ShiftKey, LLC v. NurseIO, LLC et al
| ShiftKey, LLC |
| NurseIO, LLC, Christian McNamee and Yulia McKinney |
| Christian McNamee and Yulia McKinney |
| ShiftKey, LLC |
| 4:2025cv00521 |
| May 15, 2025 |
| U.S. District Court for the Eastern District of Texas |
| Amos L Mazzant |
| Defend Trade Secrets Act (of 2016) |
| 18 U.S.C. § 1836 (a) Injunction against Misappropriation of Trade Secrets |
| Both |
Docket Report
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This docket was last retrieved on October 13, 2026. A more recent docket listing may be available from PACER.
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Filing 69
ORDER granting #68 Motion for Withdrawal of Counsel. It is hereby ORDERED that Carter Arnett PLLC (the "Firm") and all Firm attorneys who have entered appearances in this matter are withdrawn as counsel of record for Defendants Yulia McKinney and Christian McNamee. It is further ORDERED that the Clerk shall enter Defendants' pro se appearances on the docket as follows: Yulia McKinney, 1400 Tumblewood Trail, Northlake, Texas 76226, [email protected]; Christian McNamee, 3400 Napoleon Court, Plano, Texas 75023, [email protected]. Signed by Chief District Judge Amos L Mazzant on 10/17/2025. (rpc)
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Filing 68
UNOPPOSED MOTION to Withdraw as Attorney by Yulia McKinney, Christian McNamee. (Attachments: #1 Proposed Order)(Carter, Edgar)
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Filing 67
SCHEDULING ORDER: Final Pretrial Conference set for 8/6/2026 at 09:00 AM in Ctrm 208 (Sherman) before Chief District Judge Amos L Mazzant. Amended Pleadings due by 3/13/2026. Discovery due by 6/8/2026. Joinder of Parties due by 1/30/2026. Jury instructions due by 7/30/2026. Mediation Completion due by 6/15/2026. Designation of Mediator due by 5/4/2026. Motions due by 3/30/2026. Proposed Pretrial Order due by 7/16/2026. Signed by Chief District Judge Amos L Mazzant on 9/3/2025. (rpc)
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The Court hereby CANCELS the August 22, 2025 Scheduling Conference; the Court will enter a Scheduling Order. (No attachment) (tls)
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Filing 66
ANSWER to #53 Answer to Complaint, Counterclaim of Yulia McKinney by ShiftKey, LLC.(McCabe, Michael)
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Filing 65
ANSWER to #36 Answer to Complaint, Counterclaim of Christian McNamee by ShiftKey, LLC.(McCabe, Michael)
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Filing 64
ANSWER to #1 Complaint, by NurseIO, LLC.(Nunnallee, Adam)
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Filing 63
ORDER granting #62 Motion to Withdraw and Substitute Attorney. Brian Patrick Lauten, Brian Lauten, PC is withdrawn as counsel of record for NurseIO. Adam Nunnallee, Nunnallee Law, PLLC is substituted as counsel of record and lead attorney for NurseIO. Signed by Chief District Judge Amos L Mazzant on 8/11/2025. (rpc)
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Filing 62
MOTION to Substitute Attorney by NurseIO, LLC. (Attachments: #1 Proposed Order)(Nunnallee, Adam)
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Filing 61
JOINT REPORT of Rule 26(f) Planning Meeting. (Attachments: #1 Appendix 1)(Strauss, Jordan)
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Filing 60
NOTICE of Attorney Appearance by Adam Ross Nunnallee on behalf of NurseIO, LLC (Nunnallee, Adam)
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Filing 59
NOTICE OF COMPLIANCE by Yulia McKinney, Christian McNamee re #50 Order Governing Proceedings (Carter, Edgar)
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Filing 58
NOTICE OF COMPLIANCE by NurseIO, LLC re #50 Order Governing Proceedings, (Lauten, Brian)
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Filing 57
NOTICE OF COMPLIANCE by ShiftKey, LLC re #50 Order Governing Proceedings, (Strauss, Jordan)
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Filing 56
MEMORANDUM OPINION AND ORDER. It is ORDERED that Counter-Defendant Shiftkey, LLC's 12(b)(6) Motion to Dismiss Counter-Plaintiff Christian McNamee's Counterclaim (Dkt. #44 ) is hereby DENIED. Signed by Chief District Judge Amos L Mazzant on 7/28/2025. (rpc)
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Filing 55
