Ambac Assurance Corporation v. The Bank of New York Mellon
| Ambac Assurance Corporation |
| The Banco Popular de Puerto Rico Benefits Committee |
| 3:2024cv01443 |
| September 23, 2024 |
| US District Court for the District of Puerto Rico |
| Laura Taylor Swain |
| Contract: Other |
| 28 U.S.C. § 1446 Notice of Removal |
| Plaintiff |
Docket Report
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This docket was last retrieved on September 24, 2024. A more recent docket listing may be available from PACER.
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Filing 56
NOTICE TO COUNSEL re: Case Transferred from the Southern District of New York. Signed by Clerk on 9/23/2024.(idg)
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Filing 55
Case transferred in from District of New York Southern; Case Number 1:17-cv-03804. Original file certified copy of transfer order and docket sheet received.
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Filing 54
MEMO ENDORSEMENT on re: #53 Response to Order to Show Cause filed by The Bank of New York Mellon. ENDORSEMENT : Given the parties' consent to the Court's September 12, 2024 Order to Show Cause (docket entry no. 52), the Clerk of Court is respectfully requested to effectuate the transfer of this case promptly to the District of Puerto, to be heard by the undersigned in her capacity as a visiting Judge of that District. SO ORDERED. (Signed by Judge Laura Taylor Swain on 9/19/24) (yv) [Transferred from nysd on 9/23/2024.]
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CASE TRANSFERRED OUT ELECTRONICALLY from the U.S.D.C. Southern District of New York to the United States District Court - District of District of Puerto Rico.(yv) [Transferred from nysd on 9/23/2024.]
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Filing 53
RESPONSE TO ORDER TO SHOW CAUSE re: #52 Order to Show Cause,. Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 52
ORDER TO SHOW CAUSE: Therefore, the Court intends to transfer this case to that District, to be heard by the undersigned in the undersigned's capacity as a visiting judge in the District of Puerto Rico. The parties are hereby ordered to show cause in writing filed in the above captioned action by September 20, 2024, as to why the Court should not transfer this action to the District of Puerto Rico. SO ORDERED. (Signed by Judge Laura Taylor Swain on 9/12/2024) (mml) [Transferred from nysd on 9/23/2024.]
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Filing 51
LETTER addressed to Judge Laura Taylor Swain from Robert K. Kry dated July 7, 2023 re: response to BNYM supplemental authority letter (Dkt. 50). Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 50
LETTER addressed to Judge Laura Taylor Swain from Kurt F. Gwynne, Esq. of Reed Smith LLP dated June 30, 2023 re: Recent Authoritative Decision. Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 49
ENDORSED LETTER addressed to Judge Laura Taylor Swain from Robert Kry dated 5/8/2023 re: As both parties requested argument on the motion, we were wondering whether the Court anticipates hearing argument, and if so, whether there is any information the parties could provide that would be helpful to facilitate scheduling in that regard?. ENDORSEMENT: The motion is under advisement and the Court will inform the parties as to whether oral argument will be required. (Signed by Judge Laura Taylor Swain on 5/9/2023) (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 48
ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE granting #34 Motion for Luke A. Sizemore to Appear Pro Hac Vice. (Signed by Judge Laura Taylor Swain on 10/26/2022) (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 47
ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE granting #35 Motion for Victoria A. Sanford to Appear Pro Hac Vice. (Signed by Judge Laura Taylor Swain on 10/26/2022) (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 46
RESPONSE re: #37 Notice (Other), #43 Notice (Other) Reply of The Bank of New York Mellon, in Support of its Request for Judicial Notice and Response to Ambac Assurance Corporation's Request for Judicial Notice. Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 45
REPLY MEMORANDUM OF LAW in Support re: #36 MOTION to Dismiss the Second Amended Complaint. . Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 44
DECLARATION of Lauren F. Dayton in Opposition re: #36 MOTION to Dismiss the Second Amended Complaint.. Document filed by Ambac Assurance Corporation. (Attachments: #1 Exhibit A - Lex Claims Motion to Dismiss, #2 Exhibit B - Lex Claims Order, #3 Exhibit C - Lex Claims Appeal Brief, #4 Exhibit D - Ambac to COFINA Letter, #5 Exhibit E - Assured Joinder).(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 43
NOTICE of Ambac's Request for Judicial Notice and Response to BNYM's Request for Judicial Notice re: #37 Notice (Other),. Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 42
MEMORANDUM OF LAW in Opposition re: #36 MOTION to Dismiss the Second Amended Complaint. . Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 41
NOTICE OF APPEARANCE by Nancy Savitt on behalf of The Bank of New York Mellon..(Savitt, Nancy) [Transferred from nysd on 9/23/2024.]
