Goldfarb v. Channel One Russia et al
| RT America |
| Channel One Russia |
| Alex Goldfarb |
| 1:2018cv08128 |
| September 6, 2018 |
| US District Court for the Southern District of New York |
| Deborah A Batts |
| Valerie E Caproni |
| John Peter Cronan |
| John P Cronan |
| Assault Libel & Slander |
| 28 U.S.C. § 1332 lb Diversity-Libel, Assault, Slander |
| Plaintiff |
Docket Report
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FIRST MEDIATION CONFERENCE. Mediation Conference scheduled for 12/13/2023 at 11:00 AM in Mediator's Office.(sge)
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NOTICE OF MEDIATOR ASSIGNMENT - Notice of assignment of mediator. Mediator Schedule due by 11/22/2023.(sge)
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Filing 159
MEDIATION REFERRAL ORDER: It is hereby ORDERED that this case is referred for mediation to the Court-annexed Mediation Program. The parties are notified that Local Rule 83.9 shall govern the mediation and are directed to participate in the mediation in good faith. The mediation will have no effect upon any scheduling Order issued by this Court. SO ORDERED. Please reference the following when corresponding with the Mediation Office. E-mail MediationOffice@nysd.uscourts.gov, telephone (212) 805-0643, and facsimile (212) 805-0647. Mediator to be Assigned by 10/26/2023. (Signed by Judge John P. Cronan on 10/12/2023) (jca)
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Filing 158
SCHEDULING ORDER: As discussed at a conference held earlier today, trial in this matter is adjourned from December 11, 2023 to March 11, 2024. All deadlines from the Court's prior pre-trial scheduling order, Dkt. 150, are adjourned and amended as follows. The parties are ordered to appear at 10:00 a.m. on March 6, 2024 for a final pretrial conference to be held in Courtroom 12D of the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007. The final pretrial conference must be attended by the attorneys who will serve as principal trial counsel. By January 15, 2024, the parties shall submit the pretrial filings required under Rule 7, subparts B, D, and E, of the Court's Individual Rules and Practices in Civil Cases ("Individual Rules"). Any opposition to a motion in limine or response to a pretrial memorandum of law shall be submitted by January 29, 2024. The Court lifts the requirement for the submission of physical copies of documentary exhibits under Rule 7.F of its Individual Rules. Instead, and unless otherwise ordered, each party shall submit a thumb drive containing electronic copies of any documentary exhibits that it seeks to admit a trial. Rule 7.E.i of the Court's Individual Rules also will not apply at this trial. Instead, the Court will receive all testimony via live witness testimony, except for testimony by deposition if appropriate under Federal Rule of Civil Procedure 32. SO ORDERED. Responses due by 1/29/2024 Final Pretrial Conference set for 3/6/2024 at 10:00 AM in Courtroom 12D, 500 Pearl Street, New York, NY 10007 before Judge John P. Cronan. Ready for Trial by 3/11/2024. (Signed by Judge John P. Cronan on 10/12/2023) (jca)
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Minute Entry for proceedings held before Judge John P. Cronan: Telephone Conference held on October 12, 2023. The Court held a conference a status conference. Trial is adjourned, and shall now begin on March 11, 2024, with a final pretrial conference scheduled for March 6, 2024, at 10:00 a.m. The Court will separately enter an order setting amended deadlines for pre-trial filings. (Court reporter Carol Ganley). (mhe)
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Filing 157
ORDER The telephone conference scheduled for October 12, 2023 at 3:30 p.m. is rescheduled to October 12, 2023 at 12:00 p.m. At the scheduled time, all parties should call 866-434-5269, access code 9176261. ( Telephone Conference set for 10/12/2023 at 12:00 PM before Judge John P. Cronan.) (HEREBY ORDERED by Judge John P. Cronan) (Text Only Order) (mhe)
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Filing 156
MEMO ENDORSEMENT on re: #155 Letter filed by Alex Goldfarb ENDORSEMENT The parties shall appear for a telephonic conference on October 12, 2023, at 3:30 p.m. At the scheduled time, the parties should call (866) 434-5269, access code 9176261. The parties should be prepared to address the following topics at the conference: the witnesses each party plans to call at trial; whether any of those witnesses are unable to testify in person and, if so, what restrictions may impede their travel to New York; and which of the parties' anticipated witnesses have been deposed. SO ORDERED. (Telephone Conference set for 10/12/2023 at 03:30 PM before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 10/10/2023) (jca)
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Filing 155
JOINT LETTER addressed to Judge John P. Cronan from Bertrand C. Sellier dated October 5, 2023 re: Joint Status Letter. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 154
MEMO ENDORSEMENT on re: #153 Letter filed by Channel One Russia ENDORSEMENT The Court thanks the parties for the status update. The parties shall submit a further status letter within one week of receipt of any communications from OFAC concerning Channel One's license application, or by October 5, 2023 if no communications from OFAC have been received by that date. SO ORDERED. (Signed by Judge John P. Cronan on 9/5/2023) (jca)
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Filing 153
JOINT LETTER addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated September 1, 2023 re: Alex Goldfarb v. Channel One Russia, et al., No: 18-CV-08128 (JPC). Document filed by Channel One Russia..(Rivkin, David)
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Filing 152
MEMO ENDORSEMENT: on re: #151 Letter filed by Channel One Russia. ENDORSEMENT: The Court thanks the parties for the status update. The parties shall submit a further status letter within one week of receipt of any communications from OFAC concerning Channel One's license application, or by September 1, 2023 if no communications from OFAC have been received by that date. SO ORDERED. (Signed by Judge John P. Cronan on 7/18/2023) (ama)
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Filing 151
LETTER addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated 07/17/2023 re: Joint Status Letter. Document filed by Channel One Russia..(Rivkin, David)
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Filing 150
SCHEDULING ORDER: At a conference held on April 5, 2023, the Court scheduled trial in this case to commence on December 11, 2023, and further ordered the parties to appear at 10:00 a.m. on December 6, 2023 for a final pretrial conference to be held in Courtroom 12D of the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007. The final pretrial conference must be attended by the attorneys who will serve as principal trial counsel. The parties are further ordered, by October 16, 2023, to submit the pretrial filings required under Rule 7, subparts B, D, and E, of the Court's Individual Rules and Practices in Civil Cases. Any opposition to a motion in limine or response to a pretrial memorandum of law shall be submitted by October 30, 2023, and courtesy copies of documentary evidence shall be submitted by December 4, 2023, in accordance with Rule 7.F of the Court's Individual Rules and Practices in Civil Cases. Lastly, at the status conference held on April 6, 2023, counsel for Defendant Channel One Russia ("Channel One") explained that the testimony of various Channel One employees at trial, whether in person or remote, might be impeded by restrictions on their international travel or their transactions with U.S. entities or individuals. By July 17, 2023, the parties shall submit a joint status letter updating the Court on what progress has been made towards resolving those potential obstacles to holding trial in this case. SO ORDERED. Responses due by 10/30/2023 Final Pretrial Conference set for 12/6/2023 at 10:00 AM in Courtroom 12D, 500 Pearl Street, New York, NY 10007 before Judge John P. Cronan. Ready for Trial by 12/11/2023. (Signed by Judge John P. Cronan on 4/17/2023) (jca)
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Minute Entry for proceedings held before Judge John P. Cronan: In-person conference held on April 6, 2023. The Court scheduled trial to commence on December 11, 2023, and scheduled a final pre-trial conference for 10:00 a.m. on December 6, 2023. The Court will set further deadlines for pre-trial filings by separate order. (Court Reporter Doug Colavito). (mhe)
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Filing 149
ORDER The status conference currently scheduled for 3:00 p.m. on April 5, 2023 is hereby adjourned until 11:00 a.m. on April 6, 2023. The conference will take place in Courtroom 12D of the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007. ( Status Conference set for 4/6/2023 at 11:00 AM in Courtroom 12D, 500 Pearl Street, New York, NY 10007 before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 3/24/2023) (ate) Modified on 3/27/2023 (mhe). (Main Document 149 replaced on 3/27/2023) (mhe).
