Crossborder Solutions, Inc. et al v. Hoy et al

Justia Dockets & Filings Second Circuit New York Southern District Crossborder Solutions, Inc. et al v. Hoy et al

Crossborder Solutions, Inc. et al v. Hoy et al

Plaintiff:	Crossborder Solutions, Inc., Cross Border Transactions, LLC and Cross Border Transactions, LLC doing business as Crossborder Solutions
Defendant:	Liga Hoy, Lijun "Maggie" Tian, Jiaxin "Claire" Song and Macias, Gini & OConnell LLP
Case Number:	7:2020cv04877
Filed:	June 25, 2020
Court:	US District Court for the Southern District of New York
Presiding Judge:	Nelson Stephen Roman
Nature of Suit:	Contract: Other
Cause of Action:	28 U.S.C. § 1332
Jury Demanded By:	None

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This docket was last retrieved on February 28, 2024. A more recent docket listing may be available from PACER.

Date Filed	Document Text
August 14, 2020	Filing 66 ANSWER to #34 Amended Complaint,. Document filed by Macias, Gini & OConnell LLP..(Margello, Sharon)
August 14, 2020	Filing 65 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Macias, Gini & OConnell LLP..(Margello, Sharon)
August 10, 2020	Filing 64 PROPOSED ORDER FOR WITHDRAWAL OF ATTORNEY. Document filed by Lijun "Maggie" Tian. Related Document Number: #63 ..(Stein, Wendy)
August 7, 2020	Filing 63 MEMO ENDORSEMENT granting #57 Letter Motion to Seal; denying #58 Letter Motion to Compel; denying #59 Letter Motion to Compel. ENDORSEMENT: The Court is in receipt of the Plaintiffs' letter motion to compel discovery (ECF No. 59), attached, as well as Defendants Hoy and Song's reply, (ECF No. 62), and Defendant Macias Gini & O'Connell LLP's reply (ECF No. 61). Plaintiffs' application is denied. As the Court made clear, Plaintiffs were granted the expedited discovery sought in connection with the August 7th Preliminary Injunction Hearing in this matter.(See ECF No. 32.) That hearing was adjourned upon the stipulation and agreement of all parties, which provided that the terms of the preliminary injunction proposed by Plaintiffs would be extended for the duration of the arbitration. (ECF No. 56.) As Plaintiffs have obtained the injunctive relief they requested, the expedited discovery is no longer necessary. The Court grants Plaintiffs' letter motion (ECF No. 57) to file the unredacted motion (ECF No. 59) under seal. In addition, as indicated in the correspondence, Gibbons P.C. no longer intends to represent Defendant Tian. (See ECF Nos. 60, 62.) Ms. Stein and Mr. Saso are therefore directed to submit a proposed order for their withdrawal as Ms. Tian's attorneys of record in accordance with Local Rule 1.4. The Clerk of the Court is respectfully directed to terminate the motions at ECF Nos. 57, 58, and 59. SO ORDERED. (Signed by Judge Nelson Stephen Roman on 8/7/2020) (jca)
August 5, 2020	Filing 62 LETTER RESPONSE in Opposition to Motion addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated August 8, 2020 re: #58 LETTER MOTION to Compel (REDACTED) addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020. . Document filed by Liga Hoy, Jiaxin "Claire" Song..(Stein, Wendy)
August 5, 2020	Filing 61 LETTER RESPONSE in Opposition to Motion addressed to Judge Nelson Stephen Roman from Sharon Margello dated 08052020 re: #59 LETTER MOTION to Compel addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020., #58 LETTER MOTION to Compel (REDACTED) addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020. . Document filed by Macias, Gini & OConnell LLP. (Attachments: #1 Exhibit A - Notice to Take MGO's Deposition, #2 Exhibit B RFP Served on MGO).(Margello, Sharon)
August 3, 2020	Filing 60 ORDER: Defendant Tian's instant request for pro bono counsel-her first request-cannot be granted at such an early stage in the litigation. This case commenced fewer than two months ago on June 25, 2020. (ECF No. 1.) Furthermore, pursuant to the parties' agreement and stipulation, the substantive issues in this case will be resolved via arbitration. (See ECF Nos. 54, 56.) Accordingly, the Court cannot conclude at this time that Tian is unable to handle the case without assistance, although this conclusion may change as the action progresses. Therefore, because the Court does not find any circumstances which warrant the appointment of pro bono counsel at this time, Defendant Tian's request is DENIED without prejudice to renew at a later stage in the proceedings. (Signed by Judge Nelson Stephen Roman on 8/3/2020) (rj)
