T.P. v. Wyndham Hotels & Resorts, Inc. et al
| T. P. and T.P. |
| WYNDHAM HOTELS AND RESORTS, INC, Red Roof Inns, Inc., Best Western International, Inc., American Hotel and Lodging Association, Ohio Hotel and Lodging Association, Wyndham Hotels & Resorts, Inc. and Liberty Mutual Fire Insurance Company |
| Erie Insurance Exchange |
| 888 Dublin Investment, LLC doing business as Best Western North formerly known as Neuman Investment, LLC, Columbus Hotel, Inc. doing business as Best Western North and Neuman Investment, LLC |
| 2:2021cv04933 |
| October 2, 2021 |
| US District Court for the Southern District of Ohio |
| Elizabeth Preston Deavers |
| Kimberly A Jolson |
| Algenon L Marbley |
| Sarah D Morrison |
| Other Statutory Actions |
| 28 U.S.C. § 1331 Fed. Question |
| Both |
Docket Report
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Filing 125
ORDER - The Motion to Extend Answer Date #121 is GRANTED. Third-Party Defendant Columbus Hotel, Inc. shall have 7 DAYS after the Court's resolution of the pending Plaintiff A.W.s Motion to Strike for Failure to State a Claim or in the Alternative Motion to Sever, or Stay Defendant Best Western International, Inc.'s Third-Party Complaint #115 , to move or otherwise plead in response to the Third-Party Complaint. The Motion for Extension of Time to Effectuate Service #123 also is GRANTED. Defendant/Third-Party Plaintiff, Best Western International, Inc. shall have until 12/11/2023 to serve Third-Party Defendant 888 Dublin Investments f/k/a Nueman Investment LLC d/b/a Best Western North. Signed by Magistrate Judge Elizabeth Preston Deavers on September 13, 2023. (jlk)
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Notation for statistical purposes: terminating #124 Motion for Extension of Time. (jlk)
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Filing 124
This document was inadvertently filed in this case and has been refiled in the correct case per attorney. (jlk) First MOTION for Extension of Time New date requested 12/11/2023. to Serve Third Party Defendant 888 Dublin Investment LLC (Refiled to Reflect Correct Caption) by Defendant Best Western International, Inc., ThirdParty Plaintiff Best Western International, Inc.. (Attachments: #1 Exhibit Corporate Information for Third Party Defendant, #2 Exhibit Rule 4(d) Waiver Materials, #3 Exhibit Good Faith Letter to Third Party Defendant) (Shulman, Corey) Modified text and terminated motion on 9/12/2023 (jlk).
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Filing 123
First MOTION for Extension of Time New date requested 12/11/2023. to Serve Third Party Defendant 888 Dublin Investment LLC by Defendant Best Western International, Inc., ThirdParty Plaintiff Best Western International, Inc.. (Attachments: #1 Exhibit Corporate Information for Third Party Defendant, #2 Exhibit Rule 4(d) Waiver Materials, #3 Exhibit Good Faith Letter to Third Party Defendant, #4 Exhibit Affidavit of Attempted Service) (Shulman, Corey)
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Filing 122
ORDER denying #70 Motion to Intervene; denying #86 Motion to Intervene. Signed by Chief Judge Algenon L. Marbley on 9/5/2023. (cw)
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Filing 121
Joint MOTION for Extension of Time to File Answer re #100 Third Party Complaint New date requested 9/29/2023. Requested Answer date set upon Court ruling on pending Motion by ThirdParty Defendant Columbus Hotel, Inc.. (Attachments: #1 Text of Proposed Order proposed Entry & Order) (Piccin, Joseph)
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Filing 120
REPLY to Response to Motion re #115 MOTION to Strike FOR FAILURE TO STATE A CLAIM OR IN THE ALTERNATIVE MOTION TO SEVER OR STAY DEFENDANT BEST INTERNATIONAL, INC.S THIRD PARTY COMPLAINT filed by Plaintiff T.P.. (Babin, Steven)
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Filing 119
Summons Issued as to 888 Dublin Investment, LLC. (jlk)
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Filing 118
REQUEST for Issuance of Summons. (Uhl, Judd)
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Filing 116
