HAYES v. G&E REAL ESTATE MANAGEMENT SERVICES
| SHANNON HAYES |
| G&E REAL ESTATE MANAGEMENT SERVICES doing business as NEWMARK, Lexis/Nexis and NEWMARK GROUP |
| 1:2024cv01459 |
| February 26, 2024 |
| US District Court for the Southern District of New York |
| Edgardo Ramos |
| Civil Rights: Jobs |
| 28 U.S.C. § 1332 ed Diversity-Employment Discrimination |
| Plaintiff |
Docket Report
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This docket was last retrieved on April 18, 2024. A more recent docket listing may be available from PACER.
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| Filing 36 DECLARATION of Kelly C. Spina in Support re: #34 MOTION to Dismiss Plaintiff's Amended Complaint.. Document filed by G&E REAL ESTATE MANAGEMENT SERVICES. (Attachments: #1 Exhibit Amended Complaint, #2 Exhibit Charge of Discrimination, #3 Exhibit 3.28.24 Hearing Transcript before Hon. Edgardo Ramos).(Spina, Kelly) |
| Filing 35 MEMORANDUM OF LAW in Support re: #34 MOTION to Dismiss Plaintiff's Amended Complaint. . Document filed by G&E REAL ESTATE MANAGEMENT SERVICES..(Spina, Kelly) |
| Filing 34 MOTION to Dismiss Plaintiff's Amended Complaint. Document filed by G&E REAL ESTATE MANAGEMENT SERVICES. Responses due by 5/2/2024.(Spina, Kelly) |
| Filing 33 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/28/2024 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....(js) |
| Filing 32 TRANSCRIPT of Proceedings re: CONFERENCE held on 3/28/2024 before Judge Edgardo Ramos. Court Reporter/Transcriber: Marissa Lewandowski, (631) 813-9335. 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 4/26/2024. Redacted Transcript Deadline set for 5/6/2024. Release of Transcript Restriction set for 7/8/2024.(js) |
Filing 31
ORDER granting #28 Motion for Arinderjit Dhali to Appear Pro Hac Vice. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (jar)
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| Filing 30 LETTER addressed to Judge Edgardo Ramos from A.J Dhali dated March 27, 2024 re: As counsel for the Plaintiff Shannon Hayes, we respond to Defendants request to file a Rule 12 motion. Document filed by SHANNON HAYES. (jca) |
| Filing 29 LETTER RESPONSE to Motion addressed to Judge Edgardo Ramos from ARINDERJIT DHALI dated 3/27/2024 re: #26 LETTER MOTION for Conference re: #13 Amended Complaint (Pre-Motion Letter) addressed to Judge Edgardo Ramos from Kelly C. Spina dated 3/25/2024. . Document filed by SHANNON HAYES..(Dhali, Arinderjit (AJ)) |
| Filing 28 MOTION for ARINDERJIT DHALI to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-29143671. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by SHANNON HAYES. (Attachments: #1 Proposed Order Proposed Order).(Dhali, Arinderjit (AJ)) |
| Minute Entry for proceedings held before Judge Edgardo Ramos: Initial Pretrial Conference held on 3/28/2024 by telephone. Plaintiff's and Defendants' counsel present. Defendant is granted leave to file a motion to dismiss with the following briefing schedule: moving papers due April 18, 2024; opposition due March 2, 2024; and reply due March 9, 2024. (Conference was recorded.) (jar) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #28 MOTION for ARINDERJIT DHALI to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-29143671. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) |
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Filing 27
ORDER granting #26 Letter Motion for Conference re: #13 Amended Complaint (Pre-Motion Letter). The matter will be heard at the March 28 conference. Plaintiff is directed to respond by 5:00 p.m. Wednesday, March 27, 2024. (HEREBY ORDERED by Judge Edgardo Ramos)(Text Only Order) (jar)
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| Filing 26 LETTER MOTION for Conference re: #13 Amended Complaint (Pre-Motion Letter) addressed to Judge Edgardo Ramos from Kelly C. Spina dated 3/25/2024. Document filed by G&E REAL ESTATE MANAGEMENT SERVICES..(Pelage, Vernee) |
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Filing 25
STIPULATION AND ORDER OF SUBSTITUTION OF COUNSEL: IT IS HEREBY STIPULATED AND AGREED that the law firm of Littler Mendelson, P.C., shall be substituted as counsel of record for Defendant G&E Real Estate Management Services d/b/a Newmark in the above-captioned action, in the place and instead of the law firm Carr Maloney PC. SO ORDERED. (Signed by Judge Edgardo Ramos on 3/07/2024) (ama)