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Filing 148
OPINION AND ORDER re: #130 MOTION for Summary Judgment on All Claims filed by Channel One Russia. For the foregoing reasons, Channel One's motion for summary judgment on Goldfarb's claims is granted with respect to the statements it broadcast accusing Goldfarb of membership in the CIA, and is denied in all other respects. Channel One's motion for summary judgment on its anti-SLAPP counterclaims is likewise denied. The parties are directed to appear for a status conference at 3:00 p.m. on April 5, 2023 to discuss a trial date. The conference will take place in Courtroom 12D of the Daniel Patrick Moynihan U.S. Courthouse, 500 Pearl Street, New York, New York 10007. The Clerk of Court is respectfully directed to terminate the motion pending at Docket Number 130. SO ORDERED. ( Status Conference set for 4/5/2023 at 3:00 PM in Courtroom 12D, 500 Pearl Street, New York, NY 10007 before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 3/21/2023) (vfr)
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Filing 147
ORDER GRANTING WITHDRWAL OF APPEARANCE OF KENDALL E. WANGSGARD In accordance with Local Civil Rule 1.4, and upon consideration of the annexed declaration, Kendall E. Wangsgard of Baker & Hostetler LLP is hereby withdrawn as counsel for defendant Channel One Russia. SO ORDERED. Attorney Kendall Eugene Wangsgard terminated. (Signed by Judge John P. Cronan on 11/29/2022) (jca)
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Filing 146
DECLARATION of Kendall E. Wangsgard in Support re: #145 Proposed Order for Withdrawal of Attorney. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 145
PROPOSED ORDER FOR WITHDRAWAL OF ATTORNEY. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 144
RESPONSE re: #136 Affidavit in Opposition to Motion,, (Defendant's Response to Plaintiff's Additional Facts). Document filed by Channel One Russia..(Rivkin, David)
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Filing 143
DECLARATION of Kendall Wangsgard in Support re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Channel One Russia. (Attachments: #1 Exhibit 1-Article/Video, #2 Exhibit 2-Article at G000323-25, #3 Exhibit 3-English Language Transcripts and Pages).(Rivkin, David)
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Filing 142
REPLY MEMORANDUM OF LAW in Support re: #130 MOTION for Summary Judgment on All Claims. . Document filed by Channel One Russia..(Rivkin, David)
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Filing 141
ORDER granting #140 Letter Motion for Leave to File Excess Pages. The request is granted; Defendant may file a reply brief of up to 12 pages. SO ORDERED. (Signed by Judge John P. Cronan on 6/28/2022) (vfr)
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Filing 140
LETTER MOTION for Leave to File Excess Pages re: Reply Brief to the Motion for Summary Judgment addressed to Judge John P. Cronan from Kendall E. Wangsgard dated June 27, 2022. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 139
RESPONSE re: #131 Rule 56.1 Statement . Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 138
MEMORANDUM OF LAW in Opposition re: #130 MOTION for Summary Judgment on All Claims. . Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 137
DECLARATION of Bertrand C. Sellier in Opposition re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Alex Goldfarb. (Attachments: #1 Exhibit Ex. A - Alex Goldfarb transcript, #2 Exhibit Ex. B - Dmitry Borisov transcript, #3 Exhibit Ex. C - Natalia Nikonova transcript, #4 Exhibit Ex. D - Aleksej Pimanov transcript, #5 Exhibit Ex. E - Excerpts from Channel One Russia discovery production).(Sellier, Bertrand)
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Filing 136
AFFIDAVIT of Alex Goldfarb in Opposition re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Alex Goldfarb. (Attachments: #1 Exhibit Ex. A - Feb 2 2012 Channel One Broadcast, #2 Exhibit Ex. B - April 25 2012 Channel One Broadcast, #3 Exhibit Ex. C - Channel One Payment Records to Walter, #4 Exhibit Ex. D - BBC Report Malakhov Quarrel, #5 Exhibit Ex. E - Headlines, #6 Exhibit Ex. F - March 23 2018 Goldfarb Interview, #7 Exhibit Ex. G - US Dept. of State - Peskov, #8 Exhibit Ex. H - Inside Putin's Propaganda Machine, #9 Exhibit Ex. I - Agalakova BBC Russian Service interview, #10 Exhibit Ex. J - Carter v. Russia European Court of Human Rights decision).(Sellier, Bertrand)
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Filing 135
MEMORANDUM OF LAW in Support re: #130 MOTION for Summary Judgment on All Claims. . Document filed by Channel One Russia..(Rivkin, David)
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Filing 134
DECLARATION of Kendall Wangsgard in Support re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Channel One Russia. (Attachments: #1 Exhibit 1 - Goldfarb Excerpts, #2 Exhibit 2 - Nikonova Exerpts, #3 Exhibit 3 - Borisov Exerpts, #4 Exhibit 4 - Pimanov Exerpts, #5 Exhibit 5 - Plaintiff Interrog Responses Excerpts, #6 Exhibit 6 - Harvard Crimson Article (Dep Ex B), #7 Exhibit 7 - Blog July 29 (Dep Ex G), #8 Exhibit 8 - WAPO Op Ed (G649-G651), #9 Exhibit 9 - Deft Interrog Responses Excerpts, #10 Exhibit 10 - Blog July 25 (Dep Ex F), #11 Exhibit 11 - Show Transcript Pages (COR 147-167), #12 Exhibit 12 - Blog 2 Dec (Dep Ex J), #13 Exhibit 13 - GoFundMe Page (English), #14 Exhibit 14 - GoFundMe Home (Rus), #15 Exhibit 15 - June 19 Blog (Dep Ex E), #16 Exhibit 16 - Email re Medical Records, #17 Exhibit 17 - Show Transript (pages COR123-139), #18 Exhibit 18 - RIA Article (Jan 22 2016), #19 Exhibit 19 - TASS News Article, #20 Exhibit 20 - RT Poll Artcle, #21 Exhibit 21 - Reuters Soros Article, #22 Exhibit 22 - Embassy Press Release, #23 Exhibit 23 - Radio Liberty Article April 2021).(Rivkin, David)
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Filing 133
DECLARATION of Timur Siraziev in Support re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Channel One Russia..(Rivkin, David)
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Filing 132
DECLARATION of Larisa A. Nasonova in Support re: #130 MOTION for Summary Judgment on All Claims.. Document filed by Channel One Russia..(Rivkin, David)
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Filing 131
RULE 56.1 STATEMENT. Document filed by Channel One Russia..(Rivkin, David)
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Filing 130
MOTION for Summary Judgment on All Claims. Document filed by Channel One Russia..(Rivkin, David)
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Filing 129
LETTER MOTION for Leave to File Excess Pages re: Motion for Summary Judgment addressed to Judge John P. Cronan from Kendall E. Wangsgard dated May 24, 2022. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 128
MEMO ENDORSEMENT on re: #127 Letter filed by Channel One Russia. ENDORSEMENT: The request is granted. Defendant shall move for summary judgment by May 31, 2022, Plaintiff shall oppose by June 21, 2022, and Defendant shall reply by June 28, 2022. SO ORDERED. ( Motions due by 5/31/2022., Responses due by 6/21/2022, Replies due by 6/28/2022.) (Signed by Judge John P. Cronan on 4/20/2022) (vfr)
