Makina Ve Kimya Endustrisi A.S v. A.S.A.P. Logistics LTD et al
Plaintiff: MAKINA VE KIMYA ENDUSTRISI A.S
Defendant: A.S.A.P. LOGISTICS LTD, ASAP LOJISTIK VE SAVUNMA TICARET LIMITED SIRKETI D/B/A ASAP LOGISTICS AND DEFENSE AND/OR ASAP LOGISTICS AND DEFENSE GUVENLIK HIZMETLERI SANAYI VE TICARET LIMITED SIRKETI, TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI D/B/A TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI, Deborah Cross, Guven Acarer, Turker Kucuker, Ilker Kucuker, Asap Lojistik Ve Savunma Ticaret Limited Sirketi doing business as Asap Logistics And Defense And/Or Asap Logistics and Defense Guvenlik Hizmetleri Sanayi Ve Ticaret Limited Sirketi, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi doing business as Turkkey Capital Kurmsal Finans Cozumleri Limited Sirketi, Metin Nerkis and ASAP Logistics and Defense Security Services Ltd.
Cross Defendant: Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi
Cross Claimant: Asap Lojistik Ve Savunma Ticaret Limited Sirketi
Case Number: 1:2022cv03933
Filed: May 13, 2022
Court: US District Court for the Southern District of New York
Presiding Judge: Paul G Gardephe
Nature of Suit: Trademark
Cause of Action: 15 U.S.C. § 1125 la Trademark Infringement (Lanham Act)
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on August 30, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 13, 2023 Filing 152 MOTION for Daniel A. Schnapp to Withdraw as Attorney . Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
June 13, 2023 Opinion or Order Filing 151 ORDER FOR ADMISSION PRO HAC VICE granting #148 Motion for William M. Kirby to Appear Pro Hac Vice. (Signed by Judge Paul G. Gardephe on 6/13/2023) (ks)
June 13, 2023 Opinion or Order Filing 150 ORDER: The application is granted as set forth below: Fact discovery, including depositions, will be completed by August 11, 2023. By September 8, 2023, all counsel will meet face-to-face for at least one hour to discuss settlement. Party-proponents that intend to offer expert testimony in respect of a claim must make the disclosures required by Federal Rule of Civil Procedure 26(a)(2) by August 25, 2023. Party-opponents of such claim that intend to offer expert testimony in respect of such claim must make the disclosures required by Federal Rule of Civil Procedure 26(a)(2) by September 22, 2023. Expert discovery will be completed by October 6, 2023. Any party seeking to file a post-discovery dispositive motion will submit a pre-motion letter in accordance with this Court's Individual Rules, by August 18, 2023. Any opposition letter will be filed by August 23, 2023. The conference currently scheduled for June 16, 2023, is adjourned to August 31, 2023, at 11:00 a.m. SO ORDERED (Signed by Judge Paul G. Gardephe on 6/13/2023) ( Deposition due by 8/11/2023., Expert Discovery due by 10/6/2023., Fact Discovery due by 8/11/2023., Case Management Conference set for 8/31/2023 at 11:00 AM before Judge Paul G. Gardephe.) (ks)
June 12, 2023 Filing 149 JOINT LETTER addressed to Judge Paul G. Gardephe from Parties dated June 12, 2023 re: Extension of Discovery Deadlines. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Proposed Order).(Nguyen, Vincent)
June 7, 2023 Filing 148 MOTION for William M. Kirby, Jr. to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27842739. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Affidavit of W. Kirby, #2 Exhibit Certificate of Good Standing, #3 Exhibit Affidavit of Sponsoring Attorney, #4 Text of Proposed Order for Admission Pro Hac Vice).(Kirby, William)
June 7, 2023 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #148 MOTION for William M. Kirby, Jr. to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number ANYSDC-27842739. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies. (va)
February 17, 2023 Opinion or Order Filing 147 ORDER, The application is granted as set forth below: Fact discovery, including depositions, will be completed by June 16, 2023. By June 30, 2023, all counsel will meet face-to-face for at least one hour to discuss settlement. Expert discovery will be completed by July 28, 2023. Any party seeking to file a post-discovery dispositive motion will submit a pre-motion letter in accordance with this Court's Individual Rules, by August 8, 2023. Any opposition letter will be filed by August 11, 2023. The conference currently scheduled for March 16, 2023, is adjourned to June 15, 2023, at 10:00 a.m. SO ORDERED. ( Deposition due by 6/16/2023., Expert Discovery due by 7/28/2023., Fact Discovery due by 6/16/2023., Case Management Conference set for 6/15/2023 at 10:00 AM before Judge Paul G. Gardephe.) (Signed by Judge Paul G. Gardephe on 2/17/23) (yv)
February 13, 2023 Filing 146 LETTER addressed to Judge Paul G. Gardephe from Makina ve Kimya Endustrisi A.S. dated February 13, 2023 re: Ninety Day Extension of Discovery and Pre-Trial Deadlines. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
January 20, 2023 Opinion or Order Filing 145 ORDER GRANTING STIPULATION TO EXTEND DISCOVERY DEADLINES AND RELATED DATES: Plaintiff Makina ve Kimya Endustrisi A.S. ("MKE") and Defendants A.S.A.P. Logistics Ltd., ASAP Logistics and Defense Security Services Ltd., ASAP Lojistik Ve Savunma Ticaret Limited Sirketi, and Deborah Cross (collectively, the "Appearing Parties") hereby jointly request the Court enter the amended scheduling Order, as set forth below: Depositions of FactWitnesses Completion to March 16, 2023; Fact Discovery Completion to March 16, 2023; Expert Discovery Completion to April 18, 2023; as further set forth in this order. AS STIPULATED AND AGREED TO BY THE APPEARING PARTIES, IT IS SO ORDERED. The conference currently scheduled for February 2, 2023, is adjourned to March 16, 2023, at 10:15 a.m. SO ORDERED. (Signed by Judge Paul G. Gardephe on 1/20/2023) ( Deposition due by 3/16/2023., Expert Discovery due by 4/28/2023., Fact Discovery due by 3/16/2023., Case Management Conference set for 3/16/2023 at 10:15 AM before Judge Paul G. Gardephe.) (ks)
January 18, 2023 Filing 144 LETTER addressed to Judge Paul G. Gardephe from Counsel for Plaintiff and Appearing Defendants dated 1/18/2023 re: Second Request for Extension of Discovery Deadlines. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Proposed Order).(Nguyen, Vincent)
December 15, 2022 Opinion or Order Filing 143 STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material...SO ORDERED. (Signed by Judge Paul G. Gardephe on 12/15/2022) (ks)
December 15, 2022 Opinion or Order Filing 142 ORDER: In a December 12, 2022 joint letter, Plaintiff Makina ve Kimya Endustrisi A.S. and Defendants A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., ASAP Lojistik Ve Savunma Ticaret Limited Sirketi, and Deborah Cross request extensions of discovery deadlines and related dates. (Jt. Ltr. (Dkt. No. 140)) The application is granted as set forth below: Fact discovery, including depositions, will be completed by January 30, 2023. By February 13, 2023, all counsel will meet face-to-face for at least one hour to discuss settlement. Party-proponents that intend to offer expert testimony in respect of a claim must make the disclosures required by Federal Rule of Civil Procedure 26(a)(2) by January 30, 2023. Party-opponents of such claim that intend to offer expert testimony in respect of such claim must make the disclosures required by Federal Rule of Civil Procedure 26(a)(2) by February 27, 2023. Expert discovery will be completed by March 16, 2023. Any party seeking to file a post-discovery dispositive motion will submit a pre-motion letter in accordance with this Courts Individual Rules, by March 23, 2023. Any opposition letter will be filed by March 27, 2023. The conference currently scheduled for January 11, 2023, is adjourned to February 2, 2023, at 10:15 a.m. SO ORDERED. (Signed by Judge Paul G. Gardephe on 12/15/2022) ( Deposition due by 1/30/2023., Fact Discovery due by 1/30/2023., Case Management Conference set for 2/2/2023 at 10:15 AM before Judge Paul G. Gardephe.) (ks) Modified on 1/9/2023 (ks).
