Freeman v. Stake.com et al
| Christopher Freeman |
| Stake.com, Primedice, Edward Craven, Bijan Tehrani, Slicemedia B.V., Medium Rare N.V., Easygo Solutions Pty Ltd, MeBit.io and Mladen Vuckovic |
| 1:2022cv07002 |
| August 17, 2022 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| Ronnie Abrams |
| Defend Trade Secrets Act (of 2016) |
| 18 U.S.C. § 1836 (b) Civil Action to Protect Trade Secrets |
| Plaintiff |
Docket Report
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This docket was last retrieved on November 7, 2023. A more recent docket listing may be available from PACER.
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Filing 51
REPLY MEMORANDUM OF LAW in Support re: #31 MOTION to Dismiss Complaint. . Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 50
LETTER addressed to Judge Ronnie Abrams from William B. Fleming dated March 30, 2023 re: Freeman v. Stake.com, et al. Document filed by Christopher Freeman..(Fleming, William)
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Filing 49
AFFIDAVIT of Simon Lachere in Opposition re: #31 MOTION to Dismiss Complaint.. Document filed by Christopher Freeman. (Attachments: #1 Exhibit Civil Court of Paris Ruling, #2 Exhibit ANJ Warning Notice).(Fleming, William)
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Filing 48
AFFIDAVIT of Glenn Ferguson in Opposition re: #31 MOTION to Dismiss Complaint.. Document filed by Christopher Freeman. (Attachments: #1 Exhibit Ferguson CV, #2 Exhibit Reference Material, #3 Exhibit Renunciation Records, #4 Exhibit Australian Citizenship Records, #5 Exhibit Business Option Visa Information, #6 Exhibit Employer Sponsored Visa Information, #7 Exhibit PVA Declaration, #8 Exhibit PIC 4020, #9 Exhibit Ministerial Direction, #10 Exhibit UK Illegality Notice, #11 Exhibit French Illegality Application, #12 Exhibit Timothy Edwards Letter, #13 Exhibit Michael Patane Letter, #14 Exhibit Hui Ling Dean Letter, #15 Exhibit Citizenship Declaration).(Fleming, William)
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Filing 47
AFFIDAVIT of Christopher Freeman in Opposition re: #31 MOTION to Dismiss Complaint.. Document filed by Christopher Freeman. (Attachments: #1 Exhibit New York Apt Lease, #2 Exhibit Primedice Screen Capture, #3 Exhibit Primedice Screen Capture, #4 Exhibit Primedice Screen Capture).(Fleming, William)
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Filing 46
AFFIRMATION of William B. Fleming in Opposition re: #31 MOTION to Dismiss Complaint.. Document filed by Christopher Freeman. (Attachments: #1 Exhibit Stake Affiliate Program, #2 Exhibit Matter of A.J. Valdez, Matter of Z. Valdez Case, #3 Exhibit In re Siaosi Fisiimaile Koloamatangi Case, #4 Exhibit AFR Article, #5 Exhibit Fenwick & West Press Release).(Fleming, William)
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Filing 45
MEMORANDUM OF LAW in Opposition re: #31 MOTION to Dismiss Complaint. . Document filed by Christopher Freeman..(Fleming, William)
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Filing 44
ORDER granting #41 Motion for Sachiko Schuricht to Appear Pro Hac Vice (HEREBY ORDERED by Judge Ronnie Abrams)(Text Only Order) (arc)
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Filing 43
ORDER granting #39 Motion for Eliza Lehner to Appear Pro Hac Vice (HEREBY ORDERED by Judge Ronnie Abrams)(Text Only Order) (arc)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #39 MOTION for Eliza Lehner to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27348629. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #41 MOTION for Sachiko Schuricht to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27349466. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
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Filing 42
MEMORANDUM OF LAW in Support re: #31 MOTION to Dismiss Complaint. (CORRECTED). Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 41
MOTION for Sachiko Schuricht to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27349466. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic. (Attachments: #1 Affidavit of Sachiko Schuricht in Support of Motion, #2 Exhibit Certificate of Good Standing - CA, #3 Text of Proposed Order for admission Pro Hac Vice).(Schuricht, Sachi)
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Filing 40
ORDER granting #38 Letter Motion for Leave to File Document. Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 2/15/2023) (ate)
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Filing 39
MOTION for Eliza Lehner to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27348629. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com. (Attachments: #1 Affidavit of Eliza Lehner in Support of Motion, #2 Exhibit Certificate of Good Standing - NY, #3 Exhibit Certificate of Good Standing - CA, #4 Text of Proposed Order for admission Pro Hac Vice).(Lehner, Eliza)
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Filing 38
LETTER MOTION for Leave to File Corrected Memorandum of Law in Support of Defendants Motion to Dismiss the Complaint addressed to Judge Ronnie Abrams from David McGill dated 2/14/23. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com. (Attachments: #1 Exhibit 1 - Corrected Memorandum of Law, #2 Exhibit 2 - Redline Version of Corrected Memorandum of Law).(McGill, David)
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Filing 37
LETTER addressed to Judge Ronnie Abrams from David McGill dated 2/9/2023 re: Oral Argument. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 36
DECLARATION of MLADEN VUCKOVIC in Support re: #31 MOTION to Dismiss Complaint.. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 35
