Mercury Public Affairs LLC et al v. Nunez et al
Plaintiff: Mercury Public Affairs LLC and MPA Holdings Inc.
Defendant: Fabian Nunez and Kirill Goncharenko
Case Number: 1:2021cv08300
Filed: October 7, 2021
Court: US District Court for the Southern District of New York
Presiding Judge: Vernon S Broderick
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332 jd Diversity-Declaratory Judgement
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on November 3, 2021. A more recent docket listing may be available from PACER.

Date Filed Document Text
November 3, 2021 Filing 22 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, without prejudice and without costs against the defendant(s) Kirill Goncharenko, Fabian Nunez. Document filed by Mercury Public Affairs LLC, MPA Holdings Inc.. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Hammel, Jeff)
November 1, 2021 Opinion or Order Filing 21 ORDER granting #19 Motion for Ashlee Lin to Appear Pro Hac Vice (HEREBY ORDERED by Judge Vernon S. Broderick)(Text Only Order) (msa)
November 1, 2021 Opinion or Order Filing 20 ORDER granting #18 Motion for Jeremiah Reynolds to Appear Pro Hac Vice (HEREBY ORDERED by Judge Vernon S. Broderick)(Text Only Order) (msa)
October 29, 2021 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #19 MOTION for Ashlee Lin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25255823. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies. (aea)
October 28, 2021 Filing 19 MOTION for Ashlee Lin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25255823. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Kirill Goncharenko, Fabian Nunez. (Attachments: #1 Declaration, #2 Exhibit A, #3 Proposed Order).(Lin, Ashlee)
October 28, 2021 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #18 MOTION for Jeremiah Reynolds to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25253349. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
October 27, 2021 Filing 18 MOTION for Jeremiah Reynolds to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25253349. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Kirill Goncharenko, Fabian Nunez. (Attachments: #1 Declaration, #2 Exhibit A, #3 Proposed Order).(Reynolds, Jeremiah)
October 14, 2021 Opinion or Order Filing 17 ORDER granting #11 Motion for Sarah F. Mitchell to Appear Pro Hac Vice (HEREBY ORDERED by Judge Vernon S. Broderick)(Text Only Order) (msa)
October 14, 2021 Opinion or Order Filing 16 ORDER: Accordingly, it is hereby: ORDERED that Plaintiffs shall file any amended complaint by November 3, 2021. It is unlikely that Plaintiff will have a further opportunity to amend. IT IS FURTHER ORDERED that if no amended complaint is filed, Plaintiffs shall serve any opposition to the motion to dismiss by November 12, 2021. Defendants' reply, if any, shall be served by November 26, 2021. SO ORDERED. (Signed by Judge Vernon S. Broderick on 10/14/2021) ( Amended Pleadings due by 11/3/2021.) (ks)
October 14, 2021 Opinion or Order Filing 15 ORDER granting #10 Motion for Nima H. Mohebbi to Appear Pro Hac Vice (HEREBY ORDERED by Judge Vernon S. Broderick)(Text Only Order) (msa)
October 14, 2021 Opinion or Order Filing 14 ORDER granting #9 Motion for Joseph B. Farrell to Appear Pro Hac Vice (HEREBY ORDERED by Judge Vernon S. Broderick)(Text Only Order) (msa)
October 13, 2021 Filing 13 MEMORANDUM OF LAW in Support re: #12 FIRST MOTION to Dismiss for Lack of Jurisdiction . . Document filed by Kirill Goncharenko, Fabian Nunez..(Miller, Simon)
October 13, 2021 Filing 12 FIRST MOTION to Dismiss for Lack of Jurisdiction . Document filed by Kirill Goncharenko, Fabian Nunez. (Attachments: #1 Affidavit Declaration of Simon Miller, #2 Exhibit Ex. A -- Complaint, #3 Exhibit Ex. B -- Nunez/Goncharenko CA Complaint, #4 Exhibit Ex. C -- High Stakes CA Complaint, #5 Affidavit Declaration of Kirill Goncharenko, #6 Exhibit Ex. 1 -- Goncharenko Employment Agreement, #7 Exhibit Ex. 2 -- MPA Operating Agreement, #8 Exhibit Ex. 3 -- Oct. 1, 2021 Letter to Kieran Mahoney, #9 Exhibit Ex. 4 -- Oct. 8, 2021 Letter to J. Davis, #10 Exhibit Ex. 5 -- Second Amended and Restated Limited Liability Agreement of High Stakes Co. LLC, #11 Exhibit Ex. 6 -- Amendment to Second Amended and Restated Limited Liability Company Agreement of High Stakes Co. LLC, #12 Affidavit Declaration of Fabian Nunez, #13 Ex. 7 -- Nunez Employment Agreement).(Miller, Simon)
October 13, 2021 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #11 MOTION for Sarah F. Mitchell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25184295. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
