MEMO ENDORSEMENT: granting 143 Motion to Withdraw as Attorney. ENDORSEMENT: Application GRANTED. The Clerk of Court is directed to terminate Joshua Liston, Michael Beys and Nader Mobargha as counsel-of-record in the above captioned matter, and to close the motion at Dkt. No. 143. Attorney Nader Mobargha; Michael Petros Beys and Joshua Donovan Liston terminated. (Signed by Judge Lorna G. Schofield on 4/28/2017) (ap) (Entered: 04/28/2017)
DECLARATION of Joshua D. Liston in Support re: 143 MOTION for Beys Liston & Mobargha LLP, Joshua D. Liston, Michael P. Beys, and Nader Mobargha to Withdraw as Attorney .. Document filed by Felix Sater. (Liston, Joshua) (Entered: 04/27/2017)
MEMORANDUM OF LAW in Support re: 143 MOTION for Beys Liston & Mobargha LLP, Joshua D. Liston, Michael P. Beys, and Nader Mobargha to Withdraw as Attorney . . Document filed by Felix Sater. (Liston, Joshua) (Entered: 04/27/2017)
MOTION for Beys Liston & Mobargha LLP, Joshua D. Liston, Michael P. Beys, and Nader Mobargha to Withdraw as Attorney . Document filed by Felix Sater.(Liston, Joshua) (Entered: 04/27/2017)
MANDATE of USCA (Certified Copy) as to 138 Notice of Appeal, filed by Ervin Tausky, Richard E Lerner, E/O Ernest Gottdiener, Frederick Oberlander, E/O Judit Gottdiener, Suan Investments. USCA Case Number 15-4077. Ordered, Adjudged and Decreed that the judgment of the District Court is AFFIRMED. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 02/27/2017. (nd) (Entered: 02/27/2017)
ORDER of USCA (Certified Copy) as to [138] Notice of Appeal, filed by Ervin Tausky, Richard E Lerner, E/O Ernest Gottdiener, Frederick Oberlander, E/O Judit Gottdiener, Suan Investments. USCA Case Number 15-4077. Appellant moves to recall the mandate and reinstate this appeal. IT IS HEREBY ORDERED that the motion is GRANTED. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Certified: 06/06/2016. (nd)
NOTICE OF APPEAL from 49 Order,,,, 137 Order on Motion to Vacate, Order on Motion to Dismiss,,,, 40 Memorandum & Opinion,,, 62 Order on Motion for Reconsideration,,,,,,,,,,,,, 102 Order on Motion to Set Aside,. Document filed by E/O Ernest Gottdiener, E/O Judit Gottdiener, Frederick Oberlander, Suan Investments, Ervin Tausky, Richard E Lerner. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit. (Oberlander, Frederick) (Entered: 12/16/2015)
ORDER denying without prejudice 129 Motion to Vacate ; denying without prejudice 129 Motion to Dismiss. It is hereby ORDERED that Kriss II is dismissed with prejudice, but without prejudice to the continued litigation of Kriss I. It is further ORDERED that Plaintiffs' request for leave to seek Rule 11 sanctions is DENIED without prejudice to renewal at the conclusion of Kriss I. The Clerk of Court is directed to close the motion at Dkt. No. 129. (As further set forth in this Order.) (Signed by Judge Lorna G. Schofield on 11/16/2015) (kgo) (Main Document 137 replaced on 11/16/2015) (kgo). Modified on 11/16/2015 (kgo). (Entered: 11/16/2015)
MEMORANDUM OF LAW in Opposition re: 129 MOTION to Vacate Plaintiff's Notices of Voluntary Dismissal. MOTION to Dismiss With Prejudice. Filing is requested to be acknowledged as nunc pro tunc, timely made on November 9, 2015, as ECF filing failed and subsitute filing and service of these exact documents was made that date by email to the court and all counsels. Document filed by E/O Ernest Gottdiener, E/O Judit Gottdiener, Suan Investments, Ervin Tausky. (Attachments: # 1 Exhibit August 20, 2014 order of Magistrate Maas allowing indefinite time to serve a summons and complaint)(Oberlander, Frederick) (Entered: 11/10/2015)
MEMORANDUM OF LAW in Opposition re: 129 MOTION to Vacate Plaintiff's Notices of Voluntary Dismissal. MOTION to Dismiss With Prejudice. . Document filed by Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC). (Simon, Bradley) (Entered: 11/09/2015)
ORDER granting 133 Letter Motion for Extension of Time to File Response/Reply. APPLICATION GRANTED. The Clerk of Court is directed to close the motion at Docket No. 133. Responses due by 11/9/2015. (Signed by Judge Lorna G. Schofield on 10/23/2015) (kgo) (Entered: 10/23/2015)
LETTER MOTION for Extension of Time to File Response/Reply as to 131 Letter,, 132 Letter, 130 Memorandum of Law in Support of Motion,, 129 MOTION to Vacate Plaintiff's Notices of Voluntary Dismissal. MOTION to Dismiss With Prejudice. addressed to Judge Lorna G. Schofield from Frederick M. Oberlander dated October 22, 2013. Document filed by E/O Ernest Gottdiener, E/O Judit Gottdiener, Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 10/22/2015)
132
Filed: 10/21/2015, Entered: None
LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated October 21, 2015 re: Response in Opposition to Plaintiffs' October 16, 2015 Letter (ECF No. 131). Document filed by Felix Sater.(Wolf, Robert) (Entered: 10/21/2015)
131
Filed: 10/16/2015, Entered: None
LETTER addressed to Judge Lorna G. Schofield from Bradley D. Simon, Simon & Partners LLP, Counsel for Non-Parties Jody L. Kriss and Michael Ch'udi Ejekam dated October 15, 2015 re: Objection to Defedant Felix Sater's Filing of ECF Nos. 129 and 130 Motion to Vacate & Dismiss with Prejudice based on Failure to Effect Proper Service and Failure to Comply with the Court's Individual Practices in Civil Cases III. Motion Rules & Procedures A. 1.. Document filed by Michael Ejekam(alone), J. Kriss(for Bayrock Merrimac LLC).(Simon, Bradley) (Entered: 10/16/2015)
130
Filed: 10/9/2015, Entered: None
MEMORANDUM OF LAW in Support re: 129 MOTION to Vacate Plaintiff's Notices of Voluntary Dismissal. MOTION to Dismiss With Prejudice. . Document filed by Felix Sater. (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 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P)(Wolf, Robert) (Entered: 10/09/2015)
129
Filed: 10/9/2015, Entered: None
MOTION to Vacate Plaintiff's Notices of Voluntary Dismissal., MOTION to Dismiss With Prejudice. Document filed by Felix Sater.(Wolf, Robert) (Entered: 10/09/2015)
NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO F.R.C.P. 41(a)(1)(A)(i): Pursuant to F.R.C.P. 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiffs Estate of Ernest Gottdiener, Estate of Judit Gottdiener, Ervin Tausky, Suan Investments, by and through their counsel, give notice that the above-captioned action, having been previously dismissed without prejudice as to and against defendant Felix Sater aka Felix Satter, is voluntarily dismissed, without prejudice, as to and against all other remaining defendants. The Clerk of Court is directed to close this case. (Signed by Judge Lorna G. Schofield on 7/13/2015) (kgo) (Entered: 07/13/2015)
NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, WITHOUT prejudice against the defendant(s) All Defendants. Document filed by All Plaintiffs. (Oberlander, Frederick) (Entered: 07/10/2015)
NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, WITHOUT prejudice against the defendant(s) Felix Sater, Felix Satter. Document filed by All Plaintiffs. (Oberlander, Frederick) (Entered: 07/10/2015)