RESPONSE in Opposition re #115 MOTION to Strike FOR FAILURE TO STATE A CLAIM OR IN THE ALTERNATIVE MOTION TO SEVER OR STAY DEFENDANT BEST INTERNATIONAL, INC.S THIRD PARTY COMPLAINT filed by Defendant Best Western International, Inc., ThirdParty Plaintiff Best Western International, Inc.. (Shulman, Corey)
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Filing 115
MOTION to Strike FOR FAILURE TO STATE A CLAIM OR IN THE ALTERNATIVE MOTION TO SEVER OR STAY DEFENDANT BEST INTERNATIONAL, INC.S THIRD PARTY COMPLAINT by Plaintiff T.P.. (Babin, Steven)
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Filing 114
ORDER GOVERNING CONFIDENTIALITY AND PRIVILEGE. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 113
ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 112
PROTECTIVE ORDER. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 111
MOTION for Protective Order ESI Order, and Confidentiality Order by Plaintiff T.P.. (Attachments: #1 Exhibit A - Protective Order, #2 Exhibit B - Confidentiality Order, #3 Exhibit C - ESI Order) (El-Kadi, Jennifer).
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Filing 110
WAIVER OF SERVICE Returned Executed. Waiver sent to Columbus Hotel, Inc. on 7/5/2023, answer due 9/5/2023. (Shulman, Corey)
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Filing 109
ORDER granting #107 Motion for Extension of Time to file a Motion pursuant to Federal Rule of Civil Procedure 14(a)(4). Plaintiff shall have until 7/24/2023 to file a Motion. Signed by Magistrate Judge Elizabeth Preston Deavers on 7/6/2023. (vb)
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Filing 108
NOTICE of Substitution of Counsel - Joseph A. Manno substituting for Carrie E. Sheridan as to Defendant Red Roof Inns, Inc.. (Manno, Joseph)
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Filing 107
Unopposed MOTION for Extension of Time New date requested 7/24/2023. by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order) (Babin, Steven)
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Filing 106
ORDER granting #105 Motion to Continue scheduling order. Discovery due by 1/29/2024. Clawback Agreement Deadline due by 7/14/2023. Dispositive motions due by 8/13/2024. Plaintiff Primary Expert due by 3/12/2024. Plaintiff Rebuttal Expert due by 6/13/2024. Defendant Primary Expert due by 5/14/2024. Defendant Rebuttal Expert due by 6/13/2024. Signed by Magistrate Judge Elizabeth Preston Deavers on June 22, 2023. (jlk)
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Set/Reset Columbus PPTO Deadlines: Discovery due by 1/29/2024. Clawback Agreement Deadline due by 7/14/2023. Dispositive motions due by 8/13/2024. Plaintiff Primary Expert due by 3/12/2024. Plaintiff Rebuttal Expert due by 6/13/2024. Defendant Primary Expert due by 5/14/2024. Defendant Rebuttal Expert due by 6/13/2024. (jlk)
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Filing 105
Joint MOTION to Continue DATES IN SCHEDULING ORDER by Plaintiff T.P.. (Attachments: #1 Exhibit A) (El-Kadi, Jennifer)
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Filing 104
NOTATION ORDER granting #102 Motion for Leave to Appear Pro Hac Vice of Sandra J. Wunderlich. Co-counsel are directed to register for e-filing through PACER if they have not already done so. By Magistrate Judge Elizabeth Preston Deavers on 6/21/23. (ds)
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Filing 103
NOTICE by Defendant Red Roof Inns, Inc. re #102 MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9470386) of Sandra J. Wunderlich (Mikula, Chelsea)
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Filing 102
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9470386) of Sandra J. Wunderlich by Defendant Red Roof Inns, Inc.. (Mikula, Chelsea)
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Filing 101
Corporate Disclosure Statement by Defendant Red Roof Inns, Inc.. (Mikula, Chelsea)
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Filing 100
THIRD PARTY COMPLAINT filed against Columbus Hotel, Inc., 888 Dublin Investment, LLC, filed by Best Western International, Inc. Attachment: #1 Exhibit 93-3. (vb)
