Bond v. Clover Health Investments, Corp. et al
| Timothy Bond, Prabhjot Ahluwalia, Lori Brennan and Firas Jabri |
| Clover Health Investments, Corp., Andrew Toy, Chamath Palihapitiya, Vivek Garipalli and Social Capital Hedosophia Holdings Corp. III |
| Dwight G. Metcalf, Andrew Trefanos, Nish Patel, Brigitta Edberg, Rolf Edberg, Jeong Yeon Rhee, Aaron Farzan, Alejandro Handal, Christopher Bunton, The Investor Group, Kenneth Ryan Meadows and Dr. Mit Desai |
| Brinal Kaul, Matthew Yaniv and Jean-Nicolas Tremblay |
| Joseph Wagner, Steven Trieu, Ian Osborne, Jacqueline D. Reses and James Ryans |
| 3:2021cv00096 |
| February 5, 2021 |
| US District Court for the Middle District of Tennessee |
| Alistair Newbern |
| Aleta A Trauger |
| Securities/Commodities |
| Plaintiff |
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Filing 132
ORDER: The Court will hold a settlement hearing on October 2, 2023, at 3:30 p.m. in Courtroom 6C of the Fred D. Thompson U.S. Courthouse and Federal Building, 719 Church Street, Nashville, TN 37203. Signed by District Judge Aleta A. Trauger on 05/26/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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| Filing 131 CERTIFICATE OF SERVICE by Firas Jabri, Jean-Nicolas Tremblay re #129 Memorandum in Support of Unopposed Motion for Preliminary Approval of Settlement (Calandra, Brian) |
| NOTICE TO FILER re DE#129 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include all Counsel on the certificate of service. Please FILE a CONFORMED CERTIFICATE OF SERVICE for this document. (ln) |
| Filing 130 DECLARATION of Brian Calandra filed by Firas Jabri, Jean-Nicolas Tremblay re: #128 Unopposed MOTION for Settlement re Preliminary Approval. (Attachments: #1 Exhibit 1 Stipulation of Settlement, #2 Exhibit 2 NERA excerpts, #3 Exhibit 3 Firm Resume)(Calandra, Brian) |
| Filing 129 MEMORANDUM in Support of #128 Unopposed MOTION for Settlement re Preliminary Approval filed by Firas Jabri, Jean-Nicolas Tremblay . (Calandra, Brian) |
| Filing 128 Unopposed MOTION for Settlement re Preliminary Approval by Firas Jabri, Jean-Nicolas Tremblay. (Calandra, Brian) |
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Filing 127
ORDER: The court has been notified that this case has settled. It is hereby ORDERED that a stipulation of dismissal or other settlement document shall be filed within thirty (30) days of the entry of this Order. The jury trial scheduled for November 12, 2024 and the pretrial conference scheduled forNovember 8, 2024 are CANCELLED. Signed by District Judge Aleta A. Trauger on 04/25/23. (ad)
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Filing 126
ORDER: The parties have notified the Court that they have reached a resolution of all claims in this matter. Accordingly, the discovery dispute hearing set on April 25, 2023, at 10:30 a.m. #122 is CANCELLED. The parties state that they will file a notice of their independent resolution of the case. Signed by Magistrate Judge Alistair Newbern on 4/24/2023. (kc)
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| Filing 125 NOTICE of Settlement (Joint) by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner (Latham, Britt) |
| Filing 124 NOTICE of Change of Address by Benjamin A. Gastel (Gastel, Benjamin) |
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Filing 123
ORDER: Judge Trauger has referred the numerous discovery disputes articulated in the parties' joint discovery dispute statement to the Magistrate Judge for disposition. #122 . A hearing by videoconference regarding the disputes is set on April 25, 2023, at 10:30 a.m. Signed by Magistrate Judge Alistair Newbern on 3/9/2023. (kc)
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Filing 122
ORDER: It is clear from the Joint Discovery Dispute Statement filed by the parties (Doc. No. #115 ) that the discovery disputes mentioned therein cannot be resolved in a telephone conference with Judge Trauger. It is therefore ORDERED that the discovery disputes reflected in the Joint Discovery Dispute Statement are hereby REFERRED to the Magistrate Judge for disposition. Signed by District Judge Aleta A. Trauger on 3/8/2023. (mg)
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Filing 121
ORDER RESETTING CASE FOR TRIAL: Jury Trial set for 11/12/2024 at 09:00 AM in Courtroom 6C before District Judge Aleta A. Trauger. Pretrial Conference set for 11/8/2024 at 01:30 PM in Chambers - Suite 6325 before District Judge Aleta A. Trauger. Exhibit List due by 10/29/2024. Witness List due by 10/29/2024. Joint Proposed Pretrial Order due by 10/29/2024. Signed by District Judge Aleta A. Trauger on 03/08/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 120
ORDER: Upon consideration of the #117 Joint Motion for Amendment to Initial Case Management Order, the motion is hereby GRANTED. The deadline to complete all written fact discovery and depose all fact witnesses from April 4, 2023, to July 31, 2023. The deadline to file all dispositive motions from September 29, 2023, to February 8, 2024. Signed by District Judge Aleta A. Trauger on 03/08/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 119
STIPULATED PROTECTIVE ORDER: Signed by District Judge Aleta A. Trauger on 03/08/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 118