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Filing 24
ORDER: granting #22 Letter Motion for Extension of Time to Answer re #22 LETTER MOTION to Substitute Attorney. Old Attorney: Carr Maloney PC, New Attorney: Littler Mendelson, P.C. addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024. LETTER MOTION for Extension of Time to File Answer re: #13 Amended Complaint. addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024. LETTER MOTION to Adjourn Conference. addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024. NEWMARK GROUP answer due 3/25/2024; granting #22 Letter Motion to Adjourn Conference.; granting #22 Letter Motion to Substitute Attorney. The request is granted. Newmark shall respond to the amended complaint by March 25, 2024. The initial conference scheduled for March 13, 2024, is adjourned to March 28, 2024, at 11:00 a.m. The parties are reminded to dial 877-411-9748 and to enter access code: 3029857# when prompted. SO ORDERED. ( Initial Conference set for 3/28/2024 at 11:00 AM before Judge Edgardo Ramos.) Attorney Sarah W. Conkright and Andrew Frank Stewart terminated. (Signed by Judge Edgardo Ramos on 3/07/2024) (ama)
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| Filing 23 NOTICE OF APPEARANCE by Vernee Ciara Pelage on behalf of G&E REAL ESTATE MANAGEMENT SERVICES..(Pelage, Vernee) |
| Filing 22 LETTER MOTION to Substitute Attorney. Old Attorney: Carr Maloney PC, New Attorney: Littler Mendelson, P.C. addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024., LETTER MOTION for Extension of Time to File Answer re: #13 Amended Complaint addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024., LETTER MOTION to Adjourn Conference addressed to Judge Edgardo Ramos from Kelly C. Spina dated March 5, 2024. Document filed by G&E REAL ESTATE MANAGEMENT SERVICES. (Attachments: #1 Proposed Order Substitute Defense Counsel).(Spina, Kelly) |
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Filing 21
ORDER: An initial conference will be held on March 13, 2024, at 11:30 a.m. by telephone. The parties are instructed to call (877) 411-9748 and enter access code 3029857# when prompted. The Clerk of the Court is respectfully directed to terminate G&E Real Estate Management's Motion to Transfer, doc. 14.(Telephonic Initial Conference set for 3/13/2024 at 11:30 AM before Judge Edgardo Ramos.), Motions terminated: #14 MOTION to Dismiss filed by G&E REAL ESTATE MANAGEMENT SERVICES. (Signed by Judge Edgardo Ramos on 2/29/2024) (ama)
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| Filing 20 CASE TRANSFERRED IN from the United States District Court - District of District of Columbia; Case Number: 1:23-cv-00768. Original file certified copy of transfer order and docket entries received. |
| CASE OPENING INITIAL ASSIGNMENT NOTICE - TRANSFER CASE: This case is assigned to: Judge Edgardo Ramos. 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..(vba) |
| Magistrate Judge Robyn F. Tarnofsky is designated to handle matters that may be referred in this case. 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. (vba) |
| NOTE TO OUT OF STATE ATTORNEYS: Please visit the Court's website at https://nysd.uscourts.gov/ for information regarding admission to the S.D.N.Y. Bar and the CM/ECF Rules & Filing Instructions. (vba) |
| Case Designated ECF. (vba) |
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Filing 19
ORDER granting #14 Motion to Transfer Case. It is ORDERED that this action be TRANSFERRED to the United States District Court for the Southern District of New York for all further proceedings. Transfer due by 2/15/2024. See Order for details. Signed by Judge Amy Berman Jackson on 2/5/2024. (lcabj2) [Transferred from District of Columbia on 2/26/2024.]
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| SURREPLY to re #14 MOTION to Transfer Case or in the Alternative, Motion to Dismiss Plaintiff's Amended Complaint MOTION to Dismiss filed by SHANNON HAYES. (See Docket Entry #17 to view document). (znmw) [Transferred from District of Columbia on 2/26/2024.] |
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MINUTE ORDER granting #17 Motion for Leave to File Surreply. The Court will deem the #17 motion and its exhibits to be plaintiff's surreply. SO ORDERED. Signed by Judge Amy Berman Jackson on 07/06/2023. (lcabj2) [Transferred from District of Columbia on 2/26/2024.]
