FILED THE HONORABLE MARY YU HEARING DATE: SEPTEMBER IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "FILED THE HONORABLE MARY YU HEARING DATE: SEPTEMBER IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING"

Transcription

1 FILED AUG PM 1: THE HONORABLE MARY YU HEARING DATE: SEPTEMBER KING COUNTY, SUPERIOR COURT CLERK E-FILED CASE NUMBER: ---1 SEA 1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING FARMERS INSURANCE COMPANY OF WASHINGTON, a Washington corporation; FARMERS INSURANCE EXCHANGE, a foreign insurance exchange; FIRE INSURANCE EXCHANGE, a foreign insurance exchange; TRUCK INSURANCE EXCHANGE, a foreign insurance exchange; MID-CENTURY INSURANCE COMPANY, a California corporation; and FARMERS NEW WORLD LIFE INSURANCE COMPANY, a Washington corporation, v. Plaintiffs, DAMIAN GREENE, an individual; DAMIAN J. GREENE INSURANCE AGENCY, INC., a Washington corporation; SOLEYON INSURANCE PARTNERS, INC., a Washington corporation; JOSH BERG, an individual d/b/a BLUE LION BROKERS; BLUE LION BROKERS, LLC, a Washington limited liability company; and DOES -, Defendants. No SEA THIRD-PARTY DEFENDANTS ROBERT ARCHER AND ROBERT O. ARCHER INSURANCE AGENCY, INC.'S JOINDER OF THIRD-PARTY DEFENDANT FARMERS GROUP INC. S MOTION TO DISMISS DEFENDANT/THIRD-PARTY PLAINTIFF GREENE'S COUNTERCLAIMS PURSUANT TO CR 1(b)() AND ARCHER S MOTION TO DISMISS DEFENDANT/THIRD-PARTY PLAINTIFF GREENE'S CLAIMS PURSUANT TO CR 1(b)() PARTY PLAINTIFFS GREENE'S CLAIMS - 1 LEGAL\0\ /0.000

2 DAMIAN GREENE, an individual; DAMIAN J. GREENE INSURANCE AGENCY, INC., a Washington corporation, v. Third-Party Plaintiffs, FOREMOST INSURANCE COMPANY, a foreign insurance company; DONALD HORNER, an individual d/b/a DON HORNER AGENCY; ROBERT ARCHER, an individual; ROBERT O. ARCHER INSURANCE AGENCY, INC., a Washington corporation, Third-Party Defendants. 1 I. INTRODUCTION AND RELIEF REQUESTED Third-Party Defendants Robert Archer and Robert O. Archer Insurance Agency, Inc., (hereinafter, collectively, Archer ), by and through their attorneys of record, Cozen O Connor, files this Joinder to Third-Party Defendant Farmers Group, Inc. s Motion to Dismiss Defendant Greene s Counterclaims Pursuant to CR 1(b)(), (hereinafter, FGI s Motion to Dismiss ) and respectfully incorporates all facts, legal arguments, and prayer for relief made by Farmers Group, Inc. in its Motion. In addition, Archer asks for the independent relief of an Order dismissing Defendants/Third Party Plaintiffs Damian Greene and the Damian Greene Insurance Agency, Inc. s (hereinafter, collectively, Greene ) claims against Archer, asserted in Greene s Answer to Second Amended Complaint, and Amended Counterclaim and Third-Party Claims of Defendants Greene, dated July 1,. Greene fails to allege any facts to support his Third- Party claims against Archer, and accordingly, this Court should dismiss those claims, with prejudice. PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

3 1 II. STATEMENT OF FACTS By reference herein, Archer incorporates the Statement of Facts from FGI s Motion to Dismiss as if pled herein. Plaintiffs filed this lawsuit in December against Greene. On July 1,, Greene filed an [Amended] Answer to Second Amended Complaint, and Amended Counterclaim and Third-Party Claims of Defendants Greene (hereinafter, Amended Answer and Third-Party Claims ). This pleading, for the first time, asserted claims against new third-party defendants Robert Archer and the Robert O. Archer Insurance Agency, Inc. Archer is the District Manager for FGI s Washington District. The (disputed) factual references to Archer in the Amended Answer and Third-Party Claims are as follows:. Defendant Greene immediately contacted his District Manager, Bob Archer, to object to Mr. Horner setting up his office less than one mile away on the same road.. Despite Defendant Greene s objections, Mr. Archer explained there was nothing Farmers could do to stop Mr. Horner and that Farmers could not deny any individual the right to earn a living. III. STATEMENT OF THE ISSUE By reference herein, Archer incorporates the Statement of the Issue from FGI s Motion to Dismiss as if pled herein. In addition, Archer posits the following parallel issue:. Whether all of Greene s claims against Third-Party Defendants Archer should be dismissed under CR 1(b)(), because Greene s Amended Answer and Third-Party Claims allege no facts whatsoever to support any claim for relief against Archer? IV. EVIDENCE RELIED UPON In support of this Joinder and Motion to Dismiss, Archer relies upon the records and pleadings on file in this matter. PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

4 1 V. AUTHORITY AND ANALYSIS By reference herein, Archer incorporates the Legal Authority from FGI s Motion to Dismiss as if pled herein. In addition, Greene s third-party claims against Archer should likewise be dismissed as follows: A. Greene Fails to Allege Facts to Sustain A Cause of Action under Washington s Consumer Protection Act, RCW., Et Seq. Greene s first Third-Party claim against Archer asserts a violation of the Consumer Protection Act, RCW.. To state a claim under the CPA, Greene must show (1) an unfair or a deceptive act or practice; () occurring in trade or practice; () public interest impact; () injury to Greene in his business or property; and () a causal link between the unfair or deceptive acts and the injury suffered by Greene. Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. Co., Wn.d, 0, P.d 1 (). Greene fails to allege any facts at all to support these elements as to Archer, his former district manager. In particular, Greene woefully fails to even attempt to allege any facts that meet elements 1,,, or. Accordingly, dismissal of Greene s Third-Party claim against Archer is warranted. B. Greene Fails to Allege Facts to Sustain a Cause of Action for Unjust Enrichment. Greene s second Third-party claim against Archer is for unjust enrichment. The elements of said claim in Washington are: (1) plaintiff conferred a benefit upon the defendant; () the defendant knew about the benefit; and () the defendant s accepting the benefit without the payment is inequitable or unjust. Austin v. Ettl, 1 Wn. App.,, P.d (1). Greene fails to allege any facts to support these elements as to Archer. There is no allegation that Third-Party Plaintiffs Greene even conferred a benefit upon Archer, nor that Archer failed to compensate Greene for any alleged benefit. The claim fails as to Archer because it is inadequately pled and improper, pursuant to CR 1(b)(). PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