ORDER granting #116 JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER. Signed by District Judge Aleta A. Trauger on 03/08/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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| Filing 117 Joint MOTION to Amend/Correct #97 Case Management Order, by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment Proposed Order)(Latham, Britt) |
| Filing 116 Joint MOTION for Protective Order - Motion for Entry of Stipulated Protective Order by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment Proposed Order)(Latham, Britt) |
| Filing 115 DISCOVERY DISPUTE STATEMENT by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Exhibit 1 - Plaintiffs' First Requests for Production, #2 Exhibit 2 - Clover's Response and Objections to First Requests for Production, #3 Exhibit 3 - Indiv. Defendants' Responses and Objections to First Requests for Production, #4 Exhibit 4 - January 11, 2023 Letter to Schwartz, #5 Exhibit 5 - January 30, 2023 Letter to Calandra, #6 Exhibit 6 - February 6, 2023 Letter to Schwartz, #7 Exhibit 7 - February 17, 2023 Letter to Calandra, #8 Exhibit 8 - February 21, 2023, #9 Exhibit 9 - Jabri Initial Disclosures, #10 Exhibit 10 - Tremblay Initial Disclosures, #11 Exhibit 11 - Clover, et al. Initial Disclosures, #12 Exhibit 12 - Clover, et al. First Requests for Production, #13 Exhibit 13 - August 1, 2022 Letter to Calandra)(Latham, Britt) |
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Filing 114
ORDER: For the reasons explained in the accompanying Memorandum, the plaintiffs' Motion for Class Certification (Doc. No. #101 ) is hereby GRANTED. The court hereby APPOINTS Firas Jabri and Nicholas Tremblay as class representatives and Pomerantz LLP as class counsel. The court CERTIFIES the following class pursuant to Fed. R. Civ. P. 23: (OPEN ORDER TO READ.) Signed by District Judge Aleta A. Trauger on 2/14/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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| Filing 113 MEMORANDUM. Signed by District Judge Aleta A. Trauger on 2/14/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln) |
| Filing 112 CERTIFICATE OF SERVICE by Firas Jabri, Jean-Nicolas Tremblay re #111 Declaration, (Calandra, Brian) |
| NOTICE TO FILER re DE#111 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include a certificate of service. Please FILE a CONFORMED CERTIFICATE OF SERVICE for this document. (ln) |
| Filing 111 DECLARATION of Brian Calandra filed by Firas Jabri, Jean-Nicolas Tremblay re: #110 Reply. (Attachments: #1 Exhibit 1 - Lead Plaintiff's Certification, #2 Exhibit 2 - Excerpts from August 30, 2022 Transcript, #3 Exhibit 3 - Excerpts from August 31, 2022 Transcript)(Calandra, Brian) |
| Filing 110 REPLY filed by Firas Jabri, Jean-Nicolas Tremblay re #108 Response in Opposition to #101 Motion filed by Joseph Wagner, Chamath Palihapitiya, Andrew Toy, Vivek Garipalli, Clover Health Investments, Corp. (Calandra, Brian) Modified on 11/1/2022 (ln). |
| Filing 109 DECLARATION of Gary A. Crosby II filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner re: #108 Response in Opposition to Motion. (Attachments: #1 Exhibit A - Tremblay deposition excerpts, #2 Exhibit B - Cain deposition excerpts, #3 Exhibit C - Jabri deposition excerpts, #4 Exhibit D - Tremblay's Questrade Account Statement, #5 Exhibit E - Jabri's Fidelity Investment Report, #6 Exhibit F - Tremblay's Summary of Purchases and Sales)(Crace, Joseph) |
| Filing 108 RESPONSE in Opposition re #101 MOTION to Certify Class filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Crace, Joseph) |
| Filing 107 NOTICE by Firas Jabri, Jean-Nicolas Tremblay Second Notice of Errata (Attachments: #1 Exhibit Corrected Report of Matthew Cain)(Bramlett, Paul) |
| Filing 106 NOTICE by Firas Jabri, Jean-Nicolas Tremblay re #102 Memorandum in Support Notice of Errata of Transaction Summary (Attachments: #1 Attachment Certification and Transaction Summary)(Bramlett, Paul) |
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Filing 105
ORDER ON MOTION FOR LIMITED AMENDMENT TO INITIAL CASE MANAGEMENT ORDER: Upon consideration of the Joint Motion for Limited Amendment to Initial Case Management Order, the motion #104 is hereby GRANTED. For good cause shown, it is hereby ORDERED that the Initial Case Management Order (Doc. #97 ) and subsequent Order (Doc. #100 ) be modified to extend: (i) Defendants' deadline to file their opposition to class certification from September 9, 2022, to September 30, 2022; and (ii) Plaintiffs' deadline to file a reply in further support of their motion for class certification from October 10, 2022, to October 31, 2022. Signed by District Judge Aleta A. Trauger on 8/25/2022. (ln)
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| Filing 104 Joint MOTION for Limited Amendment to Initial Case Management Order by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Proposed Order)(Latham, Britt) |
| Filing 103 DECLARATION of Brian Calandra filed by Firas Jabri, Jean-Nicolas Tremblay re: #102 Memorandum in Support, #101 MOTION to Certify Class . (Attachments: #1 Exhibit A - Declaration of Firas Jabri, #2 Exhibit B - Expert Report of Matthew D. Cain, #3 Exhibit C - Pomerantz Resume)(Calandra, Brian) |