PLAINTIFFS' NOTICE OF VOLUNTARY DISMISSAL: Plaintiff's Jody Kriss and Michael Chu'di Ejekam hereby provide notice that they voluntarily dismiss the above-titled action ("Kriss II") as to all defendants herein, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). Application GRANTED. The Clerk of Court is directed to terminate Plaintiffs Jody Kriss and Michael Ejekam from this action. (Signed by Judge Lorna G. Schofield on 6/23/2015) (kgo) (Entered: 06/24/2015)
ORDER. A conference in the above referenced matter shall be held on July 13, 2015, at 3:30 p.m., in Courtroom 20A, 500 Pearl Street, New York 10007. All plaintiffs are directed to appear or be available by telephone. (Conference set for 7/13/2015 at 03:30 PM in Courtroom 20A, U.S. Courthouse, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Frank Maas.) (Signed by Magistrate Judge Frank Maas on 6/19/2015) Copies Sent By Chambers via ECF. (rjm) (Entered: 06/19/2015)
MEMO ENDORSEMENT on re: (168 in 1:10-cv-03959-LGS-FM) Letter, filed by Richard E Lerner. ENDORSEMENT: Application DENIED. (Signed by Judge Lorna G. Schofield on 6/15/2015) (lmb) (Entered: 06/15/2015)
LETTER addressed to Judge Lorna G. Schofield from Simon Miller dated June 9, 2015 re: requesting oral argument on motion to set aside April 30, 2015 order by Magistrate Maas. Document filed by Frederick Oberlander.(Miller, Simon) (Entered: 06/09/2015)
DECLARATION of Simon Miller in Support re: 112 MOTION to Set Aside 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas. Memorandum of Law in Support.. Document filed by Frederick Oberlander. (Attachments: # 1 Exhibit G)(Miller, Simon) (Entered: 06/09/2015)
REPLY MEMORANDUM OF LAW in Support re: 112 MOTION to Set Aside 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas. Memorandum of Law in Support. . Document filed by Frederick Oberlander. (Miller, Simon) (Entered: 06/09/2015)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Simon Miller dated 6/3/2015 re: Counsel states that the Court extended defendant Felix Sater's time to submit response from May 29, 2015 to June 2, 2015 with our reply due on June 9, 2015. Accordingly, our reply to the Bayrock Defendants' Response is currently due on June 5, 2015 and to Defendant Sater's on June 9, 2015. Since we believe that it is more efficient for the Court to receive a single reply addressing the arguments raised by both defendant groups rather than two separate submissions, we respectfully submit that it makes sense to make the deadlines for our replies the same. ENDORSEMENT: Application DENIED as unnecessary. The memo endorsement dated June 1, 2015, already provides that any replies shall be filed by June 9, 2015. For clarity: the controlling deadline for all replies is June 9, 2015. The Clerk of Court shall file this order in 10 Civ. 3959 and 13 Civ. 3905. (Signed by Judge Lorna G. Schofield on 6/3/2015) (mro) (Entered: 06/04/2015)
117
Filed: 6/3/2015, Entered: None
LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Lorna G. Schofield from Simon Miller dated 6/3/15. Document filed by Frederick Oberlander.(Miller, Simon) (Entered: 06/03/2015)
116
Filed: 5/19/2015, Entered: None
DECLARATION of Simon Miller in Support re: 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas.. Document filed by Frederick Oberlander. (Attachments: # 1 Exhibit A to Miller Declaration, # 2 Exhibit B to Miller Delcaration, # 3 Exhibit C to Miller Declaration, # 4 Exhibit D to Miller Declaration, # 5 Exhibit E to Miller Delcaration, # 6 Exhibit F to Miler Delcaration)(Miller, Simon) (Entered: 05/19/2015)
MEMORANDUM OF LAW in Support re: 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas. . Document filed by Frederick Oberlander. (Miller, Simon) (Entered: 05/19/2015)
FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, against the defendant(s) All Defendants. Document filed by Michael Ejekam(alone). (Simon, Bradley) Modified on 5/18/2015 (dt). (Entered: 05/15/2015)
FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - NOTICE OF VOLUNTARY DISMISSAL Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, against the defendant(s) All Defendants. Document filed by J. Kriss(alone). (Simon, Bradley) Modified on 5/18/2015 (dt). (Entered: 05/15/2015)
MOTION to Set Aside 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas. Memorandum of Law in Support. Document filed by Frederick Oberlander.(Miller, Simon) (Entered: 05/14/2015)
MOTION to Set Aside 110 MOTION to Set Aside April 30, 2015 Order of Magistrate Judge Maas. Declaration in Support of Motion to Set Aside April 30, 2015 Order. Document filed by Frederick Oberlander. (Attachments: # 1 Exhibit Exhibit A to Miller Dec., # 2 Exhibit Exhibit B to Miller Dec., # 3 Exhibit Exhibit C to Miller Dec., # 4 Exhibit Exhibit D to Miller Dec., # 5 Exhibit Exhibit E to Miller Dec., # 6 Exhibit Exhibit F to Miller Dec.)(Miller, Simon) (Entered: 05/14/2015)
LETTER addressed to Magistrate Judge Frank Maas from Robert S. Wolf, Esq. dated May 5, 2015 re: Requesting Dismissal with Prejudice on behalf of Defendant, Felix Sater. Document filed by Felix Sater.(Wolf, Robert) (Entered: 05/06/2015)
LETTER addressed to Magistrate Judge Frank Maas from Frederick M. Oberlander, Counsel for Plaintiffs dated 5/1/15 re: Status. Document filed by Ervin Tausky.(Oberlander, Frederick) (Entered: 05/02/2015)
ORDER granting in part and denying in part 106 Letter Motion for Conference. Application GRANTED in part. The deadlines stated in Paragraphs 6 and 7 of Judge Maas' Order dated April 30, 2015 (Dkt. No. 142 in Kriss I, and Dkt. No. 105 in Kriss II), are hereby STAYED. No later than May 14, 2015, Counsel for Mr. Oberlander may file formal objections to those paragraphs, in twelve-point double spaced Times New Roman font and not in excess of 15 pages. Any responses shall follow the same formatting and page restrictions, and shall be filed no later than May 29, 2015. Any reply, formatted in the same way and not to exceed 8 pages, shall be filed no later than June 5, 2015. The remaining deadlines in Judge Maas' April 30 Order remain in effect. All future submissions must be filed on ECF in accordance with the Court's Individual rules. The Clerk of Court is directed to file this Order in 10 Civ. 3959 and 13 Civ. 3905. (Signed by Judge Lorna G. Schofield on 5/1/2015) (kgo) (Entered: 05/01/2015)
LETTER MOTION for Conference (Pre-Motion Conference) addressed to Judge Lorna G. Schofield from Simon Miller dated 5/1/15. Document filed by Frederick Oberlander.(Miller, Simon) (Entered: 05/01/2015)