December 14, 2022 Filing 141 SECOND LETTER addressed to Judge Paul G. Gardephe from Respective Counsel for Plaintiff and Appearing Defendants dated 12/14/2022 re: Stipulated Confidentiality Agreement and Protective Order. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Stipulated Confidentiality Agreement and Protective Order, #2 Exhibit Non-Disclosure Agreement).(Nguyen, Vincent)
December 12, 2022 Filing 140 LETTER addressed to Judge Paul G. Gardephe from Parties dated December 12, 2022 re: Extension of Discovery Deadlines. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Proposed Order).(Nguyen, Vincent)
December 6, 2022 Filing 139 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 11/17/2022 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(McGuirk, Kelly)
December 6, 2022 Filing 138 TRANSCRIPT of Proceedings re: CONFERENCE held on 11/17/2022 before Judge Paul G. Gardephe. Court Reporter/Transcriber: Eve Giniger, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/27/2022. Redacted Transcript Deadline set for 1/6/2023. Release of Transcript Restriction set for 3/6/2023..(McGuirk, Kelly)
December 1, 2022 Opinion or Order Filing 137 MEMO ENDORSEMENT on re: #135 Letter filed by Makina Ve Kimya Endustrisi A.S. ENDORSEMENT: Plaintiff's claims against Defendant Metin Nerkis are dismissed without prejudice. The Clerk of Court is directed not to close this case. SO ORDERED. Metin Nerkis terminated. (Signed by Judge Paul G. Gardephe on 12/1/2022) (vfr)
November 29, 2022 Filing 136 FIRST LETTER addressed to Judge Paul G. Gardephe from Respective Counsel for Plaintiff and Appearing Defendants dated 11/29/2022 re: Protective Order. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Model Protective Order).(Nguyen, Vincent)
November 28, 2022 Filing 135 LETTER addressed to Judge Paul G. Gardephe from Daniel Schnapp dated November 28, 2022 re: Defendant Nerkis. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
November 28, 2022 Filing 134 PROPOSED PROTECTIVE ORDER. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
November 17, 2022 Opinion or Order Filing 133 ORDER granting #98 Motion to Withdraw as Attorney. ; granting #109 Motion for Conference re: #98 MOTION for Richard S. Mandel and Jeremy A. Berman to Withdraw as Attorney ., #109 LETTER MOTION for Conference addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 19, 2022., #128 LETTER MOTION for Leave to File Amended Declaration addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 31, 2022. ; terminating #128 Motion for Leave to File Document. For the reasons stated at today's hearing, Plaintiff's application for a default judgment is denied as to Defendants Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Turker Kucuker, and Ilker Kucuker (Dkt. No. 113), and Plaintiff's application for a preliminary injunction is denied as to Defendants A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., ASAP Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross, and Guven Acarer (Dkt. No. 78). Also for the reasons stated at today's hearing, Cowan, Liebowitz & Latman's motion to withdraw as counsel for Defendant Guven Acarer (Dkt. No. 98), is granted. Defendant Acarer has 30 days to retain new counsel or inform the Court that he will be proceeding pro se. If Defendant Acarer does not retain new counsel within 30 days, the Court will assume that he is proceeding pro se. Cowan, Liebowitz & Latman is directed to transmit a copy of this Order to Defendant Acarer. Plaintiff will submit a letter by November 28, 2022, stating whether Plaintiff will voluntarily dismiss this case as to Defendant Metin Nerkis, and if not, explain why it has a good faith basis to oppose Defendant Nerkis's proposed motion to dismiss. The conference currently scheduled for December 15, 2022 is adjourned to January 11, 2023, at 10:00 a.m. The Clerk of Court is directed to terminate the motions at (Dkt. Nos. 98, 109, 128). SO ORDERED.. (Signed by Judge Paul G. Gardephe on 11/17/2022) Attorney Jeremy Andrew Berman and Richard Stephen Mandel terminated ( Telephone Conference set for 1/11/2023 at 10:00 AM before Judge Paul G. Gardephe.) (ks)
November 17, 2022 Minute Entry for proceedings held before Judge Paul G. Gardephe: Status Conference held on 11/17/2022, ( Status Conference set for 1/11/2022 at 10:00 AM in Courtroom 705, 40 Centre Street, New York, NY 10007 before Judge Paul G. Gardephe.). (Court Reporter Eve Giniger) (mr)
November 10, 2022 Opinion or Order Filing 132 ORDER: This Court will conduct a hearing on November 17, 2022, at 4:00 p.m., concerning (1) Plaintiffs application for an order to show cause seeking a preliminary injunction as to Defendants A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., ASAP Lojistik Ve Savunma Ticaret Limited Sirketi ("ASAP Turkey"), Deborah Cross, and Guven Acarer, preventing the closure of ASAP Turkey and preventing Defendants Cross and Acarer from shutting down or otherwise closing or transferring ownership of ASAP Turkey or any other ASAP entity (Dkt. No. 78); (2) Plaintiffs application for an order to show cause seeking a default judgment against Defendants Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Turker Kucuker, and Ilker Kucuker (Dkt. No. 113); (3) Cowan, Liebowitz & Latman, P.C.'s motion to withdraw as counsel to Defendant Guven Acarer (Dkt. No. 98); and (4) No. 98); and (4) Defendant Metin Nerkis' request for permission to move to dismiss for lack of personal jurisdiction and failure to state a claim (Dkt. No. 109). SO ORDERED. (Signed by Judge Paul G. Gardephe on 11/10/2022) ( Status Conference set for 11/17/2022 at 04:00 PM before Judge Paul G. Gardephe.) (ks)
November 10, 2022 Filing 131 LETTER addressed to Judge Paul G. Gardephe from Richard S. Mandel dated November 10, 2022 re: Motion to Withdraw as Counsel for Guven Acarer. Document filed by Guven Acarer..(Mandel, Richard)
November 9, 2022 Filing 130 MEMORANDUM OF LAW re: #119 Order,, in Support of the Exercise of Personal Jurisdiction Over Turkkey Capital, Turker Kucuker, and Ilker Kucuker. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
November 4, 2022 Filing 129 LETTER addressed to Judge Paul G. Gardephe from Richard S. Mandel dated November 4, 2022 re: Status of Counsel for Guven Acarer. Document filed by Guven Acarer..(Mandel, Richard)
October 31, 2022 Filing 128 LETTER MOTION for Leave to File Amended Declaration addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 31, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross. (Attachments: #1 Exhibit Amended Declaration of Debbie Cross).(Mandel, Richard)
October 28, 2022 Filing 127 AFFIDAVIT OF SERVICE of Answers and Crossclaims served on Ilker Kucuker on October 26, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 28, 2022 Filing 126 AFFIDAVIT OF SERVICE of Answers and Crossclaims served on Turker Kucuker on October 26, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 28, 2022 Filing 125 AFFIDAVIT OF SERVICE of Answers and Crossclaims served on Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi on October 26, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi..(Mandel, Richard)
October 28, 2022 Opinion or Order Filing 124 ORDER granting #121 Letter Motion for Extension of Time to Answer re #121 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022., #122 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move, and Correcting Docket Entry No. 121, addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022., #59 Amended Complaint,,,. Guven Acarer answer due 11/11/2022; granting #122 Letter Motion for Extension of Time to Answer re #121 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022., #122 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move, and Correcting Docket Entry No. 121, addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022. Defendant Acarer's time to answer is extended to November 11, 2022. By November 4, 2022, Defendant Acarer will file a letter updating the Court on his attempts to find replacement counsel. SO ORDERED. Guven Acarer answer due 11/11/2022. (Signed by Judge Paul G. Gardephe on 10/28/2022) (kv)