July 31, 2020	Filing 59 *SELECTED PARTIES* LETTER MOTION to Compel addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020. Document filed by Crossborder Solutions, Inc., Cross Border Transactions, LLC, Liga Hoy, Macias, Gini & OConnell LLP, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Attachments: #1 Exhibit A Text Messages, #2 Exhibit B Affidavit of Liga Hoy)Motion or Order to File Under Seal: #57 .(Taber, Kenneth)
July 31, 2020	Filing 58 LETTER MOTION to Compel (REDACTED) addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc.. (Attachments: #1 Exhibit A Text Messages (REDACTED), #2 Exhibit B Affidavit of Liga Hoy (REDACTED)).(Taber, Kenneth)
July 31, 2020	Filing 57 LETTER MOTION to Seal regarding Letter Motion to Compel and Exhibits A - B attached thereto addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 31, 2020. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 30, 2020	Filing 56 STIPULATION AND ORDER: IT IS HEREBY ORDERED that pending further Order of this Court: 1. That all court deadlines in this action as to Individual Defendants as parties (but not as witnesses) are hereby stayed, with the exception of any deadlines relating to or arising out of the injunctive relief issued by this Court; and 2. The Individual Defendants and all persons acting in concert with or through any of them are enjoined for the duration of the arbitration between the Individual Defendants and Plaintiffs from: (a) Disclosing or using any CrossBorder client work product, client proposals, current or potential client lists, and information about client current and future needs (Confidential Information); (b) As to the Individual Defendants, from breaching their confidentiality obligations contained in their respective Employment Agreements with CrossBorder; (c) As to Defendants Song and Tian, from breaching their non-solicitation and non-competition contractual obligations contained in their respective Employment Agreements with CrossBorder with respect to all customers and potential future customers on Crossborder's customer or prospect lists; and (d) As to Defendants Hoy, and all persons acting in concert with or through her, from tortiously interfering with Song and Tian's contracts with CrossBorder and with any other CrossBorder employees' contracts with CrossBorder. 3. The August 7, 2020, preliminary injunction hearing previously scheduled by the Court is hereby cancelled. (Signed by Judge Nelson Stephen Roman on 7/30/2020) (rj)
July 29, 2020	Filing 55 PROPOSED STIPULATION AND ORDER. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 28, 2020	Filing 54 MEMO ENDORSEMENT on re: #52 Letter re: Letter filed by Wendy R. Stein, Esq. (Dkt no. 51) filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc., #51 Letter re: Consent to Entry of Proposed Preliminary Injunction, filed by Lijun "Maggie" Tian, Jiaxin "Claire" Song, Liga Hoy. ENDORSEMENT: The Court is in receipt of the Individual Defendants' letter (ECF No. 51), attached, as well as the Plaintiffs' reply (ECF No. 52). This correspondence informs the Court that all parties in this matter have agreed to extend the terms of the Stipulation and Order entered July 7, 2020 (ECF No. 23) for the entire duration of the arbitration process. Given that the preliminary injunction hearing is scheduled for August 7, 2020, the Court advises that a stipulation to that effect should be submitted for the Court to "so order" as soon as possible. (Signed by Judge Nelson Stephen Roman on 7/28/2020) (rj)
July 28, 2020	Filing 53 LETTER addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 28, 2020 re: Response to Letter Filed by Ken Taber. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Attachments: #1 Exhibit A, #2 Exhibit B).(Stein, Wendy)
July 28, 2020	Filing 52 LETTER addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 28, 2020 re: Letter filed by Wendy R. Stein, Esq. (Dkt no. 51). Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 28, 2020	Filing 51 LETTER addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 28, 2020 re: Consent to Entry of Proposed Preliminary Injunction. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 27, 2020	Filing 50 NOTICE OF APPEARANCE by Sharon Patricia Margello on behalf of Macias, Gini & OConnell LLP..(Margello, Sharon)
