A. R. v. Wyndham Hotels and Resorts, Inc., et al.
| A. R. |
| WYNDHAM HOTELS AND RESORTS, INC, G6 Hospitality, LLC, American Hotel and Lodging Association, Ohio Hotel and Lodging Association and Wyndham Hotels & Resorts, Inc. |
| 2:2021cv04935 |
| October 2, 2021 |
| US District Court for the Southern District of Ohio |
| Elizabeth Preston Deavers |
| Algenon L Marbley |
| Chelsey M Vascura |
| Other Statutory Actions |
| Both |
Docket Report
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This docket was last retrieved on July 18, 2023. A more recent docket listing may be available from PACER.
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Filing 79
ORDER GOVERNING CONFIDENTIALITY AND PRIVILEGE. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 78
ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 77
PROTECTIVE ORDER. Signed by Magistrate Judge Elizabeth Preston Deavers on July 18, 2023. (jlk)
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Filing 76
MOTION for Protective Order ESI Order, and Confidentiality Order by Plaintiff A. R.. (Attachments: #1 Exhibit A - Protective Order, #2 Exhibit B - Confidentiality Order, #3 Exhibit C - ESI Order) (El-Kadi, Jennifer).
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Filing 75
ORDER granting #74 Motion to Continue the 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 74
Joint MOTION to Continue DATES IN SCHEDULING ORDER by Plaintiff A. R.. (Attachments: #1 Exhibit A) (El-Kadi, Jennifer)
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Filing 73
NOTATION ORDER granting #70 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. Signed by Magistrate Judge Elizabeth Preston Deavers on 05/16/2023. (tla)
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Filing 72
AMENDED DOCUMENT by Defendant Wyndham Hotels & Resorts, Inc.. . (Reed, Michael)
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Filing 71
Notice of Deficiency re: The submitted certificate is not from the highest court of a State. Related Document: #70 MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9296633) of Melissa A. Reinckens filed by Wyndham Hotels & Resorts, Inc. Deficiency Deadline by 3/17/2023. (jlk)
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Filing 70
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9296633) of Melissa A. Reinckens by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 69
NOTATION ORDER granting #68 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 68
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9293522) of Nathan P. Heller by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 67
NOTATION ORDER granting #65 Motion for Leave to Appear Pro Hac Vice of Christopher B. Donovan as co-counsel; granting #66 Motion for Leave to Appear Pro Hac Vice of David S. Sager as co-counsel. Signed by Magistrate Judge Elizabeth Preston Deavers on February 16, 2023. (jlk)
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Filing 66
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9275356) of David S. Sager by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 65
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9275326) of Christopher B. Donovan by Defendant Wyndham Hotels & Resorts, Inc.. (Attachments: #1 Exhibit Certificate of Good Standing) (Reed, Michael)
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Filing 64
ORDER denying with prejudice as it pertains to related cases filed before 2022 and denying without prejudice as it pertains to related cases filed in or after 2022 #38 Motion to Appoint; adopting Report and Recommendations re #57 Report and Recommendations. Signed by Chief Judge Algenon L. Marbley on 1/30/2023. (cw)
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Filing 63
ANSWER to #1 Complaint, filed by Wyndham Hotels & Resorts, Inc.. (Reed, Michael)
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Filing 62
ORDER denying #30 Motion to Dismiss for Failure to State a Claim. Signed by Chief Judge Algenon L. Marbley on 12/16/2022. (cw)
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Filing 61
NOTATION ORDER granting #60 Motion for Leave to Appear Pro Hac Vice of Morgan G. 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 60
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-9126712) of Morgan Gray Harper by Plaintiff A. R.. (Attachments: #1 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 59
ORDER denying as moot #32 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 58
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-4933, 2:21-cv-4934, 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). (daf)
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Filing 57
REPORT AND RECOMMENDATION: Re #38 MOTION TO APPOINT MAGISTRATE JUDGES filed by A. R. It is RECOMMENDED that the Court DENY WITH PREJUDICE the Motion to Appoint, ECF No. 38, as it pertains to all related cases filed before 2022, and that the Court DENY WITHOUT PREJUDICE the Motion to Appoint as it pertains to all related cases filed in or after 2022. Objections to R&R due by 9/22/2022. Signed by Magistrate Judge Elizabeth Preston Deavers on September 8, 2022. (jlk)
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Filing 56
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 55
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 54
STATUS REPORT by Plaintiff A. R.. (El-Kadi, Jennifer)
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Filing 53
STATUS REPORT ORDER: Plaintiff is DIRECTED to file a written STATUS REPORT updating the Court on the current status of the new related human trafficking cases, on or before JUNE 22, 2022. Signed by Magistrate Judge Elizabeth Preston Deavers on June 15, 2022. (jlk)
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Filing 52
Response JOINT MEMORANDUM REGARDING APPOINTMENT OF A SPECIAL MASTER by Plaintiff A. R.. (Babin, Steven)
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Filing 51
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. 50.) Signed by Magistrate Judge Elizabeth Preston Deavers on June 6, 2022. (jlk)
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Filing 50
NOTICE by Plaintiff A. R. 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 49
REPLY in Support re #30 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 48
RESPONSE in Opposition re #30 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Plaintiff A. R.. (Babin, Steven)
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Filing 47
ORDER - Construing #46 Notice as a Motion to Sever pursuant to Rule 21, the Court GRANTS the Motion and DISMISSES Plaintiff's Count II against Wyndham without prejudice. Signed by Magistrate Judge Elizabeth Preston Deavers on April 28, 2022. (jlk)
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Filing 46
NOTICE by Plaintiff A. R. STIPULATED DISMISSAL WITHOUT PREJUDICE AS TO COUNT II (Attachments: #1 Text of Proposed Order) (Babin, Steven) Modified for statistical purposes on 4/28/2022 (jlk).