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Filing 127
JOINT LETTER addressed to Judge John P. Cronan from Kendall E. Wangsgard dated April 19, 2022 re: Post-Discovery Motion for Summary Judgment. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 126
MEMO ENDORSEMENT: on re: #125 Letter filed by Channel One Russia. ENDORSEMENT: The request is Granted. The Fact Discovery deadline is extended to March 23, 2022. SO ORDERED., ( Fact Discovery due by 3/23/2022.) (Signed by Judge John P. Cronan on 3/11/2022) (ama)
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Filing 125
LETTER addressed to Judge John P. Cronan from Kendall E. Wangsgard dated March 7, 2022 re: Agreement to Continue Fact Discovery. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 124
ORDER The request is granted. Fact discovery shall close on March 7, 2022, expert discovery shall close on April 21, 2022, and the parties shall file the joint post-discovery status letter by April 28, 2022. ( Expert Discovery due by 4/21/2022., Fact Discovery due by 3/7/2022.) (Signed by Judge John P. Cronan on 12/24/2021) (mhe)
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Filing 123
LETTER MOTION for Extension of Time to Complete Discovery addressed to Judge John P. Cronan from Bertrand C. Sellier dated December 20, 2021. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Minute Entry for proceedings held before Judge John P. Cronan: Telephone Conference held on December 8, 2021. By December 20, 2021, the parties shall file a joint status letter outlining (1) their views on possible alternatives to traditional remote depositions, (2) the progress of efforts to secure a reporter/translation service for a remote deposition in Russia; (3) options on a third-country for depositions, including whether the deponents would agree to those options; and (4) their views on an appropriate extension of the current discovery deadlines. (Court Reporter Steven Greenblum). (mhe)
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Filing 122
LETTER RESPONSE to Motion addressed to Judge John P. Cronan from Kendall E. Wangsgard dated December 2, 2021 re: #120 LETTER MOTION to Compel Deponents to Appear for depositions outside of Russia addressed to Judge John P. Cronan from Bertrand C. Sellier dated 11/29/2021. . Document filed by Channel One Russia. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Wangsgard, Kendall)
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Filing 121
ORDER granting #120 LETTER MOTION to Compel Deponents to Appear for depositions outside of Russia. The request is granted. The parties shall appear for a telephonic status conference on the deposition issue on December 8, 2021 at 11:00 a.m. At the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261. SO ORDERED. (Signed by Judge John P. Cronan on 11/30/2021) (jca)
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Set/Reset Hearings: Telephone Conference set for 12/8/2021 at 11:00 AM before Judge John P. Cronan. (jca)
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Filing 120
LETTER MOTION to Compel Deponents to Appear for depositions outside of Russia addressed to Judge John P. Cronan from Bertrand C. Sellier dated 11/29/2021. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 119
MANDATE of USCA (Certified Copy) USCA Case Number 21-1311. Petitioner requests a writ of prohibition barring the district court from exercising personal jurisdiction over it. It also moves to stay district court proceedings pending resolution of the petition. Upon due consideration, it is hereby ORDERED that the petition is DENIED because Petitioner has not demonstrated that it has no other adequate means to obtain the relief it seeks, such as an appeal from a final judgment. See Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380 (2004); In re Roman Catholic Diocese of Albany, New York, Inc., 745 F.3d 30, 35 (2d Cir. 2014) (per curiam); Linde v. Arab Bank, PLC, 706 F.3d 92, 117.18 (2d Cir. 2013). It is further ORDERED that the motion for a stay is DENIED as moot.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 09/22/2021..(nd)
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Filing 118
ANSWER to #117 Counterclaim. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 117
AMENDED ANSWER to #5 Complaint., COUNTERCLAIM against Alex Goldfarb. Document filed by Channel One Russia..(Rivkin, David)
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Filing 116
ORDER granting #115 Letter Motion for Leave to File Document. Defendant's request is granted. Defendant shall file its amended answer and counterclaims by August 13, 2021. SO ORDERED. (Signed by Judge John P. Cronan on 8/6/2021) (jca)
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Set/Reset Deadlines: Channel One Russia answer due 8/13/2021. (jca)
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Filing 115
LETTER MOTION for Leave to File Amended Answer and Counterclaims addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated August 6, 2021. Document filed by Channel One Russia. (Attachments: #1 Exhibit A-(Proposed) Defendant's First Amended Answer, Defenses to Complaint, and Counterclaim).(Rivkin, David)
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Minute Entry for proceedings held before Judge John P. Cronan: Telephone Conference held on June 10, 2021. The Court will set a case management plan by separate order. The parties are directed to file a post-discovery status letter, as described in the case management plan, on February 28, 2022. Plaintiff waived any right to a jury trial during the conference. (No Court Reporter Present) (mhe)
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Filing 114
CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to conducting all further proceedings before a United States Magistrate Judge, including motions and trial. 28 U.S.C. 636(c). Settlement discussions have not taken place. The parties shall be ready for trial as of two weeks following the deadline for the proposed Joint Pretrial Order. This case is not to be tried to a jury. Counsel for the patties have conferred and their best estimate of the length of trial is five (5) Court days. Motions due by 7/9/2021. Deposition due by 2/21/2022. Fact Discovery due by 1/6/2022. Expert Discovery due by 2/21/2022. (Signed by Judge John P. Cronan on 6/10/2021) (nb)
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Filing 113
ORDER granting #111 Letter Motion for Conference re: #111 LETTER MOTION for Conference re: Letter Motion for Leave to Excuse Principal Trial Counsel Requirement for IPTC addressed to Judge John P. Cronan from Kendall E. Wangsgard dated June 8, 2021. Defendant's request is granted. Mr. Wangsgard may appear for Defendant Channel One Russia at the June 10, 2021 Initial Pretrial Conference.. (Signed by Judge John P. Cronan on 6/8/2021) (nb) Modified on 6/11/2021 (nb).