ORDER: In accordance with my rulings during the conference held on April 14, 2015, and recognizing that some time has elapsed before the entry of this formal order, it is hereby ORDERED that: 1. Frederick M. Oberlander and Richard E. Lerner are relieved as counsel for Plaintiffs for all purposes in Kriss I. 2. By June 5, 2015, Plaintiffs shall file under seal their second amended complaint in Kriss I. 3. A telephone conference shall be held on June 15, 2015, at 3 p.m., in Kriss I. Counsel for the Plaintiffs shall initiate that call. 4. By May 1, 2015, Messrs Oberlander and Lerner shall identify the Plaintiffs, if any, that they represent in Kriss II. Messrs Oberlander and Lerner further shall specify the capacity in which each such Plaintiff intends to proceed. If counsel fail to comply with this order the Court will recommend that Kriss II be dismissed with prejudice, pursuant to Rule 41(b) of the Federal Rules of Civil Procedure, for failure to prosecute. 5. By May 1, 2015, Mr. Simon shall ensure that the Plaintiffs return to the Defendants all documents in their possession, custody, or control, that Messrs Oberlander and Lerner furnished to them, and that were obtained from Bernstein or his counsel, including but not limited to documents downloaded from the Bernstein hard drive. 6. By May 1, 2015, Messrs Oberlander and Lerner shall surrender to the Court, to be placed under seal, all documents in their possession, custody, or control, and any work product derived therefrom, that they obtained from Bernstein or his counsel, including but not limited to documents downloaded from the Bernstein hard drive. Messrs Oberlander and Lerner shall neither maintain a copy of, nor disseminate, any of these documents. 7. Provided that they timely comply with paragraph 6, by May 5, 2015, Messrs Oberlander and Lerner may explain, in writing, why the materials surrendered should be returned. Opposing counsel may respond to any such submission by May 12, 2015. 8. By May 14, 2015, any objections to this order shall be submitted to Judge Schofield. Counsel are cautioned, however, that any objections will not stay the deadlines stated herein, nor shall the Court grant any such stays or extensions. (Signed by Magistrate Judge Frank Maas on 4/30/2015) (lmb) (Entered: 04/30/2015)
LETTER addressed to Magistrate Judge Frank Maas from Robert S. Wolf, Esq. dated April 29, 2015 re: Objection to Frederick Oberlander's Request for Extension of Time to Comply with Court's Order. Document filed by Felix Sater.(Wolf, Robert) (Entered: 04/29/2015)
ORDER: It is hereby ORDERED that a status conference shall be held on April 14, 2015, at 11:30 a.m., in Courtroom 20A. Procedural and scheduling issues for both matters will be addressed at the conference. In the interim, no further papers shall be served or filed., ( Status Conference set for 4/14/2015 at 11:30 AM in Courtroom 20A, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Frank Maas.) (Signed by Magistrate Judge Frank Maas on 3/27/2015) (lmb) (Entered: 03/27/2015)
ORDER denying 77 Motion to Set Aside: ORDERED that the Motion to unseal the Complaint in Kriss II is DENIED pending Judge Maas order or recommendation on how the matter should proceed, consistent with this Courts adoption of the Report and Recommendation dated January 14, 2015, in Kriss I. The Clerk of Court is directed to close the motion at Dkt. No. 77. (Signed by Judge Lorna G. Schofield on 03/23/2015) (jcs) (Entered: 03/23/2015)
LETTER addressed to Magistrate Judge Frank Maas from Robert S. Wolf dated December 4, 2014 re: Request for Immediate Conference. Document filed by Felix Sater.(Wolf, Robert) (Entered: 12/04/2014)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated 12/2/2014 re: This Court can no longer indulge Plaintiffs' counsel, who are also the subject of civil contempt proceedings and a separate criminal investigation for contempt. The pendency of these frivolous incendiary claims against Mr. Sater continues to cause him to suffer substantial harm, financial and otherwise. We respectfully request the Court's immediate intervention. ENDORSEMENT: Application denied. This case has been referred to Judge Maas for all general non-dispositive pre-trial matters, and all correspondence should directed to Judge Maas, unless they pertain to issues beyond the scope of Judge Maas' jurisdiction, pursuant to 26 U.S.C. 636. (Signed by Judge Lorna G. Schofield on 12/3/2014) (djc) (Entered: 12/04/2014)
ORDER denying 95 Letter Motion for Extension of Time because the text demonstrates that this letter is not, in fact, a separate motion, but a reply in further support of the letter motion previously docketed as ECF No. 93, which motion was granted by memo endorsement on August 19, 2014. (See ECF No. 96). Counsel should also note that my Individual Practices permit the filing of letters, but not the electronic filing of Letter Motions. (See paragraph 1.A.) (Maas, Frank) (Entered: 12/03/2014)
LETTER addressed to Judge Lorna G. Schofield from Robert Wolf dated 12/02/2014 re: Request for Immediate Conference. Document filed by Felix Sater.(Wolf, Robert) (Entered: 12/02/2014)
ORDER granting 93 Letter Motion for Extension of Time. Application granted. The time for service of the summons and complaint is extended sine die. (Signed by Magistrate Judge Frank Maas on 8/19/2014) (lmb) (Entered: 08/20/2014)
LETTER MOTION for Extension of Time reply as to ECF 93, in reply to Robert Wolf's letter of 8/19/14 addressed to Magistrate Judge Frank Maas from Richard E. Lerner dated 8/19/14. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Lerner, Richard) (Entered: 08/19/2014)
LETTER RESPONSE to Motion addressed to Magistrate Judge Frank Maas from Robert S. Wolf dated 8/19/2014 re: 93 LETTER MOTION for Extension of Time to serve a summons and complaint in this matter, as otherwise provided by FRCP 4, addressed to Magistrate Judge Frank Maas from Richard E. Lerner, Esq. for Plaintiffs dated August 15, 2014. . Document filed by Felix Sater. (Wolf, Robert) (Entered: 08/19/2014)
LETTER MOTION for Extension of Time to serve a summons and complaint in this matter, as otherwise provided by FRCP 4, addressed to Magistrate Judge Frank Maas from Richard E. Lerner, Esq. for Plaintiffs dated August 15, 2014. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Lerner, Richard) (Entered: 08/15/2014)
NOTICE OF APPEARANCE by Richard E. Lerner on behalf of Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Lerner, Richard) (Entered: 08/15/2014)
LETTER addressed to Magistrate Judge Frank Maas from Robert S. Wolf dated 8/13/2014 re: Access to Amended Complaint. Document filed by Felix Sater.(Wolf, Robert) (Entered: 08/13/2014)
LETTER addressed to Judge Lorna G. Schofield from Counsels for Plaintiffs Frederick M. Oberlander and Richard E. Lerner dated July 1, 2014 re: Reply to Bayrock defendants' letter of June 30, 2014 objecting to plaintiffs' use of public documents in ECF 83 and elsewhere.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 07/01/2014)
88
Filed: 6/28/2014, Entered: None
REPLY AFFIRMATION of counsels for plaintiffs in Support re: 77 MOTION to Set Aside Magistrate's order on 10-cv-3905 ECF 68 insofar as it seals the initial complaint in this action.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Attachments: # 1 Exhibit Video of Access to 3905 docket mirror site., # 2 Exhibit Items filed in Delaware Chancery by Bayrock defendants 4154-vcs, # 3 Exhibit Document 51)(Oberlander, Frederick) (Entered: 06/28/2014)
