MSR Trust v. Nationstar Mortgage LLC
| MSR Trust |
| Nationstar Mortgage LLC d/b/a Mr. Cooper |
| 1:2021cv03089 |
| April 9, 2021 |
| US District Court for the Southern District of New York |
| George B Daniels |
| Robert W Lehrburger |
| Contract: Other |
| 28 U.S.C. § 1332 bc Diversity-Breach of Contract |
| None |
Docket Report
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This docket was last retrieved on July 12, 2023. A more recent docket listing may be available from PACER.
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Filing 67
ORDER granting #66 Letter Motion to Stay re: #66 JOINT LETTER MOTION to Stay All Deadlines addressed to Magistrate Judge Robert W. Lehrburger from Amy Kline dated April 14, 2023. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 4/17/2023) (ate)
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Filing 66
JOINT LETTER MOTION to Stay All Deadlines addressed to Magistrate Judge Robert W. Lehrburger from Amy Kline dated April 14, 2023. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 65
STATUS REPORT. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 64
STIPULATION AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material...SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 3/10/2023) (jca)
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Filing 63
PROPOSED PROTECTIVE ORDER. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 62
STATUS REPORT. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 61
MEMORANDUM DECISION AND ORDER for #57 Report and Recommendations,,,,,,, Motions terminated: #46 MOTION to Dismiss Amended Counterclaim. filed by MSR Trust. Magistrate Judge Lehrburger's Report is ADOPTED in full. MSR's motion to dismiss is GRANTED dismissing breach of contract counterclaims arising from MSR's alleged failure to indemnify all losses in Categories A, B, C, and E as well as to Nationstar's declaratory judgment counterclaim. The motion is DENIED with respect to Nationstar's claim for breach of contract arising from MSR's alleged failure to indemnify for losses in Category D. The Clerk of Court is directed to close MSR's motion, (ECF No. 46), accordingly. SO ORDERED (Signed by Judge George B. Daniels on 12/15/2022) (ks)
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Filing 60
ORDER granting #59 Letter Motion for Extension of Time to Complete Discovery. Revised schedule granted. No further extensions absent compelling circumstances. SO ORDERED. Deposition due by 4/14/2023. Motions due by 8/22/2023. Proposed Pretrial Order due by 8/22/2023. (Signed by Magistrate Judge Robert W. Lehrburger on 11/17/2022) (mml) Modified on 12/9/2022 (mml).
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Filing 59
LETTER MOTION for Extension of Time to Complete Discovery addressed to Magistrate Judge Robert W. Lehrburger from Amy S. Kline dated November 17, 2022. Document filed by MSR Trust..(Denker, Stephanie)
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Set/Reset Deadlines: Expert Discovery due by 7/14/2023. Fact Discovery due by 4/14/2023. (mml)
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Filing 58
STATUS REPORT. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 57
REPORT AND RECOMMENDATION TO HON. GEORGE B. DANIELS: MOTION TO DISMISS COUNTERCLAIM re: #46 MOTION to Dismiss Amended Counterclaim filed by MSR Trust. For the forgoing reasons, I recommend that MSR's motion to dismiss be GRANTED with respect to breach of contract claims arising from MSR's alleged failure to indemnify all losses in Categories A-C and E. The motion should be denied with respect to Nationstar's claim for breach of contract claims arising from MSR's alleged failure to indemnify for losses in Category D. I further recommend that the motion be GRANTED with respect to Nationstar's declaratory judgment counterclaim. All dismissals should be without prejudice. To the extent not discussed above, the Court has considered the parties' arguments and finds them to be without merit. Objections to R&R due by 8/11/2022. Copies transmitted this date to all counsel of record. (Signed by Magistrate Judge Robert W. Lehrburger on 7/28/2022) (mml)
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Filing 56
STATUS REPORT. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 55
REPLY MEMORANDUM OF LAW in Support re: #46 MOTION to Dismiss Amended Counterclaim. . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 54
STATUS REPORT. Joint Status Report Document filed by MSR Trust..(Denker, Stephanie)
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Filing 53
MEMORANDUM OF LAW in Opposition re: #46 MOTION to Dismiss Amended Counterclaim. . Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 52
