Case details

Court: cacd
Docket #: 2:11-cv-05764
Case Name: Aqua Connect v. Code Rebel LLC et al
PACER case #: 507063
Date filed: 2011-07-13
Date of last filing: 2013-08-12
Assigned to: Judge Ronald S.W. Lew
Referred to: Magistrate Judge Margaret A. Nagle
Case Cause: 28:1441 Notice of Removal
Nature of Suit: 190 Contract: Other
Jury Demand: None
Jurisdiction: Diversity

Parties

Represented Party Attorney & Contact Info
Aqua Connect
Plaintiff
a Nevada Corporation		 
Michael Karl Hagemann
Michael K. Hagemann
ATTORNEY HAS NOT CONSENTED TO ELECTRONIC SERVICE
1801 Century Park East Suite 2400
Century City, CA 90067
310-499-4695
Fax: 310-499-4796
Email: mhagemann@mkhagemann.com
ATTORNEY TO BE NOTICED
Code Rebel LLC
Defendant
a Hawaii limited liability company		 
Andres F Quintana
Quintana Law Group APC
26135 Mureau Road Suite 101
Calabasas, CA 91302
818-914-2100
Fax: 818-914-2101
Email: andres@qlglaw.com
ATTORNEY TO BE NOTICED

John M Houkom
Quintana Law Group
26135 Mureau Road
Suite 101
Calabasas, CA 91302
818-914-2100
Fax: 818-914-2101
Email: john@qlglaw.com
ATTORNEY TO BE NOTICED
Arben Kryeziu
Defendant
an individual		 
Andres F Quintana
(See above for address)
ATTORNEY TO BE NOTICED

John M Houkom
(See above for address)
ATTORNEY TO BE NOTICED
Vladimir Bickov
Defendant
an individual
Does
Defendant
1 through 300

Documents

Date Filed Document # Attachment # Short Description Long Description Upload date SHA1 hash
2011-07-13 1 0 Notice of Removal NOTICE OF REMOVAL from Superior Court of the State of California for the County of Los Angeles, case number BC462337 with conformed copy of summons and complaint, filed by Defendants Arben Kryeziu and Code Rebel LLC. Case assigned to Judge Ronald S.W. Lew, and Discovery to Magistrate Judge Margaret A Nagle. (Filing fee $ 350 Paid) (amar) (ds). 2011-08-03 02:57:38 db56c35ec3188e3b5ac5fb2df7c121fa16bb74e4
2011-07-13 2 0 Certificate/Notice of Interested Parties CERTIFICATION AND NOTICE of Interested Parties filed by Defendants Code Rebel LLC and Arben Kryeziu. (amar) (ds).
2011-07-13 3 0 Proof of Service (subsequent documents) PROOF OF SERVICE filed by Defendants Code Rebel LLC and Arben Kryeziu, re Notice of Removal, [1] and Certificate/Notice of Interested Parties, [2], Civil Cover Sheet is attached to the Notice of Removal served on 7/13/2011. (amar) (ds).
2011-07-15 4 0 Notice (Other) NOTICE filed by Defendnats Code Rebel LLC, Arben Kryeziu. Notice of Assignment to United States Magistrate Judge For Discovery (Quintana, Andres)
2011-07-20 5 0 Motion to Dismiss for Lack of Jurisdiction NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction filed by Defendants Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/17/2011 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Arben Kryeziu, # (2) Declaration of John Houkom, # (3) Proposed Order)(Quintana, Andres)
2011-07-22 6 0 Ex Parte Application to Continue EX PARTE APPLICATION to Continue Hearing on Defendants' Motion to Dismiss from August 17, 2011 at 10:00 am to October 12, 2011 at 10:00 am filed by plaintiff Aqua Connect. (Attachments: # (1) Declaration Declaration of Michael K. Hagemann, # (2) Proposed Order [Proposed] Order, # (3) Exhibit Exhibit 1)(Hagemann, Michael)
2011-07-25 7 0 Objection/Opposition (Motion related) Opposition re: EX PARTE APPLICATION to Continue Hearing on Defendants' Motion to Dismiss from August 17, 2011 at 10:00 am to October 12, 2011 at 10:00 am[6] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2011-07-27 8 0 Order on Ex Parte Application to Continue ORDER by Judge Ronald S.W. Lew: DENYING [6] Plaintiff Aqua Connect's Ex Parte Application to Continue the Hearing on Defendants Arben Kryeziu and Code Rebel, LLC' s Motion to Dismiss, or in the alternative, for a more Definite Statement. Defendants Arben Kryeziu and Code Rebel, LLC's Motion to Dismiss will be heard by the Court, as currently scheduled, on August 17, 2011 at 10:00 a.m. (lom)
2011-07-27 9 0 MEMORANDUM in Opposition to Motion MEMORANDUM in Opposition to MOTION to Dismiss for Lack of Jurisdiction[5] filed by Plaintiff Aqua Connect. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit 1, # (3) Exhibit 2, # (4) Exhibit 3, # (5) Exhibit 4, # (6) Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9) Exhibit 8, # (10) Exhibit 9, # (11) Exhibit 10)(Hagemann, Michael)
2011-08-03 10 0 Reply (Motion related) REPLY in support of MOTION to Dismiss for Lack of Jurisdiction[5] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration Supplemental Declaration of Arben Kryeziu)(Quintana, Andres)
2011-08-12 11 0 Motion to Remand Case to State Court NOTICE OF MOTION AND MOTION to Remand Case to Los Angeles Superior Court filed by plaintiff Aqua Connect. Motion set for hearing on 9/21/2011 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Proposed Order, # (3) Exhibit 1, # (4) Exhibit 2, # (5) Exhibit 3)(Hagemann, Michael)
2011-08-12 12 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTE ORDER IN CHAMBERS by Judge Ronald S.W. Lew: On the Court's own motion, Defendants' Arben Kryeziu and Code Rebel, LLC's Motion to Dismiss Complaint for Lack of Personal Jurisdiction [Fed.R.Civ.P. 12(b)(2)], for Failure to State a Claim [Fed.R.Civ.P. 12(b)(6)], Or in the Alternative, For a More Definite Statement [Fed.R.Civ.P.12(e)] (filed 07-20-11) [5] set for August 17, 2011 is continued to AUGUST 24, 2011, at 10:00 a.m. Defendants are ordered to serve this Court's order on Plaintiffs. Counsel are ordered to appear on this new date. (kd)
2011-08-17 13 0 Notice (Other) NOTICE filed by Defendants Code Rebel LLC, Arben Kryeziu. Notice to Plaintiff of Order Regarding the Hearing Date on Defendants' Motions (Quintana, Andres)
2011-08-24 14 0 Order on Motion to Dismiss/Lack of Jurisdiction MINUTES OF MOTION (Held and Completed; Non-Evidentiary) before Judge Ronald S.W. Lew. Defendants Arben Kryeziu and Code Rebel, LLC's Motion to Dismiss Complaint for Lack of Personal Jurisdiction [Fed.R.Civ.P. 12(b)(2)], for Failure to State a Claim [Fed.R.Civ.P. 12(b)(6)], or in the Alternative, for a More Definitive Statement [Fed.R.Civ.P. 12(e)] (filed 07-20-11) [5] is taken under submission by the Court. The Court will issue its Order. Court Reporter: Bridget Montero. (lom) 2011-08-26 11:07:15 eefe69c7883ae9d5faa762bda3633cfd9acec4b7
2011-08-31 15 0 Objection/Opposition (Motion related) OPPOSITION in opposition to re: MOTION to Remand Case to Los Angeles Superior Court[11] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of Arben Kryeziu, # (2) Declaration of Andres F. Quintana, # (3) Declaration of John M. Houkom, # (4) Proposed Order)(Quintana, Andres)
2011-09-07 16 0 Reply (Motion related) REPLY in support of motion MOTION to Remand Case to Los Angeles Superior Court[11] filed by Plaintiff Aqua Connect. (Attachments: # (1) Order, KDY, Inc. v. Hydroslotter Corp., # (2) Order, Svoboda v. Deutsche Bank Securities, Inc.)(Hagemann, Michael) 2011-09-09 00:18:23 c94552613b41b1839e232656ae58cc871f3eda78
16 1 Order, KDY, Inc. v. Hydroslotter Corp.
16 2 Order, Svoboda v. Deutsche Bank Securities, Inc.
