Disability Rights New Jersey, Inc. v. New Jersey

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

2008 WL 4192068

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

New Jersey Protection and Advocacy v. Velez

COMPLAINT against JENNIFER VELEZ ( Filing fee $ 350 receipt number 1955140.), filed by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exh. C, # 4 Exh. D, # 5 Exh. E, # 6 Exh. F, # 7 Exh. G, # 8 H, # 9 Exhibit I)(tp ) (Entered: 04/17/2008)

Corporate Disclosure Statement by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (tp ) (Entered: 04/17/2008)

Summons Issued as to JENNIFER VELEZ. Days Due - 20. Mailed to attorney. (tp ) (Entered: 04/17/2008)

NOTICE of Appearance by BERNARD JOHN COONEY on behalf of NEW JERSEY PROTECTION AND ADVOCACY, INC. (COONEY, BERNARD) (Entered: 04/23/2008)

NOTICE of Appearance by WILLIAM EMMETT DWYER on behalf of NEW JERSEY PROTECTION AND ADVOCACY, INC. (DWYER, WILLIAM) (Entered: 04/24/2008)

CERTIFICATE OF SERVICE by NEW JERSEY PROTECTION AND ADVOCACY, INC. (COONEY, BERNARD) (Entered: 05/01/2008)

Application and Proposed Order for Clerk's Order to extend time to answer Attorney GERARD ANDREW HUGHES and GERARD ANDREW HUGHES for JENNIFER VELEZ added. (HUGHES, GERARD) (Entered: 05/07/2008)

NOTICE of Appearance by MARY STEPHANIE BEATY on behalf of JENNIFER VELEZ (BEATY, MARY) (Entered: 05/07/2008)

NOTICE of Appearance by KIMBERLY E. JENKINS on behalf of JENNIFER VELEZ (JENKINS, KIMBERLY) (Entered: 05/08/2008)

CLERKS QUALITY CONTROL MESSAGE - The 7 PROPOSED ORDER submitted by D. DAUENHEIMER on 5/7/2008 must be executed by a Judicial Officer before filing. Please forward to the appropriate Judicial Officer in accordance with his/her preferred practice OR ATTACHED IT TO THE 6 BRIEF IN SUPPORT. This submission will remain on the docket unless otherwise ordered by the court. This message is for informational purposes only. (ss, )

CLERKS TEXT ORDER - The Application for a Clerks Order Extending Time to Answer - Document # 7 submitted by G. HUGHES on 5/7/2008 has been GRANTED. The answer due date has been set for 5/28/2008. (ss, )

First MOTION for More Definite Statement, First MOTION to Strike 1 Complaint, by JENNIFER VELEZ. Responses due by 6/23/2008 (Attachments: # 1 Brief, # 2 Certification of Counsel, # 3 Certificate of Service, # 4 Text of Proposed Order)(BEATY, MARY) (Entered: 05/28/2008)

Set Deadlines as to 10 First MOTION for More Definite StatementFirst MOTION to Strike 1 Complaint,First MOTION to Strike 1 Complaint,. Motion Hearing set for 7/7/2008 10:00 AM before Magistrate Judge John J. Hughes. (PLEASE NOTE THAT PURSUANT TO FED. R. CIV. P. 78 AND LOCAL RULE 7.1 (B)(4), NO ORAL ARGUMENT WILL BE HELD IN THIS MATTER AND PARTIES SHOULD NOT APPEAR UNLESS SPECIFICALLY DIRECTED TO DO SO BY THE COURT) (ss, )

BRIEF in Opposition re 10 First MOTION for More Definite StatementFirst MOTION to Strike 1 Complaint,First MOTION to Strike 1 Complaint, filed by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (THOMPSON, R.) (Entered: 06/23/2008)

BRIEF in Opposition re 10 First MOTION for More Definite StatementFirst MOTION to Strike 1 Complaint,First MOTION to Strike 1 Complaint, filed by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (Attachments: # 1 Certificate of Service, # 2 Affidavit, # 3 Exhibit, # 4 Case, # 5 Case, # 6 Case, # 7 Case, # 8 Case, # 9 Case, # 10 Case)(THOMPSON, R.) (Entered: 06/23/2008)