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Filing 40
NOTICE OF APPEARANCE by Louis M. Solomon on behalf of The Bank of New York Mellon..(Solomon, Louis) [Transferred from nysd on 9/23/2024.]
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Filing 39
MEMORANDUM OF LAW in Support re: #36 MOTION to Dismiss the Second Amended Complaint. . Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 38
DECLARATION of Kurt F. Gwynne in Support re: #36 MOTION to Dismiss the Second Amended Complaint.. Document filed by The Bank of New York Mellon. (Attachments: #1 Appendix of Exhibits for the Motion of The Bank of New York Mellon, as Trustee, for an Order Dismissing, with Prejudice, Second Amended Complaint for Failure to State a Claim Pursuant to Federal Rule of Civil Procedure 12(B)(6), #2 Exhibit 1 First Supplemental Resolution, #3 Exhibit 2 part 1 Third Amended Plan of Adjustment, #4 Exhibit 2 part 2 Third Amended Plan of Adjustment, #5 Exhibit 2 part 3 Third Amended Plan of Adjustment, #6 Exhibit 2 part 4 Third Amended Plan of Adjustment, #7 Exhibit 2 part 5 Third Amended Plan of Adjustment, #8 Exhibit 3 part 1 Confirmation Order, #9 Exhibit 3 part 2 Confirmation Order, #10 Exhibit 4 Resolution, #11 Exhibit 5 Enabling Act, #12 Exhibit 6 part 1 September 2015 Fiscal Plan, #13 Exhibit 6 part 2 September 2015 Fiscal Plan, #14 Exhibit 6 part 3 September 2015 Fiscal Plan, #15 Exhibit 7 9-24-15 Bondholder Letter, #16 Exhibit 8 2016 Restructuring Proposal, #17 Exhibit 9 Moratorium Act, #18 Exhibit 10 4-6-16 Bondholder Letter, #19 Exhibit 11 2017 Fiscal Plan, #20 Exhibit 12 3-27-17 Bondholder Letter, #21 Exhibit 13 Proposal, #22 Exhibit 14 Fiscal Plan Compliance Law, #23 Exhibit 15 5-1-17 BNYM Letter, #24 Exhibit 16 5-1-16 Ambac Breach Notice, #25 Exhibit 17 May 4 BNYM Letter, #26 Exhibit 18 4-30-17 Ambac Letter, #27 Exhibit 19 May 4 Letter to BNYM Letter, #28 Exhibit 20 2-8-16 Bondholder Letter, #29 Exhibit 21 part 1 COFINA Senior Bondholders Response, #30 Exhibit 21 part 2 COFINA Senior Bondholders Response, #31 Exhibit 22 part 1 Ambac's Motion to Dismiss, #32 Exhibit 22 part 2 Ambac's Motion to Dismiss, #33 Exhibit 23 Notice of Automatic Stay (Jacana Lawsuit), #34 Exhibit 24 Plaintiff's Response to Automatic Stay (Jacana Lawsuit), #35 Exhibit 25 COFINA's Answer, #36 Exhibit 26 part 1 Ambac Answer and Affirmative Defenses, #37 Exhibit 26 part 2 Ambac Answer and Affirmative Defenses, #38 Exhibit 26 part 3 Ambac Answer and Affirmative Defenses, #39 Exhibit 26 part 4 Ambac Answer and Affirmative Defenses, #40 Exhibit 27 part 1 Oversight Board's Motion to Dismiss, #41 Exhibit 27 part 2 Oversight Board's Motion to Dismiss, #42 Exhibit 28 Ambac Interpleader Reply, #43 Exhibit 29 NPFGC's Memorandum of Law).(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 37
NOTICE of Request of The Bank of New York Mellon, as Trustee, for Judicial Notice Pursuant to Federal Rule of Evidence 201 re: #36 MOTION to Dismiss the Second Amended Complaint.. Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 36
MOTION to Dismiss the Second Amended Complaint. Document filed by The Bank of New York Mellon. Responses due by 9/23/2022.(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #35 MOTION for Victoria A. Sanford to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26453492. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) [Transferred from nysd on 9/23/2024.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #34 MOTION for Luke A. Sizemore to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26453406. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz) [Transferred from nysd on 9/23/2024.]
