MDR UNITED LLC v. FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS et al
| MDR UNITED LLC |
| FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, RUSTY HANSEN and AMY HANSEN |
| AMY HANSEN, RUSTY HANSEN and FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS |
| MDR UNITED LLC |
| 2:2025cv05073 |
| September 4, 2025 |
| U.S. District Court for the Eastern District of Pennsylvania |
| JOSHUA D WOLSON |
| Contract: Recovery/Enforcement |
| 15 U.S.C. § 1125 Trademark Infringement (Lanham Act) |
| None |
Docket Report
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| Filing 34 MOTION to Dismiss PLAINTIFF / COUNTERCLAIM-DEFENDANT MDR UNITED, LLCS MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION TO DISMISS DEFENDANT / COUNTERCLAIM-PLAINTIFF FLEX NINE EXTERIORS, INC.S COUNTERCLAIMS WITH PREJUDICE AND REQUEST FOR ATTORNEYS FEES AND COSTS filed by MDR UNITED LLC.Memorandum, Affidavit, Certificate of Service. (Attachments: #1 Memorandum Memorandum of Law, #2 Certificate of Service Certificate of Service, #3 Appendix Table of Contents, #4 Text of Proposed Order Proposed Order, #5 Declaration Certificate from Joshua Skolnick, #6 Exhibit Exhibit A - Franchise Disclosure Document, #7 Exhibit Exhibit B - Proof of Business Entity Formation Date, #8 Exhibit Exhibit C - Negotiated Amendment)(ALEXANDER, CHRISTOPHER) |
Filing 33
ORDER THAT PLAINTIFF/COUNTERCLAIM-DEFENDANT MDR UNITED, LLC'S DEADLINE TO RESPOND TO DEFENDANT/COUNTERCLAIM-PLAINTIFF FLEX NINE EXTERIORS, INC.'S COUNTERCLAIMS IS STAYED PENDING THE OUTCOME OF THE MEDIATION. THE VIDEO PRETRIAL CONFERENCE, CURRENTLY SCHEDULED FOR 12/18/2025, IS RESCHEDULED FOR 3/24/2026 AT 10:00 AM BEFORE DISTRICT JUDGE JOSHUA D. WOLSON. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 12/5/2025. 12/5/2025 ENTERED AND COPIES E-MAILED.(ahf)
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| Filing 32 Minute Entry for proceedings held before DISTRICT JUDGE JOSHUA D. WOLSON. Telephone Conference held on 12/4/2025. (ahf) |
| Filing 31 NOTICE of Appearance by FRANK A. REINO on behalf of MDR UNITED LLC (REINO, FRANK) |
| NOTICE OF HEARING: A TELEPHONE CONFERENCE IS SCHEDULED FOR 12/4/2025 AT 2:30 PM BEFORE DISTRICT JUDGE JOSHUA D. WOLSON. COUNSEL FOR THE PARTIES ARE DIRECTED TO USE THE COURT'S DIAL-IN NUMBER, WHICH WAS PROVIDED BY CHAMBERS VIA EMAIL. (ENTERED AND EMAILED, 12/03/2025).(ja) |
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Filing 30
ORDER THAT THE MOTION FOR PRO HAC VICE ADMISSION OF ROBERT M. GALLINAR, ESQ. (DOC. NO. 27) IS GRANTED. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 12/1/2025.12/1/2025 ENTERED AND COPIES E-MAILED.(ahf)
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Filing 29
ORDER THAT THE MOTION FOR PRO HAC VICE ADMISSION OF ROBERT M. EINHORN, ESQ. (DOC. NO. 26) IS GRANTED. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 12/1/2025.12/1/2025 ENTERED AND COPIES E-MAILED.(ahf)
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Filing 28
ORDER THAT THE MOTION FOR PRO HAC VICE ADMISSION OF HIMANSHU PATEL, ESQ. (DOC. NO. 25) IS GRANTED. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 12/1/2025.12/1/2025 ENTERED AND COPIES E-MAILED.(ahf)
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| Filing 27 MOTION for Pro Hac Vice OF ROBERT M. GALLINAR ( Filing fee $ 75 receipt number APAEDC-18780962.) filed by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN.Certificate of Service.(GRIFFITH, JAMES) |
| Filing 26 MOTION for Pro Hac Vice OF ROBERT M. EINHORN ( Filing fee $ 75 receipt number APAEDC-18778462.) filed by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN.Certificate of Service.(GRIFFITH, JAMES) |