CLERKS QUALITY CONTROL MESSAGE - The 11 Brief in opposition to motion submitted by R. Thompson on 6/23/2008 did not contain a proper electronic signature (s/). PLEASE RESUBMIT THE DOCUMENT WITH THE PROPER ELECTRONIC SIGNATURE (s/ Attorneys Name.) This submission will remain on the docket unless otherwise ordered by the court.. (ss, ) (Entered: 06/24/2008)

Letter from DAG Beaty in reply to opposition to motion for more definite statement re 12 Brief in Opposition to Motion,. (BEATY, MARY) (Entered: 06/30/2008)

MEMORANDUM and ORDER granting 10 Motion for More Definite Statement; granting 10 Motion to Strike Signed by Judge Anne E. Thompson on 8/26/2008. (ss, ) (Entered: 09/09/2008)

AMENDED COMPLAINT against JENNIFER VELEZ, filed by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Summons, # 9 Corporate Disclosure Statement)(COONEY, BERNARD) (Additional attachment(s) added on 9/29/2008: # 10 Complaint Signature page) (mmh) (Entered: 09/26/2008)

CLERK'S QUALITY CONTROL MESSAGE: This message is for future reference. Counsel please be advised when filing a Corporate Disclosure Statement it should be filed as a separate document and not an attachment. In the future please file using the event Corporate Disclosure Statement found under Civil - Other Filings - Other Documents. (mmh)

Application and Proposed Order for Clerk's Order to extend time to answer as to Amended Complaint.. (BEATY, MARY) (Entered: 10/10/2008)

CLERKS TEXT ORDER - The Application for a Clerks Order Extending Time to Answer - Document # 17 submitted by M. Beaty on 10/10/2008 has been GRANTED. The answer due date has been set for 10/31/2008. (ss, )

First MOTION for Extension of Time to File Answer re 16 Amended Complaint, by JENNIFER VELEZ. (Attachments: # 1 Certificate of Service, # 2 Declaration of Counsel, # 3 Statement no brief necessary, # 4 Text of Proposed Order)(BEATY, MARY) (Entered: 10/30/2008)

Set Deadlines as to 18 First MOTION for Extension of Time to File Answer re 16 Amended Complaint,. Motion set for 12/1/2008 will be decided on the papers by Magistrate Judge John J. Hughes. No appearance required unless notified by the Court. (ss, )

ORDER granting 18 Motion for Extension of Time for dft. to Answer for 30 days Signed by Magistrate Judge John J. Hughes on 12/1/2008. (ss, ) (Entered: 12/02/2008)

First MOTION to Dismiss First Amended Complaint by JENNIFER VELEZ. Responses due by 1/20/2009 (Attachments: # 1 Brief, # 2 Certificate of Service, # 3 Text of Proposed Order)(JENKINS, KIMBERLY) (Entered: 12/31/2008)

Set Deadlines as to 20 First MOTION to Dismiss First Amended Complaint. Motion set for 2/2/2009 before Judge Anne E. Thompson. The motion will be decided on the papers. No appearances required unless notified by the court. (lk)

Letter from Bernard J. Cooney. (COONEY, BERNARD) (Entered: 01/06/2009)

Re-Set Deadlines as to 20 First MOTION to Dismiss First Amended Complaint. Motion set for 2/17/2009 before Judge Anne E. Thompson. The motion will be decided on the papers. No appearances required unless notified by the court. (ss, )

Letter from Bernard J. Cooney. (COONEY, BERNARD) (Entered: 01/21/2009)

ORDER extending time for pltf. to file opposition brief to 2/16/2009 Signed by Judge Anne E. Thompson on 1/23/2009. (ss, ) (Entered: 01/28/2009)

RESPONSE in Opposition re 20 First MOTION to Dismiss First Amended Complaint filed by NEW JERSEY PROTECTION AND ADVOCACY, INC.. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit)(THOMPSON, R.) (Entered: 02/16/2009)

Letter from Kimberly E. Jenkins, DAG re 20 First MOTION to Dismiss First Amended Complaint. (JENKINS, KIMBERLY) (Entered: 02/23/2009)

Letter from Kimberly E. Jenkins, DAG re 23 Order, 20 First MOTION to Dismiss First Amended Complaint, 24 Response in Opposition to Motion,. (JENKINS, KIMBERLY) (Entered: 02/23/2009)

Letter from Bernard J. Cooney. (COONEY, BERNARD) (Entered: 02/23/2009)