5 1 C. Greene Fails to Allege Facts to Sustain a Cause of Action for Constructive Fraud. Greene s third and final third-party claim against Archer is for constructive fraud. Constructive fraud is an action in equity, and requires, at a minimum, evidence of a the existence of a legal duty and a breach thereof. See Dexter Horton Bldg. Co. v. King County, Wn.d, 1, 1 P.d 0 (1). Greene fails to allege any facts to support the existence of a duty owed by Archer to Greene and a breach thereof by Archer. Greene asserts that Archer owed a fiduciary duty [arising from] its implied and actual promises to pay contract value Archer was not a party to any contract with Greene, and there are no allegations in the Amended Answer and Third Party Claims that establish otherwise. Accordingly, this claim fails as to Archer and should be dismissed, pursuant to CR 1(b)(). VI. CONCLUSION For all of the foregoing reasons, as well as the facts and authority in FGI s Motion to Dismiss, the Court should grant both Third-Party Defendants FGI and Archer s Motions to Dismiss Defendant/Third-Party Plaintiffs Greene s claims. DATED this th day of August,. COZEN O'CONNOR By: /s/ William F. Knowles William F. Knowles, WSBA No. Charlotte A. Archer, WSBA No. 0 Attorneys for Third-Party Defendants Robert Archer and Robert O. Archer Insurance Agency, Inc. PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

6 CERTIFICATE OF SERVICE The undersigned certifies, under penalty of perjury under the laws of the State of Washington, that the foregoing document was served upon the interested parties in the manner indicated below: 1 Molly M. Daily, WSBA No. 0 Timothy W. Snider, WSBA No. 0 Stoel Rives, LLP 00 University Street, Suite 00 Seattle, Washington 1 Phone: () -000 Fax: () Attorneys for Plaintiff William C. Smart, WSBA No. Ian S. Birk, WSBA No. 1 Keller Rohrback, LLP Third Avenue, Suite 0 Seattle, Washington 1 Phone: () -00 Fax: () - George A. Mix, WSBA No. Mix Sanders, PLLC Fifth Avenue, Suite 0 Seattle, Washington 1 Phone: () - Fax: Attorneys for Defendants / Third-Party Plaintiffs Damian Greene and Damian J. Greene Insurance Agency, Inc. ( ) Via Legal Messenger ( ) Via Overnight Courier ( ) Via Facsimile (X) Via U.S. Mail (X) Via ( ) Via Legal Messenger ( ) Via Overnight Courier ( ) Via Facsimile (X) Via U.S. Mail (X) Via ( ) Via Legal Messenger ( ) Via Overnight Courier ( ) Via Facsimile (X) Via U.S. Mail (X) Via PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

7 Patrick L. Hinton, WSBA No. Golbeck Roth, PLLC Post Office Box Bainbridge Island, Washington 1 Phone: () - Fax: () - Attorneys for Third Party Defendant Donald Horner d/b/a Don Horner Insurance Agency ( ) Via Legal Messenger ( ) Via Overnight Courier ( ) Via Facsimile (X) Via U.S. Mail (X) Via 1 SIGNED AND DATED this th day of August,, at Seattle, Washington. COZEN O'CONNOR By: /s/ Bonnie L. Enera Bonnie L. Enera, Legal Assistant PARTY PLAINTIFFS GREENE'S CLAIMS - LEGAL\0\ /0.000

8 THE HONORABLE MARY YU 1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING FARMERS INSURANCE COMPANY OF WASHINGTON, a Washington corporation; FARMERS INSURANCE EXCHANGE, a foreign insurance exchange; FIRE INSURANCE EXCHANGE, a foreign insurance exchange; TRUCK INSURANCE EXCHANGE, a foreign insurance exchange; MID-CENTURY INSURANCE COMPANY, a California corporation; and FARMERS NEW WORLD LIFE INSURANCE COMPANY, a Washington corporation, v. Plaintiffs, DAMIAN GREENE, an individual; DAMIAN J. GREENE INSURANCE AGENCY, INC., a Washington corporation; SOLEYON INSURANCE PARTNERS, INC., a Washington corporation; JOSH BERG, an individual d/b/a BLUE LION BROKERS; BLUE LION BROKERS, LLC, a Washington limited liability company; and DOES -, Defendants. DAMIAN GREENE, an individual; DAMIAN J. GREENE INSURANCE AGENCY, INC., a Washington corporation, v. Third-Party Plaintiffs, No SEA [PROPOSED] ORDER GRANTING THIRD-PARTY DEFENDANTS FARMERS GROUP, INC., ROBERT ARCHER, AND ROBERT O. ARCHER INSURANCE AGENCY, INC.'S MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM PURSUANT TO CR 1(B)() [PROPOSED] ORDER GRANTING THIRD-PARTY DEFENDANTS FARMERS GROUP, INC., ROBERT ARCHER, AND ROBERT O. ARCHER - 1 LEGAL\1\ /0.000