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Filing 112
JOINT LETTER addressed to Judge John P. Cronan from Kendall E. Wangsgard dated June 8, 2021 re: Proposed Civil Case Management Plan and Scheduling Order. Document filed by Channel One Russia. (Attachments: #1 Proposed Civil Case Management Plan and Scheduling Order, #2 Parties Position on Item 6(a)).(Wangsgard, Kendall)
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Filing 111
LETTER MOTION for Conference re: Letter Motion for Leave to Excuse Principal Trial Counsel Requirement for IPTC addressed to Judge John P. Cronan from Kendall E. Wangsgard dated June 8, 2021. Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 110
ORDER OF INITIAL PRETRIAL CONFERENCE: Initial Conference set for 6/10/2021 at 10:30 AM before Judge John P. Cronan. (Signed by Judge John P. Cronan on 5/28/2021) (ate) Modified on 6/3/2021 (ate).
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Filing 109
ANSWER to #5 Complaint. Document filed by Channel One Russia..(Rivkin, David)
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Filing 108
ORDER of USCA (Certified Copy) USCA Case Number 21-1311. Petitioner moves for an emergency stay of district court proceedings pending this petition for a writ of prohibition. IT IS HEREBY ORDERED that, to the extent the motion seeks a temporary stay pending review by a three-judge panel, the stay is DENIED. The motion is REFERRED to a three-judge motions panel.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Certified: 05/27/2021..(nd)
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Filing 107
ORDER granting #106 LETTER MOTION for Extension of Time to File Answer addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated April 19, 2021. Document filed by Channel One Russia. Defendant's request is granted. Defendant shall file an Answer to the Complaint by May 27, 2021. SO ORDERED. Channel One Russia answer due 5/27/2021. (Signed by Judge John P. Cronan on 4/19/2021) (rjm)
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Filing 106
LETTER MOTION for Extension of Time to File Answer addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated April 19, 2021. Document filed by Channel One Russia..(Rivkin, David)
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Filing 105
OPINION AND ORDER re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion . filed by Channel One Russia. For the reasons discussed above, Channel Ones renewed motion for reconsideration is denied. Channel One has failed to demonstrate "an intervening change in controlling law, the availability of new evidence, or the need to correct a clear error or prevent manifest injustice." Coopers & Lybrand LLP, 322 F.3d at 167. The Court also denies Channel One's request to certify the March 4, 2020 Order for an interlocutory appeal pursuant to 28 U.S.C. 1292(b). The Clerk of Court is respectfully directed to close the motion pending on Docket Number 96. Channel One shall file an Answer to the Complaint within fourteen days of the filing of this Order. The Court will schedule an Initial Pretrial Conference by separate order. (As further set forth in this Order.) (Signed by Judge John P. Cronan on 4/13/2021) (cf) Modified on 4/13/2021 (cf).
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Filing 104
NOTICE of Lodging Certified Translations of Exhibit B to the Declaration of Kendall Wangsgard, ECF No. 101 re: #101 Declaration in Support of Motion,. Document filed by Channel One Russia. (Attachments: #1 Certified Translations).(Wangsgard, Kendall)
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Filing 103
ORDER: The Pretrial Conference scheduled for December 16, 2020, at 11:30 a.m. is hereby adjourned sine die. If appropriate, the Court will schedule an Initial Pretrial Conference after disposition of the pending motion. So Ordered. (Signed by Judge John P. Cronan on 12/11/2020) (js)
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Filing 102
ORDER The Pretrial Conference scheduled for December 16, 2020, at 11:00 a.m. is hereby adjourned to December 16, 2020, at 11:30 a.m. (HEREBY ORDERED by Judge John P. Cronan) (Text Only Order) (mhe)
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Filing 101
DECLARATION of Kendall Wangsgard in Support re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, .. Document filed by Channel One Russia. (Attachments: #1 Exhibit A - Objections and Answers to Plaintiffs First Set of Jurisdictional Interrogatories, #2 Exhibit B - relevant pages, bates stamped G 000025-G 000029, and G 000049-G 000050).(Rivkin, David)
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Filing 100
REPLY MEMORANDUM OF LAW in Support re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . . Document filed by Channel One Russia..(Rivkin, David)
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Filing 99
MEMORANDUM OF LAW in Opposition re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . . Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 98
DECLARATION of Kendall Wangsgard in Support re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, .. Document filed by Channel One Russia. (Attachments: #1 Exhibit A - Plaintiffs Response to Defendant Channel One Russias First Set of Jurisdictional Interrogatories, #2 Exhibit B - Bates stamped G 000043-G 000047).(Rivkin, David)
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Filing 97
MEMORANDUM OF LAW in Support re: #96 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . . Document filed by Channel One Russia..(Rivkin, David)
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Filing 96
MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . Document filed by Channel One Russia..(Rivkin, David)
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Filing 95
LETTER addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated November 3, 2020 re: Clarification of the Joint Status Letter dated October 27, 2020. Document filed by Channel One Russia..(Rivkin, David)
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Filing 94
JOINT LETTER addressed to Judge John P. Cronan from David B. Rivkin, Jr. dated October 27, 2020 re: Status of the Case. Document filed by Channel One Russia..(Rivkin, David)
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Filing 93
NOTICE OF REASSIGNMENT: This case has been reassigned to the undersigned. Unless and until the Court orders otherwise, all prior orders, dates, and deadlines shall remain in effect notwithstanding the case's reassignment. Counsel for all parties are hereby directed to appear before the undersigned for a Pretrial Conference on December 16, 2020, at 11:00 a.m. In light of the ongoing COVID-19 pandemic, the Court will conduct the conference by teleconference. At the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261. Initial Conference set for 12/16/2020 at 11:00 AM before Judge John P. Cronan. (Signed by Judge John P. Cronan on 10/13/2020) (va)
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NOTICE OF CASE REASSIGNMENT to Judge John Peter Cronan. Judge Valerie E. Caproni is no longer assigned to the case. (aea)
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Filing 92
NOTICE OF DISMISSAL: PLEASE TAKE NOTICE that plaintiff Alex Goldfarb dismisses this action solely against defendant RT America a.k.a. ANO TV-Novosti pursuant to Fed. R. Civ. P. 41(a). Application GRANTED. RT America a.k.a. ANO TV-Novosti is DISMISSED. SO ORDERED., RT America (a.k.a. ANO TV-NOVOSTI) terminated. (Signed by Judge Valerie E. Caproni on 9/01/2020) (ama)
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Filing 91
NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, against the defendant(s) RT America. Document filed by Alex Goldfarb. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Sellier, Bertrand)
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***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. #91 Notice of Voluntary Dismissal was reviewed and referred to Judge Valerie E. Caproni for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (km)
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Filing 90
STIPULATED PROTECTIVE ORDER:...regarding procedures to be followed that shall govern the handling of confidential material. And as set forth herein. SO ORDERED. (Signed by Judge Valerie E. Caproni on 8/26/2020) (ama)
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Filing 89
LETTER addressed to Judge Valerie E. Caproni from David B. Rivkin, Jr. dated August 26, 2020 re: Proposed Stipulated Protective Order. Document filed by Channel One Russia. (Attachments: #1 Text of Proposed Order).(Rivkin, David)