| Filing 102 MEMORANDUM in Support of #101 MOTION to Certify Class filed by Firas Jabri, Jean-Nicolas Tremblay . (Calandra, Brian) |
| Filing 101 MOTION to Certify Class by Firas Jabri, Jean-Nicolas Tremblay. (Attachments: #1 Attachment Proposed Order)(Calandra, Brian) |
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Filing 100
ORDER ON MOTION FOR LIMITED AMENDMENT TO INITIAL CASE MANAGEMENT ORDER: Upon consideration of the Joint Motion #99 for Limited Amendment to Initial Case Management Order, the motion is hereby GRANTED. For good cause shown, it is hereby ORDERED that the Initial Case Management Order (Doc. #97 ) be modified to extend (i) Plaintiffs' deadline to file their motion for class certification from June 17, 2022 to July 1, 2022, (ii) extend Defendants deadline to file their opposition to class certification from August 19, 2022 to September 9, 2022, and (iii) Plaintiffs' deadline to file a reply in further support of their motion for class certification from September 19, 2022 to October 10, 2022. Signed by District Judge Aleta A. Trauger on 6/3/2022. (ln)
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| Filing 99 Joint MOTION for Limited Amendment to Initial Case Management Order by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Proposed Order)(Latham, Britt) |
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Filing 98
ORDER SETTING CASE FOR TRIAL: Jury Trial is set for 3/26/2024 at 9:00 AM in Courtroom 6C of the United States Courthouse, 719 Church Street, Nashville, Tennessee, before District Judge Aleta A. Trauger. Pretrial Conference is set for 3/22/2024 at 1:30 PM in chambers, Suite #6325 United States Courthouse, 719 Church Street, Nashville, Tennessee before District Judge Aleta A. Trauger. Proposed Pretrial Order due by 3/19/2024. Exhibit List due by 3/19/2024. Witness List due by 3/19/2024. Signed by District Judge Aleta A. Trauger on 4/19/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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Filing 97
INITIAL CASE MANAGEMENT ORDER: Discovery due by 4/4/2023. Dispositive Motions due by 9/29/2023. Signed by District Judge Aleta A. Trauger on 4/18/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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| Minute Entry for proceedings held before District Judge Aleta A. Trauger: Initial Case Management Conference held on 4/18/2022. (Hearing lasted :20) (ds) |
| Filing 96 PROPOSED CASE MANAGEMENT ORDER filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Latham, Britt) |
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Filing 95
ORDER: It is hereby ORDERED that the initial case management conference scheduled for Monday, April 18, 2022 at 1:30 p.m. will be held in Judge Trauger's courtroom. Lead counsel for each party shall participate in the conference. All participants will be masked and socially distanced during the conference. Signed by District Judge Aleta A. Trauger on 4/12/2022. (ln)
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| Filing 94 ANSWER to #70 Amended Complaint by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner.(Latham, Britt) |
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Filing 93
ORDER granting #92 : Having satisfied the requirements of Local Rule 83.01(b), the Motion for Gary A. Crosby II to Appear Pro Hac Vice is granted. Signed by Lynda Hill, Clerk of Court, on 03/23/2022. (lh)
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| NY State Bar status verified as active for Gary Anthony Crosby, II not admitted to this court - Local counsel secured. (ln) |
| Filing 92 MOTION for attorney Gary A. Crosby II to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3559372) by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Declaration of Gary A. Crosby II, #2 Attachment - Certificate of Good Standing, #3 Attachment - Proposed Order)(Latham, Britt) |
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Filing 91
ORDER ON MOTION FOR EXTENSION OF TIME: Upon consideration of Defendants' Motion for Extension of Time to File the Answer to Plaintiffs' First Amended Complaint for Violations of the Federal Securities Laws ("FAC"), the motion #90 is hereby GRANTED. For good cause shown, it is hereby ORDERED that Defendants may file their responsive pleading to the FAC by no later than April 11, 2022. It is further ORDERED that the initial case management conference is RESET for April 18, 2022 at 1:30 p.m. Signed by District Judge Aleta A. Trauger on 3/11/2022. (ln)
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| Reset Hearing: The Initial Case Management Conference is reset for 4/18/2022 at 1:30 PM in Chambers 825 before District Judge Aleta A. Trauger. (ln) |
| Filing 90 Unopposed MOTION for Extension of Time to File Answer re #70 Amended Complaint by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment Proposed Order)(Latham, Britt) |
| TN State Bar status verified as active for Joseph B. Crace, Jr admitted to this court. (ln) |
| Filing 89 NOTICE of Appearance by Joseph B. Crace, Jr on behalf of Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner (Crace, Joseph) |
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Filing 88