2011-09-14 17 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTE ORDER IN CHAMBERS by Judge Ronald S.W. Lew. On the Court's own motion, Plaintiff's Motion to Remand [11] set for 9/21/2011, is CONTINUED to 10/12/2011 at 10:00 a.m. Counsel are ordered to appear on this new date. (ys) 2011-09-15 03:27:52 1c4d2551d748a27bb98dcc3efe60110f247e5ee3
2011-09-26 18 0 Order on Motion to Dismiss/Lack of Jurisdiction ORDER by Judge Ronald S.W. Lew: granting in part and denying in part [5] Defendants Kreyziu and Code Rebel's Motion to Dismiss for Lack of Jurisdiction, for Failure to State a Claim [FRCP 12(b)(6)], or in the alternative, for a More Definite Statement [FRCP 12(e)] [5]. The Court DENIES Movants' Motion to Dismiss Plaintiff's Second Cause of Action for False Promise. The Court GRANTS Movants' Motion to Dismiss Plaintiff's: 1. Third Cause of Action for Inducing Breach of Contract (also known as interfering with the performance of a contract); 2. Fourth Cause of Action for Misappropriation of Trade Secrets; 3. Seventh Cause of Action for Fraudulent Transfer; with 20 days leave to amend. Finally, the Court DENIES Movants' Motion for a More Definite Statement Pursuant to Federal Rule of Civil Procedure 12(e). (See attached document for details.) (lom) 2011-09-27 22:34:24 859d62ab00dc71439afa74a44c507c9b18bd5624
2011-10-12 19 0 Order on Motion to Remand Case to State Court MINUTES OF MOTION (Non-Evidentiary; Held and Completed) before Judge Ronald S.W. Lew. Plaintiffs Motion to Remand (filed 08-12-11) [11] is DENIED. Plaintiff's Evidentiary Objection is SUSTAINED in part, and OVERRULED in part. The Court DENIES Plaintiff and Defendants Request for Attorney Fees. The Court will prepare the order. Court Reporter: Rosalyn Adams. (lom)
2011-10-15 20 0 Amended Document (Non-Motion) AMENDED DOCUMENT filed by Plaintiff Aqua Connect. First Amended Complaint (Attachments: # (1) Exhibit 1, # (2) Summons)(Hagemann, Michael) Modified on 10/19/2011 (lom). (Document is STRICKEN from the record, see Order [22].) 2011-10-15 20:36:39 2e3b488898d430c00dfdd351f957ea7dface8296
20 1 Exhibit 1 2011-10-15 20:39:21 ade402656c2c59a0addc59272ca020f5eba38844
20 2 Summons
2011-10-18 21 0 Notice of Deficiency in Electronically Filed Documents (G-112) NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Amended Document (Non-Motion)[20]. The following error(s) was found: L.R. 3-2 Filing of Initiating Documents. Complaints and other initiating documents (Crossclaim, Counterclaim, Claims, etc) in civil cases shall be filed and served in the traditional manner on paper rather than electronically. Please manually filed your First Amended Complaint. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lom) 2011-10-19 10:21:35 cddeb60435b5d1cc334ae258b32810938517a5b7
2011-10-18 22 0 Response By Court to Notice of Deficiencies (G-112B) ORDER re Amended Document (Non-Motion)[20] by Judge Ronald S.W. Lew: This document is stricken from the record. Please manually file your First Amended Complaint. (lom)
2011-10-20 23 0 Amended Complaint FIRST AMENDED COMPLAINT [1]; Jury Trial Demanded against Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu, Does, JURY DEMAND filed by Plaintiff Aqua Connect. (lom) (Additional attachment(s) added on 10/25/2011: # (1) Summons Issued) (lom). 2012-02-25 10:18:48 cc6abd3a3e5d51ac463bc3b42a0efdbaf253ad34
23 1 Summons Issued
2011-10-25 24 0 Order ORDER by Judge Ronald S.W. Lew, DENYING Plaintiff Aqua Connect, Inc.'s Motion to Remand [11]. This Court finds that Defendants Code Rebel and Kryeziu's removal was timely under 28 U.S.C. § 1446(b). Furthermore, the Court DENIES Plaintiff and Defendants Code Rebel and Kryeziu's requests for attorney's fees. (See attached document for details.) (lom) 2011-10-28 01:23:16 0b685357445515cfc693f4f78e0246330ea1ea3a
2011-11-14 25 0 Motion to Dismiss Case NOTICE OF MOTION AND MOTION to Dismiss Case Pursuant to [Fed.R.Civ.P. 12(b)(6)] filed by Defendants Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 12/20/2011 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom, # (2) Proposed Order)(Quintana, Andres) 2011-11-15 02:24:00 d42978464fb6c1f5176b8e72ad92b50fa9b6ed09
25 1 Declaration of John M. Houkom 2011-11-15 02:24:42 b9f67137963066bf9c56a7fb9677011ecbde16a5
25 2 Proposed Order
2011-11-29 26 0 Objection/Opposition (Motion related) Opposition re: MOTION to Dismiss Case Pursuant to [Fed.R.Civ.P. 12(b)(6)] MOTION to Dismiss Case Pursuant to [Fed.R.Civ.P. 12(b)(6)][25] filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael) 2012-01-05 10:42:39 5885c2a3b68066e0a6e8e00fe7a2ebfce19225f4
2011-12-06 27 0 Reply (Motion related) REPLY in support MOTION to Dismiss Case Pursuant to [Fed.R.Civ.P. 12(b)(6)] MOTION to Dismiss Case Pursuant to [Fed.R.Civ.P. 12(b)(6)][25] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Quintana, Andres) 2012-01-05 10:36:55 d0d0c4a09e409437dff304aee423e0178d8bfdcc
2011-12-09 28 0 Notice of Change of Attorney Business or Contact Information (G-06) NOTICE of Change of Attorney Information for attorney Michael Karl Hagemann counsel for Plaintiff Aqua Connect Inc. Adding Michael K. Hagemann as attorney as counsel of record for Aqua Connect, Inc. for the reason indicated in the G-06 Notice. Filed by Plaintiff Aqua Connect, Inc. (Hagemann, Michael)
2011-12-09 29 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTES (IN CHAMBERS) by Judge Ronald S.W. Lew. On the Court's own motion, Defendants Arben Kryeziu and Code Rebel, LLC.'s Motion to Dismiss First Amended Complaint For Failure to State a Claim [FRCP 12(b)(B)] (filed 11-14-11) [25] set for December 20, 2011, is taken OFF CALENDAR and is now UNDER SUBMISSION. No appearances are necessary. The Court's order will issue. (lom)
2012-02-13 30 0 Order on Motion to Dismiss Case ORDER re Defendants Arben Kryeziu and Code Rebel, LLC's (hereinafter collectively referred to as "Movants") Motion to Dismiss First Amended Complaint for Failure to State a Claim [25] by Judge Ronald S.W. Lew. The Court GRANTS Movants' Motion to Dismiss First Amended Complaint for Failure to State a Claim. Accordingly, the Court hereby DISMISSES Plaintiff's Misappropriation of Trade Secret Claim, which is Plaintiff's Third Claim in its FAC, without leave to amend. The Court dismisses without leave to amend because the Court finds that no additional facts can be alleged to support a legally cognizable misappropriation of trade secret claim. (lom) 2013-07-23 02:32:17 d3f96c410d47795fcad7834dd781a16c11887fd0
2012-02-22 31 0 Answer to Complaint ANSWER to Amended Complaint[23] JURY DEMAND. filed by Defendants Code Rebel LLC, Arben Kryeziu.(Quintana, Andres) 2012-02-25 10:17:20 01bc2b57538bdc208fd62f375235dad0af81518a
2012-03-07 32 0 Motion to Amend/Correct NOTICE OF MOTION AND MOTION to AMEND Amended Complaint[23] and Remand Action filed by plaintiff Aqua Connect Inc. Motion set for hearing on 4/4/2012 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Proposed Order, # (3) [Proposed] Second Amended Complaint)(Hagemann, Michael)
2012-03-07 33 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTES (IN CHAMBERS) by Judge Ronald S.W. Lew. The above matter is set for a Scheduling Conference on MAY 2, 2012, at 10:00 A.M. The conference will be held pursuant to F.R.Civ.P. 16(b). The parties are reminded of their obligations to disclose information and confer on a discovery plan not later than 21 days prior to the scheduling conference and report to the Court not later than 14 days after they confer as required by F.R.Civ.P. 26 and the Local Rules of this Court. Failure to comply may lead to the imposition of sanctions. (See attached document for details.) (lom)
2012-03-14 34 0 MEMORANDUM in Opposition to Motion MEMORANDUM in Opposition to MOTION to AMEND Amended Complaint[23] and Remand Action MOTION to AMEND Amended Complaint[23] and Remand Action[32] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration Declaration of John M. Houkom In Support of Opposition)(Quintana, Andres)
