Hine et al v. Iowa Stubborn Limited Liability Company et al
Plaintiff: Clay Hine, David Calland, Kirk Young and Tim Reynolds
Defendant: Iowa Stubborn Limited Liability Company, Alchemy Production Group Limited Liability Company, Marshall B. Purdy, Carl Pasbjerg and Kate Horton
Case Number: 1:2022cv01636
Filed: February 28, 2022
Court: US District Court for the Southern District of New York
Presiding Judge: Ronnie Abrams
Nature of Suit: Labor: Labor/Mgt. Relations
Cause of Action: 28 U.S.C. § 1441 nr Notice of Removal
Jury Demanded By: None
Docket Report

This docket was last retrieved on September 9, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
July 6, 2022 Opinion or Order Filing 24 SETTLEMENT CONFERENCE ORDER: A settlement conference is scheduled for Wednesday, September 7, 2022, at 10:00 a.m., and will be held telephonically. The Court will provide dial-in information by email before the conference. The parties are directed to review and comply with the Procedures for Cases Referred for Settlement to Magistrate Judge Sarah Netburn, a copy of which is available on the Court's website at https://nysd.uscourts.gov/hon-sarah-netburn. The parties are strongly encouraged to engage in good-faith settlement negotiations before the settlement conference and preferably before the submission to the Court of the Ex Parte Settlement Letters and Acknowledgment Forms, which are to be submitted by Wednesday, August 31, 2022. Should the parties resolve the litigation before the conference date, they must notify the Court in writing immediately. (Settlement Conference set for 9/7/2022 at 10:00 AM before Magistrate Judge Sarah Netburn.) (Signed by Magistrate Judge Sarah Netburn on 7/6/2022) (ras)
May 24, 2022 Opinion or Order Filing 23 ORDER: On May 23, 2022, the Honorable Ronnie Abrams assigned this matter to my docket for settlement. By May 31, 2022, the parties are directed to email Courtroom Deputy Rachel Slusher at Rachel_Slusher@nysd.uscourts.gov with three mutually convenient dates to schedule a settlement conference. Due to the Court's busy calendar, settlement conferences must generally be scheduled at least four to six weeks in advance. The Court will likely be unable to accommodate last-minute requests for settlement conferences. (Signed by Magistrate Judge Sarah Netburn on 5/24/2022) (ras)
May 23, 2022 Opinion or Order Filing 22 ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Settlement. Referred to Magistrate Judge Sarah Netburn. (Signed by Judge Ronnie Abrams on 5/23/2022) (mml)
May 20, 2022 Minute Entry for proceedings held before Judge Ronnie Abrams: Initial Pretrial Conference held on 5/20/2022. (arc)
May 13, 2022 Filing 21 JOINT LETTER addressed to Judge Ronnie Abrams from Leslie Ben-Zvi & Jonathan Gartner dated May 13, 2022 re: Per Order. Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
May 13, 2022 Filing 20 PROPOSED SCHEDULING ORDER. Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
May 2, 2022 Filing 19 REPLY MEMORANDUM OF LAW in Support re: #6 MOTION to Dismiss . . Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Lebowich, Michael)
April 11, 2022 Filing 18 FIRST MEMORANDUM OF LAW in Opposition re: #6 MOTION to Dismiss . . Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
April 11, 2022 Filing 17 DECLARATION of Clay Hine in Opposition re: #6 MOTION to Dismiss .. Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young. (Attachments: #1 Exhibit A1 - Clay Hine Deal Memo 11-12-20, #2 Exhibit A2 - David Calland Deal Memo 11-12-20, #3 Exhibit A3 - Kirk Young Deal Memo 11-12-20, #4 Exhibit A4 - Tim Reynolds Deal Memo 11-12-20, #5 Exhibit B - Actors' Equity Association Agreement and Rules Governing Emil, #6 Exhibit C1 - Pasbjerg email to Kirk Young 6-17-21, #7 Exhibit C2 - Pasbjerg email to Tim Reynolds emails 6-22-21 & 6-17-21, #8 Exhibit C3 - Carl Pasbjerg to Clay Hine Termination ltr (not email) 6-17-21, #9 Exhibit C4 - Carl Pasbjerg to David Calland Termination ltr (not email) 6-17-21, #10 Exhibit C5 - Carl Pasbjerg to Kirk Young Termination ltr (not email) 6-17-21, #11 Exhibit C6 - Carl Pasbjerg to TIm Rreynolds Termination ltr (not email) 6-17-21, #12 Exhibit D - LBZ to Carl Pasbjerg 9-13-21 FINAL, #13 Exhibit E - Termination Letter 9-14-21, #14 Exhibit F1 - David Calland