JOINT ELECTRONIC DISCOVERY SUBMISSION NO. 1 AND ORDER: One or more of the parties to this litigation have indicated they believe that relevant information may exist or be stored in electronic format, and that this content is potentially responsive to current or anticipated discovery requests. This Joint Submission and Order (and any subsequent ones) shall be the governing document(s) by which the parties and the Court manage the electronic discovery process in this action. The parties and the Court recognize that this Joint Submission and Order is based on facts and circumstances as they are currently known to each party, that the electronic discovery process is iterative, and that additions and modifications to this submission may become necessary as more information becomes known to the parties,as further set forth herein. The next scheduled meet-and-confer conference to address electronic discovery issues, including the status of electronic discovery and any issues or disputes that have arisen since the last conference or Order, shall take place on 5/18/2022. The parties shall file a status report every 60 days consistent with the scheduling order issued in the case. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 5/4/2022) (mml)
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #51 Proposed Order was reviewed and approved as to form. (km)
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Filing 51
PROPOSED ORDER. Document filed by MSR Trust..(Denker, Stephanie) Proposed Order to be reviewed by Clerk's Office staff.
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Filing 50
ORDER granting #49 JOINT LETTER MOTION for Extension of Time to File protocol for electronic discovery. Request granted. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 4/29/2022) (jca)
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Filing 49
JOINT LETTER MOTION for Extension of Time to File protocol for electronic discovery addressed to Magistrate Judge Robert W. Lehrburger from Stephanie L. Denker dated April 29, 2022. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 48
MEMORANDUM OF LAW in Support re: #46 MOTION to Dismiss Amended Counterclaim. . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 47
DECLARATION of Peter Bayard in Support re: #46 MOTION to Dismiss Amended Counterclaim.. Document filed by MSR Trust. (Attachments: #1 Exhibit 1).(Denker, Stephanie)
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Filing 46
MOTION to Dismiss Amended Counterclaim. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 45
ORDER denying as moot #38 Motion to Dismiss. In light of MSR's withdrawal of its initial motion papers and intent to file new motion papers based on Nationstar's amended pleading, the motion at Dkt. 38 is denied as moot. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 4/14/2022) (mml)
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Filing 44
LETTER addressed to Magistrate Judge Robert W. Lehrburger from Amy Kline dated April 14, 2022 re: Withdrawal of initial motion papers and plan to file revised motion. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 43
AMENDED ANSWER to., COUNTERCLAIM against MSR Trust. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Braunstein, Andrew)
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Filing 42
MEMO ENDORSEMENT on re: #41 Letter filed by MSR Trust. ENDORSEMENT: SO ORDERED. ( Amended Pleadings due by 5/24/2022., Deposition due by 12/16/2022., Expert Discovery due by 3/16/2023., Fact Discovery due by 12/16/2022., Joinder of Parties due by 4/11/2022., Motions due by 4/24/2023., Proposed Pretrial Order due by 4/24/2023.) (Signed by Magistrate Judge Robert W. Lehrburger on 3/28/2022) (ate)
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Filing 41
JOINT LETTER addressed to Magistrate Judge Robert W. Lehrburger from Stephanie L. Denker dated March 25, 2022 re: Calendar dates for all remaining deadlines. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 40
ORDER: Plaintiff has filed a motion to dismiss Defendant's counterclaim. By March 31, 2022, Defendant shall file either (1) an amended counterclaim addressing Plaintiffs concerns, or (2) a letter stating that notwithstanding Plaintiff's motion to dismiss, Defendant opts not to file an amended counterclaim. If Defendant does not file an amended counterclaim, and in the event the Court determines dismissal of the counterclaim is merited, then Defendant will not be given an opportunity to amend. If Defendant does not file an amended counterclaim, it shall file its brief in opposition to the motion to dismiss by April 14, 2022, and Plaintiff shall file a reply, if any, by April 28, 2022. If Defendant does file an amended counterclaim, then by April 14, 2022, Plaintiff shall file a letter stating whether Plaintiff (1) withdraws its motion