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Filing 45
ORDER re #42 Joint Notice of Stipulated Dismissal Without Prejudice as to Defendant Ohio Hotel and Lodging Association. Construing the parties' filing as a Motion to Sever pursuant to Rule 21, the Court GRANTS the Motion and DISMISSES Plaintiff's claims against OHLA without prejudice. (ECF No. 42.) Signed by Magistrate Judge Elizabeth Preston Deavers on April 27, 2022. (jlk)
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Filing 44
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 43
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 42
NOTICE by Plaintiff A. R. 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 41
ORDER Granting #40 Plaintiff's Motion for Extension of Time to Respond to Defendants Wyndham and OHLA's Motions 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 #30 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #32 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 40
Second MOTION for Extension of Time New date requested 4/28/2022. by Plaintiff A. R.. (Attachments: #1 Text of Proposed Order) (Babin, Steven)
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Filing 39
RULE 26(f) REPORT by Plaintiff A. R.. (El-Kadi, Jennifer)
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Filing 38
MOTION TO APPOINT MAGISTRATE JUDGES by Plaintiff A. R.. (Babin, Steven)
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Filing 37
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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NOTICE : The Preliminary Pretrial Conference set for 4/5/2022 11:30 AM is VACATED. (sln)
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Filing 36
ORDER granting #35 Joint MOTION for Extension of Time to File Response/Reply, re #30 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM , #32 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 35
Joint MOTION for Extension of Time to File Response/Reply New date requested 4/21/2022. by Plaintiff A. R.. (El-Kadi, Jennifer)
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Filing 34
NOTICE of Hearing:Preliminary Pretrial Conference set for 4/5/2022 11:30 AM in Teleconference before Magistrate Judge Elizabeth Preston Deavers. (sln)
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Filing 33
Corporate Disclosure Statement by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 32
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 31
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 30
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Wyndham Hotels & Resorts, Inc.. (Reed, Michael)
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Filing 29
NOTICE of Appearance by Michael R Reed for Defendant Wyndham Hotels & Resorts, Inc. (Reed, Michael) ***Document restricted by the Clerk on 3/4/2022- the document was meant to be filed in another case. Counsel did file this appearance in the correct case. (er).