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Filing 88
MEMO ENDORSEMENT on re: #87 Letter filed by Channel One Russia. ENDORSEMENT: Application Granted. SO ORDERED., ( Deposition due by 10/23/2020., Motions due by 11/6/2020., Responses due by 11/24/2020, Replies due by 12/7/2020.) (Signed by Judge Valerie E. Caproni on 6/01/2020) (ama)
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Filing 87
LETTER addressed to Judge Valerie E. Caproni from David B. Rivkin, Jr. dated June 1, 2020 re: Modified Schedule for Jurisdictional Discovery. Document filed by Channel One Russia..(Rivkin, David)
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Filing 86
MEMO ENDORSEMENT on re: #85 Proposed Scheduling Order filed by Alex Goldfarb. ENDORSEMENT: Application Granted. The Above schedule is adopted. SO ORDERED., ( Deposition due by 7/31/2020., Discovery due by 5/11/2020., Motions due by 8/17/2020.) (Signed by Judge Valerie E. Caproni on 5/01/2020) (ama)
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Filing 85
PROPOSED SCHEDULING ORDER. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 84
ORDER terminating #75 Motion for Reconsideration ; denying #77 Motion for Reconsideration: IT IS HEREBY ORDERED THAT: 1. Channel One's motion for reconsideration is HELD IN ABEYANCE pending jurisdictional discovery relative to Goldfarb's allegation that Channel One published the alleged defamatory material in New York through its subsidiary and agent Channel One Russia Worldwide. 2. RT America's motion for reconsideration is DENIED. As previously ordered, the Court will allow jurisdictional discovery to determine whether the Court can exercise personal jurisdiction over Defendant RT America. 3. No later than May 1, 2020, the parties must jointly propose a reasonable schedule for jurisdictional discovery as to both Defendants. The Clerk of Court is respectfully directed to close the open motions at docket entries 75 and 77. (Signed by Judge Valerie E. Caproni on 4/9/2020) (jwh)
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Filing 83
REPLY MEMORANDUM OF LAW in Support re: #77 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, RT America, A.K.A ANO TV Novosti's Motion for Reconsideration or the Alternative, Certification of the Court March 4, 2020 Order for Interlocutory Appeal. . Document filed by RT America..(Erb, Nicole)
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Filing 82
REPLY MEMORANDUM OF LAW in Support re: #75 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . . Document filed by Channel One Russia..(Rivkin, David)
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Filing 81
MEMO ENDORSEMENT on re: #79 Letter filed by Alex Goldfarb. Application GRANTED. SO ORDERED. (Signed by Judge Valerie E. Caproni on 3/31/2020) (jca)
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Filing 80
MEMORANDUM OF LAW in Opposition re: #75 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, ., #77 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, RT America, A.K.A ANO TV Novosti's Motion for Reconsideration or the Alternative, Certification of the Court March 4, 2020 Order for Interlocutory Appeal. . Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 79
LETTER addressed to Judge Valerie E. Caproni from Bertrand C. Sellier, Esq. dated March 31, 2020 re: Defer Jurisdictional Discovery. Document filed by Alex Goldfarb..(Sellier, Bertrand)
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Filing 78
MEMORANDUM OF LAW in Support re: #77 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, RT America, A.K.A ANO TV Novosti's Motion for Reconsideration or the Alternative, Certification of the Court March 4, 2020 Order for Interlocutory Appeal. . Document filed by RT America..(Erb, Nicole)
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Filing 77
MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, RT America, A.K.A ANO TV Novosti's Motion for Reconsideration or the Alternative, Certification of the Court March 4, 2020 Order for Interlocutory Appeal. Document filed by RT America..(Erb, Nicole)
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Filing 76
MEMORANDUM OF LAW in Support re: #75 MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . . Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 75
MOTION for Reconsideration re; #74 Memorandum & Opinion,,,,,, . Document filed by Channel One Russia..(Wangsgard, Kendall)
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Filing 74
OPINION AND ORDER: re: #30 MOTION to Dismiss for Lack of Jurisdiction Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim filed by RT America, #59 MOTION to Dismiss the Complaint filed by Channel One Russia. For the foregoing reasons, the Court declines to dismiss this case for forum non conveniens. The Court finds that Plaintiff has adequately alleged a basis for personal jurisdiction over Defendant Channel One Russia. Thus, Defendant Channel One's motion to dismiss is DENIED. The Court will allow jurisdictional discovery to determine whether the Court can exercise personal jurisdiction over Defendant RT America. Accordingly, Defendant RT America's motion to dismiss for lack of personal jurisdiction is DENIED without prejudice; RT America's motion to dismiss for failure to state a claim is STAYED. The parties are ordered to meet and confer. Not later than March 31, 2020, they must jointly propose a reasonable schedule for jurisdictional discovery as to RT America and indicate whether they prefer to proceed with discovery as to Channel One prior to the resolution of RT America's motion to dismiss. If the parties wish to proceed with discovery as to Channel One, the parties must also provide the Court with a proposed case management plan by that date. The Clerk of Court is respectfully directed to close the open motions at docket entries 30 and 59. SO ORDERED. (Signed by Judge Valerie E. Caproni on 3/04/2020) (ama)
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NOTICE OF CASE REASSIGNMENT to Judge Valerie E. Caproni. Judge Deborah A. Batts is no longer assigned to the case. (sjo)
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Filing 73
ORDER FOR ADMISSION PRO HAC VICE granting #72 Motion for Rodney Alan Smolla to Appear Pro Hac Vice. (Signed by Judge Deborah A. Batts on 7/25/2019) (rro)
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Filing 72
THIRD MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alex Goldfarb. Return Date set for 7/8/2019 at 05:00 PM. (Attachments: #1 Affidavit Affidavit or Rodney Alan Smolla, #2 Supplement Certificates of Good Standing, #3 Text of Proposed Order Proposed Order)(Smolla, Rodney)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #72 THIRD MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #71 SECOND MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17070781. Motion and supporting papers to be reviewed by Clerk's Office staff.. The filing is deficient for the following reason(s): expired Certificates of Good Standing from Illinois, Virginia, and Delaware. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order. (ma)
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Filing 71
FILING ERROR - DEFICIENT DOCKET ENTRY - SECOND MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17070781. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alex Goldfarb. Return Date set for 6/12/2019 at 04:45 PM. (Attachments: #1 Supplement corrected certificates of good standing, #2 Affidavit, #3 Text of Proposed Order)(Smolla, Rodney) Modified on 6/13/2019 (ma).
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #70 MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17012260. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): expired Certificate of Good Standing from Supreme Court of Delaware. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Attorney Affidavit - attach Proposed Order. (jc)
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***DELETED NOTICE. Deleted Notice Regarding Pro Hac Vice Motion. The notice incorrectly stated there were no deficiencies with the motion. (jc)
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Filing 70
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Rodney Alan Smolla to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17012260. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alex Goldfarb. (Attachments: #1 Affidavit, #2 Supplement Certificates of Good Standing, #3 Text of Proposed Order)(Smolla, Rodney) Modified on 6/12/2019 (jc).