2012-03-21 35 0 Reply (Motion related) REPLY in support MOTION to AMEND Amended Complaint[23] and Remand Action MOTION to AMEND Amended Complaint[23] and Remand Action[32] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) [Proposed] Second Amended Complaint (Amended))(Hagemann, Michael)
2012-04-03 36 0 Motion for Sanctions NOTICE OF MOTION AND MOTION for Sanctions PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE, RULE 11(B) AND 28 U.S.C. §; MEMORADUJ OF POINTS AND AUTHORITIES filed by Defendants Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 5/1/2012 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration, # (2) Declaration Supplemental Declarations, # (3) Proposed Order)(Quintana, Andres)
2012-04-06 37 0 Order on Motion to Amend/Correct MINUTES OF MOTION (Non-Evidentiary; Held and Completed) before Judge Ronald S.W. Lew. Plaintiff's Motion to Amend Complaint and remand Action (filed 03-07-120 [32] are DENIED. The Courts order will issue. Court Reporter: Mary Rickey. (lom) 2012-04-18 17:03:36 c23a640830a4b995a99ac6afe8b35185190540e9
2012-04-10 38 0 Objection/Opposition (Motion related) Opposition Opposition re: MOTION for Sanctions PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE, RULE 11(B) AND 28 U.S.C. §; MEMORADUJ OF POINTS AND AUTHORITIES MOTION for Sanctions PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE, RULE 11(B) AND 28 U.S.C. §; MEMORADUJ OF POINTS AND AUTHORITIES[36] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann)(Hagemann, Michael)
2012-04-17 39 0 Reply (Motion related) REPLY in support MOTION for Sanctions PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE, RULE 11(B) AND 28 U.S.C. §; MEMORADUJ OF POINTS AND AUTHORITIES MOTION for Sanctions PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE, RULE 11(B) AND 28 U.S.C. §; MEMORADUJ OF POINTS AND AUTHORITIES[36] filed by Defendants Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of Gerald Priore, # (2) Declaration of Beatriz Singleton, # (3) Declaration Second Supplemental Declaration of John Houkom, # (4) Declaration Second Supplemental Declaration of Andres Quintana)(Quintana, Andres)
2012-04-25 40 0 Joint Report Rule 26(f) Discovery Plan JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 9 days, filed by Defendants Code Rebel LLC, Arben Kryeziu.. (Quintana, Andres)
2012-04-27 41 0 Order ORDER by Judge Ronald S.W. Lew, DENYING Plaintiff Aqua Connect's Motion to Amend Complaint and Remand Action [32]. Upon review, the Court finds that five out of the six § 1447(e) factor factors weigh heavily against joining Moboware as an additional defendant. Analysis of these factors show that: (1) Moboware is only tangentially related to the Plaintiff's claims; (2) an action against Moboware in State Court would not be time-barred; (3) Plaintiff's motive to join Moboware should be suspected to solely defeat diversity jurisdiction; (4) Plaintiff will not suffer undue prejudice; and (5) the claims against Moboware are weak on the merits. As such, in applying its discretion, the Court finds that joining Moboware in this Action is not appropriate. Therefore, the Court, in its discretion, DENIES Plaintiffs request to join Moboware. (lom)
2012-05-09 42 0 Stipulation for Protective Order Joint STIPULATION for Protective Order filed by Plaintiff Aqua Connect Inc.(Hagemann, Michael) 2013-06-10 14:10:22 1a02c3c54b6fbe0b697c473395eedec322a495dd
2012-05-18 43 0 Order on Motion for Sanctions MINUTES OF MOTION (Non-Evidentiary; Held and Completed) before Judge Ronald S.W. Lew. Defendant Code Rebel, LLC and Arben Kryeiu's Motion for Sanctions Pursuant to FRCP Rule 11 and 28 USC 1927 (filed 04-03-12) [36] is DENIED. Plaintiff's motion to award sanctions is DENIED. The Court's order will issue. Court Reporter: Rosalyn Adams. (lom)
2012-05-22 44 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTE (IN CHAMBERS) ORDER by Judge Ronald S.W. Lew. The Scheduling Conference having previously been taken UNDER SUBMISSION, the Court sets the following dates: Discovery cut-off 1/11/2013. Expert cut-off 5/10/2013. Last day to file Motions 6/7/2013. Final Pretrial Conference set for 7/30/2013 at 10:00 A.M. Jury Trial set for 8/13/2013 at 9:00 A.M. All motions in limine shall be filed no later than the date of the Final Pretrial Conference. Oppositions shall be filed no later 7 days after the Final Pretrial Conference; and a reply, if any, shall be filed no later than 14 days after the Final Pretrial Conference. (SEE DOCUMENTS FOR DETAILS) (ys)
2012-06-06 45 0 Order ORDER Denying Defendants Code Rebel LLC and Arben Kryeziu's ("Movants") Motion for Sanctions Pursuant to Federal Rules of Civil Procedure, Rule 11(b) and 28 U.S.C. § 1927 [32] by Judge Ronald S.W. Lew. The Court also DENIES Plaintiff's own request for sanctions that Plaintiff made in its Opposition to this Motion. (lom)
2012-06-19 46 0 Waiver of Service Executed WAIVER OF SERVICE Returned Executed filed by plaintiff Aqua Connect Inc. upon Vladimir Bickov waiver sent by Plaintiff on 5/19/2012, answer due 7/18/2012. Waiver of Service signed by Volodymyr Bykov. (Hagemann, Michael)
2012-07-17 47 0 Answer to Complaint ANSWER to Amended Complaint[23] filed by Defendant Vladimir Bickov.(Quintana, Andres)
2012-07-17 48 0 Certificate/Notice of Interested Parties Certification of Interested Parties filed by Defendant Vladimir Bickov, (Quintana, Andres)
2012-08-10 49 0 Protective Order PROTECTIVE ORDER by Magistrate Judge Margaret A. Nagle, re: Stipulation for Protective Order, [42]. (mz) 2012-08-11 07:10:00 f8f5d1bc65b50adf180cd8f853e4fee0b90a2f40
2012-11-15 50 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Plaintiff Aqua Connect Inc of Notice of Motion and Motion; Declarations; Notice of Lodging; Exhibits; [Proposed] Order; Proof of Service. (Hagemann, Michael)
2012-11-16 51 0 Motion to Seal Document PLAINTIFF'S NOTICE OF MOTION AND MOTION TO SEAL EXHIBITS AND PRESERVE CONFIDENTIALITY DESIGNATIONS PURSUANT TO THE PROTECTIVE ORDER, [49] filed by Plaintiff Aqua Connect Inc. Lodged Proposed Order. (mz)
2012-11-16 52 0 Declaration (Motion related) DECLARATION OF JOSEPH COHEN IN SUPPORT OF PLAINTIFF'S MOTION TO SEAL EXHIBITS AND PRESERVE CONFIDENTIALITY DESIGNATIONS, [51] filed by Plaintiff Aqua Connect Inc. (mz)
2012-11-16 53 0 Declaration (Motion related) DECLARATION OF MICHAEL K. HAGEMANN IN SUPPORT OF PLAINTIFF'S MOTION TO SEAL EXHIBITS AND PRESERVE CONFIDENTIALITY DESIGNATIONS, [51] filed by Plaintiff Aqua Connect Inc. (mz)
2012-11-16 54 0 Notice of Lodging NOTICE OF LODGING EXHIBIT 1 filed by Plaintiff Aqua Connect, Inc. (mz)
2012-11-16 55 0 Proof of Service (subsequent documents) PROOF OF SERVICE filed by Plaintiff Aqua Connect Inc, re MOTION to Seal[51], Notice of Lodging[54], Declaration (Motion related)[52], Declaration (Motion related)[53] served on 11/15/12. (mz)
2012-11-19 56 0 Request for ADR Procedure No. 2 - (ADR-1) REQUEST for ADR Procedure No. 2 filled. Parties request to appear before a neutral selected from the court's Mediation Panel for mediation. Filed by Plaintiff Aqua Connect Inc(Hagemann, Michael)
2012-11-28 57 0 Order/Referral to ADR (No 2) (Mediation Panel) (ADR-12) ORDER/REFERRAL to ADR Procedure No 2 by Judge Ronald S.W. Lew. Case ordered to Court Mediation Panel for mediation. (jre)
2012-11-30 58 0 Motion to Amend/Correct NOTICE OF MOTION AND MOTION to Amend Amended Complaint[23] filed by Plaintiff Aqua Connect Inc. Motion set for hearing on 1/9/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit A (Proposed Second Amended Complaint), # (3) Exhibit B (Proposed Second Amended Complaint), # (4) Proposed Order)(Hagemann, Michael)
2012-12-07 59 0 Stipulation to Extend Discovery Cut-Off Date Joint STIPULATION to Extend Discovery Cut-Off Date to March 11, 2013 filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Proposed Order)(Hagemann, Michael) 2013-06-10 14:11:33 9d483730687351b04c95fcf97aade6ea48d99bd4
59 1 Proposed Order 2013-06-10 14:12:23 177d8a078992e9d1b3075662f68a9a670833c9c1
2012-12-11 60 0 Order ORDER EXTENDING DISCOVERY DEADLINE AND NO OTHER DATES [59] by Judge Ronald S.W. Lew: IT IS HEREBY ORDERED that the fact discovery deadline, and no other deadlines set in this case, be extended by two months, from January 11, 2013 to March 11, 2013. (jre)
