American Achievement Corporation v. Fitzgerald
Plaintiff: American Achievement Corporation
Defendant: Jennifer Fitzgerald
Case Number: 1:2023cv03139
Filed: April 14, 2023
Court: US District Court for the Southern District of New York
Presiding Judge: J Paul Oetken
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332 Diversity Action
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on October 17, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
September 25, 2023 Opinion or Order Filing 58 ORDER granting #57 Letter Motion for Extension of Time to File: Granted. Balfour shall file a response to the motion to dismiss on or before October 9, 2023. Fitzgerald shall file a reply on or before October 30, 2023. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (nhb)
September 22, 2023 Filing 57 JOINT LETTER MOTION for Extension of Time to File : Balfour respectfully requests a 10-day extension of time up to and including October 9, 2023, to respond to the Motion to Dismiss addressed to Judge J. Paul Oetken from Eric L. Ray dated September 22, 2023. Document filed by American Achievement Corporation..(Ray, Eric)
September 15, 2023 Filing 56 MEMORANDUM OF LAW in Support re: #55 MOTION to Dismiss / Notice of Defendant Jennifer Fitzgerald's Motion to Dismiss. . Document filed by Jennifer Fitzgerald..(Mastro, Randy)
September 15, 2023 Filing 55 MOTION to Dismiss / Notice of Defendant Jennifer Fitzgerald's Motion to Dismiss. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
August 8, 2023 Opinion or Order Filing 54 ORDER granting #53 Letter Motion for Extension of Time: Defendant Jennifer Fitzgerald shall respond to Plaintiff's Amended Complaint on or by September 15, 2023. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (nhb)
August 7, 2023 Filing 53 LETTER addressed to Judge J. Paul Oetken from Randy M. Mastro dated August 7, 2023 re: Request for an Extension of Time to Respond to the Amended Complaint. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
August 3, 2023 Opinion or Order Filing 52 ORDER granting #51 Letter Motion to Adjourn Conference: GRANTED. The hearing scheduled for August 30, 2023, is hereby cancelled in light of the withdrawal of Plaintiff's request for a preliminary injunction, and the motion for a preliminary injunction is denied as moot. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
August 2, 2023 Filing 51 LETTER MOTION to Adjourn Conference /Cancel the August 30, 2023 hearing on Balfour's motion for preliminary injunction addressed to Judge J. Paul Oetken from Eric L. Ray dated August 2, 2023. Document filed by American Achievement Corporation..(Ray, Eric)
August 2, 2023 Filing 50 AMENDED COMPLAINT amending #1 Complaint, against Jennifer Fitzgerald with JURY DEMAND.Document filed by American Achievement Corporation. Related document: #1 Complaint,. (Attachments: #1 Exhibit A: Employee Covenants Agreement, #2 Exhibit B: February 28, 2023 letter to Fitzgerald, #3 Supplement Doc #49 ORDER granting permission to file an Amended Complaint).(Lada, Jennifer)
August 1, 2023 Filing 49 MEMO ENDORSEMENT on re: #48 Letter filed by American Achievement Corporation. ENDORSEMENT: Plaintiff is hereby granted leave to file the Amended Complaint, which is permitted under Rule 3(D) of this Court's Individual Rules and Practices in Civil Cases. Plaintiff is directed to re-file the Amended Complaint on ECF within 7 days and the Clerk of Court is directed to permit such filing. (Signed by Judge J. Paul Oetken on 8/1/2023) (ate) Modified on 8/2/2023 (ate).
August 1, 2023 Filing 48 LETTER addressed to Judge J. Paul Oetken from Eric L. Ray dated August 1, 2023 re: Amended Complaint filed on July 31, 2023. Document filed by American Achievement Corporation. (Attachments: #1 Exhibit July 10, 2023 letter).(Ray, Eric)
August 1, 2023 ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Jennifer Lada re: Document No. #47 Amended Complaint,. The filing is deficient for the following reason(s): Court's leave has not been granted; the pleading is amended more than 21 days after service of a responsive pleading; the order granting permission to file the pleading was not attached. File the Exhibit to Pleading event found under the event list Other Documents and attach either opposing party's written consent or Court's leave. (vf)
July 31, 2023 Filing 47 FILING ERROR - DEFICIENT PLEADING - FRCP RULE 15 NON-COMPLIANCE - AMENDED COMPLAINT amending #1 Complaint, against Jennifer Fitzgerald with JURY DEMAND.Document filed by American Achievement Corporation. Related document: #1 Complaint,. (Attachments: #1 Exhibit A - Employee Covenants Agreement, #2 Exhibit B - February 28, 2023 letter to Fitzgerald).(Lada, Jennifer) Modified on 8/1/2023 (vf).
