Case number 1:21-cv-02123
The United States of America v. Global Occupational Safety and Health Academy, LLC > Documents
| Date Field | Doc. No. | Description (Pages) |
|---|---|---|
| Mar 2, 2023 | 56 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report 55 on expert discovery. Plaintiff has disclosed its opening expert report, no other opening expert reports have been served, and at this time, no expert depositions have been scheduled. The parties are reminded that the depositions of experts shall be completed by 3/23/23, and dispositive motions shall be filed by 5/2/23 27 . By 3/30/23, the parties shall file a joint status report confirming the completion of expert discovery. The parties shall also report whether they are mutually interested in scheduling a settlement conference with the Court. Mailed notice (cc, ) (Entered: 03/02/2023) (1) |
| Mar 1, 2023 | 55 | STATUS Report Joint Status Report on Expert Discovery (Corrected Dkt. 54) by The United States of America (Pace, David) (Entered: 03/01/2023) (2) |
| Mar 1, 2023 | 54 | STATUS Report Joint Status Report on Expert Discovery by The United States of America (Pace, David) (Incorrect pdf document linked - Docket Text Modified by Clerk's Office.). Modified on 3/1/2023 (aee, ). (Entered: 03/01/2023) (2) |
| Jan 18, 2023 | 53 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report on expert discovery 52 . Plaintiff has disclosed its opening expert and the parties are proceeding with expert discovery in accordance with the expert discovery schedule set by the Court 27 . By 3/1/23, the parties shall file a joint status report on expert discovery setting forth what additional expert discovery has been completed, what expert discovery remains, and whether any discovery disputes require the Court's attention. Mailed notice (cc, ) (Entered: 01/18/2023) (1) |
| Jan 17, 2023 | 52 | STATUS Report Joint Status Report on Expert Discovery by The United States of America (Pace, David) (Entered: 01/17/2023) (2) |
| Dec 29, 2022 | 51 | ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice. (tg, ) (Entered: 12/30/2022) (1) |
| Dec 12, 2022 | 50 | MINUTE entry before the Honorable Jeffrey Cummings:The Court has reviewed the parties' joint status report 49 informing the Court that fact discovery has been completed. By 1/17/23, the parties shall file a joint status report setting forth what expert discovery has been completed, what expert discovery remains, and whether any discovery disputes require the Court's attention. The parties are reminded that they may contact this Court's courtroom deputy if at any point they are mutually interested in scheduling a settlement conference with the Court. Mailed notice (cc, ) (Entered: 12/12/2022) (1) |
| Dec 9, 2022 | 49 | STATUS Report by The United States of America (Pace, David) (Entered: 12/09/2022) (2) |
| Nov 21, 2022 | 48 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report 47 . The parties report that plaintiff has produced an additional 350 pages of documents and completed four depositions; and defendant completed its production of documents with the exception of LinkedIn messages. Both parties have completed all discovery with the exception of the LinkedIn messages but have agreed to search terms. By 12/9/22, the parties shall file a joint status report confirming the completion of fact discovery. The parties further report they remain in agreement that no changes to the Court's expert discovery schedule 27 are needed. The Court will set a joint status report on expert discovery at a later date. Mailed notice (cc, ) (Entered: 11/21/2022) (1) |
| Nov 10, 2022 | 47 | STATUS Report Joint Status Report on the Progress of Fact Discovery by The United States of America (Pace, David) (Entered: 11/10/2022) (3) |
| Oct 5, 2022 | 46 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report on discovery 45 . The parties are continuing to exchange documents and have scheduled four depositions in advance of the 12/2/22 fact discovery deadline. The parties are continuing to meet and confer amongst themselves regarding their discovery disputes and do not require Court intervention at this time. By 11/10/22, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains, if any, and whether any discovery disputes require the Court's attention. The parties shall also report whether they are mutually interested in scheduling a settlement conference with the Court. Mailed notice (cc, ) (Entered: 10/05/2022) (1) |
| Oct 5, 2022 | 45 | STATUS Report Joint Status Report on Discovery by The United States of America (Pace, David) (Entered: 10/05/2022) (4) |