| Filing 25 MOTION for Pro Hac Vice OF HIMANSHU PATEL ( Filing fee $ 75 receipt number APAEDC-18778445.) filed by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN.Certificate of Service.(GRIFFITH, JAMES) |
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Filing 24
ORDER THAT LEAD COUNSEL FOR THE PARTIES SHALL APPEAR FOR A VIDEO PRETRIAL CONFERENCE SCHEDULED FOR 12/18/2025 AT 2:00 PM BEFORE DISTRICT JUDGE JOSHUA D. WOLSON. FURTHER INFORMATION AND DEADLINES AS OUTLINED HEREIN. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 11/20/2025. 11/20/2025 ENTERED AND E-MAILED.(ja)
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Filing 23
STIPULATION AND ORDER THAT MDR UNITED LLC TIME TO RESPOND TO FLEX NINE EXTERIORS COUNTERCLAIMS IS BY 11/26/25; ETC.. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 11/20/25. 11/20/25 ENTERED AND E-MAILED.(JL)
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Filing 22
ORDER THAT PLAINTIFF/COUNTERCLAIM DEFENDANT MDR UNITED, LLC'S MOTION TO DISMISS DEFENDANT/COUNTERCLAIM PLAINTIFF FLEX NINE EXTERIORS, INC.'S COUNTERCLAIMS WITH PREJUDICE AND REQUEST FOR ATTORNEYS' FEES AND COSTS (DOC. NO. 21) IS STRICKEN FOR FAILURE TO COMPLY WITH THE PRE-MOTION REQUIREMENTS SET FORTH IN SECTION II.B.4 OF MY POLICIES AND PROCEDURES. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 11/13/2025.11/13/2025 ENTERED AND COPIES E-MAILED.(ahf)
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| Filing 21 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by MDR UNITED LLC.Memorandum, Declaration, Certificate of Service. (Attachments: #1 Memorandum Table of Contents and Motion to Dismiss, #2 Text of Proposed Order Proposed Order, #3 Certificate of Service Certification of Service, #4 Declaration Certification of Joshua Skolnick, #5 Exhibit Exhibit A for Certification of Joshua Skolnick, #6 Exhibit Exhibit B for Certification of Joshua Skolnick, #7 Exhibit Exhibit C for Certification of Joshua Skolnick)(ALEXANDER, CHRISTOPHER). (STRICKEN PER ORDER NO. 22). Modified on 11/13/2025 (ahf). |
| Filing 20 NOTICE of Appearance by JOYANN KENNY on behalf of MDR UNITED LLC AND EXTERIORS (KENNY, JOYANN) Modified on 12/2/2025 (ahf). |
| Filing 19 AMENDED DOCUMENT by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN. Amendment to #17 Answer to Complaint,, Counterclaim, Affirmative Defenses. (GRIFFITH, JAMES) |
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Filing 18
ORDER THAT, ON OR BEFORE 11/7/2025, DEFENDANTS SHALL EITHER (a) FILE AN AMENDED ANSWER, ASSERTING ONLY AFFIRMATIVE DEFENSE THAT THEY HAVE A GOOD FAITH BASIS TO ASSERT OR (b) SHOW CAUSE, IN A MEMORANDUM NOT TO EXCEED 10 PAGES, WHY I SHOULD NOT STRIKE ALL OF THE ASSERTED AFFIRMATIVE DEFENSE, PURSUANT TO FED. R. CIV. P. 11(c)(3). SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 10/31/2025. 10/31/2025 ENTERED AND COPIES E-MAILED.(ahf)
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| Filing 17 DEFENDANT'S ANSWER to Complaint , AFFIRMATIVE DEFENSES, COUNTERCLAIM against MDR UNITED LLC by AMY HANSEN, RUSTY HANSEN, FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS. (Attachments: #1 Exhibit Exhibit A - Franchise Agreement, #2 Exhibit Exhibit B - Demand Letter)(GRIFFITH, JAMES) |
| Filing 16 Statement OF CORPORATE DISCLOSURE, RULE 7.1 by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN. (GRIFFITH, JAMES) |
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Filing 15
