Higginbotham Pawleys Island Investments LLC v. Ford Motor Company
| Higginbotham Pawleys Island Investments LLC doing business as Tidelands Lincoln |
| Ford Motor Company doing business as Lincoln Motor Company |
| 2:2020cv02977 |
| August 18, 2020 |
| US District Court for the District of South Carolina |
| Margaret B Seymour |
| Contract: Franchise |
| 28 U.S.C. § 1332 Diversity-Other Contract |
| Plaintiff |
Docket Report
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| Filing 75 STIPULATION of Dismissal With Prejudice by Ford Motor Company. (Woodward, Nickisha) |
Filing 74
ORDER DISMISSING CASE without costs and without prejudice to the right of either party, upon good cause shown within sixty (60) days, to reinstate the action if settlement is not consummated. Signed by Honorable Margaret B Seymour on 12/9/2021. (vdru, )
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| Filing 70 ADR STATEMENT/CERTIFICATION by Ford Motor Company(Woodward, Nickisha) |
| Filing 69 ADR STATEMENT/CERTIFICATION by Higginbotham Pawleys Island Investments LLC(Martin, Bradford) |
| Filing 68 NOTICE of Request for Protection from Court Appearance by Nickisha Moniece Woodward for September 23-24, 2021, October 14-15, 2021, October 22, 2021, and November 22-24, 2021 (Woodward, Nickisha) |
| Filing 67 CONSENT SIXTH AMENDED SCHEDULING ORDER granting #66 Consent MOTION to Amend/Correct Consent Scheduling Order filed by Ford Motor Company. Expert and Any Supplemental Fact Discovery due by 12/10/2021, Motion in Limine due by 1/14/2022, Motions due by 1/14/2022, Mediation Due by 10/29/2021, Rule 26(a)(3) Disclosures due by 1/21/2022, Jury Selection Deadline 3/28/2022. Signed by Honorable Margaret B Seymour on 8/18/2021. (ssam, ) |
| Filing 66 Consent MOTION to Amend/Correct Consent Scheduling Order by Ford Motor Company. Response to Motion due by 8/31/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Proposed Order Consent Sixth Amended Scheduling Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Woodward, Nickisha) |
| Filing 65 DEFENDANT'S ID OF EXPERT WITNESSES by Ford Motor Company. (Woodward, Nickisha) Modified to delete attachments per request of filing user on 8/10/2021 (ssam, ). |
| Filing 64 NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings. Motion Hearing held on 7/29/21, before Judge Margaret B. Seymour. Court Reporter/Transcriber Karen E. Martin, Telephone number/E-mail Karen_E_Martin@scd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction. Redaction Request due 8/30/2021. Redacted Transcript Deadline set for 9/9/2021. Release of Transcript Restriction set for 11/8/2021. (kmartin, ) |
| Filing 63 SUR REPLY to REPLY to Response to Motion re #42 MOTION for Sanctions Response filed by Ford Motor Company. (Attachments: #1 Exhibit #3 - 5-13-21 Hearing Transcript, #2 Exhibit #4 - 7-26-21 Email, #3 Exhibit #5 - 7-8-21 Email, #4 Exhibit #6 - 5-13-21 Email, #5 Exhibit #7 - Supplemental INT - 2021-06-24, #6 Exhibit #8 - Supplemental RFP - 2021-06-24)(Woodward, Nickisha) |
| Filing 62 TEXT ORDER granting #60 Motion for Leave to File : Defendant Ford Motor Company is granted leave to file its Sur-Reply. Entered at the Direction of The Honorable Margaret B Seymour on 8/2/2021.(vdru, ) |
| Filing 61 Minute Entry. Proceedings held before Honorable Margaret B Seymour: denying #42 Motion for Sanctions; Motion Hearing held by video on 7/29/2021 re #45 Second MOTION to Compel filed by Higginbotham Pawleys Island Investments LLC, #42 MOTION for Sanctions filed by Higginbotham Pawleys Island Investments LLC, #44 MOTION to Compel filed by Ford Motor Company. Court orders Defendant to produce items as discussed on the record. Court orders parties to try to work out the remaining motions to compel. Court Reporter: Karen Martin. (ssam, ) |
| Filing 60 MOTION for Leave to File Ford's Sur-Reply To Plaintiff's Supplemental Reply by Ford Motor Company. Response to Motion due by 8/11/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Exhibit Ford's Sur-Reply To Suppemental Reply - 2021-07-28)Proposed order is being emailed to chambers with copy to opposing counsel.(Woodward, Nickisha) |
