Case: Kosen v. American Express Financial Advisors, Inc.

Kosen v. American Express Financial Advisors Inc.

Kosen v. AMERICAN EXPRESS FINANCIAL ADVISORS, INC.

COMPLAINT against AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC. ( Filing fee $150 ). Filed by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (cdw, ) (Entered: 01/22/2002)

SUMMONS (5)Issued as to AMERICAN EXPRESS COMPANY ; AMERICAN EXPRESS FINANCIAL ADVISORS INC. ; AMERICAN EXPRESS FINANCIAL CORPORATION ; IDS FINANCIAL SERVICES, INC. ; IDS LIFE INSURANCE, INC. (cdw, )

LCvR 26.1 - CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by plaintiffs (cdw, ) (Entered: 01/22/2002)

MOTION for Leave to Appear Pro Hac Vice by Lawrence P. Schaefer, Susan E. Stokes, and Mara R. Thompson of SPRENGER & LANG, PLLC; 325 Ridgewood Avenue; Minneapolis, MN 55403 (614) 871-8910; and for Maurice William O'Brien and Nancy J. Miller of MILLER-O'BRIEN, PLLC; 1208 Plymouth Building; 12 South Sixth Street; Minneapolis, MN 55402; (612) 333-5831 by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (cdw, ) (Entered: 01/22/2002)

Unopposed MOTION for issuance of an order preliminarily approving consent decree; and directing notice to class members; and administrative order No. 1 by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Consent Decree# 2 Exhibit Ex. A to Consent Decree# 3 Exhibit Ex. B to Consent Decree# 4 Exhibit Ex. C to Consent Decree# 5 Exhibit Ex. D to Consent Decree# 6 Exhibit Ex. E to Consent Decree# 7 Exhibit Ex. F to C onsent Decree# 8 Exhibit Ex. G to Consent Decree# 9 Memorandum In Support of Motion# 10 Proposed Administrative Order# 11 Proposed Order Granting Motion# 12 Ex. 1 to Proposed Order Granting Motion)(Sprenger, Steven) Modified on 1/24/2002 (cdw, ). (Entered: 01/23/2002)

AFFIDAVIT re 4 Class Settlement by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Exhibit Ex. A1 to Schaefer Declaration# 2 Exhibit Ex. A2 to Schaefer Declaration# 3 Exhibit Ex. B1 to Schaefer Declaration# 4 Exhibit Ex. B2 to Schaefer Declaration)(Sprenger, Steven) (Entered: 01/23/2002)

ORDER granting Motion for Leave to Appear 3 Signed by Judge Henry H. Kennedy, Jr. on January 23, 2002. (Kennedy, Henry)

NOTICE of Appearance by Ralph A. Taylor on behalf of AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC. (cdw, ) (Entered: 01/24/2002)

LCvR 26.1 - CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by defendants (cdw, ) (Entered: 01/24/2002)

Consent MOTION for Leave to Appear Pro Hac Vice by Edward B. Magarian of DORSEY & WHITNEY LLP; Suite 1500; 50 South Sixth Street; Minneapolis, MN 55402; (612) 340-2600 by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC.. (cdw, ) (Entered: 01/24/2002)

Consent MOTION for Leave to Appear Pro Hac Vice by Janice M. Symchych of DORSEY & WHITNEY LLP; Suite 1500; 50 South Sixth Street; Minneapolis, MN 55402; (612) 340-2600 by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC.. (cdw, ) (Entered: 01/24/2002)

ORDER granting Motion for Leave to Appear 8 . Signed by Judge Henry H. Kennedy,Jr. on January 26, 2002. (Kennedy, Henry)

ORDER granting Motion for Leave to Appear re: Janice M. Symchych 9 Signed by Judge Henry H. Kennedy, Jr. on February 15, 2002. (Kennedy, Henry)

Minute Entry: Motion Hearing re 4 for preliminary approval of class action settlement held on 2/19/2002 and taken under advisement before Judge Henry H. Kennedy, Jr. (Court Reporter Dolores Byers.) (dcn, )

Calendar Entry Telephone Conference set for 3/20/2002 09:30 AM before Judge Henry H. Kennedy, Jr.. (dcn, )

ORDER PRELIMINARILY APPROVING CONSENT DECREE AND DIRECTING NOTICE TO CLASS MEMBERS 4 Signed by Judge Henry H. Kennedy, Jr. on March 20, 2002.(Kennedy, Henry) (Entered: 03/20/2002)