STIPULATION AND ORDER THAT THE RESPONSE DEADLINE FOR DEFENDANTS FLEX NINE EXTERIORS, INC. d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, AND RUSTY HANSEN TO RESPOND TO PLAINTIFF'S COMPLAINT IS EXTENDED TO 10/29/2025. IT IS FURTHER ORDERED THAT ALL COUNSEL MUST COMPLY WITH MY POLICIES AND PROCEDURES CONCERING THE TIMING OF REQUESTS FOR EXTENSIONS AS I WILL DENY ANY FUTURE UNTIMELY REQUESTS. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 10/07/2025. 10/07/2025 ENTERED AND E-MAILED.(ja)
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Filing 14
ORDER THAT DEFENDANT FLEX NINE EXTERIORS, INC. SHALL FILE A DISCLOSURE STATEMENT PURSUANT TO FED. R. CIV. P. 7.1(A)(1) ON OR BEFORE OCTOBER 10, 2025. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 10/06/2025. 10/06/2025 ENTERED AND E-MAILED.(ja)
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| Filing 13 STIPULATION FOR EXTENSION OF TIME by FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN. (GRIFFITH, JAMES) |
| Filing 12 NOTICE of Appearance by JAMES LEWIS GRIFFITH, JR on behalf of FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, FLEX NINE EXTERIORS, INC., AMY HANSEN, AMY HANSEN, RUSTY HANSEN, RUSTY HANSEN (GRIFFITH, JAMES) |
| Filing 11 RESPONSE TO ORDER TO SHOW CAUSE by MDR UNITED LLC. (ALEXANDER, CHRISTOPHER) |
| Filing 10 Disclosure Statement Form pursuant to FRCP 7.1 including JEZ Investments, LLC, Skolnick Holdings, LLC, or JS Equity Holdings, LLC. by MDR UNITED LLC.(ALEXANDER, CHRISTOPHER) |
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Filing 9
ORDER THAT ON OR BEFORE 9.29/2025, MDR SHALL SHOW CAUSE IN A MEMORANDUM, NOT TO EXCEED 5 PAGES, WHY I SHOULD NOT SANCTION IT OR ITS COUNSEL FOR FAILING TO COMPLY WITH MY ORDER. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 9/22/2025. 9/22/2025 ENTERED AND COPIES MAILED TO UNREPS AND E-MAILED.(ahf)
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| Filing 8 SUMMONS Returned Executed by MDR UNITED LLC re: Josyln Stevens served Summons and Complaint upon AMY HANSEN by Personal. AMY HANSEN served on 9/13/2025, answer due 10/6/2025. (ALEXANDER, CHRISTOPHER) |
| Filing 7 SUMMONS Returned Executed by MDR UNITED LLC re: Kyle Stauffer served Summons and Complaint upon RUSTY HANSEN by Personal. RUSTY HANSEN served on 9/13/2025, answer due 10/6/2025. (ALEXANDER, CHRISTOPHER) |
| Filing 6 SUMMONS Returned Executed by MDR UNITED LLC re: Kyle Stauffer served Summons and Complaint upon FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS by Personal. FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS served on 9/18/2025, answer due 10/9/2025. (ALEXANDER, CHRISTOPHER) |
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Filing 5
ORDER THAT PLAINTIFF MDR UNITED LLC SHALL FILE A DISCLOSURE STATEMENT PURSUANT TO FED.R.CIV.P. 7.1 (a)(1) ON OR BEFORE 9/11/25; ETC.. SIGNED BY DISTRICT JUDGE JOSHUA D. WOLSON ON 9/4/25. 9/5/25 ENTERED AND E-MAILED.(JL)
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| Filing 4 Summons Issued as to FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN. Forwarded To: Counsel on 9/4/2025. (ahf) |
| Filing 3 Notice re: Availability of Court-Annexed Mediation (nd) |
| Filing 2 Opt In Notice of Procedure to Consent to Random Magistrate Judge Assignment (Attachments: #1 Proposed Consent Form)(nd) |
| Filing 1 COMPLAINT against FLEX NINE EXTERIORS, INC d/b/a NOVUS ROOFING AND EXTERIORS, AMY HANSEN, RUSTY HANSEN ( Filing fee $ 405 receipt number APAEDC-18557116.), filed by MDR UNITED LLC. (Attachments: #1 Exhibit, #2 Civil Cover Sheet, #3 Designation Form)(ALEXANDER, CHRISTOPHER) |
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