PAGNATOKARP PARTNERS, LLC v. Young

Federal Civil Lawsuit District Of Columbia District Court, Case No. 1:17-cv-00275
District Judge Dabney L. Friedrich, presiding
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District Judge Dabney L. Friedrich
Last Updated July 28, 2025 at 5:27 PM EDT (4.4 months ago) Update UpdateSpaceE-Mail Alert AlertsSpaceJump Jump
Summary

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Parties
No Logo Pagnatokarp Partners, LLC, Plaintiff

Represented by Clouse Dunn LLP

Name Phone Fax E-Mail
Space Richard Rogge Dunn dunn@clousedunn.com
Space Joshua J Iacuone +1 214 239 2763 +1 214 220 3833 jiacuone@clousedunn.com

Represented by FordHarrison LLP

Name Phone Fax E-Mail
Space Jacquelyn Lorraine Thompson jthompson@fordharrison.com

Represented by Ogletree, Deakins, Nash, Smoak & Stewart, PC

Name Phone Fax E-Mail
ATTORNEY TO BE NOTICED Christopher Eric Humber +1 202 887 0855 +1 202 887 0866 chris.humber@ogletreedeakins.com
Space Christopher E. Humber chris.humber@ogletree.com
a Delaware Corporation Christopher Eric Humber +1 202 887 0855 +1 202 887 0866 chris.humber@ogletreedeakins.com
v.
No Logo Samantha D. Young, Defendant

