28, 2020. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 77 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated August 27, 2020 re: Request for Pre-Motion Conference and Stay. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit E-Mail and Memorandu, #2 Exhibit Redacted Interrogatory Responses).(Grosz, Edward) |
| Filing 76 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated August 24, 2020 re: Reply to July 31, 2020 Pre-Motion Letter. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 75 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated July 31, 2020 re: Request for Pre-Motion Conference. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 74
ORDER: The issues raised in counsel's letters to the Court of May 18, June 3 and 18 (Covington) and May 22 and June 8 (Reitler) are resolved as follows: All discovery by Innovatus is stayed until 10 days after it submits to MV Realty the definition of confidential material required by the May 28, 2020 Order. MV Realty may proceed with discovery directed to the issue of entry by others into RTL ("Right to List") agreements, particularly as related to the issue whether knowledge of such agreements was "generally available in the public" (NDA Article II). So ordered. (Signed by Judge Louis L. Stanton on 6/22/2020) (rro) Modified on 6/29/2020 (rro).
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| Filing 73 SUPPLEMENTAL LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C Raofield dated 6/18/2020. Document filed by MV Realty PBC, LLC..(Brennan, Margaret) |
| Filing 72 LETTER addressed to Judge Louis L. Stanton from Leo G. Kailas dated June 8, 2020 re: Response to Letter dated June 3, 2020 Regarding Request for Pre-Motion Conference. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Second Set of Interrogatories Served on Innovatus).(Grosz, Edward) |
| Filing 71 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated June 3, 2020 re: New Information Relevant to 5/18/20 Letter Requesting Pre-Motion Conference. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 70
ORDER re: (70 in 1:18-cv-04252-LLS): The issue raised by MV Realty's counsel's letter to the Court dated April 27, 2020, which has been the subject of various applications, inquiries, and discovery processes by MV Realty and evasions by Innovatus for years, is overdue for resolution. It is time for Innovatus to furnish the defendants in the case it brought with a clear, meaningful and reliable statement defining the confidential information it claims to have provided to those defendants. That requires separating what is confidential from what is not. For example, it would be hard to maintain that the language used in the RTL agreement is confidential since it is disclosed to every buyer who signs the agreement and is free to discuss it with others. But there may be confidential reasons why those particular words were used: those reasons must be specified (which may be done privately under the litigation's confidentiality agreement) if they are to be part of the claimed Confidentiality Information.The statement must be comprehensive. It must disclose each item and element of the Business Opportunity and, with specificity, every other item of information claimed to be confidential. Whatever is not set forth cannot later be claimedto have been confidential. Terms of reservation such as "among others" or of a right to supplement are unacceptable: they destroy the purpose of having a complete list, render the statement ineffective, and subject any claim based onConfidential Information to dismissal. (Signed by Judge Louis L. Stanton on 5/28/2020) (ml)
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Filing 69
MEMO ENDORSED ORDER granting #68 Motion to Amend/Correct #55 Order on Motion to Amend/Correct. ENDORSEMENT: SO ORDERED. (Signed by Judge Louis L. Stanton on 5/27/20) (yv)
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| Set/Reset Deadlines: Fact Discovery due by 3/3/2021. (yv) |
| Filing 68 CONSENT MOTION to Amend/Correct #55 Order on Motion to Amend/Correct . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 67 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated May 22, 2020 re: Response to Second Request for Pre-Motion Discovery Conference. Document filed by Innovatus Capital Partners, LLC..(Grosz, Edward) |
| Filing 66 ANSWER to #60 Counterclaim. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 65 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Louis L. Stanton from Jason C. Raofield dated May 18, 2020. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 64
PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Louis L. Stanton on 5/11/2020) (rro)