2012-12-18 61 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of February 7, 2012, Email re: "Become a Beyond the Rack Member Today," i.e., Exhibit "E" to Opposition to Plaintiff's Motion to Seal Exhibits and Preserve Confidentiality. (Quintana, Andres)
2012-12-18 62 0 Objection/Opposition (Motion related) OPPOSITION in opposition to re: MOTION to Seal[51] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John M. Houkom, # (2) Proposed Order)(Quintana, Andres)
2012-12-19 63 0 Objection/Opposition (Motion related) Opposition in opposition re: MOTION to Amend Amended Complaint[23] MOTION to Amend Amended Complaint[23][58] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John M. Houkom in Support of Opposition, # (2) Exhibit 4 and 5 to Declaration of John M. Houkom)(Quintana, Andres)
2012-12-20 64 0 Notice of Manual Filing (G-92) Amended NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of Exhibit "E" to Opposition to Plaintiff's Motion to Seal Exhibits; Application of Defendants to File Exhibit "E" to Opposition to Plaintiff's Motion to Seal Exhibits and Preserve Confidentiality Under Seal; [Proposed] Order re: Application to File Exhibit "E" Under Seal. (Quintana, Andres)
2012-12-20 65 0 Ex Parte Application to Strike Emergency EX PARTE APPLICATION to Strike attachment one to Defendants' opposition re Objection/Opposition (Motion related), Objection/Opposition (Motion related)[63] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Proposed Order)(Hagemann, Michael)
2012-12-20 66 0 Application to Seal APPLICATION OF DEFENDANTS CODE REBEL, LLC, ARBEN KRYEZIU AND VOLODYMYR BYKOV TO FILE EXHIBIT "E" TO OPPOSITION TO PLAINTIFF'S MOTIONTO SEAL EXHIBITS AND PRESERVE CONFIDENTIALITY UNDER SEAL filed by Defendants Vladimir Bickov, Code Rebel LLC, Does, Arben Kryeziu. (mz)
2012-12-21 67 0 Response in Opposition to Motion OPPOSITION to Emergency EX PARTE APPLICATION to Strike attachment one to Defendants' opposition re Objection/Opposition (Motion related), Objection/Opposition (Motion related)[63]Emergency EX PARTE APPLICATION to Strike attachment one to Defendants' opposition re Objection/Opposition (Motion related), Objection/Opposition (Motion related)[63][65] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John Houkom, # (2) Exhibit A of Declaration, # (3) Proposed Order)(Quintana, Andres)
2012-12-21 68 0 Order on Ex Parte Application to Strike ORDER re: Plaintiff's Ex Parte Application to Strike [65] by Judge Ronald S.W. Lew: The Court hereby GRANTS Plaintiff's Application to the extent that Exhibit 3 to Attachment One of Defendants Opposition to Plaintiff's Motion to Amend Complaint [63] contains information marked as "CONFIDENTIAL" that should have been redacted pursuant to the Parties' Stipulated Protective Order [49]. The Court has placed Attachment One under seal instead of striking the entire document [63]. Defendants shall electronically file Exhibit A, attached to its Opposition to Plaintiff's Ex Parte Application [67], with the Court. Defendants shall ensure that all necessary redactions have been made to Exhibit A, pursuant to the Parties' Stipulated Protective Order. (jre)
2012-12-24 69 0 Reply (Motion related) REPLY in support of MOTION to Seal[51] filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael)
2012-12-26 70 0 Reply (Motion related) REPLY in support of MOTION to Amend Amended Complaint[23] MOTION to Amend Amended Complaint[23][58] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit C, # (3) Exhibit D)(Hagemann, Michael)
2012-12-27 71 0 Exhibit to Motion EXHIBIT A to MOTION to Amend Amended Complaint[23] MOTION to Amend Amended Complaint[23][58] Exhibit "A" to Opposition to Plaintiff's Motion to Amend Complaint filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-01-02 72 0 Text Only Scheduling Notice TEXT ONLY ORDER (IN CHAMBERS) by Judge Ronald S.W. Lew: The hearing on Plaintiff's Motion to Amend Complaint [58], set for 1/9/2013 is hereby taken OFF CALENDAR and is now UNDER SUBMISSION. No appearances necessary on 1/9/2013. The Court's order will issue. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(jre) TEXT ONLY ENTRY
2013-01-08 73 0 Discovery Hearing MINUTES OF PLAINTIFFS MOTION TO SEAL EXHIBITS AND PRESERVE CONFIDENTIALITY DESIGNATIONS PURSUANT TO THE PROTECTIVE ORDER held before Magistrate Judge Margaret A. Nagle. The Court hears argument from counsel regarding the Motion and directs counsel to meet and confer with respect to the issues presented. Following their further efforts to meet and confer, counsel advise the court that they have reached an agreement with respect to certain issues presented. The Court directs plaintiffs counsel to prepare a joint stipulation and proposed order that reflects the agreement reached and to present that stipulation and order to defendants counsel for approval. The joint stipulation and proposed order shall be filed by no later than Thursday, January 10, 2013. Pending that filing, the Motion is taken under submission.IT IS SO ORDERED. Court Recorder: CS 1/8/13. (mz)
2013-01-10 74 0 Stipulation for Order Joint STIPULATION for Order to seal exhibits and preserve confidentiality designations pursuant to the protective order filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Proposed Order)(Hagemann, Michael)
2013-01-17 75 0 Order on Motion to Amend/Correct ORDER Re: Plaintiff's Motion To Amend Complaint [58] by Judge Ronald S.W. Lew: Plaintiff's Motion for Leave Amend Complaint is GRANTED. Plaintiff shall manually file with the Clerk's Office Exhibit B to its Motion to Amend Complaint [58] within 20 days of this order. (jre) 2013-01-19 12:21:36 0fab3e3c2a57549d6cf04b9c65b8e4ae438ad08f
2013-01-25 76 0 Notice of Assignment of Panel Mediator(ADR-11) NOTICE OF ASSIGNMENT of Panel Mediator. Mediator (ADR Panel) Gregory B Wood has been assigned to serve as Panel Mediator. (mb)
2013-01-22 77 0 Amended Complaint SECOND AMENDED COMPLAINT against defendant Vladimir Bickov, Code Rebel LLC, Arben Kryeziu; Party Does terminated amending Amended Complaint[23] jury demand,filed by plaintiff: Aqua Connect Inc (Attachments: # (1) Issued summons)(lc) 2013-02-08 18:04:03 a0f2e0a4829e621fd254c756cbadc32d761eac93
77 1 Issued summons
2013-01-25 78 0 Notice of Document Discrepancies - Granting NOTICE OF DOCUMENT DISCREPANCIES AND ORDER by Judge Ronald S.W. Lew ORDERING second amended complaint submitted without Judges Copy by Plaintiff Aqua Connect Inc received on 1/24/13 to be filed and processed; filed date to be the date the document was stamped Received but not Filed with the Clerk. Counsel admonished to follow filing requirements of this court in the future. (lc)
2013-01-22 79 0 Text Only Bounced Notice of Electronic Filing E-mail Notice of Electronic Filing re Amended Complaint[77], Summons Issued e-mailed to gwood@fulbright.com bounced due to 5.1.0 - Unknown address error 550-'5.0.0 <gwood@fulbright.com>... User unknown'. Primary e-mail address had already been corrected. Notice of Electronic Filing resent addressed to gregwood@woodipdr.com with a request that he file a G-6 form to remove himself from the case if necessary. Pursuant to the General Order and Local Rules it is the attorneys obligation to maintain all personal contact information including e-mail address in the CM/ECF system. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(tyw) TEXT ONLY ENTRY
2013-02-15 80 0 Motion to Dismiss Case NOTICE OF MOTION AND MOTION to Dismiss Case Second Amended Complaint for Failure to State a Claim filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 2/19/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Andres Quintana, # (2) Proposed Order)(Quintana, Andres)
2013-02-26 81 0 Response in Opposition to Motion OPPOSITION TO DEFENDANTS MOTION TO DISMISS THE SECOND AMENDED COMPLAINT FOR FAILURE TO STATE A CLAIM [80] filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael) Modified on 2/28/2013 due to CM/ECF error (jre).