9 1 FOREMOST INSURANCE COMPANY, a foreign insurance company; DONALD HORNER, an individual d/b/a DON HORNER AGENCY; ROBERT ARCHER, an individual; ROBERT O. ARCHER INSURANCE AGENCY, INC., a Washington corporation, Third-Party Defendants. THIS MATTER having come on duly and regularly before the undersigned Judge of the above-entitled Court upon Third-Party Defendants Farmers Group, Inc., Robert Archer, and Robert O. Archer Insurance Agency, Inc. s Motion to Dismiss Defendant/Third Party Plaintiffs Damian Greene and Damian J. Greene Insurance Agency, Inc. s Counterclaims and Claims, Pursuant to CR 1(b)(), and the Court having reviewed the files and records herein, including the following: 1. Third-Party Defendant Farmers Group Inc. s Motion to Dismiss for Failure to State a Claim Pursuant to CR 1(b)();. Declaration of Timothy W. Snider in Support of Farmers Group Inc. s Motion to Dismiss for Failure to State a Claim, Pursuant to CR 1(b)();. Third-Party Defendants Robert Archer and Robert O. Archer Insurance Agency, Inc.'s Joinder of Third-Party Defendant Farmers Group Inc. s Motion To Dismiss Pursuant To CR 1(b)() and Archer s Motion To Dismiss Defendant/Third-Party Plaintiff Greene's Claims Pursuant To CR 1(b)(); informed,. ; and.. and the Court having heard the arguments of counsel and being otherwise fully IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Third-Party Defendants Farmers Group, Inc., Robert Archer, and Robert O. Archer Insurance Agency, Inc. s Motion to Dismiss Defendant/Third Party Plaintiffs Damian Greene and Damian J. [PROPOSED] ORDER GRANTING THIRD-PARTY DEFENDANTS FARMERS GROUP, INC., ROBERT ARCHER, AND ROBERT O. ARCHER - LEGAL\1\ /0.000

10 Greene Insurance Agency, Inc. s Counterclaims and Claims, Pursuant to CR 1(b)() is hereby GRANTED. DONE IN OPEN COURT this day of,. Honorable Mary Yu 1 Presented by: COZEN O'CONNOR By: /s/ William F. Knowles William F. Knowles, WSBA No. Charlotte A. Archer, WSBA No. 0 Attorneys for Third-Party Defendants Robert Archer and Robert O. Archer Insurance Agency, Inc. STOEL RIVES By: Timothy W. Snider, WSBA No. 0 Molly Daily, WSBA no. 0 Attorneys for Third-Party Defendant Farmers Group, Inc. [PROPOSED] ORDER GRANTING THIRD-PARTY DEFENDANTS FARMERS GROUP, INC., ROBERT ARCHER, AND ROBERT O. ARCHER - LEGAL\1\ /0.000

FILED THE HONORABLE MARY YU HEARING DATE: OCTOBER 25, 2013, WITH ORAL ARGUMENT

FILED THE HONORABLE MARY YU HEARING DATE: OCTOBER 25, 2013, WITH ORAL ARGUMENT FILED OCT AM : THE HONORABLE MARY YU HEARING DATE: OCTOBER,, KING AT COUNTY :00AM WITH ORAL ARGUMENT SUPERIOR COURT CLERK E-FILED CASE NUMBER: ---1 SEA IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

More information

SUPERIOR COURT OF WASHINGTON FOR ISLAND COUNTY

SUPERIOR COURT OF WASHINGTON FOR ISLAND COUNTY 1 ROGER L. CLOSE, vs. Plaintiff, ADMIRAL'S COVE BEACH CLUB, INC., a Washington non-profit corporation, now known as ADMIRALS COVE HOMEOWNERS ASSOCIATION, INC., Defendants. SUPERIOR COURT OF WASHINGTON

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON ) ) ) ) ) ) ) ) ) ) ) ) ) Case :-cv-000-tor Document Filed 0/0/ 0 John T. John, WSBA # Daniel J. Oates, WSBA # 0 Alaskan Way, Suite 00 Seattle, Washington Telephone: ( -00 Email: jjohn@grahamdunn.com doates@grahamdunn.com Attorney

More information

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW Information or instructions: Defendant s Cross-claims and counterclaims 1. The purpose of counterclaims and cross-actions is to join persons and actions, as permitted by TRCP 39, 40, 41, 49, 50, and 51,

More information

Case 2:14-cv-00244 Document 1 Filed 02/19/14 Page 1 of 9

Case 2:14-cv-00244 Document 1 Filed 02/19/14 Page 1 of 9 Case :-cv-00 Document Filed 0// Page of UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE DR. A. CEMAL EKIN, individually and on behalf of similarly situated individuals, v. Plaintiff,

More information

[Additional Counsel Appear on Signature Page] UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON

[Additional Counsel Appear on Signature Page] UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON Case :0-cv-00-LRS Document - Filed // 0 Toby J. Marshall, WSBA # Erika L. Nusser, WSBA #0 Attorneys for the Plaintiffs Telephone: () -0 Facsimile: () 0- Email: tmarshall@tmdwlaw.com Email: enusser@tmdwlaw.com

More information

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT The Honorable Mariane Spearman 1 1 STATE OF WASHINGTON, V. STATE OF WASHINGTON KING COUNTY SUPERIOR COURT Plaintiff, ROTECH HOLDINGS LTD, a New York corporation, d/b/a ROTECH HOLDINGS, RH GROUP, RH HOLDINGS,

More information

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY

SUPERIOR COURT OF WASHINGTON, COUNTY OF KING THIS NOTICE MAY AFFECT YOUR RIGHTS PLEASE READ IT CAREFULLY SUPERIOR COURT OF WASHINGTON, COUNTY OF KING MYSPINE, PS, a Washington professional services corporation; BODY RECOVERY CLINIC LLC, a Washington Limited Liability Company; and YAROSLAV KUTSY, Plaintiffs,

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. DHL EXPRESS (USA), Inc. ( DHL ) by its attorneys, Bauer Moynihan & Johnson

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. DHL EXPRESS (USA), Inc. ( DHL ) by its attorneys, Bauer Moynihan & Johnson THE HONORABLE JOHN C. COUGHENOUR UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 1 1 MICROSOFT CORPORATION, Plaintiff, v. DHL EXPRESS (USA), Inc., Defendant / Third-Party Plaintiff.