REPLY MEMORANDUM OF LAW in Support re: 77 MOTION to Set Aside Magistrate's order on 10-cv-3905 ECF 68 insofar as it seals the initial complaint in this action. . Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone). (Oberlander, Frederick) (Entered: 06/27/2014)
REPLY MEMORANDUM OF LAW in Opposition re: 66 MOTION to Seal Document Substitute Complaint filed by dropbox and time stamp pending further direction of the Court. There is a PACER/ECF defect here. Defendant Sater improperly filed a motion as a letter on June 11, 2014, ECF 76, and ECF will not allow upload of this document, which is a combined affirmation and memorandum of law in opposition thereto, because it was not coded as a motion. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone). (Oberlander, Frederick) (Entered: 06/25/2014)
MEMO ENDORSEMENT on re: (82 in 1:13-cv-03905-LGS-FM) Letter,, filed by Bayrock Group LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Bayrock Spring Street LLC, J. Kriss, Michael Ejekam, (77 in 1:10-cv-03959-LGS-FM) Letter, filed by BayRock Spring Street LLC, Jody Kriss, BayRock Whitestone LLC, Michael Ejekam. ENDORSEMENT: Plaintiffs may file one reply in support of its motion in both actions, not to exceed five pages double-spaced, with 12-point font and at least one-inch margins. Any reply shall be filed no later than June 27, 2014. (Signed by Judge Lorna G. Schofield on 6/25/2014) (kgo) (Entered: 06/25/2014)
LETTER addressed to Judge Lorna G. Schofield from Counsels for Plaintiffs Frederick M. Oberlander and Richard E. Lerner dated June 25, 2014 re: Response to Defendant Sater's allegation that voluntarily filing in expedited timing a reply to a motion is sanctionable abuse of process.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments.(Oberlander, Frederick) (Entered: 06/25/2014)
LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated 6/25/2014 re: Plaintiffs' Counsel's June 24th letter. Document filed by Felix Sater.(Wolf, Robert) (Entered: 06/25/2014)
LETTER addressed to Judge Lorna G. Schofield from Counsels for Plaintiffs Frederick M. Oberlander and Richard E. Lerner dated June 24, 2014 re: Proposed expedited schedule for filing and serving reply to defendants' response in opposition to non-dispositive magistrate's order by June 27, 2014. Document filed by Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone).(Oberlander, Frederick) (Entered: 06/24/2014)
AFFIRMATION of Robert S. Wolf in Opposition re: 77 MOTION to Set Aside Magistrate's order on 10-cv-3905 ECF 68 insofar as it seals the initial complaint in this action.. Document filed by Felix Sater. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Wolf, Robert) (Entered: 06/23/2014)
RESPONSE in Opposition to Motion re: 77 MOTION to Set Aside Magistrate's order on 10-cv-3905 ECF 68 insofar as it seals the initial complaint in this action. . Document filed by Felix Sater. (Wolf, Robert) (Entered: 06/23/2014)
79
Filed: 6/16/2014, Entered: None
ORDER: WHEREAS, Plaintiffs filed a motion for relief from Magistrate Judge Maas's orders in each of the above cases, on June 15, 2014, and June 16, 2014, respectively. It is hereby ORDERED that no later than June 23, 2014, Defendants shall file a response to Plaintiffs' motion. ( Responses due by 6/23/2014) (Signed by Judge Lorna G. Schofield on 6/16/2014) (mro) (Entered: 06/17/2014)
78
Filed: 6/16/2014, Entered: None
LETTER addressed to Judge Lorna G. Schofield from Counsels Oberlander and Lerner (for Plaintiffs) dated June 16, 2014 re: Cancellation of Filing by Email in case of sealing. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Whitestone LLC, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments.(Oberlander, Frederick) (Entered: 06/16/2014)
MOTION to Set Aside Magistrate's order on 10-cv-3905 ECF 68 insofar as it seals the initial complaint in this action. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 06/16/2014)
LETTER addressed to Magistrate Judge Frank Maas from Robert S. Wolf dated 06/11/2014 re: service of existing amended complaint and briefing schedule for defendant's motion to dismiss. Document filed by Felix Sater.(Wolf, Robert) (Entered: 06/11/2014)
ORDER re: 52 Order for Initial Pretrial Conference. It is hereby ORDERED that the Court's April 28, 2014 Order (Dkt. # 52) is hereby vacated so that Judge Maas may hold the Rule 16 conference at the time and in the manner that he sees fit. The conference scheduled for June 10, 2014 is adjourned sine die. SO ORDERED. (Signed by Judge Lorna G. Schofield on 6/6/2014) (kgo) (Entered: 06/06/2014)
ORDER OF REFERENCE TO A MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Referred to Magistrate Judge Frank Maas. (Signed by Judge Lorna G. Schofield on 6/6/2014) (kgo) (Entered: 06/06/2014)
LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated June 6, 2014 re: Status Conference set for June 10, 2014. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone).(Oberlander, Frederick) (Entered: 06/06/2014)
FIRST LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated June 3,2014 re: Status Conference of June 10, 2014. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Lerner, Richard) (Entered: 06/04/2014)
LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated 6/3/2014 re: Compliance with April 28, 2014 Order. Document filed by Felix Sater.(Wolf, Robert) (Entered: 06/03/2014)
MEMORANDUM DECISION AND ORDER. For the reasons set forth in my memorandum decision and order dated May 29, 2014, in Kriss, et al. v. Bayrock Group LLC, et al., No. 10 Civ. 3959, the Clerk of the Court is directed to seal the Complaint in this action (ECF No. 51). (Signed by Magistrate Judge Frank Maas on 5/29/2014) Copies Sent By Chambers to all counsel via ECF. (rjm) (Entered: 05/30/2014)
ORDER REFERRING CASE TO A MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Specific Non-Dispositive Motion/Dispute: Issue raised in Plaintiff's May 22, 2014 letter (Dkt. Nos. 66-67). Referred to Magistrate Judge Frank Maas. Motions referred to Frank Maas. (Signed by Judge Lorna G. Schofield on 5/22/2014) (kgo) Modified on 5/22/2014 (kgo). (Entered: 05/22/2014)
INTERIM LETTER addressed to Judge Lorna G. Schofield from Counsels for Plaintiffs Oberlander and Lerner dated May 22, 2014 re: Completion of Filing Substitute Complaint under seal with redacted version for public upload. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 05/22/2014)
FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - MOTION to Seal Document Substitute Complaint filed by dropbox and time stamp pending further direction of the Court. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) Modified on 5/23/2014 (db). (Entered: 05/22/2014)
LETTER addressed to Judge Lorna G. Schofield from Counsels for Plaintiffs Frederick M. Oberlander and Richard E. Lerner dated May 13, 2014 re: Reponse to improperly undocketed non-ECF letter of May 12, 2014 by non-party non-intervenor Walter Saurack seeking relief although devoid of standing to do so by his refusal to appear.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 05/13/2014)