2013-03-05 82 0 Reply (Motion related) REPLY in support MOTION to Dismiss Case Second Amended Complaint for Failure to State a Claim[80] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-03-14 83 0 Text Only Scheduling Notice TEXT ONLY ORDER (IN CHAMBERS) by Judge Ronald S.W. Lew: Defendants' Motion to Dismiss Second Amended Complaint for Failure to State a Claim [80] is hereby taken UNDER SUBMISSION. The hearing set for 3/19/2013, at 10:00 a.m. is now OFF-CALENDAR. No appearances necessary on 3/19/2013. The Court's order will issue. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (jre) TEXT ONLY ENTRY
2013-04-04 84 0 Order on Motion to Dismiss Case ORDER re: Defendants Code Rebel, LLC, Arben Kryeziu, and Vlodomyr Bykov's Motion to Dismiss Second Amended Complaint for Failure to State a Claim [80] by Judge Ronald S.W. Lew: The Court hereby DENIES Defendants' Motion toDismiss Second Amended Complaint for Failure to State a Claim. SEE ORDER FOR FURTHER DETAILS. (Answer due date updated to 4/25/2013) (jre) 2013-07-23 02:28:24 8947889420b30b58894aed822d6db735a0e76d79
2013-04-18 85 0 Answer to Complaint ANSWER to Amended Complaint[77] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu.(Quintana, Andres)
2013-05-14 86 0 Motion for Leave NOTICE OF MOTION AND MOTION for Leave to To File Counterclaim filed by Defendant Code Rebel LLC. Motion set for hearing on 6/11/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Andres F. Quintana and Arben Kryeziu, # (2) Proposed Order)(Quintana, Andres)
2013-05-21 87 0 Objection/Opposition (Motion related) Opposition in opposition to re: MOTION for Leave to To File Counterclaim [86] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Joseph Cohen, # (2) Declaration of Michael K. Hagemann, # (3) Table of Exhibits; Exhibits 1-19, # (4) Carson v. Bank of America, N.A., # (5) Christakis v. Mark Burnett Prods.)(Hagemann, Michael)
2013-05-28 88 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal, and documents to be place under seal pursuant to that Application, including Exhibits "D", "E", "F", "G" and "H", in Support of Defendant Code Rebel's Reply Brief. (Quintana, Andres)
2013-05-28 89 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of [Prpposed] Order Granting Application for Filing Under Seal. (Quintana, Andres)
2013-05-28 90 0 Reply (Motion related) REPLY in support of MOTION for Leave to To File Counterclaim [86] filed by Defendant Code Rebel LLC. (Attachments: # (1) Declaration Supplemental Declaration of Andres F. Quintana)(Quintana, Andres)
2013-05-29 91 0 Ex Parte Application to Supplement EX PARTE APPLICATION to Supplement Response to Request For Production Number 14 or in the alternative to Compel Production of Executable Files filed by Defendant Code Rebel LLC. (Attachments: # (1) Declaration of John M. Houkom and Andres F. Quintana in Support, # (2) Declaration of John M. Houkom Pursuant To Local Rule 7-19.1, # (3) Proposed Order)(Quintana, Andres)
2013-05-30 92 0 Objection/Opposition (Motion related) Opposition re: EX PARTE APPLICATION to Supplement Response to Request For Production Number 14 or in the alternative to Compel Production of Executable Files[91] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit 1, # (3) Exhibit 2)(Hagemann, Michael) 2013-06-06 01:56:25 248bacbd4e6011ca94fc2ee5307e565319f550bc
92 1 Declaration of Michael K. Hagemann
92 2 Exhibit 1
92 3 Exhibit 2
2013-05-29 93 0 Application to Seal APPLICATION for filing Documents Under Seal ISO Reply to Motion for Leave to File Counterclaims [86] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (jre)
2013-05-29 94 0 Order on Application to Seal (document) ORDER Granting Application for Filing Documents Under Seal [93] by Judge Ronald S.W. Lew. (jre)
2013-06-04 95 0 Mediation Report (ADR-3) Unable to Reach Agreement MEDIATION REPORT Filed by Mediator (ADR Panel) Gregory B Wood: Mediation held on 5/10/2013. The parties are unable to reach an agreement at this time.(mb)
2013-05-29 96 0 Exhibit (non-trial) SEALED DOCUMENT- PORTIONS OF TRANSCRIPT of February 28, 2013 Deposition of Renee Mehrain (EXHIBIT D). (mat)
2013-05-29 97 0 Exhibit (non-trial) SEALED DOCUMENT- PORTIONS OF TRANSCRIPT of February 28, 2013 Deposition of Ronnie Exley (EXHIBIT E). (mat)
2013-05-29 98 0 Exhibit (non-trial) SEALED DOCUMENT- January 19, 2010 Email of Renee Mehrain (EXHIBIT F) (mat)
2013-05-29 99 0 Exhibit (non-trial) SEALED DOCUMENT- June 29, 2009 Email of Ronnie Exley (EXHIBIT G) (mat)
2013-05-29 100 0 Exhibit (non-trial) SEALED DOCUMENT- November 19, 2009 Email of Ronnie Exley (EXHIBIT H) (mat)
2013-06-07 101 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal; documents to be placed under seal pursuant to that Application, inlcuding Exhibits "C", and "E" in Support of Motion; [Proposed] Order. (Quintana, Andres)
2013-06-07 102 0 Motion for Summary Judgment NOTICE OF MOTION AND MOTION for Summary Judgment as to Second Amended Complaint or in the Alternative for Summary Adjudication filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 7/9/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of Arben Kryeziu, Volodymyr Bykov, and John M. Houkom, # (2) Declaration of Andres F. Quintana and John M. Houkom, # (3) Proposed Order)(Quintana, Andres)
2013-06-07 103 0 Statement (Motion related) STATEMENT of Uncontroverted Material Facts and Conclusions of Law re MOTION for Summary Judgment as to Second Amended Complaint or in the Alternative for Summary Adjudication[102] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-07 104 0 Request for Judgment/Renewal of Judgment REQUEST for Judgment [Proposed] Judgment for Defendants Code Rebel, LLC, Arben Kryeziu, and Volodymyr Bykov re Motion for Summary Judgment, or in the Alternative for Summary Adjudication filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. Request set for hearing on 7/9/2013 at 10:00 PM before Judge Ronald S.W. Lew. (Quintana, Andres)
2013-06-07 105 0 Motion for Sanctions NOTICE OF MOTION AND MOTION for Sanctions on Plaintiff for spoliation of evidence filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 7/9/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Proposed Order, # (2) Declaration of John M. Houkom and Andres F. Quintana)(Quintana, Andres)
2013-06-07 106 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal, Exhibit "Q" to be placed under seal persuant thereto and Proposed Order. (Quintana, Andres)
2013-06-08 107 0 Ex Parte Application to Strike EX PARTE APPLICATION to Strike re MOTION for Sanctions on Plaintiff for spoliation of evidence [105] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Proposed Order)(Hagemann, Michael) 2013-06-09 14:46:23 1048fcdd8d694dc9bd932dff7d55f8f86beebee2
107 1 Declaration of Michael K. Hagemann
107 2 Proposed Order
2013-06-10 108 0 Notice of Deficiency in Electronically Filed Documents (G-112) NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Statement (Motion related), [103], REQUEST for Judgment [Proposed] Judgment for Defendants Code Rebel, LLC, Arben Kryeziu, and Volodymyr Bykov re Motion for Summary Judgment, or in the Alternative for Summary Adjudication[104]. The following error(s) was found: Incorrect event selected. PDFS are the LR 56.-1 Proposed statement of uncontroverted facts and proposed judgment which shuld have been submitted as separate attachments. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lc)
2013-06-10 109 0 Notice of Document Discrepancies - Granting NOTICE OF DOCUMENT DISCREPANCIES AND ORDER by Judge Ronald S.W. Lew. ORDERING Applicaiton to Seal; Order; Portion of Transcript of February 22, 2013 Merchant Deposition; 1/29/2008 email submitted by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu received on 6/7/2013 to be filed and processed; filed date to be the date the document was stamped Received but not Filed with the Clerk. (jre)
2013-06-10 110 0 Objection/Opposition (Motion related) OPPOSITION in opposition to re: EX PARTE APPLICATION to Strike re MOTION for Sanctions on Plaintiff for spoliation of evidence [105] [107] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-10 111 0 Declaration (Motion related) DECLARATION of John M. Houkom in opposition to EX PARTE APPLICATION to Strike re MOTION for Sanctions on Plaintiff for spoliation of evidence [105] [107] filed by Defendants Vladimir Bickov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-11 112 0 Order on Motion for Leave MINUTES OF Defendant Code Rebel, LLC's Motion for Leave to File Counterclaim [86] held before Judge Ronald S.W. Lew: Case called and appearances are made. The Court and counsel confer. As reflected on the record, the Court DENIES Defendant Code Rebel, LLCs MOTION for Leave to File Counterclaim [86].The Courts will prepare an order on its ruling. Court Reporter: Mary Rickey. (jre)
2013-06-11 113 0 Order ORDER RE: DEFENDANT CODE REBEL, LLC'S MOTION FOR LEAVE TO FILECOUNTERCLAIMS [86] by Judge Ronald S.W. Lew: The Court DENIES CodeRebels Motion for Leave to File Counterclaims. SEE ORDER FOR FURTHER AND COMPLETE INFORMATION. (jre)
2013-06-10 114 0 Exhibit (non-trial) SEALED DOCUMENT- January 29, 2008 Email Between Defendant Volodymrr Bykov and Autmn M. Radtke (EXHIBIT C). (mat)