ORDER: For the reasons explained in the accompanying Memorandum, the defendants' Motion to Dismiss (Doc. No. #74 ) is hereby DENIED. The initial case management conference is RESET for March 30, 2022 at 2:00 p.m. Signed by District Judge Aleta A. Trauger on 2/28/2022. (ln)
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| Filing 87 MEMORANDUM. Signed by District Judge Aleta A. Trauger on 2/28/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln) |
| Filing 86 NOTICE by Dr. Mit Desai, Kenneth Ryan Meadows, Matthew Yaniv Notice of Withdrawal (Wood, Christopher) |
| Filing 85 NOTICE of Voluntary Dismissal by Matthew Yaniv (Wood, Christopher) |
| Filing 84 DECLARATION of Jed M. Schwartz filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Exhibit A - Excerpts of Transcript of Clover "Analyst Day Presentation" dated November 20, 2020)(Latham, Britt) |
| Filing 83 REPLY to Response to re #74 MOTION to Dismiss the First Amended Complaint filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Latham, Britt) |
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Filing 82
ORDER ON DEFENDANTS' MOTION TO EXCEED PAGE LIMITS: Upon consideration of Defendants' Motion #81 to Exceed Page Limits, the motion is hereby GRANTED. It is hereby ORDERED that Defendants may file a Reply Memorandum in Support of the Motion to Dismiss of up to but not to exceed twenty-five (25) pages. Signed by District Judge Aleta A. Trauger on 12/14/2021. (ln)
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| Filing 81 MOTION for Leave to File Excess Pages for Defendants' Reply Brief by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment Proposed Order)(Latham, Britt) |
| Filing 80 RESPONSE in Opposition re #74 MOTION to Dismiss the First Amended Complaint Corrects Signature Line on #79 filed 11.2.21 filed by Firas Jabri, Jean-Nicolas Tremblay. (Bramlett, Paul) |
| NOTICE TO FILER re DE#79 : The filing made at DE #79 is DISREGARDED. Counsel who signed this pleading shall re-file this document using his or her own CM/ECF filing credentials. (ln) |
| Filing 79 ***DISREGARD. FILED IN ERROR. ATTORNEY TO RE-FILE.*** RESPONSE in Opposition re #74 MOTION to Dismiss the First Amended Complaint filed by Firas Jabri, Jean-Nicolas Tremblay. (Bramlett, Paul) Modified on 11/3/2021 (ln). |
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Filing 78
ORDER ON PLAINTIFFS' MOTION FOR EXTENSION OF DEADLINES FOR PLAINTIFFS' OPPOSITION TO AND DEFENDANTS' REPLY IN FURTHER SUPPORT OF DEFENDANTS' MOTION TO DISMISS: Upon consideration of Plaintiffs' Motion #77 for Extension of Deadlines For Plaintiffs' Opposition to and Defendants' Reply In Further Support of Defendants' Motion to Dismiss, the motion is hereby GRANTED. The parties having agreed to the following, it is ORDERED that: Plaintiffs' opposition to Defendants' motion to dismiss Plaintiffs' amended complaint is due November 2, 2021. Defendants' reply in further support of their motion to dismiss Plaintiffs' amended complaint is due December 17, 2021. Signed by District Judge Aleta A. Trauger on 10/20/2021. (ln)
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| Filing 77 Consent MOTION for Extension of Time to File Response/Reply as to #74 MOTION to Dismiss the First Amended Complaint and to amend DE #65 by Timothy Bond. (Attachments: #1 Attachment Proposed Order)(Bramlett, Paul) |
| Filing 76 DECLARATION of Gary A. Crosby II filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner re: #74 MOTION to Dismiss the First Amended Complaint. (Attachments: #1 Exhibit A - Notice (U.S. ex rel. Cutler v. Cigna), #2 Exhibit B - Memorandum (U.S. ex rel. SMSF, LLC v. Biogen), #3 Exhibit C - Excerpts from Clover Final Prospectus filed January 29, 2021, #4 Exhibit D - Excerpts from Clover Form S-4 filed October 20, 2020, #5 Exhibit E - Excerpts from Clover Form 8-K filed March 1, 2021, #6 Exhibit F - Excerpts from SCH Prospectus filed December 14, 2020, #7 Exhibit G - Clover press release filed January 12, 2021, #8 Exhibit H - Hindenburg Report, #9 Exhibit I - Clover's response to Hindenburg Report, #10 Exhibit J - Excerpts from Agreement and Plan of Merger filed October 6, 2020, #11 Exhibit K - Excerpts from SCH Schedule 14A filed December 14, 2020, #12 Exhibit L - Excerpts from Clover Form S-1 filed January 13, 2021, #13 Exhibit M - Excerpts from Clover "Analyst Presentation", #14 Exhibit N - Excerpts from Medicare Communications Marketing Guidelines, #15 Exhibit O - Excerpts from Financial Accounting Standards Board's Accounting Standards Codification 850, #16 Exhibit P - Excerpts of transcript of Clover "Analyst Day Presentation")(Latham, Britt) |
| Filing 75 MEMORANDUM in Support of #74 MOTION to Dismiss the First Amended Complaint filed by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner . (Attachments: #1 Attachment - Appendix - Defendants' Summary of Alleged Misstatements)(Latham, Britt) |
| Filing 74 MOTION to Dismiss the First Amended Complaint by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Latham, Britt) |
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Filing 73
ORDER granting #72 Motion for Leave to File Excess Pages. Signed by District Judge Aleta A. Trauger on 8/19/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(mg)