ORDER OF REFERENCE TO A MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Specific Non-Dispositive Motion/Dispute (including discovery dispute): Issue raised in Bayrock Defendants' May 12 letter. Referred to Magistrate Judge Frank Maas. (Signed by Judge Lorna G. Schofield on 5/13/2014) (kgo) Modified on 5/14/2014 (kgo). (Entered: 05/13/2014)
ORDER denying 53 Motion for Reconsideration ; denying 59 Motion for Reconsideration. For the reasons stated above, Plaintiffs' Motion for Reconsideration is DENIED. The Clerk of the Court is directed to close the motion at Docket Nos. 53 and 59. Plaintiffs assert that the Complaint they filed to comply with the April 17 Order is not the complaint they would have filed, but for Defendants' alleged criminal misconduct. It is ORDERED that no later than May 21, 2014, Plaintiffs shall file either: (i) an amended complaint that Plaintiffs believe is sufficient for purposes of Rules 8 and 9(b) of the Federal Rules of Civil Procedure; or (ii) a letter advising the Court of their intent to stand by their currently operative Complaint at Docket No. 51. It is further ORDERED that Defendants' application for the June 10, 2014, conference to be advanced to an earlier date is DENIED. Counsel are directed to confer with each other prior to the conference regarding each of the matters to be considered at a Fed. R. Civ. P. 16 conference. Additionally, in accordance with the Court's Individual Rules, the parties are hereby ORDERED to file via ECF a Joint Proposed Civil Case Management Plan and Scheduling Order in PDF format no later than June 3, 2014, using the form available at the Court's website (http://nysd.uscourts.gov/judge/Schofield). The Court declines Plaintiffs' suggestion that it sua sponte recuse itself. (Signed by Judge Lorna G. Schofield on 5/8/2014) (kgo) (Entered: 05/08/2014)
LETTER addressed to Judge Lorna G. Schofield from Counsels Frederick M. Oberlander and Richard E. Lerner dated May 5, 2014 re: May 2, 2014 letter from counsel for Sater.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 05/05/2014)
AMENDED MOTION for Reconsideration re; 49 Order,,,, 53 MOTION for Reconsideration of order 49. THIS IS A CORRECTING FILING (UPLOAD) PURSUANT TO REJECTION BY ECF QUALITY ASSURANCE. THIS IS THE MOTION FOR RECONSIDERATION FILED MAY 1, 2014 WHICH HAD NON-SUBSTANTIVE ERRORS INCLUDING A PDF TRANSLATION OR CONVERSION ERROR IN EXHIBIT 5 DUE TO EUROPEAN/AMERICAN PAGING DIFFERENCES WHICH TRIGGERED A DEFECTIVE FILING NOTICE UPON INITIAL CORRECTION AND AN OMISSION FROM EXH. 3.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Ervin Tausky. (Attachments: # 1 Exhibit Exh. 1 Original Version of QueensPolitics.com May 13, 2014, # 2 Exhibit Exh. 2 Complaint in Lauria v. Kriss (N.Y.Sup.Ct. 152324/2014), # 3 Exhibit Exh. 3 Screen capture of jodykrissthief.com plus ICANN registration showing site owned by Felix Sater, # 4 Exhibit Exh. 4 Attachment to email sent Ejekam et al. April 5-7 2014 listing all sites caused to republish, # 5 Affidavit Exh. 5 Affidavit of Ejekam (motion requests leave to file same pursuant to Local Rule 6.3), # 6 Exhibit Exh. 6 Cover Sheet to original state court action herein)(Oberlander, Frederick) (Entered: 05/02/2014)
LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated May 2, 2014 re: newly filed class action complaint. Document filed by Felix Sater.(Wolf, Robert) (Entered: 05/02/2014)
FILING ERROR - DEFICIENT DOCKET ENTRY - FILER ERROR - LETTER addressed to Judge Lorna G. Schofield from Robert S. Wolf dated May 2, 2014 re: newly filed class action complaint. Document filed by Bayrock Group LLC.(Wolf, Robert) Modified on 5/6/2014 (lb). (Entered: 05/02/2014)
FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIDAVIT of Michael Chudi Ejekam in Support re: 53 MOTION for Reconsideration of order 49.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Oberlander, Frederick) Modified on 5/2/2014 (db). (Entered: 05/02/2014)
FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - MOTION to Amend/Correct This is a correction to Exh. 3 of ECF 53. This is the correct document the previously uploaded document was in error.. Document filed by Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Attachments: # 1 Exhibit Corrected Exh. 3 to ECF 53)(Oberlander, Frederick) Modified on 5/2/2014 (db). (Entered: 05/02/2014)
Vacated as per Judges Order dated 6/6/2014, Doc. #75 ORDER: Initial Conference set for 6/10/2014 at 10:45 AM in Courtroom 1106 of the United States District Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, NY 10007 before Judge Lorna G. Schofield. (Signed by Judge Lorna G. Schofield on 4/28/2014) (kgo) Modified on 6/9/2014 (kgo). (Entered: 04/28/2014)
CLASS ACTION COMPLAINT against Akerman Senterfitt LLP, Tevfik Arif, Bayrock Camelback LLC, Bayrock Group Inc., Bayrock Group LLC, Bayrock Merrimac LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, Michael Beys, Beys Stein & Mobargha LLP, Craig Brown, John Does 1-100, Sapir Does 1-100, Mel Dogan, Martin Domb, Duval & Stachenfeld LLP, Adam Gilbert, David Granin, Brian Halberg, IStar Financial, Salvatore Lauria, Lender Investor Does 1-100, Nader Mobargha, Kelly Moore, Morgan Lewis & Bockius LLP, National Union Fire Insurance Co. of Pittsburgh, PA, Nixon Peabody LLP, Elliot Pisem, Roberts & Holland LLP, Alex Salomon, Salomon & Co. PC, Michael Samuel, Alex Sapir, Tamir Sapir, Felix Sater, Satterlee Stephens Burke & Burke LLP, Walter Saurack, Julius Schwarz, Bruce Stachenfeld, Jerry Weinrich. Document filed by Bayrock Whitestone LLC, J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), E/O Judit Gottdiener, Ervin Tausky, Bayrock Spring Street LLC, Michael Ejekam(alone), E/O Ernest Gottdiener, Suan Investments, Bayrock Camelback LLC, Michael Ejekam(for Bayrock Merrimac LLC), Bayrock Group LLC.(laq) (laq). (Entered: 04/25/2014)
ORDER: WHEREAS, the Court has reviewed Plaintiffs' ex parte letter of April 7, 2014; Plaintiffs' publicly filed letter of April 7, 2014 (Dkt. No. 42); Defendants' letter of April 14, 2014; Plaintiffs letter of April 14, 2014; and Defendants' letter of April 15, 2014. It is hereby ORDERED that the allegations raised in Plaintiffs' ex parte letter shall be raised, if at all, with the appropriate authorities, and not with the Court. It is further ORDERED that Plaintiffs' request for a further stay sine die is DENIED. It is further ORDERED that Plaintiffs shall file a complaint in this action no later than April 23, 2014. Should Plaintiffs fail to do so, the Court will entertain any motions to dismiss for failure to prosecute, which Defendants may file without exchanging letters with Plaintiffs pursuant to the Court's Individual Rule III.A.3. It is further ORDERED that the parties shall file all future written communications with the Court via ECF. They are not to exceed two pages, and shall be double-spaced, in 12-point font, and have one-inch margins. Any communications submitted in violation of this paragraph will be rejected unread. (Signed by Judge Lorna G. Schofield on 4/17/2014) (kgo) (Entered: 04/17/2014)