MEMORANDUM OPINION AND ORDER. It is ORDERED that Defendant NurseIO, LLC's 12(b)(6) Partial Motion to Dismiss, and Brief in Support (Dkt. #40 ) is hereby DENIED. Signed by Chief District Judge Amos L Mazzant on 7/28/2025. (rpc)
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Filing 54
MEMORANDUM OPINION AND ORDER. It is ORDERED that Plaintiff ShiftKey, LLC's Emergency Application for Temporary Restraining Order, Preliminary Injunction, and Motion for Expedited Discovery (Dkt. #9 ) are hereby DENIED without prejudice. Signed by Chief District Judge Amos L Mazzant on 7/28/2025. (rpc)
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Filing 53
YULIA MCKINNEY ANSWER to #1 Complaint, , COUNTERCLAIM against All Plaintiffs by Yulia McKinney.(Carter, Edgar)
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Filing 52
REPLY to Response re #44 MOTION to Dismiss (12(b)(6)) Christian McNamee's Counterclaim filed by ShiftKey, LLC. (McCabe, Michael)
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Filing 51
RESPONSE in Opposition re #44 MOTION to Dismiss (12(b)(6)) Christian McNamee's Counterclaim filed by Christian McNamee. (Attachments: #1 Proposed Order)(Arnett, James)
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Filing 50
ORDER GOVERNING PROCEEDINGS: Rule 26 Meeting Report due by 8/7/2025. Rule 16 Management Conference set for 8/22/2025 at 10:30 AM via Zoom or telephone before Chief District Judge Amos L Mazzant. Signed by Chief District Judge Amos L Mazzant on 7/3/2025. (rpc)
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Filing 49
ORDER. It is ORDERED that ShiftKey, LLC's Emergency Motion for Entry of Protective Order (Dkt. #10 ) is denied as moot. Signed by Chief District Judge Amos L Mazzant on 7/2/2025. (rpc)
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Filing 48
PROTECTIVE ORDER. (Motion #33 terminated). Signed by Chief District Judge Amos L Mazzant on 7/2/2025. (rpc)
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Filing 47
ORDER granting #46 Motion to Supplement Exhibit B Previously Submitted as Dkt. 39-2. Exhibit B is attached to the Unopposed Motion to Supplement. Signed by Chief District Judge Amos L Mazzant on 6/30/2025. (rpc)
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Filing 46
UNOPPOSED MOTION Supplement Exh. B Previously Submitted as Dkt. 39-2 re #39 Reply to Response to Motion, by ShiftKey, LLC. (Attachments: #1 Exhibit Supplemental Exh. B, #2 Proposed Order)(McCabe, Michael)
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Filing 45
MOTION to Strike Exhibit B by Yulia McKinney, Christian McNamee. (Stahl, Linda)
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Filing 44
MOTION to Dismiss (12(b)(6)) Christian McNamee's Counterclaim by ShiftKey, LLC. (Attachments: #1 Proposed Order)(McCabe, Michael)
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Clerk's LR CV-10(d) Notice of Deficiency as to #45 Motion to Strike filed by Yulia McKinney, Christian McNamee. - LR CV-7(i) or LR CR-47(a)(3) requires this document to include a certificate of conference that complies with the rule. Please note that a proposed order should be attached to the Motion when refiling. Recommended cure: Within one day, Filer must refile with the word Corrected in the title of the document. The filer should use the same ECF event and when offered the docket text enhancement dropdown, select CORRECTED so it will also appear in the docket text. (rpc)
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Filing 43
RESPONSE in Opposition re #40 MOTION to Dismiss 12(b)(6) and Brief filed by ShiftKey, LLC. (Attachments: #1 Proposed Order)(McCabe, Michael)
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Filing 42
ORDER granting #38 Motion for Leave to Exceed Page Limitations. Signed by Chief District Judge Amos L Mazzant on 6/12/2025. (rpc)
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Filing 41
ORDER granting #34 Motion for Leave to File Under Seal Exhibits to the Declaration of Brandon Tappan. Signed by Chief District Judge Amos L Mazzant on 6/12/2025. (rpc)
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Filing 40
MOTION to Dismiss 12(b)(6) and Brief by NurseIO, LLC. (Lauten, Brian) (Additional attachment(s) added on 6/12/2025: #1 Proposed Order) (rpc).