More information

[Additional Counsel Appear on Signature Page] UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON

[Additional Counsel Appear on Signature Page] UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON Case :0-cv-00-LRS Document Filed 0// 0 Toby J. Marshall, WSBA # Erika L. Nusser, WSBA #0 Attorneys for the Plaintiffs Telephone: () -0 Facsimile: () 0- Email: tmarshall@tmdwlaw.com Email: enusser@tmdwlaw.com

More information

FILED 15 JAN 23 PM 3:46

FILED 15 JAN 23 PM 3:46 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY FILED JAN PM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --0- SEA SOLTERRA CITIES, LLC, a Washington company, Plaintiff, v. DUSTIN VAN WYCK, an

More information

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY

SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY THE HONORABLE CAROL MURPHY 1 1 1 1 1 SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY TARVA LEE, ) ) No: --00- Plaintiff, ) ) v. ) COMPLAINT FOR BREACH OF ) CONTRACT, BAD FAITH, FARMERS INSURANCE COMPANY

More information

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 1 1 1 1 1 1 1 1 0 1 Attorney for Defendants John Smith, and Stan Moon SUE KIM SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES CENTRAL DISTRICT, MOSK COURTHOUSE UNLIMITED Plaintiff vs. JOHN SMITH, an

More information

Case 3:08-cv-01406-JM-CAB Document 9 Filed 08/25/2008 Page 1 of 7

Case 3:08-cv-01406-JM-CAB Document 9 Filed 08/25/2008 Page 1 of 7 Case :0-cv-00-JM-CAB Document Filed 0//0 Page of 0 JOHN J. SANSONE, County Counsel County of San Diego By THOMAS D. BUNTON, Senior Deputy (State Bar No. 0 00 Pacific Highway, Room San Diego, California

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant. 1 1 1 1 1 1 1 1 0 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re ORACLE CORPORATION DERIVATIVE LITIGATION SCOTT OZAKI, derivatively and on behalf of ORACLE CORPORATION,

More information

Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6

Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6 Case 2:14-cv-00445-CW-BCW Document 62 Filed 10/20/14 Page 1 of 6 Karra J. Porter, 5223 Karra.Porter@chrisjen.com David C. Richards, 6023 David.Richards@chrisjen.com CHRISTENSEN & JENSEN, P.C. 15 West South

More information

FILED 15 JUL 27 AM 9:22

FILED 15 JUL 27 AM 9:22 FILED JUL AM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --- KNT JUDITH JORGENSEN, vs. SUPERIOR COURT OF WASHINGTON KING COUNTY Plaintiff, JAMES WONG and TYRA WONG, husband and wife creating

More information

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS HOSPITAL DISTRICT NO.1 OF CRAWFORD COUNTY, KANSAS, d/b/a, GIRARD MEDICAL

More information

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING [CLERK S ACTION REQUIRED]

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING [CLERK S ACTION REQUIRED] The Honorable Helen Halpert 1 1 1 1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING NIKOLAY BELIKOV, a married individual; TECHNO-TM ZAO, a Russian closed joint stock company,

More information

Lawyer Beware: The Consumer Protection Act

Lawyer Beware: The Consumer Protection Act February 2012 WSBA Bar News Ethics & the Law Column Lawyer Beware: The Consumer Protection Act By Mark J. Fucile Fucile & Reising LLP Since the Washington Supreme Court s decision in Short v. Demopolis,

More information

SUPERIOR COURT OF THE STATE OF WASHINGTON, KING COUNTY NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

SUPERIOR COURT OF THE STATE OF WASHINGTON, KING COUNTY NOTICE OF PROPOSED CLASS ACTION SETTLEMENT SUPERIOR COURT OF THE STATE OF WASHINGTON, KING COUNTY NOTICE OF PROPOSED CLASS ACTION SETTLEMENT If you paid money to Microsoft for an MSN account established in your name at a Best Buy store, never logged

More information

PLEASE READ THIS NOTICE AND THE ENCLOSED CLAIM FORM CAREFULLY

PLEASE READ THIS NOTICE AND THE ENCLOSED CLAIM FORM CAREFULLY SUPERIOR COURT OF THE STATE OF WASHINGTON, COUNTY OF KING If You Are a Washington Health Care Provider or a Washington PIP Insured of a USAA Company, and Your Health Care Bills Were Reduced Based on an

More information

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS If you are a current or former installation technician of Cable Communications, Inc. and worked in Oregon, please read this Notice carefully.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION INSTITUTE FOR CREATION RESEARCH GRADUATE SCHOOL, Plaintiff, v. CAUSE NO. A:09 CA 382 TEXAS HIGHER EDUCATION COODINATING

More information

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT ST. CLAIR COUNTY, ILLINOIS NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT ST. CLAIR COUNTY, ILLINOIS NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION If you were injured or provided treatment for an injury and filed a claim under your Allstate Med Pay coverage, and were compensated in an amount

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA ) ) ) ) ) ) ) ) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA 1 1 In re LONGS DRUG STORES CORP. SHAREHOLDER LITIGATION This Document Relates To: ALL ACTIONS. Lead Case No. C-0-0 CLASS ACTION FINAL JUDGMENT

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

Case 3:06-cv-00701-MJR-DGW Document 500 Filed 04/30/15 Page 1 of 15 Page ID #13368

Case 3:06-cv-00701-MJR-DGW Document 500 Filed 04/30/15 Page 1 of 15 Page ID #13368 Case 3:06-cv-00701-MJR-DGW Document 500 Filed 04/30/15 Page 1 of 15 Page ID #13368 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS ANTHONY ABBOTT, et al., ) ) No: 06-701-MJR-DGW

More information

Case 1:11-md-02290-RGS Document 396 Filed 12/06/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) ) ) )

Case 1:11-md-02290-RGS Document 396 Filed 12/06/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) ) ) ) Case 1:11-md-02290-RGS Document 396 Filed 12/06/13 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS IN RE JPMORGAN CHASE MORTGAGE MODIFICATION LITIGATION THIS DOCUMENT RELATES TO: All

More information

STATE OF INDIANA ) IN THE HOWARD COURT ) SS: COUNTY OF HOWARD ) CAUSE NO.: APPEARANCE BY ATTORNEY IN CIVIL CASE

STATE OF INDIANA ) IN THE HOWARD COURT ) SS: COUNTY OF HOWARD ) CAUSE NO.: APPEARANCE BY ATTORNEY IN CIVIL CASE STATE OF INDIANA IN THE HOWARD COURT SS: COUNTY OF HOWARD CAUSE NO.: INDIANA DEPARTMENT OF STATE REVENUE, Plaintiff, v. DAVE EVANS TIRE, INC. and DAVE EVANS, Defendants. APPEARANCE BY ATTORNEY IN CIVIL

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN ) ) ) ) ) ) ) ) ) ) ) 2:13-cv-11396-AC-LJM Doc # 88 Filed 05/11/15 Pg 1 of 12 Pg ID 3457 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN MARILYN OVERALL, on behalf of herself, individually, and on behalf of

More information

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON In re Classmates.com Consolidated Litigation, Case No.