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Filing 99
OPINION AND ORDER granting #93 Motion for Leave to File Third Party Complaint. Signed by Magistrate Judge Elizabeth Preston Deavers on 6/12/2023. (vb)
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Filing 98
REPLY to Response to Motion re #93 MOTION for Leave to File Third-Party Complaint filed by Defendant Best Western International, Inc.. (Shulman, Corey)
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Filing 97
RESPONSE in Opposition re #93 MOTION for Leave to File Third-Party Complaint filed by Plaintiff T.P.. (El-Kadi, Jennifer)
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Filing 96
NOTATION ORDER granting #85 Motion for Leave to Appear Pro Hac Vice of Melissa A. Reinckens as Co-Counsel. Co-Counsel is directed to register for e-filing through PACER unless they have done so previously. By Magistrate Judge Elizabeth Preston Deavers on 05/16/2023. (tla)
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Filing 95
ORDER granting #94 Motion to Substitute Attorney. Added attorney Elisabeth Catherine Arko,Carrie Sheridan for Red Roof Inns, Inc. Attorney Bradley J Barmen and Katherine Lynn Kennedy terminated. Signed by Magistrate Judge Elizabeth Preston Deavers on May 16, 2023. (jlk)
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Filing 94
MOTION to Substitute Attorney by Defendant Red Roof Inns, Inc.. (Mikula, Chelsea)
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Filing 93
MOTION for Leave to File Third-Party Complaint by Defendant Best Western International, Inc.. (Attachments: #1 Text of Proposed Order, #2 Exhibit A - Proposed Third Party Complaint, #3 Exhibit Exhibit 1 to Proposed Third-Party Complaint) (Shulman, Corey)
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Filing 92
RESPONSE in Opposition re #86 MOTION to Intervene filed by Defendant Red Roof Inns, Inc.. (Falin, William)
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Filing 91
NOTICE of Appearance by William H. Falin for Defendant Red Roof Inns, Inc. (Falin, William)
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Filing 90
RESPONSE in Opposition re #86 MOTION to Intervene filed by Plaintiff T.P.. (El-Kadi, Jennifer)
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Filing 89
AMENDED DOCUMENT by Defendant Wyndham Hotels & Resorts, Inc.. . (Reed, Michael)
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Filing 88
NOTATION ORDER granting #87 Motion for Leave to Appear Pro Hac Vice of Karen L. Campbell as co-counsel. Signed by Magistrate Judge Elizabeth Preston Deavers on March 10, 2023. (jlk)
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Filing 87
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9311078) of Karen L. Campbell by Defendant Best Western International, Inc.. (Attachments: #1 Certificate In Good Standing, #2 Certificate In Good Standing) (Uhl, Judd)
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Filing 86
MOTION to Intervene by Defendant Liberty Mutual Fire Insurance Company. (Attachments: #1 Exhibit, #2 Proposed Entry) (Engling, Mark)
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Filing 85
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9296673) of Melissa A. Reinckens by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 84
NOTATION ORDER granting #83 Motion for Leave to Appear Pro Hac Vice of Nathan P. Heller as co-counsel. Signed by Magistrate Judge Elizabeth Preston Deavers on March 1, 2023. (jlk)
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Filing 83
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9293508) of Nathan P. Heller by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 82
NOTATION ORDER granting #80 Motion for Leave to Appear Pro Hac Vice of Christopher Donovan as co-counsel; granting #81 Motion for Leave to Appear Pro Hac Vice of David Sager as co-counsel. Signed by Magistrate Judge Elizabeth Preston Deavers on February 16, 2023. (jlk)
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Filing 81