LETTER addressed to Judge Lorna G. Schofield from Nader Mobargha dated 4/15/2014 re: On behalf of Defendants Felix Sater and Salvatore Lauria, we respectfully object to Plaintiffs' letter, dated April 14, 2014, in which they state that they intend to submit yet another unauthorized letter on a non-issue. Document filed by Salvatore Lauria, Felix Sater.(kgo) (Entered: 04/17/2014)
LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander dated 4/14/2014 re: We have received opposing counsels response to our request for emergency relief. Unfortunately, we are now shutting down for religious observance and so will not be able to respond in more detail until Thursday morning. Document filed by Plaintiffs.(kgo) (Entered: 04/17/2014)
LETTER addressed to Judge Lorna G. Schofield from Nader Mobargha dated 4/14/2014 re: On behalf of Defendants Felix Sater and Salvatore Lauria, we respectfully submit this letter in response to your order, dated April 8, 2014, directing us to "address[] the issues raised in Plaintiffs' [April 7, 2014] ex-parte letter.". Document filed by Salvatore Lauria, Felix Sater.(kgo) (Entered: 04/17/2014)
STATUS REPORT. AFFIRMATION OF SERVICE OF Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone).(Oberlander, Frederick) (Entered: 04/10/2014)
MEMO ENDORSEMENT on re: 42 Letter, filed by Bayrock Group LLC, E/O Judit Gottdiener, J. Kriss, Bayrock Whitestone LLC, E/O Ernest Gottdiener, Bayrock Spring Street LLC, Bayrock Camelback LLC, Michael Ejekam. ENDORSEMENT: Because defense counsel needs to be able to discuss the substance of Plaintiffs' April 7, 2014, ex parte letter with their client in order to meaningfully respond, Plaintiffs' application to designate the ex parte letter "attorneys eyes only" is DENIED. Defense counsel may discuss and show the letter to their client, but shall not provide a copy of the letter. In accordance with the Court's April 8, 2014, order, Plaintiffs shall serve a copy of the April 7 letter upon Defendants immediately, or may serve and file a copy of the Complaint as previously ordered. Within five days of receipt, Defendants shall file a letter response addressing the issues raised in Plaintiff's letter. (Signed by Judge Lorna G. Schofield on 4/10/2014) (ajs) Modified on 4/11/2014 (ajs). (Entered: 04/10/2014)
ORDER: WHEREAS, on April 8, 2014, the Court received an ex parte letter from Plaintiffs seeking emergency relief. It is hereby ORDERED that the deadline to file a complaint in this action is adjourned sine die, pending the Courts resolution of the issues raised in Plaintiffs ex parte letter. It is further ORDERED that Plaintiffs shall immediately serve a copy of the ex parte letter upon Defendants. Within five days of receipt, Defendants shall file a letter response addressing the issues raised in Plaintiffs letter. (Signed by Judge Lorna G. Schofield on 4/8/2014) (cd) (Entered: 04/08/2014)
EMERGENCY LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated 4/7/14 re: Addendum to Emergency Ex Parte Request to Stay or Enlarge and for Other Relief. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone).(Oberlander, Frederick) (Entered: 04/07/2014)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated 3/25/2014 re: The plaintiffs request a 10-day enlargement of time to file the complaint, pursuant to FRCP 6. Good cause is shown. ENDORSEMENT: Application granted. Plaintiffs shall file the complaint no later than April 7, 2014. No further extensions will be granted absent extraordinary circumstances. (Signed by Judge Lorna G. Schofield on 3/26/2014) (ft) (Entered: 03/26/2014)
OPINION AND ORDER re: 21 INTERIM MOTION to Remand In Respect of ECF No. 9 filed by Bayrock Group LLC, E/O Judit Gottdiener, J. Kriss, Bayrock Whitestone LLC, E/O Ernest Gottdiener, Bayrock Spring Street LLC, Bayrock Camelback LLC, Michael Ejekam, 25 FINAL MOTION to Remand to State Court filed by Ervin Tausky, Bayrock Group LLC, E/O Judit Gottdiener, J. Kriss, Suan Investments, Bayrock Whitestone LLC, E/O Ernest Gottdiener, Bayrock Spring Street LLC, Bayrock Camelback LLC, Michael Ejekam. For the reasons set forth above, Plaintiffs motion to remand is DENIED. The Clerk of Court is directed to close the motions at docket numbers 21 and 25. Plaintiffs are ordered to file their complaint in this case by March 26, 2014. (Signed by Judge Lorna G. Schofield on 2/24/2014) (cd) (Entered: 02/25/2014)
STANDING ORDER M10-468: Stay of Certain Civil Cases Pending the Restoration of Department of Justice Funding. (Signed by Judge Loretta A. Preska on 10/1/2013) ***Original Standing Order docketed in case no. 1:13-mc-00334-LAP, document no. 2 on 10/1/2013.***(tro) (Entered: 10/01/2013)
LETTER addressed to Judge Lorna G. Schofield from Oberlander and Lerner dated September 9, 2013 re: Enlargement of time to file and serve complaint; request for pre-motion conference re FRCP 21; request to preserve the status quo ante while the court is deciding jurisdiction.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 09/09/2013)
FIRST LETTER addressed to Judge Lorna G. Schofield from Oberlander and Lerner dated September 4, 2013 re: Compliance with Individual Rules re filing a document non-publicly. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 09/04/2013)
FIRST MOTION for Discovery *** THIS IS REQUEST TO TAKE JUDICIAL NOTICE THERE IS NO PACER CODE CORRESPONDING TO THAT ***. Document filed by Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone). (Attachments: # 1 Exhibit Transcript of sentencing of Felix Sater, October 23, 2009, # 2 Exhibit Cooperation agreement, 1998, of Felix Sater., # 3 Exhibit Press release of March 2, 2000 publicizing conviction of Felix Sater, # 4 Exhibit Material from US v Coppa Confirming Public Disclosure of Felix Sater as Cooperator Over a Decade Ago, # 5 Exhibit July 20, 2010 transcript of hearing in 98-cr-1101, # 6 Exhibit Material From US v Gushlak wherein Government Withheld 5K1 Because Gushlak fraudulently concealed his conviction as Felix Sater did, # 7 Exhibit Deposition of Felix Sater March 9, 2010 in Bernstein v Bayrock Group LLC Westchester Supreme Court, # 8 Exhibit Material from US v Lauria, 98-cr-1102., # 9 Exhibit Material from US v Felix Sater 98-CR-1101 as to Plea and Sentencing, # 10 Exhibit Order of Judge Glasser March 15, 2010 confirming Sater's Oct 23, 2009 sentencing was held in open court where his name was read aloud., # 11 Exhibit Press Coverage on and after March 2, 2012,, # 12 Exhibit Entire docket of 98-CR-1101.)(Oberlander, Frederick) (Entered: 09/02/2013)
Attachment 8 Exhibit Material from US v Lauria, 98-cr-1102