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Filing 39
REPLY to Response re #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite filed by ShiftKey, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B)(Strauss, Jordan)
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Filing 38
MOTION for Leave to File Excess Pages on Its Reply ISO Corrected Emergency Application for TRO, Preliminary Injunction, and Motion for Expedited Discovery by ShiftKey, LLC. (Attachments: #1 Proposed Order)(Strauss, Jordan)
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Filing 37
NOTICE Regarding Redacted Versions of Documents Filed Under Seal at Dkt 35 by ShiftKey, LLC re #35 Sealed Document,,, (Attachments: #1 Affidavit/Declaration Redacted, #2 Exhibit A-3, #3 Exhibit A-4, #4 Exhibit A-9)(Strauss, Jordan)
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Filing 36
ANSWER to #1 Complaint, and, COUNTERCLAIM against ShiftKey, LLC by Christian McNamee.(Carter, Edgar)
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Filing 35
Sealed Exhibits to the Declaration of Brandon Tappan. (Attachments: #1 Exhibit A-3, #2 Exhibit A-4, #3 Exhibit A-5, #4 Exhibit A-6, #5 Exhibit A-6 Slipsheet, #6 Exhibit A-7, #7 Exhibit A-9, #8 Exhibit A-10, #9 Exhibit A-10 Slipsheet, #10 Exhibit A-11, #11 Exhibit A-11 Slipsheet, #12 Exhibit A-12, #13 Exhibit A-12 Slipsheet, #14 Exhibit A-13, #15 Exhibit A-14, #16 Exhibit A-14 Slipsheet, #17 Exhibit A-15, #18 Exhibit A-15 Slipsheet, #19 Exhibit A-16, #20 Exhibit A-17, #21 Exhibit A-18, #22 Exhibit A-19, #23 Exhibit A-20, #24 Exhibit A-21, #25 Exhibit A-22, #26 Exhibit A-23, #27 Exhibit A-24, #28 Exhibit A-25, #29 Exhibit A-26, #30 Exhibit A-26 Slipsheet, #31 Exhibit A-27, #32 Exhibit A-27 Slipsheet, #33 Exhibit A-28, #34 Exhibit A-29, #35 Exhibit A-30)(Strauss, Jordan) Modified text on 6/9/2025 (rpc).
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Filing 34
UNOPPOSED MOTION to Seal Document Exhibits to the Declaration of Brandon Tappan by ShiftKey, LLC. (Attachments: #1 Proposed Order)(Strauss, Jordan)
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Filing 33
JOINT MOTION for Protective Order by ShiftKey, LLC. (Attachments: #1 Proposed Order)(Strauss, Jordan)
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Filing 32
ORDER granting #30 Motion for Leave to Exceed Page Limit. It is so ORDERED that the Motion is GRANTED and the Response to Plaintiff's Emergency Application for Temporary Restraining Order, Preliminary Injunction, and Motion for Expedited Discovery is deemed filed. Signed by Chief District Judge Amos L Mazzant on 6/5/2025. (rpc)
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Filing 31
ORDER granting #28 Motion for Leave to Correct Filing and Exceed Page Limits on its Corrected Response to Plaintiff's Emergency Application for Temporary Restraining Order, Preliminary Injunction, and Motion for Expedited Discovery. Signed by Chief District Judge Amos L Mazzant on 6/5/2025. (rpc)
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Filing 30
CORRECTED MOTION to Amend/Correct Unopposed Motion for Leave to Exceed Page Limits by All Defendants. (Attachments: #1 Proposed Order)(Goff, Monica)
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Filing 29
CORRECTED RESPONSE re #28 MOTION for Leave to File Correct filing and Exceed Page Limits, #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite filed by NurseIO, LLC. (Attachments: #1 Affidavit/Declaration, #2 Affidavit/Declaration)(Lauten, Brian)
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Filing 28
MOTION for Leave to File Correct filing and Exceed Page Limits by NurseIO, LLC. (Attachments: #1 Proposed Order)(Lauten, Brian)
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Filing 27
NOTICE of Attorney Appearance by Linda R Stahl on behalf of Yulia McKinney, Christian McNamee (Stahl, Linda)
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Filing 26
MOTION for Leave to File Excess Pages by Yulia McKinney, Christian McNamee. (Attachments: #1 Proposed Order)(Arnett, James)
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Filing 25