ADMINISTRATIVE ORDER NO. 1 Signed by Judge Henry H. Kennedy, Jr. on March 20, 2002. (Kennedy, Henry) (Entered: 03/20/2002)

Minute Entry: Telephone Status Conference held on 3/20/2002 before Judge Henry H. Kennedy, Jr.; granted preliminary approval of settlement; Final approval hearing set for June 6, 2002, 10:00 a.m.(Court Reporter Jackie Wood-Miller Reporting.) (dcn, )

NOTICE of Change of Address by Ralph A. Taylor (Taylor, Ralph) (Entered: 05/30/2002)

MOTION to Approve Consent Judgment by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Affidavit of Luz Maria Davis# 2 Affidavit of Edward B. Magarian# 3 Proposed Order)(Taylor, Ralph) (Entered: 05/31/2002)

Unopposed MOTION to Appoint Counsel as Special Master, MOTION to Certify Class, MOTION for Entry of Final Judgment, MOTION for Settlement by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Memorandum in Support of Plaintiffs' Unopposed Motion for Final Approval of Consent Decree and Order and Stipulation of Reference Appointing a Special Master# 2 Declaration of L Schaefer# 3 Exhibit L Schaefer Dec - Ex A1# 4 Exhibit L Schaefer Dec - Ex A2# 5 Exhibit L Schaefer Dec - Ex B1# 6 Exhibit L Schaefer Dec - Ex B2# 7 Declaration of M Thompson# 8 Declaration of M Lieder# 9 Exhibit Lieder Dec - Ex A# 10 Exhibit Lieder Dec - Ex B# 11 Exhibit Lieder Dec - Ex C# 12 Exhibit Lieder Dec - Ex D# 13 Declaration of K Ness# 14 Exhibit Ness Dec - Ex A# 15 Exhibit Ness Dec - Ex B1# 16 Exhibit Ness Dec - Ex B2# 17 Exhibit Ness Dec - Ex B3# 18 Exhibit Ness Dec - Ex C# 19 Declaration of D Borgen# 20 Exhibit Borgen Dec - Ex A# 21 Declaration of J Anderson# 22 Declaration of M. W. O'Brien# 23 Declaration of D Heins# 24 Order Approving Consent Decree# 25 Exhibit Order Approving Consent Decee - Ex A# 26 Order and Stipulation of Reference)(Sprenger, Steven) (Entered: 05/31/2002)

Minute Entry: Motion Hearing re [] Final approval of settlement granted, hearing held on 6/6/2002 before Judge Henry H. Kennedy, Jr. (Court Reporter Jackie Wood-Miller Reorting.) (dcn, )

ORDER Approving Consent DecreeSigned by Judge Henry H. Kennedy, Jr. on June 16, 2002. (Kennedy, Henry) (Entered: 06/16/2002)

ORDER AND STIPULATION OF REFERENCESigned by Judge Henry H. Kennedy, Jr. on June 16, 2002. (Kennedy, Henry) (Entered: 06/16/2002)

JudgmentSigned by Judge Henry H. Kennedy, Jr. on June 16, 2002. (Kennedy, Henry) (Entered: 06/16/2002)

TRANSCRIPT for dates 6/6/02 ; Court Reporter Jacqueline L. Wood of Miller Reporting Company. (mpt, ) (Entered: 07/12/2002)

MOTION to Enforce the Consent Decree by Enjoining Class Member Debra Wood from Proceeding with Her Cause of Action in Nebraska and Directing Her to Dismiss Said Action with Prejudice by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Memorandum in Support of Motion# 2 Declaration of Judith Moldover# 3 Declaration of Edward Magarian with Exhibits# 4 Proposed Order)(Taylor, Ralph) (Entered: 07/17/2002)

PRELIMINARY ELECTRONIC CASE FILING ORDER . Signed by Judge Henry H. Kennedy, Jr. on July 18, 2002. (FL, ) (Entered: 07/18/2002)

NOTICE re 19 Certificates of Service of Motion Papers on Class Member Debra Wood by all defendants (Taylor, Ralph) (Entered: 07/23/2002)

ORDER deferring ruling on Motion to Enforce 19 . The clerk of the court shall schedule a hearing on plaintiffs' Motion to enforce as soon as the business of the court permits. Notice of the hearing shall be sent to Debra Wood. Counsel for plaintiffs shall serve Debra Wood with notice of the hearing by certified mail or personally also. Signed by Judge Henry H. Kennedy, Jr. on August 26, 2002.(Kennedy, Henry)