AMENDED REPLY MEMORANDUM OF LAW in Support re: 25 FINAL MOTION to Remand to State Court. This is a CORRECTED filing to remedy errors in PDF creation re initial upload including inability to attach all exhibits because of file sizes.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Attachments: # 1 Exhibit Felix Sater's October 23, 2009 Sentencing Transcript, # 2 Exhibit Felix Sater's December 10, 1998 Cooperation Agreement, # 3 Exhibit USAO, FBI, NYPD Joint March 2, 2000 Press Release Publicizing Felix Sater's RICO Conviction, # 4 Exhibit Material from US v Coppa Confirming Public Disclosure of Felix Sater as Cooperator Over a Decade Ago, # 5 Exhibit Transcript of Hearing Before the Hon. I. Leo Glasser in which the court states Felix Sater was never under any court order to hide his cooperation, # 6 Exhibit Material From US v Gushlak wherein Government Withheld 5K1 Because Gushlak fraudulently concealed his conviction as Felix Sater did, # 7 Exhibit Deposition March 9 2010 of Felix Sater in which he states he was advised not to answer whether he had been convicted of crime besides First Degree Assault on grounds that answering (and presumably telling the truth about his RICO conviction) might incriminate him)(Oberlander, Frederick) (Entered: 08/30/2013)
Attachment 1 Exhibit Felix Sater's October 23, 2009 Sentencing Transcript
Attachment 3 Exhibit USAO, FBI, NYPD Joint March 2, 2000 Press Release Publicizing Felix Sater's RICO Conviction
LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated 8/28/2013 re: Pursuant to this Court's Rules of Individual Practice III(B)7, as all briefs have now been ECF filed, thus automatically served, we request oral argument. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(lmb) (Entered: 08/30/2013)
FIRST REPLY MEMORANDUM OF LAW in Support re: 25 FINAL MOTION to Remand to State Court.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Oberlander, Frederick) (Entered: 08/28/2013)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander dated 8/19/2013 re: Accordingly, we most respectfully reserve the right to move to unseal anything that has been sealed in response to counsel's request, and disclaim any waiver or implied consent to any such sealing. ENDORSEMENT: Plaintiff is granted leave to submit a reply in support of the Motion for Remand no later than August 27, 2013. (Signed by Judge Lorna G. Schofield on 8/20/2013) (rdz) (Entered: 08/21/2013)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Joshua D. Liston dated 8/16/2013 re: Defendant is granted leave to file Exhibit 1 in redacted form and Exhibit 5 as it appears in the public record. Plaintiff's Request for Judicial Notice (Dkt. No. 28) is DENIED as moot. The Clerk is directed to close the motion at docket number 28. Motion terminated. (Signed by Judge Lorna G. Schofield on 8/20/2013) (rdz) Modified on 8/23/2013 (rdz). (Entered: 08/21/2013)
LETTER addressed to Judge Lorna G. Schofield from Joshua D. Liston dated 8/19/2013 re: We represent defendant Felix Sater in the above-referenced action and write in response to Plaintiffs Request for Judicial Notice, filed this morning on ECF (Dkt. No. 28), which is a response to my e-mailed letter of August 16, 2013, asking for permission to file two documents either in redacted form or wholly under seal. Document filed by Felix Sater.(rdz) (Entered: 08/21/2013)
FIRST MOTION Request for Judicial Notice, FRE 201 re: 27 Memorandum of Law in Opposition to Motion, 25 FINAL MOTION to Remand to State Court.. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Attachments: # 1 Exhibit Document 100 in U.S. v. Sater, 98-CR-1101 EDNY (Glasser, J.))(Oberlander, Frederick) (Entered: 08/19/2013)
Attachment 1 Exhibit Document 100 in U.S. v. Sater, 98-CR-1101 EDNY (Glasser, J.
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Joshua D. Liston dated 8/13/2013 re: We respectfully request that the Court modify the briefing schedule so that any opposition to the motion will be filed no later than August 16, 2013, and any reply will be due August 23, 2013. ENDORSEMENT: Application granted. Any opposition to the Motion for Remand shall be filed by August 16, 2013. Any reply shall be filed by August 23, 2013., ( Responses due by 8/16/2013., Replies due by 8/23/2013.) (Signed by Judge Lorna G. Schofield on 8/14/2013) (lmb) (Entered: 08/15/2013)
FINAL MOTION to Remand to State Court. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 08/02/2013)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard E. Lerner dated 7/29/13 re: Counsel writes to request a two day extension of time to file their motion for remand. ENDORSEMENT: Application granted. Plaintiffs' motion for remand shall be filed no later than August 1, 2013. Any response is due August 15, 2013, and any reply is due August 22, 2013. ( Motions due by 8/1/2013., Responses due by 8/15/2013, Replies due by 8/22/2013.) (Signed by Judge Lorna G. Schofield on 7/30/2013) (mro) (Entered: 07/30/2013)
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 7/16/2013 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 07/24/2013)
TRANSCRIPT of Proceedings re: CONFERENCE held on 7/16/2013 before Judge Lorna G. Schofield. Court Reporter/Transcriber: Rose Prater, (212) 805-0300. 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. Redaction Request due 8/19/2013. Redacted Transcript Deadline set for 8/29/2013. Release of Transcript Restriction set for 10/25/2013.(McGuirk, Kelly) (Entered: 07/24/2013)
INTERIM MOTION to Remand In Respect of ECF No. 9. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone).(Oberlander, Frederick) (Entered: 07/22/2013)
LETTER addressed to Judge Lorna G. Schofield from Richard E. Lerner dated 7/15/2013 re: Counsel submit this on behalf of Plaintiffs and Defendant Sater pursuant to this Court's 7/2/2013 and 7/8/2013 orders ECF Nos. 8 and 9. Document filed by Bayrock Camelback LLC, Bayrock Spring Street LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), Felix Sater, Suan Investments.(tro) (Entered: 07/17/2013)
ORDER denying 13 Motion for Reconsideration ; denying 13 Motion to Remand to State Court. It is hereby, ORDERED that Plaintiffs' Motion for Reconsideration or for Remand (Dkt. No. 13) is DENIED as moot as further set forth in this order. ORDERED that Defendants Donald Trump, Ivanka Trump, Trump Does 1-100 and CIM Group are DISMISSED pursuant to the Notice of Partial Discontinuance filed by Plaintiffs in state court on May 31, 2013. (Dkt. No. 8, Ex. B). ORDERED that Plaintiffs' contemplated motion for remand shall be filed no later than July 30, 2013. Defendants' response shall be filed no later than August 13, 2013. Plaintiffs' reply, if any, shall be filed no later than August 20, 2013. The Clerk is directed to close the motion at Docket Entry 13. The Clerk is also directed to remove Defendants Donald Trump, Ivanka Trump, Trump Does 1-100 and CIM Group as parties in this matter. (Signed by Judge Lorna G. Schofield on 7/16/2013) (lmb) (Entered: 07/16/2013)
NOTICE OF APPEARANCE by Frederick Martin Oberlander on behalf of E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Oberlander, Frederick) (Entered: 07/10/2013)