July 18, 2023 Opinion or Order Filing 46 ORDER granting #45 Letter Motion for Extension of Time: Granted. The preliminary injunction evidentiary hearing is adjourned to August 30, 2023, at 10:00 a.m. It will be held in 40 Foley Square, Courtroom 706. In addition, witnesses should be prepared to present specific and detailed information about competing lines of business of the companies, meaning specific revenue numbers and not merely references to "significant" portions of business. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
July 17, 2023 Filing 45 CONSENT LETTER MOTION for Extension of Time for Evidentiary Hearing addressed to Judge J. Paul Oetken from Randy M. Mastro dated July 17, 2023. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
July 14, 2023 Opinion or Order Filing 44 ORDER: Counsel for the parties shall appear for an evidentiary hearing on the pending motion for a preliminary injunction before the Court on August 23, 2023 at 10:00 am. The hearing shall be held in Courtroom 706 of the Thurgood Marshall Courthouse, 40 Foley Square, New York, New York. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (lar)
July 10, 2023 Filing 43 LETTER addressed to Judge J. Paul Oetken from Jennifer Lada dated July 10, 2023 re: intend to file an amended pleading on or before July 31, 2023. Document filed by American Achievement Corporation..(Lada, Jennifer)
June 30, 2023 Filing 42 MEMORANDUM OF LAW in Support re: #41 MOTION to Dismiss the Complaint. . Document filed by Jennifer Fitzgerald..(Mastro, Randy)
June 30, 2023 Filing 41 MOTION to Dismiss the Complaint. Document filed by Jennifer Fitzgerald. Responses due by 7/14/2023.(Mastro, Randy)
June 16, 2023 Filing 40 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 5/18/2023 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)
June 16, 2023 Filing 39 TRANSCRIPT of Proceedings re: CONFERENCE held on 5/19/2023 before Judge J. Paul Oetken. Court Reporter/Transcriber: Sadie Herbert, (212) 805-0310. 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 7/7/2023. Redacted Transcript Deadline set for 7/17/2023. Release of Transcript Restriction set for 9/14/2023..(McGuirk, Kelly)
June 14, 2023 Filing 38 LETTER addressed to Judge J. Paul Oetken from Jennifer Lada dated June 14, 2023 re: in response to letter from counsel for Defendant dated June 12, 2023. Document filed by American Achievement Corporation. (Attachments: #1 Exhibit A: June 12th letter, #2 Exhibit B: Chapter 11 Petition United States Bankruptcy Court for the Northern District of Texas, under Case No. 21-30057, #3 Exhibit C: Order of dismissal, #4 Exhibit D: Joint Motion to Dismiss Chapter 11 Petitions, #5 Exhibit E: Order granting Joint Motion to Dismiss).(Lada, Jennifer)
June 8, 2023 Filing 37 REPLY MEMORANDUM OF LAW in Support re: #15 Order to Show Cause,,,,,,,,,,, 29 Order, . Document filed by American Achievement Corporation..(Lada, Jennifer)
June 8, 2023 Filing 36 DECLARATION of Anita J. Rader in Support re: #15 Order to Show Cause,,,,,,,,,,, 29 Order,. Document filed by American Achievement Corporation..(Lada, Jennifer)
June 5, 2023 Opinion or Order Filing 35 ORDER granting #33 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh)
June 2, 2023 Opinion or Order Filing 34 ORDER granting in part and denying in part #31 Letter Motion for Extension of Time to Answer: Defendant shall move, answer, or otherwise respond on or by June 30, 2023. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (lar)
June 2, 2023 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #33 MOTION for Christopher P. Eby to Appear Pro Hac Vice ( initially filed as ECF Doc. 30 and fee paid -. Filing fee $ 200.00, receipt number ANYSDC-27774164). Motion and supporting papers to be reviewed by Clerk's. The document has been reviewed and there are no deficiencies. (sgz)
June 1, 2023 Filing 33 MOTION for Christopher P. Eby to Appear Pro Hac Vice ( initially filed as ECF Doc. 30 and fee paid -. Filing fee $ 200.00, receipt number ANYSDC-27774164). Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jennifer Fitzgerald. (Attachments: #1 Affidavit of Christopher P. Eby in Support of Admission Pro Hac Vice, #2 Exhibit - IL Certificate of Good Standing, #3 Exhibit - GA Certificate of Good Standing, #4 Text of Proposed Order Granting Pro Hac Admission).(Eby, Christopher)