July 27, 2020	Filing 49 AFFIDAVIT OF SERVICE of Summons and Complaint, Amended Complaint,. Macias, Gini & OConnell LLP served on 7/24/2020, answer due 8/14/2020. Document filed by Crossborder Solutions, Inc. ; Cross Border Transactions, LLC..(Taber, Kenneth)
July 24, 2020	Filing 48 ORDER denying without prejudice #44 Letter Motion for Discovery. The Court is in receipt of the Individual Defendants' letter motion, (ECF No. 44), attached, requesting leave to serve expedited discovery, dated July 23, 2020. The Court is also in receipt of Plaintiffs' response, dated July 24, 2020 (ECF. 45), and the Individual Defendants' reply (ECF No. 47). The Individual Defendants' application is denied without prejudice, on the basis that the discovery requests are too general and lack sufficient specificity. See Digital Sin, Inc. v. Does 1-176, 279 F.R.D. 239, 241 (S.D.N.Y. 2012) ("Courts in this district have applied a 'flexible standard of reasonableness and good cause' in determining whether to grant a party's expedited discovery request") (quoting Ayyash v. Bank Al Madina, 233 F.R.D. 325, 326-27 (S.D.N.Y. 2011) (requiring party seeking expedited discovery to show: "(1) irreparable injury, (2) some probability of success on the merits, (3) some connection between expedited discovery and the avoidance of the irreparable injury, and (4) some evidence that the injury that will result without expedited discovery looms greater than the injury that the defendant will suffer if the expedited relief is granted."). The Clerk of the Court is respectfully directed to terminate the motion at ECF No. 44. SO ORDERED. (Signed by Judge Nelson Stephen Roman on 7/24/2020) (va) Modified on 8/19/2020 (va).
July 24, 2020	Filing 47 LETTER REPLY to Response to Motion addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 24, 2020 re: #44 LETTER MOTION for Discovery Expedited Discovery Requests, with Exhibit A attached addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 23, 2020. Corrected. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 24, 2020	Filing 46 LETTER REPLY to Response to Motion addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 24, 2020 re: #44 LETTER MOTION for Discovery Expedited Discovery Requests, with Exhibit A attached addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 23, 2020. . Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 24, 2020	Filing 45 LETTER RESPONSE to Motion addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 24, 2020 re: #44 LETTER MOTION for Discovery Expedited Discovery Requests, with Exhibit A attached addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 23, 2020. . Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 23, 2020	Filing 44 LETTER MOTION for Discovery Expedited Discovery Requests, with Exhibit A attached addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 23, 2020. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 22, 2020	Filing 43 ORDER granting #40 Letter Motion for Extension of Time to Answer re #34 Amended Complaint,. The Court is in receipt of the Individual Defendants' letter motion, (ECF No. 40), attached, requesting an extension of time to file their Answer to the Amended Complaint, dated July 21, 2020. The Court is also in receipt of Plaintiffs' response, dated July 22, 2020 (ECF No. 41). The Individual Defendants are granted until August 5, 2020 to file their Answer. There will be no further extensions. The Clerk of the Court is respectfully directed to terminate the motion at ECF No. 40., Liga Hoy answer due 8/5/2020; Jiaxin "Claire" Song answer due 8/5/2020; Lijun "Maggie" Tian answer due 8/5/2020. (Signed by Judge Nelson Stephen Roman on 7/22/2020) (rj)
July 22, 2020	Filing 42 ORDER denying #33 Letter Motion for Leave to File Document. The Court is in receipt of the Individual Defendants' letter motion, (ECF No. 33), attached, requesting reconsideration of the Court's memorandum endorsement, dated July 15, 2020. (ECF No. 32.) The Court is also in receipt of Plaintiffs' response, dated July 17, 2020 (ECF No. 37) and the Individual Defendants' reply, dated July 20, 2020 (ECF No. 39). Upon due consideration of the arguments presented in the parties' submissions, the Individual Defendants' application is denied. The Clerk of the Court is respectfully directed to terminate the motion at ECF No. 33. (Signed by Judge Nelson Stephen Roman on 7/22/2020) (rj)