Represented by HIRSCHLER FLEISCHER, PC

Name Phone Fax E-Mail
Space Andrew P. Sherrod
Space Robert R. Vieth rvieth@hirschlerlaw.com
Attributes
Citation Section 28 U.S.C. § 1332
Nature of Suit 890 - Other Statutes: Other Statutory Actions
Jurisdiction Federal Question
Case Status closed
Jury Demand Defendant
Timeline
  Entries (43) Tab Overlap Calendar Events Tab Overlap Related (0) Tab Overlap Tools Right End
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Blank  Filed: 10/3/2018, Entered: 10/3/2018
MINUTE ORDER directing the Clerk of Court to close this case. Signed by Judge Dabney L. Friedrich on October 3, 2018. (JK)
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Legal Document (Payment Possibly Required) 26 Filed: 10/1/2018, Entered: 10/1/2018 Court Filing
ORDER granting the parties' 25 Joint Motion for Entry of Agreed Permanent Injunction and Final Order. See order for details. Signed by Judge Dabney L. Friedrich on October 1, 2018. (JK)
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Legal Document (Payment Possibly Required) 25 Filed: 9/28/2018, Entered: 9/28/2018
Joint MOTION for Permanent Injunction and, MOTION for Order and Agreed Permanent Injunction by SAMANTHA D. YOUNG (Attachments: # 1 Text of Proposed Order)(Vieth, Robert)
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Blank  Filed: 12/4/2017, Entered: 12/4/2017
Case directly reassigned to Judge Dabney L. Friedrich. Judge Tanya S. Chutkan is no longer assigned to the case. (ztnr)
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Blank  Filed: 10/4/2017, Entered: 10/4/2017
Set/Reset Deadlines: Cross Motions due by 12/20/2018. Response to Cross Motions due by 1/10/2019. Reply to Cross Motions due by 1/21/2019. Summary Judgment motions due by 11/30/2018. Response to Motion for Summary Judgment due by 12/20/2018. Reply to Motion for Summary Judgment due by 1/20/2019. (tb)
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Legal Document (Payment Possibly Required) 24 Filed: 10/3/2017, Entered: 10/3/2017 Court Filing
SCHEDULING ORDER: End of Discovery by 11/15/18. Defendant's Motion for Summary Judgment due 11/30/18. Plaintiff's Response and, if necessary, Combined Cross-Motion due 12/20/18. Defendant's Reply and, if necessary, Combined Response due 1/10/2019. Plaintiff's Reply, if necessary, due 1/21/201. The Court will view requests for extensions with disfavor. (See order for further details including the parties' obligation to meet, confer and present jointly any discovery disputes prior to filing a motion). Signed by Judge Tanya S. Chutkan on 10/3/17. (DJS)
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Legal Document (Payment Possibly Required) 23 Filed: 9/25/2017, Entered: 9/25/2017
SUPPLEMENT re 22 MEET AND CONFER STATEMENT. (Thompson, Jacquelyn) Modified event title on 9/26/2017 (znmw).
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Blank  Filed: 9/21/2017, Entered: 9/21/2017
Set/Reset Deadlines: Supplemental Joint Report of Parties' Planning Meeting due by 9/25/2017. (tb)
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Blank  Filed: 9/21/2017, Entered: 9/21/2017
MINUTE ORDER: In the parties' proposed Scheduling Order 22 , the parties request until 11/15/2018 to complete discovery. Absent from the parties' Joint Report of Parties' Planning Meeting 22 , is an explanation for the need for over one year to conduct discovery. The parties' general assertion that "[t]he parties anticipate this dispute to include a reasonable amount of discovery" is not sufficient. By 9/25/17, the parties are ordered to supplement their Joint Report with a joint submission, detailing the need for such an extended discovery period. Signed by Judge Tanya S. Chutkan on 9/21/2017. (lctsc2)
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Legal Document (Payment Possibly Required) 22 Filed: 9/12/2017, Entered: 9/12/2017
MEET AND CONFER STATEMENT. (Attachments: # 1 Text of Proposed Order Proposed Scheduling Order)(Vieth, Robert)
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Legal Document (Payment Possibly Required) 21 Filed: 9/11/2017, Entered: 9/11/2017
NOTICE of Appearance by Jacquelyn Lorraine Thompson on behalf of PAGNATOKARP PARTNERS, LLC (Thompson, Jacquelyn) (Main Document 21 replaced on 9/12/2017) (znmw).
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Blank  Filed: 8/16/2017, Entered: 8/16/2017
Set/Reset Deadlines: Revised Joint Report of the Parties' Planning Meeting due by 9/12/2017. Plaintiff has to 9/12/2017 to obtain new local counsel. (tb)
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Blank  Filed: 8/16/2017, Entered: 8/16/2017
MINUTE ORDER: Consistent with the court's 8/16/2017 ruling from the bench, Plaintiff has until 9/12/2017 to obtain new local counsel. Additionally, consistent with the court's ruling and pursuant to Rule 26(f) of the Federal Rules of Civil Procedure and Local Civil Rule 16.3, the parties have until 9/12/2017 to file a revised Joint Report of the Parties' Planning Meeting. The Report shall include a proposed Scheduling Order in a format similar to the sample Scheduling Order found on Judge Chutkan's court webpage, along with any proposed changes which shall be highlighted. On the same day that the parties file their Rule 26 report and proposed Scheduling Order, they shall also email a Word version of the proposed order to Chambers: Chutkan_chambers@dcd.uscourts.gov. In addition to the requirements under the Federal and Local Rules, the parties report shall contain a succinct summary of the case and the statutory basis for all causes of action and defenses. Signed by Judge Tanya S. Chutkan on 8/16/2017. (lctsc2)