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| Filing 17 MOTION for Leave to File SURREPLY to re #14 MOTION to Transfer Case or in the Alternative, Motion to Dismiss Plaintiff's Amended Complaint MOTION to Dismiss filed by SHANNON HAYES. (Attachments: #1 Exhibit 1. Hayes Affidavit., #2 Text of Proposed Order)(Dhali, Arinderjit) Modified on 6/30/2023 to correct docket event/ text (zjm). [Transferred from District of Columbia on 2/26/2024.] |
| Filing 16 REPLY to opposition to motion re #14 MOTION to Transfer Case or in the Alternative, Motion to Dismiss Plaintiff's Amended Complaint MOTION to Dismiss filed by G&E REAL ESTATE MANAGEMENT SERVICES. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit)(Conkright, Sarah) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 15 Memorandum in opposition to re #14 Motion to Transfer Case,, Motion to Dismiss, filed by SHANNON HAYES. (Attachments: #1 Exhibit 1.)(Dhali, Arinderjit) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 14 MOTION to Transfer Case or in the Alternative, Motion to Dismiss Plaintiff's Amended Complaint by G&E REAL ESTATE MANAGEMENT SERVICES. (Attachments: #1 Memorandum in Support Memorandum in Support, #2 Text of Proposed Order Proposed Order, #3 Exhibit Exhibit A, #4 Exhibit Exhibit B)(Conkright, Sarah). Added MOTION to Dismiss on 6/5/2023 (znmw). [Transferred from District of Columbia on 2/26/2024.] |
| Filing 18 Receipt on 05/26/2023 of ORIGINAL FILE, certified copy of transfer order and docket sheet from Superior Court. Superior Court Number 2023-CAB-000342. (zjm) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 13 AMENDED COMPLAINT FIRST. against All Defendants with Jury Demand filed by SHANNON HAYES.(Dhali, Arinderjit) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 12 NOTICE of Appearance by Andrew Frank Stewart on behalf of NEWMARK GROUP (Stewart, Andrew) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 11 Consent MOTION for Extension of Time to Modify Pending Deadlines by LEXIS-NEXIS. (Attachments: #1 Text of Proposed Order Proposed Order)(Thomas, John) [Transferred from District of Columbia on 2/26/2024.] |
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MINUTE ORDER granting #11 Motion for Extension of Time. In the #11 motion, the parties informed the Court that plaintiff intends to file an amended complaint, which "obviat[es] the need to file oppositions to Defendants' Motions." Therefore, the #9 and #10 motions are DENIED AS MOOT. Plaintiff must file an amended complaint by May 12, 2023. Defendants must file an answer or otherwise respond to the amended complaint by June 2, 2023. SO ORDERED. Signed by Judge Amy Berman Jackson on 04/26/2023. (lcabj2) [Transferred from District of Columbia on 2/26/2024.]
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| Filing 10 MOTION to Dismiss Plaintiff's Complaint by LEXIS-NEXIS. (Attachments: #1 Memorandum in Support of Motion to Dismiss Plaintiff's Complaint, #2 Text of Proposed Order) (Thomas, John) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 9 MOTION to Transfer Case and/or Dismiss the Complaint by NEWMARK GROUP. (Attachments: #1 Memorandum in Support, #2 Text of Proposed Order, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Conkright, Sarah). Added MOTION to Dismiss on 4/13/2023 (znmw). [Transferred from District of Columbia on 2/26/2024.] |
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MINUTE ORDER granting #6 Motion for Extension of Time to File Responsive Pleading. Defendants must answer or otherwise respond to the complaint by April 12, 2023. SO ORDERED. Signed by Judge Amy Berman Jackson on 04/06/2023. (lcabj2) [Transferred from District of Columbia on 2/26/2024.]
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| Filing 8 NOTICE of Appearance by Arinderjit Dhali on behalf of SHANNON HAYES (Dhali, Arinderjit) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 7 LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by NEWMARK GROUP (Conkright, Sarah) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 6 Consent MOTION for Extension of Time to File Responsive Pleading to Complaint by NEWMARK GROUP. (Attachments: #1 Memorandum in Support Statement of Points and Authorities, #2 Text of Proposed Order Proposed Order)(Conkright, Sarah) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 5 NOTICE of Appearance by Sarah W. Conkright on behalf of NEWMARK GROUP (Conkright, Sarah) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 4 NOTICE to Counsel/Party re #1 Notice of Removal, (Attachment: #1 Notice and Consent)(zsl) [Transferred from District of Columbia on 2/26/2024.] |
| Case Assigned to Judge Amy Berman Jackson. (zsl) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 3 ERRATA by LEXIS-NEXIS. (Thomas, John) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 2 LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by LEXIS-NEXIS, NEWMARK GROUP (Thomas, John) [Transferred from District of Columbia on 2/26/2024.] |
| Filing 1 NOTICE OF REMOVAL from D.C. Superior Court, case number 2023-CAB-00342 Filing fee $ 402, receipt number ADCDC-9945626 filed by NEWMARK GROUP, LEXIS-NEXIS. (Attachments: #1 Exhibit A - D.C. Superior Court Process, Pleadings and Orders, #2 Exhibit B - D.C. Superior Court Notice of Filing of Notice of Removal, #3 Civil Cover Sheet)(Thomas, John) [Transferred from District of Columbia on 2/26/2024.] |
| NOTICE OF ERROR re #1 Notice of Removal; emailed to jethomas@mcguirewoods.com, cc'd 2 associated attorneys -- The PDF file you docketed contained errors: 1. Noncompliance with LCvR 5.1(c). Please file an errata correcting the initiating pleading to include the name & full residence address of each party using the event Errata., 2. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zsl, ) [Transferred from District of Columbia on 2/26/2024.] |
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