June 1, 2023 Filing 32 LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from Jennifer Lada dated June 1, 2023 re: #31 LETTER MOTION for Extension of Time to File Answer re: #1 Complaint, / vacate Defendant Jennifer Fitzgerald's deadline to respond to Plaintiff's Complaint, which is currently set for June 5, 2023, pending further order of the Court . Document filed by American Achievement Corporation..(Lada, Jennifer)
June 1, 2023 Filing 31 LETTER MOTION for Extension of Time to File Answer re: #1 Complaint, / vacate Defendant Jennifer Fitzgerald's deadline to respond to Plaintiff's Complaint, which is currently set for June 5, 2023, pending further order of the Court addressed to Judge J. Paul Oetken from Melanie Burke, Esq. dated 6/1/2023. Document filed by Jennifer Fitzgerald..(Burke, Melanie)
May 23, 2023 Filing 30 FILING ERROR - DEFICIENT DOCKET ENTRY - SIGNATURE ERROR - MOTION for Christopher P. Eby to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27774164. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jennifer Fitzgerald. (Attachments: #1 Affidavit of Christopher P. Eby in Support of Motion for Submission Pro Hac Vice, #2 Exhibit Letter of Good Standing from the State Bar of Illinois, #3 Exhibit Letter of Good Standing from the State Bar of Georgia, #4 Text of Proposed Order Proposed Order).(Mastro, Randy) Modified on 5/23/2023 (va).
May 23, 2023 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #30 MOTION for Christopher P. Eby to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number ANYSDC-27774164. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Illinois; the motion was not signed correctly (requires a wet signature). 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. (va)
May 19, 2023 Minute Entry for proceedings held before Judge J. Paul Oetken: Telephonic Preliminary Injunction Hearing held on 5/19/2023. See transcript. (bh)
May 19, 2023 Opinion or Order Filing 29 ORDER: As discussed in the Order to Show Cause hearing held by telephone on May 19, 2023, the TRO, including expedited discovery (see ECF No. #15 ) is terminated pending further order. Plaintiff's reply shall be filed by June 8, 2023. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (lar)
May 18, 2023 Opinion or Order Filing 28 ORDER granting #22 Motion for Eric L. Ray to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (lar)
May 17, 2023 Filing 27 DECLARATION of Arpit Bhoti in Opposition re: #4 Proposed Order to Show Cause Without Emergency Relief, #15 Order to Show Cause,,,,,,,,,,,. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 17, 2023 Filing 26 DECLARATION of Josh Cady in Opposition re: #4 Proposed Order to Show Cause Without Emergency Relief, #15 Order to Show Cause,,,,,,,,,,,. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 17, 2023 Filing 25 DECLARATION of Jaclyn Cannon in Opposition re: #4 Proposed Order to Show Cause Without Emergency Relief, #15 Order to Show Cause,,,,,,,,,,,. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 17, 2023 Filing 24 DECLARATION of Jennifer Fitzgerald in Opposition re: #4 Proposed Order to Show Cause Without Emergency Relief, #15 Order to Show Cause,,,,,,,,,,,. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 17, 2023 Filing 23 MEMORANDUM OF LAW in Opposition re: #4 Proposed Order to Show Cause Without Emergency Relief, #15 Order to Show Cause,,,,,,,,,,, - Defendant's Memorandum of Law in Opposition to Plaintiff's Order to Show Cause for Temporary Restraining Order, Preliminary Injunction, and Expedited Discovery. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 17, 2023 Filing 22 MOTION for Eric L. Ray to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Achievement Corporation. (Attachments: #1 Affidavit of Eric L. Ray, #2 Exhibit A - NY Cert. of Good Standing, #3 Exhibit B - DC Cert. of Good Standing, #4 Exhibit C - Florida Cert. of Good Standing, #5 Text of Proposed Order for Admission Pro Hac Vice).(Ray, Eric)
May 17, 2023 Filing 21 FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Eric L. Ray to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27749755. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Achievement Corporation. (Attachments: #1 Affidavit of Eric L. Ray, #2 Exhibit A - NY Cert. of Good Standing, #3 Exhibit B - DC Cert. of Good Standing, #4 Text of Proposed Order for Admission Pro Hac Vice).(Ray, Eric) Modified on 5/17/2023 (dsh).