Deal Memo 11.23.19, #15 Exhibit F2 - Kirk Young Deal Memo 11.23.19, #16 Exhibit G1 - Pasbjerg to Calland w-Equity Contract 9-10-21, #17 Exhibit G2 - Pasbjerg to Hine w-Equity Contract 9-10-21, #18 Exhibit G3 - Pasbjerg to Reynolds w-Equity Contract 9-10-21, #19 Exhibit G4 - Pasbjerg to Young w-Equity Contract 9-10-21, #20 Exhibit H1 - TMM - Clay Hine AEA Agmt (9.7.21) - PE for signature, #21 Exhibit H2 - TMM - David Calland AEA Agmt (9.7.21) - PE.for.signature, #22 Exhibit H3 - TMM - Kirk Young AEA Agmt (9.7.21) - PE.for.signature, #23 Exhibit H4 - TMM - Tim Reynolds AEA Agmt (9.7.21) - PE.for.signature, #24 Exhibit I - Verified Complaint - 650418/2022).(Ben-Zvi, Leslie)
April 11, 2022 Filing 16 DECLARATION of Andrea Hoeschen in Opposition re: #6 MOTION to Dismiss .. Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
March 22, 2022 Opinion or Order Filing 15 ORDER granting #14 Letter Motion for Extension of Time to File Response/Reply re #14 FIRST LETTER MOTION for Extension of Time to File Response/Reply as to #7 Memorandum of Law in Support of Motion, #6 MOTION to Dismiss ., #8 Declaration in Support of Motion,, on consent addressed to Judge Ronnie Abrams. Application granted. The Court hereby adopts the parties' proposed briefing schedule. The initial conference is hereby adjourned to May 20, 2022 at 11:45 a.m. This conference will be held via telephone. The parties shall use the following dial-in information to call in to the conference: Call-in Number: (888) 363-4749; Access Code: 1015508. The parties' joint letter shall be filed on or before May 13, 2022. See Dkt. 11. Responses due by 4/11/2022. Replies due by 5/2/2022. (Signed by Judge Ronnie Abrams on 3/22/2022) (ate)
March 22, 2022 Set/Reset Hearings: Initial Conference set for 5/20/2022 at 11:45 AM before Judge Ronnie Abrams. (ate)
March 21, 2022 Filing 14 FIRST LETTER MOTION for Extension of Time to File Response/Reply as to #7 Memorandum of Law in Support of Motion, #6 MOTION to Dismiss ., #8 Declaration in Support of Motion,, on consent addressed to Judge Ronnie Abrams from Leslie Ben-Zvi dated 3-18-22. Document filed by David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
March 21, 2022 Filing 13 NOTICE OF APPEARANCE by Leslie Haim Ben-Zvi on behalf of David Calland, Clay Hine, Tim Reynolds, Kirk Young..(Ben-Zvi, Leslie)
March 18, 2022 Filing 12 CERTIFICATE OF SERVICE of Order and Notice of Initial Conference [Dkt. No. 11] served on Leslie H. Ben-Zvi, Esq, counsel of record for Plaintiffs' Clay Hine, David Calland, Kirk Young, and Tim Reynolds on March 15, 2022. Service was made by Email upon Plaintiffs' Counsel (Leslie@BenZviLaw.com). Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Gartner, Jonathan)
March 14, 2022 Opinion or Order Filing 11 ORDER AND NOTICE OF INITIAL CONFERENCE: IT IS FURTHER ORDERED that counsel for all parties appear for an initial status conference on April 22, 2022 at 12:00 p.m. This conference will be held via telephone. The parties shall use the following dial-in information to call in to the conference: Call-in Number: (888) 363-4749; Access Code: 1015508. Initial Conference set for 4/22/2022 at 12:00 PM before Judge Ronnie Abrams. (Signed by Judge Ronnie Abrams on 3/14/2022) (ate)
March 9, 2022 Filing 10 CERTIFICATE OF SERVICE of Defendants Notice of Motion to Dismiss Plaintiffs Complaint [Dkt. No. 6]; (2) Defendants Memorandum of Law in Support of Motion to Dismiss [Dkt. No. 7]; and (3) Declaration of Carl Pasbjerg in Support of Motion to Dismiss [Dkt. No. 8] and exhibits 1 through 5 served on Plaintiffs Clay Hine, David Calland, Kirk Young, and Tim Reynolds on 3/8/2022. Service was accepted by Leslie H. Ben-Zvi, Esq, counsel of record for Plaintiffs. Service was made by Email and FedEx Overnight Delivery. Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Gartner, Jonathan)
March 9, 2022 Filing 9 NOTICE OF APPEARANCE by Jonathan Reuven Gartner on behalf of Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Gartner, Jonathan)