October 27, 2022 Filing 123 REPLY MEMORANDUM OF LAW in Support re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. re #78 , Reply to [112, 114]. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
October 27, 2022 Filing 122 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move, and Correcting Docket Entry No. 121, addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 27, 2022 Filing 121 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 27, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 26, 2022 Opinion or Order Filing 120 ORDER: For the reasons stated in this Court's July 29, 2022 order (Order (Dkt. No. 32)), the request of Defendants A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross, and Guven Acarer to serve their crossclaims on Defendants Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Turker Kucuker, and Ilker Kucuker via email is granted. Defendants are directed to use the email addresses set forth for those parties in Plaintiff's July 15, 2022 submission. (See (Pltf. Br. (Dkt. No. 29)). SO ORDERED. (Signed by Judge Paul G. Gardephe on 10/26/2022) (ks)
October 26, 2022 Opinion or Order Filing 119 ORDER: Accordingly, this Court will not issue a show cause order as to Defendants Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Turker Kucuker, and Ilker Kucuker, absent evidence that this Court has personal jurisdiction over them. By November 9, 2022, Plaintiff will make a submission demonstrating that this Court has personal jurisdiction over Defendants Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Turker Kucuker, and Ilker Kucuker. Absent such a submission, Plaintiff will show cause why its claims against these Defendants should not be dismissed for lack of personal jurisdiction. SO ORDERED. (Signed by Judge Paul G. Gardephe on 10/26/2022) (ks)
October 25, 2022 Filing 118 LETTER RESPONSE in Opposition to Motion addressed to Judge Paul G. Gardephe from Daniel A. Schnapp dated October 25, 2022 re: #109 LETTER MOTION for Conference addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 19, 2022. . Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
October 20, 2022 Filing 117 PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed Default Judgment to be reviewed by Clerk's Office staff.
October 20, 2022 Filing 116 SUPPLEMENTAL MEMORANDUM OF LAW in Support re: #113 Proposed Order to Show Cause Without Emergency Relief . Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
October 20, 2022 Filing 115 AFFIDAVIT of Vincent D. Nguyen in Support re: #113 Proposed Order to Show Cause Without Emergency Relief. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - First Amended Complaint, #2 Exhibit B - Affidavit of Service of Complaint and Summons, #3 Exhibit C - Affidavit of Service of First Amended Complaint, #4 Exhibit D - Certificates of Default).(Nguyen, Vincent)
October 20, 2022 Filing 114 DECLARATION of Debbie Cross in Opposition re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery.. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 20, 2022 Filing 113 PROPOSED ORDER TO SHOW CAUSE WITHOUT EMERGENCY RELIEF. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
October 20, 2022 Filing 112 MEMORANDUM OF LAW in Opposition re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. . Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 20, 2022 ***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITHOUT EMERGENCY RELIEF. Document No. #113 Proposed Order to Show Cause Without Emergency Relief was reviewed and approved as to form. (nd)
October 20, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED DEFAULT JUDGMENT. Notice to attorney Vincent Nguyen to RE-FILE Document No. #111 Proposed Default Judgment,,. The filing is deficient for the following reason(s): the wrong event type was used to file the proposed order; documents must be filed separately. 1. Re-file the document using the event type Proposed Order to Show Cause Without Emergency Relief found under the event list Proposed Orders. 2. Re-file the Affidavit in support found under the event list Other Answers. 3. Re-file memorandum of law in support found under the event list Other Answers. 4. Re-file Proposed Default Judgment founder under the vent list Proposed Orders. (nd)
October 20, 2022 ***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. #117 Proposed Default Judgment was reviewed and approved as to form. (nd)
October 19, 2022 Filing 111 FILING ERROR - DEFICIENT DOCKET ENTRY - PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Affidavit in Support of Default Judgment, #2 Exhibit First Amended Complaint, #3 Exhibit Affidavit of Service (Complaint and Summons), #4 Exhibit Affidavit of Service (First Amended Complaint), #5 Exhibit Certificates of Default, #6 Supplement Memorandum of Law in support of default judgment, #7 Text of Proposed Order Proposed Order for Default Judgment).(Nguyen, Vincent) Proposed Default Judgment to be reviewed by Clerk's Office staff. Modified on 10/20/2022 (nd).
October 19, 2022 Filing 110 NOTICE OF APPEARANCE by Jeremy Andrew Berman on behalf of Metin Nerkis..(Berman, Jeremy)
October 19, 2022 Filing 109 LETTER MOTION for Conference addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 19, 2022. Document filed by A.S.A.P. Logistics LTD, ASAP Logistics and Defense Security Services Ltd., Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross, Metin Nerkis..(Mandel, Richard)
October 19, 2022 Filing 108 NOTICE OF APPEARANCE by Richard Stephen Mandel on behalf of Metin Nerkis..(Mandel, Richard)
October 17, 2022 Filing 107 LETTER addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 17, 2022 re: Service of Crossclaims. Document filed by ASAP Logistics and Defense Security Services Ltd...(Mandel, Richard)
October 17, 2022 Filing 106 NOTICE OF APPEARANCE by Jeremy Andrew Berman on behalf of ASAP Logistics and Defense Security Services Ltd...(Berman, Jeremy)
October 17, 2022 Filing 105 NOTICE OF APPEARANCE by Richard Stephen Mandel on behalf of ASAP Logistics and Defense Security Services Ltd...(Mandel, Richard)
October 17, 2022 Filing 104 ANSWER to #59 Amended Complaint,,,., CROSSCLAIM against Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. Document filed by ASAP Logistics and Defense Security Services Ltd...(Mandel, Richard)
October 17, 2022 Filing 103 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by ASAP Logistics and Defense Security Services Ltd...(Mandel, Richard)
October 14, 2022 Opinion or Order Filing 102 ORDER granting #90 Letter Motion for Extension of Time to Answer re #90 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 12, 2022.. The Application is granted. SO ORDERED.. (Signed by Judge Paul G. Gardephe on 10/14/2022) A.S.A.P. Logistics LTD answer due 10/28/2022; Guven Acarer answer due 10/28/2022; Asap Lojistik Ve Savunma Ticaret Limited Sirketi answer due 10/28/2022; Deborah Cross answer due 10/28/2022 (ks)
October 13, 2022 Filing 101 CLERK'S CERTIFICATE OF DEFAULT as to Ilker Kucuker.(km)
October 13, 2022 Filing 100 CERTIFICATE OF SERVICE of Motion to Withdraw as Attorney and Declaration of Richard S. Mandel in Support of Motion served on Guven Acarer on 10/13/2022. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 13, 2022 Filing 99 DECLARATION of Richard S. Mandel in Support re: #98 MOTION for Richard S. Mandel and Jeremy A. Berman to Withdraw as Attorney .. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 13, 2022 Filing 98 MOTION for Richard S. Mandel and Jeremy A. Berman to Withdraw as Attorney . Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 13, 2022 Filing 97 PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/13/2022 (km).