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| Filing 72 Joint MOTION for Leave to File Excess Pages for Motion to Dismiss Briefing by Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Proposed Order)(Latham, Britt) |
| Filing 71 WAIVER OF SERVICE Returned Executed by Firas Jabri, Jean-Nicolas Tremblay. Chamath Palihapitiya waiver sent on 7/8/2021. (Bramlett, Paul) |
| TN State Bar status verified as active for Paul Kent Bramlett and Robert P. Bramlett admitted to this court. (ln) |
| Filing 70 AMENDED COMPLAINT against All Defendants, filed by Firas Jabri, Jean-Nicolas Tremblay.(Bramlett, Paul) |
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Filing 69
ORDER granting #66 and #67 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Brian Schall and Brian Peter Calandra to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 05/07/2021. (lh)
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| Filing 68 MOTION to Amend/Correct #67 MOTION for attorney Brian Peter Calandra to Appear Pro Hac Vice on Behalf of Lead Plaintiff (paid $150 PHV fee; receipt number 0650-3366467), #66 MOTION for attorney BRIAN SCHALL to Appear Pro Hac Vice on Behalf of Lead Plaintiff (paid $150 PHV fee; receipt number 0650-3366466) by Firas Jabri. (Attachments: #1 Exhibit A-Corrected Certificate of Good Standing)(Bramlett, Paul) |
| CA State Bar status verified as active for Brian J. Schall not admitted to this court - Local counsel secured. (ln) |
| NY State Bar status verified as active for Brian Peter Calandra not admitted to this court - Local counsel secured. (ln) |
| NOTICE TO FILER re DE#67 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not sign the certificate of service. Please FILE a conformed Certificate of Service for this document. (ln) |
| NOTICE TO FILER re DE#66 : The Certificate of Good Standing must be from a United States District Court or a United States appellate court. The new certificate shall be filed within 10 days. (ln) |
| NOTICE TO FILER re DE#66 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not sign the certificate of service. Please FILE a conformed Certificate of Service for this document. (ln) |
| Filing 67 MOTION for attorney Brian Peter Calandra to Appear Pro Hac Vice on Behalf of Lead Plaintiff (paid $150 PHV fee; receipt number 0650-3366467) by Firas Jabri. (Attachments: #1 Exhibit A-Certificate of Good Standing)(Bramlett, Paul) |
| Filing 66 MOTION for attorney BRIAN SCHALL to Appear Pro Hac Vice on Behalf of Lead Plaintiff (paid $150 PHV fee; receipt number 0650-3366466) by Firas Jabri. (Attachments: #1 Exhibit A-Certificate of Good Standing)(Bramlett, Paul) |
| Filing 65 BRIEFING SCHEDULE. Signed by District Judge Aleta A. Trauger on 4/29/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln) |
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Filing 64
ORDER: Motion (DE #63 ) for Entry of Proposed Briefing Schedule GRANTED. Signed by District Judge Aleta A. Trauger on 04/29/2021. (ln)
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| Filing 63 Joint MOTION for Entry of Proposed Briefing Schedule by Clover Health Investments, Corp., Vivek Garipalli, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Proposed Order)(Latham, Britt) |
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Filing 62
ORDER granting #59 and #60 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Jed M. Schwartz and Scott A. Edelman to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 04/28/2021. (lh)
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| NY State Bar status verified as active for Jed M. Schwartz and Scott Alexander Edelman not admitted to this court - Local counsel secured . (ln) |
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Filing 61
ORDER: It is hereby ORDERED that the initial case management conference scheduled in these consolidated cases for May 3, 2021 is CONTINUED, to be reset by later order of the court. Signed by District Judge Aleta A. Trauger on 4/26/2021. (ln)
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| Filing 60 MOTION for attorney Scott A. Edelman to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3359609) by Clover Health Investments, Corp., Vivek Garipalli, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Declaration of Scott A. Edelman, #2 Attachment - Certificate of Good Standing, #3 Attachment - Proposed Order)(Latham, Britt) |
| Filing 59 MOTION for attorney Jed M. Schwartz to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3359594) by Clover Health Investments, Corp., Vivek Garipalli, Andrew Toy, Joseph Wagner. (Attachments: #1 Attachment - Declaration of Jed M. Schwartz, #2 Attachment - Certificate of Good Standing, #3 Attachment - Proposed Order)(Latham, Britt) |
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Filing 58
MEMORANDUM & ORDER: Jabri's Motion to Consolidate the Related Actions, Appoint Lead Plaintiff, and Approve Lead Plaintiff's Selection of Counsel (Doc. No. #40 ) is hereby GRANTED and Firas Jabri is APPOINTED Lead Plaintiff for this matter. Pomerantz is APPROVED as Lead Counsel, and Bramlett Law Firm is APPROVED as Liaison Counsel. Insofar as any of the listed motions' requests for consolidation are construed as still pending, those requests are hereby DENIED as moot, consolidation having already occurred. Signed by District Judge Aleta A. Trauger on 4/23/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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| Filing 57 NOTICE of Voluntary Dismissal by Brinal Kaul (Bramlett, Paul) |