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| Filing 63 PROPOSED PROTECTIVE ORDER. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Filing 62 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated May 4, 2020 re: Corrected Response to Request for Pre-Motion Discovery Conference. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Local Rule 56.1 Statement in MV Comms. Case, #2 Exhibit Response to Local Rule 56.1 Statement in Next Comms. Case).(Grosz, Edward) |
| Filing 61 LETTER addressed to Judge Louis L. Stanton from Edward P. Grosz dated May 4, 2020 re: Request by Defendants for a Pre-Motion Discovery Conference. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Exhibit Local Rule 56.1 Statement in Next Comms. Case, #2 Exhibit Response to Local Rule 56.1 Statement in Next Comms. Case).(Grosz, Edward) |
| Filing 60 ANSWER to #52 Amended Complaint,,., COUNTERCLAIM against MV Realty PBC, LLC. Document filed by Innovatus Capital Partners, LLC. (Attachments: #1 Counterclaims).(Grosz, Edward) |
| Filing 59 ORDE GRANTING MOTION FOR ADMISSION PRO HAC VICE granting #58 Motion for Margaret H. Brennan to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 4/27/2020) (rro) |
| Filing 58 MOTION for Margaret H. Brennan to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-19408047. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration in Support of Motion, #2 DC Certificate of Good Standing, #3 CA Certificate of Good Standing, #4 Text of Proposed Order).(Brennan, Margaret) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #58 MOTION for Margaret H. Brennan to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-19408047. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (laq) |
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Filing 57
MEMO ENDORSEMENT on re: (56 in 1:18-cv-07142-LLS) Letter filed by MV Realty PBC, LLC. ENDORSEMENT: So Ordered. Attorney Ravi Doshi terminated. (Signed by Judge Louis L. Stanton on 4/9/2020) (rro)
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| Filing 56 LETTER addressed to Judge Louis L. Stanton from Ravi Doshi dated April 9, 2020 re: Withdrawal of Attorney. Document filed by MV Realty PBC, LLC..(Doshi, Ravi) |
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Filing 55
MEMO ENDORSEMENT granting #54 Motion to Amend/Correct. ENDORSEMENT: SO ORDERED. (Signed by Judge Louis L. Stanton on 3/23/2020) (rro)
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| Filing 54 CONSENT MOTION to Amend/Correct #51 Scheduling Order,,, . Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
| Set/Reset Deadlines: Fact Discovery due by 1/20/2021.), Set/Reset Hearings:( Status Conference set for 1/29/2021 at 12:00 PM before Judge Louis L. Stanton.) (rro) Modified on 3/24/2020 (rro). |
| Filing 53 Costs Taxed as to #45 USCA Mandate, USCA Case Number 18-3671(L), 18-3676(CON). in the amount of $1,916.20. on 03/12/2020 in favor of Innovatus Capital Partners, LLC, Plaintiff - Counter - Defendant - Appellant, against Daryl Clark, Ritz Advisors LLC, Antony Mitchell, Amanda Zachman, Jonathan Neuman, Greg Williams, Defendants - Counter - Claimants - Appellees..(nd) |
| Filing 52 AMENDED COMPLAINT amending #1 Complaint,, against Innovatus Capital Partners, LLC.Document filed by MV Realty PBC, LLC. Related document: #1 Complaint,,. (Attachments: #1 Exhibit 1 - August 24, 2017 NDA and Term Sheet, #2 Exhibit 2 - RTL Agreement, #3 Exhibit 3 - Joinder Agreement, #4 Exhibit 4 - Zachman NDA, #5 Exhibit 5 - Williams NDA, #6 Exhibit 6 - Clark NDA, #7 Exhibit 7 - Innovatus Complaint, #8 Exhibit 8 - Ashenmil Patent, #9 Exhibit 9 - Harrington Patent).(Raofield, Jason) |
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Filing 51
SCHEDULING ORDER: This proposed Scheduling Order addresses two related actions. Amended pleadings are to be filed by March 6, 2020, with answers to amended pleadings due March 30, 2020, and answers to counterclaims due April 22, 2020. All fact discovery shall be completed by November 20, 2020. At this time, the parties anticipate deposing the following witnesses: and further set forth in this Order.Status conference at 12 noon on Friday, Dec. 4, 2020 re when to file Joint Pretrial Order. The parties anticipate that the trial will take 5-10 days.The parties anticipate that all claims will be tried to the Court. (Amended Pleadings due by 3/6/2020. Fact Discovery due by 11/20/2020. Status Conference set for 12/4/2020 at 12:00 PM before Judge Louis L. Stanton.) (Signed by Judge Louis L. Stanton on 2/21/2020) (rro)
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Filing 50
ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE granting #49 Motion for Ravi Doshi to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 2/21/2020) (rro)