Calendar Entry, Set Hearing: Hearing on Plaintiffs Motion to Enforce the Consent Decree set for 9/10/2002, 09:30 AM in Courtroom 14, before Judge Henry H. Kennedy, Jr. (dcn, )

NOTICE Of Clarification Of Status by all plaintiffs (Attachments: # 1 Notice Of Filing# 2 Certificate Of Mailing)(Sprenger, Steven) (Entered: 08/28/2002)

Minute Entry: The court having been informed that Debra Wood and Defendant American Express Financial Advisors have consented and stipulated to to the dismissal of the action she commenced in the District of Nebraska, 02cv3160, and that American Express Financial Advisors, therefore, withdraws its motion to enforce docketed July 17, 2002, the hearing on the motion scheduled for September 17, 2002 is cancelled. (Kennedy, Henry) Modified on 8/30/2002 (cdw, ).

Consent MOTION Modification of Consent Decree re 15 by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Proposed Order)(Taylor, Ralph) (Entered: 10/02/2002)

Unopposed MOTION for Disbursement of Funds in Approval of A per Capita Allocation Formula for the Business Development Fund by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7)(Sprenger, Steven) (Entered: 10/03/2002)

NOTICE re 24 exhibit attachment to motion for disbursement; FILED UNDER SEAL by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY (cdw, ) (Entered: 10/08/2002)

ORDER granting Motion 23 (Kennedy, Henry) (Entered: 10/25/2002)

ORDER granting Motion for Disbursement of Funds 24 (Kennedy, Henry) (Entered: 11/01/2002)

Unopposed MOTION for Disbursement of Funds for (1) Approval of the Point System for Allocating the Claims Portion of the Settlement Fund, (2) Acceptance of Certain Late Claim Forms, (3) Approval of the Proposed Distribution from the Claims Portion of the Settlement Fund, and (4) Approval of the Apportionment of Awards by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Memorandum in Support of Motion# 2 Affidavit Declaration of Mara R. Thompson# 3 Ex A-Thompson Decl.# 4 ExA1-Thompson Decl.# 5 ExC-Thompson Decl.# 6 ExD-Thompson Decl# 7 Ex E-Thompson Decl# 8 Ex F-Thompson Decl# 9 Declaration of Kimberly Ness# 10 ExA-Ness Decl# 11 Proposed Order# 12 ExA - Order# 13 Ex A1-Order# 14 Ex B-Order# 15 Ex C-Order# 16 Ex D-Order# 17 Ex E- Order# 18 Ex F-Order# 19 Ex B-Thompson Decl)(Sprenger, Steven) (Entered: 11/15/2002)

ORDER granting 28 Motion for Disbursement of Funds Signed by Judge Henry H. Kennedy on November 30, 2002. (Kennedy, Henry) (Entered: 11/30/2002)

MOTION for Disbursement of Funds By Class Counsel Requesting Court Approval of Recommendations as to Claimant Appeals by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Memorandum in Support of Class Counsel's Motion for Approval of Recommendations Regarding Claimant Appeals# 2 Affidavit Declaration of Kimberly Ness# 3 Declaration of Mara R. Thompson# 4 Exhibit Thompson Decl. Ex Table A# 5 Exhibit Thompson Decl. Ex Table A-1# 6 Exhibit Thompson Decl. Ex Table B# 7 Notice Regarding Exhibit Attachment# 8 Proposed Order Approving Class Counsel's Recommendations as to Claimant Appeals# 9 Order Exhibit Table 1)(Sprenger, Steven) (Entered: 02/05/2003)

NOTICE by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY re 30 sealed exhibits to their MOTION for Disbursement of Funds By Class Counsel Requesting Court Approval of Recommendations as to Claimant Appeals (3 Bulkies; FILED UNDER SEAL) (cdw, ) (Entered: 02/11/2003)

ORDER granting 30 Motion for Disbursement of Funds (Kennedy, Henry) (Entered: 03/15/2003)

NOTICE by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY Plaintiffs submitted a copy of Table 1, in paper form, to the Clerk of the Court to be filed under seal (Sprenger, Steven) (Entered: 03/20/2003)

ENTERED IN ERROR....."NOTICE OF CORRECTED DOCKET ENTRY. Document No. 34 was entered in error and counsel instructed to refile the motion to enforce consent decree as to S. Seltzer." (bcs, ) Modified on 1/29/2004 (bcs, ). Modified on 1/29/2004 (bcs, ).