| Aug 29, 2022 | 44 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report 43 . The parties have exchanged written discovery responses, are continuing to meet and confer regarding document production, and plan to proceed with depositions in due course. The parties are reminded of the 12/2/22 fact discovery deadline. By 10/5/22, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains (including the schedule for any remaining depositions), and whether any discovery disputes require the Court's attention. The parties are reminded that they may contact this Court's courtroom deputy if at any point they are mutually interested in scheduling a settlement conference with the Court. Mailed notice (cc, ) (Entered: 08/29/2022) (1) |
| Aug 24, 2022 | 43 | STATUS Report Joint Status Report on Discovery by The United States of America (Pace, David) (Entered: 08/24/2022) (3) |
| Jul 1, 2022 | 42 | MINUTE entry before the Honorable Jeffrey Cummings: By 8/24/22, the parties shall file a joint status report on discovery setting forth what discovery has been completed, what discovery remains, and whether any discovery disputes require the Court's attention. Mailed notice (cc, ) (Entered: 07/01/2022) (1) |
| Jun 30, 2022 | 41 | MINUTE entry before the Honorable Martha M. Pacold: Defendant's objections to Judge Cummings's order 36 are overruled and the court adopts Judge Cummings's well-reasoned order. Further, even assuming for the sake of argument that defendant's objections are correct, defendant presents no basis to conclude that including the challenged sentence in the protective order itself violates any law or otherwise prejudices defendant. (rao, ) (Entered: 06/30/2022) (1) |
| Jun 17, 2022 | 40 | RESPONSE by Plaintiff The United States of America to objections 38 (Pace, David) (Entered: 06/17/2022) (6) |
| Jun 13, 2022 | 39 | MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's response to defendant's objections 38 is due by 6/17/2022 and shall not exceed 6 pages. (rao, ) (Entered: 06/13/2022) (1) |
| Jun 9, 2022 | 38 | OBJECTIONS Defendant's Rule 72 Objections to Docket Numbers 36 and 37 (Topic, Matthew) (Entered: 06/09/2022) (7) |
| May 27, 2022 | 37 | CONFIDENTIALITY ORDER Signed by the Honorable Jeffrey Cummings on 5/27/2022. Mailed notice(gcy, ) (Entered: 05/27/2022) (12) |
| May 27, 2022 | 36 | MINUTE entry before the Honorable Jeffrey Cummings: The United States' motion for entry of a protective order 33 is entered over defendant's objection 35 to the inclusion in paragraph 5(a) of a sentence that states: "However, subject to all existing limitations on disclosure of information by the United States (such as but not limited to the Privacy Act, 5 U.S.C. §552a, etc.) nothing in this Order restricts in any way the use or retention of disclosed information by the United States, its agencies, or gents in accordance with or to enforce federal law." Defendant asserts that the inclusion of this provision would permit the United States to "use information obtained through the civil discovery process to investigate or prosecute a criminal case against Defendant or its principals." [35 at 1]. However, as the United States asserts, the Court's entry of a protective order without the language above would effectively grant defendant "use immunity" with respect to any documents produced by limiting the use of the documents to this case only. This would be inappropriate because "[i]t is clear that use immunity is a statutory creation,... and that Congress has delegated the authority to grant use immunity solely to the executive branch of government." United States v. Taylor, 728 F.2d 930, 934 (7th Cir. 1984) (citations omitted). Defendant also asserts that the inclusion of the above provision "would leave the United States free to share Defendant's confidential business plans and other confidential information with Defendant's competitors except where a statute or regulation prohibits disclosure." [35 at 1]. However, federal law (at 5 U.S.C. §552(b)(4)) prohibits the United States from disclosing trade secrets and commercial or financial information obtained from a person that is privileged or confidential. The Court further notes that other judges in this District have entered protective orders with similar language. See, e.g., Butler v. Wilkie, No. 19 C 2728, Order at 3 (N.D.Ill. Sept. 18, 2019). Mailed notice (cc, ) (Entered: 05/27/2022) (2) |
| May 19, 2022 | 35 | MEMORANDUM by Global Occupational Safety and Health Academy, LLC in Opposition to motion for protective order 33 (Topic, Matthew) (Entered: 05/19/2022) (6) |
| May 17, 2022 | 34 | MINUTE entry before the Honorable Jeffrey Cummings: The United States' motion for entry of a protective order 33 is entered and continued. Defendant shall file its response, if any, by 5/20/22. Mailed notice (cc, ) (Entered: 05/17/2022) (1) |
| May 16, 2022 | 33 | MOTION by Plaintiff The United States of America for protective order (Pace, David) (Entered: 05/16/2022) (6) |