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| Minute Entry for proceedings held before Judge Louis L. Stanton: Initial Pretrial Conference held on 2/21/2020. (Court Reporter Martha Martin) (ml) |
| Filing 49 MOTION for Ravi Doshi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-18867665. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration of Ravi Doshi in Support, #2 DC Certificate of Good Standing, #3 CA Certificate of Good Standing, #4 Text of Proposed Order).(Doshi, Ravi) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #49 MOTION for Ravi Doshi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-18867665. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) |
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Filing 48
MEMO ENDORSEMENT on re: #47 Letter filed by MV Realty PBC, LLC. ENDORSEMENT: So ordered. Attorney Nishchay H. Maskay terminated. (Signed by Judge Louis L. Stanton on 2/19/2020) (mro)
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| Filing 47 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated February 18, 2020 re: Withdrawal of Appearance of Nishchay Maskay. Document filed by MV Realty PBC, LLC..(Raofield, Jason) |
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Filing 46
ORDER FOR CONFERENCE PURSUANT TO RULE 16(b): Initial Conference set for 2/21/2020 at 12:00 PM in Courtroom 21C, 500 Pearl Street, New York, NY 10007 before Judge Louis L. Stanton and further set forth this Order. (Signed by Judge Louis L. Stanton on 1/23/2020) (rro)
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| Filing 45 MANDATE of USCA (Certified Copy) as to #33 Notice of Appeal, filed by Innovatus Capital Partners, LLC. USCA Case Number 18-3671. UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgments of the district court are REVERSED and REMANDED for proceedings consistent with this order. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 01/22/2020. (nd) |
| Transmission of USCA Mandate to the District Judge re: #45 USCA Mandate,. (nd) |
| Filing 44 TRUE COPY ORDER of USCA as to #33 Notice of Appeal, filed by Innovatus Capital Partners, LLC. USCA Case Number 18-3671. UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgments of the district court are REVERSED and REMANDED. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Certified: 12/30/2019. (nd) |
| Transmission of USCA Order to the District Judge re: #44 USCA Order,. (nd) |
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Filing 43
ORDER granting [52 in 18cv4252 LLS] Motion to Withdraw as Attorney. IT IS SO ORDERED. Attorney Peter R. Jerdee terminated. (Signed by Judge Louis L. Stanton on 12/11/2018) (jca)
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Filing 42
ORDER granting [53 in 18cv4252 LLS] Motion to Withdraw as Attorney. IT IS SO ORDERED. Attorney Samuel Neil Fraidin terminated. (Signed by Judge Louis L. Stanton on 12/11/2018) (jca)
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Filing 41
ORDER granting [51 in 18cv4252 LLS] Motion to Withdraw as Attorney. IT IS SO ORDERED. Attorney Gregory P. Joseph terminated. (Signed by Judge Louis L. Stanton on 12/11/2018) (jca)
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| Filing 40 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERNECE proceeding held on 8/7/18 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 39 TRANSCRIPT of Proceedings re: CONFERENCE held on 8/7/2018 before Judge Louis L. Stanton. Court Reporter/Transcriber: Jerry Harrison, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 1/2/2019. Redacted Transcript Deadline set for 1/14/2019. Release of Transcript Restriction set for 3/12/2019.(McGuirk, Kelly) |
| Filing 38 MOTION for Samuel N. Fraidin to Withdraw as Attorney . Document filed by Innovatus Capital Partners, LLC.(Fraidin, Samuel) |
| Filing 37 MOTION for Peter R. Jerdee to Withdraw as Attorney . Document filed by Innovatus Capital Partners, LLC.(Jerdee, Peter) |
| Filing 36 MOTION for Gregory P. Joseph to Withdraw as Attorney . Document filed by Innovatus Capital Partners, LLC.(Joseph, Gregory) |
| Filing 35 FINAL ORDER AND JUDGMENT: For the reasons stated in the Court's Opinion and Order of November 7, 2018, Final Judgment is hereby awarded in favor ofMV Realty on MV Realty's Complaint. Innovatus shall take nothing, and is not entitled to relief on its Counterclaims. This Final Order and Judgment shall incorporate the findings, conclusions, and rulings in all orders and memoranda of decision in this case. The Clerk of Court is directed to close this case. SO ORDERED. (rro) |
| Transmission of Notice of Appeal and Certified Copy of Docket Sheet to US Court of Appeals re: #33 Notice of Appeal. (tp) |
| Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files for #33 Notice of Appeal, filed by Innovatus Capital Partners, LLC were transmitted to the U.S. Court of Appeals. (tp) |
| Filing 34 NOTICE OF APPEARANCE by Edward Peter Grosz on behalf of Innovatus Capital Partners, LLC. (Grosz, Edward) |
| Filing 33 NOTICE OF APPEAL from #30 Order on Motion for Judgment on the Pleadings,,,, Order on Motion to Dismiss,,,. Document filed by Innovatus Capital Partners, LLC. Filing fee $ 505.00, receipt number ANYSDC-16022991. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit. (Grosz, Edward) |
| Filing 32 PROPOSED JUDGMENT. Re: Document No. #31 Notice of Settlement. Document filed by MV Realty PBC, LLC. (Raofield, Jason) Proposed Judgment to be reviewed by Clerk's Office staff. |
| Filing 31 NOTICE of Settlement of Judgment. Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| ***NOTICE TO COURT REGARDING PROPOSED JUDGMENT. Document No. #32 Proposed Judgment was reviewed and approved as to form. (km) |
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Filing 30
OPINION & ORDER with respect to #16 Motion for Judgment on the Pleadings; with respect to #19 Motion to Dismiss: MV is free to engage in the RTL business as such, without securitization, but in doing so it may not utilize or disclose materials or techniques not otherwise in general use, proprietary to Innovatus, and furnished by it to MV in confidence.That disposes of all points in the submissions of the parties in Plaintiff's motion for judgment on the pleadings in the case 18 Civ. 7142 (0kt. No. 16), Plaintiff's motion to dismiss counterclaims in the case 18 Civ. 7142 (0kt. No. 19), and Defendant's motion for judgment on the pleadings in the case 18 Civ. 4252 (Dkt. No. 37), and denies those arguments inconsistent with the foregoing dispositions. (Signed by Judge Louis L. Stanton on 11/7/2018) (ml)
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| Filing 29 REPLY MEMORANDUM OF LAW in Support re: #19 MOTION to Dismiss Counterclaims. . Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| Filing 28 REPLY MEMORANDUM OF LAW in Support re: #16 MOTION for Judgment on the Pleadings . . Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| Filing 27 RESPONSE in Opposition to Motion re: #19 MOTION to Dismiss Counterclaims. . Document filed by Innovatus Capital Partners, LLC. (Joseph, Gregory) |
| Filing 26 RESPONSE in Opposition to Motion re: #16 MOTION for Judgment on the Pleadings . . Document filed by Innovatus Capital Partners, LLC. (Joseph, Gregory) |
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Filing 25
STIPULATION AND ORDER: Innovatus shall have until October 22, 2018, to file answering papers with respect to MV Realty's motions pursuant to Federal Rules 12(b)(6) and 12(c) in the MV Realty Action and Defendants' motion pursuant to Federal Rule 12(c) in the Innovatus Action. MV Realty shall have until November 5, 2018, to file reply papers with respect to its motions pursuant to Federal Rules 12(b)(6) and 12(c) in the MV Realty Action, and Defendants in the Innovatus Action shall have until November 5, 2018 to file reply papers with respect to their motion pursuant to Federal Rule 12(c). SO ORDERED Set Deadlines/Hearing as to #19 MOTION to Dismiss Counterclaims., #16 MOTION for Judgment on the Pleadings. (Responses due by 10/22/2018, Replies due by 11/5/2018.) (Signed by Judge Louis L. Stanton on 10/4/2018) (rro)
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| Filing 24 PROPOSED SCHEDULING ORDER. Document filed by Innovatus Capital Partners, LLC. (Jerdee, Peter) |
| Filing 23 LETTER addressed to Judge Louis L. Stanton from Jason C. Raofield dated September 28, 2018 re: the Court's Letter dated September 7, 2018. Document filed by MV Realty PBC, LLC.(Raofield, Jason) |
| Filing 22 NOTICE OF CHANGE OF ADDRESS by Jason Raofield on behalf of MV Realty PBC, LLC. New Address: Covington & Burling LLP, 850 Tenth Street, NW, Washington, DC, 20001, 202-662-5072. (Raofield, Jason) |
| Filing 21 DECLARATION of Jason C. Raofield in Support re: #19 MOTION to Dismiss Counterclaims.. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit A - Proposed Scheduling Order, #2 Exhibit B - Transcript of August 10, 2018 Hearing)(Raofield, Jason) |
| Filing 20 MEMORANDUM OF LAW in Support re: #19 MOTION to Dismiss Counterclaims. . Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| Filing 19 MOTION to Dismiss Counterclaims. Document filed by MV Realty PBC, LLC.(Raofield, Jason) |
| Filing 18 DECLARATION of Jason C. Raofield in Support re: #16 MOTION for Judgment on the Pleadings .. Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit 1 - Non-Disclosure Agreement)(Raofield, Jason) |