| Filing 59 REPLY to Response to Motion re #42 MOTION for Sanctions Response filed by Higginbotham Pawleys Island Investments LLC. (Attachments: #1 Exhibit Portions of Transcript of May 13, 2021 hearing)(Martin, Bradford) |
| Filing 58 NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings. Plaintiff's Motion to Compel held on May 13, 2021, before Judge Margaret B. Seymour. Court Reporter/Transcriber Robin L. Herrera, RMR, CRR, CRC, Telephone number/E-mail robin_herrera@scd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction. Redaction Request due 8/11/2021. Redacted Transcript Deadline set for 8/23/2021. Release of Transcript Restriction set for 10/19/2021. (rher, ) |
| Filing 57 NOTICE of Request for Protection from Court Appearance by Laura WH Teer for August 2-6, 2021 (Teer, Laura) |
| Filing 56 NOTICE of Request for Protection from Court Appearance by Bradford Neal Martin for August 9-13, 2021 (Martin, Bradford) |
| Filing 55 REPLY to Response to Motion re #45 Second MOTION to Compel Response filed by Higginbotham Pawleys Island Investments LLC. (Attachments: #1 Exhibit Autodealer article)(Martin, Bradford) |
| Filing 54 REPLY to Response to Motion re #44 MOTION to Compel Response filed by Ford Motor Company. (Woodward, Nickisha) |
| Filing 52 CONSENT FIFTH AMENDED SCHEDULING ORDER: Defendants ID of Expert Witnesses Due by 8/9/2021, Expert and Any Supplemental Fact Discovery due by 9/6/2021. Signed by Honorable Margaret B Seymour on 7/14/2021. (vdru, ) |
| Filing 51 Consent MOTION for Extension of Time to Complete Discovery by Ford Motor Company. Response to Motion due by 7/27/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Proposed Order Consent Fifth Amended Scheduling Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Woodward, Nickisha) |
| Filing 50 RESPONSE in Opposition re #44 MOTION to Compel Response filed by Higginbotham Pawleys Island Investments LLC.Reply to Response to Motion due by 7/16/2021 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Martin, Bradford) |
| Filing 49 RESPONSE in Opposition re #45 Second MOTION to Compel Response filed by Ford Motor Company.Reply to Response to Motion due by 7/16/2021 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit A - Excerpt of Swann Depo)(Woodward, Nickisha) |
| Filing 48 NOTICE of Hearing on Motion #45 Second MOTION to Compel, #44 MOTION to Compel, #42 MOTION for Sanctions: VIDEO Motion Hearing set for 7/29/2021 01:00 PM before Honorable Margaret B Seymour. NOTE: The Court will send video conferencing instructions prior to the hearing. (ssam, ) |
| Filing 47 REPLY to Response to Motion re #42 MOTION for Sanctions Response filed by Higginbotham Pawleys Island Investments LLC. (Martin, Bradford) |
| Filing 46 PLAINTIFF'S ID OF EXPERT WITNESSES by Higginbotham Pawleys Island Investments LLC.(Martin, Bradford) |
| Filing 45 Second MOTION to Compel by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 7/9/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Exhibit PL Second RP, #2 Exhibit PL Third RP, #3 Exhibit Def Response to Discovery, #4 Exhibit letter to opposing counsel, #5 Exhibit email to opposing counsel, #6 Exhibit email to opposing counsel, #7 Exhibit email to opposing counsel)No proposed order.(Martin, Bradford) |
| Filing 44 MOTION to Compel by Ford Motor Company. Response to Motion due by 7/9/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Memo in Support, #2 Exhibit A-Discovery to Plaintiff, #3 Exhibit B-Plaintiff's Discovery Responses, #4 Exhibit C-Letter regarding discovery, #5 Exhibit D-Meet and Confer Letter, #6 Exhibit E-Plaintiff's Supp Discovey Responses, #7 Exhibit F-Email re extension)No proposed order.(Woodward, Nickisha) |
| Filing 43 RESPONSE in Opposition re #42 MOTION for Sanctions Response filed by Ford Motor Company.Reply to Response to Motion due by 7/1/2021 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit June 4, 2021 Email, #2 Exhibit June 7, 2021 Email)(Woodward, Nickisha) |