| May 6, 2022 | 32 | MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint status report 31 and orders as follows. By agreement of the parties, all non-confidential documents responsive to the outstanding discovery requests shall be produced by 5/20/22. By 5/16/22, plaintiff shall file a motion supporting its proposal that the underlined language on page three of the parties' joint status report should be included in the Court's Model Confidentiality Order. Defendant shall respond by 5/23/22. The Court will either promptly set a hearing or issue a ruling by mail. The parties need not produce their responsive confidential documents until the issue surrounding the confidentiality order is resolved. Mailed notice (lma, ) (Entered: 05/06/2022) (1) |
| May 4, 2022 | 31 | STATUS Report by Global Occupational Safety and Health Academy, LLC (Attachments: # 1 Exhibit Protective Order)(Topic, Matthew) (Entered: 05/04/2022) (Exhibit Protective Order) (14) |
| May 4, 2022 | 31 | STATUS Report by Global Occupational Safety and Health Academy, LLC (Attachments: # 1 Exhibit Protective Order)(Topic, Matthew) (Entered: 05/04/2022) (Main Document) (4) |
| Mar 7, 2022 | 30 | answer to amended complaint (12) Docket Text: ANSWER to amended complaint by Global Occupational Safety and Health Academy, LLC(Topic, Matthew) |
| Mar 7, 2022 | 29 | order on motion for leave to file (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Defendant's unopposed motion for leave to file an out of time answer to the amended complaint [28] is granted. Defendant is directed to file its answer separately on the docket by 3/11/2022. (rao, ) |
| Mar 4, 2022 | 28 | Exhibit A (12) |
| Mar 4, 2022 | 28 | Main Document (3) Docket Text: MOTION by Defendant Global Occupational Safety and Health Academy, LLC for leave to file an out of time Answer to the Amended Complaint (Attachments: # (1) Exhibit A)(Topic, Matthew) |
| Feb 24, 2022 | 27 | set deadlines (1) Docket Text: MINUTE entry before the Honorable Jeffrey Cummings: The Court has reviewed the parties' joint proposed scheduling order [26] and adopts the parties' proposed schedule as follows: parties to exchange initial disclosures by 3/2/22; deadline for joining of additional parties is 4/4/22; deadline for amendment of pleadings by 5/2/22; non-expert fact discovery to be completed by 12/2/22; opening expert reports due on issues for which a party bears the burden of proof by 1/9/23; rebuttal expert reports due 2/23/23; depositions of experts to be completed by 3/23/23; and dispositive motions to be filed by 5/2/23. By 5/4/22, the parties shall file a joint status report setting forth what discovery has been completed, what discovery remains, and whether any discovery disputes require the Court's attention. If the parties are mutually interested in a settlement conference, they shall also address the issues set forth in the first paragraph of the second page of the Court's Standing Order For Settlement Conferences and provide the dates that the parties are mutually available in June and July 2022 for a remote video settlement conference. The deadlines for the submission of settlement letters described in the Standing Order and the date for the settlement conference will be promptly set after the joint status report is received. Mailed notice (cc, ) |
| Feb 23, 2022 | 26 | proposed pretrial order (4) Docket Text: PROPOSED Pretrial Order Joint Proposed Scheduling Order (Pace, David) |
| Feb 15, 2022 | 25 | Exhibit C (6) |
| Feb 15, 2022 | 24 | set deadlines (1) Docket Text: MINUTE entry before the Honorable Jeffrey Cummings: This case has been referred for discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motion schedule, and for settlement [23]. The Court has reviewed the parties' recent joint status report [21]. On or before 2/23/22, the parties are ordered to have a Rule 26(f) conference and file a proposed scheduling order that includes proposed deadlines for fact discovery, expert discovery (if any), and the filing of amended pleadings, and dispositive motions. Mailed notice (cc, ) |
| Feb 15, 2022 | 25 | Main Document (12) Docket Text:FIRST AMENDED complaint by The United States of America against Global Occupational Safety and Health Academy, LLC (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I)(Pace, David) |
| Feb 15, 2022 | 25 | Exhibit A (1) |
| Feb 15, 2022 | 25 | Exhibit B (2) |
| Feb 15, 2022 | 25 | Exhibit D (1) |
| Feb 15, 2022 | 25 | Exhibit E (39) |
| Feb 15, 2022 | 25 | Exhibit F (7) |
| Feb 15, 2022 | 25 | Exhibit G (2) |
| Feb 15, 2022 | 25 | Exhibit H (37) |
| Feb 15, 2022 | 25 | Exhibit I (15) |
| Feb 14, 2022 | 23 | Expedited referral to magistrate judge (1) Docket Text: Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Jeffrey Cummings for the purpose of holding proceedings related to: discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. (rao, ) |
| Feb 11, 2022 | 22 | status report (5) Docket Text: STATUS Report Joint Initial Status Report by The United States of America (Pace, David) |
| Jan 28, 2022 | 21 | notification of affiliates pursuant to local rule 3.2 (2) Docket Text: NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Global Occupational Safety and Health Academy, LLC (Topic, Matthew) |