MOTION to Enforce The Consent Decree as to Linda Davenport by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Affidavit of Edward Magarian and Exhibits Thereto# 2 Text of Proposed Order)(Taylor, Ralph) Modified on 1/29/2004 (bcs, ). Modified on 1/29/2004 (bcs, ). (Entered: 01/23/2004)

MOTION to Enforce Consent Decree as to S. Seltzer, and Memo in Support, by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Affidavit Edward Magarian and Exhibits# 2 Affidavit Ahna Thoresen and Exhibits# 3 Text of Proposed Order)(Taylor, Ralph) (Entered: 01/23/2004)

1 Affidavit Edward Magarian and Exhibits

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2 Affidavit Ahna Thoresen and Exhibits

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3 Text of Proposed Order

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"Please disregard the notice of corrected docket entry enter on 1/28/04 for documents 34 and 35 are two separate motions pertainig to two different parties." (bcs, )

RESPONSE to 34 respondent AEFA's motion to enforce the consent decree by enjoining portion of Linda Davenport's claims in arbitration by LINDA DAVENPORT. (Attachments: # 1 Exhibit)(bcs, ) (Entered: 02/10/2004)

NOTICE of Hearing on Motions: MOTION to Enforce The Consent Decree, 34 & 35 MOTION to Enforce Consent Decree as to S. Seltzer, and Motion Hearing on 34 set for 3/19/2004 02:00 PM; Motion Hearing on 35 set for 3:00 p.m. in Courtroom 14 before Judge Judge Henry H. Kennedy. (dcn, )

REPLY in support of motion re 34 Enforcement of Consent Decree as to Linda Davenport filed by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Taylor, Ralph) (Entered: 02/17/2004)

MOTION for Leave to Appear Pro Hac Vice for Ahna Thoresen by AMERICAN EXPRESS FINANCIAL ADVISORS INC.. (Attachments: # 1 Text of Proposed Order)(Taylor, Ralph) (Entered: 02/19/2004)

MEMORANDUM relating to motion to enforce release and consent decree as to claims of Susan Seltzer before the NASD from Susan Seltzer. (Attachments: # 1 Exhibit)(bcs, ) (Entered: 03/08/2004)

Minute order re 38 granting defendants' motion for Ahna M. Thoresen to appear pro hac vice. Ahna M. Thoresen, Esq. is admitted to appear pro hac vice as co-counsel for American Express Financial Advisors, Inc. Signed by Judge Henry H. Kennedy, Jr., on February 25, 2004. (FL, )

REPLY to opposition to motion re 35 Motion to Enforce Release and Consent Decree as to Susan Seltzer filed by AMERICAN EXPRESS FINANCIAL ADVISORS INC.. (Attachments: # 1 Exhibit A (Seltzer Opposition))(Taylor, Ralph) (Entered: 03/01/2004)

Remark: THE MOTIONS HEARING SET FOR MARCH 19, 2004 HAS BEEN CANCELLED BY ORDER OF THE COURT. (dcn, )

ORDER granting 34 Motion to Enforce, granting 35 Motion to Enforce (Kennedy, Henry) (Entered: 03/07/2004)

MOTION to Compel compliance with Kosen complaint procedures and for sanctions by LINDA DAVENPORT. (Attachments: # 1 Exhibit)(bcs, ) (Entered: 03/17/2004)

NOTICE by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION of Withdrawal of Appearance of Janice Symchych as Co-Counsel (Taylor, Ralph) (Entered: 03/16/2004)

MOTION to Strike 43 MOTION to Compel compliance with Kosen complaint procedures and for sanctions, by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC.. (Attachments: # 1 Exhibit Part 1# 2 Exhibit Part 2# 3 Text of Proposed Order)(Bedell, Kevin) (Entered: 03/24/2004)

RESPONSE to 44 motion to stike by LINDA DAVENPORT. (Attachments: # 1 Exhibit)(bcs, ) (Entered: 04/16/2004)

REPLY to opposition to motion re 44 to Strike filed by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC.. (Bedell, Kevin) (Entered: 04/14/2004)

MOTION to Enforce Consent Decree by Enjoining Portion of Class Member Grabovsky's Claims in Arbitration, and Memo in Support by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Affidavit of Ahna M. Thoresen# 2 Exhibit 1 to Thoresen Affidavit# 3 Exhibit 2 to Thoresen Affidavit# 4 Exhibit 3 to Thoresen Affidavit# 5 Affidavit of Cheryl Printon# 6 Affidavit of Kimberly K Ness# 7 Exhibit A to Ness Affidavit# 8 Text of Proposed Order # 9 Certificate of Service)(Taylor, Ralph) (Entered: 06/09/2004)