to amend, or (2) stands on its initial motion papers, or (3) withdraws its initial motion papers and plans to file revised motion papers in light of the amended counterclaim. If Plaintiff stands on its initial motion papers, then Defendant's opposition shall be filed by April 28, 2022, and Plaintiff shall file its reply, if any, by May 12, 2022. If Plaintiff plans to file revised motion papers, then the motion papers shall be filed by April 28, 2022, opposition shall be filed by May 26, 2022, and a reply, if any, shall be filed by June 9, 2022. SO ORDERED. Motions due by 4/28/2022. Responses due by 5/26/2022 Replies due by 6/9/2022. Copies transmitted this date to all counsel of record. (Signed by Magistrate Judge Robert W. Lehrburger on 3/17/2022) (mml)
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Filing 39
MEMORANDUM OF LAW in Support re: #38 MOTION to Dismiss Counterclaim. . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 38
MOTION to Dismiss Counterclaim. Document filed by MSR Trust. Responses due by 3/30/2022.(Denker, Stephanie)
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Filing 37
ORDER: As an answer was filed on February 23, 2022, and the case deadlines are keyed off the answer, by March 25, 2022, the parties shall jointly file a letter setting out actual calendar dates for all remaining deadlines. SO ORDERED. Copies transmitted this date to all counsel of record. (Signed by Magistrate Judge Robert W. Lehrburger on 3/16/2022) Copies Sent By Chambers. (vfr)
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Filing 36
ANSWER to Complaint., COUNTERCLAIM against MSR Trust. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Braunstein, Andrew)
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Filing 35
MEMORANDUM DECISION AND ORDER: Adopting REPORT AND RECOMMENDATION for #31 Report and Recommendation. Magistrate Judge Lehrburger's Report is ADOPTED. Plaintiff's Motion to Remand, (ECF. No. 11), is DENIED. The Clerk of the Court is directed to close Plaintiff's motion, accordingly. SO ORDERED. (Signed by Judge George B. Daniels on 2/09/2022) (ama)
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Filing 34
JOINT LETTER addressed to Judge George B. Daniels from Stephanie L. Denker dated January 28, 2022 re: Report and Recommendation on the Motion to Remand. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 33
MEMO ENDORSEMENT on re: #32 Letter filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. ENDORSEMENT: The parties' interpretation is correct. SO ORDERED. (Signed by Magistrate Judge Robert W. Lehrburger on 9/29/2021) (mml)
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Filing 32
LETTER addressed to Judge George B. Daniels from Joseph N. Froehlich dated 09/27/2021 re: Clarification of Deadline to Respond to Complaint. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 31
REPORT AND RECOMMENDATION TO HON. GEORGE B. DANIELS: MOTION TO REMAND re: #11 MOTION to Remand to State Court filed by MSR Trust. For the foregoing reasons, the Court recommends that the motion to remand be DENIED. To the extent not addressed above, the Court has considered MSR Trust's arguments and finds them to be without merit. Objections to R&R due by 9/29/2021. (Signed by Magistrate Judge Robert W. Lehrburger on 9/15/2021) Copies transmitted this date to all counsel of record. (mml)
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Filing 30
LETTER addressed to Magistrate Judge Robert W. Lehrburger from Stephanie L. Denker dated July 7, 2021 re: Trust Agreement of MSR Trust. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 29
NOTICE of Hearing: Oral Argument set for 8/12/2021 at 9:30 AM in Courtroom 18D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Robert W. Lehrburger. Parties are instructed to review and adhere to Judge Lehrburger's individual rules and practices. (rsh)
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Filing 28
CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to a trial before a Magistrate Judge at this time. The case is not to be tried to a jury. The parties anticipate that the trial of this case will require 7 days. (As further set forth in this Order.) (Signed by Magistrate Judge Robert W. Lehrburger on 7/6/2021) (cf)
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Minute Entry for proceedings held before Magistrate Judge Robert W. Lehrburger: Initial Pretrial Conference held on 7/6/2021 at 10:30 a.m. (rsh)
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Filing 27
PROPOSED CASE MANAGEMENT PLAN. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 26