October 13, 2022 Filing 96 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Vincent D. Nguyen re: #95 Proposed Clerk's Certificate of Default I. Kucuker. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Affidavit of Service, #3 Exhibit Affidavit of Service).(Nguyen, Vincent) Modified on 10/13/2022 (km).
October 13, 2022 Filing 95 FILING ERROR - WRONG PDF FILE ASSOCIATED WITH DOCKET ENTRY - PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/13/2022 (km).
October 13, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED CLERK'S CERTIFICATE OF DEFAULT: Notice to Attorney Vincent Nguyen. RE-FILE Document No. #94 Affidavit, #93 Proposed Clerk's Certificate of Default. The filing is deficient for the following reason(s): There was no clerk's certificate filed. Please file the clerk's certificate with nothing attached. Refile your affidavit in support and attach the request to the affidavit. Re-file the document using the event type Proposed Clerk's Certificate of Default found under the event list Proposed Orders - select the correct filer/filers - attach the correct PDF that - lists the correct filed date of the complaint, lists the correct name(s) of the party(ies) who was/were served, lists the correct date the party(ies) was/were served, lists the correct filed date of the proof of service. (km)
October 13, 2022 ***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - PDF ERROR. Notice to Attorney Vincent Nguyen to RE-FILE Document #96 Affidavit #95 Proposed Clerk's Certificate of Default. The document that was filed is not the clerk's certificate of default. (km)
October 12, 2022 Filing 94 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Vincent D. Nguyen re: #93 Proposed Clerk's Certificate of Default I. Kucuker. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Affidavit of Service, #3 Exhibit Affidavit of Service, #4 Text of Proposed Order Proposed Order).(Nguyen, Vincent) Modified on 10/13/2022 (km).
October 12, 2022 Filing 93 FILING ERROR - WRONG PDF FILE ASSOCIATED WITH DOCKET ENTRY - PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/13/2022 (km).
October 12, 2022 Filing 92 CLERK'S CERTIFICATE OF DEFAULT as to TURKER KUCUKER.(km)
October 12, 2022 Filing 91 CLERK'S CERTIFICATE OF DEFAULT as to TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI D/B/A TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI.(km)
October 12, 2022 Filing 90 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated October 12, 2022. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
October 12, 2022 Filing 89 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Vincent D. Nguyen re: #88 Proposed Clerk's Certificate of Default, Defendant I. Kucuker. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Affidavit of Service, #3 Exhibit Affidavit of Service).(Nguyen, Vincent) Modified on 10/12/2022 (km).
October 12, 2022 Filing 88 FILING ERROR - DEFICIENT DOCKET ENTRY - PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Text of Proposed Order Clerk's Certificate of Default).(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/12/2022 (km).
October 12, 2022 Filing 87 PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/12/2022 (km).
October 12, 2022 Filing 86 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Vincent D. Nguyen re: #85 Proposed Clerk's Certificate of Default of Defendant T. Kucuker. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Affidavit of Service, #3 Exhibit Affidavit of Service).(Nguyen, Vincent) Modified on 10/12/2022 (km).
October 12, 2022 Filing 85 FILING ERROR - WRONG PDF FILE ASSOCIATED WITH DOCKET ENTRY - PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/12/2022 (km).
October 12, 2022 Filing 84 PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/12/2022 (km).
October 12, 2022 Filing 83 FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Vincent D. Nguyen re: #82 Proposed Clerk's Certificate of Default . Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Proof of Service, #3 Exhibit Proof of Service).(Nguyen, Vincent) Modified on 10/12/2022 (km).
October 12, 2022 Filing 82 FILING ERROR - WRONG PDF FILE ASSOCIATED WITH DOCKET ENTRY - PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent) Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers). Modified on 10/12/2022 (km).
October 12, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED CLERK'S CERTIFICATE OF DEFAULT: Notice to Attorney Vincent Nguyen. RE-FILE Document No. #89 Affidavit, #88 Proposed Clerk's Certificate of Default. The filing is deficient for the following reason(s): The clerk's certificate needs to be filed separately, with nothing attached. When you refile the affidavit, the request can be filed as an attachment to the affidavit. Re-file the document using the event type Proposed Clerk's Certificate of Default found under the event list Proposed Orders - select the correct filer/filers - attach the correct PDF that - lists the correct filed date of the complaint, lists the correct name(s) of the party(ies) who was/were served, lists the correct date the party(ies) was/were served, lists the correct filed date of the proof of service. (km)
October 6, 2022 Filing 81 DECLARATION of Servet Akkyanak in Support re: #79 Brief. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - Turkish Article, #2 Exhibit B - Translation of Turkish Article, #3 Exhibit C - ASAP Turkey Website).(Schnapp, Daniel)
October 6, 2022 Filing 80 DECLARATION of Daniel A. Schnapp in Support re: #79 Brief. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - Sep. 22, 2022 Email).(Schnapp, Daniel)
October 6, 2022 Filing 79 BRIEF re: #78 Proposed Order to Show Cause With Emergency Relief in Support of Preliminary Injunction to Prevent Closure of ASAP Turkey. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
October 6, 2022 Filing 78 PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
October 6, 2022 ***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. #78 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (km)
October 4, 2022 Filing 77 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,,,. Metin Nerkis served on 10/4/2022, answer due 10/25/2022. Service was made by E-Mail. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
October 4, 2022 Filing 76 ELECTRONIC SUMMONS ISSUED as to Metin Nerkis. (vf)
October 4, 2022 Filing 75 REQUEST FOR ISSUANCE OF SUMMONS as to METIN NERKIS, re: #59 Amended Complaint,,,. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
October 3, 2022 Filing 74 AFFIDAVIT OF SERVICE of Summons and Amended Complaint,,,. ASAP Logistics and Defense Security Services Ltd. served on 9/27/2022, answer due 10/18/2022. Service was accepted by Nick Mohammed. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
September 30, 2022 Filing 73 ANSWER to #59 Amended Complaint,,,., CROSSCLAIM against Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. Document filed by Deborah Cross..(Mandel, Richard)