| Filing 42 MOTION for Sanctions by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 6/24/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Exhibit Email to counsel, #2 Exhibit Email from counsel, #3 Exhibit Email to counsel, #4 Exhibit Email from counsel)No proposed order.(Martin, Bradford) . |
| Filing 40 CONSENT FOURTH AMENDED SCHEDULING ORDER: Plaintiffs ID of Expert Witness due by 6/28/2021, Defendants ID of Expert Witnesses Due by 7/26/2021, Expert and Fact Discovery due by 8/23/2021, Motion in Limine due by 10/8/2021, Motions due by 9/10/2021, Rule 26(a)(3) Disclosures due by 10/15/2021, Pretrial Briefs due by 10/25/2021, Jury Selection Deadline 11/1/2021, Mediation Due by 9/17/2021. Signed by Honorable Margaret B Seymour on 5/19/2021. (vdru, ) |
| Filing 39 Consent MOTION to Amend/Correct #22 Scheduling Order,, by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 6/1/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Martin, Bradford) |
| Filing 38 NOTICE of Request for Protection from Court Appearance by Nickisha Moniece Woodward for June 16-18, 2021, July 2-9, 2021, August 11-13, 2021 and August 26-27, 2021 (Attachments: #1 Proposed Order)(Woodward, Nickisha) |
| Filing 37 Minute Entry. Proceedings held before Honorable Margaret B Seymour: granting in part and denying in part #27 Motion to Compel; Motion Hearing held by telephone conference on 5/13/2021 re #27 MOTION to Compel filed by Higginbotham Pawleys Island Investments LLC. Court grants in part and denies in part the motion to compel as stated on the record. Court Reporter: Beth Krupa. (ssam, ) |
| Filing 36 TEXT ORDER: Based on the broad allegations of the complaint, the intent of the Robinson-Patman Act and other relevant federal and state statutes to eliminate unfair and discriminatory practices in commerce, and the liberal construction of the rules of civil procedure for the purpose of adequately informing litigants prior to trial, the court directs the parties to again confer in a further attempt to resolve their disputes. The parties should notify the court no later than 10:00 a.m. on Thursday, May 13, 2021, regarding any remaining issues requiring court intervention. Entered at the direction of Honorable Margaret B Seymour on 5/12/2021. (ssam, ) |
| Filing 35 NOTICE OF RESCHEDULED HEARING VIDEO Motion Hearing re: #27 Motion to Compel set for 5/13/2021 11:00 AM cancelled and rescheduled to: Telephone Conference re: #27 Motion to Compel set for 5/13/2021 11:00 AM before Honorable Margaret B Seymour. *HEARING DATE AND TIME REMAIN THE SAME, BUT HEARING WILL NOW BE HELD BY TELEPHONE CONFERENCE.* NOTE: The Court will send dial-in instructions prior to the hearing. (ssam, ) |
| Filing 34 NOTICE of Hearing on Motion #27 MOTION to Compel : VIDEO Motion Hearing set for 5/13/2021 11:00 AM before Honorable Margaret B Seymour. NOTE: The Court will send updated video conferencing instructions prior to the hearing. (ssam, ) |
| Filing 33 NOTICE of Cancellation of Hearing: VIDEO Motion Hearing re #27 MOTION to Compel set for Wednesday, 5/5/2021, at 02:45 PM. Hearing to be rescheduled at a later date. (ssam, ) |
| Filing 32 NOTICE OF RESCHEDULED HEARING VIDEO Motion Hearing set for Wednesday, 4/28/2021 at 10:30 AM cancelled and rescheduled to: VIDEO Motion Hearing re #27 MOTION to Compel set for Wednesday, 5/5/2021 02:45 PM before Honorable Margaret B Seymour. NOTE: Video conferencing instructions remain the same. (ssam, ) |
| Filing 31 NOTICE of Hearing on Motion #27 MOTION to Compel : Motion Hearing set for Wednesday, 4/28/2021 at 10:30 AM in Charleston Courtroom #4, U. S. Court House, 85 Broad St, Charleston before Honorable Margaret B Seymour. Video information and instructions will be distributed to the participating parties at a later date. (vdru, ) |
| Filing 30 REPLY to Response to Motion re #27 MOTION to Compel Response filed by Higginbotham Pawleys Island Investments LLC. (Martin, Bradford) |