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Filing 69
LETTER addressed to Judge Deborah A. Batts from Nicole Erb dated May 29, 2019 re: Joining Channel One Russia's motion to dismiss the Complaint under the doctrine of forum non conveniens. Document filed by RT America.(Erb, Nicole)
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Filing 68
DECLARATION of Sergey S. Sokolov in Support re: #59 MOTION to Dismiss the Complaint.. Document filed by Channel One Russia. (Rivkin, David)
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Filing 67
REPLY MEMORANDUM OF LAW in Support re: #59 MOTION to Dismiss the Complaint. . Document filed by Channel One Russia. (Rivkin, David)
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Filing 66
MEMORANDUM OF LAW in Opposition re: #59 MOTION to Dismiss the Complaint. . Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 65
AFFIDAVIT of Yuri Shvets in Opposition re: #59 MOTION to Dismiss the Complaint.. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 64
AFFIDAVIT of Melissa Hooper in Opposition re: #59 MOTION to Dismiss the Complaint.. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 63
AFFIDAVIT of Alex Goldfarb in Opposition re: #59 MOTION to Dismiss the Complaint.. Document filed by Alex Goldfarb. (Attachments: #1 Ex. 1, #2 Ex. 2, #3 Ex. 3, #4 Ex. 4, #5 Ex. 5, #6 Ex. 6, #7 Ex. 7, #8 Ex. 8)(Sellier, Bertrand)
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Filing 62
DECLARATION of Larisa A. Nasonova in Support re: #59 MOTION to Dismiss the Complaint.. Document filed by Channel One Russia. (Rivkin, David)
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Filing 61
DECLARATION of Sergey S. Sokolov in Support re: #59 MOTION to Dismiss the Complaint.. Document filed by Channel One Russia. (Rivkin, David)
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Filing 60
MEMORANDUM OF LAW in Support re: #59 MOTION to Dismiss the Complaint. . Document filed by Channel One Russia. (Rivkin, David)
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Filing 59
MOTION to Dismiss the Complaint. Document filed by Channel One Russia.(Rivkin, David)
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Filing 58
PROPOSED SCHEDULING ORDER. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 57
ORDER GRANTING PRO HAC VICE ADMISSION granting #55 Motion for Elizabeth Price Foley to Appear Pro Hac Vice. (Signed by Judge Deborah A. Batts on 4/4/2019) (rro)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #55 AMENDED MOTION for Elizabeth Price Foley to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
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Filing 56
REPLY MEMORANDUM OF LAW in Support re: #30 MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim. . Document filed by RT America. (Erb, Nicole)
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Filing 55
AMENDED MOTION for Elizabeth Price Foley to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Channel One Russia. (Attachments: #1 Affidavit of Foley in Support of Motion for Admission Pro Hac Vice, #2 Exhibit 1 - District of Columbia Certificate of Good Standing, #3 Exhibit 2 - Florida Certificate of Good Standing, #4 Exhibit 3 - Texas Certificate of Good Standing, #5 Text of Proposed Order Granting Pro Hac Vice Admission)(Foley, Elizabeth)
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Filing 54
LETTER addressed to Judge Deborah A. Batts from David B. Rivkin, Jr. dated March 25, 2019 re: Response to Plaintiff's March 21, 2019 Affidavit. Document filed by Channel One Russia. (Attachments: #1 Exhibit 1 - Declaration of Dmitry Orlov)(Rivkin, David)
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Filing 53
ORDER granting #50 Motion for David B. Rivkin to Appear Pro Hac Vice. IT IS HEREBY ORDERED that David B. Rivkin, Jr. is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Deborah A. Batts on 3/21/2019) (js)
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Filing 52
AFFIDAVIT of Alex Goldfarb re: #49 Letter from Channel One Russia dated March 19, 2019. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #50 MOTION for David B. Rivkin, Jr. to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16532999. 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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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #51 MOTION for Elizabeth Price Foley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16532989. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of California and Florida;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (wb)
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Filing 51
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Elizabeth Price Foley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16532989. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Channel One Russia. (Attachments: #1 Affidavit of Foley in Support of Motion for Admission Pro Hac Vice, #2 Exhibit Certificate of Good Standing, #3 Exhibit Certificate of Good Standing, #4 Exhibit Certificate of Good Standing, #5 Text of Proposed Order Granting Pro Hac Vice Admission)(Foley, Elizabeth) Modified on 3/21/2019 (wb).
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Filing 50
MOTION for David B. Rivkin, Jr. to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16532999. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Channel One Russia. (Attachments: #1 Affidavit of David B. Rivkin, Jr. in Support, #2 Exhibit 1 - Certificate of Good Standing, #3 Text of Proposed Order Granting Motion for Admission Pro Hac Vice)(Rivkin, David)
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Filing 49
LETTER addressed to Judge Deborah A. Batts from Kendall E. Wangsgard dated March 19, 2019 re: Response to Plaintiff's March 18, 2019 Letter (ECF 48). Document filed by Channel One Russia.(Wangsgard, Kendall)
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Filing 48
LETTER addressed to Judge Deborah A. Batts from Bertrand C. Sellier, Esq. dated March 18, 2019 re: Default of Defendant Channel One Russia. Document filed by Alex Goldfarb.(Sellier, Bertrand)
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Filing 47
MEMORANDUM OF LAW in Opposition re: #30 MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim. . Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 46
AFFIDAVIT of Alex Goldfarb in Opposition re: #30 MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim.. Document filed by Alex Goldfarb. (Attachments: #1 Ex. A Report from RT New York Studio, #2 Ex. B Wall Street Journal article, #3 Ex. C August 17, 2017 DOJ determination, #4 Ex. D NY Secretary of State web page RTTV, #5 Ex. E RTTV DOJ filing 02.28.2011, #6 Ex. F RTTV DOJ filing 08.17.2010, #7 Ex. G NY Secretary of State T&R, #8 Ex. H T&R Supplemental Statement, #9 Ex. I Article on Mrs. Litvinenko's March 21 2018 Interview, #10 Ex. J Politico article 03.21.2014)(Sellier, Bertrand)
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Filing 45
LETTER addressed to Judge Deborah A. Batts from Kendall E. Wangsgard dated March 15, 2019 re: Response to Plaintiff's March 14, 2019 Letter Motion (ECF 43). Document filed by Channel One Russia.(Wangsgard, Kendall)
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Filing 44
AFFIDAVIT of Dr. Alex Goldfarb in Opposition re: #40 LETTER MOTION for Conference or in the Alternative, to Stay Proceedings addressed to Judge Deborah A. Batts from Kendall E. Wangsgard dated March 12, 2019.. Document filed by Alex Goldfarb. (Attachments: #1 Ex. A-Photograph of plaintiff and Ms. Agalakova at Dec 14, 2018 event, #2 Ex. B-Plaintiff's email to counsel)(Sellier, Bertrand)
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Filing 43