Memorandum in opposition to motion re 47 Enforcement of Consent Decree by Enjoining Portion of Class Member Grabovsky's Claims in Arbitration filed by ANGELA GRABOVSKY. (Attachments: # 1 Affidavit (Declaration) of Thomas Campbell# 2 Affidavit (Declaration) of Angela Grabovsky)(Burgess, Joe) (Entered: 06/22/2004)

MOTION for Leave to Appear pro hac vice for Thomas M. Campbell by ELIZABETH BRADLER, LISA GRANQUIST, MARY ELIZABETH GRIFFIN-ROY, DEATRA HARRINGTON, DAWN HAUSCH-COOPER, REBECCA HAYES, JAN JACKSON, CATHERINE KELLY, SHELLY KOSEN, ELENI KULINSKI, SUSAN MARCOTTE, LYDIA MURPHY, MELISSA POOLE, PAULINE RICHARDS, SUSAN SELTZER, ROSALIE VILLAFRATE, LOIS WISOCKY. (Attachments: # 1 Declaration of Thomas M. Campbell# 2 Proposed Order# 3 Certificate of Service)(Sprenger, Steven) (Entered: 06/24/2004)

REPLY to opposition to motion re 47 Enforcement of Consent Decree Against A. Grabovsky filed by AMERICAN EXPRESS FINANCIAL ADVISORS INC.. (Attachments: # 1 Affidavit (2d) of Ahna Thoresen# 2 Exhibit A to 2d Thoresen Declaration# 3 Exhibit B to 2d Thoresen Declaration# 4 Exhibit C to 2d Thoresen Declaration# 5 Exhibit D to 2d Thoresen Declaration# 6 Exhibit E to 2d Thoresen Declaration# 7 Exhibit F to 2d Thoresen Declaration# 8 Affidavit of Michael Lloyd# 9 Exhibit A to Lloyd Declaration# 10 Certificate of Service)(Taylor, Ralph) (Entered: 06/29/2004)

Minute order granting 49 motion for Thomas M. Campbell to appear pro hac vice. Thomas M. Campbell is admited to appear pro hac vice as counsel for Angela Grabovsky, an alleged class member. Signed by Judge Henry H. Kennedy, Jr., on July 2, 2004. Official paperless order (FL, )

MINUTE ORDER granting 44 Motion to Strike Linda Davenport's Motion to Compel Compliance with Kosen Complaint Procedure and for Sanctions. (Kennedy, Henry)

THIS IS A TEST. Please disregard this entry. It will be deleted forthwith after the conclusion of the test. Please accept our apology for the inconvenience that this may cause you our your staff. (Burgess, Joe)

Set Hearings: Motion Hearing, motion to enforce, set for 11/29/2004 at 09:30 AM in Courtroom 14 before Judge Henry H. Kennedy. Each side will have 20 minutes for argument. (rew, )

Joint MOTION Adjournment of 11-29-04 oral argument to any date after 2/7/05 by ANGELA GRABOVSKY. (Campbell, Thomas) (Entered: 11/15/2004)

MINUTE ORDER granting 51 Motion to adjourn oral argument on MOTION to Enforce Consent Decree until after February 7, 2005. The clerk of the court shall reschedule the oral arguemnt as soon after February 7, 2005, as the business of the court permits. (Kennedy, Henry)

Set/Reset Hearings: Motion Hearing set for 11/29/2004 at 9:30 AM is OFF and reset for 3/18/2005 at 02:00 PM, 20 minutes each side, in Courtroom 14 before Judge Henry H. Kennedy. (rew, )

STIPULATION Stipulated Order and Letter from Carolyn Chalmers, Special Master by AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, AMERICAN EXPRESS COMPANY. (Attachments: # 1 Stipulated Order)(Sprenger, Steven) (Entered: 02/16/2005)

MINUTE ORDER: The court hereby adopts the parties' "Stipulated Order" regarding discovery material to be treated as confidential. The parties shall be governed by such Order. (Kennedy, Henry)

MOTION for Order Adjourning Oral Argument of March 18, 2005 by ANGELA GRABOVSKY. (Campbell, Thomas) (Entered: 03/03/2005)