May 17, 2023 >>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #21 MOTION for Eric L. Ray to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27749755. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from The Supreme Court of Florida;. 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.. (dsh)
May 17, 2023 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #22 MOTION for Eric L. Ray 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. (dsh)
May 16, 2023 Opinion or Order Filing 20 ORDER granting #19 Letter Motion for Extension of Time to Answer: Granted. Defendant shall move, answer, or otherwise respond on or by June 5, 2023. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (lar)
May 12, 2023 Filing 19 CONSENT LETTER MOTION for Extension of Time to File Answer re: #1 Complaint, until June 5, 2023 addressed to Judge J. Paul Oetken from Randy M. Mastro, Esq. dated 5/12/23. Document filed by Jennifer Fitzgerald..(Mastro, Randy)
May 12, 2023 Filing 18 NOTICE OF APPEARANCE by Melanie Burke on behalf of Jennifer Fitzgerald..(Burke, Melanie)
May 12, 2023 Filing 17 NOTICE OF APPEARANCE by Randy M. Mastro on behalf of Jennifer Fitzgerald..(Mastro, Randy)
May 11, 2023 Filing 16 UNDERTAKING ON PRELIMINARY INJUNCTION. BOND # 3511141 in the amount of $ 5,000.00 posted by American Achievement Corporation. Re: #15 Order..(nd)
May 9, 2023 Opinion or Order Filing 15 ORDER TO SHOW CAUSE WITH TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND EXPEDITED DISCOVERY. It is hereby: ORDERED, that Defendant Jennifer Fitzgerald ("Fitzgerald") show cause before the Hon. J. Paul Oetken, United States District Court for the Southern District of New York, on Friday, May 19, 2023, at 3:00 p.m., by telephone hearing accessed by dialing 888-557-8511 and entering access code 9300838 why an Order should not be entered in this matter pursuant to Rule 65 of the Federal Rules of Civil Procedure: (1) Temporarily enjoining Defendant Fitzgerald from: (a) for a 12-month period, performing any services in violation of her non-competition covenant (the "Non-Competition Provision"), and for an 18 month period, performing any services in violation of her non-solicitation covenant (the "Non-Solicitation Provision") as agreed upon with Balfour in her Employee Covenants Agreement, including on behalf of Cady, Studios LLC ("Cady") or any of its affiliates or employees/contractors; (b) accessing, using, or disclosing Balfour's Confidential Information (as defined in the Confidentiality Provision in her Employee Covenants Agreement) and as further set forth in this Order. It is ORDERED, that Defendant Fitzgerald is temporarily enjoined and restrained from: (a) accessing, using, or disclosing Balfours Confidential Information (as defined in the Confidentiality Provision in her Employee Covenants Agreement); (b) violating any other provision of the Employee Covenants Agreement, including the non-solicitation provisions contained therein; and (c) deleting or failing to preserve any evidence relating to this matter, and it is further ORDERED that discovery may commence immediately upon receipt of this Order, and Balfour is permitted to serve 10 Requests for Production upon Fitzgerald, with answers due 14 days from receipt, take the deposition of Fitzgerald, and serve a subpoena on Cady, if necessary; and it is further ORDERED that security in the amount of $5,000 be posted by Balfour prior to May 11, 2023 at 1:00 o'clock p.m. that day; and it is further ORDERED that personal service of a copy of this Order to Show Cause and annexed Memorandum of Law, and Declarations, together with the Complaint, shall be served on counsel for Defendant or her counsel, on or before May 12, 2023, and shall be deemed good and sufficient service; and it is further ORDERED, that answering papers, if any, shall be served upon counsel for Balfour and filed on ECF, on or before May 17, 2023. ( Show Cause Hearing set for 5/19/2023 at 03:00 PM before Judge J. Paul Oetken. Show Cause Response due by 5/17/2023.) (Signed by Judge J. Paul Oetken on 5/9/23) (yv) Transmission to Finance Unit (Cashiers) for processing.