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9275453) of David S. Sager by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 80
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9275442) of Christopher B. Donovan by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 79
ANSWER to #1 Complaint, with Jury Demand filed by Best Western International, Inc.. (Shulman, Corey)
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Filing 78
NOTATION ORDER granting #75 Motion for Leave to Appear Pro Hac Vice of Corey L. Shulman as co-counsel. Co-Counsel is directed to register for e-filing through PACER unless they have done so previously. Signed by Magistrate Judge Elizabeth Preston Deavers on January 25, 2023. (jlk)
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Filing 77
ORDER granting #74 MOTION for Extension of Time to file an Answer to Complaint. Defendant Best Western International, Inc. shall have until FEBRUARY 14, 2023 to respond to Plaintiff's Complaint. Signed by Magistrate Judge Elizabeth Preston Deavers on January 25, 2023. (jlk)
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Filing 76
NOTICE of Certificate of Service in support of by Defendants Best Western International, Inc., Red Roof Inns, Inc., Wyndham Hotels & Resorts, Inc. (Uhl, Judd)
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Set/Reset Deadlines: Best Western International, Inc. answer due 2/14/2023. (jlk)
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Filing 75
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9234041) of Corey Shulman by Defendants Best Western International, Inc. (Uhl, Judd) Modified Parties on 1/25/2023 (kh).
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Filing 74
MOTION for Extension of Time to File Response/Reply New date requested 2/14/2023. by Defendants Best Western International, Inc., Red Roof Inns, Inc., Wyndham Hotels & Resorts, Inc.. (Uhl, Judd)
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Filing 73
REPLY to Response to Motion re #70 MOTION to Intervene filed by Intervenor Erie Insurance Exchange. (Arnold, Gordon)
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Filing 72
RESPONSE in Opposition re #70 MOTION to Intervene filed by Plaintiff T.P.. (El-Kadi, Jennifer)
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Filing 71
ANSWER to #1 Complaint, filed by Wyndham Hotels & Resorts, Inc.. (Reed, Michael)
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Filing 70
MOTION to Intervene by Intervenor Erie Insurance Exchange. (Attachments: #1 Exhibit A Intervening Complaint of Erie Insurance Company and Exhibit 1 to Intervening Complaint) (Arnold, Gordon)
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Filing 69
STIPULATION to Extend Time to Move or Plead in Response to Complaint by Defendant Wyndham Hotels & Resorts, Inc.. (Yarnell, Elise)
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Filing 68
OPINION AND ORDER denying #36 Motion to Dismiss for Failure to State a Claim; granting in part #40 Motion to Dismiss for Failure to State a Claim with regards to its TVPRA retroactivity argument and DENIED in part with regards to Defendant BWI's remaining arguments. Signed by Chief Judge Algenon L. Marbley on December 1, 2022. (jlk)
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Filing 67
NOTATION ORDER granting #66 Motion for Leave to Appear Pro Hac Vice of Morgan Gray Harper as co-counsel. Co-Counsel is directed to register for e-filing through PACER unless they have done so previously. Signed by Magistrate Judge Elizabeth Preston Deavers on November 7, 2022. (jlk)
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Filing 66
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9126113) of Morgan Gray Harper by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing) (El-Kadi, Jennifer)
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Filing 65
ORDER denying as moot #38 Motion to Dismiss for Failure to State a Claim. Signed by Chief Judge Algenon L. Marbley on 11/2/2022. (cw)
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Filing 64