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Filing 35
MOTION for Victoria A. Sanford to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26453492. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Bank of New York Mellon. (Attachments: #1 Affidavit Declaration and Certificate of Good Standing of Victoria A. Sanford, #2 Text of Proposed Order ).(Sanford, Victoria) [Transferred from nysd on 9/23/2024.]
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Filing 34
MOTION for Luke A. Sizemore to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-26453406. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by The Bank of New York Mellon. (Attachments: #1 Affidavit Declaration of Luke A. Sizemore, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order Text of Proposed Order).(Sizemore, Luke) [Transferred from nysd on 9/23/2024.]
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Filing 33
ORDER granting #32 Letter Motion for Leave to File Excess Pages. The foregoing page extension and time extension requests are granted. Docket entry no. 32 is resolved. SO ORDERED. (Signed by Judge Laura Taylor Swain on 7/18/2022) (vfr) [Transferred from nysd on 9/23/2024.]
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Set/Reset Deadlines: The Bank of New York Mellon answer due 7/25/2022. Motions due by 7/25/2022. (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 32
LETTER MOTION for Leave to File Excess Pages for Memorandum of Law and to Modify Briefing Schedule addressed to Judge Laura Taylor Swain from Kurt F. Gwynne, Esq. of Reed Smith LLP dated July 18, 2022. Document filed by The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 31
SECOND AMENDED COMPLAINT amending #8 Amended Complaint against The Bank of New York Mellon with JURY DEMAND.Document filed by Ambac Assurance Corporation. Related document: #8 Amended Complaint..(Molo, Steven) [Transferred from nysd on 9/23/2024.]
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Filing 30
ORDER granting #27 Motion to Vacate #12 Order Staying Case ; granting #27 Motion for Leave to File Document. Plaintiff has filed a motion (docket entry no. 27) requesting that the Court (1) lift the stay of proceedings that was previously entered on June 19, 2017 (docket entry no. 12); and (2) grant Plaintiff leave to file a Second Amended Complaint. Defendant does not oppose the motion to lift the stay, and does not take a position on the motion for leave to amend. For substantially the reasons stated in Plaintiff's moving brief and declaration (docket entry nos. 28 and 29), both of Plaintiff's requests are granted. The stay is lifted. Plaintiff's Second Amended Complaint shall be filed by July 11, 2022. Defendant shall respond to the Second Amended Complaint in accordance with the applicable Federal Rules of Civil Procedure, SDNY Local Civil Rules, and this Court's Individual Rules. Docket entry no. 27 is resolved. SO ORDERED. (Signed by Judge Laura Taylor Swain on 7/6/2022) (vfr) [Transferred from nysd on 9/23/2024.]
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Case Stay Lifted. (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 29
DECLARATION of Robert K. Kry in Support re: #27 MOTION to Vacate #12 Order Staying Case, . MOTION for Leave to File Second Amended Complaint .. Document filed by Ambac Assurance Corporation. (Attachments: #1 Exhibit A - proposed Second Amended Complaint, #2 Exhibit B - redline).(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 28
MEMORANDUM OF LAW in Support re: #27 MOTION to Vacate #12 Order Staying Case, . MOTION for Leave to File Second Amended Complaint . . Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 27
MOTION to Vacate #12 Order Staying Case, ., MOTION for Leave to File Second Amended Complaint . Document filed by Ambac Assurance Corporation. (Attachments: #1 Text of Proposed Order.).(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 26
NOTICE OF APPEARANCE by Lauren F. Dayton on behalf of Ambac Assurance Corporation..(Dayton, Lauren) [Transferred from nysd on 9/23/2024.]