September 30, 2022 Filing 72 ANSWER to #59 Amended Complaint,,,., CROSSCLAIM against Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. Document filed by Asap Lojistik Ve Savunma Ticaret Limited Sirketi..(Mandel, Richard)
September 30, 2022 Filing 71 ANSWER to #59 Amended Complaint,,,., CROSSCLAIM against Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. Document filed by A.S.A.P. Logistics LTD..(Mandel, Richard)
September 30, 2022 Filing 70 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Asap Lojistik Ve Savunma Ticaret Limited Sirketi..(Mandel, Richard)
September 30, 2022 Filing 69 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by A.S.A.P. Logistics LTD..(Mandel, Richard)
September 30, 2022 Opinion or Order Filing 68 ORDER granting #67 Letter Motion for Extension of Time to Answer re #67 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated September 28, 2022., #59 Amended Complaint. The Application is granted. SO ORDERED., (A.S.A.P. Logistics LTD answer due 10/14/2022; Guven Acarer answer due 10/14/2022; Asap Lojistik Ve Savunma Ticaret Limited Sirketi answer due 10/14/2022; Deborah Cross answer due 10/14/2022.) (Signed by Judge Paul G. Gardephe on 9/30/22) (yv)
September 28, 2022 Filing 67 LETTER MOTION for Extension of Time to File Answer re: #59 Amended Complaint,,, or Otherwise Move addressed to Judge Paul G. Gardephe from Richard S. Mandel dated September 28, 2022. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
September 26, 2022 Filing 66 ELECTRONIC SUMMONS ISSUED as to ASAP Logistics and Defense Security Services Ltd.. (sj)
September 25, 2022 Opinion or Order Filing 65 CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to conducting further proceedings before a Magistrate Judge,including motions and trial, pursuant to 28 U.S.C. 636(c). This case is to be tried to a jury. Fact Discovery due by 12/16/2022. Deposition due by 12/16/2022. Expert Discovery due by 1/30/2023. Counsel for the parties have conferred and their present best estimate of the length of trial is: 5 to 14 days. Telephone Conference set for 12/15/2022 at 10:30 AM before Judge Paul G. Gardephe. (Signed by Judge Paul G. Gardephe on 9/25/2022) (va)
September 25, 2022 Opinion or Order Filing 64 ORDER: For the reasons stated at the September 23, 2022 hearing, Plaintiff's application for a preliminary injunction is denied as to Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Metin Nerkis, Turker Kucuker, and Ilker Kuucker. SO ORDERED. (Signed by Judge Paul G. Gardephe on 9/25/2022) (va)
September 24, 2022 Filing 63 REQUEST FOR ISSUANCE OF SUMMONS as to ASAP LOGISTICS AND DEFENSE SECURITY SERVICES LTD., re: #59 Amended Complaint,,,. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
September 23, 2022 Minute Entry for proceedings held before Judge Paul G. Gardephe: Initial Pretrial Conference held on 9/23/2022. (Court Reporter Eve Giniger) (mr)
September 22, 2022 Opinion or Order Filing 62 ORDER: The preliminary injunction hearing and initial pretrial conference, currently scheduled for September 22, 2022, will instead take place on September 23, 2022 at 4:15 p.m. by telephone. Plaintiff is directed to provide notice of this adjournment to all Defendants who have not appeared in this case. SO ORDERED. (Signed by Judge Paul G. Gardephe on 9/22/2022) Initial Conference set for 9/23/2022 at 04:15 PM before Judge Paul G. Gardephe. (ks)
September 20, 2022 Filing 61 AFFIDAVIT OF SERVICE. Ilker Kucuker served on 9/19/2022, answer due 10/11/2022; Turker Kucuker served on 9/19/2022, answer due 10/11/2022; Metin Nerkis served on 9/19/2022, answer due 10/11/2022; Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi served on 9/19/2022, answer due 10/11/2022. Service was made by Email. Document filed by Makina Ve Kimya Endustrisi A.S..(Nguyen, Vincent)
September 19, 2022 Opinion or Order Filing 60 ORDER FOR ADMISSION PRO HAC VICE granting #58 Motion for Vincent Nguyen to Appear Pro Hac Vice. (Signed by Judge Paul G. Gardephe on 9/19/2022) (ks)
September 19, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Daniel Schnapp re: Document No. #59 Amended Complaint. The filing is deficient for the following reason(s): all of the parties listed on the pleading were not entered on CM ECF (ASAP LOGISTICS AND DEFENSE SECURITY SERVICES LTD.). Docket the event type Add Party to Pleading found under the event list Complaints and Other Initiating Documents. (gp)
September 19, 2022 ADD PARTY FOR PLEADING. Defendants/Respondents ASAP Logistics and Defense Security Services Ltd. added. Party added pursuant to #59 Amended Complaint,,,.Document filed by Makina Ve Kimya Endustrisi A.S. Related document: #59 Amended Complaint,,,..(Schnapp, Daniel)
September 16, 2022 Filing 59 FIRST AMENDED COMPLAINT amending #3 Complaint, against A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross, Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, Metin Nerkis with JURY DEMAND.Document filed by Makina Ve Kimya Endustrisi A.S. Related document: #3 Complaint,. (Attachments: #1 Exhibit A - ASAP Turkey Website Page, #2 Exhibit B - ASAP Turkey Website Page, #3 Exhibit C - ASAP Turkey Website Page, #4 Exhibit D - ASAP Turkey Press Release, #5 Exhibit E - ASAP Turkey Contact Information, #6 Exhibit F - Phone Registration Information, #7 Exhibit G - ASAP Logistics US Annotated Bill of Landing, #8 Exhibit H - Letter of Intent, #9 Exhibit I - ASAP Full Corporate Offer for MKE Ammunition, #10 Exhibit J - ASAP Invoice for MKE Ammunition).(Schnapp, Daniel)
September 14, 2022 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #58 MOTION for Vincent D. Nguyen to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26670779. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
September 13, 2022 Filing 58 MOTION for Vincent D. Nguyen to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26670779. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Affidavit of Vincent D. Nguyen in Support of Motion for Admission Pro Hac Vice, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order for Admission Pro Hac Vice).(Nguyen, Vincent)
September 8, 2022 Opinion or Order Filing 57 ORDER granting #53 Letter Motion to Adjourn Conference. The preliminary injunction hearing and initial pre-trial conference, currently scheduled for September 16, 2022, will instead take place on September 22, 2022 at 4:15 p.m. To the extent that Plaintiff intends to amend the Complaint, the amended complaint shall be filed by September 16, 2022. The Clerk of Court is directed to terminate the motion at Docket Number 53. SO ORDERED. Initial Conference set for 9/22/2022 at 04:15 PM before Judge Paul G. Gardephe.. (Signed by Judge Paul G. Gardephe on 9/8/2022) (jca)
September 8, 2022 Filing 56 LETTER addressed to Judge Paul G. Gardephe from Richard S. Mandel dated September 8, 2022 re: Request for Adjournment. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
September 8, 2022 Set/Reset Deadlines: Amended Pleadings due by 9/16/2022. (jca)