July 22, 2020	Filing 41 LETTER addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 22, 2020 re: in response to Defendants' Request for an Extension of Time to Respond to Amended Complaint - Dkt. #40. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 21, 2020	Filing 40 LETTER MOTION for Extension of Time to File Answer re: #34 Amended Complaint, addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 21, 2020. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Attachments: #1 Exhibit A).(Stein, Wendy)
July 20, 2020	Filing 39 REPLY MEMORANDUM OF LAW in Support re: #33 LETTER MOTION for Leave to File Proposed Motion to Compel (reconsider) addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 15, 2020. . Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 17, 2020	Filing 38 ELECTRONIC SUMMONS ISSUED as to Macias, Gini & OConnell LLP..(jgo)
July 17, 2020	Filing 37 LETTER addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 17, 2020 re: Response to Letter Motion from Defendants Liga Hoy, Jiaxin "Claire" Song and Lijun "Maggie" Tian's (collectively, the "Individual Defendants") requesting Reconsideration of Order Granting Expedited Discovery, Dkt No. 33. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 16, 2020	Filing 36 ORDER with respect to #33 Letter Motion for Leave to File Document. The Court is in receipt of Defendants' letter motion, (ECF No. 33), attached, requesting reconsideration of the Court's memorandum endorsement, dated July 15, 2020. (ECF No. 32.) Plaintiffs are directed to file their response on or before Friday, July 17, 2020. Defendants' reply, if any, shall be filed on or before Monday July 20, 2020. In these submissions, the parties are instructed to cite to controlling authority in support of their respective positions where possible. (Signed by Judge Nelson Stephen Roman on 7/16/2020) (rj)
July 16, 2020	Filing 35 REQUEST FOR ISSUANCE OF SUMMONS as to Macias, Gini & O'Connell LLP, re: #34 Amended Complaint,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 16, 2020	Filing 34 AMENDED COMPLAINT amending #1 Complaint, against Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian, Macias, Gini & OConnell LLP.Document filed by Crossborder Solutions, Inc., Cross Border Transactions, LLC. Related document: #1 Complaint,. (Attachments: #1 Exhibit A.1 Employment Agreement, #2 Exhibit A.2 Employment Agreement, #3 Exhibit A.3 Employment Agreement).(Taber, Kenneth)
July 16, 2020	Set/Reset Deadlines: Responses due by 7/17/2020 Replies due by 7/20/2020. (rj)
July 15, 2020	Filing 33 LETTER MOTION for Leave to File Proposed Motion to Compel (reconsider) addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 15, 2020. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 15, 2020	Filing 32 MEMO ENDORSEMENT on #30 granting #24 Letter Motion for Conference.ENDORSEMENT: The Court reviewed Plaintiffs' attached pre-motion letter seeking expedited discovery, dated July 8, 2020 (ECF No. 24.), as well as Defendants' response (ECF No. 30). The Court has also reviewed Defendants' pre-motion letter seeking to compel arbitration, dated July 9, 2020 (ECF No. 27), as well as Plaintiffs' response (ECF No. 28). Defendants' application regarding arbitration is denied without prejudice as premature. Each of the relevant employment agreements include a provision that, in the event of Defendants' breach of certain restrictive covenants, Plaintiff CrossBorder is entitled "in addition to any other right or remedy, to injunctive relief in any court of competent jurisdiction... enjoining or restraining [Defendants] from any such violation or threatened violations."). See Compl., ECF No. 1, Exs. A.1- A.3 10. As such, this matter is properly before the Court as it relates to any injunctive relief sought. As to any other form of relief, the parties appear to be in agreement that arbitration is appropriate for those portions of Plaintiffs' claims that do not concern injunctive relief. Plaintiffs are granted the expedited discovery sought in connection with the August 7th Preliminary Injunction Hearing in this matter, limited to the ten proposed document requests and four depositions: the three named Defendants, and the Macias Gini & O'Connell LLP witness in accordance with Federal Rule of Civil Procedure 30(b)(6). The depositions must also be limited to issues relevant to the injunctive relief sought.The Clerk of the Court is respectfully directed to terminate the motion at ECF No. 24. (Signed by Judge Nelson Stephen Roman on 7/14/2020) (rro)