NOTICE of Hearing: Initial Pretrial Conference set for 7/6/2021 at 10:30 AM before Magistrate Judge Robert W. Lehrburger. Parties shall call the teleconference number at (888)-398-2342, and enter access code 9543348. Counsel shall jointly complete and file Judge Lehrburger's [Proposed] Civil Case Management Plan and Scheduling Order, which must be submitted in compliance with Judge Lehrburger's Individual Practices no later than one week before the initial case management conference. If suitable for the case, the parties are encouraged to use Judge Lehrburger's model Joint Electronic Discovery Submission and Proposed Order. These forms are available on the SDNY website at http://nysd.uscourts.gov/judge/Lehrburger.(rsh)
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Filing 25
ORDER: The July 8, 2021 initial conference is cancelled, in light of this Court's referral to Magistrate Judge Lehrburger for General Pretrial, Specific Non-Dispositive Disputes, and Dispositive Motions. SO ORDERED. (Signed by Judge George B. Daniels on 6/16/2021) (ama)
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Filing 24
ORDER OF REFERENCE TO A MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement), Dispositive Motion (i.e., motion requiring a Report and Recommendation) and Specific Non-Dispositive Motion/Dispute: Motion to Remand (ECF No. 11). Referred to Magistrate Judge Robert W. Lehrburger. SO ORDERED. Motions referred to Robert W. Lehrburger. (Signed by Judge George B. Daniels on 6/16/2021) (ama)
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Filing 23
REPLY MEMORANDUM OF LAW in Support re: #11 MOTION to Remand to State Court . . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 22
ORDER ADMITTING AMY S. KLINE PRO HAC VICE granting #21 Motion for Amy S. Kline to Appear Pro Hac Vice. (Signed by Judge George B. Daniels on 6/1/2021) (mro)
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Filing 21
MOTION for Amy S. Kline to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24595072. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MSR Trust. (Attachments: #1 Affidavit of Amy S. Kline, #2 Exhibit Certificates of Good Standing, #3 Text of Proposed Order).(Kline, Amy)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #21 MOTION for Amy S. Kline to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24595072. 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 20
LETTER addressed to Judge George B. Daniels from Joseph N. Froehlich dated May 24, 2021 re: requesting oral argument in connection with Plaintiff's motion to remand. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 19
MEMORANDUM OF LAW in Opposition re: #11 MOTION to Remand to State Court . . Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 18
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Nationstar Mortgage Holdings Inc., Corporate Parent Nationstar Sub1 LLC, Corporate Parent Nationstar Sub2 LLC, Corporate Parent Mr. Cooper Group Inc. for Nationstar Mortgage LLC d/b/a Mr. Cooper. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 17
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Natixis S.A., Corporate Parent Natixis North America LLC, Corporate Parent CM REO Holdings Trust, Corporate Parent Natixis Real Estate Holdings LLC f/k/a Natixis Real Estate Capital, Inc., Other Affiliate Groupe BPCE for MSR Trust. Document filed by MSR Trust..(Denker, Stephanie)
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Filing 16
MEMO ENDORSEMENT on re: #15 Letter filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. ENDORSEMENT: SO ORDERED. (Signed by Judge George B. Daniels on 5/13/2021) (mro)
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney Stephanie L Denker to RE-FILE Document #13 Rule 7.1 Corporate Disclosure Statement. ERROR(S): Not All Corporate Parents/Other affiliates were added. Please re-file this document and when prompted: Are there any corporate parents or other affiliates?, select the YES radio button and enter the Corporate Parent(s) or Affiliate(s). (ldi)
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Filing 15
LETTER addressed to Judge George B. Daniels from Joseph N. Froehlich dated May 12, 2021 re: Request for extension of time to respond to complaint. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Braunstein, Andrew)
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Filing 14
ORDER FOR ADMISSION PRO HAC VICE granting #9 Motion for Thomas George Yoxall to Appear Pro Hac Vice. (Signed by Judge George B. Daniels on 5/12/2021) (mro)
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Filing 13
FILING ERROR - NOT ALL CORPORATE PARENTS/OTHER AFFILIATES WERE ADDED - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Natixis S.A., Corporate Parent Natixis North America LLC, Corporate Parent Natixis Real Estate Holdings LLC, Corporate Parent CM REO Holdings Trust for MSR Trust. Document filed by MSR Trust..(Denker, Stephanie) Modified on 5/13/2021 (ldi).