| Filing 29 RESPONSE in Opposition re #27 MOTION to Compel Response filed by Ford Motor Company.Reply to Response to Motion due by 4/21/2021 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: #1 Exhibit Fords Responses to Plaintiffs First Requests to Produce, #2 Exhibit Fords Responses to Plaintiffs First Interrogatories, #3 Exhibit Fords Responses to Plaintiffs First Requests for Admission, #4 Exhibit Fords Supplemental Responses to Plaintiffs First Requests to Produce, #5 Exhibit Fords Supplemental Responses to Plaintiffs First Interrogatories, #6 Exhibit Fords Responses to Plaintiffs Second Requests to Produce, #7 Exhibit Fords Responses to Plaintiffs Third Requests to Produce, #8 Exhibit Jan. 12, 2021 Letter from Plaintiffs Counsel, #9 Exhibit Jan. 29, 2021 Letter from Fords Counsel, #10 Exhibit Mar. 15, 2021 Email from Plaintiffs Counsel)(Woodward, Nickisha) |
| Filing 28 NOTICE of Request for Protection from Court Appearance by Bradford Neal Martin for May 3-6, May 17-21, August 9-13, Nov 7-14 (Martin, Bradford) |
| Filing 27 MOTION to Compel by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 4/14/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Exhibit Def Answers to First Interrogatories, #2 Exhibit Def Response to First RP, #3 Exhibit Def Answers to First RTA, #4 Exhibit Emails re meet and confer, #5 Exhibit PL written objections, #6 Exhibit Def response to objections, #7 Exhibit Emails re protective order, #8 Exhibit Emails re meet and confer, #9 Exhibit Def Supp Answers to RTP, #10 Exhibit Def Supp Answers to Interrogatories)No proposed order.(Martin, Bradford) |
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Filing 26
ORDER granting #25 Motion for Confidentiality Order: The parties have stipulated that certain discovery material is and should be treated as confidential and have agreed to the terms of this order. Details regarding the designation and treatment of confidential materials are set forth in Order. Signed by Honorable Margaret B Seymour on 2/11/2021.(vdru, )
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| Filing 25 Consent MOTION for Confidentiality Order by Ford Motor Company. Response to Motion due by 2/24/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Proposed Order Confidentiality Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Woodward, Nickisha) |
| Filing 24 NOTICE of Request for Protection from Court Appearance by Nickisha Moniece Woodward for May 12-14, 2021, May 28, 2021 - June 7, 2021, and June 16-18, 2021 (Attachments: #1 Proposed Order Order of Protection)(Woodward, Nickisha) |
| Filing 22 CONSENT THIRD AMENDED SCHEDULING ORDER: Plaintiffs ID of Expert Witness due by 5/24/2021, Defendants ID of Expert Witnesses Due by 6/28/2021, Records Custodian Affidavit due by 3/5/2021, Initial Fact Discovery due by 4/19/2021, Expert and Supplemental Fact Discovery due by 7/26/2021, Motion in Limine due by 9/24/2021, Motions due by 8/9/2021, Rule 26(a)(3) Disclosures due by 9/30/2021, Pretrial Briefs due by 10/11/2021, Jury Selection Deadline 10/18/2021, Mediation Due by 9/17/2021. Signed by Honorable Margaret B Seymour on 12/17/2020. (vdru, ) Modified on 12/28/2020 to correct signature date. (vdru, ). |
| Filing 21 Consent MOTION to Amend/Correct #19 Scheduling Order,, by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 1/4/2021. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Martin, Bradford) |
| Filing 19 CONSENT SECOND AMENDED SCHEDULING ORDER: Plaintiffs ID of Expert Witness due by 1/25/2021, Defendants ID of Expert Witnesses Due by 3/5/2021, Records Custodian Affidavit due by 3/5/2021, Discovery due by 4/19/2021, Motion in Limine due by 6/15/2021, Motions due by 5/3/2021, Rule 26(a)(3) Disclosures due by 7/19/2021, Pretrial Briefs due by 7/29/2021, Jury Selection Deadline 8/5/2021, Mediation Due by 7/2/2021. Signed by Honorable Margaret B Seymour on 11/20/2020. (vdru, ) |
| Filing 18 Consent MOTION to Amend/Correct #17 Scheduling Order,, by Higginbotham Pawleys Island Investments LLC. Response to Motion due by 12/3/2020. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Martin, Bradford) |
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Filing 17