July 14, 2020	Filing 31 NOTICE OF APPEARANCE by Paul Anthony Saso on behalf of Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Saso, Paul)
July 13, 2020	Filing 30 LETTER RESPONSE in Opposition to Motion addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 13, 2020 re: #24 LETTER MOTION for Conference addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated 07/08/2020. . Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Attachments: #1 Exhibit A, #2 Exhibit B).(Stein, Wendy)
July 10, 2020	Filing 29 ORDER FOR PRO HAC VICE ADMISSION granting #25 Motion for Paula M. Weber to Appear Pro Hac Vice. (Signed by Judge Nelson Stephen Roman on 7/10/2020) (nb)
July 10, 2020	Filing 28 LETTER addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated July 10. 2020 re: Response to Defendants' July 9, 2020 Pre-Motion Submission for Motion to Compel Arbitration (Dkt 27). Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 9, 2020	Filing 27 LETTER addressed to Judge Nelson Stephen Roman from Wendy R. Stein, Esq. dated July 9, 2020 re: Anticipated Motion to Compel Arbitration. Document filed by Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Stein, Wendy)
July 9, 2020	Filing 26 DECLARATION of Paula M. Weber in Support re: #25 MOTION for Paula M. Weber to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-20617799. Motion and supporting papers to be reviewed by Clerk's Office staff.. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc.. (Attachments: #1 Exhibit A California Bar Certificate of Good Standing for Paula Weber, #2 Text of Proposed Order).(Weber, Paula)
July 9, 2020	Filing 25 MOTION for Paula M. Weber to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-20617799. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Weber, Paula) Modified on 7/9/2020 (aea). Modified on 7/9/2020 (ad).
July 9, 2020	>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #25 MOTION for Paula M. Weber to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-20617799. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. Declaration and Certificate in Doc # 26. (ad)
July 8, 2020	Filing 24 LETTER MOTION for Conference addressed to Judge Nelson Stephen Roman from Kenneth W. Taber dated 07/08/2020. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc.. (Attachments: #1 Exhibit A - Plaintiffs' First Set of Requests for the Production of Documents to Defendant Liga Hoy).(Taber, Kenneth)
July 7, 2020	Filing 23 STIPULATION AND ORDER: IT IS HEREBY ORDERED that pending further Order of this Court: 1. That all court deadlines in this action are hereby stayed for thirty (30) days; and 2. Until the Court rules on Plaintiffs' preliminary injunction motion, Defendants, including their agents, employees and all persons acting in concert with any of them, are enjoined from: (a) Disclosing or using any CrossBorder client work product, client proposals, current or potential client lists, and information about client current and future needs ("Confidential Information"); (b) Breaching their confidentiality obligations contained in their respective Employment Agreements with CrossBorder; (c) As to Defendants Song and Tian, from breaching their non-solicitation and non-competition contractual obligations contained in their respective Employment Agreements with CrossBorder with respect to all customers and potential future customers on Crossborder's customer or prospect lists; and (d) As to Defendant Hoy, from tortiously interfering with Song and Tian' s contracts with Cross Border and with any other CrossBorder employees' contracts with CrossBorder. We hereby consent to the form and entry of the within Order: The Show Cause Hearing for Preliminary Injunction Teleconference is adjourned from July 7, 2020 until August 7, 2020 at 2:00 pm. Call-in instructions are previously listed on ECF. The Court further directs Defendants' response papers to Plaintiffs' motion for preliminary injunction be filed on or before July 28, 2020. Plaintiffs' reply papers, if any, shall be filed on or before August 4, 2020. Counsel shall provide an electronic version of their respective papers by email to Chambers on the date of filing. (Signed by Judge Nelson Stephen Roman on 7/7/2020) (rj)