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Filing 12
MEMORANDUM OF LAW in Support re: #11 MOTION to Remand to State Court . . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 11
MOTION to Remand to State Court . Document filed by MSR Trust..(Denker, Stephanie)
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Filing 10
NOTICE OF APPEARANCE by Stephanie L Denker on behalf of MSR Trust..(Denker, Stephanie)
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Filing 9
MOTION for Thomas George Yoxall to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. (Attachments: #1 Affidavit, #2 Certificate of Good Standing, #3 Text of Proposed Order).(Yoxall, Thomas)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #9 MOTION for Thomas George Yoxall 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. (vba)
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Filing 8
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Thomas G. Yoxall to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number BNYSDC-24451762. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. (Attachments: #1 Affidavit, #2 Certificate of Good Standing, #3 Text of Proposed Order).(Yoxall, Thomas) Modified on 4/26/2021 (wb).
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #8 MOTION for Thomas G. Yoxall to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number BNYSDC-24451762. 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 Texas;. 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 7
MEMO ENDORSEMENT on re: #6 Letter filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. ENDORSEMENT: SO ORDERED. Nationstar Mortgage LLC d/b/a Mr. Cooper answer due 5/17/2021. (Signed by Judge George B. Daniels on 4/15/2021) (kv)
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Filing 6
LETTER addressed to Judge George B. Daniels from Joseph N. Froehlich dated April 14, 2021 re: Extension of time to respond to complaint. Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper..(Froehlich, Joseph)
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Filing 5
INITIAL PRETRIAL CONFERENCE: Initial Conference set for 7/8/2021 at 09:30 AM in Courtroom 11A at the United States District Courthouse, 500 Pearl Street, New York, NY 10007 before Judge George B. Daniels. (Signed by Judge George B. Daniels on 4/12/2021) (mro)
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Filing 4
NOTICE OF APPEARANCE by Joseph Nicholas Froehlich on behalf of Nationstar Mortgage LLC d/b/a Mr. Cooper. (Attachments: #1 Affidavit Certificate of Service).(Froehlich, Joseph)
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge George B. Daniels. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. 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 #https://nysd.uscourts.gov/rules/ecf-related-instructions..(pc)
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Magistrate Judge Robert W. Lehrburger 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: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (pc)
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Case Designated ECF. (pc)
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Filing 3
CIVIL COVER SHEET filed..(Braunstein, Andrew)
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Filing 2
FILING ERROR - DEFICIENT PLEADING - PDF ERROR - CIVIL COVER SHEET filed..(Braunstein, Andrew) Modified on 4/12/2021 (pc).
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Filing 1
NOTICE OF REMOVAL from Supreme Court, County of New York. Case Number: 651520/2021. (Filing Fee $ 402.00, Receipt Number ANYSDC-24376104).Document filed by Nationstar Mortgage LLC d/b/a Mr. Cooper. (Attachments: #1 Exhibit Copy of Process, Pleadings, and Orders as required by 28 U.S.C. 1446).(Braunstein, Andrew)
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| Defendant: Nationstar Mortgage LLC d/b/a Mr. Cooper | |
| Represented By: | Andrew Max Braunstein |
| Represented By: | Joseph Nicholas Froehlich |
| Represented By: | Thomas G Yoxall |
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| Plaintiff: MSR Trust | |
| Represented By: | Amy S. Kline |
| Represented By: | Stephanie L Denker |
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