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON In re Classmates.com Consolidated Litigation, Case No. UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON In re Classmates.com Consolidated Litigation, Case No. 09-cv-0045-RAJ NOTICE OF PROPOSED CLASS ACTION SETTLEMENT TO: ALL MEMBERS OF THE

More information

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION JONATHAN DANIEL, ) ) Plaintiff, ) No. 14 CV 01232 ) vs. ) ) Honorable Michael M. Mihm THE CITY OF PEORIA, et al.,

More information

Case 1:08-cv-03178-JEI-KMW Document 31 Filed 06/05/2009 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Case 1:08-cv-03178-JEI-KMW Document 31 Filed 06/05/2009 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Case 1:08-cv-03178-JEI-KMW Document 31 Filed 06/05/2009 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ARTHUR R. and JANE M. TUBBS, : individually and on behalf of : others similarly

More information

SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS

SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS AND NOW, the undersigned, in settlement of their dispute as described herein, hereby mutually covenant and agree as follows: WHEREAS, Jeffery Pendleton of

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE HARRY O. LUTZ AND PAULA G. LUTZ; Hon. Case No. v ONE WEST, a successor in interest to INDYMAC BANK, F.S.B.; TITLE SOURCE, INC.; THE MORTGAGE

More information

MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY. Appearing on behalf of the Named Plaintiff and the Class were attorneys Daniel P.

MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY. Appearing on behalf of the Named Plaintiff and the Class were attorneys Daniel P. ,5SEPV Wl0: 3ii /"'LCD JCOURT MONTANA EIGHTH JUDICIAL DISTRICT COURT, CASCADE COUNTY Robert Jacobsen, -vs- Allstate Insurance Company, Plaintiff, Defendant. Cause No.: ADV-03-201(d) Final Order Approving

More information

No. C06-1723 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

No. C06-1723 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 1 JEREMY JEPSON, on behalf of himself and a Class of all others similarly situated, v. Plaintiff, TICOR TITLE INSURANCE COMPANY, a foreign corporation Defendant. UNITED STATES DISTRICT COURT WESTERN DISTRICT

More information

Case 1:06-cv-01143-OWW -SMS Document 80 Filed 01/23/08 Page 1 of 6

Case 1:06-cv-01143-OWW -SMS Document 80 Filed 01/23/08 Page 1 of 6 Case :0-cv-0-OWW -SMS Document 0 Filed 0//0 Page of 0 0 Clark J. Burnham, State Bar No. 0 Andrew R. Shalauta, State Bar No. Michelle M. Meyers, State Bar No. BURNHAM BROWN 0 Harrison Street, th Floor Oakland,

More information

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014 FILED NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 01/17/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK - - - - - - - - - - - - - - - - - - -

More information

Case 3:11-cv-05274-RBL Document 40 Filed 06/14/13 Page 1 of 11

Case 3:11-cv-05274-RBL Document 40 Filed 06/14/13 Page 1 of 11 Case :-cv-0-rbl Document 0 Filed 0// Page of Honorable Ronald B. Leighton Court Use only above this line. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA WILLIAM S. BENDIXEN, and

More information

HOW TO FILE AN ANSWER

HOW TO FILE AN ANSWER PRO SE OFFICE UNITED STATES DISTRICT COURT DANIEL PATRICK MOYNIHAN UNITED STATES COURTHOUSE 500 PEARL STREET, ROOM 230 NEW YORK, NEW YORK 10007 Ruby J. Krajick CLERK OF COURT HOW TO FILE AN ANSWER An answer

More information

Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS

Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS Case 3:06-cv-00701-MJR-DGW Document 526 Filed 07/20/15 Page 1 of 8 Page ID #13631 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ILLINOIS ANTHONY ABBOTT, et al., ) ) No: 06-701-MJR-DGW Plaintiffs,

More information

COURT ORDER STANDARD OF REVIEW STATEMENT OF FACTS

COURT ORDER STANDARD OF REVIEW STATEMENT OF FACTS DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, CO 80202 Plaintiffs: JON C. COOK, an individual, and THE LUMBERYARDS DEVELOPMENT, L.L.C., a Colorado Limited Liability Company,

More information

Case 1:14-cv-13477-FDS Document 64 Filed 01/29/16 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:14-cv-13477-FDS Document 64 Filed 01/29/16 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:14-cv-13477-FDS Document 64 Filed 01/29/16 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS RICHARD MEYER and KATHLEEN LEONE, on behalf of themselves and all others similarly

More information

SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY

SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY In re EXPEDIA HOTEL TAXES AND FEES LITIGATION Master File No. 05-02060-1 SEA NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION If you booked a hotel stay

More information

SETTLEMENT AND RELEASE OF ALL CLAIMS AGREEMENT

SETTLEMENT AND RELEASE OF ALL CLAIMS AGREEMENT AGREEMENT THIS AGREEMENT ("Agreement") is made and entered into by and between the City of Seattle ("City") and the Seattle Times Company ("Seattle Times"). Together, the Seattle Times and the City are

More information

PIERCE COUNTY DISTRICT COURT 930 TACOMA AVE S, Room 239, TACOMA, 98402. Small Claims Information

PIERCE COUNTY DISTRICT COURT 930 TACOMA AVE S, Room 239, TACOMA, 98402. Small Claims Information 930 TACOMA AVE S, Room 239, TACOMA, 98402 Small Claims Information A Small Claims case can be filed for the recovery of money only. This amount cannot exceed $5,000. LEGAL ADVICE The clerk will assist

More information

No. ) ) COMES NOW the plaintiff by and through her attorney, Roger K. Anderson, and states her I. PARTIES AND JURISDICTION

No. ) ) COMES NOW the plaintiff by and through her attorney, Roger K. Anderson, and states her I. PARTIES AND JURISDICTION FILED 1 MAY 1 AM :0 1 KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: 1--8-1 SEA 3 8 IN THE SUPERIOR COURT OF WASHINGTON FOR KING COUNTY SANDRA S. NOREEN, Plaintiff, vs. 1 MICHAEL W. BUGNI, individually

More information

) GLOBAL TITLE, LLC, ) d/b/a GLOBAL TITLE SERVICES, ) ) Plaintiff, ) ) v. ) Case No: CL-2011-6749 ) CAPITAL ONE FINANCIAL CORP. ) ) Defendant.