May 9, 2023 Filing 14 NOTICE OF APPEARANCE by Michael E Hantman on behalf of American Achievement Corporation..(Hantman, Michael)
May 5, 2023 Opinion or Order Filing 13 ORDER granting #12 Motion to Appear Pro Hac Vice. Granted. So ordered. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (bh)
May 4, 2023 Filing 12 MOTION for Michael E. Hantman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27696779. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Achievement Corporation. (Attachments: #1 Affidavit in support of motion, #2 Exhibit A - Cert. of Good Standing, #3 Text of Proposed Order to Admit Michael E. Hantman Pro Hac Vice).(Hantman, Michael)
May 4, 2023 >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #12 MOTION for Michael E. Hantman to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27696779. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
April 26, 2023 Filing 11 LETTER addressed to Judge J. Paul Oetken from Jennifer Lada dated April 26, 2023 re: acceptance of service of documents by Mr. Jeff Childers, counsel for Defendant Jennifer Fitzgerald. Document filed by American Achievement Corporation..(Lada, Jennifer)
April 17, 2023 Filing 10 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate AAC ICONIC Intermediate Holdings LLC for American Achievement Corporation. Document filed by American Achievement Corporation..(Lada, Jennifer)
April 17, 2023 Filing 9 ELECTRONIC SUMMONS ISSUED as to Jennifer Fitzgerald..(gp)
April 17, 2023 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. 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)
April 17, 2023 Case Designated ECF. (gp)
April 17, 2023 Magistrate Judge Jennifer Willis 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)
April 17, 2023 ***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION AND EXPEDITED DISCOVERY. Document No. #4 Proposed Order to Show Cause Without Emergency Relief, was reviewed and approved as to form. (nd)
April 14, 2023 Filing 8 REQUEST FOR ISSUANCE OF SUMMONS as to Jennifer Fitzgerald, re: #1 Complaint,. Document filed by American Achievement Corporation..(Lada, Jennifer)
April 14, 2023 Filing 7 MEMORANDUM OF LAW in Support re: #4 Proposed Order to Show Cause Without Emergency Relief, #1 Complaint, . Document filed by American Achievement Corporation..(Lada, Jennifer)
April 14, 2023 Filing 6 DECLARATION of Jennifer Lada in Support re: #4 Proposed Order to Show Cause Without Emergency Relief, #1 Complaint,. Document filed by American Achievement Corporation..(Lada, Jennifer)
April 14, 2023 Filing 5 DECLARATION of Anita J. Rader, in Support of re: #1 Complaint, #4 Proposed Order to Show Cause Without Emergency Relief, . Document filed by American Achievement Corporation. (Attachments: #1 Exhibit A - Employee Covenants Agreement, #2 Exhibit B - February 15th Email, #3 Exhibit C - February 28, 2023 letter to Fitzgerald).(Lada, Jennifer)
April 14, 2023 Filing 4 PROPOSED ORDER TO SHOW CAUSE WITHOUT EMERGENCY RELIEF. Document filed by American Achievement Corporation. Related Document Number: #1 ..(Lada, Jennifer) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
April 14, 2023 Filing 3 FILING ERROR - DEFICIENT DOCKET ENTRY - MISSING DIVERSITY INFORMATION - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate AAC ICONIC Intermediate Holdings LLC for American Achievement Corporation. Document filed by American Achievement Corporation..(Lada, Jennifer) Modified on 4/14/2023 (kw).
April 14, 2023 Filing 2 CIVIL COVER SHEET filed..(Lada, Jennifer)
April 14, 2023 Filing 1 COMPLAINT against Jennifer Fitzgerald. (Filing Fee $ 402.00, Receipt Number ANYSDC-27609370)Document filed by American Achievement Corporation. (Attachments: #1 Exhibit A - Employee Covenants Agreement, #2 Exhibit B - February 28, 2023 letter to Fitzgerald).(Lada, Jennifer)
April 14, 2023 ***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Jennifer Lada to RE-FILE Document No. #3 Rule 7.1 Corporate Disclosure Statement,. The filing is deficient for the following reason(s): the jurisdiction of this action is based on diversity - the party/intervenor did not name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. Re-file the document using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes radio button - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time - name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. (kw)

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Plaintiff: American Achievement Corporation
Represented By: Jennifer Lada
Represented By: Eric L. Ray
Represented By: Michael E Hantman
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Defendant: Jennifer Fitzgerald
Represented By: Randy M. Mastro
Represented By: Christopher Patrick Eby
Represented By: Melanie Burke
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