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Filing 25
MEMO ENDORSEMENT on re: #24 Status Report filed by Ambac Assurance Corporation. ENDORSEMENT: The case will remain stayed and administratively closed. The parties are directed to file a further status report by October 21, 2022, unless motion practice has been commenced or the case has been dismissed before that date. SO ORDERED. (Signed by Judge Laura Taylor Swain on 5/18/2022) (vfr) [Transferred from nysd on 9/23/2024.]
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Filing 24
STATUS REPORT. Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 23
MEMO ENDORSEMENT: denying as moot #9 MOTION to Transfer Case . filed by The Bank of New York Mellon. ENDORSEMENT: The outstanding Motion to Transfer Venue (docket entry no. 9) in the above-captioned case is denied as moot, in light of the confirmation of the PROMESA Title III plan of adjustment for COFINA in the District of Puerto Rico. See In re the Financial Oversight and Management Board for Puerto Rico as representative of Puerto Rico Sales Tax Financing Corporation (COFINA), case no. 17-bk-03284 (D.P.R.). The above-captioned case remains stayed by virtue of the Court's June 19, 2017 Order (docket entry no. 12). The parties shall submit a further status report by May 16, 2022. The Clerk of Court is directed to mark this case as administratively closed for statistical purposes only. SO ORDERED. (Signed by Judge Laura Taylor Swain on 11/17/2021) (js) [Transferred from nysd on 9/23/2024.]
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Filing 22
RESPONSE TO ORDER TO SHOW CAUSE re: #13 Order to Show Cause,,,,,. Document filed by Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 21
MEMO ENDORSEMENT on re: #18 MOTION for Theresa A. Foudy to WITHDRAW AS COUNSEL. . filed by Ambac Assurance Corporation. ENDORSEMENT: The foregoing withdrawal request is granted. The Clerk's Office is respectfully directed to update the docket accordingly. Docket entry no. 18 is resolved. So Ordered. Attorney Theresa Ann Foudy terminated. (Signed by Judge Laura Taylor Swain on 11/12/2021) (js) [Transferred from nysd on 9/23/2024.]
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Filing 20
MEMO ENDORSEMENT on re: #17 NOTICE AND ORDER FOR WITHDRAWAL OF COUNSEL: filed by The Bank of New York Mellon ENDORSEMENT: The foregoing withdrawal request is granted. The Clerk's Office is respectfully directed to update the docket accordingly. SO ORDERED. Attorney Christopher Neil Gray terminated. (Signed by Judge Laura Taylor Swain on 11/12/2021) (js) [Transferred from nysd on 9/23/2024.]
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Filing 19
DECLARATION of Theresa A. Foudy in Support re: #18 MOTION for Theresa A. Foudy to Withdraw as Attorney .. Document filed by Ambac Assurance Corporation..(Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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Filing 18
MOTION for Theresa A. Foudy to Withdraw as Attorney . Document filed by Ambac Assurance Corporation..(Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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Filing 17
PROPOSED ORDER FOR WITHDRAWAL OF ATTORNEY. Document filed by The Bank of New York Mellon..(Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 16
NOTICE OF APPEARANCE by Kurt Gwynne on behalf of The Bank of New York Mellon..(Gwynne, Kurt) [Transferred from nysd on 9/23/2024.]
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Filing 15
NOTICE OF APPEARANCE by Robert Kelsey Kry on behalf of Ambac Assurance Corporation..(Kry, Robert) [Transferred from nysd on 9/23/2024.]
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Filing 14
NOTICE OF APPEARANCE by Steven Francis Molo on behalf of Ambac Assurance Corporation..(Molo, Steven) [Transferred from nysd on 9/23/2024.]
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Filing 13
ORDER: On May 24, 2017, Defendant filed a motion to transfer venue (docket entry no. 9) requesting that this case be transferred from the Southern District of New York to the District of Puerto Rico because the matter was related to a case that was pending in the District of Puerto Rico-namely, In re the Financial Oversight and Management Board for Puerto Rico asrepresentative of Puerto Rico Sales Tax Financing Corporation (COFINA), case no. 17-bk-03284 (D.P.R.) (the "COFINA Case"). On May 30, 2017, an Order Granting Interpleader was issued in the COFINA Case, which (1) granted Defendant interpleader status in the COFINA Case, and (2) stayed the above-captioned Southern District action. (Case no. 17-bk-03284, docket entry no. 110.) There have been no further filings by the parties in this action since that time. The parties are accordingly directed to show cause in writing filed no later than November 15, 2021, as to why the outstanding venue motion should not be denied as moot and the above-captioned action dismissed as moot in light of the confirmation of the PROMESA Title III plan of adjustment for COFINA in the District of Puerto Rico. SO ORDERED. Show Cause Response due by 11/15/2021. (Signed by Judge Laura Taylor Swain on 11/01/2021) (ama) [Transferred from nysd on 9/23/2024.]