2013-06-10 115 0 Exhibit (non-trial) SEALED DOCUMENT- PORTIONS of Transcript of February 22, 2013 Deposition of Peter Merchant (EXHIBIT E) (mat)
2013-06-07 116 0 Application to Seal SEALED DOCUMENT- APPLICATION for Filing Documents Under Seal. (mat)
2013-06-12 117 0 Ex Parte Application for Order Emergency EX PARTE APPLICATION for Order for ADVANCE AND DENY, OR, IN THE ALTERNATIVE, CONTINUE DEFENDANTS MOTION FOR SUMMARY JUDGMENT [F.R.C.P. 6(C)(1)(C), 56(D)] filed by Plaintiff's Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Table of Exhibits; Exhibits 1-9, # (3) Proposed Order)(Hagemann, Michael)
2013-06-10 118 0 Order on Application to Seal (document) ORDER GRANTING APPLICATION FOR FILING DOCUMENTS UNDER SEAL [116] by Judge Ronald S.W. Lew. See Order for details. (jre)
2013-06-10 119 0 Application to Seal SEALED DOCUMENT- APPLICATION for Filing Documents Under Seal. (mat)
2013-06-11 120 0 Exhibit (non-trial) SEALED DOCUMENT- May 2, 2011 Email from Bill Silverstein to Joseph Cohen (EXHIBIT Q). (mat)
2013-06-11 121 0 Order on Application to Seal (document) ORDER by Judge Ronald S.W. Lew: granting [119]defendant Code Rebel Application for filing documents Under Seal (lc)
2013-06-13 122 0 Objection/Opposition (Motion related) OPPOSITION opposition to re: EX PARTE APPLICATION to Strike re MOTION for Sanctions on Plaintiff for spoliation of evidence [105] [107] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-13 123 0 Objection/Opposition (Motion related) Objection re: EX PARTE APPLICATION to Strike re MOTION for Sanctions on Plaintiff for spoliation of evidence [105] [107] (Objection to Defendants Supplemental Opposition [122]) filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael)
2013-06-12 124 0 Order on Ex Parte Application to Strike ORDER re: Plaintiff's Ex Parte Application to Strike and/or Advance and Deny Defendants' Motion Re Spoilation [107] by Judge Ronald S.W. Lew: The Court hereby DENIES Plaintiffs Ex Parte Application. Plaintiff has not shown good cause as to why an ex parte application is necessary here and how Plaintiff would be prejudiced if required to brief Defendants Motion for Sanctions for Spoliation of Evidence [105]. SEE ORDER FOR FURTHER DETAILS. (jre)
2013-06-13 125 0 Objection/Opposition (Motion related) OPPOSITION in opposition to re: Emergency EX PARTE APPLICATION for Order for ADVANCE AND DENY, OR, IN THE ALTERNATIVE, CONTINUE DEFENDANTS MOTION FOR SUMMARY JUDGMENT [F.R.C.P. 6(C)(1)(C), 56(D)] [117] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of Andres F. Quintana and John M. Houkom)(Quintana, Andres)
2013-06-13 126 0 Response in Support of Motion RESPONSE IN SUPPORT of Emergency EX PARTE APPLICATION for Order for ADVANCE AND DENY, OR, IN THE ALTERNATIVE, CONTINUE DEFENDANTS MOTION FOR SUMMARY JUDGMENT [F.R.C.P. 6(C)(1)(C), 56(D)] [117] filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael)
2013-06-14 127 0 Declaration (Motion related) DECLARATION of Michael K. Hagemann (New Evidence) in support of Emergency EX PARTE APPLICATION for Order for ADVANCE AND DENY, OR, IN THE ALTERNATIVE, CONTINUE DEFENDANTS MOTION FOR SUMMARY JUDGMENT [F.R.C.P. 6(C)(1)(C), 56(D)] [117] filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael)
2013-06-14 128 0 Objection/Opposition (Motion related) OBJECTION in opposition to re: Emergency EX PARTE APPLICATION for Order for ADVANCE AND DENY, OR, IN THE ALTERNATIVE, CONTINUE DEFENDANTS MOTION FOR SUMMARY JUDGMENT [F.R.C.P. 6(C)(1)(C), 56(D)] [117] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-14 129 0 Order on Ex Parte Application for Order ORDER re: Plaintiff's Ex Parte Application to Advance and Deny, or, in the Alternative, Continue Defendants' Motion for Summary Judgment [117] by Judge Ronald S.W. Lew: The Court hereby DENIES Plaintiff's Ex Parte Application. The Court notes that this is Plaintiff's second consecutive ex parte application seeking to avoid filing an opposition to Defendants' pending motions. Plaintiff has not shown good cause as to why ex parte relief is necessary here and how Plaintiff would be prejudiced if required to file an opposition to Defendants' Motion for Summary Judgment. SEE ORDER FOR FURTHER DETAILS. (jre) 2013-06-15 02:32:29 e4c3d4a4500a2dd4ff72c996601b8bce672464a6
2013-06-17 130 0 Ex Parte Application for Order re Discovery Matter Emergency EX PARTE APPLICATION for Order for TERMINATING SANCTIONS; OR EVIDENTIARY SANCTIONS; OR TO COMPEL PERMISSION FOR INSPECTION; AND FOR MONETARY SANCTIONS; OR, AN ORDER SHORTENING TIME IN THE ALTERNATIVE filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Table of Exhibits; Exhibits 1-13, # (3) Proposed Order)(Hagemann, Michael)
2013-06-18 131 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Plaintiff Aqua Connect Inc of PLAINTIFFS APPLICATION TO SEAL EXHIBITS AND OTHER DOCUMENTS PURSUANT TO THE PROTECTIVE ORDER [49] AND LR 79-5.1; PROPOSED ORDER; DECLARATION OF MICHAEL K. HAGEMANN IN OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT; DECLARATION OF JOSEPH COHEN IN OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT; PLAINTIFFS SEALED STATEMENT OF GENUINE DISPUTES OF MATERIAL FACTS IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT; CONFIDENTIAL PORTIONS OF DEPOSITION OF ARBEN KRYEZIU; TABLE OF SEALED EXHIBITS; EXHIBITS 4, 15, 17, 19, 20. (Hagemann, Michael)
2013-06-18 132 0 Objection/Opposition (Motion related) Opposition re: MOTION for Summary Judgment as to Second Amended Complaint or in the Alternative for Summary Adjudication[102] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) STATEMENT OF GENUINE DISPUTES OF MATERIAL FACTS, # (2) Declaration of Ronnie Exley, # (3) Objections to Defendants' Evidence, # (4) Table of Exhibits; Exhibits 1-21, # (5) Bykov Deposition, # (6) Kyreziu Deposition, # (7) Law Review Article re Unjust Enrichment, # (8) Proof of Service of Documents Pending Seal)(Hagemann, Michael)
2013-06-18 133 0 Objection/Opposition (Motion related) Opposition re: MOTION for Sanctions on Plaintiff for spoliation of evidence [105] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Declaration of Joseph Cohen, # (3) Exhibit 1, # (4) Exhibit 2)(Hagemann, Michael)
2013-06-19 134 0 Objection/Opposition (Motion related) OPPOSITION in opposition to re: Emergency EX PARTE APPLICATION for Order for TERMINATING SANCTIONS; OR EVIDENTIARY SANCTIONS; OR TO COMPEL PERMISSION FOR INSPECTION; AND FOR MONETARY SANCTIONS; OR, AN ORDER SHORTENING TIME IN THE ALTERNATIVE [130] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John M. Houkom and Andres F. Quintana)(Quintana, Andres)
2013-06-20 135 0 Text Only Scheduling Notice TEXT ONLY ORDER (IN CHAMBERS) by Judge Ronald S.W. Lew re: The Emergency EX PARTE APPLICATION for Order for TERMINATING SANCTIONS; OR EVIDENTIARY SANCTIONS; OR TO COMPEL PERMISSION FOR INSPECTION; AND FOR MONETARY SANCTIONS; OR, AN ORDER SHORTENING TIME IN THE ALTERNATIVE [130] is hereby referred to Magistrate Judge Nagel for report, recommendation and proposed order. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(jre)
2013-06-20 136 0 Text Only Scheduling Notice NOTICE by Magistrate Judge Margaret A. Nagle scheduling Plaintiff's Emergency Ex Parte Application for hearing on 6/25/2013 at 10:00 AM before Magistrate Judge Margaret A. Nagle. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(ec) TEXT ONLY ENTRY
2013-06-20 137 0 Application to Seal PLAINTIFF'S APPLICATION to Seal Exhibits and Other Documents Pursuant to the Protective Order [49] and LR 79-5.1 filed by Plaintiff Aqua Connect Inc. (jre)
2013-06-20 138 0 Order on Application to Seal (document) ORDER by Judge Ronald S.W. Lew granting [137] Application to Seal. See order for details. (jre)
2013-06-21 139 0 Motion for Hearing re Discovery Matter NOTICE OF MOTION AND MOTION for Hearing re Designation Under Protective Order filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 7/23/2013 at 10:00 AM before Magistrate Judge Margaret A. Nagle. (Attachments: # (1) Declaration of John M. Houkom, Andres F. Quintana and Arben Kryeziu, # (2) Proposed Order)(Quintana, Andres)
139 1 Declaration of John M. Houkom, Andres F. Quintana and Arben Kryeziu
139 2 Proposed Order
2013-06-24 140 0 Text Only Scheduling Notice NOTICE by Magistrate Judge Margaret A. Nagle continuing the hearing re: Plaintiff's Emergency Ex Parte Application[130] and setting a status conference regarding all outstanding discovery for 6/27/2013 at 11:30 AM before Magistrate Judge Margaret A. Nagle. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(ec) TEXT ONLY ENTRY
2013-06-25 141 0 Reply (Motion related) REPLY in support of MOTION for Sanctions on Plaintiff for spoliation of evidence [105] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration Supplemental Declarations of John M. Houkom and Andres F. Quintana)(Quintana, Andres)
2013-06-25 142 0 Objection/Opposition (Motion related) EVIDENTARY OBJECTIONS in support of re: MOTION for Sanctions on Plaintiff for spoliation of evidence [105] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-25 143 0 Reply (Motion related) REPLY in support MOTION for Summary Judgment as to Second Amended Complaint or in the Alternative for Summary Adjudication[102] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John M. Houkom in Support of Reply)(Quintana, Andres)