July 7, 2020	Filing 22 NOTICE OF APPEARANCE by Wendy Risa Stein on behalf of Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian..(Stein, Wendy)
July 7, 2020	Filing 21 PROPOSED STIPULATION AND ORDER. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
July 7, 2020	Set/Reset Deadlines: ( Responses due by 7/28/2020, Replies due by 8/4/2020.), Set/Reset Hearings:( Telephone Conference set for 8/7/2020 at 02:00 PM before Judge Nelson Stephen Roman.) (rj)
July 6, 2020	Filing 20 SUMMONS RETURNED EXECUTED Summons and Complaint, served. Liga Hoy served on 6/30/2020, answer due 7/21/2020. Service was accepted by Liga Hoy. Document filed by Crossborder Solutions, Inc. ; Cross Border Transactions, LLC..(Taber, Kenneth)
July 2, 2020	Filing 19 SUMMONS RETURNED EXECUTED. Jiaxin "Claire" Song served on 6/30/2020, answer due 7/21/2020. Service was accepted by QI Hi. Document filed by Crossborder Solutions, Inc. ; Cross Border Transactions, LLC..(Taber, Kenneth)
July 1, 2020	Filing 18 SUMMONS RETURNED EXECUTED. Lijun "Maggie" Tian served on 6/29/2020, answer due 7/20/2020. Service was accepted by Steve Wang. Document filed by Crossborder Solutions, Inc. ; Cross Border Transactions, LLC..(Taber, Kenneth)
June 26, 2020	Filing 17 SCHEDULING ORDER: It is hereby ORDERED that the above case is scheduled for Show Cause Hearing for Preliminary Injunction teleconference on July 7, 2020 at 10:00 am. To access the teleconference, please follow these directions: (1) Dial the Meeting Number: (877) 336-1839; (2) Enter the Access Code: 1231334 #; (3) Press pound (#) to enter the teleconference as a guest. In preparation for and while engaging in a teleconference, please follow these guidelines: 1. Use a landline whenever possible. 2. Use handset rather than speakerphone. 3. Identify yourself each time you speak. 4. Be mindful that, unlike in a courtroom setting, interrupting can render both speakers unintelligible. 5. Mute when not speaking to eliminate background noise, i.e., dog barking, kids playing, sirens, papers shuffling, emails pinging, drinking, breathing. It all comes through. This will also prevent interruptions. 6. Avoid voice-activated systems that don't allow the speaker to know when someone else is trying to speak and they cut off the beginning of words. 7. Spell proper names. 8. Have judge confirm reporter is on the line. 9. If someone hears beeps or musical chimes, that means someone has either come in or left the conference. Please be aware that the judge may need to clarify that the reporter has not lost the line. (This has happened before, and the reporter had to dial back in and tell the judge the last thing that the court reporter transcribed.) Plaintiffs' counsel directed to serve a copy of the Order on Defendants or their respective counsel and file proof of service. SO ORDERED., Telephone Conference set for 7/7/2020 at 10:00 AM before Judge Nelson Stephen Roman. (Signed by Judge Nelson Stephen Roman on 6/26/2020) (rj)
June 26, 2020	Filing 16 ORDER TO SHOW CAUSE FOR PRELIMINARY INJUNCTION AND TEMPORARY RESTRAINING ORDER: Show Cause Hearing set for 7/7/2020 at 10:00 AM before Judge Nelson Stephen Roman or as soon thereafter as counsel may be heard, why an order should not be issued pursuant to Rule 65 of the Federal Rules of Civil Procedure enjoining the Defendants during the pendency of this action. ORDERED that the Plaintiff is not required to provide an undertaking in support of the restraining order; and it is further ORDERED that service by facsimile and overnight delivery of a copy of this Order and the above-referenced Declarations, Memorandum of Law and Complaint, with exhibits annexed thereto, upon the Defendants or their respective counsel on or before June 26, 2020, at 6:00 p.m. shall be deemed good and sufficient service thereof. (Signed by Judge Nelson Stephen Roman on 6/26/2020) (rj)