August 31, 2022 Filing 55 PROPOSED CASE MANAGEMENT PLAN. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 29, 2022 Opinion or Order Filing 54 ORDER granting #51 Motion for Juliet J. DeFrancisco to Appear Pro Hac Vice.. (Signed by Judge Paul G. Gardephe on 8/29/2022) (rro)
August 25, 2022 Filing 53 LETTER MOTION to Adjourn Conference addressed to Judge Paul G. Gardephe from Richard S. Mandel dated August 25, 2022. Document filed by A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
August 23, 2022 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #51 MOTION for Juliet J. DeFrancisco 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. (aea)
August 22, 2022 Opinion or Order Filing 52 ORDER: The show cause hearing currently scheduled for August 25, 2022 will instead take place on Friday, September 16, 2022 at 10:30 a.m. SO ORDERED. (Signed by Judge Paul G. Gardephe on 8/22/2022) ( Telephone Conference set for 9/16/2022 at 10:30 AM before Judge Paul G. Gardephe.) (ks)
August 22, 2022 Filing 51 MOTION for Juliet J. DeFrancisco to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - NY State Certificate of Good Standing, #2 Exhibit B - Commonwealth of MA Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(DeFrancisco, Juliet)
August 15, 2022 Opinion or Order Filing 50 STIPULATION PRELIMINARY INJUNCTION AND ORDER: IT IS HEREBY STIPULATED by and between Plaintiff Makina Ve Kimya Endustrisi A.S's ("MKE") Defendants A.S.A.P. Logistics Ltd. ("ASAP"), ASAP Lojistik Ve Savunma Ticaret Limited Sirketi (ASAP Turkey), Deborah Cross, and Guven Acarer (collectively referred herein as the Defendants), through their undersigned counsel of record, to resolve MKEs pending Order to Show Cause for a Preliminary Injunction (ECF No. 8) (the "Order to Show Cause") on the terms and conditions stated herein: 1. The terms of this stipulation shall remain in force during the pendency of this litigation or until further order by the Court. 2. Defendants shall not use "Makina Ve Kimya Endustrisi" name, The MKE Mark ("MKE"), the MKE Logo, or any confusingly similar names, marks, or logos in connection with any of Defendants' goods or services, or goods or services offered by businesses owned, in whole in part, by any of Defendants (their "businesses"); 3. Defendants shall not represent, hold out, or otherwise assert that Defendants or their businesses have for sale, can make available for sale, can obtain, or otherwise provide MKE products, 4. Defendants shall not make available for sale or sell, any purported MKE products directly or through their businesses; As further set forth in this order. Nothing in this Stipulation shall be deemed a waiver of any rights, defenses, claims and remedies in the litigation, all of which are expressly reserved. 11. The Court shall have continuing jurisdiction over this matter and shall retain jurisdiction for resolving any disputes that may arise under this Stipulation. The preliminary injunction hearing scheduled for August 25, 2022 will proceed as scheduled as to Defendants not named in this stipulation. SO ORDERED. (Signed by Judge Paul G. Gardephe on 8/15/2022) (ks)
August 15, 2022 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #46 MOTION for Juliet J. DeFrancisco to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26540178. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): Motion and Affidavit Needs to Say Admitted in MASSACHUSETTS also;. 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. (sgz)
August 12, 2022 Filing 49 NOTICE OF APPEARANCE by Jeremy Andrew Berman on behalf of A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Berman, Jeremy)
August 12, 2022 Filing 48 NOTICE OF APPEARANCE by Richard Stephen Mandel on behalf of A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross..(Mandel, Richard)
August 12, 2022 Filing 47 PROPOSED STIPULATION AND ORDER. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 12, 2022 Filing 46 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Juliet J. DeFrancisco to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26540178. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Affidavit with Exhibit A - Certificates of Service (NY and MA), #2 Exhibit Exhibit A - Certificates of Service (NY and MA), #3 Text of Proposed Order Proposed Order).(DeFrancisco, Juliet) Modified on 8/15/2022 (sgz).
August 10, 2022 Filing 45 AFFIDAVIT OF SERVICE served on ASAP LOJISTIK VE SAVUNMA TICARET LIMITED SIRKETI D/B/A ASAP LOGISTICS AND DEFENSE AND/OR ASAP LOGISTICS AND DEFENSE GUVENLIK HIZMETLERI SANAYI VE TICARET LIMITED SIRKETI. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 10, 2022 Filing 44 AFFIDAVIT OF SERVICE served on A.S.A.P. LOGISTICS LTD. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 10, 2022 Filing 43 AFFIDAVIT OF SERVICE served on TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI D/B/A TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 10, 2022 Filing 42 AFFIDAVIT OF SERVICE served on TURKER KUCUKER. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 10, 2022 Filing 41 AFFIDAVIT OF SERVICE served on ILKER KUCUKER. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 10, 2022 Filing 40 AFFIDAVIT OF SERVICE served on GUVEN ACARER. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - Two Error Messages Received in Response to E-Mails Sent to Defendant).(Schnapp, Daniel)
August 10, 2022 Filing 39 AFFIDAVIT OF SERVICE served on Deborah Cross. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - 8/2/2022 Affidavit of Service for Defendant Deborah Cross).(Schnapp, Daniel)
August 9, 2022 Filing 38 WAIVER OF SERVICE RETURNED EXECUTED. Guven Acarer waiver sent on 8/9/2022, answer due 10/11/2022; Asap Lojistik Ve Savunma Ticaret Limited Sirketi waiver sent on 8/9/2022, answer due 10/11/2022; Deborah Cross waiver sent on 8/9/2022, answer due 10/11/2022. Document filed by Guven Acarer; Asap Lojistik Ve Savunma Ticaret Limited Sirketi; Deborah Cross..(Mandel, Richard)
August 4, 2022 Filing 37 ELECTRONIC SUMMONS ISSUED as to Asap Lojistik Ve Savunma Ticaret Limited Sirketi. (sj)
August 3, 2022 Filing 36 REQUEST FOR ISSUANCE OF SUMMONS as to ASAP Lojistik Ve Savunma Ticaret Limited Sirketi d/b/a ASAP Logistics and Defense and/or ASAP Logistics and Defense Guvenlik Hizmetleri Sanayi Ve Ticaret Limited Sirketi, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
August 3, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Daniel Adam Schnapp to RE-FILE Document No. #35 Request for Issuance of Amended Summons,. The filing is deficient for the following reason(s): the wrong event type was used to file the request for issuance of summons;. 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. (pc)
August 2, 2022 Filing 35 FILING ERROR - DEFICIENT PLEADING - SUMMONS REQUESTED - WRONG EVENT TYPE SELECTED FROM MENU - REQUEST FOR ISSUANCE OF AMENDED SUMMONS as to ASAP Lojistik Ve Savunma Ticaret Limited Sirketi d/b/a ASAP Logistics and Defense and/or ASAP Logistics and Defense Guvenlik Hizmetleri Sanayi Ve Ticaret Limited Sirketi, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel) Modified on 8/3/2022 (pc).