2013-06-25 144 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal, Proposed Order, Exhibit "H," and Supplemental Objections to Declarations of Cohen, Exley and Hagemann. (Quintana, Andres)
2013-06-25 145 0 Objection/Opposition (Motion related) OBJECTION In Support re: MOTION for Summary Judgment as to Second Amended Complaint or in the Alternative for Summary Adjudication[102] to Declarations of Joseph Cohen, Ronnie Exley and Michael K. Hagemann filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-20 146 0 Declaration (Motion related) SEALED DOCUMENT - DECLARATION of Michael K. Hagemann opposition to Defendants' Motion for Summary Judgment. (cbr)
2013-06-20 147 0 Declaration (Motion related) SEALED DOCUMENT - DECLARATION of Joseph Cohen in opposition to Defendants' Motion for Summary Judgment. (cbr)
2013-06-20 148 0 Exhibit to Motion SEALED DOCUMENT - TABLE OF SEALED EXHIBITS; EXHIBITS 4, 15, 17, 19, 20. (cbr)
2013-06-20 149 0 Transcript SEALED DOCUMENT - CONFIDENTIAL Portions of Deposition of Arben Kryeziu. (cbr)
2013-06-20 150 0 Statement (Motion related) SEALED DOCUMENT - PLAINTIFF'S SEALED STATEMENT of Genuine Disputes of Material Facts in Opposition to Motion for Summary Judgment. (cbr)
2013-06-26 151 0 Ex Parte Application to Extend Discovery Cut-Off Date EX PARTE APPLICATION to Extend Discovery Cut-Off Date to 8/19/2013 and continue trial to 10/14/13 filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit 4, # (3) Exhibit 14, # (4) Exhibit 15, # (5) Proposed Order)(Hagemann, Michael)
2013-06-27 152 0 Order on Ex Parte Application to Supplement MINUTES OF Discovery Hearing held before Magistrate Judge Margaret A. Nagle:denying [91] Ex Parte Application to Supplement; denying [130] Ex Parte Application for Order. [See order for details] Court Recorder: CS. (ec)
2013-06-27 153 0 Objection/Opposition (Motion related) Opposition in opposition re: EX PARTE APPLICATION to Extend Discovery Cut-Off Date to 8/19/2013 and continue trial to 10/14/13[151] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-27 154 0 Declaration (Motion related) DECLARATION of John M. Houkom in opposition to EX PARTE APPLICATION to Extend Discovery Cut-Off Date to 8/19/2013 and continue trial to 10/14/13[151] in support of Opposition filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-06-28 155 0 Text Only Bounced Notice of Electronic Filing E-mail Notice of Electronic Filing re Objection/Opposition [153] and Declaration [154] e-mailed to Gregory B. Wood bounced due to invalid email address. Notice of Electronic Filing resent addressed to gregwood@woodipdr.com with a request that he file a G-6 form to remove himself from the case if necessary. Pursuant to the General Order and Local Rules it is the attorneys obligation to maintain all personal contact information including e-mail address in the CM/ECF system.. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(jj) TEXT ONLY ENTRY
2013-07-01 156 0 Order on Ex Parte Application to Extend Discovery Cut-Off Date ORDER re: Plaintiffs Ex Parte Application to Extend the Expert Discovery Deadline Pursuant to Stipulation and Continue Trial; or an Order Shortening Time in the Alternative [151] by Judge Ronald S.W. Lew: Plaintiffs Ex Parte Application is DENIED. SEE ORDER FOR FURTHER DETAILS. (jre)
2013-07-02 157 0 Text Only Scheduling Notice TEXT ONLY ORDER (IN CHAMBERS) by Judge Ronald S.W. Lew: Defendants' Motions for Summary Judgment [102] and for Sanctions for Spoliation [105] set for hearing on 7/9/2013, at 10:00 am are hereby taken OFF-CALENDAR and are now UNDER SUBMISSION. No appearances necessary on 7/9/2013. The Court's orders will issue. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (jre)
2013-07-02 158 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Plaintiff Aqua Connect Inc of PLAINTIFFS APPLICATION TO SEAL DEPOSITION EXCERPT PURSUANT TO THE PROTECTIVE ORDER [49] AND LR 79-5.1; PROPOSED ORDER; CONFIDENTIAL PORTIONS OF DEPOSITION OF ARBEN KRYEZIU. (Hagemann, Michael)
2013-07-02 159 0 Objection/Opposition (Motion related) Opposition re: MOTION for Hearing re Designation Under Protective Order [139] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Excerpts of Deposition of Arben Kryeziu, # (3) Exhibit 3, # (4) Exhibit 4, # (5) Exhibit 5)(Hagemann, Michael)
2013-06-27 160 0 Application to Seal SEALED DOCUMENT- APPLICATION for Filing Documents Under Seal in Connection with Defendants Code Rebel, LLC, Arben Kryeziu, and Volodymyr Bykov's Reply in Support of Motion for Summary Judgment, or in the Alternative Summary Adjudication. (mat)
2013-07-01 161 0 Order on Application to Seal (document) ORDER by Judge Ronald S.W. Lew granting [160] Application to Seal. (jre)
2013-06-27 162 0 Supplement(Motion related) SEALED DOCUMENT - DEFENDANTS CODE REBEL, LLC, ARBEN KRYEZIU, AND VOLODYMYR BYKOV'S SUPPLEMENTAL EVIDENTIARY OBJECTIONS TO DECLARATIONS OF JOSEPH COHEN, RONNIE EXLEY AND MICHAEL K. HAGEMANN IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE SUMMARY ADJUDICATION. (lom)
2013-07-01 163 0 Exhibit (non-trial) SEALED DOCUMENT - VIDEOTAPED DEPOSITION OF VOLODYMYR BYKOV aka VLADIMIR BICKOV FRIDAY, FEBRUARY 15, 2013 ATTORNEY'S EYES ONLY (EXHIBIT "H"). (lom)
2013-07-09 164 0 Reply (Motion related) REPLY in support MOTION for Hearing re Designation Under Protective Order [139] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration Supplemental Declarations of John M. Houkom and Andres F. Quintana)(Quintana, Andres)
2013-07-09 165 0 Exhibit List JOINT Exhibit List filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu.. (Quintana, Andres)
2013-07-09 166 0 Witness List Witness List filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu.. (Quintana, Andres)
2013-07-09 167 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal, [Proposed] Order, and Confidential Excerpts of Defendants' Memorandum of Contentions of Law and Fact. (Quintana, Andres)
2013-07-09 168 0 Witness List Witness List filed by Plaintiff Aqua Connect Inc.. (Hagemann, Michael)
2013-07-09 169 0 Memorandum of Contentions of Fact and Law MEMORANDUM of CONTENTIONS of FACT and LAW filed by Plaintiff Aqua Connect Inc. (Hagemann, Michael)
2013-07-09 170 0 Memorandum of Contentions of Fact and Law MEMORANDUM of CONTENTIONS of FACT and LAW filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres)
2013-07-10 171 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#1) to Exclude Plaintiff's Expert Witnesses filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/7/2013 at 10:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom, # (2) Proposed Order)(Quintana, Andres)
2013-07-10 172 0 Audio Recording Form (AO-436) COMPACT DISC Order for date of proceedings 6/27/2013 to 6/27/2013 re: Order on Ex Parte Application to Supplement, Order on Ex Parte Application for Order re Discovery Matter, Discovery Hearing[152], filed by Plaintiff Aqua Connect Inc. Court will contact Michael K. Hagemann at mhagemann@mkhlaw.com with any questions regarding this order. Transcript portion requested: Pre-Trial Proceeding: 6/27/2013. FEE PAID. (Hagemann, Michael)
2013-07-11 173 0 Order ORDER re: Briefing Schedule on Motions in Limine; Defendants' Motion in Limine No. 1 [171] by Judge Ronald S.W. Lew: The Court hereby re-sets the briefing schedule for any motions in limine to be filed in this Action. SEE ORDER FOR DETAILS. The Court hereby VACATES the August 7, 2013, hearing re Defendants' Motion in Limine No. 1 [171]. (jre)
2013-07-10 174 0 Application to Seal APPLICATION for Filing Documents Under Seal filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (jre)
2013-07-12 175 0 Order on Application to Seal (document) ORDER Granting Application for Filing Documents Under Seal [174] by Judge Ronald S.W. Lew. (jre)
2013-07-11 176 0 Supplement (non-motion) SEALED DOCUMENT-CONFIDENTIAL EXCERPTS OF DEFENDANTS' MEMORANDUM OF CONTENTIONS OF FACT AND LAW (lc)
2013-07-19 177 0 Notice of Lodging Proposed Pretrial Order NOTICE OF LODGING Proposed Pretrial Conference Order Plaintiff Aqua Connect Inc. (Attachments: # (1) [Proposed] Final Pretrial Conference Order)(Hagemann, Michael)
2013-07-23 178 0 Text Only Scheduling Notice TEXT ONLY ORDER (IN CHAMBERS) by Judge Ronald S.W. Lew: The Final Pretrial Conference, set for 7/30/2013, at 10:00 AM, is hereby CONTINUED to 7/30/2013, at 12:00 PM. Counsel shall appear at this new later time. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (jre)
2013-07-23 179 0 Order on Motion for Summary Judgment ORDER RE: Defendants' Motion for Summary Judgment, or in the Alternative for Summary Adjudication [102]; Defendants' Motion for Sanctions for Spoliationof Evidence [105] by Judge Ronald S.W. Lew: For the reasons set forth above, this Court GRANTS IN PART AND DENIES IN PART Defendants Motion forSummary Judgment as follows: Breach of Contract - DENY; False Promise - GRANT; Unfair Competition - DENY; Unjust Enrichment - GRANT. The Court DENIES Defendants Motion for Sanctions. SEE ORDER FOR FURTHER DETAILS. (jre) 2013-07-24 07:08:27 b4e683a18395d35369cdad4e7e3e7fd33cfe76f7