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Filing 28
NOTICE of Appearance by Michael R Reed for Defendant Wyndham Hotels & Resorts, Inc. (Reed, Michael)
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Set/Reset Deadlines: Wyndham Hotels & Resorts, Inc. answer due 3/2/2022. (jlk)
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Filing 27
ANSWER to #1 Complaint, with Jury Demand filed by American Hotel and Lodging Association. (Chang, Steven)
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Filing 26
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 25
RELATED CASE MEMORANDUM ORDER: The Chief Judge has determined that this case and case number 2:19-cv-849 ARE related. Case reassigned to Magistrate Judge Elizabeth Preston Deavers for all further proceedings. Signed by Chief Judge Algenon L. Marbley on February 22, 2022. (jlk)
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Set/Reset Deadlines: Ohio Hotel and Lodging Association answer due 3/4/2022. (agm)
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Filing 24
STIPULATION for Extension of Time to Move or Plead by Defendant Ohio Hotel and Lodging Association. (Haque, Ali)
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Filing 23
NOTICE of Voluntary Dismissal by Plaintiff A. R. (El-Kadi, Jennifer)
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Filing 22
NOTATION ORDER granting #16 , #17 & #20 Motions for Leave to Appear Pro Hac Vice of Kelsie Overton, Christopher V. Tisi & Kimberly L. Adams. PHV Counsel is directed to register for e-filing through PACER unless they have done so previously. Signed by Magistrate Judge Chelsey M. Vascura on 1/11/2022. (er)
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Filing 21
NOTICE of Appearance by Ali I. Haque for Defendant Ohio Hotel and Lodging Association (Haque, Ali)
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Filing 20
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8658802) of KIMBERLY L. ADAMS by Plaintiff A. R.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Florida) (Babin, Steven)
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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; 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) (El-Kadi, Jennifer)
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Filing 18
NOTICE of Appearance by Jennifer Jana El-Kadi for Plaintiff A. R. (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-8656124) of Christopher Vincent Tisi by Plaintiff A. R.. (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-8654179) of KELSIE MARIE OVERTON by Plaintiff A. R.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama) (Babin, Steven)
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Filing fee: $ 200, receipt number AOHSDC-8654156 - Related Document: 14 Order on Motion for Leave to Appear Pro Hac Vice,,,.. (Babin, Steven)
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Filing 15
NOTICE of Appearance by Steven A. Chang for Defendant American Hotel and Lodging Association (Chang, Steven)
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Filing 14
NOTATION ORDER granting #12 Motion for Leave to Appear Pro Hac Vice of Denise Wiginton as co-counsel; granting #13 Motion for Leave to Appear Pro Hac Vice of Gregory Zarzaur as co-counsel. Co-Counsel is directed to register for e-filing through PACER unless they have done so previously. Signed by Magistrate Judge Chelsey M. Vascura on December 20, 2021. (jlk)
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Filing 13
MOTION for Leave to File FOR ADMISSION PRO HAC VICE OF GREGORY MARTIN ZARZAUR by Plaintiff A. R.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama, #3 Exhibit Certificate of Good Standing Mississippi) (Babin, Steven) Modified event on 12/20/2021 (jlk).
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Filing 12
MOTION for Leave to File FOR ADMISSION PRO HAC VICE OF DENISE PAULINE WIGINTON by Plaintiff A. R.. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Good Standing Alabama, #3 Exhibit Certificate of Good Standing Georgia) (Babin, Steven) Modified event on 12/20/2021 (jlk).
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Filing 11
NOTATION ORDER denying without prejudice #4 , #6 , and #7 Motions for Leave to Appear Pro Hac Vice of Gregory Zarzaur, Kimberly Adams, and Christopher Tisi. By Magistrate Judge Chelsey M. Vascura on 12/16/2021. (agm)
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Filing 10
NOTICE of Appearance by D Patrick Kasson for Defendant American Hotel and Lodging Association (Kasson, D)
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Filing 9
Notice of Deficiency re: The submitted certificate is not from the highest court of a State. Related Documents: #4 , #6 , #7 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 8
NOTATION ORDER granting #3 & #5 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 Chelsey M. Vascura on 11/12/2021. (er)
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Filing 7
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8578415) of Christopher Tisi by Plaintiff A. R.. (Attachments: #1 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-8578415) of Kimberly Adams by Plaintiff A. R.. (Attachments: #1 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 5
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8578415) of Kathryn Avila by Plaintiff A. R.. (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 4
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number AOHSDC-8578415) of Gregory Zarzaur by Plaintiff A. R.. (Attachments: #1 Exhibit Certificate of Good Standing, #2 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 3
MOTION for Leave to Appear Pro Hac Vice (Filing fee of $1000 paid, receipt number AOHSDC-8578415) of Emmie Paulos by Plaintiff A. R.. (Attachments: #1 Exhibit Certificate of Good Standing) (Babin, Steven)
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Filing 2
Summons Issued as to American Hotel and Lodging Association, G6 Hospitality, LLC, Ohio Hotel and Lodging Association and WYNDHAM HOTELS AND RESORTS, INC. (er)
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Filing 1
COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 402 paid - receipt number: AOHSDC-8524918), filed by A. R.. (Attachments: #1 Civil Cover Sheet, #2 Summons Form, #3 Summons Form, #4 Summons Form, #5 Summons Form) (Babin, Steven) (Attachments 1-5 replaced on 10/5/2021- documents were not flattened) (er).
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