ORDER extending time for dft. to file certain reply papers to 3/16/2009 Signed by Judge Anne E. Thompson on 2/27/2009. (ss, ) (Entered: 03/04/2009)

ORDER directing Mr. Cooney to submit a proposed form of notice to be sent to the Department of Justice per the 27 letter by 3/9/2009 Signed by Judge Anne E. Thompson on 3/3/2009. (ss, ) (Entered: 03/04/2009)

ORDER certifying to the Attorney General of the United States a challenge to the constitutionality of an act of Congress Signed by Judge Anne E. Thompson on 3/9/2009. (ss, ) (Entered: 03/10/2009)

REPLY BRIEF to Opposition to Motion re 20 First MOTION to Dismiss First Amended Complaint filed by JENNIFER VELEZ. (Attachments: # 1 Certificate of Service)(JENKINS, KIMBERLY) (Entered: 03/16/2009)

Letter from Kimberly E. Jenkins. (JENKINS, KIMBERLY) (Entered: 03/20/2009)

Case Reassigned to Magistrate Judge Lois H. Goodman. (jjq, )

CONSENT ORDER extending time to serve Notice of Intervention on or before 5/11/2009 Signed by Judge Anne E. Thompson on 4/8/2009. (ss, ) (Entered: 04/08/2009)

SECOND CONSENT ORDER extending time to serve and file notice of intervention Signed by Judge Anne E. Thompson on 5/11/2009. (ss, ) (Entered: 05/14/2009)

NOTICE by UNITED STATES OF AMERICA to Intervene Pursuant to 28 U.S.C. 2403(a) (Attachments: # 1 Certificate of Service)(RUYMANN, JOHN) (Entered: 05/18/2009)

BRIEF of the United States as Intervenor in Support of the Constitutionality of Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act filed by UNITED STATES OF AMERICA. (Attachments: # 1 Certificate of Service)(RUYMANN, JOHN) (Entered: 06/29/2009)

MEMORANDUM AND ORDER denying 20 Motion to Dismiss Signed by Judge Anne E. Thompson on 7/20/2009. (ss, ) (Entered: 07/23/2009)

Letter from Kimberly E. Jenkins, DAG re 16 Amended Complaint,. (JENKINS, KIMBERLY) (Entered: 07/27/2009)

LETTER ORDER that Deft's answer to the First Amended Complaint is due on 8/24/2009. Signed by Judge Anne E. Thompson on 7/28/2009. (mmh) (Entered: 07/29/2009)

First ANSWER to Amended Complaint by JENNIFER VELEZ.(HUGHES, GERARD) (Entered: 08/24/2009)

ORDER, Initial Conference set for 11/9/2009 02:00 AM before Magistrate Judge Lois H. Goodman Signed by Magistrate Judge Lois H. Goodman on 8/26/2009. (ss, ) (Entered: 08/26/2009)

Letter from Bernard J. Cooney. (Attachments: # 1 Text of Proposed Order, # 2 Text of Proposed Order)(COONEY, BERNARD) (Entered: 11/02/2009)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Initial Pretrial Conference held on 11/9/2009. (ij, )

PRETRIAL SCHEDULING ORDER: Telephone Status Conference set for 2/23/2010 09:30 AM before Magistrate Judge Lois H. Goodman. Fact Discovery due by 11/30/2010. Motions to amend/join new parties due by 9/24/2010; returnable 10/18/2010. Signed by Magistrate Judge Lois H. Goodman on 11/16/2009. (mmh) (Entered: 11/18/2009)

NOTICE of Appearance by JAMES BRADFORD MC ILVAIN on behalf of JENNIFER VELEZ (Attachments: # 1 Certificate of Service)(MC ILVAIN, JAMES) (Entered: 11/19/2009)

Letter from Bernard J. Cooney re 42 Letter. (Attachments: # 1 Affidavit, # 2 Affidavit)(COONEY, BERNARD) (Entered: 11/23/2009)

PROTECTIVE ORDER Signed by Magistrate Judge Lois H. Goodman on 12/2/2009. (ss, ) (Entered: 12/03/2009)

STIPULATION AND ORDER to amend caption Signed by Magistrate Judge Lois H. Goodman on 10/29/2009. (ss, ) (Entered: 12/03/2009)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 2/23/2010. (ij, )