RESPONSE in Opposition re #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite filed by Yulia McKinney, Christian McNamee. (Attachments: #1 Affidavit/Declaration of Yulia McKinney, #2 Affidavit/Declaration of Christian McNamee, #3 Affidavit/Declaration of Linda Stahl, #4 Exhibit LinkedIn search, #5 Exhibit ShiftKey webpages, #6 Exhibit ShiftKey webpages, #7 Exhibit fastcompany article, #8 Exhibit BBB webpage, #9 Proposed Order)(Arnett, James)
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Filing 24
RESPONSE re #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite filed by NurseIO, LLC. (Attachments: #1 Affidavit/Declaration, #2 Affidavit/Declaration)(Lauten, Brian)
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Filing 23
NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Motion Hearing held on 5/23/2025 before Judge Amos Mazzant. Court Reporter/Transcriber: Christina Bickham,Telephone number: 903-209-4013, [email protected]. NOTICE RE REDACTION OF TRANSCRIPTS: The parties have seven (7) days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.txed.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.. Motion to Redact due 6/18/2025. Release of Transcript Restriction set for 8/26/2025. (Bickham, Chris)
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Filing 21
WAIVER OF SERVICE Returned Executed by ShiftKey, LLC. Yulia McKinney waiver sent on 5/27/2025, answer due 7/28/2025. (McCabe, Michael)
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Filing 22
ORDER granting #8 Motion for Leave to File Excess Pages. Signed by Chief District Judge Amos L Mazzant on 5/27/2025. (rpc)
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Filing 20
NOTICE of Attorney Appearance by Nicole Angelica Paige on behalf of ShiftKey, LLC (Paige, Nicole)
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Filing 19
Paper Transcript Request by ShiftKey, LLC for proceedings held on 05/23/2025, TRO and Emergency Motions before Judge Amos L. Mazzant. (McCabe, Michael) (Forwarded to Chris Bickham on 5/23/25.) Modified on 5/23/2025 (bmf). (Forwarded to Chris Bickham on 5/23/2025.) Modified on 5/23/2025 (wea).
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Filing 18
Minute Entry for proceedings held before Chief District Judge Amos L Mazzant: Motion Hearing held on 5/23/2025 from 10:43 - 11:58 re #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite filed by ShiftKey, LLC. Court will allow Defendant to file response by 6/2/2025; Plaintiff's reply due 6/9/2025. Attorney Appearances: Plaintiff - Michael McCabe, Jordan Strauss, Nicole Paige; Defense - Brian Carter, Courtney Bowline, Bob Arnett, Leon Carter. (Court Reporter - Chris Bickham) (Attachments: Plaintiff's Powerpoint #1 Defendants' Exhibit List, #2 Defendants' Exhibits 1 and 2) (kkc)
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Filing 17
NOTICE of Attorney Appearance by James Robert Arnett, II on behalf of Yulia McKinney, Christian McNamee (Arnett, James)
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Filing 16
NOTICE of Attorney Appearance by Nichol M. John on behalf of Yulia McKinney, Christian McNamee (John, Nichol)
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Filing 15
NOTICE of Attorney Appearance by Monica Litle Goff on behalf of Yulia McKinney, Christian McNamee (Goff, Monica)
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Filing 14
NOTICE of Attorney Appearance by Edgar Leon Carter on behalf of Yulia McKinney, Christian McNamee (Carter, Edgar)
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Filing 13
SUMMONS Returned Executed by ShiftKey, LLC. NurseIO, LLC served on 5/20/2025. (Attachments: #1 Affidavit/Declaration)(McCabe, Michael)
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Filing 12
SUMMONS Returned Executed by ShiftKey, LLC. Christian McNamee served on 5/17/2025. (McCabe, Michael)
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Filing 11
NOTICE of Certification of Michael McCabe ISO ShiftKey's Corrected Emergency TRO Application, Preliminary Injunction, and Motion for Expedited Discovery by ShiftKey, LLC re #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite (Attachments: #1 Exhibit A)(McCabe, Michael)
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Filing 10