October 13, 2021 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #10 MOTION for Nima H. Mohebbi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25184073. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
October 13, 2021 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #9 MOTION for Joseph B. Farrell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25183701. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
October 12, 2021 Filing 11 MOTION for Sarah F. Mitchell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25184295. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC. (Attachments: #1 Declaration in Support of Motion for Admission Pro Hac Vice, #2 Exhibit A - Certificate of Good Standing, #3 Text of Proposed Order).(Mitchell, Sarah)
October 12, 2021 Filing 10 MOTION for Nima H. Mohebbi to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25184073. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC. (Attachments: #1 Declaration in Support of Motion for Admission Pro Hac Vice, #2 Exhibit A - Certificate of Good Standing, #3 Text of Proposed Order).(Mohebbi, Nima)
October 12, 2021 Filing 9 MOTION for Joseph B. Farrell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-25183701. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC. (Attachments: #1 Declaration in Support of Motion for Admission Pro Hac Vice, #2 Exhibit A - Certificate of Good Standing, #3 Text of Proposed Order).(Farrell, Joseph)
October 12, 2021 Filing 8 NOTICE OF APPEARANCE by Simon Joel Kasha Miller on behalf of Kirill Goncharenko, Fabian Nunez..(Miller, Simon)
October 8, 2021 Filing 7 ELECTRONIC SUMMONS ISSUED as to Kirill Goncharenko. (vf)
October 8, 2021 Filing 6 ELECTRONIC SUMMONS ISSUED as to Fabian Nunez. (vf)
October 8, 2021 ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Jeff G. Hammel. The following case opening statistical information was erroneously selected/entered: County code Albany. The following correction(s) have been made to your case entry: the County code has been modified to XX Out of State. (vf)
October 8, 2021 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Vernon S. Broderick. 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..(vf)
October 8, 2021 Case Designated ECF. (vf)
October 8, 2021 Magistrate Judge James L. Cott 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. (vf)
October 7, 2021 Filing 5 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Omnicom Group Inc. for MPA Holdings Inc., Mercury Public Affairs LLC. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC..(Hammel, Jeff)
October 7, 2021 Filing 4 REQUEST FOR ISSUANCE OF SUMMONS as to Kirill Goncharenko, re: #1 Complaint,,,. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC..(Hammel, Jeff)
October 7, 2021 Filing 3 REQUEST FOR ISSUANCE OF SUMMONS as to Fabian Nunez, re: #1 Complaint,,,. Document filed by MPA Holdings Inc., Mercury Public Affairs LLC..(Hammel, Jeff)
October 7, 2021 Filing 2 CIVIL COVER SHEET filed..(Hammel, Jeff)
October 7, 2021 Filing 1 COMPLAINT against Kirill Goncharenko, Fabian Nunez. (Filing Fee $ 402.00, Receipt Number ANYSDC-25167267)Document filed by Mercury Public Affairs LLC, MPA Holdings Inc.. (Attachments: #1 Exhibit A - 2013 Mercury LLC Agreement, #2 Exhibit B - 2017 Amendment, #3 Exhibit C - 2017 NewCo Agreement, #4 Exhibit D - Goncharenko Employment Agreement, #5 Exhibit E - Nunez Employment Agreement, #6 Exhibit F - Goncharenko 2008 PCA, #7 Exhibit G - Goncharenko 2013 PCA, #8 Exhibit H - Goncharenko 2015 PCA, #9 Exhibit I - Nunez 2013 PCA, #10 Exhibit J - Nunez 2015 PCA, #11 Exhibit K - NewCo New Jersey LLC APA, #12 Exhibit L - Actum I LLC California Registration Form, #13 Exhibit M - Goncharenko, Nunez, Actum First Amended Complaint, #14 Exhibit N - LA Times Article).(Hammel, Jeff)

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Plaintiff: Mercury Public Affairs LLC
Represented By: Jeff G. Hammel
Represented By: Joseph Farrell
Represented By: Nima Mohebbi
Represented By: Sarah F Mitchell
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Plaintiff: MPA Holdings Inc.
Represented By: Jeff G. Hammel
Represented By: Joseph Farrell
Represented By: Nima Mohebbi
Represented By: Sarah F Mitchell
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Defendant: Fabian Nunez
Represented By: Jeremiah T. Reynolds
Represented By: Simon Joel Kasha Miller
Represented By: Ashlee Lin
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Defendant: Kirill Goncharenko
Represented By: Jeremiah T. Reynolds
Represented By: Simon Joel Kasha Miller
Represented By: Ashlee Lin
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