LETTER ORDER directing counsel for pltf. to provide a proposal for the resolution of this matter by 3/15/2010 and scheduling a teleconference for 5/18/2010 @ 9:30am Signed by Magistrate Judge Lois H. Goodman on 2/24/10. (ss, ) (Entered: 02/24/2010)

NOTICE of Change of Address by JAMES BRADFORD MC ILVAIN (Attachments: # 1 Certificate of Service)(MC ILVAIN, JAMES) (Entered: 03/12/2010)

Letter from J. Bradford McIlvain, Esquire. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(MC ILVAIN, JAMES) (Entered: 04/12/2010)

Letter from Bernard J. Cooney. (Attachments: # 1 Exhibit)(COONEY, BERNARD) (Entered: 04/15/2010)

ATTENTION COUNSEL: The Conference Call scheduled for May 18, 2010 has been RESCHEDULED to May 20, 2010 at 9:30 a.m. Defendant's counsel to initiate the call at that time. (ij, )

Letter from J. Bradford McIlvain. (MC ILVAIN, JAMES) (Entered: 04/19/2010)

NOTICE of Appearance by NATALIE D'AMORA on behalf of JENNIFER VELEZ (D'AMORA, NATALIE) (Entered: 05/04/2010)

NOTICE of Appearance by ALISON PRICE CORBIN on behalf of DISABILITY RIGHTS NEW JERSEY, INC. (Attachments: # 1 Certificate of Service)(CORBIN, ALISON) (Entered: 05/14/2010)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 5/20/2010. (ij, )

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 5/27/2010. (ij, )

ORDER confirming matters discussed during teleconference 5/20/2010 and setting scheduling conference for 9/3/2010 @ 11:30am Signed by Magistrate Judge Lois H. Goodman on 6/7/2010. (ss, ) (Entered: 06/08/2010)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 9/3/2010. (ij, )

SCHEDULING ORDER: Telephone Conference set for 1/13/2011 09:30 AM before Magistrate Judge Lois H. Goodman. Discovery due by 12/31/2010. Motions due by 5/27/2010. Signed by Magistrate Judge Lois H. Goodman on 9/22/2010. (ss, ) (Entered: 09/22/2010)

NOTICE of Appearance by AMIT SONDHI on behalf of DISABILITY RIGHTS NEW JERSEY, INC. (Attachments: # 1 Certificate of Service)(SONDHI, AMIT) (Entered: 10/18/2010)

ATTENTION COUNSEL: Conference Call set for December 6, 2010 at 2:30 p.m. with Magistrate Judge Lois H. Goodman. Plaintiff's counsel to initiate the call at that time. (ij, )

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 12/6/2010. (ij, )

STIPULATION REGARDING DISCOVERY by JENNIFER VELEZ. (MC ILVAIN, JAMES) (Entered: 12/14/2010)

ATTENTION COUNSEL: The Telephone Conference scheduled for January 13, 2011 at 9:30 a.m. with Magistrate Judge Lois H. Goodman has been RESCHEDULED to take place at 10:30 a.m. (ij, )

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 1/13/2011. (ij, )

ORDER setting certain discovery deadlines. Telephone Scheduling Conference set for 3/25/2011 02:00 PM Magistrate Judge Lois H. Goodman. Fact Discovery due by 2/25/2011. Dispositive Motions due by 8/12/2011. Signed by Magistrate Judge Lois H. Goodman on 1/25/2011. (mmh) (Entered: 01/26/2011)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 3/25/2011. (ij, )

STIPULATION re 58 Stipulation by DISABILITY RIGHTS NEW JERSEY, INC.. (COONEY, BERNARD) (Entered: 03/28/2011)

TEXT ORDER setting a Telephone Conference for May 18, 2011 at 9:30 a.m. with Magistrate Judge Lois H. Goodman. Plaintiff's counsel to initiate the call at that time. Ordered by Magistrate Judge Lois H. Goodman on 3/29/11. (ij, ) (Entered: 03/29/2011)

LETTER ORDER granting Counsel's request for certain deadlines to be extended; however the 5/18/2011 Telephone Conference is to take place as planned; Dispositive Motions due by 9/30/2011. Signed by Magistrate Judge Lois H. Goodman on 4/12/2011. (eaj) Modified on 4/13/2011 (ij). (Entered: 04/12/2011)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 5/18/2011. (ij, )