AFFIDAVIT OF SERVICE of Order dated July 2, 2013 (Dkt. 11) served on All Parties on 7/3/13. Service was made by MAIL. Document filed by Felix Sater. (Liston, Joshua) (Entered: 07/10/2013)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander and Richard Lerner dated 7/8/2013 re: Request for pre-motion conference in re motion to remand or to sever. ENDORSEMENT: A pre-motion conference is not required for a motion to remand (see Individual Rule III.A.3). Plaintiffs' may raise the contemplated motion to remand at the initial pretrial conference scheduled for July 16, 2013. The parties are directed to review and comply with Individual Rule III.A.3, which requires the parties to exchange letters prior to the filing of a motion to remand. In addition, counsel for Plaintiffs are advised that letters to Chambers shall not exceed two pages in length, and pre-motion letters to Chambers shall not exceed three pages in length, including any attachments, per the Court's individual rules. (Signed by Judge Lorna G. Schofield on 7/9/2013) (lmb) (Entered: 07/09/2013)
ENDORSED LETTER addressed to Judge Lorna G. Schofield from Joshua D. Liston dated 7/8/2013 re: We respectfully request that the July 16, 2013 conference be adjourned and that the parties be relieved of submitting the Proposed Case Management Plan in advance of that date. ENDORSEMENT: With respect to Kriss et al. v. Bayrock Group LLC, et al., No. 13-cv-3905, it is hereby ORDERED that the parties need not submit a Proposed Case Management Plan and Scheduling Order prior to the scheduled initial pretrial conference, but should submit a joint status letter as previously ordered. It is further ORDERED that the initial pretrial conference will be held as scheduled, on July 16, 2013, at 10:30 a.m. Counsel for all parties who have been served are directed to enter an appearance on ECF prior to the conference. (Signed by Judge Lorna G. Schofield on 7/9/2013) (lmb) (Entered: 07/09/2013)
AFFIDAVIT OF SERVICE of Order ECF 45 and Individual Rules served on Five (5) entity defendants through counsel Walter Saurack on July 9, 2013. Service was made by MAIL and electronic. Document filed by E/O Ernest Gottdiener, E/O Judit Gottdiener, J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky. (Oberlander, Frederick) (Entered: 07/09/2013)
FIRST MOTION for Reconsideration re; 1 Notice of Removal In Respect of ECF No. 9., FIRST MOTION to Remand to State Court In Respect of ECF No. 1. Document filed by E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments, Ervin Tausky.(Oberlander, Frederick) (Entered: 07/08/2013)
ORDER: This case has been assigned to me for all purposes. It is hereby ORDERED that counsel for all parties appear for an initial pretrial conference with the Court at the time and place listed below. All pretrial conferences must be attended by the attorney who will serve as principal trial counsel. Any open legal issues can be addressed at the conference. DATE AND PLACE OF CONFERENCE: July 16, 2013, at 10:30 a.m., before Judge Lorna G. Schofield in Courtroom 1106 of the United States District Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, New York. SO ORDERED. (Signed by Judge Lorna G. Schofield on 7/2/2013) (rsh) (Entered: 07/03/2013)
AFFIDAVIT OF SERVICE served on Plaintiffs and co-Defendants on 6/24/13. Service was made by MAIL. Document filed by Felix Sater. (Mobargha, Nader) (Entered: 07/02/2013)
ORDER: that this action is dismissed without prejudice solely as against Defendant Kaminsky. This dismissal shall be without effect on Plaintiffs claims against any other defendant. SO ORDERED.Todd Kaminsky terminated. (Signed by Judge Lorna G. Schofield on 6/25/2013) (rsh) (Entered: 06/25/2013)
NOTICE OF REMOVAL from Supreme Court, County of New York. Case Number: 651715-13. Document filed by Felix Sater. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(tro) (Entered: 06/25/2013)
LETTER addressed to Judge Lorna G. Schofield from Frederick M. Oberlander dated 6/17/2013 re: Counsel for plaintiffs request that the Court sign our attached proposed order confirming the action has remained in state court, where since 2:30 p.m. June 5, 2013 Mr. Kaminsky has with finality ceased to be defendant by our voluntary dismissal of him as of right. Document filed by Bayrock Camelback LLC, Bayrock Group LLC, Bayrock Spring Street LLC, Bayrock Whitestone LLC, E/O Ernest Gottdiener, E/O Judit Gottdiener, Michael Ejekam(alone), Michael Ejekam(for Bayrock Merrimac LLC), J. Kriss(for Bayrock Merrimac LLC), J. Kriss(alone), Suan Investments.(rsh) (Entered: 06/24/2013)
LETTER addressed to Judge Lorna G. Schofield from Nader Mobargha dated 6/21/2013 re: Counsel for defendant Felix Sater respectfully submit that this Court enter an order dismissing AUSA Kaminskly from the case. Any further consideration of remand is now moot, absent a formal motion addressing Sater's Notice of Removal. Document filed by Felix Satter.(rsh) (Entered: 06/24/2013)
LETTER addressed to Judge Lorna G. Schofield from Jessica Jean Gu dated 6/14/2013 re: This Office represents Assistant United States Attorney Todd Kaminsky (AUSA Kaminsky) of the Eastern District of New York who was named as a defendant in a Summons with Notice that was filed in the Supreme Court of the State of New York, County of New York on May 10, 2013. On June 7, 2013, this Office removed the case to this Court where it was assigned docket number 13 Civ. 3905. Although the case has yet to be assigned, it has been referred to Your Honor as potentially related to Kriss, et al. v. Bayrock Group LLC, et al., 10 Civ. 3959 (LGS). This Office writes to request that the Court endorse the attached proposed order which: (1) dismisses without prejudice AUSAKaminsky as a defendant to the instant action; and (2) pursuant to 28 U.S.C. 1447(c), remands the case to the Supreme Court of the State of New York, County of New York. Document filed by Todd Kaminsky. (rsh) (Entered: 06/24/2013)
LETTER addressed to Judge Lorna G. Schofield from Nader Mobargha dated 6/14/2013 re: We represent defendant Felix Sater in the above-referenced actions and write in response to the government's letter of this date seeking an order (1) dismissing Assistant U.S. Attorney Todd Kaminsky as a defendant; and (2) remanding the case, pursuant to 28 U.S.C. 1447(c), to the New York Supreme Court Although we do not oppose Mr. Kaminsky's dismissal as a defendant, we believe that Mr. Sater also has a valid basis to remove the action to federal court. Accordingly, we would request an opportunity to submit removal papers on his behalf and oppose the application to remand, by no later than June 21, 2013. Document filed by Felix Satter.(rsh) (Entered: 06/24/2013)
CERTIFICATE OF SERVICE of Notice of Removal served on All Parties Named in Summons on June 7, 2013. Service was made by Fed Ex. Document filed by Todd Kaminsky. (Hu, Jessica) (Entered: 06/14/2013)
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