VRC Companies, LLC v Rodriguez
Plaintiff: VRC Companies, LLC doing business as Vital Records Control, Inc.
Defendant: Carlos Rodriguez doing business as Medical Records Made Easy and MRME LLC
Case Number: 2:2022cv02461
Filed: July 15, 2022
Court: US District Court for the Western District of Tennessee
Presiding Judge: Samuel H Mays
Referring Judge: Mark S Norris
2 Judge: Tu M Pham
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332 Diversity-Breach of Contract
Jury Demanded By: None
Docket Report

This docket was last retrieved on February 22, 2023. A more recent docket listing may be available from PACER.

Date Filed Document Text
February 22, 2023 Filing 53 JUDGMENT. Signed by Judge Mark S. Norris on 2/22/23. (Norris, Mark)
February 14, 2023 Filing 52 NOTICE of Change of Address by Daniel Caden Crowell & Notice of Change of Firm Name (Crowell, Daniel)
February 3, 2023 Opinion or Order Filing 51 ORDER of USCA as to #46 Notice of Interlocutory Appeal filed by MRME LLC, Carlos Rodriguez. ORDER filed granting stipulation to dismiss case - mediation #21 filed by Ms. Lisa A. Krupicka. Entered by order of the court. (jae)
February 3, 2023 Filing 50 STIPULATION for Entry of Final Judgment by VRC Companies, LLC. (Attachments: #1 Exhibit Proposed Agreed Final Judgment of Permanent Injunction)(Krupicka, Lisa)
November 25, 2022 Filing 49 NOTICE of Change of Address by Daniel Caden Crowell (Crowell, Daniel)
November 21, 2022 Filing 48 TRANSCRIPT RELEASE NOTICE: By Administrative Order 2008-35 the United States District Court for the Western District of Tennessee implemented a policy regarding remote access to electronic transcripts. Pursuant to that policy, as well as Civil Rule 5.2 and Criminal Rule 49.1, each party's attorney is required to review a transcript for information that should be redacted pursuant to the Judicial Conference's privacy policy which requires that Social Security numbers be redacted to show only the last four digits; birth dates should contain only the year of birth; individuals known to be minors should be referred to with initials; and financial account numbers should be redacted to the last four digits. Additionally, in criminal case files, home addresses should reveal only the city and state of residence.Our records indicate that the 90-day restriction on public access to an electronic transcript(s) in this matter will lapse within 10 days. If a redaction request is required but has not been filed, please do so immediately. Please feel free to contact our office for further guidance on this issue. (re: DE#41 ; release date 11/28/2022) (tlh)
October 31, 2022 Filing 47 USCA Case Number 22-5959 for #46 Notice of Interlocutory Appeal filed by MRME LLC, Carlos Rodriguez. Civil Case Docketed. Notice filed by Appellant Carlos Rodriguez. Transcript needed: y. (csf)
October 28, 2022 Filing 46 NOTICE OF INTERLOCUTORY APPEAL as to #45 Order on Motion for Preliminary Injunction by MRME LLC, Carlos Rodriguez. Filing fee $ 505, receipt number ATNWDC-4002724. Appeal Record due by 11/18/2022. (Crowell, Daniel)
September 28, 2022 Opinion or Order Filing 45 PRELIMINARY INJUNCTION ORDER. Signed by Judge Mark S. Norris on 9/28/22. (Norris, Mark)
September 19, 2022 Filing 44 NOTICE by VRC Companies, LLC re #43 Stipulation of Opposition (Stuart, Sarah)
September 19, 2022 Filing 43 STIPULATION re #35 MOTION for Preliminary Injunction Proposed Consent Preliminary Injunction by MRME LLC, Carlos Rodriguez. (Crowell, Daniel)
September 1, 2022 Filing 42 REPLY to Response to Motion re #40 Response in Opposition to Motion, Plaintiff's Response to Defendant's Supplemental Brief filed by VRC Companies, LLC. (Krupicka, Lisa)