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Blank  Filed: 8/16/2017, Entered: 8/16/2017
Minute Entry for Proceedings held before Judge Tanya S. Chutkan: Status Conference held on 8/16/2017. For the reasons stated on the record in open Court, the 12 Motion to Withdraw Appearance as Local Counsel is Granted. The appearance of Christopher E. Humber as local counsel for plaintiff is withdrawn. Counsel is directed to turn over all files to new local counsel, when obtained. It is further ORDERED that the parties are directed to file an updated Meet & Confer Statement by 9/12/2017. (Court Reporter Janice Dickman) (jth)
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Legal Document (Payment Possibly Required) 20 Filed: 8/15/2017, Entered: 8/15/2017
NOTICE OF FILING REDACTED DOCUMENT to 12 MOTION to Withdraw Appearance as Local Counsel, 13 MOTION for Leave to File Documents Under Seal For Ex Parte, In Camera Review by PAGNATOKARP PARTNERS, LLC (The original PDF Document contained privacy information and was restricted pursuant to the E-Government Act.) (Attachments: # 1 Exhibit 1)(Humber, Christopher)
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Blank  Filed: 8/15/2017, Entered: 8/15/2017
MINUTE ORDER: Movant Ogletree, Deakins, Nash, Smoak & Steward, P.C. ("Ogletree") is hereby ordered to file a more reasonably redacted version of the Declaration of Christopher E. Humber, dated May 17, 2017, by 8/15/2017 at 5:00 p.m. (ECF 13 - 2 ). Ogletree redacted every word of the Humber Declaration other than the introductory paragraph and signature page, despite the fact that much of the information contained in the heavily redacted declaration appears within Ogletree's publicly-filed briefs. Signed by Judge Tanya S. Chutkan on 8/15/2017. (lctsc2)
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Legal Document (Payment Possibly Required) 19 Filed: 8/11/2017, Entered: 8/11/2017
Joint STATUS REPORT regarding Motion to Withdraw re 12 MOTION to Withdraw Appearance as Local Counsel by PAGNATOKARP PARTNERS, LLC. (Humber, Christopher) Modified to add link on 8/14/2017 (znmw).
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Legal Document (Payment Possibly Required) 18 Filed: 8/9/2017, Entered: 8/9/2017
MEET AND CONFER STATEMENT. (Vieth, Robert)
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Blank  Filed: 8/8/2017, Entered: 8/8/2017
Set/Reset Deadlines: Joint Status Report due by 8/11/2017. (tb)
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Blank  Filed: 8/8/2017, Entered: 8/8/2017
MINUTE ORDER: By Friday, August 11, 2017 at 5 p.m., the Parties shall file a joint status report of not more than three pages informing the court of the status of the pending Motion to Withdraw 12 filed by counsel for Plaintiff. Signed by Judge Tanya S. Chutkan on 8/8/2017. (lctsc2)
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Blank  Filed: 7/26/2017, Entered: 7/26/2017
Set/Reset Hearings: Status Conference set for 8/16/2017 at 10:15 AM in Courtroom 2 before Judge Tanya S. Chutkan. (tb)
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Blank  Filed: 6/14/2017, Entered: 6/14/2017
MINUTE ORDER: A Status Conference is hereby set for 8/16/17 at 10:15 a.m. in Courtroom 2. At the status conference the court will consider the motion to withdraw 12 filed by counsel for the Plaintiff. A company representative from PAGNATOKARP PARTNERS, LLC who has legal authority to bind the company shall appear at the status conference. The Clerk of the Court shall mail a copy of this order to: PAGNATOKARP PARTNERS, LLC, 11951 Freedom Drive, No. 1260, Reston, VA 20190. Signed by Judge Tanya S. Chutkan on 6/14/17. (DJS)
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Blank  Filed: 6/14/2017, Entered: 6/14/2017
MINUTE ORDER: Denying without prejudice 7 Defendant's Motion to Dismiss the complaint, in light of the Amended Complaint filed by the Plaintiff 10 . See Barnes v. District of Columbia, 42 F. Supp.3d 111, 117 (D.D.C. 2014) ("When a plaintiff files an amended complaint as of right within 21 days after the filing of the motion to dismiss under Rule 12(b), (e), or (f), the amended complaint becomes the operative pleading... and any pending motion to dismiss becomes moot.") (citations omitted); 6 Charles Allen Wright & Arthur R. Miller, Federal Practice and Procedure ยง 1476 (3d ed. 2010) (explaining that an amended pleading "under Rule 15(a) supersedes the pleading it modifies and remains in effect throughout the action unless it subsequently is modified"). Signed by Judge Tanya S. Chutkan on 6/14/17. (DJS)
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Blank  Filed: 6/14/2017, Entered: 6/14/2017
MINUTE ORDER: Granting 8 9 Motions for Leave to Appear Pro Hac Vice. Rogge Dunn and Joshua J. Iacuone are hereby admitted pro hac vice to appear in this matter on behalf of Plaintiff. Signed by Judge Tanya S. Chutkan on 6/14/17. (DJS)
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Legal Document (Payment Possibly Required) 17 Filed: 5/31/2017, Entered: 5/31/2017
REPLY to opposition to motion re 12 MOTION to Withdraw Appearance as Local Counsel, 13 MOTION for Leave to File Documents Under Seal For Ex Parte, In Camera Review filed by PAGNATOKARP PARTNERS, LLC. (Attachments: # 1 Exhibit 2014 BAC Outside Counsel Agt, # 2 Exhibit 2017 BAC Outside Counsel Agt, # 3 Exhibit 2016 BAC SEC Form 10-K)(Humber, Christopher)
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Legal Document (Payment Possibly Required) 16 Filed: 5/26/2017, Entered: 5/26/2017
ANSWER to 10 Amended Complaint by SAMANTHA D. YOUNG. Related document: 10 Amended Complaint filed by PAGNATOKARP PARTNERS, LLC.(Vieth, Robert)