| Filing 56 RESPONSE in Opposition to #19 Motion to Consolidate Cases, Competing Lead Plaintiff Motions, and for Appointment of Lead Plaintiff and Approval of Lead Plaintiff's Selection of Lead Counsel filed by Dr. Mit Desai and Kenneth Ryan Meadows. (Wood, Christopher) Modified on 4/22/2021 (ds). |
| Filing 55 MEMORANDUM OF LAW in Further Support of #40 Motion to Consolidate Cases filed by Firas Jabri. (Attachments: #1 Attachment Declaration of Jeremy Lieberman, #2 Exhibit A-Schedule of transactions filed by Levi & Korsinsky in iRhythm litigation, #3 Exhibit B-Schedule of transactions filed by Levi & Korsinsky in EHang litigation, #4 Exhibit C-Schedule of transactions filed by Levi & Korsinsky in Astrazeneca litigation, #5 Exhibit D-Schedule of transactions filed by Levi & Korsinsky in Tricida litigation, #6 Exhibit E-Schedule of transactions filed by Levi & Korsinsky in QuantumScape litigation)(Bramlett, Paul) Modified on 4/22/2021 (ds). |
| Filing 54 SUPPLEMENTAL DECLARATION of Jeffrey C. Block filed by Christopher Bunton re: #28 MOTION to Consolidate Cases , Appointment as Lead Plaintiff, and Approval of Selection of Lead Counsel, #53 Memorandum in Support. (Attachments: #1 Exhibit A - Fee & Co-Counsel Agreement)(Stranch, James) |
| Filing 53 MEMORANDUM in Further Support of #28 MOTION to Consolidate Cases , Appointment as Lead Plaintiff, and Approval of Selection of Lead Counsel and in Opposition to Competing Motions filed by Christopher Bunton. (Stranch, James) |
| Filing 52 NOTICE by Aaron Farzan, Alejandro Handal of Non-Opposition to Competing Motions for Consolidation and Appointment (Swafford, Tara) |
| Filing 51 NOTICE by The Investor Group of Non-Opposition to Competing Lead Plaintiff Motions (Barrett, Charles) |
| Filing 50 NOTICE by Dwight G. Metcalf re #19 MOTION to Consolidate Cases MOTION to Appoint Counsel and for Appointment as Lead Plaintiff . Notice of Non-Opposition of Dwight G. Metcalf to Competing Motions for Consolidation, Appointment as Lead Plaintiff and Approval of Selection of Counsel. (Spragens, John) |
| Filing 49 NOTICE by Brigitta Edberg, Rolf Edberg, Nish Patel, Jeong Yeon Rhee, Andrew Trefanos of Non-Opposition to the Competing Motions for Consolidation of Actions, Appointment as Lead Plaintiff, and Approval of Selection of Counsel (Belz, Saul) |
| Filing 48 NOTICE by Prabhjot Ahluwalia of Non-Opposition to the Competing Motions for Appointment as Lead Plaintiff and Approval of Selection of Counsel (Belk, Larry) |
| Filing 47 NOTICE by Lori Brennan of Non-Opposition to the Competing Motions for Consolidation, Appointment of Lead Plaintiff, and Approval of Selection of Counsel (Holifield, James) |
| TN State Bar status verified as active for Britt K. Latham admitted to this court. (ln) |
| Filing 46 CERTIFICATE Amended Certificate of Service filed by Clover Health Investments, Corp., Vivek Garipalli, Andrew Toy, Joseph Wagner. (Latham, Britt) |
| Filing 45 BUSINESS ENTITY DISCLOSURE STATEMENT filed by Clover Health Investments, Corp.. (Latham, Britt) |
| Filing 44 NOTICE of Appearance by Britt K. Latham on behalf of Clover Health Investments, Corp., Vivek Garipalli, Andrew Toy, Joseph Wagner (Latham, Britt) |
| Filing 43 CERTIFICATE OF SERVICE by Prabhjot Ahluwalia re #17 Declaration, #16 Memorandum in Support, #15 MOTION to Consolidate Cases MOTION to Appoint Counsel (Belk, Larry) |
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Filing 42
ORDER CONSOLIDATING RELATED CASES: Pursuant to Rule 42(a) of the Federal Rules of Civil Procedures, Bond v. Clover Health Investments, Corp. et al, No. 3:21-cv-00096, Kaul v. Clover Health Investments, Corp. et al., No. 3:21-cv-00101, Yaniv v. Clover Health Investments, Corp. et al., No. 3:21-cv-00109, and Tremblay v. Clover Health Investments, Corp. et al., No. 3:21-cv-00138 are consolidated for all purposes. CASE NO. 3:21-cv-96 SHALL BE THE LEAD CASE, AND ALL FILINGS SHALL BE MADE UNDER THAT CASE NUMBER. Signed by District Judge Aleta A. Trauger on 4/8/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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| NOTICE TO FILER re DE#15 , #16 , #17 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include all Counsel on the certificate of service. Please FILE a conformed Certificate of Service for this document. (ln) |
| TN State Bar status verified as active for John Tate Spragens admitted to this court. (ln) |
| Filing 41 MEMORANDUM in Support of #40 MOTION to Consolidate Cases and Appoint Lead Plaintiff and Lead and Liaison Counsel filed by Firas Jabri Intervenor Plaintiff. (Attachments: #1 Attachment Lieberman Declaration, #2 Exhibit A-PSLRA Notice, #3 Exhibit B-Plaintiff's Certification, #4 Exhibit C-Damages Analysis, #5 Exhibit D-Plaintiff's Declaration, #6 Exhibit E-Pomerantz Resume, #7 Exhibit F-Bramlett resume, #8 Attachment Certificate of Service)(Bramlett, Paul) |
| Filing 40 MOTION to Consolidate Cases and Appoint Lead Plaintiff and Lead and Liaison Counsel by Firas Jabri. (Attachments: #1 Attachment Certificate of Service, #2 Attachment Proposed Order)(Bramlett, Paul) |