RELATED CASE MEMORANDUM ORDER: The Judges agree that this case and case number 2:22-cv-2690, 2:21-cv-5022, 2:19-cv-849, 2:21-cv-4934, 2:21-cv-4935, 2:22-cv-1924, and 2:22-cv-2682 ARE related. Case reassigned to Chief Judge Algenon L. Marbley and Magistrate Judge Elizabeth Preston Deavers for all further proceedings. Signed by Judge Edmund A. Sargus and Chief Judge Algenon L. Marbley on 9/28/2022. (daf)
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Filing 63
RELATED CASE MEMORANDUM ORDER: The Chief Judge has determined that case numbers 2:19-cv-755, 2:19-cv-849, 2:19-cv-2970, 2:19-cv-4965, 2:19-cv-5384, 2:21-cv-4933, 2:21-cv-4934, 2:21-cv-4935, 2:21-cv-5022, 2:22-cv-1924, 2:22-cv-2682, and 2:22-cv-2683 ARE related. Signed by Chief Judge Algenon L. Marbley and Judge Edmund A. Sargus, Jr. on 07/11/2022. (tla)
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Filing 62
RELATED CASE MEMORANDUM ORDER: The Chief Judge has determined that this case and case number 2:19-cv-755, 2:19-cv-849, 2:19-cv-2970, 2:19-cv-4965, 2:19-cv-5384, 2:21-cv-4933, 2:21-cv-4934, 2:21-cv-4935, 2:21-cv-5022, 2:22-cv-1924, and 2:22-cv-2682 ARE related. Signed by Chief Judge Algenon L. Marbley and Judge Michael H. Watson on 07/05/2022. (tla)
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Filing 61
NOTICE by Plaintiff T.P. OF FILING JOINT MEMORANDUM REGARDING APPOINTMENT OF A SPECIAL MASTER (Babin, Steven)
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Filing 60
ORDER: Construing the parties' Notice as a Motion to Sever pursuant to Rule 21, the Court GRANTS the Motion and DISMISSES Plaintiff's claims against Defendant American Hotel and Lodging Association without prejudice. (ECF No. 59.) Signed by Magistrate Judge Elizabeth Preston Deavers on June 6, 2022. (jlk)
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Filing 59
NOTICE by Plaintiff T.P. JOINT NOTICE OF STIPULATED DISMISSAL WITHOUT PREJUDICE AS TO DEFENDANT AHLA (Attachments: #1 Text of Proposed Order) (El-Kadi, Jennifer) Modified text and event on 6/6/2022 (jlk). Construing Notice as a Motion to Sever pursuant to Rule 21.
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Filing 58
REPLY in Support re #36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Defendant Wyndham Hotels & Resorts, Inc.. (Reed, Michael) Modified text on 5/27/2022 (tla).
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Filing 57
REPLY to Response to Motion re #40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Defendant Best Western International, Inc.. (Uhl, Judd)
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Filing 56
ORDER granting #52 and #54 Motion to Dismiss. The Court DISMISSES Plaintiffs Count II against Best Western, without prejudice. Signed by Magistrate Judge Elizabeth Preston Deavers on 4/29/2022. (daf)
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Filing 55
RESPONSE in Opposition re #40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Plaintiff T.P.. (Avila, Kathryn)
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Filing 54
NOTICE by Plaintiff T.P. STIPULATED DISMISSAL WITHOUT PREJUDICE AS TO COUNT II (Attachments: #1 Text of Proposed Order) (Babin, Steven) Modified event type on 4/29/2022 (daf).
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Filing 53
ORDER re #48 Joint Notice of Stipulated Dismissal Without Prejudice as to Defendant OHLA; and #51 STIPULATED DISMISSAL WITHOUT PREJUDICE AS TO COUNT II. Construing the parties' filings as Motions to Sever pursuant to Rule 21, the Court GRANTS the Motions and DISMISSES Plaintiff's claims against OHLA, and Plaintiff's Count II against Wyndham, without prejudice. (ECF Nos. 48, 51.) Signed by Magistrate Judge Elizabeth Preston Deavers on April 27, 2022. (jlk)
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Filing 52
MOTION to Dismiss and Withdraw Count II Without Prejudice by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order) (Babin, Steven)
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Filing 51
NOTICE by Plaintiff T.P. STIPULATED DISMISSAL WITHOUT PREJUDICE AS TO COUNT II (Attachments: #1 Text of Proposed Order) (Babin, Steven) Modified for statistical purposes on 4/27/2022 (jlk).