| Filing 17 MEMORANDUM OF LAW in Support re: #16 MOTION for Judgment on the Pleadings . . Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| Filing 16 MOTION for Judgment on the Pleadings . Document filed by MV Realty PBC, LLC.(Raofield, Jason) |
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Filing 15
STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel, and subject to the approval of the Court, that: MV Realty shall have until September 24, 2018, to answer or otherwise respond to Innovatus' s Counterclaim. Although no deadline has been established for doing so, on or before September 24, 2018, MV Realty will also file a motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c) with respect to the claim in MV Realty's Complaint. SO ORDERED. (MV Realty PBC, LLC answer due 9/24/2018.)( Motions due by 9/24/2018.) (Signed by Judge Louis L. Stanton on 9/14/2018) (anc)
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| Filing 14 PROPOSED STIPULATION AND ORDER. Document filed by MV Realty PBC, LLC. (Maskay, Nishchay) |
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Filing 13
ORDER GRANTING ADMISSION PRO HAC VICE granting #9 Motion for Nishchay H. Maskay to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 9/11/2018) (jwh)
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| Filing 12 NOTICE OF APPEARANCE by Samuel Neil Fraidin on behalf of Innovatus Capital Partners, LLC. (Fraidin, Samuel) |
| Filing 11 NOTICE OF APPEARANCE by Peter R. Jerdee on behalf of Innovatus Capital Partners, LLC. (Jerdee, Peter) |
| Filing 10 ANSWER to #1 Complaint,,., COUNTERCLAIM against MV Realty PBC, LLC. Document filed by Innovatus Capital Partners, LLC.(Joseph, Gregory) |
| Filing 9 MOTION for Nishchay H. Maskay to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-15497280. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Declaration of Nishchay H. Maskay, #2 DC Certificate of Good Standing, #3 VA Certificate of Good Standing, #4 Proposed Order)(Maskay, Nishchay) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #9 MOTION for Nishchay H. Maskay to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-15497280. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (ma) |
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Filing 8
ORDER GRANTING ADMISSION PRO HAC VICE granting #6 Motion for Jason C. Raofield to Appear Pro Hac Vice. (Signed by Judge Louis L. Stanton on 8/10/2018) (ne)
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| Filing 7 ELECTRONIC SUMMONS ISSUED as to Innovatus Capital Partners, LLC. (pne) |
| Case Designated ECF. (pne) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #6 MOTION for Jason C. Raofield to Appear Pro Hac Vice as Counsel for Plaintiff. Filing fee $ 200.00, receipt number 0208-15425973. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) |
| CASE REFERRED TO Judge Louis L. Stanton as possibly related to 18CV4252. (pne) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. (pne) |
| NOTICE OF CASE REASSIGNMENT to Judge Louis L. Stanton. Judge Unassigned is no longer assigned to the case. (wb) |
| CASE ACCEPTED AS RELATED. Create association to 1:18-cv-04252-LLS. Notice of Assignment to follow. (wb) |
| Magistrate Judge Sarah Netburn 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. (wb) |
| Filing 6 MOTION for Jason C. Raofield to Appear Pro Hac Vice as Counsel for Plaintiff. Filing fee $ 200.00, receipt number 0208-15425973. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MV Realty PBC, LLC. (Attachments: #1 Certificate of Good Standing, #2 Proposed Order, #3 Declaration of Jason C. Raofield)(Raofield, Jason) |
| Filing 5 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by MV Realty PBC, LLC.(Raofield, Jason) |
| Filing 4 REQUEST FOR ISSUANCE OF SUMMONS as to Innovatus Capital Partners, LLC, re: #1 Complaint,,. Document filed by MV Realty PBC, LLC. (Raofield, Jason) |
| Filing 3 STATEMENT OF RELATEDNESS re: that this action be filed as related to 18-CV-04252. Document filed by MV Realty PBC, LLC.(Raofield, Jason) |
| Filing 2 CIVIL COVER SHEET filed. (Raofield, Jason) |
| Filing 1 COMPLAINT against Innovatus Capital Partners, LLC. (Filing Fee $ 400.00, Receipt Number 0208-15425871)Document filed by MV Realty PBC, LLC. (Attachments: #1 Exhibit 1 - NDA and Term Sheet, #2 Exhibit 2 - RTL Agreement, #3 Exhibit 3 - Proposed Joinder to NDA, #4 Exhibit 4 - Harrington Patent, #5 Exhibit 5 - NDA (Zachman), #6 Exhibit 6 - NDA (Williams), #7 Exhibit 7 - NDA (Clark), #8 Exhibit 8 - Innovatus Complaint, #9 Exhibit 9 - Correspondence Between Counsel)(Raofield, Jason) |
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