August 1, 2022 Filing 34 WAIVER OF SERVICE RETURNED EXECUTED. A.S.A.P. Logistics LTD waiver sent on 8/1/2022, answer due 9/30/2022. Document filed by A.S.A.P. Logistics LTD..(Erickson, Clarence)
July 29, 2022 Opinion or Order Filing 33 ORDER granting #8 Motion for Order to Show Cause. It is ORDERED that A.S.A.P. Logistics LTD ("ASAP US"), ASAP Lojistik Ve Savunma Ticaret Limited Sirketi ("ASAP Turkey"), Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi ("Turkkey Capital), Deborah Cross) Guven Acarer, Metin Nerkis, Turker Kucuker and Ilker Kucuker (collectively "Defendants") show cause before this Court on August 25, 2022 at 11:45 a.m., why an order should not be made and entered herein granting a preliminary injunction enjoining Defendants from engaging in activities that violate 15 U.S.C. 1125(a), unfair competition common law, and New York General Business Law 349, including, but not limited to enjoining Defendants from using the Plaintiffs Trademarks and/or otherwise associating their businesses, activities, or themselves, with Plaintiff in any way, and expedited discovery. ORDERED that the service of a copy of this Order to Show Cause and its supporting papers shall be made on each Defendant by August 2, 2022, and deemed effective as to each Defendant if completed by the following means: (1) Defendants ASAP US and Deborah Cross shall be served by any manner permitted by Federal Rules of Civil Procedure 4( e) and (h); and (2) the Turkish Defendants - namely, ASAP Turkey, Turldcey Capital, Guven Acarer, Metin Nerkis, Turker Kucuker, and liker Kucuker - shall be served via the email addresses listed in Plaintiffs submission at Docket Number 29 (see July 25, 2022 Order (Dkt. No. 32)). Defendants will file their response to this Order to Show Cause by August 12, 2022. Any reply will be filed by August 15) 2022. SO ORDERED.. (Signed by Judge Paul G. Gardephe on 7/29/2022) (ks)
July 29, 2022 Opinion or Order Filing 32 ORDER: For the reasons stated above, Plaintiff's motion for alternative service is granted. SO ORDERED. (Signed by Judge Paul G. Gardephe on 7/29/2022) (ks)
July 29, 2022 Set/Reset Deadlines: ( Replies due by 8/15/2022., Show Cause Response due by 8/12/2022.), Set/Reset Hearings:( Telephone Conference set for 8/25/2022 at 11:45 AM before Judge Paul G. Gardephe.) (ks)
July 20, 2022 Opinion or Order Filing 31 ORDER: The conference in this matter currently scheduled for July 21, 2022 will instead take place on August 25, 2022 at 11:45 a.m. by telephone. The parties are directed to dial 888-363-4749 to participate, and to enter the access code 6212642. SO ORDERED. (Signed by Judge Paul G. Gardephe on 7/20/2022) ( Telephone Conference set for 8/25/2022 at 11:45 AM before Judge Paul G. Gardephe.) (ks)
July 15, 2022 Filing 30 DECLARATION of Daniel Schnapp in Support re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery.. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - ASAP Turkey Website Contact Page, #2 Exhibit B - ASAP Turkey Website Homepage, #3 Exhibit C - TC Website Contact Page, #4 Exhibit D - Metin Nerkis LinkedIn, #5 Exhibit E - Metin Nerkis E-Mail Address).(Schnapp, Daniel)
July 15, 2022 Filing 29 RESPONSE in Support of Motion re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. . Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
July 11, 2022 Opinion or Order Filing 28 ORDER: Accordingly, Plaintiff's request for leave to serve the Turkish Defendants through alternative service is denied without prejudice. By July 15, 2022, Plaintiff will supplement its motion for alternative service by describing the email addresses it seeks to use to serve the Turkish Defendants, and by submitting evidence that such email addresses are reasonably calculated to apprise each of the Turkish Defendants of the pendency of this action. Plaintiff's submission should also state the basis for its assertion that service through the Hague Service Convention may result in a six-to-eight-month delay in service. With respect to Plaintiff's request for leave to file an amended complaint (see June 22, 2022 Pltf. Motion (Dkt. No. 27) at 12-13), Fed. R. Civ. P. 15(a)(1)(B) permits a plaintiff to amend its pleading as a matter of right within "21 days after service of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), whichever is earlier." Since Defendants have not yet been served and have not otherwise responded to the Complaint, Plaintiff may amend its Complaint as a matter of right under Fed. R. Civ. P. 15(a) (1)(B). SO ORDERED. (Signed by Judge Paul G. Gardephe on 7/11/2022) (ks)
June 22, 2022 Filing 27 RESPONSE in Support of Motion re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. . Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
June 17, 2022 Opinion or Order Filing 26 ORDER: Plaintiff has submitted a proposed order to show cause seeking a preliminary injunction against Defendants in this action alleging violations of the Lanham Act, 15 U.S.C. Section 1125(a), New York General Business Law, 349, and unfair competition. (Dkt. No. 8) Plaintiff will make a submission by June 22, 2022 addressing the following: (1) why service by certified mail on the Turkish defendants would be lawful given that Turkey has objected to service by mail under the Hague Service Convention; (2) the basis for exercising personal jurisdiction over the Turkish defendants; and (3) an explanation for why Defendant Metin Nerkis is not listed in the caption. SO ORDERED. (Signed by Judge Paul G. Gardephe on 6/17/2022) (ks)
June 8, 2022 Filing 25 ELECTRONIC SUMMONS ISSUED as to Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. (vf)
June 8, 2022 Filing 24 ELECTRONIC SUMMONS ISSUED as to Turker Kucuker. (vf)
June 8, 2022 Filing 23 ELECTRONIC SUMMONS ISSUED as to Ilker Kucuker..(vf)
June 8, 2022 Filing 22 ELECTRONIC SUMMONS ISSUED as to Guven Acarer. (vf)
June 8, 2022 Filing 21 ELECTRONIC SUMMONS ISSUED as to Deborah Cross. (vf)
June 8, 2022 Filing 20 ELECTRONIC SUMMONS ISSUED as to A.S.A.P. Logistics LTD. (vf)
June 8, 2022 Filing 19 REQUEST FOR ISSUANCE OF SUMMONS as to Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 Filing 18 REQUEST FOR ISSUANCE OF SUMMONS as to Turker Kucuker, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 Filing 17 FILING ERROR - DEFICIENT - SUMMONS REQUEST As To - REQUEST FOR ISSUANCE OF SUMMONS as to Metin Nerkis, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin) Modified on 6/8/2022 (vf).
June 8, 2022 Filing 16 REQUEST FOR ISSUANCE OF SUMMONS as to ILKER KUCUKER, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 Filing 15 REQUEST FOR ISSUANCE OF SUMMONS as to GVEN ACARER, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 Filing 14 REQUEST FOR ISSUANCE OF SUMMONS as to DEBORAH CROSS, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 Filing 13 FILING ERROR - DEFICIENT - SUMMONS REQUEST - REQUEST FOR ISSUANCE OF SUMMONS as to ASAP LOJISTIK VE SAVUNMA TICARET LIMITED SIRKETI D/B/A ASAP LOGISTICS AND DEFENSE AND/OR ASAP LOGISTICS AND DEFENSE GUVENLIK HIZMETLERI SANAYI VE TICARET LIMITED SIRKETI, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin) Modified on 6/8/2022 (vf).