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Filing 12
Vacated as per Judge's Order dated 7/6/2022, Doc. #30 ORDER: Pursuant to the May 30, 2017, Order of the United States District Court for the District of Puerto Rico (see docket entry no. 11, Ex. A), this case is stayed pending further order of the Court. (Signed by Judge Laura Taylor Swain on 6/19/2017) (mro) Modified on 7/6/2022 (vfr). [Transferred from nysd on 9/23/2024.]
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Filing 11
LETTER addressed to Judge Laura Taylor Swain from Theresa A. Foudy dated June 13, 2017 re: May 30, 2017 Order Staying Litigation. Document filed by Ambac Assurance Corporation.(Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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Filing 10
MEMORANDUM OF LAW in Support re: #9 MOTION to Transfer Case . . Document filed by The Bank of New York Mellon. (Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 9
MOTION to Transfer Case . Document filed by The Bank of New York Mellon.(Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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NOTICE OF CASE REASSIGNMENT to Judge Laura Taylor Swain. Judge Unassigned is no longer assigned to the case. (wb) [Transferred from nysd on 9/23/2024.]
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CASE ACCEPTED AS RELATED. Create association to 1:17-cv-03750-LTS. Notice of Assignment to follow. (wb) [Transferred from nysd on 9/23/2024.]
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Filing 8
FIRST AMENDED COMPLAINT against The Bank of New York Mellon with JURY DEMAND.Document filed by Ambac Assurance Corporation.(Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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Filing 7
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Ambac Financial Group, Inc. for Ambac Assurance Corporation. Document filed by Ambac Assurance Corporation.(Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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Filing 6
NOTICE OF APPEARANCE by Theresa Ann Foudy on behalf of Ambac Assurance Corporation. (Foudy, Theresa) [Transferred from nysd on 9/23/2024.]
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. (kl) [Transferred from nysd on 9/23/2024.]
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***NOTICE TO ATTORNEY REGARDING CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Christopher Neil Gray. The following case opening statistical information was erroneously selected/entered: Cause of Action code Civil Miscellaneous Case - Other. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 28:1446nr Notice of Removal. (kl) [Transferred from nysd on 9/23/2024.]
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Case Designated ECF. (kl) [Transferred from nysd on 9/23/2024.]
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Case Opening Fee Refunded: for #1 Notice of Removal,. Filing fee refunded for Receipt number 0208-13687895, for the following reason(s): DUPLICATE PAYMENT. (dig) [Transferred from nysd on 9/23/2024.]
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CASE REFERRED TO Judge Laura Taylor Swain as possibly related to 1:17-cv-03750-UA. (kl) [Transferred from nysd on 9/23/2024.]
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Filing 5
STATEMENT OF RELATEDNESS re: that this action be filed as related to 1:17-cv-3750. Document filed by The Bank of New York Mellon.(Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 4
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent The Bank of New York Mellon Corp. for The Bank of New York Mellon. Document filed by The Bank of New York Mellon.(Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 3
CIVIL COVER SHEET filed. (Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 2
NOTICE OF REMOVAL from Supreme Court of the State of New York, County of New York. Case Number: 652356/2017. (Filing Fee $ 400.00, Receipt Number 0208-13687950).Document filed by The Bank of New York Mellon. (Attachments: #1 Exhibit A)(Gray, Christopher) [Transferred from nysd on 9/23/2024.]
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Filing 1
FILING ERROR - DUPLICATE DOCKET ENTRY NOTICE OF REMOVAL from Supreme Court of the State of New York, County of New York. Case Number: 652356/2017. (Filing Fee $ 400.00, Receipt Number 0208-13687895).Document filed by The Bank of New York Mellon.(Gray, Christopher) Modified on 5/22/2017 (kl). [Transferred from nysd on 9/23/2024.]
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