| Jan 28, 2022 | 20 | answer to complaint (12) Docket Text: ANSWER to Complaint with Jury Demand by Global Occupational Safety and Health Academy, LLC(Topic, Matthew) |
| Dec 28, 2021 | 19 | order on motion to withdraw as attorney (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Daniel Hwang's motion to withdraw as attorney of record on behalf of Defendant [18] is granted. Attorney Daniel I Hwang terminated. (rao, ) |
| Dec 26, 2021 | 18 | motion to withdraw as attorney (2) Docket Text: MOTION by Attorney Daniel Hwang to withdraw as attorney for Global Occupational Safety and Health Academy, LLC. No party information provided (Hwang, Daniel) |
| Dec 16, 2021 | 17 | order on motion for extension of time (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Defendant's agreed/consent motion for extension of time [16] is granted. Defendant to answer or otherwise plead to the complaint by 1/28/2022. The parties are directed to file the initial joint status report by 2/11/2022. (rao, ) |
| Dec 16, 2021 | 16 | extension of time (3) Docket Text: MOTION by Defendant Global Occupational Safety and Health Academy, LLC for extension of time (Topic, Matthew) |
| Dec 15, 2021 | 15 | attorney appearance (1) Docket Text: ATTORNEY Appearance for Defendant Global Occupational Safety and Health Academy, LLC by Matthew Vincent Topic (Topic, Matthew) |
| Dec 2, 2021 | 14 | attorney appearance (1) Docket Text: ATTORNEY Appearance for Plaintiff The United States of America by David Lucian Pace (Pace, David) |
| Oct 15, 2021 | 13 | order on motion for extension of time (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Agreed/Consent motion for extension of time [12] is granted. Defendant to answer or otherwise plead to the complaint by 12/20/2021. The parties are given until 12/21/2021 to file the initial joint status report. (rao, ) |
| Oct 14, 2021 | 12 | extension of time (3) Docket Text: MOTION by Defendant Global Occupational Safety and Health Academy, LLC for extension of time with consent (Hwang, Daniel) |
| Aug 14, 2021 | 11 | order on motion for extension of time (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Defendant's agreed/consent motion for extension of time [10] is granted. Defendant to answer or otherwise plead to plaintiff's complaint by 10/19/2021. The parties are directed to file the initial joint status report by 10/22/2021. (rao, ) |
| Aug 13, 2021 | 10 | extension of time (3) Docket Text: MOTION by Defendant Global Occupational Safety and Health Academy, LLC for extension of time with consent (Hwang, Daniel) |
| Jun 16, 2021 | 9 | Initial Status Report outline (2) |
| Jun 16, 2021 | 9 | Main Document (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: Defendants' agreed motion for extension of time [8] is granted. Defendant to answer or otherwise plead to Plaintiff's complaint by 8/20/2021. The parties are directed to file the initial joint status report by 8/23/2021. (Attachments: # (1) Initial Status Report outline) (rao, ) |
| Jun 16, 2021 | 8 | extension of time (3) Docket Text: MOTION by Defendant Global Occupational Safety and Health Academy, LLC for extension of time with Consent (Hwang, Daniel) |
| Jun 14, 2021 | 7 | attorney appearance (1) Docket Text: ATTORNEY Appearance for Defendant Global Occupational Safety and Health Academy, LLC by Daniel I Hwang (Hwang, Daniel) |
| May 24, 2021 | 6 | Initial Status Report outline (2) |
| May 24, 2021 | 6 | Main Document (1) Docket Text: MINUTE entry before the Honorable Martha M. Pacold: The parties are directed to file an initial joint status report by 6/24/2021. (Attachments: # (1) Initial Status Report outline) (rao, ) |
| May 20, 2021 | 5 | waiver of service executed (1) Docket Text: WAIVER OF SERVICE returned executed by The United States of America. Global Occupational Safety and Health Academy, LLC waiver sent on 4/20/2021, answer due 6/21/2021. (Munnelly, Jenna) |
| Apr 23, 2021 | 4 | civil cover sheet (1) Docket Text: CIVIL Cover Sheet (Munnelly, Jenna) |
| Apr 23, 2021 | 3 | attorney appearance (1) Docket Text: ATTORNEY Appearance for Plaintiff The United States of America by Jenna Elizabeth Munnelly (Munnelly, Jenna) |
| Apr 23, 2021 | 2 | Patent/Trademark report (10) Docket Text: MAILED Trademark report to Patent Trademark Office, Alexandria VA. (jh, ) |
| Apr 22, 2021 | N/A | case assigned (0) Docket Text: CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Jeffrey I. Cummings. Case assignment: Random assignment. (dxb, ) |
| Apr 20, 2021 | 1 | Exhibit I (15) |
| Apr 20, 2021 | 1 | Exhibit H (37) |
| Apr 20, 2021 | 1 | Exhibit G (2) |
| Apr 20, 2021 | 1 | Exhibit F (7) |
| Apr 20, 2021 | 1 | Exhibit E (39) |
| Apr 20, 2021 | 1 | Exhibit D (1) |
| Apr 20, 2021 | 1 | Exhibit C (6) |
| Apr 20, 2021 | 1 | Exhibit B (2) |
| Apr 20, 2021 | 1 | Exhibit A (1) |
| Apr 20, 2021 | 1 | Main Document (12) Docket Text: COMPLAINT filed by THE UNITED STATES OF AMERICA; (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)(Munnelly, Jenna) |