AMENDED SCHEDULING ORDER: Telephone Status Conference set for 6/21/2011 at 02:30 PM before Magistrate Judge Lois H. Goodman, Defendant is to initiate the call; Dispositive Motions due by 10/18/2011. Signed by Magistrate Judge Lois H. Goodman on 5/24/2011. (eaj) (Entered: 05/25/2011)

ATTENTION COUNSEL: The Telephone Conference scheduled for June 21, 2011 has been RESCHEDULED to June 20, 2011 at 12:30 p.m. with Magistrate Judge Lois H. Goodman. (ij, )

Substitution of Attorney - Attorney NATALIE D'AMORA and JAMES BRADFORD MC ILVAIN terminated. Attorney LANCE J. KALIK for JENNIFER VELEZ added.. (KALIK, LANCE) (Entered: 06/17/2011)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 6/20/2011. (ij, )

LETTER ORDER: Resetting certain Scheduling Order deadlines; Telephone Status Conference set for 9/13/2011 09:30 AM before Magistrate Judge Lois H. Goodman. Dispositive Motions due by 11/23/2011. Signed by Magistrate Judge Lois H. Goodman on 6/30/2011. (mmh) (Entered: 06/30/2011)

AMENDED SCHEDULING ORDER:Dispositive Motions due by 11/23/2011, shall be returnable 1/17/2012. Signed by Magistrate Judge Lois H. Goodman on 8/19/2011. (eaj) (Entered: 08/22/2011)

Text Minute Entry for proceedings held before Magistrate Judge Lois H. Goodman: Telephone Conference held on 9/13/2011. (ij, )

ORDER granting Plaintiffs request to extend the briefing schedule for dispositive motions as follows: Dispositive Motions due 12/21/2011; Opposition due 1/23/2012; reply in further support due 2/26/2012; made returnable 2/21/2012. Signed by Magistrate Judge Lois H. Goodman on 11/9/2011. (eaj) (Entered: 11/09/2011)

LETTER ORDER that Dispositive Motions shall be filed by 1/13/2012; Opposition 2/3/2012; Reply to Opposition 2/17/2012; Motions returnable 2/21/2012. Signed by Magistrate Judge Lois H. Goodman on 12/20/2011. (eaj) Modified on 12/21/2011 (eaj, ). (Entered: 12/20/2011)

LETTER ORDER that Dispositive Motions are due by 1/27/2012; Opposition due by 2/17/2012 and Reply due by 3/2/2012. Signed by Magistrate Judge Lois H. Goodman on 1/13/2012. (mmh) (Entered: 01/13/2012)

LETTER ORDER extending the deadline to file dispositive motions until 2/10/2012, returnable 3/5/2012; Counsel are to report by joint submission on the status by 2/7/2012. Signed by Magistrate Judge Lois H. Goodman on 1/25/2012. (eaj) (Entered: 01/25/2012)

LETTER ORDER granting counsel a 2 week extension to file summary judgment motions; Initial Briefs are due 2/24/2012, Opposition due 3/9/2012, Reply Briefs due 3/26/2012, Returnable 4/2/2012; Counsel are to report on the status by no later than 2/17/2012. Signed by Magistrate Judge Lois H. Goodman on 2/8/2012. (eaj) (Entered: 02/08/2012)

Letter from Lance Kalik. (KALIK, LANCE) (Entered: 02/17/2012)

LETTER ORDER that the request for a stay is granted; that the parties are to update the Court by 3/30/2012 regarding status of the settlement. Signed by Magistrate Judge Lois H. Goodman on 2/23/2012. (gxh) (Entered: 02/23/2012)

Letter from Lance J. Kalik. (KALIK, LANCE) (Entered: 03/30/2012)

LETTER ORDER granting counsel's request for an additional 30-day stay of the deadlines. Signed by Magistrate Judge Tonianne J. Bongiovanni on 4/2/2012. (gxh) (Entered: 04/02/2012)

CLERK'S QUALITY CONTROL MESSAGE - This message is in reference to the 75 LETTER ORDER filed on 4/2/2012. Please be advised that although Civil Action No. 08-1858 is referenced on the Letter Order, this Letter Order was intended for Civil Action 05-4723 only. Please disregard this filing. (gxh)