LETTER addressed to Judge Deborah A. Batts from Bertrand C. Sellier, Esq. dated March 14, 2019 re: Channel One Russia's Application to Respond. Document filed by Alex Goldfarb.(Sellier, Bertrand)
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Filing 42
AFFIDAVIT OF SERVICE of Motion and Supporting Papers in Support of Plaintiff's Motion for a Default Judgment Against Defendant Channel One Russia served on Channel One Russia, Vladimir Lenskiy on December 13, 2018. Service was made by Mail. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 41
ORDER granting #40 Letter Motion for Conference. Defendant Channel One Russia is GRANTED 30 days to move or respond to the Complaint. Failure to do so will result in the entry of a default judgment against them. (Signed by Judge Deborah A. Batts on 3/13/2019) (cf)
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Filing 40
LETTER MOTION for Conference or in the Alternative, to Stay Proceedings addressed to Judge Deborah A. Batts from Kendall E. Wangsgard dated March 12, 2019. Document filed by Channel One Russia.(Wangsgard, Kendall)
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Filing 39
NOTICE OF APPEARANCE by Kendall Eugene Wangsgard on behalf of Channel One Russia. (Wangsgard, Kendall)
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Filing 38
ORDER granting #36 Letter Motion for Extension of Time to Answer re #5 Complaint. GRANTED, as per the Court's March 6, 2019 Order. SO ORDERED. (Signed by Judge Deborah A. Batts on 3/6/2019) (rro)
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Filing 37
STIPULATION FOR A BRIEFING SCHEDULE: WHEREAS, the parties have conferred through counsel and agree as follows: IT IS HEREBY STIPULATED AND AGREED that the last date for Plaintiff to respond to ANO TV Novosti's motion to dismiss shall be Monday, March 18, 2019, and the last day for ANO TV Novosti to submit reply papers in further support of its motion to dismiss shall be or Tuesday, April 2, 2019. IT IS HEREBY FURTHER STIPULATED AND AGREED that ANO TV Novosti expressly preserves, and does not waive, any and all rights, privileges, defenses, objections, and/or immunities that may be available to it, including without limitation defenses or objections to the lawsuit, the court's jurisdiction, and the venue of the action. SO ORDERED. Set Deadlines/Hearing as to #30 MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim. (Responses due by 3/18/2019, Replies due by 4/2/2019.) (Signed by Judge Deborah A. Batts on 3/6/2019) (rro)
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Filing 36
LETTER MOTION for Extension of Time to File Answer re: #35 Letter addressed to Judge Deborah A. Batts from Bertrand C. Sellier, Esq. dated March 6, 2019. Document filed by Alex Goldfarb.(Sellier, Bertrand)
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Filing 35
LETTER addressed to Judge Deborah A. Batts from Nicole Erb dated March 6, 2019 re: TV Novosti's unopposed motion to dismiss #30 . Document filed by RT America.(Erb, Nicole)
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Filing 34
MEMO ENDORSEMENT on re: #19 Letter filed by Alex Goldfarb. ENDORSEMENT: Granted. SO ORDERED. (Signed by Judge Deborah A. Batts on 2/14/2019) (rro)
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Filing 33
ORDER GRANTING PRO HAC VICE ADMISSION granting #28 Motion for Matthew S. Leddicotte to Appear Pro Hac Vice. (Signed by Judge Deborah A. Batts on 2/14/2019) (jca)
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Filing 32
PROPOSED SCHEDULING ORDER. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #28 MOTION for Matthew S. Leddicotte to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16331911. 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 31
MEMORANDUM OF LAW in Support re: #30 MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim. . Document filed by RT America. (Erb, Nicole)
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Filing 30
MOTION to Dismiss for Lack of Jurisdiction /Motion to Dismiss Plaintiff's Complaint for Lack of Personal Jurisdiction and Failure to State a Claim. Document filed by RT America.(Erb, Nicole)
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Filing 29
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by RT America.(Erb, Nicole)
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Filing 28
MOTION for Matthew S. Leddicotte to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-16331911. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by RT America. (Attachments: #1 Affidavit in Support of Motion, #2 Certificate of Good Standing, #3 Text of Proposed Order)(Leddicotte, Matthew)
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Filing 27
MOTION for Default Judgment as to Defendant Channel One Russia. Document filed by Alex Goldfarb.(Sellier, Bertrand)
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Filing 26
AFFIDAVIT of Bertrand C. Sellier in Support. Document filed by Alex Goldfarb. (Attachments: #1 Ex. A-Certificate of Default, #2 Ex. B-Complaint, #3 Ex. C-Proposed Default Judgment)(Sellier, Bertrand)
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Filing 25
CLERK'S CERTIFICATE OF DEFAULT as Channel One Russia. (km)
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Filing 24
AFFIDAVIT of Bertrand C. Sellier, Esq. in Support re: #23 Proposed Clerk's Certificate of Default. Document filed by Alex Goldfarb. (Attachments: #1 Exhibit Ex. A-Affidavit of Service)(Sellier, Bertrand)
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Filing 23
PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Alex Goldfarb. (Sellier, Bertrand) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).
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Filing 22
STIPULATED 60-DAY STAY IN FAVOR OF SETTLEMENT OR MEDIATION: WHEREAS, the parties have conferred through counsel and agree as follows: IT IS HEREBY STIPULATED AND AGREED that a sixty-day extension of Defendant RT America, a.k.a. ANO TV-Novosti's time to respond to Plaintiff's Complaint will permit Plaintiff Goldfarb and Defendant RT America, a.k.a. ANO TV-Novosti to explore possible settlement or mediation. IT IS HEREBY FURTHER STIPULATED AND AGREED the last date for Defendant RT America, a.k.a. ANO TV-Novosti to answer or otherwise respond to Plaintiff's Complaint shall be February 11, 2019. IT IS HEREBY FURTHER STIPULATED AND AGREED that Defendant RT America, a.k.a. ANO TV-Novosti expressly preserves, and does not waive, any and all rights, privileges, defenses, objections, and/or immunities that may be available to it, including without limitation defenses or objections to the lawsuit, the court's jurisdiction, and the venue of the action. The Parties' extension request is GRANTED. Defendant RT America, a.k.a. ANO TVNovosti, has until 2/11/19 to answer or otherwise respond to the Complaint. SO ORDERED. (RT America answer due 2/11/2019.) (Signed by Judge Deborah A. Batts on 12/11/2018) (rro)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED CLERK'S CERTIFICATE OF DEFAULT: Notice to Attorney Bertrand Sellier. RE-FILE Document No. #20 FIRST MOTION for Entry of Default as to Alex Goldfarb .. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the proposed Clerk's Certificate of Default is the wrong document. Re-file the Clerk's Certificate of Default only under Proposed orders, as a Proposed Clerk's Certificate of Default, then separately file a Affidavit in Support of the Clerk's Certificate under Other answers, Affidavit in support of a Non-Motion. (dt)
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Filing 21
PROPOSED STIPULATION AND ORDER. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 20
FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION for Entry of Default as to Alex Goldfarb . Document filed by Alex Goldfarb. (Attachments: #1 Exhibit A, #2 Exhibit B)(Sellier, Bertrand) Modified on 12/11/2018 (dt).