August 30, 2022 Filing 41 NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on August 23, 2022 before Judge Mark S. Norris. Court Reporter Lisa Mayo, Telephone number (901) 495-1537. Notice is hereby given that an official transcript of a proceeding has been filed by the court reporter in this matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript, and twenty-one (21) calendar days to file a Request for Redaction. Redaction is the responsibility of the attorneys and pro se litigants who attended the hearing to which the transcription applies. Each party is responsible for reviewing and requesting redaction of testimony of witnesses that were called for the party and for that party's own statements. Any party needing a copy of the transcript to review for redaction purposes may purchase a copy from the court reporter or view the document at the clerk's office public terminal.. Notice of Intent to Request Redaction due 9/6/2022. Redaction Request due 9/20/2022. Release of Transcript Restriction set for 11/28/2022. (Mayo, Lisa)
August 26, 2022 Filing 40 RESPONSE in Opposition re #35 MOTION for Preliminary Injunction filed by All Defendants. (Attachments: #1 Exhibit Ex. 1 - Ram Tool & Supply Co. v. HD Supply Constr. Supply, Ltd., #2 Exhibit Ex. 2 - Amarr Co. v. Depew, #3 Exhibit Ex. 3 - BNA Assocs., LLC v. Goldman Sachs Specialty Lending Grp., L.P.)(Crowell, Daniel)
August 23, 2022 Filing 39 Exhibit and Witness List from Preliminary Injunction Hearing held on 08/23/2022.(zsf)
August 23, 2022 Filing 38 MINUTES: Preliminary Injunction Hearing held on 08/23/2022 before Judge Mark S. Norris. Attys Lisa A. Krupicka & Sarah E. Stuart appeared for the plaintiff; Attys Daniel C. Crowell & Leslie Goff Sanders appeared for the defendant. Also present were Frederick Palo, VRC Chief Executive Officer, Dan McFarland, VRC Chief Operating Officer, and defendant Carlos Rodriguez. Plaintiff's motion #35 for preliminary injunction - pending. Opening statements. Plaintiff's proof/sworn witnesses: Frederick Palo: Exhs. 1-8, Defendant's Exhs. 9 (ID only), 10, 11; Dan McFarland: Exhs. 12 (ID only), 13 (coll). Plaintiff rests. Defendant's proof/sworn witnesses: Carlos A. Rodriguez. Defendant rests. Rebuttal proof: Frederick Palo. Defendant's offer of a proposed preliminary injunction as stated on the record in open court. Defendant to file supplemental brief by close of business on Friday, 08/26/2022. Plaintiff's response due by close of business on Friday, 09/02/2022. Matter taken under advisement. Order to be entered. (Court Reporter: Lisa Mayo)(zsf)
August 22, 2022 Filing 37 RESPONSE in Opposition re #35 MOTION for Preliminary Injunction filed by All Defendants. (Attachments: #1 Exhibit Fitness & Ready Meals LLC v. Eat Well Nashville LLC, 2022 Tenn. App. LEXIS 81 (Tenn. Ct. App. March 1, 2022), #2 Exhibit Vaughn v. Weems, 1994 Tenn. App. LEXIS 712 (Tenn. Ct. App. Dec. 7, 1994), #3 Exhibit Combs v. Brick Acquisition Company, 2013 Tenn. App. LEXIS 709 (Tenn. Ct. App. Oct. 30, 2013))(Crowell, Daniel)
August 19, 2022 Filing 36 NOTICE by VRC Companies, LLC re #27 Order on Motion for TRO of Surety Bond (Stuart, Sarah)
August 16, 2022 Filing 35 MOTION for Preliminary Injunction by VRC Companies, LLC. (Attachments: #1 Memorandum)(Krupicka, Lisa)
August 16, 2022 Filing 34 WAIVER OF SERVICE Returned Executed by VRC Companies, LLC. MRME LLC waiver sent on 8/16/2022, answer due 10/17/2022. (Krupicka, Lisa)
August 16, 2022 Filing 33 Summons Issued as to MRME LLC. The filer has been notified electronically that the summons has been issued, and the new docket entry reflects this. Upon notification of the new docket entry, the filer is to print the issued summons in order to effect service. (btg)
August 15, 2022 Filing 32 AMENDED COMPLAINT against MRME LLC, filed by VRC Companies, LLC. (Attachments: #1 Summons) (Krupicka, Lisa)
August 3, 2022 Opinion or Order Filing 31 ORDER DENYING AS MOOT #28 DEFENDANT'S EMERGENCY MOTION TO MODIFY TEMPORARY RESTRAINING ORDER. Signed by Judge Mark S. Norris on 08/03/2022.(Norris, Mark)