) GLOBAL TITLE, LLC, ) d/b/a GLOBAL TITLE SERVICES, ) ) Plaintiff, ) ) v. ) Case No: CL-2011-6749 ) CAPITAL ONE FINANCIAL CORP. ) ) Defendant. VIRGINIA: IN THE CIRCUIT COURT FOR FAIRFAX COUNTY ) GLOBAL TITLE, LLC, ) d/b/a GLOBAL TITLE SERVICES, ) ) Plaintiff, ) ) v. ) Case No: CL-2011-6749 ) CAPITAL ONE FINANCIAL CORP. ) ) Defendant. ) ) AMENDED

More information

Case 15-60070 Document 126 Filed in TXSB on 10/09/15 Page 1 of 5

Case 15-60070 Document 126 Filed in TXSB on 10/09/15 Page 1 of 5 Case 15-60070 Document 126 Filed in TXSB on 10/09/15 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS VICTORIA DIVISION In re: HII TECHNOLOGIES, INC. Chapter 11 Debtor

More information

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT. Defendants, through undersigned counsel, admit, deny, and allege as follows with

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT. Defendants, through undersigned counsel, admit, deny, and allege as follows with HONORABLE BRUCE HELLER 1 1 1 1 1 1 1 0 LEAGUE OF EDUCATION VOTERS, et al. v. STATE OF WASHINGTON KING COUNTY SUPERIOR COURT Plaintiffs, STATE OF WASHINGTON, et al. Defendants. NO. --1- SEA Defendants,

More information

IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH 12 18090. -vs- ) JUDGE LYNCH

IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH 12 18090. -vs- ) JUDGE LYNCH IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO C. PAUL TIPPS, et al., ) Plaintiffs, ) CASE NO. 08 CVH 12 18090 -vs- ) JUDGE LYNCH NEIL S. CLARK, et al., ) Defendants. ) ANSWER OF DEFENDANTS NEIL S.

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE No. 09-CV-01084-JCC

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE No. 09-CV-01084-JCC THE HONORABLE JOHN C. COUGHENOUR JUSTIN GAWRONSKI and A. BRUGUIER, individually and on behalf of all others similarly situated, Plaintiffs, UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT

More information

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) )

CLARK COUNTY, NEVADA. ANSWER ) Defendant. ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ANS (NAME) (ADDRESS) (CITY, STATE, ZIP) (TELEPHONE) Defendant Pro Se DISTRICT COURT CLARK COUNTY, NEVADA ) ) Case No.: Plaintiff,

More information

The two sides disagree on how much money, if any, could have been awarded if Plaintiffs, on behalf of the class, were to prevail at trial.

The two sides disagree on how much money, if any, could have been awarded if Plaintiffs, on behalf of the class, were to prevail at trial. SUPERIOR COURT OF THE COUNTY OF LOS ANGELES If you are a subscriber of Kaiser Foundation Health Plan, Inc. and you, or your dependent, have been diagnosed with an autism spectrum disorder, you could receive

More information

Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA FIRST FINANCIAL INSURANCE COMPANY * CIVIL ACTION VERSUS * NO: 09-7349 JOSE ARRIAGA

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their CASE 0:13-cv-00873-RHK-TNL Document 1 Filed 04/15/13 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael A. Ofor, Case No: Plaintiff, v. Steven Lecy, and City of Minneapolis, NOTICE

More information

EXHIBIT A NOTICE OF PROPOSED CLASS SETTLEMENT

EXHIBIT A NOTICE OF PROPOSED CLASS SETTLEMENT Case 12-30885-hdh7 Doc 72 Filed 11/22/13 Entered 11/22/13 11:07:32 Page 15 of 27 EXHIBIT A NOTICE OF PROPOSED CLASS SETTLEMENT ALL PERSONS WHO PAID MONEY FOR A MEMBERSHIP IN LULLY S, INC. d/b/a THE RIGHT

More information

COURT OF APPEAL OF THE STATE OF CALIFORNIA FIFTH APPELLATE DISTRICT. Plaintiff and Respondent, v. Kern County Superior Court

COURT OF APPEAL OF THE STATE OF CALIFORNIA FIFTH APPELLATE DISTRICT. Plaintiff and Respondent, v. Kern County Superior Court COURT OF APPEAL OF THE STATE OF CALIFORNIA FIFTH APPELLATE DISTRICT PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff and Respondent, F065134 v. Kern County Superior Court ARMANDO ALVAREZQUINTERO, No. BF132212A

More information

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DESTINY ANNMARIE RIOS Plaintiff VS. CIVIL ACTION NO. 5:14-cv-00590

More information

Case 1:14-cv-01323-ERK-JMA Document 1-1 Filed 02/27/14 Page 1 of 2 PageID #: 6 CIVIL COVER SHEET (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.

Case 1:14-cv-01323-ERK-JMA Document 1-1 Filed 02/27/14 Page 1 of 2 PageID #: 6 CIVIL COVER SHEET (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM. Case 1:14-cv-01323-ERK-JMA Document 1-1 Filed 02/27/14 Page 1 of 2 PageID #: 6 CIVIL COVER SHEET (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) I. (a) PLAINTIFFS DEFENDANTS Nemet Motors, LLC d/b/a Nemet

More information

Case 1:10-cv-10170-NMG Document 38 Filed 06/15/11 Page 1 of 9. United States District Court District of Massachusetts MEMORANDUM & ORDER

Case 1:10-cv-10170-NMG Document 38 Filed 06/15/11 Page 1 of 9. United States District Court District of Massachusetts MEMORANDUM & ORDER Case 1:10-cv-10170-NMG Document 38 Filed 06/15/11 Page 1 of 9 WESTERN WORLD INSURANCE COMPANY, INC., Plaintiff, v. JAMES CZECH and WILLIAMS BUILDING COMPANY, INC., Defendants. United States District Court

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I.