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Filing 19
LETTER addressed to Judge Deborah A. Batts from Bertrand C. Sellier dated November 9, 2018 re: Amending Caption. Document filed by Alex Goldfarb.(Sellier, Bertrand)
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Filing 18
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - LETTER MOTION to Compel the Clerk to Amend Caption addressed to Judge Deborah A. Batts from Bertrand C. Sellier dated November 9, 2018. Document filed by Alex Goldfarb.(Sellier, Bertrand) Modified on 11/9/2018 (db).
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Notice to Attorney Bertrand Charles Sellier to RE-FILE Document #18 LETTER MOTION to Compel the Clerk to Amend Caption addressed to Judge Deborah A. Batts from Bertrand C. Sellier dated November 9, 2018. Use the event type Letter found under the event list Other Documents. (db)
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - PDF ERROR. Notice to Attorney Nicole Erb to RE-FILE Document #15 Rule 7.1 Corporate Disclosure Statement. (The filer listed on the PDF is not a party in this action) (lb)
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Filing 17
STIPULATION TO EXTEND TIME FOR DEFENDANT ANO TV NOVOSTI TO RESPOND TO COMPLAINT: IT IS HEREBY STIPULATED AND AGREED that the last date for ANO TV Novosti to answer or otherwise respond to Plaintiff's Complaint shall be December 13, 2018. IT IS HEREBY FURTHER STIPULATED AND AGREED that ANO TV Novosti expressly preserves, and does not waive, any and all rights, privileges, defenses, objections, and/or immunities that may be available to it, including without limitation defenses or objections to the lawsuit, the court's jurisdiction, and the venue of the action. But, ANO TV Novosti will not object to the sufficiency of service of process. GRANTED. SO ORDERED. (RT America answer due 12/13/2018.) (Signed by Judge Deborah A. Batts on 11/5/2018) (rro)
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Filing 16
PROPOSED STIPULATION AND ORDER. Document filed by RT America. (Erb, Nicole)
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Filing 15
FILING ERROR - WRONG PDF FILE ASSOCIATED WITH DOCKET ENTRY - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by RT America.(Erb, Nicole) Modified on 11/7/2018 (lb).
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Filing 14
NOTICE OF APPEARANCE by Nicole Erb on behalf of RT America. (Erb, Nicole)
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NOTICE OF CASE REASSIGNMENT to Judge Deborah A. Batts. Judge Richard J. Sullivan is no longer assigned to the case. (sjo)
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Filing 13
CERTIFICATE OF SERVICE. RT America served on 10/22/2018, answer due 11/13/2018. Service was made by Mail. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 12
ORDER granting #11 Letter Motion to Compel. Goldfarb's motion is GRANTED. IT IS HEREBY ORDERED that, within fourteen days of the date of this order, Goldfarb shall serve the summons, complaint, all documents attached to the complaint, and this order on Matthew S. Leddicotte of White & Case LLP by courier and email. IT IS FURTHER ORDERED that, once service has been completed, Goldfarb shall file a certificate of service on the Court's electronic docket indicating that service has been effected. (Signed by Judge Richard J. Sullivan on 10/19/2018) (mro)
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Filing 11
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - LETTER MOTION to Compel Service of Process via courier and email to Matthew S. Leddicotte, Esq. and Margarita Simonyan addressed to Judge Richard J. Sullivan from Bertrand C. Sellier dated October 5, 2018. Document filed by Alex Goldfarb.(Sellier, Bertrand) Modified on 10/30/2018 (ldi).
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Filing 10
AFFIDAVIT OF SERVICE of Summons in a Civil Action and Verified Complaint with Supporting Exhibits served on Channel One Russia on September 26, 2018. Service was accepted by Nancy Dougherty, Authorized Agent, Office of the Secretary of State. Document filed by Alex Goldfarb. (Sellier, Bertrand)
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Filing 9
NOTICE OF CHANGE OF ADDRESS by Bertrand Charles Sellier on behalf of Alex Goldfarb. New Address: Rottenberg Lipman Rich, P.C., 230 Park Avenue, 18th Floor, New York, New York, United States 10169, 2126613080. (Sellier, Bertrand)
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Filing 8
NOTICE OF APPEARANCE by Bertrand Charles Sellier on behalf of Alex Goldfarb. (Sellier, Bertrand)
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Filing 7
ELECTRONIC SUMMONS ISSUED as to Channel One Russia, RT America. (dnh)
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Filing 6
REQUEST FOR ISSUANCE OF SUMMONS as to Channel One Russia and RT America, re: #5 Complaint. Document filed by Alex Goldfarb. (Rosberger, Richard)
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Filing 5
COMPLAINT against Channel One Russia, RT America. Document filed by Alex Goldfarb.(Rosberger, Richard)
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Filing 4
CIVIL COVER SHEET filed. (Rosberger, Richard)
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Richard J. Sullivan. Please download and review the Individual Practices of the assigned District Judge, located at #http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #http://nysd.uscourts.gov/ecf_filing.php. (pne)
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***NOTICE TO ATTORNEY TO ELECTRONICALLY FILE CIVIL COVER SHEET. Notice to Attorney Richard Edward Rosberger. Attorney must electronically file the Civil Cover Sheet. Use the event type Civil Cover Sheet found under the event list Other Documents. (pne)
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Magistrate Judge Stewart D. Aaron is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #http://nysd.uscourts.gov/forms.php. (pne)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Richard Edward Rosberger to RE-FILE Document No. #1 Complaint,. The filing is deficient for the following reason(s): the All Defendant radio button was selected; the wrong party/parties whom the pleading is against were selected; the pleading was not signed by the filing attorney. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (pne)
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Case Designated ECF. (pne)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Richard Edward Rosberger to RE-FILE Document No. #3 Request for Issuance of Summons,. The filing is deficient for the following reasons: party name in the 'To' field contains an alias that does not appear on the pleading caption; All text in the section of the PDF that states 'Clerk of Court' must be removed. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (pne)
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Filing 3
FILING ERROR - DEFICIENT PLEADING - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Channel One Russia and RT America, aka ANO TV-Novosti, re: #1 Complaint. Document filed by Alex Goldfarb. (Sellier, Bertrand) Modified on 9/7/2018 (pne).
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Filing 2
NOTICE OF CHANGE OF ADDRESS by Richard Edward Rosberger on behalf of Alex Goldfarb. New Address: Rottenberg Lipman Rich, P.C., 230 Park Avenue, 18th Floor, New York, New York, United States 10169, (212) 661-3080. (Rosberger, Richard)
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Filing 1
FILING ERROR - DEFICIENT PLEADING - FILED AGAINST PARTY ERROR - SIGNATURE ERROR -COMPLAINT against All Defendants. (Filing Fee $ 400.00, Receipt Number 0208-15536101)Document filed by Alex Goldfarb.(Rosberger, Richard) Modified on 9/7/2018 (pne).
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