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Filing 50
PRELIMINARY PRETRIAL ORDER: The Court adopts the following schedule: Venue and Jurisdiction Deadline due by 6/1/2022. Joinder of Parties due by 10/19/2022. Motions to Amend due by 10/19/2022. Initial Disclosures due by 6/25/2022. Discovery due by 7/31/2023. Clawback Agreement Deadline due by 6/1/2022. Dispositive motions due by 1/12/2024. Primary Expert due by 9/14/2023. Rebuttal Expert due by 11/13/2023. Settlement Demand due by 2/27/2023. Response to Settlement Demand due by 4/17/2023. Mediation Deadline: 5/2023. Signed by Magistrate Judge Elizabeth Preston Deavers on April 26, 2022. (jlk)
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Filing 49
Minute Entry for proceedings held before Magistrate Judge Elizabeth Preston Deavers: Preliminary Pretrial Conference held on 4/26/2022. (sln)
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Filing 48
NOTICE by Plaintiff T.P. Joint Notice of Stipulated Dismissal Without Prejudice as to Defendant OHLA (Attachments: #1 Text of Proposed Order) (Babin, Steven) Modified for statistical purposes on 4/27/2022 (jlk).
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Filing 47
ORDER granting #46 Motion for Extension of Time to Respond to Defendants Wyndham, Best Western, and OHLAs Motion to Dismiss. Plaintiff shall have until APRIL 28, 2022 to file responses in opposition to Defendants' pending motions to dismiss, and Defendants shall have until MAY 26, 2022 to file reply briefs. Signed by Magistrate Judge Elizabeth Preston Deavers on April 21, 2022. (jlk)
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Set/Reset Deadlines as to #36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #38 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . Responses due by 4/28/2022 and Replies due by 5/26/2022. (jlk)
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Filing 46
Second MOTION for Extension of Time New date requested 4/28/2022. by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order) (Babin, Steven)
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Filing 45
RULE 26(f) REPORT by Plaintiff T.P.. (El-Kadi, Jennifer)
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Filing 44
NOTICE of Hearing:Preliminary Pretrial Conference set for 4/26/2022 11:30 AM in Teleconference before Magistrate Judge Elizabeth Preston Deavers. (sln)
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Filing 43
ORDER granting re #42 Joint MOTION for Extension of Time to File Response/Reply to #36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #38 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . Responses due by 4/21/2022. Replies due by 5/19/2022. Signed by Magistrate Judge Elizabeth Preston Deavers on March 21, 2022. (jlk)
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Filing 42
Joint MOTION for Extension of Time to File Response/Reply New date requested 4/21/2022. by Plaintiff T.P.. (El-Kadi, Jennifer)
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Filing 41
Corporate Disclosure Statement by Defendant Best Western International, Inc.. (Uhl, Judd)
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Filing 40
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Best Western International, Inc.. (Attachments: #1 Exhibit Exhibt A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Text of Proposed Order Proposed Order) (Uhl, Judd)
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Filing 39
Corporate Disclosure Statement by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 38
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 37
Corporate Disclosure Statement by Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotels & Resorts, Inc. identifying Corporate Parent Wyndham Hotels & Resorts, Inc. for Wyndham Hotels & Resorts, Inc... (Reed, Michael)
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Filing 36
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Wyndham Hotels & Resorts, Inc.. (Reed, Michael)
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Filing 35
NOTICE of Appearance by Michael R Reed for Defendant Wyndham Hotels & Resorts, Inc. (Reed, Michael)
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Set/Reset Deadlines: Best Western International, Inc. answer due 3/11/2022; Wyndham Hotels & Resorts, Inc. answer due 3/2/2022. (jlk)
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Filing 34
ANSWER to #1 Complaint, with Jury Demand filed by American Hotel and Lodging Association. (Chang, Steven)
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Filing 33
STIPULATION To Extend Time For WHRI to Move or Plead in Response to Complaint by Defendant Wyndham Hotels & Resorts, Inc.. (Yarnell, Elise)
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Filing 32
STIPULATION for Extension of Time to Answer by Defendant Best Western International, Inc.. (Uhl, Judd)