| Filing 39 DECLARATION of Christopher M. Wood in Support filed by Dr. Mit Desai, Kenneth Ryan Meadows re: #37 MOTION to Consolidate Cases , for Appointment as Lead Plaintiff MOTION to Appoint Counsel . (Attachments: #1 Exhibit A - PSLRA Notice, #2 Exhibit B - Certifications, #3 Exhibit C - Estimate of losses, #4 Exhibit D - Joint Declaration in Support)(Wood, Christopher) |
| Filing 38 MEMORANDUM in Support of #37 MOTION to Consolidate Cases , for Appointment as Lead Plaintiff MOTION to Appoint Counsel filed by Dr. Mit Desai, Kenneth Ryan Meadows . (Wood, Christopher) |
| Filing 37 MOTION to Consolidate Cases , for Appointment as Lead Plaintiff, MOTION to Appoint Counsel by Kenneth Ryan Meadows, Dr. Mit Desai. (Attachments: #1 Attachment Text of Proposed Order)(Wood, Christopher) |
| Filing 36 DECLARATION of Charles F. Barrett filed by The Investor Group re: #34 MOTION to Consolidate Cases and Appoint as Lead Plaintiff MOTION to Appoint Counsel . (Attachments: #1 Exhibit A - Notice of Pendency of Action, #2 Exhibit B - The Investor Group members' PSLRA Certifications, #3 Exhibit C - Joint Declaration in Support of the Motion of the Investor Group for Appointment as Lead Plaintiff, and Approval of Selection of Counsel, #4 Exhibit D - Firm Resume of Faruqi & Faruqi, LLP, #5 Exhibit E - Certificate from Women's Business Enterprise National Council, #6 Exhibit F - Firm Resume of Neal & Harwell, PLC)(Barrett, Charles) |
| Filing 35 MEMORANDUM in Support of #34 MOTION to Consolidate Cases and Appoint as Lead Plaintiff MOTION to Appoint Counsel filed by The Investor Group . (Barrett, Charles) |
| Filing 34 MOTION to Consolidate Cases and Appoint as Lead Plaintiff, MOTION to Appoint Counsel by The Investor Group. (Attachments: #1 Attachment Proposed Order)(Barrett, Charles) |
| Filing 33 Additional Attachments (Proposed Order Granting Motion of Aaron Farzan and Alejandro Handal) to Main Document re: #27 MOTION to Consolidate Cases , Appoint as Lead Plaintiff, Approve Counsel. (Swafford, Tara) |
| Filing 32 DECLARATION of Jeffrey C. Block filed by Christopher Bunton re: #28 MOTION to Consolidate Cases , Appointment as Lead Plaintiff, and Approval of Selection of Lead Counsel. (Attachments: #1 Exhibit A - Rosen PSLRA Notice, #2 Exhibit B - Bunton LP Cert. (signed), #3 Exhibit C - Clover Loss Chart, #4 Exhibit D - Bunton LP Decl. (signed), #5 Exhibit E - Block Leviton Resume, #6 Exhibit F - BSJ Firm Resume)(Stranch, James) |
| Filing 31 NOTICE of Filing Declaration of Pavithra Rajesh by Aaron Farzan, Alejandro Handal re #27 MOTION to Consolidate Cases , Appoint as Lead Plaintiff, Approve Counsel (Attachments: #1 Attachment Rajesh Declaration, #2 Exhibit A - Press Release, #3 Exhibit B - PSLRA Certification, #4 Exhibit C - Table of Losses, #5 Exhibit D - Firm Resume)(Swafford, Tara) |
| Filing 30 DECLARATION of Melissa A. Fortunato filed by Brigitta Edberg, Rolf Edberg, Nish Patel, Jeong Yeon Rhee, Andrew Trefanos re: #25 MOTION to Consolidate Cases Appointment as Lead Plaintiff and Approval of Selection of Counsel. (Attachments: #1 Exhibit Signed Certifications, #2 Exhibit Loss Chart, #3 Exhibit Signed Joint Declaration, #4 Exhibit Rosen PSLRA Notice, #5 Exhibit Firm Resume, #6 Exhibit Glankler Brown Firm Resume)(Belz, Saul) |
| Filing 29 MEMORANDUM in Support of #28 MOTION to Consolidate Cases , Appointment as Lead Plaintiff, and Approval of Selection of Lead Counsel filed by Christopher Bunton . (Stranch, James) |
| Filing 28 MOTION to Consolidate Cases , Appointment as Lead Plaintiff, and Approval of Selection of Lead Counsel by Christopher Bunton. (Attachments: #1 Attachment Proposed Order)(Stranch, James) |
| Filing 27 MOTION to Consolidate Cases , Appoint as Lead Plaintiff, Approve Counsel by Aaron Farzan, Alejandro Handal. (Attachments: #1 Attachment Memorandum in Support)(Swafford, Tara) |
| Filing 26 MEMORANDUM in Support of #25 MOTION to Consolidate Cases Appointment as Lead Plaintiff and Approval of Selection of Counsel filed by Brigitta Edberg, Rolf Edberg, Nish Patel, Jeong Yeon Rhee, Andrew Trefanos . (Belz, Saul) |
| Filing 25 MOTION to Consolidate Cases Appointment as Lead Plaintiff and Approval of Selection of Counsel by Andrew Trefanos, Nish Patel, Brigitta Edberg, Rolf Edberg, Jeong Yeon Rhee. (Attachments: #1 Attachment Proposed Order)(Belz, Saul) |
| Filing 24 DECLARATION OF AL HOLIFIELD IN SUPPORT OF LORI BRENNAN'S #22 MOTION TO CONSOLIDATE RELATED ACTIONS AND FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF COUNSEL filed by Lori Brennan. (Attachments: #1 Exhibit PSLRA Notice, #2 Exhibit PSLRA Certfication, #3 Exhibit Loss Chart, #4 Exhibit BL Firm Resume, #5 Exhibit Holifield Firm Resume)(Holifield, James) Modified on 4/9/2021 (ln). |
| Filing 23 MEMORANDUM OF LAW IN SUPPORT OF LORI BRENNAN'S #22 MOTION TO CONSOLIDATE RELATED ACTIONS AND FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF COUNSEL filed by Lori Brennan . (Holifield, James) Modified on 4/9/2021 (ln). |
| Filing 22 MOTION TO CONSOLIDATE RELATED ACTIONS AND FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF COUNSEL by Lori Brennan. (Attachments: #1 Exhibit Declaration, #2 Exhibit PLSRA Notice, #3 Exhibit PLSRA Certification, #4 Exhibit Loss Chart, #5 Exhibit Firm Resume, #6 Exhibit Holified Firm Resume, #7 Attachment Memorandum of Law, #8 Attachment Proposed Order)(Holifield, James) Modified on 4/9/2021 (ln). |