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Legal Document (Payment Possibly Required) 15 Filed: 5/24/2017, Entered: 5/24/2017
RESPONSE re 12 MOTION to Withdraw Appearance as Local Counsel, 13 MOTION for Leave to File Documents Under Seal For Ex Parte, In Camera Review filed by PAGNATOKARP PARTNERS, LLC. (Attachments: # 1 Exhibit Sines Affidavit, # 2 Exhibit Dunn Affidavit)(Humber, Christopher)
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Legal Document (Payment Possibly Required) 14 Filed: 5/19/2017, Entered: 5/19/2017
REPLY to opposition to motion re 7 MOTION to Dismiss Complaint for Failure to State a Claim Upon Which Relief Can be Granted filed by SAMANTHA D. YOUNG. (Vieth, Robert)
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Legal Document (Payment Possibly Required) 13 Filed: 5/17/2017, Entered: 5/17/2017
MOTION for Leave to File Documents Under Seal For Ex Parte, In Camera Review by PAGNATOKARP PARTNERS, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Text of Proposed Order)(Humber, Christopher)
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Legal Document (Payment Possibly Required) 12 Filed: 5/17/2017, Entered: 5/17/2017
MOTION to Withdraw Appearance as Local Counsel by PAGNATOKARP PARTNERS, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Text of Proposed Order)(Humber, Christopher)
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Legal Document (Payment Possibly Required) 11 Filed: 5/12/2017, Entered: 5/12/2017
Memorandum in opposition to re 7 MOTION to Dismiss Complaint for Failure to State a Claim Upon Which Relief Can be Granted filed by PAGNATOKARP PARTNERS, LLC. (Humber, Christopher)
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Legal Document (Payment Possibly Required) 10 Filed: 5/12/2017, Entered: 5/12/2017
AMENDED COMPLAINT against SAMANTHA D. YOUNG with Jury Demand filed by PAGNATOKARP PARTNERS, LLC.(Humber, Christopher)
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Legal Document (Payment Possibly Required) 9 Filed: 5/11/2017, Entered: 5/11/2017
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Joshua J. Iacuone, :Firm- Clouse Dunn LLP, :Address- 1201 Elm Street, Suite 5200, Dallas, TX 75270. Phone No. - (214) 220-0077. Fax No. - (214) 220-3833 Filing fee $ 100, receipt number 0090-4948737. Fee Status: Fee Paid. by PAGNATOKARP PARTNERS, LLC (Attachments: # 1 Declaration Declaration of Joshua J. Iacuone, # 2 Text of Proposed Order Proposed Order)(Humber, Christopher)
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Legal Document (Payment Possibly Required) 8 Filed: 5/11/2017, Entered: 5/11/2017
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Rogge Dunn, :Firm- Clouse Dunn LLP, :Address- 1201 Elm Street, Suite 5200, Dallas, TX 75270. Phone No. - (214) 220-0077. Fax No. - (214) 220-3833 Filing fee $ 100, receipt number 0090-4948718. Fee Status: Fee Paid. by PAGNATOKARP PARTNERS, LLC (Attachments: # 1 Declaration Declaration of Rogge Dunn, # 2 Text of Proposed Order Proposed Order)(Humber, Christopher)
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Blank  Filed: 5/3/2017, Entered: 5/3/2017
MINUTE ORDER: Granting 6 Motion for Leave to Appear Pro Hac Vice. Andrew Philip Sherrod is hereby admitted pro hac vice to appear in this matter on behalf of Defendant. Signed by Judge Tanya S. Chutkan on 5/3/17. (DJS)
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Legal Document (Payment Possibly Required) 7 Filed: 4/28/2017, Entered: 4/28/2017
MOTION to Dismiss Complaint for Failure to State a Claim Upon Which Relief Can be Granted by SAMANTHA D. YOUNG (Attachments: # 1 Memorandum in Support of Motion to Dismiss, # 2 Text of Proposed Order)(Vieth, Robert)
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Legal Document (Payment Possibly Required) 6 Filed: 4/28/2017, Entered: 4/28/2017
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Andrew P. Sherrod, :Firm- Hirschler Fleischer, PC, :Address- 2100 East Cary Street, Richmond, VA 23223. Phone No. - 804-771-9575. Fax No. - 804-644-0957 Filing fee $ 100, receipt number 0090-4932349. Fee Status: Fee Paid. by SAMANTHA D. YOUNG (Attachments: # 1 Affidavit Declaration of Andrew P. Sherrod, # 2 Text of Proposed Order)(Vieth, Robert)
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Legal Document (Payment Possibly Required) 5 Filed: 3/23/2017, Entered: 3/23/2017
WAIVER OF SERVICE by SAMANTHA D. YOUNG. SAMANTHA D. YOUNG waiver sent on 2/28/2017, answer due 4/29/2017. (Vieth, Robert)
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Legal Document (Payment Possibly Required) 4 Filed: 3/10/2017, Entered: 3/10/2017
NOTICE of Appearance by Robert R. Vieth on behalf of SAMANTHA D. YOUNG (Vieth, Robert)
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Legal Document (Payment Possibly Required) 3 Filed: 2/14/2017, Entered: 2/14/2017
SUMMONS Issued Electronically as to SAMANTHA D. YOUNG. (Attachments: # 1 Notice of Consent) (md)
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Blank  Filed: 2/13/2017, Entered: 2/14/2017
Case Assigned to Judge Tanya S. Chutkan. (md)
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Legal Document (Payment Possibly Required) 2 Filed: 2/13/2017, Entered: 2/13/2017
LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PAGNATOKARP PARTNERS, LLC (Humber, Christopher)
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Legal Document (Payment Possibly Required) 1 Filed: 2/13/2017, Entered: 2/13/2017
COMPLAINT against SAMANTHA D. YOUNG ( Filing fee $ 400 receipt number 0090-4840769) filed by PAGNATOKARP PARTNERS, LLC. (Attachments: # 1 Civil Cover Sheet, # 2 Summons Summons)(Humber, Christopher)
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