Simkins et al v. Blackbaud Inc
| Kristiina Molnar, Rosalie Simkins and Jessica Case |
| Blackbaud Inc |
| 3:2021cv00431 |
| February 10, 2021 |
| US District Court for the District of South Carolina |
| J Michelle Childs |
| P.I.: Other |
| 28 U.S.C. § 1332 |
| Plaintiff |
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Filing 37
ORDER APPOINTING MEDIATOR. This Order relates to all actions. Signed by Honorable J Michelle Childs on 4/9/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, )
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| Filing 36 CASE MANAGEMENT ORDER NO. 7B (PLAINTIFFS' DEFENDANT FACT SHEET). This Order relates to all actions. Signed by Honorable J Michelle Childs on 4/7/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 35 MOTION to Seal by Plaintiffs' Lead Counsel. Response to Motion due by 4/16/2021. 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, #3 Certificate of Service)No proposed order.Associated Cases: 3:20-mn-02972-JMC et al.(Kimpson, Marlon) |
| Filing 34 TEXT ORDER granting #32 Motion to Appear Pro Hac Vice. Signed by Honorable J Michelle Childs on 4/1/2021.(asni, ) |
| Filing 33 TEXT ORDER granting #31 Motion to Appear Pro Hac Vice. Signed by Honorable J Michelle Childs on 4/1/2021.(asni, ) |
| Filing 32 MOTION to Appear Pro Hac Vice by Emma M. Wright ( Filing fee $ 350 receipt number 0420-9749097) by Jessica Case, Kristiina Molnar, Rosalie Simkins. Response to Motion due by 4/15/2021. 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 Application/Affidavit for Pro Hac Vice Admission, #2 Proposed Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Wright, Emma) |
| Filing 31 MOTION to Appear Pro Hac Vice by Christopher L. Springer ( Filing fee $ 350 receipt number 0420-9749038) by Jessica Case, Kristiina Molnar, Rosalie Simkins. Response to Motion due by 4/15/2021. 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 Application/Affidavit for Pro Hac Vice Admission, #2 Proposed Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Springer, Christopher) |
| Filing 30 TEXT ORDER: After the second case management conference, the court asked the parties to email a letter to the court detailing their preferred sequence of discovery and motions by March 26, 2021. (ECF No. 53 at 3.) Both parties submitted letters because they were unable to reach an agreement on sequencing. In their letter, Plaintiffs asked the court to allow the parties to submit updated proposals on April 9, 2021, contending that the parties' discussions about sequencing will be more productive after Plaintiffs file their Consolidated Class Action Complaint on April 2, 2021. As the court encourages the parties' collaborative efforts to reach an agreement on the sequence of discovery and motions in this litigation, the court will accept updated proposals from the parties. The parties shall email their updated proposals to childs_ecf@scd.uscourts.gov by April 9, 2021 at 5:00 pm EST. After the court reviews the parties' updated proposals, it will enter a case management order specifying how the litigation will proceed. Signed by Honorable J Michelle Childs on 3/30/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 29 STIPULATED CONFIDENTIALITY ORDER. This Order relates to all actions. Signed by Honorable J Michelle Childs on 3/29/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 28 TEXT ORDER: This matter is before the court to address the production of the forensic report referenced in Case Management Order No. 7A. Because the parties have not yet submitted an agreed upon confidentiality order for its review, the court extends the deadline in Case Management Order No. 7A to 72 hours from the entry date of this Order. This Order relates to all actions. refiled by the clerk to spread to all cases. Signed by Honorable J Michelle Childs on 3/26/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 26 CASE MANAGEMENT ORDER NO. 7A (FORENSIC REPORT PRODUCTION)This Order relates to all actions. Signed by Honorable J Michelle Childs on 3/26/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
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Filing 25
SCHEDULING ORDER PURSUANT TO CASE MANAGEMENT ORDER NO. 4 Consolidated Complaint due by 4/2/2021, Answer or Rule 12(b) Motion(s) on Jurisdiction, Standing, Forum Selection, or Other Procedural Grounds due by 5/3/2021, Plaintiffs' Opposition(s) due by 6/2/2021, Defendant's Reply due by 6/23/2021. Signed by Honorable J Michelle Childs on 3/26/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, )
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| Filing 24 TEXT ORDER: After reviewing the parties' proposals, the court selects the Honorable Gregory M. Sleet ("Judge Sleet") to serve as Mediator in this MDL. The parties shall submit a joint proposed order appointing Judge Sleet and detailing his duties by April 9, 2021. Signed by Honorable J Michelle Childs on 3/26/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 23 TEXT ORDER: After reviewing the parties' proposals, the court selects Maura R. Grossman ("Grossman") to serve as Special Master for Discovery. The parties shall submit a joint proposed order appointing Grossman and detailing her duties by April 9, 2021. Signed by Honorable J Michelle Childs on 3/26/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 22 NOTICE of Hearing: Status Conference set for 4/30/2021 10:00 AM - 12:00 PM in Columbia # 3, Matthew J. Perry Court House, 901 Richland St, Columbia before Honorable J Michelle Childs. Please see attached call-in instructions for counsel planning to participate by telephone. An invitation for counsel who wish to appear by video conference will be conducted at a later date. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 21 TEXT ORDER: The third case management conference on April 30, 2021 will take place in Courtroom 3. As Courtroom 3 can only accommodate twenty (20) people while maintaining social distancing, Plaintiffs and Defendant will be limited to six (6) in-person representatives each. Other attorneys who would like to participate in the conference may do so via video or phone. Defense Counsel and Plaintiffs' Liaison Counsel are asked to email a list of the attorneys who would like to participate by video to childs_ecf@scd.uscourts.gov by April 20, 2021. Attorneys who would like to participate by phone will find the conference call instructions attached to the hearing notice in the main docket (3:20-mn-02972-JMC). Signed by Honorable J Michelle Childs on 3/24/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 19 CASE MANAGEMENT ORDER NO. 7 (SUMMARY OF CASE MANAGEMENT CONFERENCE NO. 2). This Order relates to all actions. Signed by Honorable J Michelle Childs on 3/22/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 18 STIPULATED ORDER GOVERNING PRIVILEGE LOGS. This Order relates to all actions. Signed by Honorable J Michelle Childs on 3/15/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 17 TEXT ORDER: In preparation for the second case management conference, the court asks Plaintiffs' Lead Counsel and Defense Lead Counsel to each propose up to five (5) candidates to serve as Special Master for Discovery and/or Settlement in this MDL. Submissions should be emailed to childs_ecf@scd.uscourts.gov by Thursday, March 18, 2021 at 12:00 pm EST, list the candidate's contact information, and indicate whether the candidate is suited to serve as Discovery Special Master, Settlement Special Master, or both. Signed by Honorable J Michelle Childs on 3/15/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
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Filing 16
STIPULATION AND ORDER REGARDING THE DISCOVERY OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION. This Order relates to all actions. Signed by Honorable J Michelle Childs on 3/15/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, )
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| Filing 15 NOTICE OF HEARING: The Third Status Conference is set for April 30, 2021 10:00 AM - 12:00 PM in Columbia #3, Matthew J. Perry Court House, 901 Richland St, Columbia before Honorable J Michelle Childs. Call-in instructions and invitations for counsel who wish to appear by video conference will be provided at a later date. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 14 STIPULATED ORDER GOVERNING THE TAKING OF REMOTE DEPOSITIONS. This Order relates to all actions Signed by Honorable J Michelle Childs on 3/10/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 13 TEXT ORDER: Case Management Order No. 4 (ECF No. 23) requires the parties to submit their proposed Confidentiality Order, Initial ESI Protocol, Discovery Protocol, Document Production Formats, and Privilege Log Stipulation (collectively, "Proposed Governance Documents") to the court by March 9, 2021. This matter is before the court on the joint request of the parties to extend the deadline for submitting the Proposed Governance Documents to March 12, 2021. The court GRANTS the request and extends the deadline for submitting the Proposed Governance Documents to March 12, 2021. Signed by Honorable J Michelle Childs on 3/9/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 12 CASE MANAGEMENT ORDER NO. 6 (PROTOCOL FOR COMMON BENEFIT WORK AND EXPENSES) Signed by Honorable J Michelle Childs on 3/5/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 11 WAIVER OF SERVICE by Jessica Case, Rosalie Simkins, Kristiina Molnar. Blackbaud Inc waiver executed on 2/17/2021, answer due 4/19/2021. (Freeman Cappio, Gretchen) |
| Filing 10 NOTICE of Hearing: Status Conference set for 3/19/2021 10:00 AM in Columbia # 3, Matthew J. Perry Court House, 901 Richland St, Columbia before Honorable J Michelle Childs. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 9 TEXT ORDER: The second case management conference on March 19, 2021 will take place in Courtroom 3 instead of Courtroom 1. As Courtroom 3 can only accommodate twenty (20) people while maintaining social distancing, Plaintiffs and Defendants will be limited to six (6) in-person representatives each. Other attorneys who would like to participate in the conference may do so via video or phone. Defense counsel and Plaintiffs' Liaison Counsel are asked to email a list of the attorneys who would like to participate by video to childs_ecf@scd.uscourts.gov by March 9, 2021. Attorneys who would like to participate by phone will find the conference call instructions attached to the hearing notice in the main docket (3:20-mn-02972-JMC). Signed by Honorable J Michelle Childs on 2/22/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 8 NOTICE of Appearance by Celeste Tiller Jones on behalf of Blackbaud Inc (Jones, Celeste) |
| Filing 7 CASE MANAGEMENT ORDER NO. 5 (APPOINTMENT OF LEADERSHIP COUNSEL). This Order relates to all actions. Signed by Honorable J Michelle Childs on 2/16/2021. Associated Cases: 3:20-mn-02972-JMC et al.(asni, ) |
| Filing 6 TEXT ORDER granting #5 Motion to Appear Pro Hac Vice. Signed by Honorable J Michelle Childs on 2/16/2021.(asni, ) |
| Filing 5 MOTION to Appear Pro Hac Vice by Gretchen Freeman Cappio ( Filing fee $ 350 receipt number 0420-9646439) by Jessica Case, Kristiina Molnar, Rosalie Simkins. Response to Motion due by 2/26/2021. 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 Application/Affidavit for Pro Hac Vice Admission, #2 Proposed Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Freeman Cappio, Gretchen) (Additional attachment(s) added on 2/16/2021: #3 Supreme Court Certificate) (asni, ). |
| Filing 3 Local Rule 26.01 Answers to Interrogatories by Jessica Case, Kristiina Molnar, Rosalie Simkins.(asni, ) |
| Filing 2 Summons Issued as to Blackbaud Inc. (asni, ) |
| Filing 1 COMPLAINT against Blackbaud Inc ( Filing fee $ 402 receipt number 0420-9643994.), filed by Jessica Case, Rosalie Simkins, Kristiina Molnar. Service due by 5/11/2021 (Attachments: #1 Exhibit A Gmail, #2 Exhibit B Gmail)(asni, ) |
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