SCHEDULING ORDER Motions to Amend Pleadings due by 11/16/2020, Plaintiffs ID of Expert Witness due by 12/21/2020, Defendants ID of Expert Witnesses Due by 1/29/2021, Records Custodian Affidavit due by 1/29/2021, Discovery due by 3/15/2021, Motion in Limine due by 5/11/2021, Motions due by 3/29/2021, Rule 26(a)(3) Disclosures due by 6/14/2021, Pretrial Briefs due seven (7) days prior to the date set for jury selection, Jury Selection on or after 7/1/2021, Mediation Due by 5/28/2021. Signed by Honorable Margaret B Seymour on 10/21/2020. (vdru, )
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| Filing 16 Local Rule 26.03 Answers to Interrogatories by Ford Motor Company.(Woodward, Nickisha) |
| Filing 15 Rule 26(f) Report by Ford Motor Company. (Attachments: #1 Proposed Order Amended Conference and Scheduling Order)(Woodward, Nickisha) |
| Filing 14 Plaintiff's Local Rule 26.03 Answers to Interrogatories by Higginbotham Pawleys Island Investments LLC.(Martin, Bradford) |
| Filing 13 TEXT ORDER granting #12 Motion to Appear Pro Hac Vice: It is ordered that Robert Hugh Ellis who represents Ford Motor Company is granted admission pro hac vice in this case. Entered at the Direction of The Honorable Margaret B Seymour on 10/5/2020.(vdru, ) |
| Filing 12 MOTION to Appear Pro Hac Vice by Robert Hugh Ellis ( Filing fee $ 350 receipt number 0420-9380064) by Ford Motor Company. Response to Motion due by 10/15/2020. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: #1 Affidavit Application/Affidavit for Pro Hac Vice Admission, #2 Exhibit Certificate of Good Standing - Michigan, #3 Exhibit Certificate of Good Standing - Wisconsin, #4 Proposed Order Order for Admission Pro Hac Vice)Proposed order is being emailed to chambers with copy to opposing counsel.(Woodward, Nickisha) |
| Filing 11 MEDIATION ORDER: Mediation Due by 5/28/2021. Signed by Honorable Margaret B Seymour on 9/16/2020. (vdru, ) |
| Filing 10 CONFERENCE AND SCHEDULING ORDER: Rule 26(f) Conference Deadline 10/6/2020, 26(a) Initial Disclosures due by 10/20/2020, Rule 26 Report due by 10/20/2020, Motions to Amend Pleadings due by 11/16/2020, Plaintiffs ID of Expert Witness due by 12/14/2020, Defendants ID of Expert Witnesses Due by 1/13/2021, Records Custodian Affidavit due by 1/13/2021, Discovery due by 3/15/2021, Motion in Limine due by 5/11/2021, Motions due by 3/29/2021, Rule 26(a)(3) Disclosures due by 6/14/2021, Pretrial Briefs due by 6/24/2021, Jury Selection Deadline 7/1/2021, Mediation Due by 5/28/2021. Signed by Honorable Margaret B Seymour on 9/16/2020. (vdru, ). |
| Filing 9 AMENDED ANSWER to Plaintiff's Complaint by Ford Motor Company. (Woodward, Nickisha) |
| Filing 8 REPLY by Ford Motor Company to #7 Order . (Woodward, Nickisha) |
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Filing 7
ORDER re #1 Notice of Removal, filed by Ford Motor Company. Signed by Honorable Margaret B Seymour on 9/4/2020. (vdru, )
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| Filing 6 Local Rule 26.01 Answers to Interrogatories by Higginbotham Pawleys Island Investments LLC. (Martin, Bradford). Clerk removed document originally filed as an attachment in order to file as a separate entry. (vdru, ) |
| Filing 5 DISCLOSURE STATEMENT PURSUANT TO FRCP 7.1 by Higginbotham Pawleys Island Investments LLC. (Martin, Bradford) Modified to remove attachment and refile as separate entry, # 6, on 9/4/2020. (vdru, ). |
| Filing 4 ANSWER to Complaint by Ford Motor Company.(Woodward, Nickisha) |
| Filing 2 Local Rule 26.01 Answers to Interrogatories by Ford Motor Company.(vdru, ) |
| Filing 1 NOTICE OF REMOVAL from Georgetown County Court of Common Pleas, case number 2020-CP-22-583. (Filing fee $ 400 receipt number 0420-9284899), filed by Ford Motor Company. (Attachments: #1 State Court Documents A: State Court Documents, #2 Exhibit B: Certified Mail Receipt). (vdru, ) |
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| Plaintiff: Higginbotham Pawleys Island Investments LLC doing business as Tidelands Lincoln | |
| Represented By: | Bradford Neal Martin |
| Represented By: | Laura WH Teer |
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| Defendant: Ford Motor Company doing business as Lincoln Motor Company | |
| Represented By: | Nickisha Moniece Woodward |
| Represented By: | Robert Hugh Ellis |
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