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Filing 31
ANSWER to #1 Complaint, with Jury Demand filed by Red Roof Inns, Inc.. (Kennedy, Katherine)
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Filing 30
NOTICE by Defendant Red Roof Inns, Inc. of Appearance of Brad J. Barmen (Kennedy, Katherine)
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Set/Reset Deadlines: Ohio Hotel and Lodging Association answer due 3/4/2022. (jlk)
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Filing 29
STIPULATION for Extension of Time to Move or Plead by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 28
ORDER granting #27 Motion for Extension of Time to Plead or Move in Response to Complaint. The parties shall have until FEBRUARY 17, 2022 to respond to Plaintiff's Complaint. Signed by Magistrate Judge Elizabeth Preston Deavers on January 19, 2022. (jlk)
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Set/Reset Deadlines: Red Roof Inns, Inc. answer due 2/17/2022. (jlk)
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Filing 27
Unopposed MOTION for Extension of Time New date requested 2/17/2022. to Plead or Move in Response to Complaint by Defendant Red Roof Inns, Inc.. (Attachments: #1 Text of Proposed Order) (Kennedy, Katherine)
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Filing 26
NOTICE of Appearance by Katherine Lynn Kennedy for Defendant Red Roof Inns, Inc. (Kennedy, Katherine)
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Filing 25
NOTICE of Appearance by Ali I. Haque for Defendant Ohio Hotel and Lodging Association (Haque, Ali)
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Filing 24
ORDER granting #23 Motion for Leave to Appear Pro Hac Vice of Kimberly Adams as co-counsel. The Clerk is DIRECTED to REFUND the filing fees associated with the Motion for Admission Pro Hac Vice of Christopher Vincent Tisi, ECF No. 17, and the Motion for Admission Pro Hac Vice of Kimberly L. Adams, ECF No. 23, as the filing fees already were paid for these attorneys, see ECF Nos. 8, 9. Signed by Magistrate Judge Elizabeth Preston Deavers on January 5, 2022. (jlk)
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Filing 23
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8658705) of KIMBERLY L. ADAMS by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Florida) (Babin, Steven)
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Filing 22
NOTATION ORDER finding as moot #6 Motion for Leave to Appear Pro Hac Vice of Gregory Zarzaur; finding as moot #9 Motion for Leave to Appear Pro Hac Vice of Christopher Vincent Tisi; granting #14 Motion for Leave to Appear Pro Hac Vice of Denise P. Wiginton as co-counsel; granting #15 Motion for Leave to Appear Pro Hac Vice of Gregory Zarzaur as co-counsel; granting #16 Motion for Leave to Appear Pro Hac Vice of Kelsie M. Overton as co-counsel; granting #17 Motion for Leave to Appear Pro Hac Vice of Christopher Vincent Tisi as co-counsel. Signed by Magistrate Judge Elizabeth Preston Deavers on January 4, 2022. (jlk)
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Filing 21
ORDER denying #8 Motion for Leave to Appear Pro Hac Vice of Kimberly Adams. Signed by Magistrate Judge Elizabeth Preston Deavers on January 4, 2022. (jlk)
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Filing 20
SUMMONS Returned Executed as to Defendant Red Roof Inns, Inc.. Red Roof Inns, Inc. served on 12/28/2021, answer due 1/18/2022. (El-Kadi, Jennifer)
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Filing 19
WAIVER OF SERVICE Returned Executed. Waiver sent to American Hotel and Lodging Association on 12/27/2021, answer due 2/25/2022; Best Western International, Inc. on 12/27/2021, answer due 2/25/2022; Ohio Hotel and Lodging Association on 12/20/2021, answer due 2/18/2022; Wyndham Hotels & Resorts, Inc. on 12/27/2021, answer due 2/25/2022. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D) (El-Kadi, Jennifer)
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Filing 18
NOTICE of Appearance by Jennifer Jana El-Kadi for Plaintiff T.P. (El-Kadi, Jennifer)
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Filing 17
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8656143) of Christopher Vincent Tisi by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Maryland, #3 Exhibit Certificate of Good Standing DC) (Babin, Steven)
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Filing 16
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8654249) of KELSIE MARIE OVERTON by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama) (Babin, Steven)
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Filing 15
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8654239) of GREGORY MARTIN ZARZAUR by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama, #3 Exhibit Certificate of Good Standing Mississippi) (Babin, Steven) PHV filing fee refunded on 1/3/2022. Fee was paid previously, see ECF No. #6 . (sln).