DECLARATION of EDWARD CRAVEN in Support re: #31 MOTION to Dismiss Complaint.. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 34
DECLARATION of BIJAN TEHRANI in Support re: #31 MOTION to Dismiss Complaint.. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 33
DECLARATION of DAVID H. MCGILL in Support re: #31 MOTION to Dismiss Complaint.. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic. (Attachments: #1 Exhibit A - Slice Media Certificate of Incorporation, #2 Exhibit B - PBS News Hour - Gamblers wager billions, #3 Exhibit C - CoinDesk - Why Bitcoins Gambling Boom is Only Just Getting Started, #4 Exhibit D - Letter to Orrick on Amended Complaint, #5 Exhibit E - Bunnings Group Limited v. CHEP Australia, 2021 NSWCA 342, #6 Exhibit F - Coco v. AN Clark Engineers Ltd, 1968, 1 A IPR 587, #7 Exhibit G - Commonwealth of Australia v John Fairfax and Sons, 1980 32 ALR 485, #8 Exhibit H - Daebo Shipping Co LItd v. The Ship Go Star, 2012 FCAFC 156, #9 Exhibit I - HK Frost Holdings Pty Ltd (in liq) v Darvall McCutcheon a firm, 1999 FCA 570, #10 Exhibit J - Hoath and Anor v. Connect Internet Services Pty Ltd, 2006 NSWSC 158, #11 Exhibit K - Kafataris v. Davis, 2016 FCAFC 134, #12 Exhibit L - Moorgate Tobacco Co Ltd v Philip Morris Ltd and Anor, 1984, 56 ALR 193, #13 Exhibit M - Penfolds Wines Pty ltd v Elliot, 1946, 74 CLR 204, #14 Exhibit N - Ruscoe and Moore v. Cryptopia Ltd, 2020 NZHC 728).(McGill, David)
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Filing 32
MEMORANDUM OF LAW in Support re: #31 MOTION to Dismiss Complaint. . Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic. (Attachments: #1 Exhibit 1 - Corrected Redline of Complaint to FAC).(McGill, David)
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Filing 31
MOTION to Dismiss Complaint. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 30
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Edward Craven, Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Primedice, Slicemedia B.V., Stake.com, Bijan Tehrani, Mladen Vuckovic..(McGill, David)
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Filing 29
NOTICE OF APPEARANCE by David Harrison McGill on behalf of Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Slicemedia B.V., Mladen Vuckovic..(McGill, David)
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Filing 28
NOTICE OF APPEARANCE by R. David Hosp on behalf of Easygo Solutions Pty Ltd, MeBit.io, Medium Rare N.V., Slicemedia B.V., Mladen Vuckovic..(Hosp, R.)
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Filing 27
FIRST AMENDED COMPLAINT amending #1 Complaint against Edward Craven, Primedice, Stake.com, Bijan Tehrani, Slicemedia B.V., Medium Rare N.V., Easygo Solutions Pty Ltd, MeBit.io, Mladen Vuckovic with JURY DEMAND.Document filed by Christopher Freeman. Related document: #1 Complaint. (Attachments: #1 Exhibit Amendment Blackline).(Fleming, William)
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Filing 26
MEMO ENDORSEMENT on re: #25 Letter filed by Primedice, Bijan Tehrani, Edward Craven, Stake.com. ENDORSEMENT: Application granted. SO ORDERED. ( Amended Pleadings due by 1/6/2023., Joinder of Parties due by 1/6/2023., Motions due by 2/9/2023., Replies due by 4/13/2023., Responses due by 3/23/2023) (Signed by Judge Ronnie Abrams on 12/29/2022) (ate)
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Filing 25
LETTER addressed to Judge Ronnie Abrams from David McGill dated 12/28/2022 re: Schedule for anticipated Motion to Dismiss. Document filed by Edward Craven, Primedice, Stake.com, Bijan Tehrani..(McGill, David)
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Filing 24
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Edward Craven, Primedice, Stake.com, Bijan Tehrani..(McGill, David)
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Filing 23
CASE MANAGEMENT PLAN AND SCHEDULING ORDER: All parties do not consent to conducting all further proceedings before a United States Magistrate Judge, including motions and trial. 28 U.S.C. 636(c). This case is to be tried to a jury. The parties have conferred and their present best estimate of the length of trial is 7 trial days. (Signed by Judge Ronnie Abrams on 12/2/2022) (ate)
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Minute Entry for proceedings held before Judge Ronnie Abrams: Initial Pretrial Conference held on 12/2/2022. (arc)
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Filing 22
ORDER granting #21 Motion for Stephen Patrick Hall to Appear Pro Hac Vice (HEREBY ORDERED by Judge Ronnie Abrams)(Text Only Order) (arc)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #21 MOTION for Stephen Patrick Hall to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27012412. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies. (sac)
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Filing 21
MOTION for Stephen Patrick Hall to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27012412. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Edward Craven, Primedice, Stake.com, Bijan Tehrani. (Attachments: #1 Affidavit Affidavite, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Hall, Stephen)
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Filing 20
PROPOSED CASE MANAGEMENT PLAN. Document filed by Christopher Freeman..(Fleming, William)
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Filing 19
JOINT LETTER addressed to Judge Ronnie Abrams from William B. Fleming dated November 23, 2022 re: Joint Status Letter. Document filed by Christopher Freeman..(Fleming, William)
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Filing 18
NOTICE OF APPEARANCE by R. David Hosp on behalf of Edward Craven, Primedice, Stake.com, Bijan Tehrani..(Hosp, R.)