EMERGENCY MOTION for Protective Order by ShiftKey, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(McCabe, Michael)
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NOTICE of Hearing on #9 CORRECTED MOTION for Temporary Restraining Order EMERGENCY MOTION for Preliminary Injunction EMERGENCY MOTION to Expedite set for 5/23/2025 at 10:45 a.m. in Ctrm 208 (Sherman) before Chief District Judge Amos L Mazzant. (kkc)
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Filing 9
CORRECTED MOTION for Temporary Restraining Order , EMERGENCY MOTION for Preliminary Injunction , EMERGENCY MOTION to Expedite by ShiftKey, LLC. (Attachments: #1 Affidavit/Declaration Brandon Tappan, #2 Exhibit A-1, #3 Exhibit A-2, #4 Exhibit A-3, #5 Exhibit A-4, #6 Exhibit A-5, #7 Exhibit A-6, #8 Exhibit A-7, #9 Exhibit A-8, #10 Exhibit A-9, #11 Exhibit A-10, #12 Exhibit A-11, #13 Exhibit A-12, #14 Exhibit A-13, #15 Exhibit A-14, #16 Exhibit A-15, #17 Exhibit A-16, #18 Exhibit A-17, #19 Exhibit A-18, #20 Exhibit A-19, #21 Exhibit A-20, #22 Exhibit A-21, #23 Exhibit A-22, #24 Exhibit A-23, #25 Exhibit A-24, #26 Exhibit A-25, #27 Exhibit A-26, #28 Exhibit A-27, #29 Exhibit A-28, #30 Exhibit A-29, #31 Exhibit A-30, #32 Exhibit B, #33 Proposed Order)(McCabe, Michael)
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Filing 8
MOTION for Leave to File Excess Pages on Corrected Emergency Application for TRO, Preliminary Injunction, and Motion for Expedited Discovery by ShiftKey, LLC. (Attachments: #1 Proposed Order)(McCabe, Michael)
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Filing 7
SUMMONS Issued as to Christian McNamee. (baf)
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Filing 6
SUMMONS Issued as to Yulia McKinney. (baf)
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Filing 5
SUMMONS Issued as to NurseIO, LLC. (baf)
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Clerk's LR CV-10(d) Notice of Deficiency as to #3 Motion for TRO, Motion for Preliminary Injunction, Motion to Expedite, - LR CV-7(a) or CR-47(a) prescribes a page limit that this document exceeds. Recommended cure: Within one day, Filer must refile with the word Corrected in the title of the document. The filer should use the same ECF event and when offered the docket text enhancement dropdown, select CORRECTED so it will also appear in the docket text. (baf)
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Case assigned to Chief District Judge Amos L Mazzant. (baf)
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In accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form #Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice Regarding Consent to Proceed Before Magistrate Judge. (baf)
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Filing 4
NOTICE of Attorney Appearance by Jordan Christine Strauss on behalf of ShiftKey, LLC (Strauss, Jordan)
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Filing 3
EMERGENCY MOTION for Temporary Restraining Order , MOTION for Preliminary Injunction , MOTION to Expedite by ShiftKey, LLC. (Attachments: #1 Exhibit A, #2 Exhibit A-1, #3 Exhibit A-2, #4 Exhibit A-3, #5 Exhibit A-4, #6 Exhibit A-5, #7 Exhibit A-6, #8 Exhibit A-7, #9 Exhibit A-8, #10 Exhibit A-9, #11 Exhibit A-10, #12 Exhibit A-11, #13 Exhibit A-12, #14 Exhibit A-13, #15 Exhibit A-14, #16 Exhibit A-15, #17 Exhibit A-16, #18 Exhibit A-17, #19 Exhibit A-18, #20 Exhibit A-19, #21 Exhibit A-20, #22 Exhibit A-21, #23 Exhibit A-22, #24 Exhibit A-23, #25 Exhibit A-24, #26 Exhibit A-25, #27 Exhibit A-26, #28 Exhibit A-27, #29 Exhibit A-28, #30 Exhibit A-29, #31 Exhibit A-30, #32 Exhibit B, #33 Proposed Order)(McCabe, Michael)
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Filing 2
Fed. R. Civ. P. 7.1(a)(1) Disclosure Statement filed by ShiftKey, LLC identifying Corporate Parent ShiftKey Purchaser, LLC, Other Affiliate ShiftKey Parent, LLC for ShiftKey, LLC. (McCabe, Michael)
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Filing 1
COMPLAINT against All Defendants ( Filing fee $ 405 receipt number ATXEDC-10842745.), filed by ShiftKey, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Civil Cover Sheet)(McCabe, Michael)
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