| Filing 21 DECLARATION of John Spragens filed by Dwight G. Metcalf re: #19 MOTION to Consolidate Cases MOTION to Appoint Counsel and for Appointment as Lead Plaintiff. (Attachments: #1 Exhibit A - Certification, #2 Exhibit B - Loss Analysis, #3 Exhibit C - Notice of Kaul Action, #4 Exhibit D - Notice of Bond Action, #5 Exhibit E - Mr. Metcalf Declaration, #6 Exhibit F - Labaton Sucharow Firm Resume)(Spragens, John) |
| Filing 20 MEMORANDUM in Support of #19 MOTION to Consolidate Cases MOTION to Appoint Counsel and for Appointment as Lead Plaintiff filed by Dwight G. Metcalf . (Spragens, John) |
| Filing 19 MOTION to Consolidate Cases , MOTION to Appoint Counsel and for Appointment as Lead Plaintiff by Dwight G. Metcalf. (Attachments: #1 Attachment Proposed Order)(Spragens, John) |
| Filing 18 NOTICE of Appearance by John Tate Spragens on behalf of Dwight G. Metcalf (Spragens, John) |
| Filing 17 DECLARATION of Lucas E. Gilmore filed by Prabhjot Ahluwalia re: #15 MOTION to Consolidate Cases MOTION to Appoint Counsel . (Attachments: #1 Exhibit A - Movant's Certification, #2 Exhibit B - Loss Chart, #3 Exhibit C - Notice of Pendency, #4 Exhibit D - Movant's Declaration, #5 Exhibit E - Hagens Berman Resume)(Belk, Larry) |
| Filing 16 MEMORANDUM in Support of #15 MOTION to Consolidate Cases MOTION to Appoint Counsel filed by Prabhjot Ahluwalia . (Belk, Larry) |
| Filing 15 MOTION to Consolidate Cases , MOTION to Appoint Counsel by Prabhjot Ahluwalia. (Attachments: #1 Attachment Proposed Order)(Belk, Larry) |
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Filing 14
STIPULATION AND ORDER REGARDING SERVICE OF COMPLAINT AND TIME TO RESPOND TO COMPLAINT. Signed by District Judge Aleta A. Trauger on 3/30/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ln)
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| Filing 13 STIPULATION AND PROPOSED ORDER REGARDING SERVICE OF COMPLAINT AND TIME TO RESPOND TO COMPLAINT by Timothy Bond. (Stranch, James) |
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Filing 12
ORDER granting #8 : Having satisfied the requirements of Local Rule 83.01(b), the Motion to Appear Pro Hac Vice of Stephen J. Teti is granted. Signed by Vicki Kinkade, Chief Deputy Clerk, on 2/19/21. (vk)
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Filing 11
ORDER granting #7 : Having satisfied the requirements of Local Rule 83.01(b), the Motion to Appear Pro Hac Vice of Jacob A. Walker is granted. Signed by Vicki Kinkade, Chief Deputy Clerk, on 2/19/21. (vk)
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Filing 10
ORDER granting #6 : Having satisfied the requirements of Local Rule 83.01(b), the Motion to Appear Pro Hac Vice of Jeffrey C. Block is granted. Signed by Vicki Kinkade, Chief Deputy Clerk, on 2/19/21. (vk)
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| Filing 9 SUMMONS returned executed by Timothy Bond. Clover Health Investments, Corp. served on 2/12/2021. (Gastel, Benjamin) |
| MA State Bar status verified as active for Jeffrey C. Block, Jacob A. Walker, and Stephen J. Teti not admitted to this court - Local counsel secured. (ln) |
| Filing 8 MOTION for attorney Stephen J. Teti to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3313163) by Timothy Bond. (Attachments: #1 Attachment Certificate of Good Standing)(Gastel, Benjamin) |
| Filing 7 MOTION for attorney Jacob A. Walker to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3313162) by Timothy Bond. (Attachments: #1 Attachment Certificate of Good Standing)(Gastel, Benjamin) |
| Filing 6 MOTION for attorney Jeffrey C. Block to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3313161) by Timothy Bond. (Attachments: #1 Attachment Certificate of Good Standing)(Gastel, Benjamin) |
| Filing 5 Summons issued as to Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, and Andrew Toy. Service copies will be returned to counsel (J. Gerard Stranch, IV) by mail. (ln) |
| Filing 4 NOTICE of Initial Case Management Conference set for 5/3/2021 at 1:30 PM in Chambers 825 before District Judge Aleta A. Trauger. (ln) |
| Filing 3 NOTICE of Business Entity Disclosure Statement filing requirement. (ln) |
| Filing 2 NOTICE/INFORMATION regarding Consent of the Parties to the Magistrate Judge. (ln) |
| TN State Bar status verified as active for James Gerard Stranch, IV and Benjamin A. Gastel admitted to this court. (ln) |
| NOTICE TO COUNSEL Jeffrey C. Block, Jacob A. Walker, and Stephen J. Teti: WITHIN 21 DAYS, counsel shall file a Motion to Appear Pro Hac Vice, a Certificate of Good Standing signed by the Clerk of a United States District Court or a U. S. appellate court where admitted, and pay a fee of $150.00 (LR 83.01(b)). PHV due by 3/1/2021. (ln) |
| Filing 1 COMPLAINT against Clover Health Investments, Corp., Vivek Garipalli, Chamath Palihapitiya, and Andrew Toy (Filing fee $402, Receipt number 0650-3309173) filed by Timothy Bond. (Attachments: #1 Attachment 1 - Plaintiff's Certification, #2 Attachment 2 - Civil Cover Sheet).(ln) |
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