March 7, 2022 Filing 8 DECLARATION of Carl Pasbjerg in Support re: #6 MOTION to Dismiss .. Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy. (Attachments: #1 Exhibit 1: Actors' Equity Association Agreement and Rules Governing Employment under the Equity/League Production Contract, #2 Exhibit 2: Deal Term Memorandums dated 11/12/2020, #3 Exhibit 3: Actors' Equity Association Standard Minimum Production Contracts sent 9/10/2021, #4 Exhibit 4: Plaintiffs' Counsel Leslie Ben-Zvi Letter dated 7/6/2021, #5 Exhibit 5: Plaintiffs' Counsel Leslie Ben-Zvi Letter dated 9/13/2021).(Lebowich, Michael)
March 7, 2022 Filing 7 MEMORANDUM OF LAW in Support re: #6 MOTION to Dismiss . . Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Lebowich, Michael)
March 7, 2022 Filing 6 MOTION to Dismiss . Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Lebowich, Michael)
March 3, 2022 Filing 5 CERTIFICATE OF SERVICE of (1) Defendants Notice of Removal and exhibits filed in connection therewith [Dkt. Nos 1, 1-1, 1-2, and 1-3]; (2) Civil Cover Sheet for this Action [Dkt. No. 2]; (3) Rule 7.1 Statements of Defendants Alchemy Production Group Limited Liability Company [Dkt. No. 3] and Iowa Stubborn Limited Liability Company [Dkt. No.4]; (4) the Individual Rules and Practices in Civil Cases for Judge Ronnie Abrams; (4) the Individual Practices in Civil Cases for Magistrate Judge Sarah Netburn; and (5) this Courts Electronic Case Filing Rules & Instructions served on Plaintiffs' Counsel, Leslie Ben-Zvi, Esq. Feldman, Golinski, Reedy + Ben-Zvi PLLC on March 3, 2022. Service was made by Email and FedEx Overnight Delivery. Document filed by Alchemy Production Group Limited Liability Company, Kate Horton, Iowa Stubborn Limited Liability Company, Carl Pasbjerg, Marshall B. Purdy..(Gartner, Jonathan)
March 1, 2022 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Ronnie Abrams. 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..(gp)
March 1, 2022 Magistrate Judge Sarah Netburn is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (gp)
March 1, 2022 Case Designated ECF. (gp)
February 28, 2022 Filing 4 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Arrow Theatrical LLC, Other Affiliate Ithaka Theatrical LLC for Iowa Stubborn Limited Liability Company. Document filed by Iowa Stubborn Limited Liability Company..(Lebowich, Michael)
February 28, 2022 Filing 3 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent One Viking Productions, Inc. for Alchemy Production Group Limited Liability Company. Document filed by Alchemy Production Group Limited Liability Company..(Lebowich, Michael)
February 28, 2022 Filing 2 CIVIL COVER SHEET filed..(Lebowich, Michael)
February 28, 2022 Filing 1 NOTICE OF REMOVAL from Supreme Court, County of New York. Case Number: 650418/2022. (Filing Fee $ 402.00, Receipt Number ANYSDC-25788050).Document filed by Alchemy Production Group Limited Liability Company, Marshall B. Purdy, Kate Horton, Carl Pasbjerg, Iowa Stubborn Limited Liability Company. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3).(Lebowich, Michael)

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Search for this case: Hine et al v. Iowa Stubborn Limited Liability Company et al
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Plaintiff: Clay Hine
Represented By: Leslie Haim Ben-Zvi
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Plaintiff: David Calland
Represented By: Leslie Haim Ben-Zvi
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Plaintiff: Kirk Young
Represented By: Leslie Haim Ben-Zvi
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Plaintiff: Tim Reynolds
Represented By: Leslie Haim Ben-Zvi
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Defendant: Iowa Stubborn Limited Liability Company
Represented By: Michael J Lebowich
Represented By: Jonathan Reuven Gartner
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Defendant: Alchemy Production Group Limited Liability Company
Represented By: Michael J Lebowich
Represented By: Jonathan Reuven Gartner
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Defendant: Marshall B. Purdy
Represented By: Michael J Lebowich
Represented By: Jonathan Reuven Gartner
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Defendant: Carl Pasbjerg
Represented By: Michael J Lebowich
Represented By: Jonathan Reuven Gartner
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Defendant: Kate Horton
Represented By: Michael J Lebowich
Represented By: Jonathan Reuven Gartner
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