CAUSE NO. PLAINTIFF S ORIGINAL PETITION. Greg Abbott, and complains of OLD UNITED LIFE INSURANCE COMPANY ( Defendant ), and I. CAUSE NO. STATE OF TEXAS, Plaintiff, v. OLD UNITED LIFE INSURANCE COMPANY, Defendant. IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS JUDICIAL DISTRICT PLAINTIFF S ORIGINAL PETITION TO THE HONORABLE JUDGE

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically Document Page 1 of 16 Steven C. Tycksen, #3300 Chad Shattuck, #9345 TYCKSEN & SHATTUCK, L.C. 12401 South 450 East, Unit E1 Draper, Utah 84020 Telephone: 801-748-4081 Facsimile: 801-748-4087 steve@tyshlaw.com

More information

Plaintiffs, -against- IAS Part 5 Justice Kathryn E. Freed. WHEREAS Eric T. Schneiderman, Attorney General of the State of New York

Plaintiffs, -against- IAS Part 5 Justice Kathryn E. Freed. WHEREAS Eric T. Schneiderman, Attorney General of the State of New York SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------------X THE PEOPLE OF THE STATE OF NEW YORK, by ERIC T. SCHNEIDERMAN, Attorney

More information

SETTLEMENT AGREEMENT AND MUTUAL RELEASE. WHEREAS, Prince was employed as KSU s head football coach between December 5, 2005 and December 31, 2008; and

SETTLEMENT AGREEMENT AND MUTUAL RELEASE. WHEREAS, Prince was employed as KSU s head football coach between December 5, 2005 and December 31, 2008; and SETTLEMENT AGREEMENT AND MUTUAL RELEASE This Settlement Agreement and Mutual Release ( Agreement ) is made and entered into this 6 th day of May, 2011, by and between Kansas State University ( KSU ) and

More information

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON SHARON SUMERA, NO. 66944-3-I Respondent, DIVISION ONE v. GREGORY BEASLEY and JANE DOE UNPUBLISHED OPINION BEASLEY, husband and wife and the marital community

More information

Case 1:16-cv Document 1 Filed 07/07/16 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:16-cv Document 1 Filed 07/07/16 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Case 1:16-cv-01415 Document 1 Filed 07/07/16 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SHAWN JAIN and GLORIA HACKMAN, individually and on behalf of others similarly situated

More information

IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANT IHOR FIGLUS

IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANT IHOR FIGLUS EFiled: Oct 31201202:31P Transaction ID 47478356 Case No. 7936-VCP IN THE COURT OF CHANCERY OF THE STATE OF DELA WARE EMERGING EUROPE GROWTH FUND, L.P., and HORIZON CAPITAL GP LLC, a Delaware limited liability

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. No. 2:08-md-01919-MJP. Lead Case No. C07-1874 MJP

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. No. 2:08-md-01919-MJP. Lead Case No. C07-1874 MJP UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE IN RE WASHINGTON MUTUAL, INC. SECURITIES, DERIVATIVE AND ERISA LITIGATION This Document Relates to: ERISA Action No. 2:08-md-01919-MJP

More information

2016 IL App (1st) U. No FIFTH DIVISION April 29, 2016 IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

2016 IL App (1st) U. No FIFTH DIVISION April 29, 2016 IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT 2016 IL App (1st) 150195-U No. 1-15-0195 NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

More information

2014 IL App (1st) 130250-U. No. 1-13-0250 IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

2014 IL App (1st) 130250-U. No. 1-13-0250 IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT 2014 IL App (1st) 130250-U FIFTH DIVISION September 12, 2014 No. 1-13-0250 NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION PLAINTIFF MCAFEE, INC. S THIRD AMENDED COMPLAINT UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION McAFEE, INC. v. Plaintiff, WILMER, CUTLER, PICKERING, HALE AND DORR, L.L.P JURY REQUESTED No. 4:08-cv-160 MHS-DDB Defendant.

More information

STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT NO. Attorney General, and Audrey L. Udashen, Assistant Attorney General, brings this action

STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT NO. Attorney General, and Audrey L. Udashen, Assistant Attorney General, brings this action 1 1 1 1 1 STATE OF WASHINGTON, V. STATE OF WASHINGTON SNOHOMISH COUNTY SUPERIOR COURT Plaintiff, MICHAEL'S OFFICE LLC; MYKHAYLO BENDZAR a/k/a MICHAEL BENDZAR, in his individual capacity and d/b/a MICHAEL'S

More information

Case3:09-md-02032-MMC Document345 Filed08/09/12 Page1 of 7

Case3:09-md-02032-MMC Document345 Filed08/09/12 Page1 of 7 Case:0-md-00-MMC Document Filed0/0/1 Page1 of 1 1 1 1 1 1 0 1 In Re: Chase Bank USA, N.A. Check Loan Contract Litigation THIS DOCUMENT APPLIES TO ALL ACTIONS UNITED STATES DISTRICT COURT NORTHERN DISTRICT

More information

Case 3:09-cv-00298-N Document 1065 Filed 04/16/2010 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Case 3:09-cv-00298-N Document 1065 Filed 04/16/2010 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION Case 3:09-cv-00298-N Document 1065 Filed 04/16/2010 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v.

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

SMALL CLAIMS RULES. (d) Record of Proceedings. A record shall be made of all small claims court proceedings.