2013-07-23 180 0 Findings of Fact & Conclusions of Law FINDINGS OF FACT AND CONCLUSIONS OF LAW [102] signed by Judge Ronald S.W. Lew. (jre) 2013-07-24 07:08:32 3b2cf56ed1c8ec835b73818f11868332b438a662
2013-07-23 181 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#4) to Exclude "open source" information filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 182 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#5) to Exclude other versions of ACTS program filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 183 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#3) to Exclude evidence not produced during discovery filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew.(Quintana, Andres)
2013-07-23 184 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#6) to Exclude evidence of alleged breach of Apple agreement filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 185 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#10) to Exclude contractual interpretations contrary to express terms filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 186 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#8) to Exclude Gummerman's Expert Report and Testimony filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 PM before Judge Ronald S.W. Lew.(Quintana, Andres)
2013-07-23 187 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#7) to Exclude evidence of unalleged breaches filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 188 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#9) to Exclude issues already adjudicated filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration John M. Houkom)(Quintana, Andres)
2013-07-23 189 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#11) to Exclude educational sales filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 190 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#12) to Exclude Expert Report and Testimony of Hermansen filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 191 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#2) to Exclude character evidence filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 192 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#13) to Exclude undisclosed damages calculations filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 193 0 Motion in Limine to Exclude NOTICE OF MOTION AND MOTION IN LIMINE (#14) to Exclude evidence of lost profits on unfair business practices claim filed by defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. Motion set for hearing on 8/13/2013 at 09:00 AM before Judge Ronald S.W. Lew. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-23 194 0 Order on Motion for Hearing re Discovery Matter MINUTES OF Discovery Hearing held before Magistrate Judge Margaret A. Nagle:granting, in part [139] Motion for Hearing. With respect to defendants request for an award of reasonable attorneys fees and costs incurred in bringing Defendants Motion, the Court directs that by no later than 5:00 p.m. on Friday, July 26, 2013, defense counsel shall file the following: (1) a short memorandum of points and authorities that sets forth the legal authority supporting the award of the requested attorneys fees and costs; and (2) a supplemental declaration that details the reasonable attorneys fees and costs incurred in bringing Defendants Motion. Pending the filing of these further submissions, defendants request for an award of fees and costs will remain under submission.Court Recorder: CS. (ec)
2013-07-23 195 0 Minutes of In Chambers Order/Directive - no proceeding held MINUTE ORDER IN CHAMBERS by Magistrate Judge Margaret A. Nagle Plaintiffs Application To Seal Deposition Excerpt Pursuant to The Protective Order [49] And LR 79-5.1 [158]. By no later than 5:00 p.m. on Friday, July 26, 2013, defendants shall file a declaration that explains why filing the excerpts of the deposition of Arben Kryeziu under seal is appropriate and meets the good cause standard for filing under seal pursuant to Local Rule 79-5. Pending the filing of the further submission, Plaintiffs Application will remain under submission. (ec)
2013-07-24 196 0 Audio Recording Form (AO-436) COMPACT DISC Order for date of proceedings 7/23/2013 to 7/23/2013 re: Order on Motion for Hearing re Discovery Matter, Discovery Hearing,,,,,, [194], filed by Plaintiff Aqua Connect Inc. Court will contact Michael K. Hagemann at mhagemann@mkhlaw.com with any questions regarding this order. Transcript portion requested: Pre-Trial Proceeding: 7/23/2013. FEE PAID. (Hagemann, Michael)
2013-07-24 197 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal; [Proposed[ Order Granting Application for Filing Under Seal; and, Declaration of John M. Houkom in Support of Motion in Limine No. 3. (Quintana, Andres)
2013-07-24 198 0 Notice of Manual Filing (G-92) NOTICE of Manual Filing filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu of Application for Filing Under Seal, [Proposed] Order Granting Application for Filing Under Seal, and, Declaration of John M. Houkom in Support of Motion in Limine No. 8. (Quintana, Andres)
2013-07-26 199 0 Supplement(Motion related) SUPPLEMENT to MOTION for Hearing re Designation Under Protective Order [139] per July 23, 2013 Order of the Court filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Attachments: # (1) Declaration of John M. Houkom)(Quintana, Andres)
2013-07-28 200 0 Motion Related Document RESPONSE TO SUPPLEMENT [199] re MOTION for Hearing re Designation Under Protective Order [139] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann)(Hagemann, Michael)
2013-07-26 201 0 Application to Seal APPLICATION For Filing Documents Under Seal in Connection with Motion in Limine No. 3 filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (jre) Modified on 7/29/2013 to reflect correct file date (jre).
2013-07-26 202 0 Order on Application to Seal (document) ORDER Granting Application [201] for Filing Documents Under Seal in Connection with Motion in Limine No. 3 by Judge Ronald S.W. Lew. (jre) Modified on 7/29/2013 to reflect corrrect file date (jre).
2013-07-26 203 0 Application to Seal APPLICATION for Filing Documents Under Seal in Connection with Motion In Limine No. 8 filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (jre) Modified on 7/29/2013 to reflect correct file date (jre).
2013-07-26 204 0 Order on Application to Seal (document) Order Granting Application for Filing Documents Under Seal in Connection with Motion in Limine No. 8 [203] by Judge Ronald S.W. Lew. (jre)
2013-07-30 205 0 Order on Motion in Limine to Exclude MINUTES OF STATUS CONFERENCE held before Judge Ronald S.W. Lew. Case called. Court and counsel confer. A Status Conference is held. The Court vacates the Final Pretrial Conference and Jury Trial dates. The Court sets the following dates: DISCOVERY CUT-OFF 10-30-13; EXPERT CUT-OFF 01-30-14; MOTION FILING CUT-OFF 01-30-14; FINAL PRETRIAL CONFERENCE 03-18-14 at 10 A.M.; JURY TRIAL 04-15-14 at 9 A.M. All Motion in Limine hearing dates are VACATED with the exception of Motion in Limine #2 (doc. #191). Counsel shall file an opposition to the motion, if any, on or before August 5, 2013. New Motions in Limine may be filed after discovery has been completed. Court Reporter: Deborah Gackle. (jre)
2013-07-30 206 0 Amended Minutes AMENDED MINUTES OF STATUS CONFERENCE held before Judge Ronald S.W. Lew: Case called. Court and counsel confer. A Status Conference is held. The Court vacates the Final Pretrial Conference and Jury Trial dates. The Court sets the following dates: DISCOVERY CUT-OFF 10-30-13; EXPERT CUT-OFF 01-30-14; MOTION FILING CUT-OFF 01-30-14; FINAL PRETRIAL CONFERENCE 03-18-14 at 10 A.M.; JURY TRIAL 04-15-14 at 9 A.M. All MotionS in Limine are VACATED with the exception of Motion in Limine #2 (doc. #191). Counsel shall file an opposition to the motion, if any, on or before August 5, 2013. New Motions in Limine may be filed after discovery has been completed. Court Reporter: Deborah Gackle. (jre) (Main Document 206 replaced on 7/30/2013) (jre).
2013-07-26 207 0 Declaration (Motion related) SEALED DOCUMENT-DECLARATION OF JOHN M HOUKOM IN SUPPORT OF MOTION IN LIMINE NO.8 TO EXCLUDE AND STRIKE THE EXPERT REPORT OF LEE GUMMERMAN (lc)
2013-07-26 208 0 Declaration (Motion related) SEALED DOCUMENT-DECLARATION OF JOHN M HOUKOM IN SUPPORT OF MOTION IN LIMINE NO.3 TO EXCLUDE EVIDENCE AND TESTIMONY RELATED TO DOCUMENTS AND INFORMATIONNOT PRODUCED DURING DISCOVERY (lc)
2013-08-05 209 0 Objection/Opposition (Motion related) Opposition re: MOTION IN LIMINE (#2) to Exclude character evidence [191] filed by Plaintiff Aqua Connect Inc. (Attachments: # (1) Declaration of Michael K. Hagemann, # (2) Exhibit 1, # (3) Exhibit 2, # (4) Select Portions of Bykov Deposition, # (5) Select Portions of Kryeziu Deposition)(Hagemann, Michael)
2013-08-12 210 0 Reply (Motion related) REPLY in support MOTION IN LIMINE (#2) to Exclude character evidence [191] filed by Defendants Volodymyr Bykov, Code Rebel LLC, Arben Kryeziu. (Quintana, Andres) 2013-08-13 13:04:04 b65a956b834e2271428ce605205b2221aa4f51d9