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Filing 17
NOTICE OF APPEARANCE by David Harrison McGill on behalf of Edward Craven, Primedice, Stake.com, Bijan Tehrani..(McGill, David)
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Filing 16
ELECTRONIC SUMMONS ISSUED as to Bijan Tehrani. (sj)
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Filing 15
ELECTRONIC SUMMONS ISSUED as to Primedice. (sj)
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Filing 14
REQUEST FOR ISSUANCE OF SUMMONS as to Bijan Tehrani, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William)
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Filing 13
REQUEST FOR ISSUANCE OF SUMMONS as to Primedice, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William)
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Filing 12
MEMO ENDORSEMENT on re: #5 Letter filed by Christopher Freeman. ENDORSEMENT: The initial pretrial conference is adjourned to December 2, 2022 at 1:30 p.m. Call-In Number: (888) 363-4749; Access Code: 1015508#. The parties shall file a proposed case management plan and joint status letter no later than one week prior to the conference, assuming service is effectuated by that date. SO ORDERED. ( Initial Conference set for 12/2/2022 at 01:30 PM before Judge Ronnie Abrams.) (Signed by Judge Ronnie Abrams on 10/19/2022) (tg)
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Filing 11
ELECTRONIC SUMMONS ISSUED as to Stake.com..(jgo)
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Filing 10
ELECTRONIC SUMMONS ISSUED as to Edward Craven..(jgo)
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Filing 9
REQUEST FOR ISSUANCE OF SUMMONS as to Edward Craven, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William)
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Filing 8
FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Bijan Tehrani, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William) Modified on 10/19/2022 (jgo).
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Filing 7
FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Primedice, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William) Modified on 10/19/2022 (jgo).
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Filing 6
REQUEST FOR ISSUANCE OF SUMMONS as to Stake.com, re: #1 Complaint. Document filed by Christopher Freeman..(Fleming, William)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney William Fleming to RE-FILE Document No. #8 Request for Issuance of Summons, #7 Request for Issuance of Summons. The filing is deficient for the following reason(s): party name on the PDF 'To' section does not match name listed on docket entry text;. 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. (jgo)
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Filing 5
LETTER addressed to Judge Ronnie Abrams from William B. Fleming dated 10/18/2022 re: Freeman v. Stake.com, et al, No. 1:22-cv-07002-RA (S.D.N.Y.). Document filed by Christopher Freeman..(Fleming, William)
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Filing 4
ORDER: An initial pretrial conference is scheduled in this matter for October 21, 2022. Pursuant to the Court's August 24, 2022 Order, the parties were obligated to submit a proposed case management plan and joint letter by October 14, 2022. As of the date of this order, the parties have not filed these materials. The parties are directed to file a joint status letter and proposed case management plan no later than October 20, 2022. (Signed by Judge Ronnie Abrams on 10/18/2022) (ate)
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Filing 3
ORDER AND NOTICE OF INITIAL CONFERENCE: IT IS FURTHER ORDERED that counsel for all parties appear for an initial status conference on October 21, 2022 at 11:00 a.m. Unless the parties request otherwise, the Court will hold this conference by 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 10/21/2022 at 11:00 AM before Judge Ronnie Abrams. (Signed by Judge Ronnie Abrams on 8/24/2022) (ate)
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***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney William Fleming. The following case opening statistical information was erroneously selected/entered: Dollar Demand 200,000,000,000; County code Albany; Fee Status code due (due). The following correction(s) have been made to your case entry: the Dollar Demand has been modified to 9,999,000; the County code has been modified to XX Out of State; the Fee Status code has been modified to pd (paid). (vf)
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***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney William Fleming. The party information for the following party/parties has been modified: Edward Craven, Primedice, Stake.com, Bijan Tehrani, Christopher Freeman. The information for the party/parties has been modified for the following reason/reasons: party role was entered incorrectly. (vf)
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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..(vf)
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Case Designated ECF. (vf)
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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)
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Filing 2
CIVIL COVER SHEET filed..(Fleming, William)
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Filing 1
COMPLAINT against Edward Craven, Primedice, Stake.com, Bijan Tehrani. (Filing Fee $ 402.00, Receipt Number ANYSDC-26558362)Document filed by Christopher Freeman..(Fleming, William)
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