August 2, 2022 Filing 30 NOTICE by Carlos Rodriguez re #28 MOTION to Amend/Correct #27 Order on Motion for TRO of Withdrawal of Defendant's Motion to Modify Temporary Restraining Order (Crowell, Daniel)
August 2, 2022 Filing 29 RESPONSE in Opposition re #28 MOTION to Amend/Correct #27 Order on Motion for TRO filed by VRC Companies, LLC. (Attachments: #1 Exhibit Exhibit A - Supplemental Declaration of Danny Palo)(Stuart, Sarah)
August 1, 2022 Filing 28 MOTION to Amend/Correct #27 Order on Motion for TRO by Carlos Rodriguez. (Crowell, Daniel)
August 1, 2022 Opinion or Order Filing 27 TEMPORARY RESTRAINING ORDER. Signed by Judge Mark S. Norris on 08/01/2022. (Norris, Mark)
July 29, 2022 Filing 26 AFFIDAVIT Declaration of Danny Palo by VRC Companies, LLC. (Krupicka, Lisa)
July 29, 2022 Filing 25 SETTING LETTER: Preliminary Injunction Hearing set for Tuesday, 08/23/2022 at 10:00 AM in Courtroom 4 - Memphis before Judge Mark S. Norris. (zsf)
July 29, 2022 Filing 24 Minute Entry for proceedings held before Judge Mark S. Norris: Motion Hearing held on 07/29/2022 re #8 Plaintiff's Motion for Temporary Restraining Order. Atty Lisa Krupicka appeared for the plaintiff; Atty Daniel Crowell appeared for the defendant. Oral argument given by counsel. After hearing oral argument by counsel, the Court granted Plaintiff's Motion #8 for Temporary Restraining as stated on the record in open court. Bond set at $100,000.00. Preliminary Injunction Hearing set for Tuesday, 08/23/2022 at 10:00 AM in Courtroom 4 - Memphis before Judge Mark S. Norris. Order to enter. (Court Reporter: Lisa Mayo) (zsf)
July 28, 2022 Filing 23 NOTICE by Carlos Rodriguez of Filing Supplemental Declaration of Carlos A. Rodriguez (Attachments: #1 Exhibit Supplemental Declaration of Carlos A. Rodriguez)(Crowell, Daniel)
July 27, 2022 Filing 22 [**TEXT ENTRY ONLY - NO IMAGE ATTACHED**] NOTICE of Hearing on Motion: A Hearing on Plaintiff's Motion for Temporary Restraining Order #8 has been RESET (TIME CHANGE ONLY) for Friday, July 29, 2022 at 2:30 P.M. in Courtroom 4 - Memphis before Judge Mark S. Norris. (zsf)
July 27, 2022 Filing 21 REPLY to Response to Motion re #16 Response in Opposition to Motion, Plaintiff's Reply in Support of its Motion for Temporary Restraining Order filed by VRC Companies, LLC. (Krupicka, Lisa)
July 27, 2022 Filing 20 NOTICE of Hearing on Motion: A Hearing on Plaintiff's Motion for Temporary Restraining Order #8 has been set for Friday, July 29, 2022 at 4:00 P.M. in Courtroom 4 - Memphis before Judge Mark S. Norris. (zsf)
July 27, 2022 Judge Mark S. Norris added. Judge John T. Fowlkes, Jr no longer assigned to case. (vlg) (btg).
July 25, 2022 Filing 19 Judge John T. Fowlkes, Jr added. (btg)
July 25, 2022 Opinion or Order Filing 18 ORDER OF RETURN FOR REASSIGNMENT. Signed by Judge Mark S. Norris on 07/25/2022. (Norris, Mark)
July 22, 2022 Filing 17 NOTICE of Appearance by Leslie Goff Sanders on behalf of Carlos Rodriguez (Sanders, Leslie)
July 22, 2022 Filing 16 RESPONSE in Opposition re #8 MOTION for Temporary Restraining Order filed by Carlos Rodriguez. (Attachments: #1 Exhibit Declaration of Carlos A. Rodriguez, #2 Exhibit Resume of Carlos A. Rodriguez, #3 Exhibit Exhibit G to Asset Purchase Agreement, #4 Exhibit Dauenhauer v. Bank of N.Y. Mellon, #5 Exhibit Wood v. Sehorn)(Crowell, Daniel)
July 21, 2022 Filing 15 NOTICE of Appearance by Stephen Craig Stovall on behalf of Carlos Rodriguez (Stovall, Stephen)
July 20, 2022 Filing 14 Judge Mark S. Norris added. (btg)
July 20, 2022 Opinion or Order Filing 13 ORDER REASSIGNING CASE. Judge Samuel H. Mays, Jr no longer assigned to case. Signed by Judge Samuel H. Mays, Jr on 7/20/2022. (Mays, Samuel)
July 20, 2022 Filing 12 WAIVER OF SERVICE Returned Executed by VRC Companies, LLC. Carlos Rodriguez waiver sent on 7/19/2022, answer due 9/19/2022. (Krupicka, Lisa)