June 8, 2022 Filing 12 REQUEST FOR ISSUANCE OF SUMMONS as to A.S.A.P. LOGISTICS LTD, re: #3 Complaint,. Document filed by Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
June 8, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Huseyin Alper Tosun to RE-FILE Document No. #13 Request for Issuance of Summons, #17 Request for Issuance of Summons. The filing is deficient for the following reason(s):Defendant party name error. Defendant party name listed on Summons PDF does not correspond to pleading caption. 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. (vf)
June 3, 2022 Filing 11 DECLARATION of Daniel A. Schnapp in Support re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery.. Document filed by Makina Ve Kimya Endustrisi A.S. (Attachments: #1 Exhibit A - Complaint, ECF No. 1, #2 Exhibit B - Letter for Intent for Cooperation, #3 Exhibit C - Text Messages from Defendant, #4 Exhibit D - Corporate Offer from Defendants, #5 Exhibit E - Invoice from Defendants, #6 Exhibit F - Trademark Registration, #7 Exhibit G - Text Messages with Defendants).(Schnapp, Daniel)
June 3, 2022 Filing 10 DECLARATION of Servet Akkaynak in Support re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery.. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
June 3, 2022 Filing 9 MEMORANDUM OF LAW in Support re: #8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. . Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
June 3, 2022 Filing 8 MOTION for Order to Show Cause for Preliminary Injunction and Expedited Discovery. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
May 25, 2022 Filing 7 NOTICE OF APPEARANCE by Huseyin Alper Tosun on behalf of Makina Ve Kimya Endustrisi A.S..(Tosun, Huseyin)
May 17, 2022 Filing 6 AO 120 FORM TRADEMARK - CASE OPENING - SUBMITTED. In compliance with the provisions of 15 U.S.C. 1116, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following trademark(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF)..(sj)
May 17, 2022 Filing 5 NOTICE OF PRETRIAL CONFERENCE: COUNSEL FOR PLAINTIFF(S) MUST: (i) IMMEDIATELY NOTIFY ALL ATTORNEYS IN THIS ACTION BY SERVING UPON EACH OF THEM COPIES OF THIS NOTICE AND THE COURT'S INDIVIDUAL PRACTICES; AND (ii) SEND A COPY OF SUCH NOTICE TO CHAMBERS (without attachments). IF COUNSEL FOR PLAINTIFF(S) IS UNAWARE OF THE IDENTITY OF COUNSEL FOR ANY OF THE PARTIES, COUNSEL FOR PLAINTIFF(S) MUST IMMEDIATELY SEND COPIES OF THE NOTICE AND INDIVIDUAL PRACTICES TO THAT PARTY PERSONALLY. Initial Conference set for 7/21/2022 at 11:45 AM in Courtroom 705, 40 Centre Street, New York, NY 10007 before Judge Paul G. Gardephe. (Signed by Judge Paul G. Gardephe on 5/17/2022) (kv)
May 16, 2022 Filing 4 AO 120 FORM TRADEMARK - NOTICE OF SUBMISSION BY ATTORNEY. AO 120 Form Patent/Trademark for case opening submitted to court for review..(Schnapp, Daniel)
May 16, 2022 Filing 3 COMPLAINT against A.S.A.P. Logistics LTD, Guven Acarer, Asap Lojistik Ve Savunma Ticaret Limited Sirketi, Deborah Cross, Ilker Kucuker, Turker Kucuker, Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi. Document filed by Makina Ve Kimya Endustrisi A.S..(Schnapp, Daniel)
May 16, 2022 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Daniel Adam Schnapp to RE-FILE Document No. #1 Complaint,. The filing is deficient for the following reason(s): the All Defendant radio button was selected;. 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. (pc)
May 16, 2022 ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Daniel Adam Schnapp. The following case opening statistical information was erroneously selected/entered: Cause of Action code 15:44; County code New York;. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 15:1125; the County code has been modified to XX Out of U.S.;. (pc)
May 16, 2022 ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Daniel Adam Schnapp. The party information for the following party/parties has been modified: MAKINA VE KIMYA ENDUSTRISI A.S, A.S.A.P. LOGISTICS LTD, ASAP LOJISTIK VE SAVUNMA TICARET LIMITED SIRKETI D/B/A ASAP LOGISTICS AND DEFENSE AND/OR ASAP LOGISTICS AND DEFENSE GUVENLIK HIZMETLERI SANAYI VE TICARET LIMITED SIRKETI, TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI D/B/A TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps; alias party name was entered in all caps;. (pc)
May 16, 2022 ***NOTICE TO ATTORNEY TO SUBMIT AO 120 FORM PATENT/TRADEMARK. Notice to Attorney Daniel Adam Schnapp to submit a completed AO 120 Form Patent/Trademark to court for review. Use the event type AO 120 Form Patent/Trademark - Notice of Submission by Attorney found under the event list Other Documents. (pc)
May 16, 2022 Magistrate Judge Gabriel W. Gorenstein 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)
May 16, 2022 Case Designated ECF. (pc)
May 16, 2022 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Paul G. Gardephe. 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)
May 13, 2022 Filing 2 CIVIL COVER SHEET filed..(Schnapp, Daniel)
May 13, 2022 Filing 1 FILING ERROR - DEFICIENT PLEADING - FILED AGAINST PARTY ERROR -COMPLAINT against All Defendants. (Filing Fee $ 402.00, Receipt Number ANYSDC-26146201)Document filed by MAKINA VE KIMYA ENDUSTRISI A.S. (Attachments: #1 Exhibit A - TC Authorization, #2 Exhibit B - Offer, #3 Exhibit C - ASAP Invoice).(Schnapp, Daniel) Modified on 5/16/2022 (pc).

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Search for this case: Makina Ve Kimya Endustrisi A.S v. A.S.A.P. Logistics LTD et al
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Plaintiff: MAKINA VE KIMYA ENDUSTRISI A.S
Represented By: Daniel Adam Schnapp
Represented By: Huseyin Alper Tosun
Represented By: Juliet DeFrancisco
Represented By: Vincent Dai-Viet Nguyen
Represented By: William Kirby
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Defendant: A.S.A.P. LOGISTICS LTD
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Defendant: ASAP LOJISTIK VE SAVUNMA TICARET LIMITED SIRKETI D/B/A ASAP LOGISTICS AND DEFENSE AND/OR ASAP LOGISTICS AND DEFENSE GUVENLIK HIZMETLERI SANAYI VE TICARET LIMITED SIRKETI
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Defendant: TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI D/B/A TURKKEY CAPITAL KURUMSAL FINANS COZUMLERI LIMITED SIRKETI
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Defendant: Deborah Cross
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Defendant: Guven Acarer
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Defendant: Turker Kucuker
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Defendant: Ilker Kucuker
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Defendant: Asap Lojistik Ve Savunma Ticaret Limited Sirketi doing business as Asap Logistics And Defense And/Or Asap Logistics and Defense Guvenlik Hizmetleri Sanayi Ve Ticaret Limited Sirketi
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Defendant: Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi doing business as Turkkey Capital Kurmsal Finans Cozumleri Limited Sirketi
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Defendant: Metin Nerkis
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Defendant: ASAP Logistics and Defense Security Services Ltd.
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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Cross defendant: Turkkey Capital Kurumsal Finans Cozumleri Limited Sirketi
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Cross claimant: Asap Lojistik Ve Savunma Ticaret Limited Sirketi
Represented By: Richard Stephen Mandel
Represented By: Jeremy Andrew Berman
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