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Filing 14
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8654218) of DENISE PAULINE WIGINTON by Plaintiff T.P.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama, #3 Exhibit Certificate of Good Standing Georgia) (Babin, Steven)
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Filing 13
NOTICE of Appearance by Steven A. Chang for Defendant American Hotel and Lodging Association (Chang, Steven)
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Filing 12
NOTICE of Appearance by D Patrick Kasson for Defendant American Hotel and Lodging Association (Kasson, D)
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Filing 11
Notice of Deficiency re: The submitted certificate is not from the highest court of a State. Related Documents: #6 , #8 , #9 MOTIONS for Leave to Appear Pro Hac Vice of Gregory Zarzaur, Kimberly Adams & Christopher Tisi filed by A. R. Deficiency Deadline by 11/29/2021. (er)
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Filing 10
ORDER granting #5 & #7 Motions for Leave to Appear Pro Hac Vice of Emanuella Paulos and Kathryn Avila. PHV Counsel is directed to register for e-filing through PACER unless they have done so previously. Signed by Magistrate Judge Elizabeth Preston Deavers on 11/12/2021. (er)
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Filing 9
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8579004) of Christopher V. Tisi by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 8
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8579004) of Kimberly Adams by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 7
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8579004) of Kathryn L. Avila by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing, #2 Exhibit Certificate of Good Standing, #3 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 6
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8579004) of Gregory Zarzaur by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing, #2 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 5
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $1000 paid, receipt number AOHSDC-8579004) of Emmie J. Paulos by Plaintiff T.P.. (Attachments: #1 Exhibit Certificate of Good Standing, #2 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 4
RELATED CASE MEMORANDUM ORDER: The Judges agree that this case and case numbers 2:19-cv-849 and 2:19-cv-5384 ARE related. Case reassigned to Chief Judge Algenon L. Marbley and Magistrate Judge Elizabeth Preston Deavers for all further proceedings. Signed by Judge Sarah D. Morrison and Chief Judge Algenon L. Marbley on 10/6/2021. (kk2)
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Filing 2
Summons Issued as to American Hotel and Lodging Association, Best Western International Inc., Ohio Hotel and Lodging Association, Red Roof Inns Inc., and Wyndham Hotels & Resorts Inc. (Attachments: #1 Summons Form Red Roof Inns, #2 Summons Form Best Western International, #3 Summons Form American Hotel & Lodging Association, #4 Summons Form Ohio Hotel & Lodging Association) (kk2)
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Filing 1
COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 402 paid - receipt number: AOHSDC-8524902), filed by T.P. (Attachments: #1 Civil Cover Sheet, #2 Summons Form, #3 Summons Form, #4 Summons Form, #5 Summons Form, #6 Summons Form) (Babin, Steven) (Attachment 1 replaced on 10/8/2021) (jlk).
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