July 20, 2022 Filing 11 RESPONSE in Opposition re #10 MOTION for a Briefing Schedule and Hearing re #8 MOTION for Temporary Restraining Order proposed order submitted filed by VRC Companies, LLC. (Stuart, Sarah)
July 20, 2022 Filing 10 MOTION for a Briefing Schedule and Hearing re #8 MOTION for Temporary Restraining Order proposed order submitted by Carlos Rodriguez. (Attachments: #1 Proposed Order)(Crowell, Daniel)
July 19, 2022 Filing 9 NOTICE of Appearance by Daniel Caden Crowell on behalf of Carlos Rodriguez (Crowell, Daniel)
July 18, 2022 Filing 8 MOTION for Temporary Restraining Order by VRC Companies, LLC. (Krupicka, Lisa)
July 15, 2022 Filing 7 NOTICE of Appearance by Sarah Elizabeth Stuart on behalf of VRC Companies, LLC (Stuart, Sarah)
July 15, 2022 Filing 6 Summons Issued as to Carlos Rodriguez. The filer has been notified electronically that the summons has been issued, and the new docket entry reflects this. Upon notification of the new docket entry, the filer is to print the issued summons in order to effect service. (btg)
July 15, 2022 Filing 5 NOTICE OF RIGHT TO CONSENT TO THE EXERCISE OF CIVIL JURISDICTION BY A MAGISTRATE JUDGE Pursuant to 28 U.S.C. 636(c), Fed.R.Civ.P.73, and Local Rule 72.1, this Court has designated the Magistrate Judges of this District to conduct trials and otherwise dispose of any civil case that is filed in this Court. Your decision to consent, or not consent, to the referral of your case to a United States Magistrate Judge for trial and entry of a final judgment must be entirely voluntary. The judge or magistrate judge to whom the case has been assigned will not be informed of your decision unless all parties agree that the case may be referred to a magistrate judge for these specific purposes. A less than unanimous decision will not be communicated by this office to either the judge or magistrate judge. The consent form is available on the courts website at https://www.tnwd.uscourts.gov/forms-and-applications.php (btg)
July 15, 2022 Filing 4 NOTICE TO COMPLY WITH PLAN FOR ALTERNATE DISPUTE RESOLUTION (ADR): Pursuant to Section to 2.1 of the ADR Plan, all civil cases filed on or after Sept. 1, 2014, shall be referred automatically for ADR. For compliance requirements, refer to the ADR Plan at: http://www.tnwd.uscourts.gov/pdf/content/ADRPlan.pdf (btg)
July 15, 2022 Filing 3 NOTICE OF CASE TRACKING ASSIGNMENT PURSUANT TO LOCAL RULE 16.2: Pursuant to Local Rule 16.2, this case has been assigned to the Standard track. http://www.tnwd.uscourts.gov/pdf/content/LocalRules.pdf (btg)
July 15, 2022 Filing 2 Judge Samuel H. Mays, Jr and Chief Magistrate Judge Tu M. Pham added. (btg)
July 15, 2022 Filing 1 COMPLAINT Verified Complaint for Injunctive Relief and Damages and Application for Temporary Restraining Order against Carlos Rodriguez (Filing fee $ 402 receipt number ATNWDC-3921490), filed by VRC Companies, LLC d/b/a/ Vital Records Control. (Attachments: #1 Civil Cover Sheet, #2 Exhibit Asset Purchase Agreement, #3 Exhibit Employment Agreement, #4 Exhibit 2017 Non Compete, #5 Exhibit Termination Agreement, #6 Exhibit 2021 Non Compete, #7 Exhibit 2022 Severance Agreement, #8 Summons Summons to Carlos Rodriguez)(Krupicka, Lisa)

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Plaintiff: VRC Companies, LLC doing business as Vital Records Control, Inc.
Represented By: Sarah Elizabeth Stuart
Represented By: Lisa A. Krupicka
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Defendant: Carlos Rodriguez doing business as Medical Records Made Easy
Represented By: Daniel Caden Crowell
Represented By: Leslie Goff Sanders
Represented By: Stephen Craig Stovall
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Defendant: MRME LLC
Represented By: Daniel Caden Crowell
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