SMALL CLAIMS RULES. (d) Record of Proceedings. A record shall be made of all small claims court proceedings. SMALL CLAIMS RULES Rule 501. Scope and Purpose (a) How Known and Cited. These rules for the small claims division for the county court are additions to C.R.C.P. and shall be known and cited as the Colorado

More information

Case 3:11-cv-00545-RCJ-WGC Document 96 Filed 12/18/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

Case 3:11-cv-00545-RCJ-WGC Document 96 Filed 12/18/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA Case 3:11-cv-00545-RCJ-WGC Document 96 Filed 12/18/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA HOWARD L. HOWELL, Lead Plaintiff, ELLISA PANCOE, Individually and on Behalf of All Others

More information

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SUSAN CARNABY V. C IVIL ACTION NUMBER H-08-1366 C ITY

More information

Filing a Motion for Change of Venue in a Family Law Case

Filing a Motion for Change of Venue in a Family Law Case Filing a Motion for Change of Venue in a Family Law Case Should I use this packet? This packet has the instructions and forms you will need to ask the court to move your family law case to a different

More information

SETTLEMENT AGREEMENT AND RELEASE

SETTLEMENT AGREEMENT AND RELEASE SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release ( Agreement ) is made and entered into by and between Cheryl Coryea ( Coryea or Plaintiff ), and Rochester Independent School District

More information

f?elw 4 NOV 1211 O3USDc-tee UNITED STATES DISTRICT COURT DISTRICT OF OREGON No. CV-03-0404-HA INC. SECURITIES LITIGATION CLASS ACTION

f?elw 4 NOV 1211 O3USDc-tee UNITED STATES DISTRICT COURT DISTRICT OF OREGON No. CV-03-0404-HA INC. SECURITIES LITIGATION CLASS ACTION f?elw 4 NOV 1211 O3USDc-tee UNITED STATES DISTRICT COURT DISTRICT OF OREGON In re ELECTRO SCIENTIFIC INDUSTRIES, INC. SECURITIES LITIGATION This Document Relates To: ALL ACTIONS. No. CV-03-0404-HA CLASS

More information

Law Offices of I.M. Tagaropulos, P.C., located in Houston, Texas.

Law Offices of I.M. Tagaropulos, P.C., located in Houston, Texas. N.A.S.D. AWARD NATIONAL ASSOCIATION OF SECURITIES DEALERS In the M&tter of the Arbitration Between Name of Claimant/Counter-Respondent Merrill Lynch, Pierce, Fenner & Smith, Inc. 94-00844 Name of Respondents/Counter-Claimants

More information

Andrew C. Snyder, Esq. 8400 East Prentice Avenue, #1500 Case No. 2013CV31667 Denver, Colorado 80111 Ctrm.: 269 Phone Number: 303-409-7777

Andrew C. Snyder, Esq. 8400 East Prentice Avenue, #1500 Case No. 2013CV31667 Denver, Colorado 80111 Ctrm.: 269 Phone Number: 303-409-7777 DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, Colorado 80202 FRED J. JOSEPH, Securities Commissioner for The State of Colorado, Plaintiff, v. PROVIDENCE FINANCIAL SERVICES,

More information

SETTLEMENT AGREEMENT AND GENERAL RELEASE. This Settlement Agreement and General Release ( AGREEMENT ) is made as of

SETTLEMENT AGREEMENT AND GENERAL RELEASE. This Settlement Agreement and General Release ( AGREEMENT ) is made as of SETTLEMENT AGREEMENT AND GENERAL RELEASE This Settlement Agreement and General Release ( AGREEMENT ) is made as of March 29, 2004 by and between Defendant NETWORK ASSOCIATES, INC. ( NAI ) and Plaintiffs

More information

Case 2:02-cv-00950-TS Document 602 Filed 06/19/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF UTAH ) ) ) ) ) ) ) ) ) )

Case 2:02-cv-00950-TS Document 602 Filed 06/19/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF UTAH ) ) ) ) ) ) ) ) ) ) Case 2:02-cv-00950-TS Document 602 Filed 06/19/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF UTAH OWNER-OPERATOR INDEPENDENT DRIVERS ASSOCIATION, INC., ET AL., Plaintiffs, v. C.R. ENGLAND, INC.,

More information

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT NOTICE OF PROPOSED CLASS ACTION SETTLEMENT TO: All persons and entities which have paid the City of Ferndale (the City ) for water and sanitary sewage disposal services between January 22, 2008 and December

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA JANET HEROLD Regional Solicitor BRUCE L. BROWN Associate Regional Solicitor DONNA F. BOND Trial Attorney Office of the Solicitor UNITED STATES DEPARTMENT OF LABOR 300 Fifth Avenue, Suite 1120 Telephone:

More information

IN THE COURT OF APPEALS OF OHIO TENTH APPELLATE DISTRICT D E C I S I O N. Rendered on December 28, 2012

IN THE COURT OF APPEALS OF OHIO TENTH APPELLATE DISTRICT D E C I S I O N. Rendered on December 28, 2012 [Cite as City of Columbus, Div. of Taxation v. Moses, 2012-Ohio-6199.] IN THE COURT OF APPEALS OF OHIO TENTH APPELLATE DISTRICT City of Columbus, Division of Taxation, : Plaintiff-Appellee, : No. 12AP-266

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA CASE 0:11-cv-02781-SRN-JSM Document 604 Filed 04/06/15 Page 1 of 15 ROGER KRUEGER, et al., UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA v. Plaintiffs, No. 11-CV-02781 (SRN/JSM) AMERIPRISE FINANCIAL,

More information

IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division Document Page 1 of 15 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ) In re: ) Case No. 07-11440-RGM Ronald Steven Federici, ) Chapter 7 Debtor. ) ) ) W.

More information

This Class Action Settlement May Affect Your Rights A Court authorized this Notice. This is not a solicitation from a lawyer.

This Class Action Settlement May Affect Your Rights A Court authorized this Notice. This is not a solicitation from a lawyer. Garrett Kacsuta, et al., v. Lenovo (United States) Inc. Case No. 13-cv-00316-CJC (RNBx) OWNERS OF CERTAIN MODELS OF LENOVO BRAND ULTRABOOK COMPUTERS MAY CLAIM SETTLEMENT BENEFITS. This Class Action Settlement

More information

WHAT THIS NOTICE CONTAINS BASIC INFORMATION. 1. Why did I get this notice?

WHAT THIS NOTICE CONTAINS BASIC INFORMATION. 1. Why did I get this notice? SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA If you are or were employed by Flextronics or Solectron as an Area Team Leader or Territory Manager assigned to a Verizon Wireless store

More information

CERTIFICATE OF SERVICE I hereby certify that on March 13, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the

More information