June 25, 2020	Filing 15 ELECTRONIC SUMMONS ISSUED as to Lijun "Maggie" Tian..(jgo)
June 25, 2020	Filing 14 ELECTRONIC SUMMONS ISSUED as to Liga Hoy..(jgo)
June 25, 2020	Filing 13 ELECTRONIC SUMMONS ISSUED as to Jiaxin "Claire" Song..(jgo)
June 25, 2020	Filing 12 MEMORANDUM OF LAW in Support re: #8 Proposed Order to Show Cause With Emergency Relief, . Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 11 AFFIDAVIT of Stephanie Israel in Support re: #8 Proposed Order to Show Cause With Emergency Relief,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc.. (Attachments: #1 Exhibit A Employment Agreement, #2 Exhibit B Employment Agreement, #3 Exhibit C Employment Agreement).(Taber, Kenneth)
June 25, 2020	Filing 10 AFFIDAVIT of Michael Bandemer in Support re: #8 Proposed Order to Show Cause With Emergency Relief,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc.. (Attachments: #1 Exhibit 1 Curriculum Vitae).(Taber, Kenneth)
June 25, 2020	Filing 9 AFFIRMATION of Kenneth W. Taber re: #8 Proposed Order to Show Cause With Emergency Relief, . Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 8 PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
June 25, 2020	Filing 7 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Cross Border Transactions, LLC..(Taber, Kenneth)
June 25, 2020	Filing 6 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 5 REQUEST FOR ISSUANCE OF SUMMONS as to Lijun "Maggie" Tian, re: #1 Complaint,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 4 REQUEST FOR ISSUANCE OF SUMMONS as to Jiaxin "Claire" Song, re: #1 Complaint,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 3 REQUEST FOR ISSUANCE OF SUMMONS as to Liga Hoy, re: #1 Complaint,. Document filed by Cross Border Transactions, LLC, Crossborder Solutions, Inc...(Taber, Kenneth)
June 25, 2020	Filing 2 CIVIL COVER SHEET filed..(Taber, Kenneth)
June 25, 2020	Filing 1 COMPLAINT against Liga Hoy, Jiaxin "Claire" Song, Lijun "Maggie" Tian. (Filing Fee $ 400.00, Receipt Number ANYSDC-20421386)Document filed by Crossborder Solutions, Inc., Cross Border Transactions, LLC. (Attachments: #1 Exhibit Ex A.1 Employment Agreement, #2 Exhibit Ex A.2 Employment Agreement, #3 Exhibit Ex A.3 Employment Agreement).(Taber, Kenneth)
June 25, 2020	***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. #8 Proposed Order to Show Cause With Emergency Relief, was reviewed and approved as to form. (dt)
June 25, 2020	Case Designated ECF. (jgo)
June 25, 2020	Magistrate Judge Judith C. McCarthy 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. (jgo)
June 25, 2020	CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Nelson Stephen Roman. 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..(jgo)
June 25, 2020	***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Kenneth William Taber. The following case opening statistical information was erroneously selected/entered: Dollar Demand $75,000,000; 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 $75,000; the County code has been modified to Westchester; the Fee Status code has been modified to pd (paid);. (jgo)

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Search for this case: Crossborder Solutions, Inc. et al v. Hoy et al
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Defendant: Liga Hoy
Represented By:	Paul Anthony Saso
Represented By:	Wendy Risa Stein
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Defendant: Lijun "Maggie" Tian
Represented By:	Paul Anthony Saso
Represented By:	Wendy Risa Stein
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Defendant: Jiaxin "Claire" Song
Represented By:	Paul Anthony Saso
Represented By:	Wendy Risa Stein
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Defendant: Macias, Gini & OConnell LLP
Represented By:	Sharon Patricia Margello
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Plaintiff: Crossborder Solutions, Inc.
Represented By:	Kenneth William Taber
Represented By:	Paula M. Weber
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Plaintiff: Cross Border Transactions, LLC
Represented By:	Kenneth William Taber
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Plaintiff: Cross Border Transactions, LLC doing business as Crossborder Solutions
Represented By:	Kenneth William Taber
Represented By:	Paula M. Weber
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