STIPULATION re 53 MOTION for Order Adjourning Oral Argument of March 18, 2005 (Stipulated Order) by ANGELA GRABOVSKY. (Campbell, Thomas) (Entered: 03/03/2005)

MINUTE ORDER granting 53 MOTION for Order Adjourning Oral Argument of March 18, 2005. Oral argument shall take place on May 20, 2005, at 11:00 A.M. (Kennedy, Henry)

Order withdrawing 47 defendants' motion to enforce consent decree by enjoining portion of Class Member Angela Grabovsky's Claims in Arbitration, Docketed June 9, 2004. Signed by Judge Henry H. Kennedy on May 20, 2005. (FL, ) (Entered: 05/20/2005)

NOTICE of Filing of Special Master's Report and Order by AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, AMERICAN EXPRESS COMPANY (Attachments: # 1 Special Master's Report and Order)(Bedell, Kevin) (Entered: 05/31/2005)

NOTICE of Change of Address by Steven M. Sprenger (Sprenger, Steven) (Entered: 06/02/2005)

NOTICE OF WITHDRAWAL OF APPEARANCE as to AMERICAN EXPRESS FINANCIAL ADVISORS INC., IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC., AMERICAN EXPRESS FINANCIAL CORPORATION, AMERICAN EXPRESS COMPANY. Attorney Kevin B. Bedell terminated. (Bedell, Kevin) (Entered: 07/15/2005)

MOTION for Leave to Seal Confidential Documents by SUSAN SELTZER (zrdj) (Entered: 11/17/2020)

Case randomly reassigned to Judge Ketanji Brown Jackson. Judge Henry H. Kennedy has retired and is no longer assigned to the case. (ztnr)

SUPPLEMENT re 59 MOTION for Leave to File filed by SUSAN SELTZER. (zrdj) (Entered: 11/20/2020)

Case Assigned/Reassigned

RESPONSE re 59 MOTION for Leave to File filed by SUSAN SELTZER. (Lieder, Michael) (Entered: 12/09/2020)

Notice of Correction by SUSAN SELTZER re 59 MOTION for Leave to File (zrdj) (Entered: 12/14/2020)

RESPONSE re 59 MOTION for Leave to File and Response to Petition filed by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Magid, Creighton) (Entered: 12/22/2020)

MOTION to Permit Plaintiff to Proceed Pro Se and Remove Class Counsel by SUSAN SELTZER (zjf) (Entered: 01/01/2021)

MOTION to Withdraw as Attorney by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION, IDS FINANCIAL SERVICES, INC., IDS LIFE INSURANCE, INC.. (eg) (Entered: 02/25/2021)

RESPONSE re 65 MOTION to Withdraw as Attorney filed by SUSAN SELTZER. (zjf) (Entered: 03/19/2021)

SEALED DOCUMENT re 66 Response to motion filed by SUSAN SELTZER. (This document is SEALED and only available to authorized persons.)(zjf) (Entered: 03/19/2021)

MOTION to Reopen Case (Redacted) by SUSAN SELTZER. (Attachment(s) added on 8/5/2021: # 1 Sealed Motion to Reopen; # 2 Exhibit Motion to Order Contempt with Sanctions) (zjf). (Entered: 08/05/2021)

MOTION for Contempt with Sanctions by SUSAN SELTZER. (zjf) (Entered: 08/13/2021)

MOTION for CM/ECF Password by SUSAN SELTZER. (zjf) (Entered: 08/17/2021)

RESPONSE re 68 MOTION to Reopen Case filed by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Magid, Creighton) (Entered: 08/16/2021)

ERRATA AS TO RESPONSE TO MOTION TO REOPEN by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION re 70 Response to Motion. (Attachments: # 1 Errata)(Magid, Creighton) Modified to add link on 8/17/2021 (znmw). (Entered: 08/17/2021)

ERRATA WITH RESPECT TO RESPONSE TO MOTION TO REOPEN CASE by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION re 70 Response to motion filed by AMERICAN EXPRESS COMPANY, AMERICAN EXPRESS FINANCIAL ADVISORS INC., AMERICAN EXPRESS FINANCIAL CORPORATION. (Attachments: # 1 Errata)(Magid, Creighton) (Entered: 08/17/2021)

NOTICE OF ERROR re 70 Response to motion; emailed to magid.chip@dorsey.com, cc'd 9 associated attorneys -- The PDF file you docketed contained errors: 1. Invalid attorney signature, 2. DO NOT REFILE - Counsel is reminded that a electronic or wet signature is required on filing(s) (zjf, )